Interpretation ID: aiam0108
National Highway Users Conference
National Press Building
Washington
DC 20004;
Dear Mr. O'Toole:#Thank you for your letter of August 23, to Mr. Georg Nield, concerning the compliance of crane carriers and fire engines with Federal Motor Vehicle Safety Standards 103 and 104.#The crane carrier you have described is a 'motor vehicle' subject to the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. For purposes of the Federal Motor Vehicle Safety Standards the described crane carrier is classified as a 'truck.' Although currently Federal Standards 103 and 104 do not apply to trucks both standards, by amendment, issued April 24, 1968, (33 F.R. 6466-69), will be applicable to trucks manufactured on or after January 1, 1969.#Similarly, a fire truck is a 'motor vehicle' and a 'truck' and subject to all Federal Motor Vehicle Safety Standards applicable to this category of vehicle, including Standards 103 and 104. However, the open cabs found on many fire trucks may make full compliance with Standard 103 impossible. A public docket, Docket No. 24, has been established to receive comments pertaining to the possible classification of fire fighting equipment as a separate vehicle category which might be exempt from certain standards.#Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations;