Interpretation ID: aiam0622
Jr.
Executive Secretary
Truck Equipment & Body Distributors Association
602 Main Street
Cincinnati
OH 48202;
Dear Mr. Pieratt: In your letter of February 23 you present a fact situation in which final stage manufacturer receives a completed vehicle, 'such as a Ford Econoline,' and is instructed by the ultimate purchaser to add seats and seatbelts, flashing lights, etc. to transform the vehicle into a small school bus. You ask:; ???'Must this vehicle be certified as a bus, even though it had bee certified previously by the chassis maker as a completed truck? How would a person so certify?<<<; Where a completed, certified vehicle is altered after manufacture, th issue is whether sufficient modifications have been made to the original vehicle that the one who modifies it must be considered a manufacturer in his own right. Considering the scope of modifications you describe, and the change of vehicle type from 'truck' to 'bus' (if its carrying capacity is over 10 persons), or to 'multipurpose passenger vehicle' (if it can carry 10 persons or less), this question would most likely be answered in the affirmative. In such a case the modifying manufacturer would have to certify the vehicle as complying with all applicable standards. He would have the responsibility of ensuring that his modifications did not affect the vehicle's original compliance with the standards, as well as full responsibility for any standards that become newly applicable because of the change of vehicle type.; Yours truly, Richard B. Dyson, Assistant Chief Counsel