Interpretation ID: nht69-1.39

DATE: 08/01/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Bedell Trailer Company

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of June 12, 1969, in which you enclosed a certification label you are now using and in essence ask why it will not be satisfactory after August 31, 1969.

Manufacturers were put on notice, by publication in the Federal Register, Volume 32, No. 215, dated November 4, 1967, that the National Highway Safety Bureau had under study an appropriate program which would lead to specific regulations applicable to certification. It was requested that manufacturers submit, among other things, a sample of the certification label or tag they were using.

As a result of that study, a proposal was promulgated and published in the Federal Register, Volume 33, No. 205, dated October 9, 1968. Interested parties were given the opportunity to express their views and after due consideration a rule was published on January 24, 1969, Federal Register, Volume 34, No. 16.

Shortly thereafter peitions for reconsideration of the Certification Regulation were received. The "Denial of Petitions for Reconsideration," Federal Register, Volume 34, No. 81, states in part, "Objection was made to the specification of the language of the conformity statement." This specification has been determined to be necessary, however, in order to eliminate the burden of seeking approval of proposed labels, as many manufacturers found advisable under the previous rule, and to inform both regulated persons and the public of the requirement of the "Act".

It is regretted that the Certification Regulation, that becomes effective with vehicles manufactured after August 31, 1969, makes the labels in your inventory obsolete, however, we feel that manufacturers have had ample prior warning of a pending specific regulation.

ENCLOSURES F-6, F-34, F-54, F-59 and F-60