Interpretation ID: nht79-2.25

DATE: 10/22/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Carolina International, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John W. Howard, III Product Engineering Manager Carolina International, Inc. 1 Hurstbourne Park, Suite 703 Louisville, Kentucky 40222

Dear Mr. Howard:

This is in response to your letter of June 19, 1979, and in confirmation of your telephone conversation with Mr. Schwartz of my office.

The VIN format you forwarded with your letter is essentially correct. There are, however, several aspects of it which should be modified. They will be discussed as numbered in your letter.

It is important to point out at the outset that Standard 115 requires Carolina International Inc. to assign a VIN to only those vehicles for which it is the first stage manufacturer, in this case trailers. Ford and General Motors will be assigning a VIN to those vehicles for which it is the first stage manufacturer, even though Carolina is the final stage manufacturer.

I. World Identification Numbers.

The first three characters of the VIN designate the manufacturer, make, and type of vehicle. While Carolina is the final stage manufacturer for several types of vehicles, it is the first stage manufacturer for only one type. Consequently, one manufacturer identifer is sufficient. As the Agency has contracted with the Society of Automotive Engineers (SAE) to act as its agent in assigning these Identification codes (see enclosed notice), you should communicate with the SAE if your identifier was not assigned by it.

II. Vehicle Description Section (VDS).

Your proposed coding for the VDS is satisfactory, except that it encodes data relating to vehicles produced by other manufacturers who would, as explained above, assign the VIN for those vehicles.

III. Check Digit.

The mathematical values assigned to the alphabetic characters are not correct. Please consult Table IV in Notice 8 (44 PR 17489, March 22, 1979) which I have enclosed.

IV. Vehicle Indicator Section.

The format utilized in this section is correct, except that the series of trailer must be indicated in the Vehicle Descriptor Section. Perhaps this can be encoded where you previously intended to indicate chassis type (2.4).

I hope this information has been helpful. Please write or call Mr. Schwartz of my office at 202-426-1834 should you have any additional questions.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

June 19, 1979

Mr. Frederick Schwartz, Jr. Office of the Chief Counsel National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

RE: Federal Motor Vehicle Safety Standard No. 115, Vehicle Identification No.

Dear Mr. Schwartz:

Per our telephone conversation last week, and pursuant to the above referenced standard, attached please find an outline of Carolina International, Inc.'s proposed method to meet the above referenced standard.

Please review, and return an approved copy to me for our files. Should you have any questions, or need additional information, please call.

Sincerely,

John W. Howard, III Product Engineering Manager

JWH/nhs Encl.