Interpretation ID: aiam1132
Femco
Inc.
P.O. Box 687
500 North Bypass
McPherson
KS 67460;
Dear Mr. Beshore: This is in reply to your letter of April 16, 1973, inquiring whethe any Federal laws apply to your building and installation of a man-lift (pictures of which you enclose) in a completed pick-up truck. You state you understand that if the man-lift is installed on a completed vehicle, you are not considered the final-stage manufacturer.; Based on the information you have provided us, we believe you interpretation to be correct. It does not appear that you have altered the pick-up truck in a way that would make your company responsible for conformity with Federal safety standards or regulations.; The NHTSA has proposed certain requirements for vehicle alterers (cop enclosed). These requirements would very likely apply to you, when effective, if the addition of the man-lift occurs before the purchase of the pick-up truck for a purpose other than resale.; Yours truly, Richard B. Dyson, Assistant Chief Counsel