Interpretation ID: nht93-3.23

DATE: April 27, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TO: Raymond S. Byers -- Engineering Manager, Research, Testing, and Certification, Utilimaster Motor Corporation

TITLE: None

ATTACHMT: Attached to letter dated 12-1-92 from Raymond S. Byers to Administrator, NHTSA (OCC 8258)

TEXT: This letter responds to your inquiry regarding the alternate placement of a vehicle certification label in your "Aeromate" van. I apologize for the delay in responding.

As you noted in your letter, 49 CFR S567.4 requires that a motor vehicle manufacturer affix a certification label to each vehicle it makes, and permits the manufacturer to place the label in any one of the places listed in that provision. If none of the listed locations is practicable, S567.4 directs the manufacturer to suggest an alternate position for the affixed label, and to request National Highway Traffic Safety Administration (NHTSA) approval for that position.

You explain in your letter that in your "Aeromate" vehicle, the driver's door slides between an inner and outer metal panel, thus making it impossible to affix the label to the hinge pillar, door-latch post, or the door edge that meets the door-latch post. Based on the photographs you included with your letter, affixing the label to the inside of the driver's side door would be unacceptable because, when opened, the door slides between the two metal panels. Thus, when the door is in the open position, the label would be obscured from the view of any observer. You propose installing the label on the inner metal panel in front of the driver's side door opening, to the left of the driver's legs under the instrument panel, and include photographs showing the label affixed to the proposed position. You state, and your photographs appear to confirm, that the location would be visible from the driver's position, and for inspection by officials.

In directing a manufacturer to put its certification label in those places set out in S567.4, NHTSA's purpose is to make these labels easy to see and read. Based on the information you supplied, the agency determines that for this particular vehicle design, installing the certification label as you propose will facilitate seeing and reading the label. On the other hand, placing the label as specified in S567.4 may not be practicable and might interfere with unobstructed viewing of the label. Therefore, on the condition that your company's label complies in all other respects with S567.4, NHTSA grants your request to install the certification label on the inner metal panel in front of the driver's door opening as shown in the photographs that you provided to us.

I hope this information is helpful. If you have any further questions, feel free to contact David Elias of my office at the above address or by phone, at (202) 366-2992.