Interpretation ID: aiam2787
Ullman
Fowler & Jeffries
Inc.
2231 Devine Street
Columbia
SC 29205;
Dear Mr. Fowler: This responds to your March 6, 1978, letter asking about the complianc responsibilities of a final-stage manufacturer who mounts a body on a motor vehicle chassis. In the situation you describe, the chassis would have been tested for compliance with the standards by the chassis manufacturer and the body would have been tested by the body manufacturer. You ask whether the final assembler would be required to crash test the vehicle as assembled.; The chassis manufacturer has responsibilities for compliance wit Federal safety standards that are outlined in Part 567, *Certification*, and Part 568, *Motor Vehicles Manufactured in Two or More Stages*, of our regulations. The chassis manufacturer must include with its chassis an incomplete vehicle document that describes how to complete the vehicle without impairing the compliance of the chassis with Federal safety standards. Although not required by our regulations, body manufacturers often provide documents addressing the compliance of their vehicle bodies with applicable safety standards. If a body that complies with Federal standards is mounted in accordance with the instructions of the incomplete vehicle document, the final-stage manufacturer can ordinarily assume that the completed vehicle complies with the safety standards. Based upon this assumption, it can certify that the vehicle complies with all applicable standards.; By following the instructions of the incomplete vehicle manufacture and relying upon the statements of the body manufacturer, the final-stage manufacturer would be considered to have exercised due care in ensuring that the vehicle complies. However, if the final-stage manufacturer does not follow the incomplete vehicle manufacturer's instructions or in some way makes a major modification that would affect the compliance of the vehicle, it might become necessary for it to undertake some further testing to ensure continued compliance. The amount of further testing, in these instances, would depend upon the extend of modification of the vehicle body or chassis.; For your information, our safety standards and regulations are locate in Volume 49 of the Code of Federal Regulations Parts 501 *et seq*. I am enclosing a sheet which details the applicability of Federal standards to various vehicles.; If after reading this letter, you still have questions that require meeting, contact Roger Tilton of my staff.; Sincerely, Joseph J. Levin, Jr., Chief Counsel