Interpretation ID: 77-3.6

TYPE: INTERPRETATION-NHTSA

DATE: 06/22/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Grove Manufacturing Company

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 17, 1977, letter concerning National Highway Traffic Safety Administration's (NHTSA) tire label requirements contained in Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. You address the situation in which it is not practicable to affix the information label to the door.

Location of vehicle certification labels and tire information labels is governed by Part 567.4(c). This section provides that the primary location of the required labels is either the hinge pillar, door-latch post, or door edge that meets the door-latch post, next to the drivers seating position, or if none of these locations is practicable, to the left side of the instrument panel. Further, if none of the above locations is practicable, you may request an alternate location from the agency. I am enclosing a copy of Part 567 explaining how to request an alternate location for the information label.

SINCERELY,

February 17, 1977

Administrator National Highway Traffic Safety Administration

Subject: Request for deviation applicable to Part 567, and FMVSS #120 (Certification Labeling)

Reference: 42 FR 7140 dated February 7, 1977

As manufacturers of mobile hydraulic cranes it has always been our company policy to conform to all applicable Federal Motor Vehicle Safety Standards to the best of our ability. As you are probably aware, a self-propelled crane has unique features as regards their work function, and as such, manufacturers are obligated, morally and legally, to assure these features, both carrier and superstructure modes are properly placarded as to operation, maintenance, etc. and notwithstanding, safety which is always our prime concern.

The most important document that accompanies our product line to the ultimate user is the operators handbook. Not only do we supply such a document with the physical shipment of the crane but also provide a second set geared to the specific model involved to the buying distributor. The operators handbook must be fully understood and digested before a crane operator physically operates the equipment. It is to be noted, that the prime-mover (carrier) is equally important as to safety of operation as is the superstructure cranning function.

Tire and rim selection from the design Engineering viewpoint is rather unique within our industry in that, crane manufacturers per se do authorize limited "Lift" capability on rubber and subsequent movement of the load at a given maximum speed. Decal location of these "on rubber" limits are posted to the centerline of the driver side carrier door adjacent to the vehicle certification label. In addition, this information is fully cited in our operators handbook along with suggested substitutes of tires and rims with their recommended cold PSI for on rubber and highway functions.

One must also consider the usage factor of this type of equipment within the realm the real world. Construction companies and users of our type of equipment are considered unique in that usage of the equipment is primarily performed in an off-highway configuration, yet is capable of travel from the owners yard to the job site. However, in terms of odometer miles on the carriage in any given time-frame, it would equal merely a fraction of an over the road semi-tractor type piece of equipment.

Attached herewith as Enclosure 1 and Enclosure 2 are typical examples of our certification label and tire inflation chart decals. Attached as Enclosure 3 is a typical decal installation drawing on one of our crane families. Please note the many different types of decals ie, caution, warning, danger, etc. which we, as vehicle manufacturers, feel obligated to attach to our machine totally in the interest of safety to our users. To expand our present certification label to include suitable tire and rim information would increase the overall size by one-third. The label is presently sensitized to a metal mounting plate which is needed due to the acoustical package placed on the exterior of the door for noise abatement. The door therefore, would require extensive redesign along with an enlarged mounting attachment for the decal. Predicated on the type of equipment, work function, and limited highway travel mode, it is requested that your Administration reconsider the label information requirements under S5.3 for our type of equipment and keeping in mind that we have and are conforming to the standard and merely are asking relief as to location of the mandated information.

GROVE MANUFACTURING COMPANY

R. G. Wilkins Product Safety & Reliability Analyst

cc: E. GARDENHOUR; W. KENNER; L. JOHNSON; F. KRUECK; H. BARRETT; B. SPANGLER

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