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Interpretation ID: aiam0061

Maurice Wexler, Esq., Heiskell, Donelson, Adams, Williams & Wall, Suite 2020 First National Bank Building, Memphis, TN 38103; Maurice Wexler
Esq.
Heiskell
Donelson
Adams
Williams & Wall
Suite 2020 First National Bank Building
Memphis
TN 38103;

Dear Mr. Wexler: Mr. Bridwell has asked that I reply to your letter of April 9, 1968. Enclosed for your information is a copy of the chassis-cab ruling an regulation issued December 29, 1967. Under the terms of the ruling and regulation and the National Traffic and Motor Vehicle Safety Act of 1966, when a truck body manufacturer assembles the truck body to a chassis-cab he is responsible for certification only if the completed vehicle is delivered to a dealer or distributor. The body manufacturer assembling the body to the chassis-cab would, however, be responsible for the vehicle's compliance with the lighting standard if not previously met by the chassis-cab manufacturer. Moreover if the addition of the body affects the chassis-cabs previous compliance with standards the body manufacturer would be responsible for compliance.; With regard to bodies mounted on chassis-cabs manufactured prior t January 1, 1968 compliance and certification is not required. However, the body, if manufactured on or after January 1, 1968, would have to contain glazing that complies with Standard No. 205 because the body is manufactured for use on motor vehicles and as such must meet any applicable equipment standards.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel