Interpretation ID: aiam1164
Taylor Machine Works
Inc.
P.O. Box 150
Louisville
MS 39339;
Dear Mr. Monk: This is in reply to your letter of May 25, 1973, to Michael Peskoe o this office, requesting clarification of the regulations regarding the certification of motor vehicles. You enclose an incomplete vehicle document concerning a particular tractor, a certification label you would affix to that tractor after its completion, a drawing of a trailer certification label, and a sample quarterly report of production figures for vehicles manufactured by your company.; Mr. Peskoe indicated to you over the phone that in meeting you certification responsibilities for these vehicles, they are certified independently of each other. It appears from your letter that this approach, which is the correct one, is the approach you are using.; With reference to your responsibilities for the certification of th tractor, if the truck does not have a certification label attached to it when you receive it, it is true that when you complete it by mounting a fifth wheel you must then attach a certification label. The label you enclose (exhibit 1) contains the necessary information in the appropriate order. You should obtain the information for the label primarily from the incomplete vehicle document, but may, as you state, rely on your own engineering judgment or contact the truck manufacturer. If, however, in relying on your own judgment you depart from the information contained in the incomplete vehicle document, you may be responsible for failures of the vehicle to conform to applicable standards and regulations.; The sample trailer certification label which you have submitted is no consistent with the certification regulations. We have taken the position that the information must be presented on the label in the form and in the order specified in the regulations. With respect to your sample label, the regulations do not presently call for a kingpin rating. Although we have just proposed to require a weight rating for the trailer coupling, this information should not now be included on the label. The regulations also do not permit ratings for tandem axles to be stated as tandem ratings. Each axle must be independently identified and a separate rating provided for it. Moreover, tire sizes are permitted to be specified only in conjunction with weight ratings. There are no provisions for the listing of plies, apart from their inclusion in a tire size designation, or for the listing of an inflation pressure. Again, information that is not specifically required cannot be inserted between items of required information, and your drawing of a trailer is not permitted unless it is placed after the required information. Finally, the regulations call for gross vehicle weight rating (the phrase 'gross trailer weight rating' is inappropriate) to follow the gross axle weight ratings, and the order in which you present this information must be reversed. I believe you should reexamine the Certification regulations in order to obtain specific guidance on the order and form of the required information.; The sample quarterly production report you submit conforms to th requirements of section 573.5(b) of the Defect Reports regulations. However, that section requires only the reporting of the number of vehicles, identified by make, model, and model year (if appropriate). While we are happy to receive the additional information you provide, you are not required to furnish it to us.; Yours truly, Richard B. Dyson, Assistant Chief Counsel