Interpretation ID: nht72-6.14

DATE: 11/10/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letters of September 25 and October 19, 1972. In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (@ 573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the reguations therefore apply to them.

Your letter of October 19 asks whether a person who installs a fifth wheel in a pickup truck is considered a "remanufacturer." Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22800, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.