Interpretation ID: nht79-2.23

DATE: 10/25/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Co.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. W. G. Milby Manager, Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley, Georgia 31030

Dear Mr. Milby:

This is in response to your letter of March 29, 1979, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115). We are sorry for the delay in responding.

You wish to know whether the "body number" that Blue Bird Body Company assigns to its school buses will satisfy the requirement of S4.5.3.3 that the last six characters of the Vehicle Identification Number (VIN) represent the production sequence of the vehicle. Your concern arises from the fact that the "body number" does not indicate the true numerical sequence of manufacture. As explained in Notice 5 (43 FR 36448) and Notice 6 (43 FR 52246) the production sequence represents the "number sequentially assigned by the manufacturer in the production process" (S4.5.3.3), rather than the numerical sequence of actual manufacture. Consequently, the Blue Bird body number may be used as the production sequence number since the "body numbers" are sequentially assigned when purchase orders for the buses are received.

Sincerely,

Frank Berndt Chief Counsel

March 29, 1979

Mr Joseph L. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration Washington D.C. 20590

Reference: 1. FMVSS 115 Vehicle Identification Number Amendment dated March 27, 1979 2. Telephone conversation by Bob DuMond with Nelson Erickson, NHTSA on March 13, 1979

Dear Mr. Levin:

I am writing with reference to section S 4.5.3.3 of the above Federal Standard and seek your approval of our interpretation of the term "production sequence number" contained within this section.

As a manufacturer of a forward control type of school bus, Blue Bird Body Company will be required to develop a VIN (Vehicle Identification Number) as referenced in the Federal Standard. Blue Bird assigns a body number to each vehicle as soon as a purchase order is accepted. This unique number forever establishes the identity of each vehicle. All pertinent body and chassis information can be determined by knowing this number. Body and chassis service numbers are set up for the customer use in handling service problems. These numbers indicate exact production sequence of the separate body and chassis. Also, our Federal Certification records establish the day that the vehicle was certified. However, permanent files can be accessed at any time by using any of these numbers for information relative to each unique vehicle.

Our plan is to reduce error in the VIN by having the number computer generated. All pertinent information required by FMVSS 115 will be carried in our computer files. Because the body number is the earliest number assigned to the vehicle, Blue Bird would seek to use this number as the "production sequence number". However, due to early assignment of this number, sometimes six months prior to production, this body number will not indicate true numerical sequence. However, the importance of the value of this particular number as identified by NHTSA for recall campaign, etc. would ideally be the one for Blue Bird to use.

Therefore, I seek your approval of the use of the Blue Bird Body Company

"body number" as the "production sequence number." I am looking forward to your favorable response. Thank you.

Very truly yours,

W. G. Milby Manager, Engineering Services

WGM:oct

cc: VIN Committee