Interpretation ID: aiam2488
Executive Vice President
Meyer Products
Inc.
18513 Euclid Avenue
Cleveland
OH 44112;
Dear Mr. Henry: This is in response to your November 16, 1976, letter concerning th removal of snow plow assemblies prior to testing motor vehicles for conformity to Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity*.; You have pointed out that a snow plow assembly includes component other than the part that actually contacts and moves the snow. You have requested confirmation of your interpretation that 'no part of the snow plow assembly, including the mounting components, was to be attached to a vehicle for purposes of [compliance testing] ...'; That interpretation is incorrect. The presence or absence of snow plo components on a vehicle during compliance testing depends on whether the components are included in the vehicle's 'unloaded vehicle weight'. As the July 16, 1976, letter from Mr. Robert Carter of this agency to the Jeep Corporation indicates, unloaded vehicle weight includes the weight of accessories that are not ordinarily removed from the vehicle when they are not in use. The statement in that letter that 'snow plows' would be removed by the NHTSA prior to compliance testing can be amplified as follows: 1) A snow plow, i.e., the component of a snow plow assembly that actually contacts and moves the snow, will be removed. 2) Those other components of a snow plow assembly that, like the snow plow itself, are ordinarily removed when not in use will also be removed. 3) Those components which are not ordinarily removed from the vehicle when not in use will not be removed by the NHTSA prior to compliance testing. The agency will abide by a manufacturer's good faith categorization of accessories and components of accessories.; Sincerely, Frank Berndt, Acting Chief Counsel