Interpretation ID: nht79-2.19

DATE: 02/13/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Hisakazu Murakami Nissan Motor Co., Ltd. P.O. Box 1606 560 Sulvan Avenue Englood Cliffs, New Jersey 07632

Dear Mr. Murakami:

This is in reponse to your letter of September 29, 1978, and in confirmation of your conversation with Mr. Schwartz of my office. 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 the notice of proposed rulemaking to further amend the standard are enclosed.

Your letter raises a number of questions concerning Federal Motor Vehicle Safety Standard No. 115. These questions will be answered in the order posed in your letter.

Q-1. The term "line" is defined in S3 of the standard to mean "a name which a manufacturer applies to a family of vehicles within a make which have a degree of commonality in construction, such as body, chassis or cab type". You are correct in saying that "B210" is a Datsun "line."

Q-2. You ask whether it is necessary in designating a vehicle "line" to distinguish between independent and rigid axle systems within the same model of vehicle. The answer to your question is no. It is not necessary to make this distinction. In your example, either Case 1 or Case 2 would be correct.

Q-3. You ask whether it is necessary in designating a vehicle "line" to distinguish between different lengths of wheel base within the same family of vehicles. Again, the answer to your question is no. In your example, either Case 1 or Case 2 would be correct.

Q-4. You ask whether it is necessary in designating vehicle "body type" to distinguish between a 2-door vehicle and a 4-door vehicle. It is necessary to make this distinction.

Q-5. You also ask whether it is necessary in designating vehicle "body type" to distinguish between a sedan and a hardtop. It is not necessary to make this distinction.

Q-6. You ask whether it would be necessary in designating a vehicle "series" to distinguish between a Datsun 810 with air conditioning and power steering and a Datsun 810 without these features. It is not necessary to make this distinction.

Q-7. You ask whether it would be necessary in designating a vehicle "series" to distinguish between a Datsun B210 with a cigarette lighter and a Datsun B210 without a cigarette lighter and with a less elegant interior. It is not neces- sary to make this distinction. A Datsun B210 with two doors would have a different "body type" than a Datsun B210 with four doors, however.

Q-8. You ask whether in designating vehicle "engine type", you may use the same character (e.g., "H") to designate different engines so long as they are within different "lines", or whether you must use different characters for each engine type you manufacture.

The vehicle description section (VDS) of the VIN is used to describe a group of vehicles with common characteristics. One of these characteristics is engine type. The VDS is a "code word" which is translated as a whole into the appropriate specification. Each VDS is unique, and the use of a specific character in one VDS does not bar its use in another VDS, whether or not the meaning is the same or different. Consequently, "HB210" can represent a Datsun B210 with an 85 CID displacement engine and "HA100" can represent a DATSUM 510 with a 119 CID displacement engine. In your example, both Column 1 and Column 2 would be permissible.

Q-9. You ask whether it is necessary to uniquely distinguish all engine types within a make, or whether it is sufficient to distinguish engine types within a line. As explained above, each vehicle discriptor section is unique. Consequently, you may use the same characters in more than one VDS provided the VDS can be translated into the specific engine type. In your example, either Column 1 or Column 2 would be permissible.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

September 28, 1978

Mr. Joseph J. Levin Chief Counsel NHTSA D.O.T. 400 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Levin:

Enclosed please find some questionnaire which I would like to get your interpretation on as soon as possible. It is regarding FMVSS 115, VIN.

Thank you.

Very truly yours,

NISSAN MOTOR CO., LTD.

Hisakazu Murakami Staff, Safety

HM:mh CC: Mr. Nelson Erickson, Office of Motor Vehicle Programs NHTSA Enclosures