Interpretation ID: aiam3098
Administrator
Vehicle Regulations
Volkswagen of America
Inc.
7111 E. Eleven Mile Road
Warren
Michigan 48090;
Dear Mr. Haenchen: This is in response to your letter of September 25, 1979, requesting a interpretation of the term 'restraint system type' as contained in Table I of S4.5.2 of Federal Motor Vehicle Safety Standard No. 115. In addition, this is in confirmation of Volkswagen's statement of the conclusions reached in the meeting with Messrs. Carson, Parker and Schwartz of the National Highway Traffic Safety Administration.; The agency has carefully considered your request that 'restraint syste type' not be interpreted to require a distinction between active and passive belt systems. The agency must deny your request. As the introduction of mandatory passive restraints approaches, information concerning restraint system type is of exceptional importance to the agency. It is important not only to evaluate the overall effectiveness of the various types of passive restraint system types. Consequently, it is necessary that passive belt systems be differentiated from other restraint systems types by decoding the vehicle identification number (VIN).; The agency has also considered the alternative Volkswagen suggeste which is to submit this information separately to the agency on a magnetic tape. Motor vehicle safety research is carried out by many organizations aside from the NHTSA, however, and Standard No. 115 is intended to make information available to these other researchers as well. Consequently, the agency can not accept the alternative you suggest.; As regards the other questions raised in the meeting with NHTSA staff this is to confirm that paragraphs 2 through 4 of our November 20, 1978, letter remain the position of the agency despite the changes in Standard No. 115 since that time. A copy of that letter is enclosed. Likewise, the agency can confirm that the World Manufacturer Identifiers assigned to Volkswagen by the Society of Automotive engineers fulfill the requirements of S6.1 of Standard No. 115.; As requested, the agency has reviewed the VIN format Volkswagen intend to utilize (attachments 2-4 of this letter) and has determined that it meets the requirements of the standard. As explained at the meeting, specific details concerning an engine need not be encoded so long as the information is available from the manufacturer and different engine types can be differentiated by means of the VIN (S4.5.2).; Volkswagen also pointed out to the agency at the meeting that the firs eight characters of the VIN for a particular model might remain the same for several model years, although the characteristics of the vehicle which they codify might change from model year to model year. For example, a 1981 Dasher might have a different engine that a 1982 Dasher, yet that part od the VIN which contained this information would remain the same. This is authorized by Standard No. 115, so long as the correct information for each model year is submitted to the agency. Volkswagen also asked at the meeting what the correct procedure would be for submitting information to the agency concerning vehicles whose line is not subdivided into several series. In this instance, indicate that the line and series are the same. However, even if the series is not divided into more than one body type, this body type must be reported to the agency (S4.5.2). The engine displacement may be indicated in cubic centimeters, and the horsepower in H.P. SAE net (S3). If only one engine make is used, this information must be submitted to the agency, but need not be directly reflected in the VIN (S6.3).; Volkswagen has also asked when information concerning vehicles importe into the United States must be submitted to the agency. Manufacturers of imported vehicles are required to report VIN codes 60 days before the vehicles are imported into the United States to comply with S6.2.; The agency is considering the petitions of a number of manufacturers t establish engine horsepower groupings for reporting purposes and to establish a flexible effective date for vehicles whose model year begins between September 1, 1980 and December 31, 1980. We expect to respond shortly to the petitions.; Sincerely, Frank Berndt, Chief Counsel