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Interpretation ID: aiam0707

Mr. A. R. Williams, Sales Manager, Ronway Trans Craft Systems, 80 Ross Road, Ashtabula, OH 44004; Mr. A. R. Williams
Sales Manager
Ronway Trans Craft Systems
80 Ross Road
Ashtabula
OH 44004;

Dear Mr. Williams: Mr. Toms has asked me to reply to your letter of May 12, 1972, in whic you ask for guidance in regard to the Federal Motor Vehicle Safety Standards (FMVSS) that would apply to equipment described in your brochure.; Your responsibilities under the National Traffic and Motor Vehicl Safety Act of 1966 (the Act) and FMVSS and regulations would depend on the way the equipment is marketed and you should be guided by the following:; >>>1. If you market the body and/or the chassis adaptor unit, the would be considered items of motor vehicle equipment for which there are no applicable standards. Although the standards do not apply, you should assure yourself that no safety-related defects exist.; 2. A person who mounts the chassis adaptor unit on a chassis-cab woul be considered the final stage manufacturer within the meaning of Part 568 of Title 49 of the Code of Federal Regulations and he would be responsible for conformity. The following pertinent publications are enclosed.; 1. The National Traffic and Motor Vehicle Safety Act of 1966. 2. Federal Motor Vehicle Safety Standard No. 108 with amendment effective on January 1, 1972.; 3. Notice of Publications Change. 4. Part 566 of Title 49 of the Code of Federal Regulations Manufacturer Identification.; 5. Part 567 - Certification 6. Part 568 - Vehicles Manufactured in Two or More Stages. 7. Part 573 - Defect Reports. 8. Part 574 -Tire Identification.<<< It is anticipated that many members of my staff will be attendin Transpo 72. They, no doubt, will be very interested in seeing your exhibit as well as the many others that will be there. However, I would recommend that you direct any questions you might have relating to interpretations of the standards and regulations to the Administration.; Thank you for your interest in the programs of the National Highwa Traffic Safety Administration.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;