Interpretation ID: nht78-1.50

DATE: 12/06/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Palmer Machine Works

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Dick Palmer Palmer Machine Works Old Round House Road Amory, Mississippi 38821

Dear Mr. Palmer:

This is in response to your letter of November 10, 1978, concerning Federal Motor Vehicle Standard No. 115, Vehicle identification number, and in confirmation of your telephone conversation with Mr. Schwartz of my office.

Unfortunately, we do not have a simplified version of the standard which applies only to trailers. We have also modified the standard somewhat since the August 1978 version you referred to in your letter. I have attached a copy of the modification as well as a proposed further modification. I realize this is a complex standard, and, therefore, offer the following comments:

1. Since you produce less than 500 vehicles per year, characters 1, 2, 3, 11, 12 and 13 of the VIN will represent your manufacturer identifier. The date by which your manufacturer identifier must be submitted to the NHTSA has been changed to September 1, 1979. It is our understanding that the Society of Automotive Engineers will be willing to help you determine your manufacturer identifier. You should contact: Mr. Leo Ziegler, Society of Automotive Engineers, 400 Commonwealth Drive, Warrendale, Pennsylvania 15096, (412) 776-4841.

2. The 4th, 5th, 6th, 7th, and 8th characters of the VIN represent descriptive information about your vehicles. In the case of trailers, the type of trailer, series, body type, length and axle configuration must be represented. Since your model number can be associated with all these characteristics, you may want to incorporate it into the vehicle descriptor section.

3. The 9th character of the VIN represents the model year of the vehicle, and should be determined from Table II which appears in the standard.

4. The 10th character of the VIN represents the plant of manufacture. Since your firm has only one plant, you may choose any character you desire except one specifically precluded by the standard.

5. Since your firm manufacturers less than 500 vehicles each year, the last three characters of the VIN represent the number that is sequentially assigned to a vehicle in your production process.

6. The check digit which immediately precedes the third character of the VIN is determined by the mathematical operation described in section S5 of the standard. Since most characters in your VIN will be standarized, the check digit should be fairly easy to determine.

Please contact me if you have any further questions. Any trade associations to which you belong should also be helpful in establishing your VIN procedures.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

November 10, 1978

Administrator, National Highway Traffic Safety Administration 400 Seventh Street S W Washington, D. C. 20590

Attention: VIN Coordinator

Gentlemen:

I have just read pages 36448 through 36454 of Federal Register, Vol. 43, No. 160 - Thursday, August 17, 1978. This is of course concerning the new VIN Standard No. 115. I am very confused as to how this affects our company as a manufacturer.

Dump trailers are the only product manufactured by the company. All of the trailers are manufactured at the same facility. Between 250 and 300 trailers are manufactured annually.

In S6.1 I notice that I am required to submit the unique identifies for each vehicle by January 1, 1979. Can you please send me a more simplified explanation of this standard that would pertain to trailers only? Please let me hear from you as soon as possible. Thank you.

Sincerely,

PALMER MACHINE WORKS, INC.

Dick Palmer