Interpretation ID: nht73-6.11
DATE: 06/26/73
FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA
TO: Taylor Machine Works Inc.
TITLE: FMVSR INTERPRETATION
TEXT: This is in reply to your letter of May 25, 1973, to Michael Peskoe of this office, requesting clarification of the regulations regarding the certification of motor vehicles. You enclose an incomplete vehicle document concerning a particular tractor, a certification label you would affix to that tractor after its completion, a drawing of a trailer certification label, and a sample quarterly report of production figures for vehicles manufactured by your company.
Mr. Peskoe indicated to you over the phone that in meeting your certification responsibilities for these vehicles, they are certified independently of each other. It appears from your letter that this approach, which is the correct one, is the approach you are using.
With reference to your responsibilities for the certification of the tractor, if the truck does not have a certification label attached to it when you receive it, it is true that when you complete it by mounting a fifth wheel you must then attach a certification label. The label you enclose (exhibit 1) contains the necessary information in the appropriate order. You should obtain the information for the label primarily from the incomplete vehicle document, but may, as you state, rely on your own engineering judgment or contact the truck manufacturer. If, however, in relying on your own judgement you depart from the information contained in the incomplete vehicle document, you may be responsible for failures of the vehicle to conform to applicable standards and regulations.
The sample trailer certification label which you have submitted is not consistent with the certification regulations. We have taken the position that the information must be presented on the label in the form and in the order specified in the
2 regulations. With respect to your sample label, the regulations do not presently call for a Kingpin rating. Although we have just proposed to require a weight rating for the trailer coupling, this information should not now be included on the label. The regulations also do not permit ratings for tandem axles to be stated as tandem ratings. Each axle must be independently identified and a separate rating provided for it. Moreover, tire sizes are permitted to be specified only in conjunction with weight ratings. There are no provisions for the listing of plies, apart from their inclusion in a tire size designation, or for the listing of an inflation pressure. Again, information that is not specifically required cannot be inserted between items of required information, and your drawing of a trailer is not permitted unless it is placed after the required information. Finally, the regulations call for gross vehicle weight rating (the phrase "gross trailer weight rating" is inappropriate) to follow the gross axle weight ratings, and the order in which you present this information must be reversed. I believe you should reexamine the Certification regulations in order to obtain specific guidance on the order and form of the required information.
The sample quarterly production report you submit conforms to the requirements of section 573.5 (b) of the Defect Reports regulations. However, that section requires only the reporting of the number of vehicles, identified by make, model, and model year (if appropriate). While we are happy to receive the additional information you provide, you are not required to furnish it to us.
Yours truly,
TAYLOR MACHINE WORKS, INC.
May 25, 1973
Michael Peskoe U.S. Department of Transportation
Dear Mr. Peskoe:
Reference is to our conversation of May 23, wherein we asked for clarification on the Department of Transportation's vehicle certification laws.
We discussed, Taylor Machine Works is a manufacturer of dump trailers with but 90% of them used in the construction industry and about 10% of them in the refuse industry. We normally manufacture the trailer complete and in about 80% of our cases, we mount them on some user's new truck. Also, we mount the fifth wheel and the hydraulics for actuating the dump cylinder on the trailer.
Normally when we receive a new truck, they have with the vehicle a vehicle Manufacturer Document. I have enclosed a copy of such a document of a specific truck which happens to be an International Harvester Company truck #75797CGB14608. As you can see from this document, IH has placed a gross vehicle weight rating of 44,860 pounds on the truck tractor. The truck's front axle has a 10,860 rating and each of the tandems have a 17,000 pound rating. Also, this truck has affixed to the facing of the door on the operator's side a serial plate tag which states a gross vehicle weight rating of 44,860 pounds.
In weighting the truck, we found the following to be approximately the weights of the truck with the fifth wheel installed and ready to connect a trailer. (See diagram). The two tandem drive axle total 8,300 pounds, the steer axle of the truck 7,120 pounds. Upon connecting our trailer to this truck, we found the weights to be as follows: steer axle of the truck 7,290 pounds, truck tandem 10,640 pounds, and trailer tandem 7,470 pounds. (See attached sheets).
This was a typical installation that we make on our trailers. Since the rear axle rating is a total of 34,000 pounds, we feel that the vehicle will accept approximately 24,000 pounds on the king pin from the trailer and our componentry in the tandem axle has a rating of 36,000 pounds. Therefore, we would mark on the
2 certification plate that trailer T-3272 has a 60,000 pound rating. We would attach the marked certification plate to the trailer which shows the approximate king pin load of 24,000 pounds and tandem rating of 36,000 pounds and gross trailer weight rating of 60,000 pounds.
We understand from our conversation that if this truck does not have truck vehicle rating tag on it or the tractor, when we mount the fifth wheel we must put a vehicle certification plate similar to our Exhibit No. 1 which rate this truck showing what its capacity would be to the best of our knowledge or by contacting its manufacturer. Also, we would enter on a quarterly basis a report similar to the attached sample copy. We have taken this IH truck and trailer T-3272 and entered it on this report and would like for you to review if and make your suggestions.
Mr. Peskoe, if any of the above is not in keeping with what your office desires, please advise and we will make the necessary corrections. Also, on any other items concerning the certification of our product, we would be very grateful if you would make recommendations.
(Illegible word) you very much.
Very truly yours,
J. T. Monk Director of Engineering
Attachments
VEHICLE CERTIFICATION
EXHIBIT NO. 1
COMPLETED VEHICLE MANUFACTURED BY: TAYLOR MACHINE WORKS, INC.
DATE OF COMPLETION: MAY, 1973
INCOMPLETE VEHICLE MANUFACTURED BY: INTERNATIONAL, HARVESTER COMPANY
DATE INC. VEHICLE MFG FEB., 1973
GROSS VEH. WEIGHT RATING 44,860 LBS
GROSS AXLE WEIGHT RATING FRONT, 10, 860 LBS.
1st INC. 17,000 LBS.
REAR 17,000 LBS.
THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOP VEHICLE SAFETY STANDARDS IN EFFECT IN MAY, 1973
VEHICLE ID NUMBER: 75797CGB14608
TYPE VEHICLE CLASSIFICATION: (X) TRUCK () BUS () MPV
Title 49 - Code of Federal Regulations Part 568 - Vehicles Manufactured in Two or More Stages. Section 6 - Canada Motor Vehicle Safety Regulations
International Harvestor Company 401 North Michigan Avenue Chicago, Illinois 60611 U.S.A. Date of Manufacture: 2-73 VIN: 75797CGB14608 GVWR: 44860 GAWR: Front Axle 10860 1st Intermediate 17000 2nd Intermediate Rear Axle 17000
Vehicle Type: *[Truck or MPV (Multipurpose Passenger Vehicle)]
TRUCK TRACTOR
The following listing of PWVSS (Federal Motor Vehicle Safety Standards) apply to this incomplete vehicle as of the date shown above. This vehicle fully conforms to those standards preceded by a double asterisk (**) as of the date shown above.
* It is the responsibility of the final-stage manufacturer to specify on the certification label the proper vehicle type for which this vehicle is completed.