Interpretation ID: FREIGHTLINER.CRS

Mr. Bob Johnson
Senior Compliance Analyst
Freightliner LLC
4747 N Channel
Portland, OR 97208-3849

Dear Mr. Johnson:

This responds to your letter of April 16, 2001, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on the new Freightliner Sprinter vehicle.

NHTSA's regulations at 49 CFR 567.4(c) prescribe specific locations for the installation of vehicle certification labels, and provide that if none of those locations are practicable, the manufacturer may suggest an alternate location for the agency's approval. Your letter states that DaimlerChrysler engineers in Germany attempted to position the label in one of the locations specified in section 567.4, but were not successful owing to the size of the label, the lack of available space to accommodate the label at some of those locations, and the presence of removable padding on the surface at other of those locations.

The alternate location for which you have requested approval is below the driver's seat on an outward facing portion of the mounting pillar. You state that the pillar is a permanent part of the vehicle's floor structure, and that at this location, the label can be easily read and is well protected from weathering and abrasion.

In specifying locations for the placement of vehicle certification labels, NHTSA's objective is to ensure that those labels may be easily read. The location that you have proposed for the new Freightliner Sprinter would meet this objective. NHTSA therefore approves your request.

If you have any further questions regarding vehicle certification requirements, feel free to contact Coleman Sachs of my staff at 202-366-5238.

Sincerely,

John Womack
Acting Chief Counsel

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