Interpretation ID: nht91-2.28

DATE: March 12, 1991

FROM: David A. White -- Manager, Reliability, Grumman Olson

TO: Associated Administrator For Enforcement, NHTSA

COPYEE: A. Charney; K. Sexton

TITLE: None

ATTACHMT: Attached to letter dated 4-25-91 from Paul Jackson Rice to David A. White (A37; Part 556)

TEXT:

Enclosed is a notification of a noncompliance to 49 CFR (567.4(g)(6) requiring the vehicle identification number be located on the vehicle certification tag. Grumman Olson is petitioning to have the noncompliance be deemed inconsequential and is seeking relief from the notification and repair requirements based on that possibility.

Enclosure

DEFECT AND NONCOMPLIANCE REPORT 49 CFR PART 573

573.5(c)(1) Manufacturer name - Grumman Olson

(2) Identification of vehicles involved 1990 and 1991 walk in vans - Models Kurbmaster and Route Star

(3) Quantity - Approximately 380

(4) Percentage estimated to contain the defect - 100%

(5) Description of defect/noncompliance The certification tags of these vehicles listed the Grumman Olson body identification number in place of the vehicle identification number specified in 49 CFR 567.4(g)(6)

(6) N/A

(7) Bases on which the manufacturer determined the existence of the noncompliance Quality Control found the incorrect information during the normal inspection process.

(8) Description of manufacturers program to remedy the noncompliance.

Grumman Olson wishes to petition to have the noncompliance considered inconsequential. This request is based on the following information. 1) The vehicle identification is located on the VIN tag required by 49 CFR 571.115.4.6 even though this tag is required only on vehicles with GVWR of 10,000 pounds or less, Grumman Olson installs the tag regardless of GVWR.

2) Grumman's records are based primarlly on the body identification number and not the vehicle identification number. Vehicles involved in recalls are tracked by the body I.D. Since Grumman Olson manufacturers a body and installs it on a stripped chassis provided by another manufacturer the body I.D. is the only number Grumman Olson assigns and is more useful to Grumman than the VIN.

(9) Representative copy of communications None