Interpretation ID: nht72-5.43

DATE: 08/23/72

FROM: LAWRENCE R. SCHNIEDER FOR RICHARD B. DYSON -- NHTSA

TO: Truck Body Equipment Association Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 20, 1972, concerning the Certification of vehicles having a dual purpose. You ask how you should determine weight ratings when a vehicle is intended to carry loads of varying weights, and cite as an example a vehicle designed to carry both gasoline and #2 fuel oil. You indicate that you are presently placing a second certification label on the vehicle, a copy of which you enclose, to inform the customer of the allowable weights.

The method you are using may not be consistent with the Certification regulations, as our position is that weight or axle values that may be confused with GAWP or GVWR cannot appear on the Certification (Part 567) label, or on adjoining labels. This will be the case if the "total" in the "chassis rated weight" column differs from the figure you provide on the Part 567 label for GVWR (assuming that the front and rear axle figures are identical to the GAWR figures on the Part 567 label). Gross vehicle weight rating is not necessarily the total of all axle weight ratings.

We recommend that the weight ratings be computed on the basis of the heaviest load that the vehicle is designed to carry, without attempting (for certification purposes) to anticipate the density of particular cargoes.