Interpretation ID: nht72-4.50

DATE: 10/01/72 EST

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Pioneer Machinery Inc.

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of September 15, 1972, you ask for clarification of the records that Pioneer Machinery, Inc., as a manufacturer and installer of truck hoists and racks, is required to keep.

There are several regulations issued by the National Highway Traffic Safety Administration that could apply to Pioneer. The first of these is 49 CFR Part 566, Manufacturer Identification. Under this regulation manufacturers of vehicles and equipment to which a Federal motor vehicle safety standard applies must file certain information with the NHTSA. Although Pioneer may not manufacturer equipment subject to a standard, it could be a final-stage manufacturer, as defined by 49 CFR Part 568, Vehicles Manufactured in Two or More Stages, and subject to both these regulations. I enclose a copy of each. If Pioneer determines it is a "final-stage manufacturer" then it would also be subject to the obligations of Part 568 (@ 568.6) and the requirements of Part 567 (@ 567.5) Certification, copy enclosed.

If Pioneer is a "final-stage manufacturer," it must file quarterly reports of production figures pursuant to 49 CFR Part 573, (@ 573.5 (b)) Defect Reports. I have also enclosed a copy of this regulation for your review.