Interpretation ID: aiam2533
President
Bohmer - Reed
Inc.
Motorhome Conversions
Brooten
MN 56316;
Dear Mr. Bohmer: This responds to your February 25, 1977, letter asking whether you motor home conversions make you a manufacturer or an alterer for purposes of compliance with the regulations of the National Highway Traffic Safety Administration (NHTSA).; In your conversion of motor homes, you install used bodies on ne chassis. The NHTSA considers the mounting of a used body on a new chassis to be the manufacture of a new motor vehicle that requires certification. This makes you a manufacturer rather than an alterer. The rules for certification are found in Part 567, *Certification*, and Part 568, *Vehicles Manufactured in Two or More Stages*. I have enclosed copies of these regulations for your information.; Your second question asks whether the converted vehicle must compl with Standard No. 302, *Flammability of Interior Materials*, even though the original body was manufactured prior to the effective date of the standard. Vehicles must comply with all standards in effect on the date of their manufacture. For vehicles that you complete by mounting a body on a new chassis, you are permitted to treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in Part 568), the date of final completion of the vehicle, or a date between those dates. Therefore, it appears that the vehicle you manufacture would be required to comply with Standard No. 302.; Sincerely, Frank Berndt, Acting Chief Counsel