Interpretation ID: nht72-5.50

DATE: 03/30/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Champion Carriers Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 25, 1972, wherein you state that you manufacture "off-highway vehicles for cranes, drill rigs and truck terminals" and request that we advise you of the requirements regarding manufacturer registration which became effective February 1, 1972. In a telephone conversation with Mr. David Fay of NHTSA on March 23, 1972, you indicated further that the type of vehicle you manufacture is represented by the picture at the bottom of your January 25 letter to us.

We would not consider these vehicles to be "off-highway vehicles." In our view they appear to be similar to truck tractors, and have a primary purpose of transporting other vehicles (which may be off-highway vehicles) over the public roads. Consequently, we would consider them to be trucks under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1331 et seq.) and the motor vehicle safety standards and regulations issued pursuant to the Act.

As a manufacturer of such vehicles you must comply with the Manufacturer Identification regulations (49 CFR Part 566) and a copy of them is enclosed as you requested. Also enclosed is a copy of the National Traffic and Motor Vehicle Safety Act, and information on how to obtain copies of the Motor Vehicle Safety Standards and regulations.

IF YOU HAVE FURTHER QUESTIONS, PLEASE WRITE.