Interpretation ID: aiam1790
Executive Vice President
Truck Body and Equipment Association
5530 Wisconsin Avenue
Suite 1220
Washington
DC 20015;
Dear Mr. Sweet: This is in response to your petition of January 31, 1975, in which yo requested relief from the requirements of Standard No. 121 as it applies to final-stage manufacturers. Your petition stated that the incomplete vehicle manufacturers have not furnished advance information on the limits of the final body configurations imposed by Standard 121, in time for final-stage manufacturers to design and prepare to manufacture conforming bodies after the standard goes into effect on March 1.; The NHTSA recognizes the difficulties posed by this lack of informatio for final-stage manufacturers. Of course, completed vehicles are required to conform only to standards in effect on the date of completion of the chassis, so that the problem does not materialize until chassis completed on or after March 1 begin to be received and worked on by the final-stage manufacturers. On the other hand, Standard 121 probably will require redesign of some body configurations in order to remain within the limits set by the chassis manufacturers.; We do not believe that a delay in the application of Standard 121 t multistage vehicles would be advisable. As you know, the agency did consider postponing the standard in December, and decided against it based partly on information indicating that such a last-minute delay would be disruptive and wasteful. The conclusion would be even more valid today. Since the standard applies only to completed vehicles, it could not be suspended with respect to completed vehicles with the chassis still required to comply. Even if this were possible, it might cause anomalous and even hazardous results, since the final-stage manufacturers could disregard any design cautions of the chassis manufacturers, and could remove or disable portions of the chassis brake systems. Furthermore, even a complete delay in the standard with respect to the classes of vehicles with which you are concerned would probably not accomplish your purposes, since the chassis manufacturers could not be expected to produce chassis conforming to the standard, with accompanying documentation, during the period of delay.; For these reasons, your petition for delay of Standard 121 is denied You and your members may be assured that, within the limits of the law, this agency will be understanding in its approach to problems experienced by final-stage manufacturers as they bring their vehicles into conformity with the new standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;