Interpretation ID: nht68-3.17

DATE: 03/02/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Field Body Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, in regard to certification of your product and questions regarding interpretation of the Chassis-Cab regulation.

In regard to your letter furnishing us certification information, what you have provided will be very useful to us; however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with an actual sample of your certification label and the method of attachment.

Concerning your request for clarification in regard to the extent of responsibility for adherence to applicable safety standards to your type of vehicle, the following should be of assistance:

First, your vehicle, completed, falls into the category defined as a "truck" and as such, must adhere to Safety Standards 102, 107, 108, 205 and 209. We have enclosed a copy of the Federal Register, Volume 32, No. 23, dated February 3, 1967, and several other pertinent amendments.

Regarding extent of responsibility of the chassis-cab body manufacturer, and final assembler of the units into a completed vehicle, these are clarified in Section 2 you refer to in your letter. I assume this is Federal Register Volume 33, No. 1, dated January 3, 1968, "Notice of Ruling regarding Chassis-Cabs," but in case it is not I am enclosing a copy for your reference. This notice defines two main points which I will endeavor to state in a few words as follows:

If the original manufacturer of the chassis, after January 1, 1968, cannot or does not include all the safety standard regulations required for the type of end product or completed assemblage, then the final assembler is responsible to certify that all applicable safety standards are included and the vehicle is so certified and labeled.

Thank you for your interest in the safety program.