Interpretation ID: nht76-3.41

DATE: 11/10/76

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. J. W. Lawrence

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your July 19, 1976, letter requesting an interpretation of @ 567.4(g) of 49 CFR Part 567, Certification, with respect to the listing of pound and kilogram weight ratings.

You have cited my June 30, 1976, letter to Toyota Motor Sales, which stated that weight ratings may be expressed in both pounds and kilograms, provided that each kilogram rating appears "after" the corresponding pound rating. You have also cited 49 CFR Part 567.4(g), which specifies that "Gross Axle Weight Rating" or "GVWR" be "followed by" the pound ratings for each axle, identified in order from front to rear.

If A and B are two items of information on a label, the NHTSA interprets "A is followed by B" to mean "B appears to the right of A or below A or both." We consider "B appears after A" to have the identical meaning.

The pairing of pound and kilogram ratings that is permitted by the interpretation in the Toyota letter must appear hierarchically within the sequence of axle ratings specified in @ 567.4(g). For example, the following listing is permitted:

GAWR FRONT 2000lbs/907kgs Rear 2200lbs/998kgs while the following listing is not permitted:

GAWR FRONT 2000lbs REAR 2200lbs (907kgs/998kgs).