Interpretation ID: aiam3386
Jr.
Hendrickson Mfg. Co.
Mobile Equipment Division
8001 West 47th Street
Lyons
IL 60534;
Dear Mr. Lenz: This responds to your November 25, 1980, letter asking whether an safety standards have been violated by a truck modification that you perform. In your modification, you alter a chassis to provide right-hand controls. The vehicle is then sent to a final-stage manufacturer for completion.; As an incomplete vehicle manufacturer, you are required to attach th appropriate label to the vehicle in accordance with Part 567, *Certification*. That label makes certain statements about the compliance of the vehicle with safety standards as a result of your modifications.; You ask whether any safety standards have been violated by you modifications. It is impossible for the agency to determine compliance without testing one of your vehicles. You list several changes that you make to the vehicle, including the addition of: a foot throttle, foot service brake, hand spring brake, turn signal, transmission selector, and steering wheel. The agency has safety standards that govern many of these devices. These standards are found in Volume 49 of the Code of Federal Regulations, in Part 571. It is a manufacturer's responsibility to ensure that its vehicles comply with these standards. The only advice that we can offer is that nothing precludes the type of modifications that you propose. The installation of right-hand controls is permissible as long as the compliance with all safety standards is maintained.; Sincerely, Frank Berndt, Chief Counsel