Interpretation ID: nht79-4.8

DATE: 03/13/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Thomas Built Buses Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 28, 1979, letter asking about the remanufacturing of vehicles using old chassis and new bodies. In particular, you ask whether these vehicles must comply with the new safety standards.

The remanufacturing operation that you mention need not comply with the new safety standards. Such a remanufactured vehicle may need to comply with the safety standards in effect on the date of manufacture of the used chassis. Otherwise, there might be a rendering inoperative of the compliance of the vehicle with the safety standards. I am enclosing a copy of an interpretation that discusses the remanufacturing issue.

SINCERELY,

Thomas BUILT BUSES, INC.

February 28, 1979

Office Of The Chief Counsel U.S. Department of Transportation

Attn: Roger Tilton

Subject: Body Re-Mount

Dear Mr. Tilton:

We are inquiring with respect to the mounting of a "new" body on an "old" chassis.

In reviewing previous rulings, we find numerous references to the opposite e.g. "new" chassis - "old" body.

It is our understanding that the chassis since it constitutes what is considered the "motor vehicle" is the ruling factor. In other words, any replacement body should and must meet at least the Federal Standards in effect at the time of the manufacturing date of the chassis. It is preferred that the body meet the Federal Standards in effect at the time of body's manufacture.

While you personally may not handle this particular segment of the standards, we would appreciate your forwarding our inquiry to the proper party.

Thanking you in advance, we remain

James Tydings, Specifications Engineer