Interpretation ID: nht73-4.42

DATE: 08/09/73

FROM: AUTHOR UNAVAILABLE; James E. Wilson; NHTSA

TO: Truck Trailer Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 5, 1973, requesting a uniform location for trailer certification labels required by both the Hazardous Materials regulations (49 CFR @ 178.340-10) and NHTSA Certification regulations (49 CFR Part 567). You request that location be specified as the "forward half of the left side of the trailer."

NHTSA Certification regulations, as you note, presently provide that the certification label for trailers must be placed on the "forward half of the left side of the vehicle" (49 CFR @ 567.4(d)). This requirement does not distinguish between the frame and the tank shell, and the reference to "vehicle" in the language of the provision is considered inclusive of both. The Certification regulations therefore appear to permit the location of the label that you request.

I note, however, that drawings in your letter, those titled "Acceptable Locations of Certification Labels" and "Suggested Locations for Certification Labels", picture as an appropriate label location the front of the vehicle.

This location is not permitted by the NHTSA Certification regulations, which clearly call for the label to be affixed to the vehicle "left side". While it is not clear whether you intended to request that the label be permitted to be affixed to the vehicle front, we do not find sufficient justification in your letter to depart from the existing requirements in this regard.