Interpretation ID: nht71-5.19

DATE: 12/10/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 1, 1971, enclosing a diagram of a revised "Vehicle Identification Plate," and requesting our approval, based on the Certification regulations. Your submission of this revised diagram is in response to our letter to you dated November 10, 1971, wherein we disapproved of an earlier version of the identification plate due to the manner in which the axle manufacturer's ratings of the axles were presented.

In your revised diagram, you refer to the ratings in question as the axle manufacturers "gross weight ratings." We believe that this language is still subject to being easily confused with the GAWR required on the Certification label, and we cannot conclude that wording the label in this fashion is consistent with the Certification regulations.

In our letter of November 10 we stated, "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 manufacturers rating of the axles." Thus, in our opinion elimination of the words "gross weight" from your revised label will eliminate the conflict between your vehicle identification plate and the Certification requirements.