This article was published in the December 2013
edition of NTEA News
Question: We’re a truck equipment distributor, and
occasionally a dealer or customer will ask us to remove the cargo
box from the pickup and upfit the truck with a commercial body. The body could
be for service/utility, platform/stake or van body applications. Do we have a
certification obligation? If so, what guidelines do we need to
follow?
Answer: Yes there is a certification obligation.
There are two parts to this answer: First, performing the work for
the truck dealer, and second, performing the work directly for the end
user.
There are two basic rules of motor vehicle certification: (1) all motor
vehicles must be certified in the final stage, and (2) all manufacturing
operations performed on a motor vehicle prior to the first retail sale
for use must be certified.
Federal motor vehicle certification regulations 49 CFR 567.7 and 568.8
require vehicles altered prior to the first retail sale (meaning, licensed
and titled in some state) to certify to all applicable Canadian/Federal
Motor Vehicle Safety Standards (C/FMVSS) affected by the alteration. The pickup
trucks on which you install commercial bodies were previously certified in the
final-stage by their respective manufacturers. However, by removing the pickup
box and installing a commercial body, you are altering these
completed vehicles. When this occurs prior to the first retail
sale, you have a certification obligation.
As a cautionary note, it is advisable not to do anything to a used
vehicle that you wouldn’t do to a new vehicle. Even though there may not be a
certification obligation, the person performing the installation can still be
held liable for recall and remedy if it results in noncompliance or causes a
safety defect.
Determining
Eligibility
Before the first bolt is turned, it’s
important to make sure that the vehicle is eligible for pickup box removal.
Anyone performing pickup box removal should obtain copies of available OEM Data
Books, Body Builder Layout Books (including the OEM’s Pickup Box
Removal Program issued each model year) and Incomplete Vehicle
Documents/Manuals (IVDs/IVMs) from all of the chassis manufacturers
offering a Pickup Box Removal Program.
Each fall, the NTEA compiles information from Ford
Commercial Truck, Chevrolet and GMC Commercial Truck, and Ram Commercial
regarding the models eligible for pickup box removal and publishes
this data as a Technical Report. The Technical
Reports for current model year vehicles are available at
www.ntea.com/technicalreports.
In the “Pickup Box Removal” section of a Body Builder
Book, the individual manufacturer will stipulate the conditions,
limitations and guidelines under which the body can be installed and allow
the alterer to be reasonably assured of compliance with all CMVSS, FMVSS,
U.S. Environmental Protection Agency and California Air Resources Board
emission standards as well as Canadian noise and radio frequency
interference standards. Some basic limitations/guidelines
include, but are not limited to, minimum and maximum secondary unit body weight,
maximum body center of gravity height and maximum overall body height, minimum
cab-to-body clearance and maximum unloaded vehicle weight.
When the box is removed, vehicle conformity to the following standards
is affected. These include, but are not limited to:
- C/FMVSS 105: Hydraulic/Electric
Brake Systems
- C/FMVSS 108: Lighting
Equipment
- C/FMVSS 111: Rearview
Mirrors
- C/FMVSS 126: Electronic
Stability Control* (see the following related section)
- C/FMVSS 135: Light Vehicle
Brake Systems
- C/FMVSS 204: Steering Control
Rearward Displacement
- C/FMVSS 208: Occupant Crash
Protection
- C/FMVSS 212: Windshield
Mounting
- C/FMVSS 219: Windshield Zone
Intrusion
- C/FMVSS 301: Fuel System
Integrity* (see the following related section)
Body Builder Manuals and Layout Books usually contain necessary
instructions, diagrams and parts lists that provide guidance to the
alterer in the areas of lighting, fuel filler systems and, sometimes, body
mounting recommendations.
It is important to recognize that if an alterer deviates from the
manufacturer’s guidelines, the alterer must be able to document and
certify that, as altered, the vehicle conforms to all Canadian/U.S. motor
vehicle safety and emissions standards. Since some of the aforementioned
standards are “crash test standards”, it may be necessary to conduct appropriate
testing and/or engineering analysis in order to establish conformity. For the
average installer, dynamic testing which is prohibitively expensive, is not
feasible, so completing the vehicle within the manufacturer’s guidelines is
critical.
*Important Information on C/FMVSS 126
and 301
Electronic stability control (C/FMVSS 126)
applies to trucks, buses, multipurpose vehicles and passenger cars with a gross
vehicle weight rating (GVWR) of 10,000 lbs. or less. For vehicles built in two
or more stages, the standard became applicable Sept. 1, 2012. However,
chassis manufacturers had to meet the standard by Sept. 1, 2011,
which is why some IVDs now have C/FMVSS 126 information. Ford, GM and Ram
all address C/FMVSS 126 in their IVDs, but each manufacturer has different
requirements for the final-stage manufacturer, and its own list of limitations
on modifications when altered to assure compliance to C/FMVSS 126.
Following are some common restrictions among the OEMs:
- Modifications to stability
control systems
- Modifications to tires and
wheels
- Modifications to the braking
system
- Modifications to the suspension
systems
- Maximum completed vehicle
center of gravity (horizontal, vertical and sometimes lateral)
- Maximum completed vehicle
weights
C/FMVSS 301: Fuel System Integrity on Vehicles 10,000 lbs. GVWR or Less
may require upfitters to follow specific chassis manufacturer guidelines when
installing bodies on vehicles. Some manufacturers are installing additional
bracing or rear crossmembers on the vehicle to meet these crash test
requirements. An OEM may require that the bracing or crossmember be retained or
an equivalent structure be installed when mounting bodies and equipment on the
vehicle. See the chassis manufacturer’s IVD or Body Builder Book for guidance
and restrictions.
Labeling
Affixing an altered
certification label to the vehicle is the last act in the pickup
box removal. If you have any questions, call the NTEA Technical Services
Department at 1-800-441-6832 from 8:00am–5:00pm EST,
Monday–Friday.