Interpretation ID: nht91-6.3

DATE: September 18, 1991

FROM: Al Lipinski -- President, Mini-Max

TO: Hall, Jackson, Rice -- NATSA (NHTSA), Chief Counsel

TITLE: None

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to Al Lipinski (A38; Std. 108; Part 567)

TEXT:

I talked with Steve Kratzke on September 18, 1991 regarding the Dynamic Testing requirements for alterers of certified vehicles.

We are a small conversion company of walk in van type light trucks located in Escanaba, MI. Our projected production for 1992 is 75 vehicles. We do not alter anything forward of the B pillar of a certified vehicle, thus the crash protection system installed by the original manufacturer is not disturbed. We afix an additional label stating the vehicle alterations conform to all applicable FMVSS.

I would appreciate a letter stating what the dynamic testing requirements are for an alterer of a certified vehicle for my files in case this question arises in the future.