Interpretation ID: aiam2355
Director
Automotive Safety Engineering
Environmental Activities Staff
General Motors Corporation
Warren
MI 48093;
Dear Mr. Martin: It has come to the attention of the National Highway Traffic Safet Administration that General Motors Corporation is planning to include in its 1977 Cadillac incomplete vehicle document the following statement with respect to Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity*:; >>>Conformity with FMVSS 301 is not substantially determined by th design of this incomplete vehicle and General Motors makes no representation as to conformity with this Standard.; The use of this statement would not comply with 49 CFR Part 568 *Vehicles Manufactured in Two or More Stages*.; A copy of the March 8, 1976, letter from Mr. W.J. Owen of the Cadilla Motor Car Division to Mr. R.B. Kurre of the Wayne Corporation is attached for your reference. That letter was included in the petition of Wayne's Miller-Meteor Division for a temporary exemption from Standard No. 301-75 as applied to ambulances and funeral coaches that Wayne manufactures using Cadillac commercial chassis.; I understand that these chassis are delivered to Wayne with the fue system components already installed, that Wayne removes certain components in order to mount the body and that those components are reinstalled after the mounting of the body.; The incomplete vehicle document is required by S568.4(a)(7) to includ a--; >>>[l]isting (sic) by number of each standard...followed in each cas by one of the following types of statement, as applicable:; (i) A statement that the vehicle when completed will conform to th standard if no alterations are made in identified components of the incomplete vehicle. ...; (ii) A statement of specific conditions of final manufacture unde which the manufacturer specifies that the completed vehicle will conform to the standard. ...; (iii) A statement that conformity with the standard is no substantially determined by the design of the incomplete vehicle, and that the incomplete vehicle manufacturer makes no representation as to conformity with the standard.<<<; There is a factual limitation on use of the third statement. It may no be used for standards conformity to which is substantially determined by the design of the incomplete vehicle. Where the basic fuel system components, including fuel tank and lines and filler pipe, are included in the incomplete vehicles, compliance of the completed vehicle with Standard No. 301-75 is substantially determined by both the design of the incomplete vehicle and the manner of completion by the final stage manufacturer. Therefore, General Motors is required to include a statement of the first or second type with respect to Standard No. 301-75 in the incomplete vehicle documents accompanying Cadillac commercial chassis that are manufactured on or after September 1, 1976, and designed for completion into multipurpose passenger vehicles. Such chassis that are manufactured before that date are not required by Part 568 to include any statement concerning Standard No. 301-75, because there are no fuel system integrity requirements for multipurpose passenger vehicles until that date.; The above discussion also applies to any other commercial chassi manufactured by General Motors for sale as incomplete vehicles.; Yours truly, Frank Berndt, Acting Chief Counsel