Interpretation ID: GF000333

Mr. Joe Isaac
Production Group Leader
Duncan Manufacturing
100 E. Halliburton Blvd.
Duncan, OK 73533

Dear Mr. Isaac:

This responds to your January 10, 2005, e-mail regarding certification issues pertaining to certain trailers.

In your e-mail to Jeff Woods, you explained that your company purchases trailers that are already equipped with lights, brakes, tires, and rims. You indicated to us that the trailers are not certified, but come equipped with "incomplete vehicle documents" or "IVDs" that usually specify, among other things, the gross vehicle weight rating (GVWR), the gross axle weight ratings (GAWR), and tire information. Your company installs engines, transmissions, pumps, and driveshaft components in order for these trailers to perform oilfield services. You ask whether the trailers being purchased by your company are considered "completed vehicles" pursuant to 49 CFR 568.3, and whether the modifications performed by your company constitute "addition of readily detachable components".

Briefly, the National Highway Traffic Safety Administrations vehicle certification regulations state that a person who alters a previously certified vehicle need not re-certify the vehicle, if the alterations are limited to addition, substitution, or removal or readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting (see 49 CFR 567.6). Because the trailers purchased by your company are not certified when you receive them for the purpose of performing further modifications, the provisions of 567.6 would not apply to you. Instead, under Part 568.3, you are considered the final stage manufacturer of these trailers, and you are required to certify that these vehicles meet the applicable Federal motor vehicle safety standards. Our answers to your specific question follow.

The trailer modifications performed by your company do not constitute the addition of "readily attachable components". As specified in 567. 6, components such as mirrors or tire and rim assemblies are considered "readily attachable components". Other similar changes, including minor finishing operations or painting, that do not affect the vehicles stated weight rating would not require re-certification of the vehicle. In the present case, however, you permanently attach onto each trailer a sizeable quantity of work-performing equipment. Based on the information provided in your e-mails and the attached photograph, the trailers stated weight rating is affected by these modifications. Thus, the modifications performed by your company do not constitute the addition of "readily detachable components", even if the trailers purchased by your company were certified when you received them.

I hope you find this information helpful. If you have any other questions please contact Mr. George Feygin at (202) 366-2992.

Sincerely,

/s

Jacqueline Glassman
Chief Counsel

ref:568
d.3/16/05