Interpretation ID: nht74-5.17

DATE: 03/01/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 18, 1973, inquiring whether a manufacturer would be an intermediate or final-stage manufacturer if he installs truck bodies or material handling devices (frequently final-stage manufacturing operations) but he expects that a later manufacturer will either extend the chassis frame or add a third axle. These additions are necessary to make the vehicle safe to operate.

In most cases, we would consider the manufacturer in question to be an intermediate manufacturer. Under the definitions of "completed vehicle," "intermediate manufacturer," and "final-stage manufacturer" (49 CFR 568.3), the manufacturer would be a final-stage manufacturer only if, at the time he completes his manufacturing operation, the vehicle requires no further manufacturing to perform its intended function, unless the further manufacturing involves only "readily-attachable components."

In the case you present, the vehicle cannot perform its intended function unless further modifications are made. That it be able to perform its intended function implies that it be able to do so safely. The answer ultimately depends, therefore, on whether the additions that will be made to the vehicle involve only readily attachable components. We would not generally consider either an extension of the chassis or the addition of a third axle to involve only readily attachable components.

Of course, in those cases where no further modifications are necessary for safe operation, the crane or body installer will be the final-stage manufacturer.