Interpretation ID: aiam0597
Fairmont Railway Motors
Inc.
Fairmont
MN 56031;
Dear Mr. Nolte: This is in reply to your letter of January 4, 1973, concerning th applicability of the Federal motor vehicle safety standards to passenger cars with railway guide wheels manufactured by your company.; You indicate that the guide wheels are installed on a passenger car b removing the bumpers, installing the wheels, and reinstalling the bumper shock absorbers with a new bumper of your own design. This operation is considered to be a manufacturing operation, for purposes of our regulations. If Fairmont installs the wheels on a new vehicle, then sells the vehicle to a customer, the vehicle will have to conform to the applicable safety standards. If, however, Fairmont installs the wheels on a completed vehicle that is owned by the customer, or if it sells the wheel assemblies for installation by a customer, the vehicle will not be required to conform.; The safety standard applicable to passenger car bumpers is Standard No 215. I have enclosed a copy for your reference.; Yours truly, Richard B. Dyson, Assistant Chief Counsel