Interpretation ID: nht73-2.6

DATE: 05/18/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Femco Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 16, 1973, inquiring whether any Federal laws apply to your building and installation of a man-lift (pictures of which you enclose) in a completed pick-up truck. You state you understand that if the man-lift is installed on a completed vehicle, you are not considered the final-stage manufacturer.

Based on the information you have provided us, we believe your interpretation to be correct. It does not appear that you have altered the pick-up truck in a way that would make your company responsible for conformity with Federal safety standards or regulations.

The NHTSA has proposed certain requirements for vehicle alterers (copy enclosed). These requirements would very likely apply to you, when effective, if the addition of the man-lift occurs before the purchase of the pick-up truck for a purpose other than resale.