ID: nht80-1.9

DATE: 02/06/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Yokohama Rubber Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Your September 10, 1979, letter to our Tire Division has been referred to me for reply, since you are requesting an interpretation of Federal Motor Vehicle Safety Standard No. 119 (49 CFR @ 571.119). You asked two questions in your letter. First, you asked whether the definition you offered for "maximum speed" was correct. If it was correct, you stated that the tire could exceed the speed restriction shown on the tire at a lighter load, and showed how the information could be set forth on the tire. The listing of varying maximum loads at different maximum speeds is not permitted to appear on the tire. Second, you asked if speed restricted tires could specify a speed restriction other than the 35, 50, and 55 mile per hour (mph) restrictions shown in the endurance test schedule of Standard No. 119. The answer to this question is no.

Regarding your first question, you defined a tire's maximum speed as "the highest speed at which a tire can carry the maximum single load that is molded on the tire sidewall." This definition is an acceptable one for tires with a speed restriction listed for them. However, you went on to note that if this definition was acceptable, then a tire could list varying maximum loads at varying maximum speeds. Such a listing is expressly prohibited by the language of Standard No. 119.

S6.5 of Standard No. 119 specifies that each tire subject to the Standard shall be marked with the information that is set forth in following paragraphs. Paragraph (d) of S6.5 requires the maximum load rating and corresponding inflation pressures for single load tires, the type of tire about which you are inquiring, to appear as: Max load lbs. at psi cold. Paragraph (e) of S6.5 requires that a speed restriction on the tire appear only as: Max speed mph. Hence, a single load tire can be labeled with only one maximum load and only one maximum speed.

Your second question was whether a manufacturer could restrict the speed of a tire subject to Standard No. 119 to a speed other than the three speed restrictions shown in Table III of the Standard. Paragraph S6.1 requires all tires to pass the endurance test requirements of the Standard, and Table III shows the load and speeds to which the tires will be subjected during the endurance test. If the tire being subjected to the endurance test does not qualify for the special speeds and loads as one of the three speed restricted tires shown in the table or as a motorcycle tire, the tire would be tested at the speed and load shown under the heading "All other". This would mean that the tire's speed restriction would be ignored for purposes of the endurance test, and it would be tested as if it were a non-speed restricted tire. Such a tire would presumably fail the endurance test under these conditions, and no tire which fails to pass the endurance test can be sold in the United States. As a practical matter, therefore, speed restrictions other than the three shown in Table III of the Standard are not recognized by this agency.

The three speed restrictions shown in Table III of the Standard were adopted from descriptions of three types of speed restricted tires used by the United States tire industry in 1972, when the agency was initially promulgating Standard No. 119. If your company would like to add another speed restriction to those shown in Table III, you should file a petition for rulemaking with this agency requesting an amendment to Standard No. 119.

Sincerely,

ATTACH.

September 10, 1979

Tire Division, National Highway Safety Administration,

Re: Confirmation of the definition of Max. Speed

Dear Sirs,

We would like to confirm that meaning of Max. Speed specified in S6.5e of FMVSS No. 119 is as follow:

1 Max. Speed means the highest speed at which a tire can carry the max. single load that is molded on the tire sidewall.

If the actual carrying load is lower than max. single load, the tire can run at a higher speed than the Max. Speed molded on the tire sidewall.

Example

Tire Size 1000R20 Load range H

Max. Load single 6610lbs

Max. Speed 35MPH Load LBS Speed MPH 6610 Max. Load 35 Max. Speed 5300 42 4600 50

2 According to Table Endurance Test Schedule, Max. Speed For Speed-restricted Service is specified as 55, 50 or 35 MPH. May we choose speeds different from the above?

In this case, if Max. Speed chosen is 40 MPH, should the 50 MPH endurance test condition be used?

We would appreciate it very much if you would give careful consideration to our questions.

Very truly yours,

The Yokohama Rubber Co., LTD -- Tire Quality Assurance Department; Taiji Ide, Manager

ID: nht80-2.1

DATE: 04/14/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Moped Associates

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 11, 1980, forwarding to Mr. Schwartz of my office the proposed vehicle identification number (VIN) scheme for American Moped Associates, and in confirmation of your subsequent telephone conversation with Mr. Schwartz.

Your VIN scheme complies with the requirements of Federal Motor Vehicle Safety Standard No. 115, with the following exceptions. The fourth through eighth characters of the VIN are required by S4.5.2 and Table I of the Standard to encode certain descriptive characteristics of the vehicle. For motorcycles, which include mopeds, this information is (1) type of motorcycle, (2) line, (3) engine type and (4) net brake horsepower. While the information which American Moped Associates proposed to encode in the fourth through eighth characters will undoubtedly be useful to your company, it is not necessary to advise the agency of your internal coding. Further, while much of the information the Standard requires to be decoded from these characters is self-evident because of your product line, it is none-the-less necessary to forward this information to the agency as specified in the Standard.

Based on your discussions with Mr. Schwartz, it appears this may be easily accomplished utilizing essentially the same format as you currently propose. It is my understanding that you no longer intend to encode the color in the fifth position of the VIN, but rather utilize a single "filler" character such as an "M". Further, I understand that all your mopeds utilize the same engine and comprise two lines characterized by the number of speeds. Consequently, based on your product line, your submission to the agency might read:

Characters 1-3 LAM: WMI assigned to American Moped Associates. Character 4 (internal use) Character 5 M: Indicates moped type; gasoline, one cylinder engine with a displacement of ; net-brake horsepower measured at the crankshaft of . Character 6 (internal use). Character 7 1 indicates one-speed Indian line. Character 7 1 indicates two-speed Indian line. Character 8 (internal use) Character 9 Check digit. Character 10 Model year. Character 11 T: Indicates Taipei plant of manufacture.

Y: Indicates Yuanlin plant of manufacture. Characters 12-17 Sequential number.

Please feel free to contact Mr. Schwartz should you have any further questions on this matter. Sincerely,

ATTACH.

AMERICAN MOPED ASSOCIATES

March 11, 1980

Frederic Schwartz -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schwartz:

Pursuant to our recent telephone conversation concerning implementation of our VIN number, please find below for your approval a sample VIN number with notes explaining our coded identifiers.

LAMMB11A - AT123456

LAM - WMI assigned to American Moped Associates

M - Carburetor Type - alternate would be K

B - Color Black - G; Green - R; Red - W; White

1 - Wheel Type 1; Spoke - 2; Mag

1 - Number of Speeds 1; 1 Speed - 2; 2 Speed

A - Series changes letter from A to Z --- Check digit

A - Year of manufacture

T - Plant of mfr. T; Taipei - Y; Yuanalin

12346 - Numerical Sequence

If you have any questions, please feel free to call me at 1-800-854-6213.

Sincerely,

Bart Achille -- National Sales Manager

ID: nht80-2.10

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Union Springs Central School District

TITLE: FMVSS INTERPRETATION

TEXT:

APR 22 1980

Steven J. Kalies, Ed.D Asst. Supt. for Business Union Springs Central School District Union Springs, New York 13160

Dear Dr. Kalies:

This is in response to your letter of January 22, 1980, asking whether the Dubl-Life Saver Support restraint vest manufactured by Easy Way Products Co. is in compliance with applicable Federal motor vehicle safety standards. The advertisement you enclosed with your letter describes the Dubl-Life Saver as a support restraint vest for the safe transportation of all sizes of handicapped children in motor vehicles. The advertisement further claims that the safety belts used with the vest exceed "federal specifications".

Based on the information in the advertisement, it appears that the restraint vest does not provide pelvic restraint and thus does not comply with Standard No. 209, Seat Belt Assemblies. I have referred this matter to the agency's Office of Vehicle Safety Compliance for appropriate action.

The University of Michigan's Highway Safety Research Institute has conducted tests of various devices used to restrain handicapped children. I have enclosed a copy of a Society of Automotive Engineers paper describing the results of the testing.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

January 22, 1980

National Highway Traffic Safety Administration Office of Chief Counsel 400 7th St., S.W. Washington, D. C. 20590

Gentlemen:

As requested in the attached letter from Mr. Irving Rodness, Motor Vehicle Program Specialist, we are enclosing a copy of the brochure concerning the Dubl-Life Saver Support restraint vest from Easy Way Products Co.

Please advise as soon as possible if this vest meets federal specifications, as stated in the attached brochure.

Sincerely,

Steven J. Kalies, Ed.D Asst. Supt. for Business

jf Enc.

January 18, 1980

Mr. Steven J. Kalies Union Springs Central School District Union Springs, New York 13160

Dear Mr. Kalies:

During our telephone conversation, I envisioned the device you described being covered by our Federal Motor Vehicle Safety Standard (FMVSS) 209, Seat Belt Assemblies. By the description on the price sheet you enclosed in your letter of 1/8/80, I am now not too sure. This device may not be covered at all or is covered under our FMVSS 213, Child Restraint.

After a conversation with the NHTSA's Office of Chief Counsel, I am taking the liberty of forwarding your letter to them for their review and response. It would be helpful if a brochure or picture of this device could be sent to our Washington Office. If available, mail it to: NHTSA, Office of Chief Counsel (NOA-30), 400 7th Street, S.W., Washington, D.C. 20590, ATTN: Mr. Stephen L. Oesch. Thank you for bringing this matter to our attention.

Sincerely,

Irving Rodness Motor Vehice Program Specialist

cc: OCC NOA-30

ID: nht80-2.11

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: MPI, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This confirms your April 9, 1980, telephone conversation with Roger Tilton of my staff in which you asked whether a styrofoam board that lies beneath a layer of polyurethane foam would be required to comply with the flammability requirements of Standards No. 302, Flammability of Interior Materials.

As Mr. Tilton explained to you, the standard applies to seating components such as yours only to the extent that they fall within 1/2 inch of the occupant compartment air space. This requirement is specified in paragraph S4.2 of the standard. You indicated that your styrofoam board would not fall within 1/2 inch of the compartment because the polyurethane cover will always be thicker than 1/2 inch. Assuming this is true, your styrofoam board would not be required to comply with the standard.

ID: nht80-2.12

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Gas Alternatives Systems

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 1, 1980, letter asking what you must do to certify devices that you plan to import for sale in the United States. The devices to which you refer would convert an automobile's fuel system from gas to compressed natural gas or propane.

The National Highway Traffic Safety Administration issues safety standards and requires manufacturers of motor vehicles and equipment to certify that their vehicles or equipment comply with all applicable standards. To certify compliance to the standards, manufacturers must test or conduct some form of analysis of their vehicles or equipment. The Federal government does not get involved in the actual certification process. Once a manufacturer determines that its equipment or vehicles comply with the standards, it can then certify the vehicles or equipment without getting government approval.

With respect to the device that you propose to import, the agency has no safety standards applicable to this type of a device. Accordingly, as an importer of this equipment, you would have no certification responsibilities. However, the agency has a vehicle safety standard regulating fuel systems. If your device were designed to be installed in new motor vehicles, the manufacturer of those vehicles would be required to insure that your device would comply with the standard applicable to fuel systems. If your device would be installed on used vehicles, no manufacturer, dealer or repair business would be permitted to installed it if such installation would render inoperative the compliance of the vehicle with the safety standards.

To help clarify these general guidelines further, I am enclosing a copy of Part 567, Certification, which describes how to certify a vehicle in compliance with the safety standards. Further, I am enclosing a copy of our Safety Standard No. 301, Fuel System Integrity, which details the fuel system requirements for motor vehicles. Finally, we have prepared a short letter that gives information on the installation of alternate fuel systems in motor vehicles and that is enclosed for your information.

If we can be of further assistance, please contact us.

ENC.

ID: nht80-2.13

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Kenworth Truck Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your telephone conversation with Mr. Schwartz of my office in which you asked whether net brake horsepower must be decipherable from the engine type encoded in the vehicle identification number (VIN) of heavy trucks.

The precise net brake horsepower of heavy trucks (or any other vehicle class or type) need not be encoded. This was the point which the agency was making in its March 22, 1979 (44 FR 17489) statement that:

(While) net brake horsepower is among the characteristics to be considered in establishing an engine type, there is no requirement that it be encoded in the engine type code. In some instances, such as with heavy truck engines, encodement would not be practicable.

However, except as provided below, the range of net brake horsepower must be encoded to differentiate engine types as required by section 4.5.2 of Federal Motor Vehicle Safety Standard 115. To define the acceptable range of net brake horsepower for a single engine type, the agency made a clarifying amendment to that section (February 25, 1980; 45 FR 12257). Footnote 1 to Table I provides that otherwise identical engines having net brake horsepower ratings that vary up to plus or minus 10 percent, may be treated as being of the same engine type.

The exception to the requirement to encode the range of net brake horsepower involves manufacturers which intend to utilize more than 33 engine types whose horsepower ranges fall outside of the plus or minus 10 percent parameters. These manufacturers will be unable to encode their current or anticipated engine types utilizing only a single VIN position since there are 33 separate characters authorized to be used for each VIN position. Consequently, they need not encode net brake horsepower in any way. The agency did not intend that more than one VIN position be used to encode net brake horsepower. Using more than one position would be impracticable at this time given the amount of information that needs to be encoded in the VIN.

Please contact Mr. Schwartz should have any further questions concerning this subject.

ID: nht80-2.14

DATE: 04/23/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Douthitt; Mitchell & Paul

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 19, 1980, letter asking whether it is legal for a manufacturer to build a chassis that would normally have a high gross axle weight rating (GAWR) while continuing to certify the combined axle and chassis to a lower GAWR and gross vehicle weight rating (GVWR). The answer to your question is yes.

The chassis-cab manufacturer and the final stage manufacturer when certifying the proper GVWR and GAWR must consider the entire vehicle and its capacity to sustain the load for which it is designed. Therefore, if a manufacturer installs a heavy axle but does not reinforce the frame to correspond with the heavier axle, it must select a GVWR that reflects the capacity of the weaker frame rather than the stronger axle. The GAWR can be any amount appropriate for a given axle without regard to the vehicle's GVWR, provided the sum total of the Gross Axle Weight Ratings (GAWR) is not less than the Gross Vehicle Weight Rating (GVWR).

Your problem arises because the contract for purchase of the chassis-cab specified only the GAWR without insisting that the GVWR be similarly increased. This is entirely a private contractual matter and no Federal regulation of which we are aware has been violated.

ID: nht80-2.15

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: TRW, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

April 24, 1980 NOA-30

Mr. Nicholas M. Stefano Manager, Mechanical Device Development Advanced Systems Engineering TRW, Inc. Building E2, Room 4O62 One Space Park Redondo Beach, California 90278

Dear Mr. Stefano:

This responds to your letter of January 7, 1980, in which you described an automotive, electronic display device being designed by TRW and asked for a legal opinion as to its potential compliance with Federal Motor Vehicle Safety Standard No. 127, Speedometers and Odometers. You noted that, upon installation in a motor vehicle, TRW's device would continuously display vehicle and engine speed readings in the form of a bargraph. In potentially hazardous situations requiring the driver to take extra caution or to shut down the vehicle's engine, the TRW device would intermittently interrupt the display of vehicle and engine speeds with sequences of verbal messages. In light of this, you asked whether the fact that TRW's device would not display the vehicle speed during every moment of vehicle operation would prevent it from complying with Safety Standard No. 127.

Based on our understanding of your design, it appears that alternating the display of speed and verbal messages would not violate the standard. Although the future development of electronic digital speedometers was considered in the development of Safety Standard No. 127, the specific type of device described in your letter was not contemplated. The agency had expected that all speedometers would continuously display vehicle speed. While the intermittent display feature would apparently not violate Safety Sandard No. 127 as it is now written, we are concerned about the possible adverse impact upon traffic safety that this feature might have. In particular, we have in mind the effects of a driver's being unable to determine vehicle speed when he or she is approaching or negotiating a curve or exit ramp. Rapid deceleration to a particular speed is typically necessary in auch situations. In the case of a speedometer which periodically does not display vehicle speed for periods of 5 seconds, a vehicle that interval and a vehicle traveling at 40 mph, approximately 300 feet.

Although your alternative mode of operation would reduce this interval through flashing the speed for periods of 0.10 seconds, we question whether such a short period would be sufficient to enable drivers to read their speedometers. We solicit any tests or research that TRW has done on the safety side effects of your design. A member of the agency's accident avoidance division will contact you to discuss this issue further.

In looking at your design, we noted several aspects of it that would apparently not comply with Safety Standard No. 127. The design does not appear to be graduated in both miles and kilometers per hour as required by Section 9.1.2. Further, the design neither has the numeral 55 nor highlights either that numeral or the point at which vehicle speed equals 55 mph as required by section 4.1.5.

Finally, I would emphasize that this letter represents only the agency's opinion based on the information supplied in your letter. The NHTSA does not formally render judgment on the compliance of any vehicle or equipment design with any safety standard before the manufacturer's certification of its product. It is the manufacturer's responsibility under the law to determine whether its vehicle or equipment comply with all applicable safety standards and regulations and to certify its vehicles in accordance with that determination.

I hope that you will find this response helpful and have not been inconvenienced by our delay in sending it to you.

Sincerely,

Frank Berndt Chief Counsel

1272.1-80-02 January 7, 1980

Legal Counsel National Highway Transportation Safety Administration Department of Transportation 400 - 7th Street, S.W. Washington, D.C. 20590

Subject: Federal Motor Vehicle Standard No. 127

Dear Sir:

TRW is in the process of designing electronic display devices for the drivers of automobiles, trucks, tractors, off-highway vehicles, and agricultural equipment. One design concept utilizes a fluorescent display tube with 20 character positions which displays in bargraph form the vehicle speed and the engine RPM. The display is driven by a microprocessor. The microprocessor also collects data from a number of sensors that check the water level in the radiator, the water temperature and engine oil pressure. We intend to use the same display tube that shows speed and RPM to alert the driver to (1) conditions requiring caution on his part; or (2) to "dangerous" conditions requiring shutdown of the engine to avoid serious damage to the engine.

The microprocessor can drive the tube to provide a sequence of displays as shown in Figures 1 and 2 attached. In Figure 1 the top line shows a box for each of the 20 character positions. The speed is 48 MPH as indicated by the top bargraph; and the engine is running at 1220 RPM, as seen from the bottom bargraph in the top display. When the microprocessor detects a "caution" or "danger" condition, it immediately removes both bargraph messages and conveys a message to the driver in a series of 0.9 second ON and 0. 1 second OFF displays, as can be seen by reading the messages on each display line, reading from top to bottom.

In the case of the "caution" message, after 5 seconds the bargraphs return to a steady display condition for 15 seconds. The "caution" message is then repeated for 5 seconds, followed by 15 seconds of steady bargraph display. This message mode is continued until (1) the driver takes some action to change the situation; or (2) the situation changes from a "caution" to a "danger" condition. Figure 2 shows what happens in the latter case.

Subject regulation No. 127 does not offer any guidance to the engineer concerned with these new display concepts since the concepts were not anticipated at the time the regulation was prepared. If the legal interpretation is that the driver must have the vehicle speed displayed to him at every moment, an alternative mode of programming the display would utilize the 0.10 second OFF time slot to display the bargraph for MPH. In this case, the MPH information would not be seen by the driver for only 0.9 seconds (instead of 5 seconds, as in the previous sequence mode).

In either scheme, the basic reason for using one tube to display both MPH/ RPM and caution/danger messages is that the driver is constantly scanning MPH and RPM and will therefore be alerted sooner to a potential breakdown. It is also less costly to the truck purchaser because the cost of the second tube and its associated wiring is eliminated.

We would very much appreciate your guidance in this matter. We have talked by telephone to NHTSA technical personnel at your San Francisco and Washington offices and they have advised that we should seek your legal interpretation.

Very truly yours,

Nicholas M. Stefano

NMS:ml Attachments (2): Figure 1. Caution Message Sequence (Typical) Figure 2. Danger Message Sequence (Typical)

ID: nht80-2.16

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

APR 24 1980 NOA-30

Mr. James E. Forrester Manager of Engineering Services Truck Body and Equipment Association, Inc. 5530 Wisconsin Avenue, Suite 1220 Washington, D.C. 20015

Dear Mr. Forrester:

This responds to your March 17, 1980, letter asking for an interpretation of the certification label requirements as they apply to a manufacturer who performs some manufacturing operation on a stripped chassis. You indicated in your letter that the stripped chassis is not a chassis-cab and, therefore, does not have a certification label. You further stated that the second manufacturer's modification of the stripped chassis do not convert it to a chassis-cab.

The chassis certification label requirements of Part 567, Certification, and Part 568, Vehicles Manufactured in Two or More Stages, apply only to chassis-cabs as that term is defined in Part 567. Since the incomplete vehicle to which you refer is not a chassis-cab at either of the first two stages of its manufacture, it is not required to be labeled. The second manufacturer is required to amend the incomplete vehicle document where necessary to show the effects of its changes to the incomplete vehicle.

Your second question poses a similar hypothetical, except that the second manufacturer completes the incomplete vehicle to the point where it is a chassis-cab. In this instance, the second manufacturer is required to attach the chassis-cab certification label. Also, all necessary amendments must be made in the incomplete vehicle document.

Sincerely,

Frank Berndt Chief Counsel

17 March 1980

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Attention: Roger Tilton

Gentlemen:

The purpose of this letter is to confirm your oral interpretation of certification procedures involving stripped chassis and chassis cabs. A member of TBEA plans to modify stripped chassis and is seeking guidance as to the proper procedures.

Your interpretation was that:

(1) In the case where they start with a stripped chassis and do work that does not cause it to become a chassis cab, their only responsibility under Parts 567 and 568 is to provide an addendum to the incomplete vehicle document as described in Part 568. No certification label is required in this instance.

(2) Where they start with a stripped chassis and their work results in the incomplete vehicle being classified as a chassis cab then they are considered the chassis cab manufacturer and are required to:

(a) provide an addendum to the incomplete vehicle document (Part 568)

(b) attach a certification label which contain the statements of Part 567.5a

The location of the certification label must be in accordance with Part 567, Certification.

Your written confirmation of the above is requested.

Sincerely yours,

James E. Forrester Manager of Engineering Services

ID: nht80-2.17

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Karl-Heinz Ziwica Manager, Safety & Emission Control Engineering BMW of North America, Inc. Montvale, New Jersey 07645

Dear Mr. Ziwica:

This responds to your letter of March 12, 1980. You asked whether, in the case of motorcycles, the appearance of the vehicle identification number (VIN) on the certification label required by 49 CFR Part 567 satisfies the requirements of S4.3 of Safety Standard No. 115 (49 CFR 571.115). The answer is yes. The Part 567 certification label meets note that, in order to satisfy Safety Standard No. 115, the VIN on the certification label must meet the style requirements of S4.3.1.

Sincerely,

Frank Berndt Chief Counsel

March 12, 1980

Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 - 7th Street S.W. Washington DC 20590

RE: Request for Interpretation FMVSS 115, Vehicle Identification Number

Dear Sir

We request confirmation, that in the case of motorcycles, it would be permissible to simultaneously comply with FMVSS 115, S 4.3, and Part 567.4 (a), (b), (e) and (g)(6), which describe the method of affixing a VIN to a motorcycle in substantially the same language that is not mutually exclusive. It is our understanding that the certification label, which must bear the VIN, if applied in the form of a permanent label that cannot be removed without destruction, to the chassis of a motorcycle as close as practicable to the intersection of the steering post with the handle bars, would fulfill the requirements of both Part 567 and FMVSS 115.

Very truly yours

Karl-Heinz Ziwica, Manager Safety & Emission Control Engineering

KHZ/jps