Interpretation ID: aiam4278
Senior Safety Engineer
Grumman Olson
Post Office Box 2005
Sturgis
MI 49091;
Dear Mr. White: This letter responds to your inquiry of November 17, 1986, asking thi agency to approve an alternate location for the certification label of a light duty truck your company intends to manufacture for the United States Post Office. Section 567.4 of the National Highway Traffic Safety Administration (NHTSA) regulations requires that a motor vehicle manufacturer affix a certification label to each vehicle it makes, and permits the manufacturer to place the label in any one of the places set out in that provision. If none of those locations is practicable, S567.4 directs the manufacturer to suggest an alternate place to affix the label, and to ask our approval for that alternative.; You explain in your letter that in the circumstances you describe, th S567.4 locations are impractical. First, you explain, the vehicle's sliding doors make the hinge pillar and door latch post and edge too small and irregularly shaped for a label. Second, if your company places the label on the inside of the sliding door, opening the door would hide the label. Third, you assert that the instrument panel is too small for a label.; You enclose a drawing to illustrate where your company intends to plac the certification label. According to your description, the certification label will be placed on a fixed panel behind the driver, and between the cab and the load compartment. This panel is one part of a three piece assembly of which the remaining two components are a center sliding door and a second fixed panel. You state that a person can see the certification label from the driver's area without moving any vehicle item.; In directing a manufacture to put its certification label in thos places set out in S567.4, NHTSA's purpose is to make these labels easy to see and read. Based on the information you supplied, the agency determines that for this particular design, installing the certification label as your company proposes will facilitate seeing and reading the label, while placing the label as specified in S567.4 may not be practicable or might interfere with those activities. Therefore, on the condition that your company's label complies in all other respects with S567.4, NHTSA grants your request to install the certification label on the forward side of the left hand bulkhead fixed panel.; Sincerely, Erika Z. Jones, Chief Counsel