Interpretation ID: nht67-1.33

DATE: 03/18/67

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Petroleum Equipment Institute

TITLE: FMVSR INTERPRETATION

TEXT: The General Counsel of the Department of Transportation has asked that(Illegible Word) further to your letter of February 13, 1968 to the Department of Transportation.

Enclosed in a copy of the National Traffic and Motor Vehicle Safety Act of 1966, published Federal Motor Vehicle Safety Standards and a regulation and ruling issued December 29, 1967 pertaining to "chassis-cabs" and persons who combine "chassis-cabs" with motor vehicle bodies or other like structures.

Based on the limited information given in your letter it appears that members of your organization who affix a task to a chassis-cab, as defined in(Illegible Word) 5.3(b), will be responsible for "(1) compliance of the combined assemblage with. . .standards in effect in the date of(Illegible Word) of the chassis-cab. . .not already. . .certified to by the chassis-cab manufacturer, and (2) compliance with all applicable standards in effect on the date of manufacture of the chassis-cab to the extent that the addition of a body or other structure to the chassis-cab affects the chassis-cabs previous conformance with applicable standards."

As to the certification requirement, which is set forth in section 114 of the National Traffic and Motor Vehicle Safety Act of 1966 (copy enclosed) and amplified by a notice issued October 31, 1967, ((Illegible Words) than requirement as it relates to your organization members would be limited to a situation where your members combine a chassis-cab which has not been certified to be in conformance with Standard 108 with a body or other like structure and sells the combined assemblage to a distributor or dealer. In this case certification of compliance with the lighting standard (Standard No. 108) would be mandatory.

The Petroleum Equipment Institute(Illegible Word) will be added to the Federal Highway Administrator's Office of Public Affairs mailing list and it will(Illegible Words) published rulings and regulations relating to traffic safety. Additionally, enclosed is a copy of present regulations and rulings published to date.

I hope this letter adequately answers the question you raise.