Interpretation ID: nht72-5.19

DATE: 09/12/72

FROM: JOSEPH R. O'GORMAN FOR FRANCIS ARMSTRONG -- NHTSA

TO: Gardner-Denver Company

COPYEE: E. ROBERT ANDERSON -- REGIONAL ADMINISTRATOR, NHTSA REGION VI

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1972, to our Regional Office in Fort Worth, Texas, that has been referred to me, in which you request information concerning intermediate and final stage manufacturers.

I am enclosing, among other things, a copy of Part 568 of Title 49 of the Code of Federal Regulations that specifies the responsibilities of intermediate and final stage manufacturers. The final stage manufacturer applies the "Gross Axle Weight Rating" to the certification label in accordance with paragraph 567.5 of the Certification Regulation, a copy of Part 567 is also enclosed. The Preamble to Part 568 - Vehicles Manufactured in Two or More Stages, states ". . . By its definition a completed vehicle is one that requires no further manufacturing operations in order to perform its intended function, other than the attachment of readily attachable components and minor finishing operations . . ."

"In the event that a 'readily attachable component is a component regulated by the standard, such as a mirror or a tire, the final-stage manufacturer must assume responsibility and certify the vehicle even though he does not install the particular component. . . ." Persons who change tires, that are furnished by the final-stage manufacturer, prior to delivery to the user are not responsible for certification. However, he should assure himself that the tires he installs are compatible with the weight ratings on the certification label affixed by the final-stage manufacturer.

Final-stage manufacturers can rely on the documentation supplied by the incomplete and/or the intermediate vehicle manufacturer in establishing his weight ratings as long as he has no reason to believe it is false or does nothing in his operation that would change the ratings. Good business practices would dictate that a manufacturer would retain information supplied by other manufacturers that he uses as a basis for his certification.

If you have further questions, I will be pleased to answer them.