Interpretation ID: nht72-5.31

DATE: 09/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Ingram Manufacturing Co.

TITLE: FMVSR INTERPRETATION

TEXT: I apologize for the delay in answering your letter regarding Part 585, Manufacturer Identification. You describe the vehicles you manufacture and ask whether you are a manufacturer within the meaning of the regulation and therefore required to submit information regarding your products.

Part 566 applies to manufacturers of motor vehicles and motor vehicle equipment to which a motor vehicle safety standard applies. "Motor vehicle" is defined in the National Traffic and Motor Vehicle Safety Act as "any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways". Since the portable tandem rollers you describe appear to be manufactured for construction or farm use you are not considered a manufacturer of motor vehicles and are not covered by Part 566. Therefore you are not required to submit information under that regulation. For similar reasons you are not covered by the certification requirements of Part 567 and 568 which you also mentioned.