Interpretation ID: nht91-5.34

DATE: September 4, 1991

FROM: Michael E. Kastner -- Director of Government Relations, National Truck Equipment Association

TO: Paul J. Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12-6-91 from Paul Jackson Rice to Michael E. Kastner (A38; Part 567; VSA 108(a)(2)(A))

TEXT:

I wanted to thank you for taking the time to meet with Mark Sidman and myself last Friday concerning FMUSS 204 and the difficulties faced by Multi-stage Manufacturers in certification. I also wanted to take this opportunity and pose a question to you or your staff.

The National Truck Equipment Association ("NTEA") has encountered a number of questions involving the need for an altered certification label under a particular set of circumstances. We would like NHTSA's interpretation of the following scenario.

An NTEA member receives a truck which is certified as a completed vehicle. This vehicle has not yet been titled or registered for use in any state. The NTEA member then installs a piece of equipment. This piece of equipment would not be considered readily attachable, nor would this equipment modify the completed vehicle's weight ratings. Both the completed truck manufacturer and the equipment manufacturer have stated that installation of this equipment would not affect compliance with any federal motor vehicle safety standards.

Under these circumstances, does the company installing the equipment on the completed vehicle need to affix an altered vehicle label?

Traditionally, the NTEA has advised its members that an altered vehicle label is required in this situation. If that is not the case we would like to advise our members accordingly.

Thank you in advance for your assistance with this matter.