Interpretation ID: 2775y
Vice President-Engineering
Truck Trailer Manufacturers Association
1020 Princess Street
Alexandria, Virginia 22314
Dear Mr. Vierimaa:
This is in response to your association's request that this office review the most recent revision of the Truck Trailer Manufacturers Association's (TTMA) Recommended Practice Number 56, "Trailer Vehicle Identification Number." After that review, we have the following comments. Please note, however, that these comments do not constitute any sort of NHTSA approval or endorsement of the TTMA's Recommended Practice.
The TTMA Recommended Practice appears to provide correct information about NHTSA's vehicle identification number (VIN) requirements, as set forth in 49 CFR Part 565, Vehicle Identification Number-Content Requirements and Standard No. 115, Vehicle Identification Number-Basic Requirements (49 CFR 571.115). However, in several instances, the Recommended Practice goes beyond what is required by NHTSA's VIN regulations to recommend one particular means be used to assign a section of the VIN, when NHTSA's regulations leave the assignment of that section to the discretion of the vehicle manufacturer. Examples of the TTMA recommendations going beyond the NHTSA regulations may be found in the explanations provided in Part 13.0 on the Vehicle Descriptor (Second) Section Code, Part 14.0 Check Digit (Third) Section Code, and Part 15.0 Vehicle Indicator (Fourth) Section Code. While TTMA is free to make these recommendations, it may be helpful for your members to recognize the distinction between VIN information that is required by NHTSA, and therefore must follow an exact format according to Federal law, as opposed to matters that are within the discretion of the assigner of the VIN, and for which the TTMA provides one suggested means by which the requirement(s) may be fulfilled.
We offer the following comments on particular sections of this recommended practice: Part 6.0 Definitions
The definitions of "body type," "line," "make," and "series" are not identical to the definitions in Title 49 CFR Part 565. In addition, since this section of your recommended practice states that the definitions in Part 6 "are used in NHTSA regulations," you may wish to note that NHTSA does not define the terms "production sequence," and "type of trailer" in its regulations.
Part 9.1 Location
This part should note that 49 CFR Part 567.4(d) requires certification labels (which must include VINs) to be affixed "to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle."
Part 11.0 VIN Content
You may wish to note that the content requirements in this part of the recommended practice are a paraphrase and explanation of NHTSA's VIN content requirements, set forth at 49 CFR Part 565 Vehicle Identification Number-Content Requirements.
16.0 References
Please note that the National Highway Traffic Safety Administration has issued a VIN system information bulletin dated July 1985. I am enclosing a copy of it. Please feel free to reproduce this information and provide it to your members. They may also receive it directly from NHTSA by writing to us.
If there are any further questions or concerns, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel
Enclosure ref:ll5#565 d:l2/3/90