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Interpretation ID: nht92-5.11

DATE: July 24, 1992

FROM: Tim Flagstad

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/12/92 from Paul J. Rice to Tim Flagstad (A39; Part 591; Std. 115; VSA 1392)d))

TEXT:

I am writing in regards to your letter dated July 20, 1992. In your letter you reffer to Joan Moniz stating that "the truck bears no certification label". I can not say if the 1981 Kenworth VIN. #M911042 has a certification label on it now that it is in Hawaii. I do know that the truck had one when it came through Customs and when we had posession of the truck here in Calif.

To title the truck in California we had to supply Calif. DMV with a 'Verification of Vehicle Certificate'. We had a licensed Vin Verifier verify the Vin number along with the Federal Certification Label. We were given a signed DMV Verification of Vehicle Form attesting to the VIN # and it's location and to the presence of a Federal Certification Label and that it agrees with the VIN. number. This was submitted to the Calif. DMV along with the other title documents.

I also have several photos that were sent to me of the truck when it was in Canada by the Dealer I bought the truck from. One shows the cab with the driver's door open and the certification label is visible on the door edge.

I can attest to having seen the label myself when the truck was here. I have spoken to the Dealer I bought the truck from and he says he inspected the truck personally before it went to Customs and that the label was definitly on the truck.

I have spoken to the Kenworth Truck Co. and was told that if the Certification Label is missing a factory replacement would be available if the truck is brought to the local Kenworth Dealership for inspection and affixing the label.

As the Certification Label was on the truck at the time it came through Customs, how would this affect the entry status of this vehicle? Would you please clarify this for me?

Could you please fax me your written response to this letter to (619) 477-6249 and mail the original to: Tim Flagstad, 220 W. 14th St. National City, Ca. 91950.