Steve,
Any time I have seen "color" as a category on a birth (and sometimes marriage) record it does refer to race.
I've seen forms that asked for description of complexion, however that is different from "color." Complexion might be described as ruddy or fair, etc.
Many births were attended by midwifes, and many were barely literate and/or their English was limited. It may be that the midwife did not understand the question.
I do not know if most NYC birth certs were written out by the midwife, or by a clerk. That would be an interesting thing to find out.
It may be that a clerk just made an error, or misunderstood what the midwife said, or the midwife simply did not understand the question.
Regards,
Sherri Bobish