Interpretation ID: nht75-6.2

DATE: 03/04/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gerard Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 4, 1975, requesting information on forms and information to be used in complying with NHTSA Certification regulations (49 CFR Parts 567, 568) and Manufacturer Identification regulations (49 CFR Part 566).

There are no special forms which the NHTSA provides for manufacturers for purposes of compliance with these requirements. Part 566 information may be furnished on a business letterhead. Part 567 and 568 information should be furnished in any form which complies with the prescribed requirements. Although the Certification requirements may be modified as the result of litigation, the NHTSA will consider compliance with the published requirements to meet any manufacturer's responsibilities for Certification under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1403).

If you have further questions, please feel free to write again.

YOURS TRULY,

GERARD, INC.

February 4, 1975

Office of Chief Counsel National Highway Traffic Safety Administration

We are in the beginning stages of manufacturing wrecker bodies to be mounted on truck chassis. We will mount some in our plant to complete the vehicle, but some will be shipped in kit form to our distributors for their installation.

I have contacted Mr. J. Leon Conner of the National Highway Traffic Safety Administration in Atlanta and he sent me parts 566, 567 and 568 in Title 49, Code of Federal Regulations. He also advised me that some of the requirements of these regulations are being reviewed in litigation proceedings in Washington.

We are desperately trying to get into a position to start shipping units, but their seems to be doubt as to what will be required, on our part, to certify the vehicles. Could you please furnish me the necessary information and forms so that we can comply to Federal Regulations.

J. T. Roberts -- VICE PRESIDENT-SALES