Interpretation ID: nht73-4.14

DATE: 05/02/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Leaseway Transportation Corp.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter dated February 28, 1973 asking whether a planned wholly owned subsidiary of Leaseway Transportation Co. would be required to certify vehicles which it readies for service adding numerous components, including fifth wheels, for another company, also a wholly owned subsidiary of Leaseway Transportation Co. You state that under this arrangement title is always held by some component of the Leaseway organization.

Persons who install fifth wheels have generally been considered to be "final-stage manufacturers" under NHTSA certification regulations (49 CFR Parts 567, 568). Final-stage manufacturers, including those who complete vehicles for their own use, are required to complete such vehicles in conformity with applicable Federal standards, and to certify that conformity pursuant to 49 CFR Parts 567, 568. The NHTSA position is that the status of the title does not affect the basic responsibility of final-stage manufacturers to certify the conformity of vehicles that they manufacture.