Interpretation ID: nht76-3.25

DATE: 08/19/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Modular Ambulance Corp.

TITLE: FMVSR INTERPETATION

TEXT: We have received your letter of July 26, 1976, petitioning for a temporary exemption from Motor Vehicle Safety Standard No. 301-75. When you forward the financial statements promised we shall prepare a notice for the Federal Register.

I would like to comment on two aspects of your petition. The first is that in our opinion, each manufacturer supplying you with a chassis is an "incomplete vehicle" manufacturer as defined by 49 CFR Part 568, and should be able to provide you with sufficient information, in the incomplete vehicle document accompanying each chassis, to enable you to insure that your ambulances upon completion conform with Standard No. 301-75. I enclose a copy of a recent letter that we sent General Motors expressing our views on this subject. Since your problem is basically similar, as part of your good faith efforts to meet Standard No. 301-75 you should attempt to obtain compliance information from your chassis manufacturers as soon as you can. We would like to be informed if you are unable to obtain this information.

My second comment is that your petition presents the "worst case" approach, based upon the presumed necessity to crash test each of the 11 models you manufacture. As a matter of clarification, there is no legal requirement that a manufacturer conduct a barrier test before he certifies compliance with Standard No. 301-75. He must, however, have a reasonable basis for certification that the vehicle, if barrier tested, would meet Standard No. 301-75. Many manufacturers prefer the assurance that is provided by testing according to a standard's procedure. However, engineering calculations, computer simulations, etc., can often provide a reasonable basis for certification. You may wish to reevaluate your petition's cost estimates in light of this.