Interpretation ID: nht81-2.42

DATE: 07/01/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Airstream

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 26, 1981, letter asking for a clarification of the certification requirements applicable to vehicles that you manufacture. The units frequently are completed by you, but in some instances, they are shipped to a final manufacturer for completion of the interior work.

Your first question asks whether you should label the vehicle as a final-stage manufacturer since your vehicle is road worthy and needs only the addition of an interior finish prior to sale. In order to certify the vehicle as a final-stage manufacturer, the vehicle that you produce must be a completed vehicle (49 CFR Part 568). A completed vehicle is one that is finished and requires no further manufacturing operations to perform its intended functions with the exceptions of minor finishing operations or readily attachable components. If your vehicle is completed in a manner that it can perform its intended functions, you may label the vehicle as a final-stage manufacturer. The person performing alterations on your vehicle may then be required to add an alterer's label.

If the finishing operation that will be made to your vehicle is more than the attachment of readily attachable components or minor finish work, the person doing the finishing work may label the vehicle as a final-stage manufacturer. In determining whether the installation of a bathroom, kitchen, furniture, beds, appliances, or seats is an installation of readily attachable components, you should consider whether it requires special expertise or tools. If it requires either, it is not the installation of readily attachable components.

Your second question asks whether your vehicle would be considered a chassis-cab in those instances where another manufacturer might be attaching a final-stage label. The answer to this question is no. The definition of chassis-cab in part 567, Certification, states that it is a vehicle with a completed occupant compartment that needs only the addition of work performing or load carrying components to complete its function. It appears that your vehicle does not have a completed occupant compartment and, therefore, would not be considered a chassis-cab.

Finally, you ask what will happen if you label the vehicle as a final-stage manufacturer and a subsequent manufacturer significantly alters the vehicle. You ask whether you could treat the vehicle as an incomplete vehicle and furnish the documentation required by Part 568. If you label the vehicle as a final-stage vehicle, you cannot treat it as an incomplete vehicle. However, you may convey information similar to that conveyed in an incomplete vehicle document to the subsequent manufacturer to ensure that it can comply with all of the standards. In fact, that manufacturer may require such information in order to be able to make the necessary modifications.