Interpretation ID: aiam3087
Halliburton Services
Drawer 1431
Ducan
Oklahoma 73533;
Dear Mr. Bechtel: This is in response to your letter of May 1, 1979, requesting a interpretation of the definition of 'incomplete vehicle' contained in Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your subsequent telephone conversations with Mr. Schwartz of my office.; The term 'incomplete vehicle' is defined in S3 of the standard to mea 'an assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attached components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed trailer.; You are correct in saying that most of the components listed in th definition are not meant to be part of a trailer. Consequently, an incomplete Trailer would consist of only those components, such as a frame, listed in the definition which are meant to be part of the completed trailer. The outfitting of an incomplete trailer for a specific purpose would not be sufficient to make Halliburton Serviced responsible for assigning the vehicle identification number.; Sincerely, Frank Berndt, Chief Counsel