Interpretation ID: aiam2448
Jr.
Vice President-General Counsel
Warner & Swasey
11000 Cedar Avenue
Cleveland
OH 44106;
Dear Mr. King: This is in response to your October 29, 1976, letter concerning th status of Warner and Swasey Company with regard to the fire truck chassis that it manufactures.; Strictly speaking, the status of Warner and Swasey is simply that o 'manufacturer,' as the term is defined in Section 102(5) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391,; et seq*.) (the Act). Your real concern appears to be with the lega classification of the company's products.; From the description in your letter, the chassis that are produced b Warner and Swasey for sale to fire truck apparatus manufacturers are clearly 'incomplete vehicles,' as that term is defined in S 568.3 of 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*. The current definitions of the terms 'motor vehicle,' 'motor vehicle equipment,' 'original equipment,' and 'replacement equipment' are found in Sections 102 and 159 of the Act. With these definitions, the National Highway Traffic Safety Administration considers an incomplete vehicle to be an item of original equipment, which is in turn an item of motor vehicle equipment rather than a motor vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel