Interpretation ID: 77-1.49

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/77

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Bohmer-Reed Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 25, 1977, letter asking whether your motor home conversions make you a manufacturer or an alterer for purposes of compliance with the regulations of the National Highway Traffic Safety Administration (NHTSA).

In your conversion of motor homes, you install used bodies on new chassis. The NHTSA considers the mounting of a used body on a new chassis to be the manufacture of a new motor vehicle that requires certification. This makes you a manufacturer rather than an alterer. The rules for certification are found in Part 567, Certification, and Part 568, Vehicles Manufactured in Two or More Stages. I have enclosed copies of these regulations for your information.

Your second question asks whether the converted vehicle must comply with Standard No. 302, Flammability of Interior Materials, even though the original body was manufactured prior to the effective date of the standard. Vehicles must comply with all standards in effect on the date of their manufacture. For vehicles that you complete by mounting a body on a new chassis, you are permitted to treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in Part 568), the date of final completion of the vehicle, or a date between those two dates. Therefore, it appears that the vehicle you manufacture would be required to comply with Standard No. 302.

SINCERELY,

February 25, 1977

Chief Counsel NHTSA

Our's is a new company which was formed for the purpose of going into business converting customers 31' Airstream Trailers, from 1968 to present models, into Motorhomes.

We build the chassis and do the conversion. We do not use any of the airstream chassis or suspension.

Our chassis components have been designed by Bendix for rear suspension and brakes; Spicer Dana for the front axle; Firestone for the air suspension; Saginaw Gears for the steering system; and Ford Motors for the engine, transmission and cooling systems.

We are attempting to comply with the Federal Docket in all respects.

My first question is, are we to be considered a manufacturer or an alterer?

Second, on Airstream Trailers, 1968 through September 1, 1972, must 302 be complied with if it does not already comply?

I would appreciate any information you could furnish me on this matter.

John O. Bohmer President Bohmer - Reed, Inc. Motorhome Conversions