Interpretation ID: nht78-1.49

DATE: 12/08/78

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Conco Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

December 8, 1978 NOA-30

Mr. O. R. Schmidt Conco Inc. Mendota, Illinois 61342

Dear Mr. Schmidt:

This is in response to your letter of October 27, 1978, concerning the application of Motor Vehicle Safety Standard No. 115 to final stage manufacturers and in confirmation of your telephone conversation with Mr. Schwartz of my office.

The National Highway Traffic Safety Administration has amended Standard No. 115 to shift the responsibility for assigning the vehicle identification number for vehicles manufactured in more than one stage from the final stage manufacturer to the incomplete vehicle manufacturer (copy enclosed). We appreciate your desire to comply fully with the standard but, with this recent amendment, compliance will not be required by final stage manufacturers.

In response to your question concerning the "model year" to be used for trailers, the calendar year is acceptable as the "model year." Should you have any other questions concerning your responsibility for assigning VINs to the trailers you manufacture, please do not hesitate to contact me.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Enclosure

October 27, 1978

Mr. Nelson Erickson Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Subject: Revised Standard No. 115 Vehicle Identification Number

Dear Sir:

The O'Brien Division of Conco Inc. is a small manufacturer of truck mounted and trailer mounted sewer cleaning equipment which is sold predominately to municipalities, counties, etc., and in some cases to private contractors. So far this year we have built 15 truck mounted units and 52 trailer mounted units.

With reference to the revised Standard No. 115 on Vehicle Identification Numbers, we presently have no major questions in regard to its application to our trailer mounted equipment, since we control the manufacture of these units from start to finish. We are, however, confused about its application to our truck mounted units, particularly as regards the second section of the VIN. Enumerated below are items that hopefully you can clarify for us:

1. The majority of truck chassis-cab units that we use are Fords, but we have used Chevrolet, GMC, and International trucks. Among these four truck manufacturers there are more than 40 different truck models that potentially we can use to mount our equipment on. (As a matter of information, our equipment is mounted on the truck chassis frame without making any alterations to the truck chassis, in the same way that a farmer would mount his own grain box on a similar truck chassis.) Some of these truck chassis we buy, and some are furnished to us or specified by our customers. The only thing we have concerned ourselves with to date is the appropriateness of the axle ratings and the GVWR. Since we don't always know in advance what truck we will be using, we have to anticipate in our coding of the second section of the VIN all of the potential truck models that we might be using. The second section has five characters available for deciphering eight items of information, including the identification of the incomplete vehicle manufacturer as spelled out in S4.5.2. In order to do this, it is necessary to combine some attributes into one character. Our intention would be to combine (1) the incomplete vehicle manufacturer, (2) the model or line, and (3) the series. Our first question - how is it possible to code a potential of 40 plus models of truck chassis into a single character that has available only 33 numbers and letters (Table III of S4.6) for identification purposes? Our second question - will the incomplete vehicle manufacturer such as Ford, Chevrolet, GMC, or International furnish us with a coded second section in their incomplete vehicle document that we could use in conjunction with our first and third section portions of the VIN, assuming, of course, that the attributes of the second section have not been altered? If this were the case, the first question would be resolved, and our only concern would be to furnish you data for the first and third sections of the VIN.

2. Is it permissible for the Vehicle Identification Number as specified in the revised Standard No. 115 to appear in the space provided on the certification label for "Vehicle I.D.", or is it mandatory for the VIN to appear on a separate label? This issue is confusing as regards trailers and trucks with a GVWR of over 10,000 lbs.

3. In the case of trucks, do we, as a final stage manufacturer, represent the model year as being the model year of the truck chassis, or the calendar year of final stage manufacture? Assume that on September 10, 1980 we mount one of our units on a 1981 model Ford truck. This would require the use of the code letter "B". Further assume that two weeks later, on September 24, 1980, we mount a unit on a 1980 model Ford truck which is a new truck that a dealer has left over from the previous model year inventory. In this case we would have to revert back to the code letter "A". This is inconsistent with the natural chronology of events. The above example represents a very real possibility and, therefore, as a final stage manufacturer, we would prefer to use the calendar year of manufacture where the sequence would be totally under our control. There is no way that we could control the model year sequence as illustrated in the above example.

Also, in the case of trailers such as we manufacture, the model year as used by auto and truck manufacturers is absolutely meaningless since we do not have annual model changes. Here again we would prefer to use the calendar year of manufacture as the basis for the code.

We would appreciate your comments and any clarification you can give us on the above listed items.

Yours very truly,

CONCO INC.

O. R. Schmidt Manager of R & D

ORS:jn