Interpretation ID: nht72-6.35

DATE: 02/02/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Triple H Frame Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 1, 1971, stating that you are an incomplete vehicle manufacturer, and asking for clarification of provisions of section 568.4 of Title 49. Code of Federal Regulations ("Vehicles Manufactured in Two or More Stages"), that refer to standards. You indicated in a phone conversation of December 17, 1971, with Michael Peskoe of this office that you manufacture travel trailer and mobile home frames, which may be equipped by you with both tires and a trailer hitch before being sent to the subsequent manufacturer for completion.

The reference to "standards" in @ 568.4, as you were informed on December 17, is to the Motor Vehicle Safety Standards (49 CFR 571.101 et saq.; formerly 571.21 et seq.) which apply to motor vehicles manufactured for sale in the United States. Copies of the standards, as you were also informed, may be purchased as indicated in the enclosed Notice of Publications Change.

You stated on December 17 that you planned to include the statement of 568.4(a)(7)(iii) as part of your certification label. Based on the information you have provided, this choice appears to be consistent with the requirements of Part 568. This is because the only motor vehicle safety standard presently applicable to trailers and mobile homes in Standard No. 108. (Illegible Words) Devices, and Associated Equipment. It appears quite possible that conformance to this standard would not be substantially determined by the design of the incomplete vehicle you manufacture.

We are pleased to be assistance.