Interpretation ID: aiam4385
Chief Product Engineer
E. E. Etnyre & Company
200 Jefferson Street
Oregon
IL 61061;
Dear Mr. Decker: This is in reply to your letter of July 30, 1969, to the Federa Highway Administration, that has been referred to this office. In your letter you ask for a yes or no answer to specific questions relative to certification of assemblies completed from chassis-cabs. The answers to your questions follow:; 1. *QUESTION:*>>>'We manufacture bodies that are sold through non-exclusive dealer that sells construction equipment. The dealers sale includes only the body and its mounting on a chassis-cab. The chassis-cab is furnished by the customer and is normally purchased through a second dealer that handles truck sales. The chassis-cab is delivered to our factory for the mounting of the body. Do we supply certification for the completed vehicle?'<<<; *ANSWER:*>>>The answer to your first question is yes, you would suppl certification to the dealer or distributor at the time of delivery of the vehicle.<<<; 2. *QUESTION:*>>>'If the answer to the first question is yes, do w remove the temporary certification label on the chassis cab (367.5), write the chassis-cab vehicle identification number on this and place this in our file as evidence that the vehicle we assemble has been furnished with a certified chassis- cab?'<<<; *ANSWER:*>>>A simple yes or no answer cannot be given to question No 2. The method you use in procuring and retaining information relative to the chassis-cab would be up to you. The procedure you describe, writing the chassis-cab identification numbers on the label and placing same in your file would be considered satisfactory.<<<; 3. *QUESTION:*>>>'With reference to the vehicle identification number paragraph 367.4(g)(4), do we supply only our vehicle identification (or serial) number?'<<<; *ANSWER:*>>>Yes, you would only supply your vehicle identification (o serial) number in accordance with Part 367.4(g)(2) of the regulation.<<<; 4. *QUESTION:*>>>'Paragraph 367.4(g)(2) requires the month and year o manufacture. It further states 'This shall be the time during which work was completed at the place of main assembly of the vehicle.' In a previous response to a letter of ours signed by Mr. F. C. Turner and addressed to Senator Charles Persy (copy enclosed). Mr. Turner stated that a FHWA ruling stated that a completed assemblege (sic) need only conform to the standards that were in effect at the time of completion of the chassis-cab. May we assume that the date we should supply on this requirement will be the month and year of manufacture as stated on the label in paragraph 367.5?'<<<; *ANSWER:*>>>Yes, the month and year of manufacture of the chassis-ca would be used to satisfy the requirements of 367.4(g)(2), month and year of manufacture.<<<; We trust this will clarify the situation for you. Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service;