Interpretation ID: nht72-5.9

DATE: 04/08/72

FROM: JOSEPH R. GORMAN FOR FRANCIS ARMSTRONG -- NHTSA

TO: Strick Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 25, 1972, enclosing sample certification labels and requesting our review and comments. The labels you have submitted follow correspondence to you from NHTSA dated February 18, 1972, wherein we disapproved an earlier format you wished to use. Your revised label consists of multiple listings using punched holes and overlays to indicate appropriate information.

We do not consider your revised label to be completely consistent with the Certification regulations (Part 567) in that the information is still presented in a way that is somewhat (and we might add unnecessarily) confusing. This confusion occurs because you do not fully delete information that is inapplicable to the vehicle in question. For example, regarding GVWR and GAWR in samples 2 and 3, you do not delete the entire number (leaving the zeroes and the suffix, lbs.) and it is not clear, in our view, whether the figures have been deleted or whether the label is disfigured. We believe the entire figure should be delted where it is not applicable. Similarly, in the case of month and year, and vehicle number, all the information you wish to omit should be completely deleted. This would require deletion of all months other than the month of manufacture and all numbers other than the vehicle number.

Finally, in using an overlay (sample 4), the overlay should be done in such a manner that the label does not give the appearance of having been tampered with.

We trust this clarifies the situation.