Interpretation ID: nht69-1.41

DATE: 07/09/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Tank Truck Service

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letters dated April 7 and June 3, 1969, in which you request clarification of the Certification Regulations that become effective with vehicles manufactured after August 31, 1969.

You are correct in your interpretation that the certification should be attached to the door post or the other locations in the cab of a vehicle that are specified in section 367.4(c). You should note, however, that the label is not a "body certification", as you describe it, but certifies that the entire vehicle conforms to applicable safety standards.

With regard to your suggestion that the label should be placed on the body rather than the chassis of the vehicle, since in the case of your vehicles the body is likely to last longer, it has been determined that uniformity of location is of primary importance for enforcement purposes. The life of various components varies, as you know, from one vehicle to another. These regulations do not cover the situations in which used components are recombined with new ones.

Thank you for your cooperation.