Interpretation ID: nht89-1.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/18/89

FROM: DAVID BLUMBERG -- STRUCTO FAB INCORPORATION

TO: CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/09/89 FROM STEPHEN P. WOOD -- NHTSA TO DAVID BLUMBERG; REDBOOK A33 [6]; VSA 102 [5]; VSA 108 [A] [2] [A]; PART 566

TEXT: Dear Chief Counsel

I had a rather lengthy conversation with George Shifflett, Safety Compliance Specialist, about our proposed business. Based on what he said I believe we qualify as a remanufacturer, but he suggested we write for your interpretation.

We plan on acquiring used chassis, less the corroded body, from various third parties. These chassis are from the right hand drive jeep vehicles, presently being used by the U.S. Post Office.

Once we obtain the chassis we then plan to repair, to restore or to replace parts required to bring the chassis up to a quality level.

When the vehicle mechanics are satisfactory we will add a new fiberglass body and hood. We will also add new seats and interior decoration.

As stated earlier I believe the assembly process described above qualifies us as a re-manufacturer, but because we wish to be sure we are asking for your opinion.

Very truly yours,