This article was published in
the February 2013 edition of NTEA
News
Question: A customer has asked us to change
the gross vehicle weight rating (GVWR) of a new incomplete truck to which we are
adding a body. We received two identical truck chassis for the same customer,
both with a front gross axle weight rating (GAWR) of 8,000 lbs. and a rear GAWR
of 19,500 lbs. However, one chassis has a GVWR of 27,500 lbs. and the other a
25,950-lb. GVWR. Identical truck bodies will be mounted on the chassis and we
will provide a final-stage certification.
The truck dealer ordered the chassis with an option that provided a
25,950-lb. GVWR requested by the customer, but the factory made a mistake and
the option code that would have provided the 25,950-lb. GVWR was somehow omitted
during the build sequence. The customer refused to take delivery of the chassis
with the higher GVWR, so the truck dealer requested that we re-rate the
27,500-lb. GVWR chassis down to 25,950 lbs. GVWR. The chassis manufacturer would
not provide a new incomplete vehicle label reflecting the lower GVWR, but did
provide a letter to our company, the final-stage manufacturer, stating that the
GVWR should be 25,950 lbs. Can we certify the vehicle in the final stage at the
lower GVWR?
Answer: Yes, you can certify the vehicle.
The GVWR and GAWRs provided by the incomplete vehicle manufacturer
can be changed by a final-stage manufacturer or alterer. However, if the ratings
are changed, there must be some analysis, testing or documentation to back-up
the re-rating. You may also want to consult the incomplete vehicle document
provided by the chassis manufacturer to see if you will be assuming any
additional responsibilities in changing the GVWR. (In this
case, the chassis manufacturer helped provide the
final-stage manufacturer with additional necessary documentation with the
letter.)
In a Jan. 3, 1972 interpretation to the NTEA (then known
as the Truck Equipment Body Distributors Association), the National Highway
Traffic Safety Administration provides the following guidance: “The
information supplied to the final-stage manufacturer by the incomplete vehicle
manufacturer under Part 568 is to assist the final-stage manufacturer in
completing the vehicle in conformity with the standards, and
certifying in conformity with Part 567. There are no requirements, however, as
to how the final-stage manufacturer uses this information.
“If they wish to take on the responsibility of changing the ratings in
either direction, or to disregard the conformity information, that is their
right. Of course, they will be assuming legal responsibility for whatever
changes they make, as indicated by the facts of the particular situation
and the information contained in the incomplete vehicle document.
Similarly, they have the right to make whatever physical changes they wish to
the chassis, and as such assume the normal responsibilities of a manufacturer in
doing so including the responsibilities for the FMVSS standards
affected by the changes. The Part 568 document [incomplete vehicle
document] offers the final-stage manufacturer protection to the extent that they
choose to stay within its limits; but it is their choice.”
As always, if you have any questions, call the NTEA Technical
Services Department at 1-800-441-6832 from 8:00AM–5:00PM EST,
Monday–Friday. We’ll be glad to help!