Interpretation ID: nht90-4.69

TYPE: Interpretation-NHTSA

DATE: November 30, 1990

FROM: Leonard M. Anderson -- Vice President, Engineering, Miller Trailers, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3-19-91 from Paul Jackson Rice to Leonard M. Anderson (A37; Part 565; Part 566); Also attached to letter dated 12-24-84 from Erika Z. Jones to Richard E. Bond (A29; Part 565); Also attached to letter dated 5-30-86 to A dministrator, Attention VIN- Coordinator NHTSA, from Richard E. Bond (OCC 769)

TEXT:

Miller Trailers, Inc. requests interpretation of the World Manufacturer Identifier (WMI) requirement in Part 565, Vehicle Identification Number-Content Requirements.

Oshkosh Truck Corporation, Oshkosh Wisconsin is currently in the process of purchasing the assets of Miller Trailers, Inc. Upon the finalization of this purchase, Miller Trailers, Inc. will become Oshkosh Trailer Division and the existing Miller Traile rs, Inc. will cease to exist as a manufacturing entity.

Miller Trailers, Inc. has a WMI which was assigned prior to the effective date of S-115. Our unique identifier is "1ML". Our specific question is whether our existing WMI can be continued when we become Oshkosh Trailer Division of Oshkosh Truck Corpora tion?

The personnel and the responsibility for certification of Miller's highway semi-trailers will continue to be the responsibility of these same personnel located at the same facilities whose identity will become Oshkosh Trailer Division.

Also, the responsibility for maintaining records showing first ownership will remain the responsibility of Oshkosh Trailer Division.

Oshkosh Truck Corporation has its own WMI, however, the vehicles manufactured by Oshkosh are primarily powered vehicles. Oshkosh has manufactured specialized trailers as a part of a military system, however, these products are not at all similar to the commercial highway trailers manufactured by Miller Trailers, Inc.

It is believed that the purchase of Miller Trailer's assets by Oshkosh Truck Corporation will be completed in December, 1990 at which time ongoing trailer production will be the responsibility of Oshkosh Trailer Division rather than Miller Trailers, Inc.

We would appreciate your prompt response to this matter.