Interpretation ID: nht72-6.7

DATE: 09/19/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gorou Utsunomiya

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 8, 1972, enclosing sketches of motor vehicles and asking into which vehicle category under the motor vehicle safety standards they fall. The numbered paragraphs below correspond to those in your letter.

1. Figures 1, 2, and 3 illustrate trailers under the standards. Trailers are presently subject only to Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment." Trailers equipped with air brakes and manufactured after September 1, 1974, will be required to conform to Standard No. 121, "Air Brake Systems." It is unlikely that many camping or recreational trailers will be subject to these requirements.

2. Figure 4 illustrates two pickup trucks equipped with slide-in campers. Pickup trucks must conform to all standards applicable to trucks. The campers must conform, as you state, to Motor Vehicle Safety Standard No. 205, "Glazing Materials." Both pickup trucks and slide-in campers will be required to conform to a new Standard No. 126, "Truck-Camper Loading," when that standard becomes effective. A copy of the standard is enclosed.

3. In referring to the illustrations of the pickup trucks equipped with slide-in campers, you ask whether the requirements applicable to the trucks when combined with a camper are different from those applicable when the truck is not so equipped. The answer is no. The standards applicable to pickup trucks (those that are applicable to "trucks") are the same whether or not the pickup is equipped with a camper.

4. The requirements for pickup trucks and slide-in campers do not differ if both components are manufactured by the same company.

5. Wagon campers and motor homes are considered to be multipurpose passenger vehicles when constructed on truck chassis. The illustrations you enclose appear to us to represent vehicles manufactured on truck chassis.