Interpretation ID: aiam1749
Executive Director
Truck Equipment & Body D/A
602 Main Street
Cincinnati
OH 45202;
Dear Mr. Pieratt: This is in reply to your letter of December 17, 1974, asking whether person who installs a third axle or dromedary unit to a completed vehicle, or removes the body from a pickup truck and installs a service body, should affix a vehicle alterer label to the vehicle in accordance with 49 CFR SS 567.7 and 568.8. You refer to two earlier letters we had written to you in which we took the position that each of these activities was 'remanufacturing,' requiring recertification.; Requirements for vehicle alterers were published June 13, 1973 (38 F 15961) (effective February 1, 1974), and were intended to supplant our prior opinions regarding 'remanufacturing,' or, as we described it, the modification of previously completed, certified vehicles so as to significantly affect either the vehicle's configuration or purpose. Those opinions, which included our letters to you, were based on our interpretation of rather general provisions of the National Traffic and Motor Vehicle Safety Act, and the Certification regulations (49 CFR Parts 567, 568) then in effect.; The alterer requirements provide specific criteria for a determinatio of whether additional certification is required, viz., when the alterations either involve other than readily attachable components or invalidate existing weight ratings. In each of the three cases you present, it appears to us that other than readily attachable components are involved, and alterer labels would be required. Moreover, the changes to the vehicle would appear to alter the load-carrying capacity or the intended full load, and these changes might make it necessary or desirable to change the weight ratings on the certification label.; Yours truly, Richard B. Dyson, Acting Chief Counsel