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Understanding 49 CFR 595 "Make Inoperative"
Register with
NHTSA
This registration is for ALL dealers who convert vehicles
for the disabled, and we hope you
have already completed this. If you have not, a copy of a
generic letter to NHTSA is
below. Please make sure to use your own letter head and place
your company information in the
proper places. Keep a copy for your records and send the
original Certified Return Receipt mail. This will be your way
of proving your registration with them. (NHTSA will not send
you any type of response.)
Proper Record
Keeping
NMEDA has developed a form to comply
with the "Make Inoperative" ruling from NHTSA. Please follow
the steps listed below.
-
Make copies of this
form.
-
Fill out the necessary information
on your company.
-
Fill out your customer's
information.
-
Fill out your customer's vehicle
information.
-
Mark if the modifications are
being done for a driver and/or passenger.
-
Check all modifications made to
vehicle (don't forget the load carrying capacity).
-
Make a copy of the completed form.
-
Give the original to your customer
to be kept with the vehicle's papers.
-
File your copy of the form in the
customer's file, to be kept for 5 years.
-
Affix your label as required by
NHTSA, adjacent to the original certification label
or alterer's certification label, if applicable
Also included below is the same
form with bulleted points of what
modifications fall under
each category. This is for the modifier's use only (a cheat
sheet, if you will).
Labels
A big part of CFR 49 Part 595 is
the label requirements. Labels should include:
-
Modifier's name.
-
Modifier's physical address.
-
The statement "This vehicle has
been modified in accordance with 49 CFR 595.6
and may no longer comply with all Federal Motor Vehicle Safety
Standards in effect at the time of its original manufacture."
-
Affix your label, as required by
NHTSA, adjacent to the original certification label
or the alterer's certification label, if applicable.
You may purchase these labels from
NMEDA at 25 cents each.
Notice to QAP Modifiers: The
compliance label is in addition to the RADCO numbered label. (Reason
- There is no place on the QAP label for the modifier's name
and address.)
A Final Note
The ruling clearly chose not to
exempt FMVSS #301 "Fuel System Integrity". This
means that any lowered floor modifications where the fuel tank
or connections are made
or relocated will have to be of a type that has been certified
by the supplier as complying with FMVSS #301. The certification
can be through some combination of testing and engineering
analysis but it must be available to NHTSA upon request.
If you are curious about the
specific details of any of the FMVSS or the "Exemption from
the Make Inoperative Prohibition" final rule you can find links
on the NHTSA website at
www.nhtsa.dot.gov and view
them for yourself. This article is an attempt to cut through
all
the extraneous discussion and put the ruling into plain language
while maintaining the intent
of the ruling but the rule itself and the standards referenced
would take precedence. If you
are not familiar with the FMVSS then you really need to get a
copy and look them over.
Letter to NHTSA
Attn: Administrator
National Highway Traffic Safety
400 Seventh Street S.W.
Washington, DC 20590
Dear Administrator:
Please be advised that we wish to register with your agency as a
specialty vehicle modifier
for people with disabilities.
Our corporate name is:
We are located at:
State of
Incorporation:
We make modifications for people with disabilities to operate or
ride as a passenger in the modified vehicle and we intend to
avail our-self of the exemption provided in 49 CRF 595.7
Thank you for your time and should you have any questions,
please do not hesitate to
contact us at the above.
Sincerely,
(your name)
(company name)
(your position/title) |
