Interpretation ID: nht78-2.1

DATE: 12/06/78

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

TO: American Honda Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Brian Gill American Honda Motor Co., Inc. P.O. Box 50 Gardena, California 90247

Dear Mr. Gill:

This is in response to your letters of October 9, 1978, and October 20, 1978, concerning Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number.

Since the agency was considering petitions for reconsideration when your letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of the amendments to the standard and a copy of a notice of proposed rulemaking to further amend the standard are enclosed.

The type face shown in the attachment to your letter of October 9, 1978, meets the requirements of S4.3.1. Since the standard does not specify a location for the placement of the VIN on motorcycles, it may be stamped on the certification label. However, Honda should also consider stamping the VIN on the cycle frame as well, to aid in recovery if the motorcycle is stolen.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Enclosures

October 9, 1978

Office of Chief Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 - 7th Street, S.W. Washington, DC 20591

Dear Sir:

Attached are sheets showing the format of the type face which Honda Motor Co., Ltd. intends to use for the vehicle identification number required by FMVSS 115.

Please inform me as soon as possible whether this type face meets the requirement of S4.3.1 of Standard number 115.

Yours truly,

AMERICAN HONDA MOTOR CO., INC.

Brian Gill Manager Certification Department

BG:lw

Enclosure

October 20, 1978

Office of Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh St. S.W. Washington, D.C. 20590

Dear Sir:

This is to request your official interpretation as to the suitability of a method for compliance with the requirement of section S4.3 of FMVSS 115, Vehicle Identification Number (V.I.N.). That section gives the general requirements for the part of the vehicle upon which the V.I.N. must appear.

Section S4.4 of the standard gives specific requirements for the location of the V.I.N. for passenger cars and trucks of 10,000 pounds or less GVNR but there is no such specification for other vehicles, such as motorcycles.

We respectfully request your confirmation that the requirements of S4.3 for motorcycles will be met if the V.I.N. is stamped on the label required by S 567.4 (e) of Part 567 - Certification.

Your earliest response will be appreciated. Please call me if you have any questions.

Yours truly,

AMERICAN HONDA MOTOR CO., INC.

Brian Gill Manager Certification Department

BG:rk