SIMPLY by mounting truck bodies on a new chassis, truck equipment distributors become final-stage vehicle manufacturers just as if they were Ford, GM, or Chrysler.
But this is where the similarities end and the legal requirements begin. As final-stage manufacturers, truck equipment distributors must certify that the vehicles they build for operation on public highways conform to applicable federal motor vehicle safety standards (FMVSS).
Vehicle certification is a legal requirement found in Title 49 of the United States Code, Section 30115, said Louis Kleinstiver, director of technical services at the National Truck Equipment Association (NTEA). Non compliance can result in fines of $1,100 for each violation up to a maximum of $880,000 for a related series of violations.
All records related to the manufacturing and certification of a vehicle by a final-stage manufacturer must be retained for a minimum of five years, Kleinstiver said. Retaining records for a longer period is a business decision.
A certification stating the vehicle is in compliance label must be affixed to the vehicle, Kleinstiver said during a seminar in Las Vegas at the NTEA 34th annual convention and exhibition. He explained federal regulations that control the certification of motor vehicles.
Rules Affecting Distributors The two major rules that affect truck equipment distributors as manufacturers of motor vehicles are found in Section 49 of the Code of Federal Regulations (CFR) Parts 567 and 568, Kleinstiver said. Part 567 sets the basic certification requirements. Part 568 covers vehicles manufactured in two or more stages.
As manufacturers of motor vehicles, truck equipment distributors are regulated by the National Highway Traffic Safety Administration (NHTSA), Kleinstiver said. NHTSA's primary responsibility is the promulgation and enforcement of FMVSS. Vehicle recalls for safety reasons is also the responsibility of NHTSA.
Any manufacturer of motor vehicles and motor vehicle equipment, including truck equipment distributors that mount truck bodies on new chassis, is required to certify that the vehicles are in compliance with applicable standards, Kleinstiver said. The NTEA is often asked "who is a manufacturer?"
"We get this question a lot," Kleinstiver said. "People will say 'I'm not a manufacturer. I'm a truck equipment distributor.'"
But truck equipment distributors are motor vehicle manufacturers if they install truck bodies or truck-mounted equipment on new, incomplete vehicles or altered, completed motor vehicles prior to the first purchase, he said. Motor vehicle manufacturers are required to register with the NHTSA.
Certifying Incomplete Vehicles "Registration is a very simple process, and the required paperwork takes about 15 minutes to complete," Kleinstiver said. A manufacturer identification form can be obtained from NTEA.
Two simple rules determine when certification is required, he said. The first rule is that vehicles must be certified in the final manufacturing stage. The second rule is that manufacturing operations performed on motor vehicles prior to the first purchase must be certified.
The requirements for vehicle certification and certification labeling end when the vehicle is certified in the final stage and purchased for the first time, Kleinstiver said. After the vehicle is licensed and titled, it is technically a used vehicle and there is no longer a certification-labeling obligation.
If a distributor mounts a truck body on a chassis already purchased by a customer, the distributor still has a certification obligation, he said. This is because the completed vehicle was never certified in the final manufacturing stage.
Types of Certification Four types of certification exist for motor vehicles:
Incomplete vehicle certification is for cab, strip, cowl, and cutaway chassis. These chassis require further manufacturing before they can be used for their intended function.
Intermediate-stage certification is for vehicles that receive an alteration between the manufacture of the incomplete vehicle and its manufacturing in the final stage.
Final-stage certification is performed on a vehicle before it is licensed, titled, and put into service for the first time.
Altered certification occurs when the vehicle is altered prior to the first purchase.
For example, altered certification is required if the bed is removed from a new pickup truck before it is licensed and titled so that a service body can be installed. The pickup was certified in the final stage by the manufacturer. But then it was altered prior to the first purchase.
Vehicles can be certified as complying with FMVSS in several ways, Kleinstiver said. The first way to certify a vehicle is with an incomplete vehicle document. Ford calls its version a manual and GM calls it a document.
The incomplete vehicle document must be furnished with every incomplete vehicle as required by 49 CFR, Part 568. A final-stage manufacturer first determines the type of completed vehicle as defined in the document. For every incomplete vehicle model, the manufacturer identifies the applicable FMVSS and defines what the completed form may be for each model.
Each applicable standard is provided with a type one, two, or three certification statement by the chassis manufacturer, Kleinstiver said. Type one is a statement of conditional conformity, which says the vehicle conforms with FMVSS as long as certain components on the chassis are not removed or altered.
Type Two Certification Type two certification is a statement of conditional conformity with specific instructions that must be followed, he said. Sometimes chassis manufacturers require adherence to both type one and type two statements. Type three contains no statement of conditional conformity with FMVSS.
"With a type three statement, you're on your own," Kleinstiver said.
The incomplete vehicle document is used to perform an FMVSS compliance analysis. Compliance should be documented. The NTEA sells FMVSS compliance worksheets in pads of 50.
When performing this analysis, applicable standards are compared against the work performed by the final-stage manufacturer on the vehicle to determine which type of certification is used, Kleinstiver said.
In some cases, a final-stage manufacturer may not be able to determine which certification to use based on the work done to the incomplete vehicle, he said. The final-stage manufacturer may have to complete engineering analysis and/or testing based on the FMVSS to verify the standard.
Weight Distribution Analysis A weight distribution analysis is helpful to determine if the completed vehicle can carry the anticipated payload, Kleinstiver said. The NTEA sells worksheets in pads of 50 to complete this analysis, which ensures the cargo-bed payload does not exceed the gross axle weight ratings provided by the chassis manufacturer.
Other useful tools for weight-distribution analysis are NTEA spreadsheet files in Lotus 1,2,3 and Microsoft Excel formats, Kleinstiver said. The NTEA offers three different spreadsheets.
The Weight & CG spreadsheet calculates a completed vehicle's horizontal, vertical, and lateral center of gravity. The spreadsheet reduces the amount of time needed to complete a weight distribution analysis.
Axle Mod is a spreadsheet available in two versions for wheelbase modifications and axle additions. With Axle ModII, a vehicle modifier can add up to five additional axles. The Truck-Trailer spreadsheet is for straight trucks pulling a trailer with a ball-hitch or pintle hook.
The final-stage manufacturer has the ultimate responsibility for certification, Kleinstiver said. After the final-stage manufacturer determines that the completed vehicle conforms to applicable FMVSS, it can affix a certification label.
Affixing Certification Label NHTSA says the certification label can be affixed to the hinge pillar, the door-latch post, the door edge that meets the door-latch post, the left of the instrument panel, or the inward surface of the door next to the driver's seat. If none of these locations work, a final-stage manufacturer can write NHTSAand request an alternate location.
"I've never heard of NHTSA denying a reasonable request for an alternative location," Kleinstiver said.