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American Government Special Collections Reference Desk

American Government


Barry Felrice
National Highway Traffic Safety Administration
Federal Register
September 26, 1994

[Federal Register: September 26, 1994]


49 CFR Part 567


AGENCY: National Highway Traffic Safety Administration (NHTSA), 
Department of Transportation (DOT).

ACTION: Denial of petition for rulemaking.


SUMMARY: This notice denies a petition for rulemaking submitted by the 
American Association of Motor Vehicle Administrators (AAMVA) concerning 
vehicle identification numbers (VINs). One of this agency's Federal 
motor vehicle safety standards requires all motor vehicles to have a 
VIN. In addition, NHTSA's certification regulation requires the 
certification label on each motor vehicle to bear that vehicle's VIN. 
AAMVA suggested that NHTSA amend its certification regulation to 
require the VIN of each trailer to be marked in a second location on 
the trailer to ensure the VIN is present on the vehicle in the event 
the certification label becomes illegible or lost. The petitioner also 
believes marking the VIN in a second location will help state officials 
find the VIN during vehicle inspections.
    NHTSA is denying the petition because the agency has an ongoing 
rulemaking on the issue of improving the permanency and legibility of 
vehicle certification labels on trailers and other motor vehicles. 
Since those labels include the VIN, possible improvements to 
certification labels would address petitioner's concerns about the 
permanency and legibility of the VIN.

FOR FURTHER INFORMATION CONTACT: Dr. Leon DeLarm, Chief, Pedestrian, 
Heavy Truck and Child Crash Protection Division, Office of Vehicle 
Safety Standards, National Highway Traffic Safety Administration, 400 
Seventh Street, SW, Washington, DC 20590; (202) 366-4920.


    NHTSA's certification regulation, 49 CFR 567, Certification, 
requires motor vehicle manufacturers to affix a certification label to 
each motor vehicle. The label constitutes the manufacturer's 
certification that the vehicle complies with all applicable Federal 
motor vehicle safety standards. Section 567.4 specifies where the label 
must be located and what information it must include. With respect to 
trailers, the label must be located on the forward half of the left 
side of the vehicle such that it is easily readable from outside the 
vehicle without moving any part of the vehicle. One of the items of 
information required to be displayed on the label is the VIN.
    The VIN is a unique identifier that facilitates NHTSA's analysis of 
accident data and assessment of vehicle recall campaigns. Standard No. 
115, Vehicle Identification Number--Basic Requirements, 49 CFR 571.115, 
requires each motor vehicle to have a VIN. It further requires the VIN 
to be marked clearly and indelibly either on a part of the vehicle that 
is not designed to be removed or on a separate plate or label, such as 
the vehicle certification label required by 49 CFR 567. 49 CFR 565, 
Vehicle Identification Number--Content Requirements, specifies the 
content and format for the VIN. Among other things, Part 565 requires 
the VIN to provide information on the characteristics of the vehicle, 
such as its gross vehicle weight rating (GVWR).
    Since a trailer's VIN is placed on the certification label, the 
extent to which a trailer's VIN remains legible throughout the life of 
the vehicle depends on the permanency of that label. Part 567 specifies 
that, unless riveted, the label must be permanently affixed such that 
it cannot be removed without destroying it (Sec. 567.4(b)). However, 
Part 567 does not specify any other requirements that ensure the 
permanency of the certification label, such as requiring the label to 
be fabricated from a durable material.

The Petition

    AAMVA petitioned NHTSA to improve the permanency of the VIN 
marking. AAMVA petitioned on behalf of its members, state motor vehicle 
administrators. They use the VIN to register vehicles, to determine 
proper ownership of vehicles, and to find the GVWR that the vehicle 
manufacturer assigned to the vehicle. The petitioner said that state 
officials use the GVWR information for, among other purposes, 
determining whether a vehicle is overloaded on the highways. AAMVA 
suggested that NHTSA require trailers to have the VIN stamped, etched 
or otherwise permanently marked in a location other than the 
certification label. AAMVA stated that certification labels are 
typically plastic coated and become illegible with age and exposure to 
the elements. Thus, the information on the label--particularly the 
VIN--becomes ``illegible long before the useful life of the trailer'' 
ends. Petitioner believed that a second VIN marking would provide a 
backup means for determining the weight ratings and other pertinent 
information for the trailer.

Agency Decision

    NHTSA is denying AAMVA's petition. The petitioner's justification 
for its suggestion, missing GVWR information, is being addressed for 
trailers in a separate NHTSA rulemaking. That rulemaking action seeks 
to improve the permanency and legibility of the certification labels 
used on commercial motor vehicles. It was initiated when NHTSA granted 
in part a petition for rulemaking submitted by the Michigan Department 
of State Police (MDSP).
    The MDSP raised concerns similar to those of the AAMVA regarding 
the ability of state officials to locate GVWR and VIN information on 
commercial vehicles. The MDSP stated that law enforcement officers 
often have difficulty determining the GVWRs of commercial vehicles 
because the labels on those vehicles are often damaged, painted over or 
removed, usually accidently, during the life of the vehicle. The 
petitioner believed that a vehicle's VIN and GVWR information should be 
made more accessible and legible on commercial vehicles to enable 
police officers to more readily inspect and investigate commercial 
vehicles during routine traffic stops. Among other things, the MDSP 
suggested requiring certification labels for large commercial vehicles, 
including trailers, to be made of metal, with raised or recessed 
letters and numbers (see RIN 2127-AE71).
    In response to the MDSP petition, NHTSA will consider the need to 
improve the permanency and legibility of the certification labels for 
large trailers, and possible ways to improve the labels. Since these 
labels include the VIN, any improvements to the certification label 
will have the effect of improving the permanency and legibility of the 
VIN. In addition, NHTSA will request comments in that rulemaking on 
whether small trailers should also meet the requirements being proposed 
for large trailers, and whether some different approach, other than the 
proposed metal label requirement, would be more effective for the 
certification labels. Since that rulemaking will address AAMVA's 
concerns about the permanency and legibility of VIN markings, AAMVA's 
petition is moot.

    Authority: 49 U.S.C. 322, 30111, 30162; delegations of authority 
at 49 CFR 1.50 and 501.8.

    Issued on September 21, 1994.
Barry Felrice,
Associate Administrator, for Rulemaking.
[FR Doc. 94-23731 Filed 9-23-94; 8:45 am]

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