Interpretation ID: nht94-4.5

TYPE: INTERPRETATION-NHTSA

DATE: August 18, 1994

FROM: H. Kristie Jones -- President, P.J.'s Fabrication Inc., Stanfield, OR

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to 10/05/94 letter from Philip R. Recht to H. Kristie Jones (A42; std. 115)

TEXT: P.J.'s Fabrication Inc. is a trailer manufacturing business. We are a new company and need assistance with rules and regulations regarding VIN numbers.

We have contracted with Coulson Commander Trailers, Boise, Idaho to build trailers under Coulson's name. As the manufacturer, P.J.'s accepts responsibility for warranty work and quality control to meet DOT specifications. My question, who issues the VIN number and Certificate of Origin?

I called Dorothy Nacomma on 8-18-94, she has informed me that P.J.'s Fabrication will issue the VIN number, but suggested I write to you for written confirmation of such.

At your earliest convenience, could you possibly sent us this confirmation.

Your time and consideration in this matter is greatly appreciated.