Interpretation ID: nht72-6.15

DATE: 08/16/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Thoroughbred Homes Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your inquiry of July 26, 1972, concerning the application of defect reporting requirements to mobile home manufacturers

Although mobile homes are not specifically mentioned in the National Traffic and Motor Vehicle Safety Act, they are considered to be motor vehicle subject to the Act. Because of their unique characteristics, mobile house have been categorized as a separate vehicle type, "mobile structure trailer," under the motor vehicle safety standards, 49 CFR Part 571. "Mobile structure trailer is defined in section 571.3 of that part.

The Defect Reports regulations (49 CFR Part 573) apply to manufacturers of all types of motor vehicles, including mobile structure trailers. They require manufacturers to report the number of vehicles manufactured during each calendar quarter. The description of the regulation's requirements in the article you enclosed is somewhat incomplete and accordingly we have enclosed a copy of the regulation for your guidance.

There are no specific forms which we require to be used in the submission of the specified informations. Copies of acceptable formats you may wish to use, however, are also enclosed.