Interpretation ID: nht72-2.9

DATE: 03/13/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributers Association

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of February 23 you present a fact situation in which a final stage manufacturer (Illegible Words)a completed vehicle, such as a Ford Econoline and is instructed by the ultimate puchaser to add seats and seatbelts, flashing lights, etc. to transform the vehicle into a small school bus. You ask:

"Must this vehicle be certified as a bus, even though it had been certified previously by the chassis maker as a completed truck? How would a person to certify?

Where a completed, certified vehicle is altered after manufacture, the issue is whether sufficient modifications have been made to the original vehicle that the one who modifies it must be considered a manufacturer in his own right. Considering two scope of modifications you describe, and the change of vehicle type from "truck" to "bus" (if its carrying capacity is over 10 persons), or to multipurpose passenger vehicle (if it can carry 10 persons or less), this question would most likely be answered in the affirmative. In such a case the modifying manufacturer would have to certify the vehicle as complying with all applicable standards. He would have the responsibility of ensuring that his modifications did not affect the vehicle's original compliance with the standards, as well as full responsibility for any standards that became newly applicable because of the change of vehicle type.

Yours Truly,