Interpretation ID: nht69-1.43

DATE: 06/02/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Parsons Mobile Products Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter dated March 18, 1969, in which you state, "[We] differ from all other motor-home manufcturers in that we use an existing chassis body combination, which has already been certified by General Motors Corporation. Therefore, to the best of our knowledge, all certification and safety requirements are being cut or exceeded at this time."

Your letter and the materials that you enclosed with it indicate that you alter a completed vehicle in a way that affects components necessary for compliance with safety standards, and change the vehicle type from a truck to a multipurpose passenger vehicle within the meaning or regulations issued pursuant to the National Traffic and Motor Vehicle Safety Act (49 CFR @ 371.3). In as doing you the evidently acting as a manufacturer within the(Illegible word) of section 102(5) of the Act, and must comply with the Certification Regulations that apply to motor vehicle manufacturer (49 CFR Part 367. pp. 38-40 of the enclosed pamphlet). Copies of the Act and pertinent regulations are enclosed.

The information requested in our letter to you dated February 14, 1969, is still relevant. Could we please have your response to that inquiry as soon as possible.

We trust this reply will be of assistance to you in your desire to comply with existing Federal Motor Vehicle Safety Standards and regulations.