Interpretation ID: aiam2773
North Central Tank Repair
Box 300
Holdingford
MN 56340;
Dear Ms. Schulte: This responds to your January 13, 1978, letter asking several question about a manufacturer's certification responsibilities under Part 568, *Vehicles Manufactured in Two or More Stages*.; In your letter, you enclosed a copy of a TBEA form and ask whether i complies with Federal regulations and where you can obtain copies. This form is supplied by TBEA to assist manufacturers in their own recordkeeping. It is not required by any Federal regulation. You should consult TBEA for copies of the form.; Secondly, you ask whether Standard No. 120, *Tire Selection and Rim for Motor Vehicles Other Than Passenger Cars*, has altered the responsibilities of the intermediate manufacturer. An intermediate manufacturer's responsibility for compliance with Standard No. 120 is the same as his responsibility for compliance with any other Federal motor vehicle safety standard.; In your third question, you ask whether the addition of a 'tag' o 'pusher' axle to a used chassis requires compliance with Standard No. 121, *Air Brake Systems*. The addition of one axle to a used chassis does not constitute the manufacture of a new chassis. Therefore, if the chassis were manufactured prior to the time that Standard No. 121 became effective, modification of the chassis would not need to comply with the standard. If the chassis already complies with the standard, you would be prohibited from rendering inoperative the compliance of the vehicle with the standard.; You ask what the penalties are for violation of the Federa certification requirements. Under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et seq*.) violations of the Act or regulations are punishable by $1,000 per violation up to a maximum of $800,000 for a related series of violations.; In your last question you ask whether the incomplete vehicle documen should remain with the intermediate or final stage manufacturer on completion of a vehicle. The final stage manufacturer should retain the incomplete vehicle document.; Sincerely, Joseph J. Levin, Jr., Chief Counsel