Interpretation ID: aiam0206
Administrative Assistant
Holan
Division of Ohio Brass Company
4100 W. 150th Street
Cleveland
OH 44135;
Dear Mr. Macho: This is in reply to your letter of January 19, 1970, in which you aske whether section 371.13, Labeling of Chassis-Cabs, requires chassis-cab manufacturers to indicate the date of manufacture by month, day and year, or whether month and year alone is sufficient.; The wording of the section is 'date of manufacture', without furthe elaboration. While in most contexts this phrase refers to a specific day, the present scheme of labeling and certification leads us to the conclusion that the month and year will be sufficient to satisfy the intent of the regulation.; The main regulator purpose of the requirement is to make it clear whic standards are applicable to the chassis cab and therefore to the complete vehicle under our ruling. A similar purpose is fulfilled by the date-of-manufacture requirement in the Certification Regulations, 49 CFR Part 367, and there the requirement is explicitly stated as month and year only. It is the practice of the National Highway Safety Bureau to make standards effective on the first day of a month, and therefore it is unnecessary to require manufacturers to incur the extra expense of a daily label change.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations;