Interpretation ID: nht80-2.32

DATE: 05/06/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Miller Tilt-Top Trailer Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 2, 1980, in which you request approval for the vehicle identification numbering (VIN) system Miller Tilt-Top Trailer, Inc., proposes to use to satisfy the requirements of Federal Motor Vehicle Safety Standard 115 (49 CFR 571.115).

The National Highway Traffic Safety Administration does not approve a manufacturer's compliance with the safety standards, as manufacturers serve as self-certifiers under the National Traffic and Motor Vehicle Safety Act. However, my office has reviewed your proposed system. Based on our understanding of the information that you have provided, your system apparently complies with Standard No. 115. We would also recommend that when you submit information to the agency pursuant to S6 of the standard, you follow each "series" designation (4th and 5th characters of the VIN) with the phrase "rectangular, flat platform trailer and body."

Sincerely,

ATTACH.

April 2, 1980

Fred Schwartz -- U.S. Department of Transportation, National Highway Traffic Safety Administration

Re: FMVSS-115 VIN Requirement

Dear Mr. Schwartz:

The following is my understanding of the new VIN requirement, as it will be implemented by Miller Tilt-Top Trailer:

- To be supplied by S.A.E.

- Series of trailer (i.e. "OT").

- Length of platform to nearest foot (i.e. "20"). *

- Number of axles (i.e. "4").

- Check digit (calculated per S5.1).

- Model year (i.e. "A" for 1980).

- Plant of manufacture (i.e. "M" for Milwaukee).

- Sequential number assigned by Miller Trailer

* - All trailers that we manufacture have a rectangular, flat platform which should satisfy the "Type of Trailer" and "Body Type" information requirements.

Does all of this information meet with D.O.T. approval?

Sincerely,

MILLER TILT-TOP TRAILER, INC.;

Philip J. Carpenter -- Administrative Engineer