Interpretation ID: 1984-3.49

TYPE: INTERPRETATION-NHTSA

DATE: 12/07/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Transportation Manufacturing Corporation -- Robert Zeaton, Director of Engineering

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robert Zeaton Director of Engineering Transportation Manufacturing Corporation P.O. Box 5670 (R.I.A.C.) Roswell, New Mexico 88201

This responds to your October 11, 1984, letter to the National Highway Traffic Safety Administration asking for permission to use an alternative location for certification labels required by Part 567, Certification.

According to your letter, you are requesting permission to use an alternative location because the locations specified in S567.4(c) are not practicable in your new "MCI" series of intercity buses. The label could not be legible when affixed to areas surrounding the driver's seating position without removing some permanently attached items, such as the driver's seat or steering column cover. You propose, as an alternative, the installation of the labels on the vertical left hand face of the entrance door stepwell. You state that this panel assembly is not removable for servicing and is readily visible in the entrance door and stepwell area.

In consideration of the problems of installing the certification labels on the new MCI buses in the positions specified in S567.4(c) and since the agency desires that these labels be easily readable, we grant your request to install your labels in these new "MCI" series of intercity buses in the alternative locations that you suggested, provided that all the other requirements of S567.4 are met.

Sincerely,

Frank Berndt Chief Counsel October 11, 1984 "4 PAGES INSERT HERE"

Administrator NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street S.W. Washington DC 20590 Gentlemen:

This letter is being sent to you to address the requirements for the location of the VIN plate in a motor vehicle as outlined in the Code of Federal Regulations under Title 49 - Transportation, Part 567 -Certification. In S567.4 - Requirements For Manufacturers of Motor Vehicles, the requirements for the location of the VIN plate in the vehicle are specified. There is a general requirement outlined that locates the VIN plate in the immediate vicinity of the driver's seat position.

Attached please find several photographs illustrating the problems with locating the VIN plate in the immediate area of the driver' s compartment on our new (MCI) series of intercity bus. The 'MCI' bus will go into production late this year with first vehicle deliveries scheduled for the end of 1984 or early 1985. A considerable amount of time has been spent reviewing possible locations for the VIN plate. The panel areas to the immediate left side, rear, and right side (driver's console) were all considered. As can be seen in the attached photos, there is no available location where the plate can be permanently installed and still be legible without removing some permanently attached items such as the driver's seat or steering column cover. From the standpoint of federal, state, and local inspections, as well as access to information for customer warranty purposes, this would of course not be practical.

Our present production vehicle (model MC-9) has the VIN plate located in the overhead ceiling cap to the left of the driver's seat (photo #5). As can be seen in photo #6, the new 'MCI' series of buses has the parcel rack extended over the driver's area, eliminating the ceiling cap mounting area. The lower dash area of the vehicle was also investigated, but there is not a practical location available.

After all of our investigations, the location that was found to be the most suitable on the new 'MCI' series was the vertical left hand face of the entrance door stepwall. This is shown in photos #4 and #6. In this location, the VIN plate is permanently rivetted to a stainless steel panel that forms an integral part of the bus. This panel assembly is not removable for servicing and is readily visible in the entrance door and stepwell area.

This proposed location in the front stepwell is by far the most practical one. We would therefore request that this proposal be reviewed and approved at your earliest possible convenience.

Very truly yours,

Robert Zeaton Director of Engineering

Attachments: 4 pages of photos

RZ/jsi