Interpretation ID: nht72-6.1
DATE: 05/19/72
FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA
TO: The United Methodist Church
TITLE: FMVSR INTERPRETATION
TEXT: This is in reply to your letter of May 2, 1972, in which you request information relating to your responsibilities under the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) and the Federal Motor Vehicle Safety Standards (FMVSS)and regulations issued thereunder.
Motor homes are not defined as such under the regulations. They fall in the category of a multipurpose passenger vehicle and would be subject to all of the standards that apply to that type vehicle.
I am enclosing the following publications. The answers to your questions can be found therein:
1. The Act
2. December 2, 1971, edition of the Federal Register - Recodification
3. Part 566 of Title 49 of the Code of Federal Regulations - Manufacturer Identification
4. Part 567 - Certification
5. Part 568 - Vehicles Manufactured in Two or More Stages
6. Part 573 - Defect Reports
7. Part 574 - Tire Identification
8. Notice of Publications Change
In the event you purchase an incomplete vehicle (chasis) from Cadillac, they will furnish the documentation as required by Part 568. In modifying the chassis you assume the role as an intermediate manufacturer and the recreational vehicle manufacturer becomes the final stage manufacturer. All terms are defined in Part 568.
Federal regulations concerning anti-pollution emission control devices are not the responsibility of the Department of Transportation, but of the Environmental Protection Agency. A copy of your inquiry is being furnished to the Director, Division of Certification and Surveillance, Mobile Source Pollution Control Program, 2565 Plymouth Road, Ann Arbor, Michigan 48105. He will, I am sure, forward such information as he deems appropriate.
If you have further questions, I will be pleased to answer them.
SINCERELY, UNITED METHODIST CHURCH
Norman E. Douglas Pastor and Student Chaplain Alfred, New York
MAY 2, 1972
Motor Vehicle Programs Administrator National Highway Traffic Safety Admin.
Dear Sir:
I am interested in beginning a proposed project for modification of an available chassis for use as base for motor homes. The Cadillac commercial chassis is used by coach builders for hearses and ambulances. I have conceived the idea of suitable modifying this chassis for use by Recreational Vehicle Manufacturers for the use in motor homes. I have completed a pilot project, taking the chassis from a used hearse, and combining it with a commercially built travel trailer to make a 24 foot motor home. This vehicle has been registered in New York State, and had successfully completed over 4,000 miles, including a winter trip to Florida.
I am now in communication with the Cadillac Division of General Motors, seeking to persuade them of the suitability of this chassis for such use. The chassis changes I found necessary involved relocating the dash, driver controls and driver seating to a cab-forward, over-engine position. This involved re-routing steering, braking and engine controls. Beyond this the Cadillac chassis was used almost completely intact.
In anticipation of using new Cadillac chassis for such modification, could you please tell me what safety regulations, certifications and/or testing would be necessary prior to selling such modified chassis to the Recreational Vehicle trade? Would you please send me copies of what would be construed as applicable regulations, please?
Could you also outline for me, in rough fashion, the respective areas of responsibility of Cadillac Division as original manufacturer, of my own firm as chassis modifier, and of the Recreational Vehicle manufacturer as assembler of the final vehicle?
It appears at present that I will have to operate separately from the Cadillac Division, dealing directly with the (Illegible Words). If a large enough market appears, I will need to know what federal regulations must be complied with before our project can begin. Your help in this field will be gratefully appreciated.
VERY SINCERELY,
Norman E. Douglas