Interpretation ID: nht70-2.23

DATE: 08/27/70

FROM: AUTHOR UNAVAILABLE; R.A. Diaz; NHTSA

TO: Lanes Auto Sales

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter in which you asked about the requirements of the Federal motor vehicle safety standards in regard to combination of new and used components.

In your first group of questions, you asked whether you could put a used fifth wheel or a used dump body on a new truck. The answer is yes, but the finished vehicle must conforms to all the motor vehicle safety standards applicable to that type of vehicle at the time it is completed. At this time, probably the only standard that would require action on your part would be Standard 108 on lighting systems, Other Standards applicable to trucks have been proposed, however, which will require you to take further action or observe certain limits in the future, and you should take stops to keep informed of the applicable requirements. I an enclosing a copy of current standards and regulations, and if you will fill out the enclosed form you will be put on a smailing list for notices that apply to your operations.

Also in reference to this group of questions, the requirements on persons who complete vehicles are the same whether they own the trucks or do the work for a dealer or for the ultimate user.

You also asked about building "a trailer out of new frames using old axles, brakes, and wheels, with parts made before 1966". In such a case, the vehicle that you build must conform to current applicable safety standards, unless it is a repair job done on a presently registered used vehicle that will continue to be registered as a used vehicle. Whether you call the trailer a used or new one depends on the State requirements - you may do whatever is permitted by your State licensing authorities in this regard.

Finally, you asked whether, when you build a trailer with used wheels, axles, bearings, brake drums, and springs, you may put on used tires. At present you certainly may do so, since there is no Federal safety standard for truck tires. It is probable that one will be issued in the future, however, and if and when such a standard becomes effective, any tires you use must meet the requirements of that standard.

Please let us know if we can be of further assistance.

Enclosures