We need a unified voice

[undysworld]

Sorry, didn't mean to offend. Perhaps I need to rephrase that.

I fully agree that your DMV is a state regulatory agency. That means they have to administer state law. But even though your DMV is likely part of your state's DOT and there is also a federal U.S. DOT, your state's DMV doesn't have the authority to administer federal laws (at least to my layman's knowledge). (An exception might be Motor Carrier laws?)

In Wisconsin, one of the state statutes that caused former military vehicle owners a lot of grief was 341.10(6), which basically says that DMV must refuse registration for a vehicle without a federal certification label. State law doesn't require the cert. label on new cars, federal law (Title49USC) does, so WisDOT/DMV won't prosecute someone who builds a car without a cert. label - the feds (U.S. DOT/NHTSA) do. But under that state law, WisDOT/DMV does refuse registration for lacking the fed. cert. label.

What federal code are you thinking should be amended? (Sorry if I missed this earlier in the thread. I looked, but...?)

I'd also be curious what your proposed change/s would be, but you might want to communicate this via pm.

I've never had a hand in changing federal law, so I've got no idea how difficult it is, but I suspect it might be easier to change your state's law than to change federal code.

I'm not trying to knock your idea, just thinkin' out loud.

 

[doghead]

Looks like Oregon is getting some help.

http://www.steelsoldiers.com/showth...may-share-roads-with-military-surplus-Humvees

 

[MaverickH1]

Sorry, didn't mean to offend. Perhaps I need to rephrase that.

I fully agree that your DMV is a state regulatory agency. That means they have to administer state law. But even though your DMV is likely part of your state's DOT and there is also a federal U.S. DOT, your state's DMV doesn't have the authority to administer federal laws (at least to my layman's knowledge). (An exception might be Motor Carrier laws?)

In Wisconsin, one of the state statutes that caused former military vehicle owners a lot of grief was 341.10(6), which basically says that DMV must refuse registration for a vehicle without a federal certification label. State law doesn't require the cert. label on new cars, federal law (Title49USC) does, so WisDOT/DMV won't prosecute someone who builds a car without a cert. label - the feds (U.S. DOT/NHTSA) do. But under that state law, WisDOT/DMV does refuse registration for lacking the fed. cert. label.

What federal code are you thinking should be amended? (Sorry if I missed this earlier in the thread. I looked, but...?)

I'd also be curious what your proposed change/s would be, but you might want to communicate this via pm.

I've never had a hand in changing federal law, so I've got no idea how difficult it is, but I suspect it might be easier to change your state's law than to change federal code.

I'm not trying to knock your idea, just thinkin' out loud.

No offense taken! I thought federal code specifically said military vehicles were excluded from the FMVSS and that sticker was not required for them ever. There was even a letter from the NHTSA (I think) to California which said that the federal government did not require California to block military vehicles without an FMVSS from being road legal. However, if California wanted to require the FMVSS in their state code they were allowed to.

My interpretation might be incorrect. But I'd like to more firmly and clearly say in federal code that former military vehicles are never required to meet the FMVSS by the federal government and maybe include that the military vehicles already meet the required military safety standard.

In my case, that would shift things back towards the state where they cannot claim that the feds told them no and that an FMVSS is required. It would also show the states that there are safety standards for these trucks, which might make them more comfortable about them being road worthy.

/shrugs

 

[MaverickH1]

Looks like Oregon is getting some help.

http://www.steelsoldiers.com/showth...may-share-roads-with-military-surplus-Humvees

Thanks, I'll have to check this out.

 

[undysworld]

I'd say you're mostly correct on things. But there are some assumptions that are often incorrectly made. Try these:

Title49USC30112 is the federal prohibition against manufacturing, selling, or importing a vehicle unless it meets FMVSS. This (subsection B9) is often referred to as the "25yr. old import exemption", and is how older foreign vehicles can be imported without having to meet FMVSS. But this is a misconception, as this same exemption applies to ALL MOTOR VEHICLES, not just imports. Any vehicle older than 25 yrs. old is exempted from FMVSS requirements.

Title49CFR571.7 exempts military vehicles from FMVSS. In it, subsection (a)(c) states; "Military Vehicles. No standard applies to a vehicle or item of equipment manufactured for, or sold directly to, the Armed Forces of the U.S. in conformity with contractual specifications." The common misconception is that this says that military vehicles DO NOT meet FMVSS. But stating that something is not required to meet a standard is not the same as stating that it does not meet the standard. Nothing precludes military vehicles from meeting FMVSS standards, even if they are not required to do so.

Title49USC30115 requires a Certification Label signifying compliance with FMVSS on every vehicle. Whether a U.S. Military vehicle was equipped with a cert. label or not is largely a matter of manufacturing. Chevrolet produced govt. contract vehicles on dedicated assembly lines, and all VINs had a "D" in the 4th position and lacked the cert. label. Dodge supplied vehicles from standard lines, and most carried a cert. label. PRESENCE OF A CERTIFICATION LABEL SUGGESTS COMPLIANCE WITH FMVSS, BUT A LACK OF CERTIFICATION LABEL DOES NOT GUARANTEE NONCOMPLIANCE WITH FMVSS.

U.S. Govt. document MIL-STD-1180B specifies that vehicles built for the U.S. Govt. must meet MIL-STD equipment requirements that are exact equivalents to FMVSS. This applies to tired (non-tracked) vehicles up to and including 5-ton variants. IN FACT, nearly all U.S. Military vehicles were required to meet standards which are identical to FMVSS standards.

Confused yet?? I don't think it's the entire answer to your issue, but it might help with some of the questions.

​

 

[USAFSS-ColdWarrior]

I'd say you're mostly correct on things. But there are some assumptions that are often incorrectly made. Try these:

Title49USC30112 is the federal prohibition against manufacturing, selling, or importing a vehicle unless it meets FMVSS. This (subsection B9) is often referred to as the "25yr. old import exemption", and is how older foreign vehicles can be imported without having to meet FMVSS. But this is a misconception, as this same exemption applies to ALL MOTOR VEHICLES, not just imports. Any vehicle older than 25 yrs. old is exempted from FMVSS requirements.

Title49CFR571.7 exempts military vehicles from FMVSS. In it, subsection (a)(c) states; "Military Vehicles. No standard applies to a vehicle or item of equipment manufactured for, or sold directly to, the Armed Forces of the U.S. in conformity with contractual specifications." The common misconception is that this says that military vehicles DO NOT meet FMVSS. But stating that something is not required to meet a standard is not the same as stating that it does not meet the standard. Nothing precludes military vehicles from meeting FMVSS standards, even if they are not required to do so.

Title49USC30115 requires a Certification Label signifying compliance with FMVSS on every vehicle. Whether a U.S. Military vehicle was equipped with a cert. label or not is largely a matter of manufacturing. Chevrolet produced govt. contract vehicles on dedicated assembly lines, and all VINs had a "D" in the 4th position and lacked the cert. label. Dodge supplied vehicles from standard lines, and most carried a cert. label. PRESENCE OF A CERTIFICATION LABEL SUGGESTS COMPLIANCE WITH FMVSS, BUT A LACK OF CERTIFICATION LABEL DOES NOT GUARANTEE NONCOMPLIANCE WITH FMVSS.

U.S. Govt. document MIL-STD-1180B specifies that vehicles built for the U.S. Govt. must meet MIL-STD equipment requirements that are exact equivalents to FMVSS. This applies to tired (non-tracked) vehicles up to and including 5-ton variants. IN FACT, nearly all U.S. Military vehicles were required to meet standards which are identical to FMVSS standards.

Confused yet?? I don't think it's the entire answer to your issue, but it might help with some of the questions.

​

This in invaluable information.
Maybe it (the facts in this post) should be engraved for all posterity or at least made a STICKY of some sort in the "Politics Related to NV's" Forum.

 

[Austringer]

and sell out combat fighting vehicle owners, like the NRA did to MG owners in 85/86?

 

[undysworld]

and sell out combat fighting vehicle owners, like the NRA did to MG owners in 85/86?

I don't think this thread is about guns. As far as combat fighting vehicles, the govt. only provides an SF-97 form on vehicles that are generally road-going vehicles. Something like a Bradley never will be on-road, as it's 12 ft. wide and 50,000# GVW, just for starters.

To All,

Here's a few more comments about FMVSS-compliance and the Federal Certification Labels.

FMVSS began (generally) in 1968, and has gotten more strict as the years went by. You can download a pdf of them, along with their dates of implementation here.

When a manufacturer builds a vehicle, NHTSA tests a few of them for compliance and then approves self certification of all subsequent identical vehicles. This means the manufacturer certifies that the vehicle met applicable FMVSS for that model-year at the time it was manufactured, by adhering a label to the door or door frame.

A Certification Label is a permanent label. This does not mean that this label must remain on the door forever. It means that it is impossible to remove the label intact - it will be destroyed.

A vehicle can go out-of-compliance with FMVSS at any time. If one of your two headlights burn out, your vehicle no longer conforms to FMVSS. If (when) your tires or your wipers wear too much, same situation. This is why the presence of a certification label suggests compliance with FMVSS, but does not guarantee it.

Many times the door of a vehicle must be replaced due to accident or rust, or repainted by choice. When this happens, the Certification Label is often lost. If you buy a new door, the door must be DOT-approved and have a label to show this, but the new door will not have a Certification Label for the vehicle. (No manufacturer would certify that a used car that someone else owns currently meets FMVSS, so they won't give you a sticker.) So a lack of a sticker can't really tell you much about whether the vehicle met FMVSS when it was built.

And remember, any vehicle older than 25 years old is exempted from FMVSS anyway!

That is why states also have their own rules about what equipment a Motor Vehicle must have, in order to register for on-road operation. If you want to register and operate on-road, you must comply with all applicable laws of the road. If you don't, you'll give all the rest of us green truck drivers a bad reputation!