There's more to pickup box removal than meets the eye

From an NTEA member 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? 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. 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.

There's more to pickup box removal than meets the eye

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