Interpretation ID: 77-2.31

TYPE: INTERPRETATION-NHTSA

DATE: 05/11/77

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Chief Counsel

TITLE: FMVSS INTERPRETATION

TEXT: We seek your help in the clarification and interpretation of federal certification regulations, with specific emphasis on the assignment of responsibilities to the final manufacturer of trailerized and truck mounted tanks. A number of serious problems are encountered in the fulfillment of the responsibility for certification. For example, after a customer picks up his tank and leaves our premises it is impossible to know exactly what changes in tires and chassis or what product and what quantity of product he may haul in the tank.

Tanks may haul such products as ice cream mix, whey, frozen orange juice, wine, additives and various other products that have considerable variation in density. Recently, a number of our tanks were used for hauling water in place of bulk milk or cream, due to the drought conditions existing in Wisconsin. Therefore, it is our firm conviction that the manufacturer should show on the certification both the gross vehicle and axle weight rating in pounds for the completed vehicle. It would then become the responsibility of the operator of the vehicle to see that the volume of product hauled in relation to density is within the vehicle load carrying limitations. It is certainly within control of the operator to limit the loading of his vehicle, to select replacement tires required to handle the load and to replace the chassis for his tank that meets the load carrying requirements of his vehicle.

So that each vehicle is operated safely and within federal safety regulations, we urge your interpretation of the certification regulations whereby the final manufacturer would certify the ratings of the completed vehicle in the amount of weight specified, as a better and more workable certification procedure.