Interpretation ID: nht72-5.24

DATE: 06/12/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: McLaughlin Equipment Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in further reply to your letters to the National Transportation Safety Board and the Secretary of Commerce that have been referred to this office.In your letter to the National Transportation Safety Board you discuss the remounting of old school bus bodies on new truck chassis and ask, what are the implications of a body shop taking the responsibility of modifying the vehicle?" It is assumed that when you refer to modifying you mean remounting a used school bus body on a new chassis.

Persons (Illegible Words) new chassis are considered to be manufacturers within the meaning of the National Traffic and Motor Vehicle Safety Act and specifically a final stage manufacturer as defined in Part 565 of Title as of the Code of Federal Regulations.

We appreciate your bringing this situation to our attention and presently have the matter under investigation.

If you are aware of any one currently involved in this type of business (Illegible Word) might not be aware of their responsibilities, please furnish specific details.

I am enclosing the following pertinent publications:

1. National Traffic and Motor Vehicle Safety Act.

2. Notice of Publications Change.

3. Part 356 of Title 69 of the Code of Federal Regulations - Manufacturer Identification.

4. Part 567 - Certification.

5. Part 565 - Vehicles Manufactured in Two or More Stages.

6. Part 573 - Defect Reports.

7. Part 574 - Tire Identification.

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