Interpretation ID: aiam3151

Mr. W.G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, Georgia 31030; Mr. W.G. Milby
Manager
Engineering Services
Blue Bird Body Company
P.O. Box 937
Fort Valley
Georgia 31030;

Dear Mr. Milby: This is in response to your letter of March 29, 1979, requesting a interpretation of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115). We are sorry for the delay in responding.; You wish to know whether the 'body number' that Blue Bird Body Compan assigns to its school buses will satisfy the requirement of S4.5.3.3 that the last six characters of the Vehicle Identification Number (VIN) represent the production sequence of the vehicle. Your concern arises from the fact that the 'body number' does not indicate the true numerical sequence of manufacture. As explained in Notice 5 (43 Fr 36448) and Notice 6 (43 FR 52246) the production sequence represents the 'number sequentially assigned by the manufacturer in the production process' (S4.5.3.3), rather than the numerical sequence of actual manufacture. Consequently, the Blue Bird body number may be used as the production sequence number since the 'body numbers' are sequentially assigned when purchase orders for the buses are received.; Sincerely, Frank Berndt, Chief Counsel