Interpretation ID: nht81-1.38

DATE: 03/13/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Halliburton Services

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Ralph Houser Environmental Engineer Halliburton Services Drawer 1431 Duncan, OK 73536

Dear Mr. Houser:

This is in response to your letter posing a number of questions concerning the application of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) to trucks rebuilt by your company using a variety of new and used components.

Section 571.7(e) of Part 49, CFR, provides that when a new cab is used in the assembly of a truck, the truck will be considered newly manufactured unless the engine, transmissions and drive axle(s) are not new, and at least two of these components were taken from the same vehicle. If the truck is considered newly manufactured, a new vehicle identification number (VIN) must be assigned to the vehicle. In all other circumstances, the vehicle assumes the VIN of the vehicle most significantly represented in the reconstructed vehicle.

Sincerely,

Frank Berndt Chief Counsel

(405) 251-3569 October 29, 1980

Mr. Frederic Schwartz, Chief Council National Highway Traffic Safety Administration Department of Transportation NOA 30 Room 5211 Washington, DC 20590

Dear Sir: RE: 49 CFR Parts 571.7(a), 571.7(e), 571.115

Halliburton Services requests a written interpretation from your office regarding Vehicle Indentification Number (VIN) requirements under the circumstances as described below.

A. A truck is purchased by a company. The company uses the truck for a period of 10 years. At that time the truck is rebuilt by the company using a new cab only. Does this rebuilding operation require the issuance of a new VIN for the truck?

B. A truck is purchased by a company. The company uses the truck for a period of 10 years. At that time the truck is rebuilt by the company using a new cab and a new engine. Does this rebuilding operation require the issuance of a new VIN for the truck?

C. A truck is purchased by a company. The company uses the truck for a period of 10 years. At that time the truck is rebuilt by the company using a new cab, new engine and new transmission. Does this rebuilding operation require the issuance of a new VIN for the truck?

Your assistance in this matter will be greatly appreciated.

Very truly yours,

Ralph Houser Environmental Engineer

RH:jw Certified Mail cc: Nelson Erickson Bill Gilchrist Richard Mize Scott Morris Dale Bragg