Interpretation ID: 1984-4.7
TYPE: INTERPRETATION-NHTSA
DATE: 12/18/84
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Tennant Company -- Russell D. Schantz, District Manager
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Russell D. Schantz District Manager Tennant Company 1080 North Kraemer Place P.O. Box 66066 Anaheim, CA 92B06
This responds to your letter regarding the industrial power sweeper manufactured by your company. You stated that the California Department of Motor Vehicles is insisting that your sweepers have a 17-digit VIN when an owner attempts to register and license them.
The VIN requirements in Federal Motor Vehicle Safety Standard No. 115, Vehicle Identification Number--Basic Requirements, apply only to "motor vehicles," which are manufactured primarily for use on the public roads. According to the sales literature and specification sheets you submitted, your product is a small sweeper, with a top speed of 8.5 mph, which is sold for use on off-road industrial sites. Some of the vehicles may incidentally use public roads to move from site to site. Based on this information, we have concluded that your low-speed sweeper is not a motor vehicle and is therefore not required to have a VIN.
This office has contacted the California Department of Motor Vehicles and learned that the form letter concerning the VIN was sent to you in error. Walt Steuben of that office said that there is an exception for vehicles which are "incidentally operated on road" between work sites. He said that the sweeper would need license plates and a sticker. He also requested that you contact him at (916) 445-2961.
Sincerely, Frank Berndt Chief Counsel cc: Mr. Joe Kasper Tennant Company 701 North Lilac Drive P.O. Box 1452 Minneapolis, MN 55440
October 15,1984 Tennant Company P.O. Box 931 Minneapolis, MN 55440
Gentlemen:
An application for registration of the above described vehicle is being held.
The application submitted by your franchised dealer does no include a 17 position vehicle identification number (VIN)
Federal Motor Vehicle Safety Standard 115 requires that manufacturers assign a 17 position alpha numeric vehicle identification number (VIN) to passenger vehicles, trucks, buses, motorcycles, trailers and incomplete vehicles (cab and chasses) operated on roads beginning September of 1980. This VIN must be supplied and approved by:
World Manufacturer Identifier Repository (WMI) 400 Commonwealth Drive Warrendale, PA 15086 Phone: (412) 776-4841
The State of California is enforcing this standard beginning with 1983 year model vehicles. To complete the application, we will require the following: 1. If the vehicle has 17 position VIN approved by the WMI, complete the enclosed Statement of Facts identifying the full, true VIN. When we receive the Statement of Facts, the registration application will be processed.
2. If this vehicle does not have a WMI approved VIN, but you have recent begun assigning a WIM approved VIN, complete the enclosed Statement of Facts so stating. Also return a sample, e.g. photocopy, of the WMI approved VIN configuration. When we receive the Statement of Facts and sample, the registration application will be processed.
3. If this vehicle does not have a WMI approved VIN and your company has not applied for an approved WMI VIN configuration, contact the WMI at the above listed address and telephone numbers.
Upon receipt of your WMI VIN configuration, send a copy of your WMI configuration to us and complete the enclosed Statement of Facts stating the date you will begin the assignment of the new VIN.
When we receive the Statement of Facts and copy of your WMI configuration, the registration application will be processed.
Please refer all correspondence or inquiries to the above file number.
R. Toney TD 2/3 MP Enc cc : Schultz Building Company INSERT ATTACHMENT