Interpretation ID: nht72-3.26

DATE: 07/17/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mercury Fabricators

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 20, 1972, in which you ask whether Motor Vehicle Safety Standards Nos. 206 (Door Locks and Door Retention Components) and 302 (Flammability of Interior Materials) apply to aluminum sleeper cabs which you manufacture for what appears to be installation on truck tractors.

Each motor vehicle safety standard is by its terms applicable to specific types of motor vehicles and motor vehicle equipment. Each vehicle or item of equipment to which a standard applies must conform to the standard until its first purchase by a user. Components which are incorporated into vehicles before their first purchase are considered to be part of the vehicle, and as a practical matter must conform to all standards applicable to it.

Standard No. 302 becomes effective September 1, 1972, and applies to trucks, which includes truck tractors. If a sleeper cab you manufacture is incorporated into a truck before its first purchase by a user, then it must conform to the standard. Moreover, the components to which the standard applies (paragraph S4.1) include mattress covers, and if you determine the standard applies under the criteria we have provided, mattress covers which you furnish must conform to the standard. You indicate you have tested the flammability of the cab utilizing a torch. While you may test for conformity to the standard in any way you choose, whether or not your product conforms to the standard will be determined by NHTSA utilizing the test procedures specified in the standard. Manufacturers who utilize procedures different from those in the standard should take care to correlate the results they obtained to those that would be obtained using the standard's procedures.

Standard No. 206 also applies to trucks, and will become effective for all side doors leading to passenger compartments on September 1, 1972. Consequently, if the sleeper cabs you manufacture are incorporated into trucks before their first purchase the sleeper cabs must conform to Standard No. 206

Enclosures