Interpretation ID: nht71-4.45

DATE: 11/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 25, 1971, concerning steps you plan to take to comply with the Certification regulations (49 CFR Part 567), which were amended on October 8, 1971 (36 F.R. 19593). You indicate that you plan to affix, in addition to the required Certification label containing the vehicle's gross vehicle and gross axle weight ratings, an additional "vehicle identification data plate" which would be attached to the driver's door panel inside the cab. This plate will specify an axle capacity for each axle and an additional gross vehicle weight rating, but here the figures will reflect the vehicle's maximum potential capability. The axle capacities on the vehicle identification plate will be the axle manufacturer's ratings, and added together will be the maximum allowable gross vehicle weight rating. It appears from your letter that you intend using the maximum potential capability of the vehicle as a substitute for listing gross axle and vehicle weight ratings for all available tire and wheel combinations, which was proposed as an option for manufacturers in a notice published on October 8, 1971 (36 F.R. 19617). Your question is whether, under the Certification regulations, you may affix the vehicle identification plate in addition to the required Certification label.

While we agree that a legitimate purpose may be served by the information you wish to provide on the vehicle identification plate, we consider that the manner in which you have chosen to furnish this information is inconsistent with the Certification regulations. Specifically, the inclusion of two different figures under the heading "Gross Vehicle Weight Rating" conflicts with the requirement that a single figure be provided. The figure on the vehicle identification plate may be frequently higher than that on the Certification label, and if followed might result in vehicle overload. Also, the summing of the axle manufacturer's ratings to arrive at a "gross vehicle weight rating" is not

wholly consistent with the definition of that term in 49 CFR @ 568.3, which calls for a manufacturer's figure based on the capacity limitations of the vehicle's tires, rims, suspension system and other components, as well as its axles.

If you wish to provide information based on the vehicle's axle capability, we prefer that it not be represented as a vehicle or axle weight rating, but that it be described as the axle manufacturer's rating of the axles.