Interpretation ID: aiam4386
Jr.
Executive Secretary
Truck Equipment & Body Distributors Assoc.
602 Main Street
Cincinnati
OH 45202;
Dear Mr. Pieratt: With reference to your phone conversation with Make Peskoe on Septembe 8, I have enclosed a copy of an NHTSA opinion which concludes that a person adding a snow plow to a completed vehicle is not required to certify the vehicle. In such a case, the existing certification label should be left in place. You should note that the opinion also states that if the mounting of the snow plow causes the vehicle not to conform to any applicable motor vehicle safety standard, and the vehicle is not brought back into conformity before sale, the person mounting the plow will be violating section 108(a)(1) of the National Traffic and Motor Vehicle Safety act, and will be subject to civil penalties and other sanctions as prescribed in sections 109 and 110 of the Act.; Yours truly, Richard B. Dyson, Assistant Chief Counsel