Interpretation ID: nht75-4.4

DATE: 05/28/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Dairy Equipment Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Dairy Equipment's April 3, 1975 request for a discussion of what constitutes the manufacture of a trailer in cases where used components from an existing vehicle are involved.

In response to a similar request from the Truck Trailer Manufacturers Association, the National Highway Traffic Safety Administration recently prepared a comprehensive discussion of this subject, a copy of which is enclosed for your information.

YOURS TRULY,

April 3, 1975

David E. Wells, Chief Counsel Federal Highway Administration Department of Transportation

Confirming the phone conversation on March 31, 1975 between Mr. Kazmierazack of the D.O.T. and Mr. Ehinger of our company regarding the rebuilding of used trailers, Mr. Kazmierzack stated that we can obtain an official ruling by writing to your office.

We have customers who want to replace the tank of an existing semi-trailer tank motor vehicle utilizing the under carriage frame, suspension, axles, wheels, and tires from the old semi-trailer. Can you confirm to us in writing Mr. Kazmierzack's verbal approval to Mr. Ehinger that this type of repair does not incur any obligation to comply with current motor vehicle safety standards? We intend to retain the vehicle identification number, make, and model year.

Thank you for your consideration.

DAIRY EQUIPMENT COMPANY

Jim Koester Product Engineer