Interpretation ID: nht87-1.68

TYPE: INTERPRETATION-NHTSA

DATE: 04/21/87

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Mr. Koji Tokunaga

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Koji Tokunaga Manager, Engineering Isuzu Motors America, Inc. 21415 Civic Center Drive Southfield, MI 48076-3969

Dear Mr. Tokunaga:

This letter responds to your inquiry of June 25, 1986, requesting an interpretation of S4.5 of Standard No. 115, Vehicle Identification Number--Basic Requirements, regarding the "part of the vehicle" on which the vehicle identification number (VIN) shoul d appear. I regret the delay in replying to your letter.

You ask whether either of two specific locations within the passenger compartment of a vehicle would meet the VIN location requirement, and submit diagrams of these locations. Paragraph S4.5 of Standard No. 115 reads:

"The VIN of each vehicle shall appear clearly and indelibly upon either a part of the vehicle other than the glazing that is not designed to be removed except for repair or upon a separate plate or label which is permanently affixed to such a part."

You state in your letter that your concern is whether a VIN or a plate or label with the VIN affixed to it, may be "fitted to a part that is not designed to be removed except for repair but that can be replaced by a new part as a result of the repair."

We interpret S4.5 to require that the VIN be placed on a part that is designed to be removed only for the purpose of repairing (or replacing) that part. Thus, the VIN may not be placed on a part which is designed to be removed to allow the maintenance or repair of other parts.

The first location you describe is the instrument panel front cover. That cover is a plastic strip immediately behind and below the inner surface of the front windshield, and it appears from your diagram that the part is designed to be removed only for i ts repair or replacement. If that is correct, placing the VIN at this location would meet the requirement of S4.5.

The second location is the top of the meter upper hood. On your diagram, this location seems to be on the plastic cover for the speedometer and tachometer. It appears from the diagram that the meter upper hood is designed to be removed to permit the repa ir or maintenance of those meters or other parts of the dash board. If this is the case, then this location would not comply.

As a separate matter, we note from your diagram that the meter hood location may be in a passenger car, multipurpose passenger vehicle, or light truck. If that is so, you must meet both the S4.5 requirement with respect to placement of the VIN, and the r eadability requirement of S4.6.

I hope this information is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel

June 25, 1986

Mr. Jeffrey R. Miller Chief Counsel National Highway Traffic Safety Administration 700 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Miller:

Subject: Confirmation of NHTSA's Interpretation of our Request

The attached letter, DE-85-181, requested your agency's interpretation regarding "a part of the vehicle" where the vehicle identification number (VIN) is required to appear.

We mailed this letter last August. However, we have not received your interpretation. On June 24th and 25th, Mr. Imai or Isuzu Motors America, spoke with your secretary and was informed that you do not have any record of this request. Therefore, we are s ending this letter again. Please check your records and please forward your interpretation.

We would appreciate your response as soon as possible.

If you have any questions, please contact us.

Sincerely yours,

Koji Tokunaga Manager, Engineering

August 26. 1985

Mr. Jeffrey R. Miller Chief Counsel National Highway Traffic Safety Administration 700 Seventh Street. S.W. Washington. D.C. 20590

Dear Mr. Miller:

Subject: VIN Durability.

The purpose of this letter is to request your agency's interpretation regarding "a part of the vehicle" where the vehicle identification number (VIN) is required to appear.

FMVSS 115. S4.5 requires a VIN to be fitted to "...a part of the vehicle...that is not designed to be removed except for repair Our concern is whether the VIN may be fitted to a part that is not designed to be removed except for repair but that can be re placed by a new part as a result of the repair. In the context of a specific vehicle, we would request you to advise us whether it meets the requirement to affix the VIN or a VIN plate or label to either of the following parts in the locations shown in t he attached fig. 1 and 2:

1. Instrument panel front cover (Fig. 1)

This cover is made of plastics and can be detached from the vehicle by removing a clip on each side and the three screws shown. There is a possibility, although not great, of this cover being replaced by a new cover when damaged or badly stained.

2. Meter upper hood (Fig. 2)

This hood is also made of plastics, and can be detached from the vehicle by removing the four screws shown. The possibility of this hood being replaced is still smaller but not nil.

We would appreciate your prompt confirmation as to whether affixing the VIN to these parts meets the requirements of S4.5 of FMVSS 115.

Sincerely yours.

Koji Tokunaga Manager. Engineering

SEE HARD COPY FOR GRAPHIC ILLUSTRATIONS