Interpretation ID: nht76-5.45
DATE: 03/01/76
FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA
TO: Maryland Department of Transportation
COPYEE: J. CARSON
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your letter of January 26, 1976, to Mr. Fred Vetter, expressing your concern about Federal Motor Vehicle Safety Standard (FMVSS) No. 115, Vehicle Identification Numbers (VINs).
The National Highway Traffic Safety Administration (NHTSA) is well aware of the importance of the VIN and its use in requirements for certification, defect investigation, recall campaigns, inspection and registration. We are also well aware of its importance to other users such as State administrations, law enforcement agencies, insurance companies and vehicle manufacturers. The VIN is crucial to the identification of stolen, junked and recycled vehicles.
It was NHTSA's intention with the initial issuance of FMVSS No. 115, to include within its scope all aspects of vehicle numbering relative to the vehicles to which it applied, and to leave any aspects for which there were no specific requirements to the discretion of the manufacturers until such requirements could be issued. This, of course, is the basis of our position that any state rules in this area must be the same as the Federal standards.
We agree, however, that the VIN may be more effective if it is standardized in structure, format, and information content. The NHTSA, through its personnel who are members of the Society of Automotive Engineers and International Standards Organization Committees, has been participating in the efforts to develop a worldwide VIN system for several years. The NHTSA plans to issue in the next few months an NPRM to amend FMVSS No. 115 that will specify requirements for a standardized, uniform identification numbering system for all motor vehicles on a worldwide basis. We welcome all help and recommendations in this action.
I sincerely hope that VESC will provide comments and recommendations to the docket as we proceed in our rulemaking action.