Interpretation ID: 77-3.2

TYPE: INTERPRETATION-NHTSA

DATE: 06/15/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Hendrickson Mfg. Co.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your May 17, 1977, letter asking for an interpretation of "unloaded vehicle weight." You are interested specifically in whether cranes and drill rigs are included in the computation of a vehicle's "unloaded vehicle weight."

"Unloaded vehicle weight" is defined in the Code of Federal Regulations, Title 49, Part 571.3 to mean

the weight of a vehicle with maximum capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants.

Through a previous interpretation (copy enclosed), the National Highway Traffic Safety Administration (NHTSA) has determined that the "weight of the vehicle" includes the weight of those accessories that are installed on a vehicle before delivery and are not ordinarily removed.

From the description of the apparatus to which you refer in your letter, it would appear that the cranes or drilling rigs are not normally removed from the vehicle when not in use. Further, the removal of these pieces of equipment appears to be a cumbersome task. Accordingly, it is the opinion of the NHTSA that the weight of the equipment to which you refer would be part of the "weight of the vehicle" and, therefore, would be included in the computation of the "unloaded vehicle weight."

SINCERELY,

May 17, 1977

Attention: George Reagle National Highway Traffic Safety Administration

Hendrickson Mfg. Co. manufactures crane carrier and drill rig chassis. In order to determine if a few of these vehicles would be exempt from the Standard 121 by Section 3, Part d of the Standard, we require a clear interpretation of the term "unloaded vehicle weight".

Hendrickson Mfg. Co. builds a few crane carrier and drill rig chassis for operation over the public highway system, without special permit. Some of these chassis when completed, have a completed vehicle weight over 95% of the GVWR with a speed attainable in two miles of 45 MPH or less. These vehicles would be exempt from the Standard 121 if the unloaded vehicle weight is defined as being the same as the completed vehicle weight.

The confusion on the term "unloaded vehicle weight" comes about because it is necessary, at times, to strip the vehicle of heavy components, in order to comply with State weight restrictions. To reduce the weight of the vehicle, large and heavy components such as the four outrigger boxes (1000 lbs. each) and counter weight (over 1000 lbs) are dismantled from the vehicle. Because of the difficulty involved in the removal and installation, these heavy components would be removed from the vehicle only when necessary to comply with weight laws.

We petition the Administrator for a ruling that would clarify the term "unloaded vehicle weight" as would apply to crane carriers and drill rigs.

HENDRICKSON MFG. CO.

Kenneth R. Brennan Engineer

cc: M. A. SIGNA