Interpretation ID: nht74-3.23

DATE: 10/02/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bendix Home Systems Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 21, 1974, asking whether the terms "loaded vehicle weight" or "rated cargo load" include the liquid for both water potable tanks and waste holding tanks in the case of motor homes and multipurpose passenger vehicles. You indicated in a phone conversation with Mike Peskoe of this office on September 4, 1974, that the purpose of your question is to determine whether the weight of this liquid would be included in a manufacturer's computation of gross vehicle weight rating. You also ask for definitions of "loaded vehicle weight" and "rated cargo load."

It is not required that a determination of gross vehicle weight rating include the weight of a full amount of liquid in both the potable and the waste holding tanks on the assumption, stated in your letter, that in actual use the holding tank is empty when the potable tank is filled, and the liquid is drawn gradually from one tank to the other. It should be placed in the potable tank for determining GVWR, for this more closely reflects a new vehicle configuration.

The term "loaded vehicle weight" is not defined in the Federal motor vehicle safety standards or regulations nor are we aware of its use therein. A related term, "maximum loaded vehicle weight," is defined in Motor Vehicle Safety Standard No. 110 (49 CFR 571.110), but this definition is not applicable to your question. "Rated cargo load" is also not specifically defined, but is used in the requirements for gross vehicle weight rating in 49 CFR 567 and as a test condition in Motor Vehicle Safety Standard No. (Illegible Word) It is intended to mean the manufacturer's good faith rating of the weight of a vehicle's full cargo.