Interpretation ID: nht68-1.11
DATE: 09/27/68
FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA
TO: Blaw-Knox Company
TITLE: FMVSS INTERPRETATION
TEXT: Thank you for your letter of July 11, 1968, in which you provided certification information.
With reference to the Service Bulletin dated "4-10-68" in the second paragraph you state that mixer units mounted at the factory will display a "Certification of Compliance" plate. Blaw-Knox, when it is the party mounting a mixed to a chassis-cab, must insure compliance with Federal Standard No. 108 in effect on the date of manufacture of the chassis-cab, but it is required to furnish certification only when the completed vehicle is being shipped to a dealer or distributor for sale to the ultimate purchaser. No certification is required when such a purchaser brings a chassis-cab to the factory for mixer installation. With reference to the third paragraph, it is not necessary for you to supply a certification plate for mixer equipment, which is shipped from the factory for mounting elsewhere. Compliance with Federal Standard No. 108 is the responsibility of the party who mounts the mixer to the chassis-cab.
Since the chassis-cab manufacturer will have provided serial number information sufficient to determine the requirements of Standards No. 108 in effect on the date of manufacturer of the chassis-cab, it is not necessary to include the mixer serial number on the certification plate. We would suggest that you may comply with the certification plate. We would suggest that you may comply with te certification requirements of Section 114 of the Act when you deliver the completed vehicle to a dealer or distributor for sale to the ultimate purchaser by wording your certification as follows:
"Blaw-Knox Company certifies to the distributor or dealer that it has mounted the mixer unit to the chassis and that the completed vehicle conforms with Federal Motor Vehicle Safety Standard No. 108."
A notice of proposed rule making which will result in more specific requirements with reference to certification will be published in the Federal Register in the near future. A copy of the notice will be sent Blaw-Knox.
Sincerely,
July 11, 1968
U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau
Attention: Joseph R. O'Gorman -- Acting Director, Office of Performance Analysis Motor Vehicle Safety Performance Service
Subject: Motor Vehicle Safety Standard No. 108
Gentlemen:
The following information is being sent to you at the direction of Mr. David A. Fay, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service, per his letter of June 27th, 1968 (copy enclosed).
Mr. Fay's letter was in answer to the writer's letter of May 6th (copy enclosed) requesting approval of the method being used by Blaw-Knox Company in order to comply with the certification requirements of Motor Vehicle Safety Standard 108. Mr. Fay indicated that the following additional information would be required.
1. The location on the vehicle at which the certification label or tag will be placed: This location is indicated on Blaw-Knox drawing C-8450-911 (enclosed).
2. Actual sample certification tag: Enclosed
3. The means by which the certification tag will be attached: Also indicated on drawing C-8450-911.
Should any additional information be required please write or call Blaw-Knox Company, Construction Equipment Division, Mattoon, Illinois.
Very truly yours,
BLAW-KNOX COMPANY
Construction Equipment Division --
J. M. Wright,
Assistant Sales Manager
Enclosures