Interpretation ID: nht75-3.23

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Compact Van Equipment Co. Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 17, 1975, inquiring as to the regulations to which you may be subject by manufacturing and selling interior shelving, interior safety bulkheads, and roof mounted ladder carriers for Ford Econoline vans.

The National Highway Traffic Safety Administration has issued regulations covering the alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. (49 CFR @@ 567.7 and 567.8; copy enclosed). Under these regulations, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than "readily attachable" components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.

From the description of your products, it appears that no special expertise or tools are required for their installation. They would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that they are "readily attachable", and that an alterer label is therefore not required when these products are installed.

The only Safety Standard that might apply to your products is Standard No. 302, Flammability of Interior Materials (copy enclosed).

In addition, as items of motor vehicle equipment, your products are subject to the requirements of the National Motor Vehicle and Traffic Safety Act of 1966, as amended, and must therefore be free from safety-related defects.

If you have any further questions, feel free to write again.

SINCERELY,

July 17, 1975

James Holtkamp Office of Chief Council National Highway & Safety Administration Department of Transportation

Persuant to our phone conversation of July 16, '75, I am inquiring about what regulations my company would be subject to when we begin to manufacture and sell interior shelving, interior safety bulkheads, and roof mounted ladder carriers for the small Ford Econoline type van truck.

I am aware of Motor Carrier Safety regulations regarding the use of safety bulkheads on vehicles engaged in inter-state commerce (U. S. Dept. of Transportation, Federal Highway Adm. Bureau of Motor Carrier Safety regulation, Title 49, Chapter 111, subchapter B., Part 393-104

Also, I am aware of certification requirements for vehicles, partiall completed vehicles, and bodies and trailers.

However, to my knowledge there are no regulations pertaining to the type of equipment I am requesting further information on.

Would you be kind enough to pass on to me any information that I should have and outline any regulations that I might be subject to as a manufacturer, or installer of this type equipment.

Please note, that normally my company would not take title to any vehicle that our equipment is manufactured for.

Wade H. Barrineau, 111 President