Interpretation ID: 1982-2.27

DATE: 08/01/82 EST

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Hon. Bob McEwen - H.O.R.

TITLE: FMVSR INTERPRETATION

TEXT:

This responds to your July 8, 1982, letter to Mr. William Dabaghi of the Department enclosing correspondence from your constituent Mr. Donald M. Robinson. Mr. Robinson would like to know whether Federal regulations prohibit him from purchasing a pickup cab and chassis without the body attached. The answer to his question is no.

The National Highway Traffic Safety Administration only requires that all vehicles be manufactured in compliance with the applicable motor vehicle safety standards. We have no requirement, nor do we know of any other Federal regulation, that would prevent Mr. Robinson from purchasing just the cab and chassis of a vehicle that he desires. When he adds his own utility body to the cab and chassis, he would become the final-stage vehicle manufacturer and would be required to certify that the completed vehicle complies with all applicable Federal safety standards. I am enclosing copies of the regulations pertinent to such an operation.

If I can be of further assistance to you or Mr. Robinson, please contact me.

Sincerely,

Administrator

Enclosures: Constituent's Correspondence 49 CFR Parts 567 & 568

Mr. William K. Dabaghi Director of Congressional Affairs U.S. Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Dabaghi:

The enclosed correspondence regarding regulations governing truck equipment sales was sent to me by Mr. Donald M. Robinson, Manager, Buckeye Rural Electric Cooperative, Inc., P.O. Box 279, Gallipolis, Ohio 45631.

If you could assist me in replying to this inquiry by asking someone on your staff to investigate the matter and provide to me the appropriate information, I would be most grateful.

Again Mr. Dabaghi, thank you for your cooperation in this matter. If I may provide any additional information necessary to you, please do not hesitate to call upon me.

With personal regards,

Sincerely,

Bob McEwen Member of Congress

BM:ly Enclosure

June 23, 1982

Congressman Robert McEwen 124 Joy Avenue Hillsboro, Ohio 45133

We have asked truck dealers in the area for bids on two one-half ton cab and chassis and one three-quarter ton cab and chassis trucks upon which we intended to install utility beds so that the trucks would be equipped properly to be used as service trucks on our distribution system.

We have been told by the dealers that they cannot order just the cab and chassis but have to include the pickup bed for which we have absolutely no use. This is our first knowledge of this and, quite frankly, it shocks me.

We are told that this is a federal law, regulation or whatever.

Could you check into this matter at your convenience to see if there is any recourse?

We will appreciate whatever you can do.

Yours truly,

Donald M. Robinson, Manager

DMR/mb