Interpretation ID: aiam1149
RVI
Inc. Suite 406
1140 Connecticut Avenue
Washington
DC 20006;
Dear Mr. Humphreys: This is in reply to your letter of May 18, 1973, concerning a defec notification campaign involving furnaces manufactured by Suburban Manufacturing Company of Dayton, Tennessee, that have been used in recreational vehicles. You ask whether the obligation of the individual vehicle manufacturers under the Safety Act and applicable regulations may be met if the appropriate documents and notices are sent or filed by Suburban Manufacturing.; Suburban Manufacturing Company may prepare and submit to NHTSA or mai to purchasers, on behalf of the individual vehicle manufacturers, the information required by 49 CFR Part 573 'Defect Reports,' 49 CFR Part 577, 'Defect Notification,' and Section 113 of the Safety Act (15 U.S.C. 1402). However, the requirements must be met as they apply to manufacturers of motor vehicles, and not manufacturers of equipment. Moreover, the vehicle manufacturers themselves will still be responsible if any of the documents filed or sent by Suburban Manufacturing Company fail to fully conform to all applicable requirements.; Sincerely, Lawrence R. Schneider, Chief Counsel