ID: nht91-6.28

DATE: October 17, 1991

FROM: Carl Miller -- O.E. Sales Manager, DICO Tire, Inc.

TO: Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 11-15-91 from Paul Jackson Rice to Carl Miller (A38; Part 574)

TEXT:

This is a request for an interpretation of a regulation.

At DICO Tire, we manufacture high speed boat trailer tires. Presently we provide a warranty along with a recall information card to the original equipment manufacturers to be issued to the customer at the time of purchase. We also provide warranty and recall information cards to dealers for the replacement males market. It has been my understanding that we were to provide recall information cards on any tire with a D.O.T. stamp on it whether it was sold in the original equipment market or sold in the replacement market. A comment was made that there was a new ruling which stated the recall information cards were no longer required in the replacement market.

Could you please clarify this point?

ID: nht91-6.29

DATE: October 17, 1991

FROM: Matthew J. Plache -- Gardner, Carton & Douglas

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: John Rigby Esq.

TITLE: None

ATTACHMT: Attached to letter dated 12-3-91 from Paul Jackson Rice to Matthew J. Plache (A38; VSA 102(3); VSA 108(a)(1)(A))

TEXT:

I am writing to request an interpretation of whether Daihatsu America, Inc. would be in violation of federal law, including specifically section 1397(a) (1) of the National Traffic and Motor Vehicle Safety Act ("NTMVSA"), 15 U.S.C. S1397 (a) (1), if it were to sell Daihatsu HIJET vehicles in accordance with specifications such as those contained in the Request for Bid issued by the City of Los Angeles Department of General Services on September 9, 1991 (Bid Number F5995), a copy of which is attached hereto.

BACKGROUND

Daihatsu America, Inc. ("Daihatsu") is the exclusive distributor of of Daihatsu HIJET vehicles ("HIJET") in the United States. HIJETs are manufactured in Japan by Daihatsu Motor" Co. Ltd.

HIJETs are general purpose off-road utility vehicles. They are not intended for use on the public roads, streets or highways. As such, HIJETs do not comply with certain of the federal motor vehicle safety standards applicable to "motor vehicles" under the NTMVSA.

HIJETs are powered by a 550cc gasoline-powered engine and are unable, as manufactured for the United States market and as sold in the United States, to exceed a speed of 25 mph. Since HIJETs are not intended for on-road use, they are not affixed with a certification of conformity, as described in S1403 of the NTMVSA, 15 U.S.C. S1403. HIJETs were first marketed and sold in the United States in 1977. Since that time, they have always been advertised, promoted and sold as off-road vehicles. They are affixed with a warning label indicating that they are for off-road use only. HIJETs are sold by dealers that do not also sell vehicles that are classified as "motor vehicles" under the NTMVSA.

THE LOS ANGELES BID REQUEST

The attached bid request solicits bids for vehicles being purchased for use by the Recreation and Parks Equipment Division of the City of Los Angeles. The bid request describes the vehicles being solicited as the "Daihatsu full cab 'HIJET' without glass," the "Mitsubishi flow thru SH27F 1/," or equivalent vehicle. The specifications included with the bid request are almost an exact description of the Daihatsu HIJET. See last two pages of the attachment hereto.

Two aspects of the specifications are troublesome to Daihatsu. First, they require that the "vehicle must be capable of being registered for street use in California." In essence, this language, which appears in the third sentence of the first paragraph of the specifications, indicates that the vehicles being solicited are for use on the public roads, streets and highways. In other words, the solicitation is for vehicles that would be classified as "motor vehicles" under the NTMVSA.

The second troublesome aspect of the specifications is the requirement, set forth in the last paragraph thereof, that the contractor must apply to register the vehicles and obtain for them "Exempt Special Equipment 'SE' license plates." This is a special type of California license plate used on government-owned vehicles. Most importantly, "SE" license plates are established for use with "on-road" vehicles; they are not generally available for exclusively off-road vehicles. Once again, this requirement

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1/ The Mitsubishi vehicle is similar in design to the Daihatsu HIJET. In October, 1988, NHTSA's Chief Counsel issued an interpretive ruling in connection with the Mitsubishi vehicle, concluding that "the Mitsubishi SH27 lightweight truck does not appear to be a motor vehicle under the Safety Act." Letter from Erika Z. Jones, Chief Counsel, NHTSA to Mr. Hiroshi Kato, MMC Services, Inc., page 3 (October 31, 1988).

indicates that the solicitation is for vehicles that would be classified as "motor vehicles" under the NTMVSA.

Daihatsu is not certain that it could comply with these two aspects of the solicitation without running afoul of federal law, including certain strictures set forth in the NTMVSA. As stated above, HIJETs do not conform to all of the federal safety standards applicable to motor vehicles, nor are they affixed with a certificate of conformity as described in 15 U.S.C. S1403. Thus, Daihatsu is concerned that if it were to deliver HIJET vehicles, or even to offer to deliver such vehicles, in accordance with these specifications, it might violate certain of the prohibitions set forth in section 1397 (a) (1) of the NTMVSA, 15 U.S.C. S1397 (a)(1).

REQUEST FOR INTERPRETIVE LETTER

As noted above, I am seeking an interpretive ruling indicating whether Daihatsu would violate federal law if it were to deliver, or offer to deliver, HIJET vehicles in accordance with specifications such as those contained in the Los Angeles bid request. Daihatsu is especially concerned about this matter because it has recently received a number of similar solicitations for "HIJET-like" vehicles which, although not as problematic as the Los Angeles bid request, could be interpreted as solicitations for "on-road" vehicles.

Please note that because of its concerns about potential violations of federal law, Daihatsu has refrained from submitting a bid in accordance

with the Los Angeles specifications. Other suppliers of similar vehicles, however, apparently do not share Daihatsu's concerns.2/ Thus, until the issues raised in this letter are resolved, Daihatsu will be at a competitive disadvantage in similar bidding situations.

For these reasons, I request that you expedite your response to this letter. Please note that I recently spoke about this

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2/ Indeed, the Los Angeles contract was recently awarded to a supplier of the Mitsubishi vehicle. As noted in footnote 1, above, this vehicle is the subject of a NHTSA exemption letter. As with the HIJET, the Mitsubishi vehicle also fails to comply with certain of the Federal safety standards applicable to "on-road" vehicles.

matter with John Rigby of your office; he suggested I submit a request in writing for an interpretive ruling.

Please let me know if you require any further information.

ID: nht91-6.3

DATE: September 18, 1991

FROM: Al Lipinski -- President, Mini-Max

TO: Hall, Jackson, Rice -- NATSA (NHTSA), Chief Counsel

TITLE: None

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to Al Lipinski (A38; Std. 108; Part 567)

TEXT:

I talked with Steve Kratzke on September 18, 1991 regarding the Dynamic Testing requirements for alterers of certified vehicles.

We are a small conversion company of walk in van type light trucks located in Escanaba, MI. Our projected production for 1992 is 75 vehicles. We do not alter anything forward of the B pillar of a certified vehicle, thus the crash protection system installed by the original manufacturer is not disturbed. We afix an additional label stating the vehicle alterations conform to all applicable FMVSS.

I would appreciate a letter stating what the dynamic testing requirements are for an alterer of a certified vehicle for my files in case this question arises in the future.

ID: nht91-6.30

DATE: October 21, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Robert A. Adams -- Vice President, Solar Car Corporation

TITLE: None

ATTACHMT: Attached to letter dated 9-12-91 from Robert A. Adams to NHTSA Administrator

TEXT:

This responds to the petition by Solar Car Corporation dated September 12, 1991, for a temporary exemption from the Federal motor vehicle safety standards. The basis of the petition is "low-emission engine features."

According to the petition, Solar Car "retrofits" Ford Festivas, Dodge Colts, and Chevrolet S 10 pickup trucks to electric and solar electric configuration. We understand this to mean that Solar Car converts new, previously untitled vehicles, rather than that it converts vehicles that are brought to it by their owners. If the latter is the situation, a temporary exemption is unavailable for these vehicles, as our authority to provide exemptions does not cover vehicles that have been in use.

The petition requests a blanket exemption from compliance with the Federal motor vehicle safety standards. If such a petition is to be submitted, it must follow the format specified by the exemption regulation, 49 CFR 555.6(c), providing information with respect to each standard as to how an exempted vehicle would differ from a conforming one, and why an exemption from that standard would not unduly degrade motor vehicle safety. This information is completely lacking from the Solar Car petition. As you might imagine, NHTSA does not encourage petitions that request exemption from all applicable Federal motor vehicle safety standards, and, in point of fact, has never considered such a petition. Furthermore, in the case of Solar Car, such a comprehensive petition does not appear necessary for it to pursue its business plan.

The base car or truck converted by Solar Car will already have been certified by its manufacturer as complying with all applicable Federal motor vehicle safety standards (which are found at 49 CFR Part 571).

What Solar Car must do is to determine which of those standards may be affected by its conversion operations, and then determine the extent of any noncompliance that may be created. With the thought that it may assist you, I enclose a copy of a Federal Register notice that discusses the petition of another vehicle converter, and the standards which appeared to be affected by its conversion operations. Although the notice was published in 1975, our requirements have not changed since that time.

We shall be pleased to consider this matter further when we have received a petition that meets the procedural requirements of Part 555. If you have any questions, Taylor Vinson of my staff is available to answer them (202-366-5263).

Enclosure

Copy of the Federal Register, Volume 40, No. 120 (6/20/75) titled Electric Fuel Propulsion Corporation; Petition for Temporary Exemption From Federal Motor Vehicle Safety Standards (Text omitted)

ID: nht91-6.31

DATE: October 21, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Frank Kenney -- Sporting Tailors Manufacturing Co.

TITLE: None

ATTACHMT: Attached to letter dated 6-29-90 from Paul Jackson Rice to Ed McCarron (Std. 302); Also attached to copy of 49 CFR 571.302, pages 517-519, Flammability of interior materials; Also attached to letter dated 8-12-91 from Frank Kenney to NHTSA Office of the Chief Counsel (OCC 6356)

TEXT:

This responds to your letter concerning the applicability of Federal motor vehicle safety standard No. 302, Flammability of Interior Materials, (49 CFR 571.302, copy enclosed) to your product, a roll bar top or "Bikini Top" for use on vehicles such as Jeep Wranglers. You explained that the material would consist of three layers: a vinyl top layer, a flame retardant middle layer, and a brushed nylon tricot black backing as the lower layer. In addition, a binding fabric strip would be sewn around the edges of the roll bar top to lend stability and a finished appearance. You also explained that you may supply a tote bag in which the bikini top could be stored. Your questions are addressed below.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has no authority to certify or approve motor vehicles or items of motor vehicle equipment for compliance with the Federal motor vehicle safety standards. Instead, the National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 et seq.) establishes a "self-certification" process under which each manufacturer is responsible for certifying that each of its products complies with all applicable safety standards. This agency periodically tests vehicles and items of motor vehicle equipment for compliance with the safety standards, and also investigates alleged defects related to motor vehicle safety.

The Safety Act also gives this agency authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. The agency has exercised this authority to establish Standard No. 302. That standard sets forth flammability resistance requirements applicable to all new motor vehicles.

If your bikini top is added to a new vehicle, i.e., before the vehicle is sold for the first time to a consumer, then it must comply with Standard No. 302. That standard applies to certain vehicle occupant compartment components, including convertible tops, on new motor vehicles. Your bikini top would be considered a convertible top. Persons selling new vehicles equipped with your convertible top would need to ensure that the vehicles, including your top, conform to Standard No. 302.

Standard No. 302 does not directly apply to aftermarket items of motor vehicle equipment, i.e., accessories or additions to motor vehicles sold to owners of used vehicles. Nevertheless, section 108(a)(2)(A) of the Safety Act could affect the use of a product such as yours sold in the

aftermarket. That section prohibits manufacturers, distributors, dealers, or repair shops from knowingly "rendering inoperative" devices or elements of design that were installed in a motor vehicle to comply with the Federal motor vehicle safety standards. NHTSA does not consider it to be a violation of the "render inoperative" prohibition when a dealer adds a convertible top which enables a vehicle to continue to meet Standard No. 302 and the other safety standards.

The prohibitions of section 108(a)(2)(A) do not apply to the actions of a vehicle owner in adding to or otherwise modifying his or her vehicle. Thus, a vehicle owner would not violate the Safety Act by installing your bikini top, even if doing so would negatively affect the safety features of his or her vehicle.

You should be aware that, as the manufacturer of an aftermarket item of motor vehicle equipment, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall and remedy of products with defects relating to motor vehicle safety. In the event that you or NHTSA determines that your product contains a safety related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. I note that, whether or not Standard No. 302 applies to your convertible top, the product's flammability characteristics could be relevant to whether it contained a safety related defect.

I will now address you specific questions about Standard No. 302, on the assumption that the standard applies to your product. After explaining your belief that the main part of the material complies with Standard No. 302, you asked whether the binding fabric strip sewn all around the edges of the roll would also have to be made flame retardant. As explained below, the binding fabric strip would have to comply with Standard No. 302.

Under sections S4.1 and S4.2, any portion of a convertible top which is within 1/2 inch of the occupant compartment air space must meet the standard's flammability requirements. It is our opinion that the binding fabric strip sewn around the edges of your convertible top would be part of the convertible top and thus subject to this provision. I note that it is the agency's longstanding interpretation that a component "incorporated into" a component that is listed in section S4.1 of Standard No. 302 is subject to the standard. A June 29, 1990 interpretation to Mr. Ed McCarron (copy enclosed) explains this policy in the context of a mattress. In particular, that interpretation addressed whether a fabric "corner reinforcement" that is stitched on the outside of the mattress cover was subject to Standard No. 302. In answering in the affirmative, the interpretation explained that the corner reinforcement is incorporated into the mattress cover through the stitching process. By analogy, your "stitched binding strip" would be incorporated into your convertible top and thus subject to Standard No. 302.

The interpretation letter to Mr. McCarron further explained the testing procedures related to composite materials. Any components that do not

adhere to other materials at every point of contact would be tested separately under S4.2.1. Any components that adhere to other material at every point of contact would be tested as a composite with the other material.

The sample enclosed with your letter indicates that the binding fabric strip does not adhere to the main part of the bikini top at every point of contact. Instead, the binding strip is folded over the edge of the main part of the bikini top and held in place by single stitching. Therefore, it would be tested separately from the main part of the bikini top.

You also asked whether a tote bag used to store the roll bar top would be required to comply with Standard No. 302. The answer to that question is no. The list of components subject to Standard No. 302 set forth in S4.1 does not include a tote bag or similar item.

Finally, you stated that you understand that you must conform to 49 CFR Part 566, Manufacturer Identification, and asked whether there would be anything else that would apply to your product. No NHTSA requirements other than those discussed above would apply to your product.

I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Enclosure

Letter dated 6-29-90 from Paul Jackson Rice to Ed McCarron of Western Star Trucks Inc. (Text omitted)

Enclosure

Copy of 49 CFR 571.302: Standard No. 302, Flammability of Interior Materials (Text omitted)

ID: nht91-6.32

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Earl H. Kester -- President, Seatco

TITLE: None

ATTACHMT: Attached to letter dated 9-19-91 from Earl H. Kester to Paul Jackson Rice

TEXT:

This responds to your letter concerning requirements that apply to retail establishments that sell and install replacement seats on used vans and pickup trucks. You noted that a vehicle's seats affect its compliance with Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, and asked whether businesses which sell and install replacement seats are required by Federal law to use ones that enable the vehicle to continue to comply with that standard. As discussed below, the answer to our question is yes.

The National Traffic and Motor Vehicle Safety Act specifies that vehicles must conform with all applicable safety standards up until the first purchase for purposes other than resale. After the first purchase, the vehicle is no longer required by Federal law to conform with all safety standards. However, section 108(a)(2)(A) of the Safety Act provides as follows:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .

In order to avoid violating this provision, a manufacturer, dealer, distributor, or repair business which removes and replaces a seat must use a replacement seat which enables the vehicle to continue to comply with Standard No. 208 and other safety standards for which the original seat was designed to ensure compliance. I note that the "render inoperative" provision does not require a company to test a vehicle after installation of a new seat to ensure that it continues to comply with all applicable standards. However, if an analysis of the replacement seat, as installed, indicates that the resulting vehicle would no longer comply with the requirements of Standard No. 208 and other relevant safety standards, the company could not legally perform such an installation.

I hope this information is helpful.

ID: nht91-6.33

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: David L. Kulp -- Manager, Fuel Economy Planning & Compliance, Environmental and Safety Engineering Staff, Ford Motor Company

TITLE: None

ATTACHMT: Attached to letter dated 8-9-91 from David L. Kulp to Orron E. Kee (OCC 6441)

TEXT:

This responds to your letter to Mr. Orron Kee of this agency that asked whether, to comply with Corporate Average Fuel Economy (CAFE) reporting requirements, Ford must report off-highway data as listed, in 49 CFR S537.7(c)(5) for light trucks that otherwise come within the definition of light trucks at 49 CFR S523.5(a). As discussed below, the answer to your question is no.

Under S523.5, a light truck is an automobile other than a passenger automobile which is either designed to perform at least one of a number of functions listed in S523.5(a) or is designed for off-highway operation as described in S523.5(b). Since the characteristics described in (a) and (b) are not mutually exclusive, some vehicles are considered light trucks under both (a) and (b).

Section 537.7(c) (5) provides that for each model type of an automobile which is classified as an automobile capable of off-highway operation under Part 523, i.e., S523.5(b), certain data relevant to that classification must be included in a manufacturer's fuel economy reports. Your letter raises the issue of whether this information must be reported for vehicles which are considered light trucks under S523.5(a) but which would also be considered light trucks under S523.5(b). It is our opinion that S537.7(c)(5)'s requirement to report data relevant to the classification of a vehicle as capable of off-highway operation applies only for vehicles which are considered light trucks solely on that basis and not to vehicles that are otherwise considered light trucks under S523.5(a).

ID: nht91-6.34

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Martin L. Marinoff

TITLE: None

ATTACHMT: Attached to letter dated 7-30-91 from Martin L. Marinoff to NHTSA (OCC 6511)

TEXT:

This responds to your letter asking about Federal Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems. You stated that you believe the standard requires vehicles to have a warning light system that indicates loss of pressure or low fluid level in the braking system and asked if this belief is correct.

Your understanding about Standard No. 105 is correct. I have enclosed a copy of that standard for your information. The requirements for brake system indicator lamps are set forth at section S5.3 of the standard.

ID: nht91-6.35

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Phil Lanam -- City of Ukiah Fire Department

TITLE: None

ATTACHMT: Attached to letter dated 8-19-91 from Phil Lanam to Taylor Vinson (OCC 6412); Also attached to letter dated 3-4-80 from Frank Berndt to Joe Cain

TEXT:

This responds to your letter about the installation of new standard "S" cam air brakes on a 1978 Ford truck. You explained that because you were having problems with the vehicle's anti-skid system, you were planning to replace it with a new braking system. As discussed below, Federal law does not prohibit you or a commercial business from replacing the anti-skid system with a standard current brake system.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Highway Traffic and Motor Vehicle-Safety Act (Safety Act), it is the responsibility of the manufacturer to ensure that its motor vehicles or items of equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter.

The agency has issued Federal motor vehicle safety standard (FMVSS) No. 121, Air Brake Systems. That standard applies to almost all new trucks, buses, and trailers equipped with air brake systems.

As originally manufactured, Ford, as the manufacturer was required to certify that the truck satisfied the requirements of all applicable safety standards. Among other things, the vehicle's brakes would have been required to comply with FMVSS No. 121.

The National Traffic and Motor Vehicle Safety Act specifies that vehicles must conform with all applicable safety standards up until the first purchase for purposes other than resale. After the first purchase, the vehicle is no longer required by Federal law to conform with all safety standards. However, the Safety Act includes a provision that prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from "rendering inoperative" any device or element of design installed in or on a vehicle in compliance with an applicable safety standard. The render inoperative provision does not apply to modifications made by the owner of a vehicle.

The issue of whether a late 1970's antilock system for heavy vehicles can be disconnected by a commercial business is a special case under the render inoperative provision, since those antilock systems were used by some manufacturers to comply with certain requirements of FMVSS No. 121 that were later invalidated by a court decision. I have enclosed a copy

of a March 4, 1980 letter which addresses that issue. Based on this letter, a commercial business could replace the anti-skid system with a standard current brake system without violating the render inoperative provision.

I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht91-6.36

DATE: October 23, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Al Lipinski -- President, Mini-Max

TITLE: None

ATTACHMT: Attached to letter dated 9-18-91 from Al Lipinski to Messrs. Hall, Jackson, and Rice, NHTSA (OCC 6509)

TEXT:

This responds to your letter asking what the dynamic testing requirements are for alterers of certified vehicles. You stated that you are a small conversion company of walk in van type light trucks, that you do not alter anything forward of the B pillar of the previously certified vehicle, and that the crash protection system installed by the original manufacturer is not disturbed. You also stated that you affix an additional label stating the vehicle alterations conform to all applicable Federal motor vehicle safety standards.

I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. As you are aware, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 et seq.; Safety Act), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Under NHTSA's certification regulation, an alterer is a person who alters previously certified vehicles by means other than the addition, substitution, or removal of readily attachable components, or minor finishing operations, or in such a manner that the vehicle's stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale. An alterer is required to certify that every vehicle it alters continues to comply with all applicable safety standards after the alterer has performed its operations on the vehicle. See 49 CFR Part 567.7.

Alterers must have some independent basis for their certification that an altered vehicle continues to comply with all applicable safety standards. This does not, however, mean that an alterer must conduct crash testing, even with respect to standards that include dynamic test requirements. Certifications of continuing compliance for altered vehicles may be based on, among other things, engineering analyses, computer simulations, actual testing, or instructions for alteration voluntarily provided by the original vehicle manufacturer in a "body builder's guide."

Your letter suggests that you are primarily concerned about the dynamic test requirements of Standard No. 208 Occupant Crash Protection. I note that in establishing that standard's dynamic test requirements for light trucks, NHTSA made those requirements optional for walk in van type trucks. See S4.2.2 of Standard No. 208. Thus, the walk in van type

trucks you alter were not required to comply with the Standard No. 208's dynamic test requirements and may not have been designed to do so. You can find out by contacting the original vehicle manufacturer.

I hope this information is helpful.