Interpretation ID: aiam4413
PSI Mobile Products Inc.
25 Eldredge
P.O. Box 1183
Mt. Clemens
MI 48043;
Dear Mr. Landers: This is in response to your letter requesting confirmation of a Jul 11, 1983 determination by this agency that your special tow tractor vehicle is exempt from Federal motor vehicle safety standards. You indicate in your letter that you now have three sizes of tow tractors and that your market may expand to include commercial airline use as well as the Department of Defense.; Based on the information you have provided us, we confirm our previou determinations that baggage tow tractors are not subject to the Federal motor vehicle safety standards. The agency has consistently interpreted the definition of motor vehicle as excluding vehicles such as airport runway vehicles that are intended and sold solely for off-road use and are not equipped for highway use. Further, we note that section 571.7(c) of Title 49, Code of Federal Regulations, provides that; >>>No standard applies to a vehicle or item of equipment manufacture for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.<<<; Your vehicles might become subject to the Federal motor vehicle safet standards if there is a material change in the facts regarding the intended or actual use, design or sale of your vehicles. Please remember that compliance with all Federal motor vehicle safety standards is the obligation of each manufacturer of motor vehicles or motor vehicle equipment. We appreciate your continuing efforts at classifying correctly your vehicles.; Sincerely, Erika Z. Jones, Chief Counsel