Interpretation ID: nht70-1.39

DATE: 02/02/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Holan; Division of Ohio Brass Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 19, 1970, in which you asked whether section 371.13, Labeling of Chassis-Cabs, requires chassis-cab manufacturers to indicate the date of manufacture b month, day and year, or whether mouth and year alone is sufficient.

The wording of the section is "date of manufacture", without further elaboration. While in most contexts this phrase refers to a specific day, the present scheme of labeling and certification lands as to the conclusion that the month and year will be sufficient to satisfy the intent of the regulation.

The main regulator purpose of the requirement is to make it clear which standards are applicable to the chassis-cab and therefore to the complete vehicle under our rulings. A similar purpose is fulfilled by the date-of-signature require out in the Certification Regulations, 49 CFR Part 367, and there the requirement is simplicitly stated as month and year only. It is the practice of the National Highway Safety Bureau to make standards effective on the first day of month and therefore it is unnecesary to require manufacturers to incur the extra expense of a daily lable change.

We are pleased to be of assistance.