Interpretation ID: nht95-2.37

TYPE: INTERPRETATION-NHTSA

DATE: April 14, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: David A. White -- Manager of Reliability, Grumman Olson

TITLE: NONE

ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM DAVID A. WHITE TO NHTSA ADMINISTRATOR

TEXT: Dear Mr. White:

This responds to your letter of March 14, 1995, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on certain vehicles manufactured by Grumman Olson. Your lette r describes those vehicles as van bodies mounted on either cutaway chassis or chassis cabs that are sold as part of Grumman Olson's Freight Star line. Your letter further states that as chassis manufacturers have made changes to the doors and interiors of their vehicles, Grumman Olson has found it "increasingly difficult, if not impossible" to locate its certification label, which measures three and one half by six inches, in any of the locations specified in NHTSA certification regulations at 49 CFR 5 67.4.

Paragraph (c) of that section prescribes specific locations for the installation of vehicle certification labels, and provides that if none of those locations are practicable, the manufacturer may suggest an alternate location for NHTSA's approval. The location that you have recommended is on the forward half of the left side of the cargo box, which is the same location as the one specified in 49 CFR 567.4(d) for the placement of certification labels on trailers. In a photograph that you subsequently faxed to us, the proposed location was more precisely identified as the left front corner of the cargo box, immediately behind the cab.

In specifying locations for the placement of vehicle certification labels, NHTSA's objective is to ensure that those labels may be easily read. The location that you have proposed for vehicles in Grumman Olson's Freight Star line would meet this objecti ve. NHTSA therefore approves your request.

To ensure that vehicles manufactured for sale in the United States may be distinguished from those manufactured for sale in Canada, NHTSA strongly suggests that the letters "U.S." or "U.S.A." be inserted before the word "Federal" in the safety standard c ompliance statement that must be included in the certification label under 49 CFR 567.4(g)(5).

If you have any further questions regarding vehicle certification requirements, feel free to contact Coleman Sachs of my staff at the above address, or by telephone at (202) 366-5238.