Interpretation ID: nht80-1.30

DATE: 03/11/80

FROM: JAMES W. LAWRENCE -- MANAGER ENGINEERING RELIABILITY & GOVERNMENT STANDARDS DEPT. WHITE MOTOR CORPORATION

TO: FRANK BERNDT -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN.

TITLE: FMVSS-115 REQUEST FOR INTERPRETATION - S 4.5.3.3 SEQUENTIAL ASSIGNMENT OF SERIAL NUMBERS

TEXT: Dear Mr. Berndt:

White Motor Corporation sequentially assigns serial numbers by customer to enhance problem reporting, repair parts purchasing, vehicle licensing and defect recall. When a customer orders 50 vehicles, the attributes of which are identical, the 50 serial numbers will be sequential and assigned only to those vehicles. During the manufacturing process, if all or part of the order is cancelled, the serial numbers assigned to the unbuilt vehicles are cancelled and not reissued for any other vehicle. The remaining numbers as well as those in preceeding and subsequent customer orders are therefore sequential even though not every number is used.

The preamble discussion on page 36451 of the August 17, 1978 Federal Register addressing the issue of some manufacturers desiring to keep confidential the total number of vehicles manufactured is, in our opinion, a corrolary to this condition. White believes, and requests confirmation that, the requirement for sequential assignment does not also require the use of every number in the sequence.

Sincerely,