NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam5358OpenLance Tunick, Esq. Bugatti 1919 Mount Zion Golden, CO 80401; Lance Tunick Esq. Bugatti 1919 Mount Zion Golden CO 80401; "Dear Mr. Tunick: This responds to your letter concerning low volum CAFE exemptions. I apologize for the delay in our response. You asked whether Bugatti Automobili S.p.A. (Bugatti) and Lotus Cars, Ltd. (Lotus), both of which are controlled by the same holding company, may submit separate low volume CAFE exemption petitions requesting two separate alternative standards. As discussed below, the answer to this question is no. Since any alternative CAFE standard would apply to Bugatti and Lotus together, a single combined petition must be submitted for a single alternative standard. According to your letter and a separate one received from Lotus, General Motors sold Lotus to Bugatti International Holding, SA, in August 1993. That holding company also controls Bugatti, which is planning to enter the U.S. market in the near future. Lotus and Bugatti intend to submit petitions for low volume CAFE exemptions. Moreover, the joint annual production of Bugatti and Lotus is far below the 10,000 vehicles per year eligibility threshold for low volume CAFE exemptions. In a telephone conversation with Edward Glancy of my staff, you indicated that Lotus cars are imported by Lotus USA. You also indicated that Bugatti cars could be imported by Lotus USA, or could be imported by a new company that would be established by Bugatti, e.g., 'Bugatti USA.' Finally, you indicated that Lotus USA is not in a control relationship with any other auto manufacturers. In addressing whether Bugatti and Lotus would be eligible for two separate standards, I will begin by identifying the statutory provisions which are relevant to determining who manufactures the vehicles at issue. Under section 501(8) of the Motor Vehicle Information and Cost Savings Act, '(t)he term 'manufacturer' means any person engaged in the business of manufacturing automobiles.' Under section 501(9), '(t)he term 'manufacture' (except for purposes of section 502(c)) means to produce in the customs territory of the United States, or to import.' Under section 501(10), '(t)he term 'import' means to import into the customs territory of the United States.' Under these sections, the company which imports foreign-built cars into the United States is the manufacturer of those automobiles. Thus, if Lotus USA imported Lotus cars and Bugatti cars, Lotus USA, rather than Bugatti Automobili S.p.A. and Lotus Cars, Ltd., would be considered the manufacturer of those vehicles for CAFE purposes. Since Lotus USA would be the manufacturer of all the vehicles under this scenario, and CAFE standards apply to all passenger automobiles manufactured by a manufacturer, there would be no basis for Bugatti and Lotus to request two separate standards. Instead, a single alternative standard would need to be requested for Lotus USA, which would cover all automobiles imported by that company. This result would not change if Bugatti established a new company, Bugatti USA, for importing cars into the U.S. This is because of the operation of section 503(c), which provides that any reference to 'automobiles manufactured by a manufacturer' is deemed to include all automobiles manufactured by persons who control, are controlled by, or are under common control with, such manufacturer. Since Lotus USA and Bugatti USA would presumably be under common control (traced back to Bugatti International Holding, SA), their fleets would be combined for CAFE purposes. Since many of the arguments you raise in your letter are relevant to this type of scenario, i.e., one in which Lotus and Bugatti cars would be considered to be manufactured by manufacturers within a control relationship, I will assume it for the rest of this letter. As you noted in your letter, NHTSA addressed the issue of how alternative CAFE standards apply to manufacturers within a control relationship in a July 1991 decision concerning low volume exemption petitions submitted by Ferrari. Ferrari and Alfa Romeo were under the common control of Fiat. We stated the following: Because of the operation of section 503(c), Ferrari and Alfa Romeo are in essence the same manufacturer for purposes of CAFE standards. As discussed below, under section 502, the same CAFE standard should apply to both manufacturers together. This is true for both generally applicable standards and alternative standards. Section 502(a), in setting forth the generally applicable standard, specifies a standard for 'passenger automobiles manufactured by any manufacturer.' Section 502(c)(1), in setting forth requirements relating to low volume exemptions, specifies that such exemptions may not be granted unless the Secretary establishes, by rule, alternative average fuel economy standards for 'passenger automobiles manufactured by manufacturers' which receive exemptions under this subsection. Under 503(c)(1), any reference to 'automobiles manufactured by a manufacturer' is deemed to include all automobiles manufactured by persons who control, are controlled by, or are under common control with, such manufacturer. Thus, any CAFE standard which applies to Ferrari should apply to Ferrari and Alfa Romeo together. Therefore, granting Ferrari a low volume exemption in MY 1988 would create a paradox, since Alfa Romeo is indisputably not eligible (given its own worldwide production) for an exemption. A similar paradox would arise in the context of determining compliance with the statute. Under section 503(a), neither manufacturer may have an independent CAFE value. Instead, by operation of section 503(c), they share a CAFE value that is based on the total volume of cars imported by both companies. Thus, a decision to grant an exemption to Ferrari while applying the generally applicable standard to Alfa Romeo would cause compliance enforcement difficulties by compelling the agency to try to compare a combined CAFE value to separate CAFE standards. 56 FR 31461, July 10, 1991. You argued in your letter that, because of factual differences, the Ferrari/Alfa analysis should not be applied to the Bugatti/Lotus situation, and Bugatti and Lotus should be permitted to submit separate low volume CAFE exemption petitions requesting two separate alternative standards. While we agree that there are factual differences, e.g., Ferrari and Alfa Romeo together produced too many vehicles to meet the eligibility threshold while Bugatti and Lotus do not, the situations are identical with respect to the issue of how CAFE standards apply to manufacturers within a control relationship. In particular, since Lotus USA and Bugatti USA would be under common control and because of the operation of section 503(c), the two companies would in essence be the same manufacturer for purposes of CAFE standards. Any alternative standard issued under section 502 would apply to the two companies together. Moreover, neither manufacturer would have an independent CAFE value under section 503(a). Instead, by operation of section 503(c), they would share a CAFE value that is based on the total volume of cars imported by both companies. Therefore, the same CAFE standard would necessarily apply to the two companies together. You raised several other objections in your letter. First, you stated that the CAFE statute provides that 'a manufacturer' may submit a petition for a CAFE exemption, and a joint petition would not fall within this provision. In fact, any one of the related companies (Lotus, Lotus USA, Bugatti, the Bugatti U.S. subsidiary, or the holding company) could submit a petition on behalf of the combined companies. However, any such petition would apply to the combined fleet of both Bugatti USA and Lotus USA. You also stated that combining two small companies together would muddy the question of the best fuel economy that each company is capable of achieving. However, NHTSA would simply assess the 'maximum feasible average fuel economy level' that could be achieved by the combined Bugatti/Lotus fleet. We recognize that this level would be dependent on assumptions about the relative volumes of Bugatti USA and Lotus USA. However, the agency needs to take this factor into account in assessing the capability of any manufacturer which produces vehicles with varying fuel economy values. Finally, you stated that if a joint alternative standard was established, NHTSA would face a difficult enforcement situation in the event of a failure to comply with the standard. You asked how the agency would divide the civil penalties. It is our opinion that Lotus USA and Bugatti USA would be jointly and severally liable for the full amount of the civil penalty, although we would permit the two companies to divide the penalty between themselves. I would like to address two other issues that are raised by the factual situation described in your letter: (1) the immediate eligibility of Bugatti/Lotus given that Lotus was owned by General Motors until August 1993, and (2) the timing of petitions for low volume exemptions. As you know, section 502(c)(1) specifies that low volume exemptions are only available for manufacturers 'who manufactured ... fewer than 10,000 passenger automobiles in the second model year preceding the model year for which the application is made....' (Emphasis added.) During the time that Lotus was owned by General Motors, the combined companies manufactured far more than 10,000 vehicles. It is our opinion that Lotus does not have to wait two years from the date it ceased being in a control relationship with General Motors to be eligible, given the circumstances described above. In particular, we believe that the requirement that a manufacturer have manufactured fewer than 10,000 passenger automobiles in the second model year preceding the model year for which the application is made was intended to address varying production levels (above and below 10,000) and not a situation where a small manufacturer such as Lotus is sold by a large manufacturer. With respect to the timing of petitions, NHTSA's regulations at 49 CFR 525.6, Requirements for petition, state that petitions from low volume manufacturers for alternative fuel economy standards must be 'submitted not later than 24 months before the beginning of the affected model year, unless good cause for later submission is shown.' Clearly, the deadline for a timely submission for model years 1994-96 has passed. On the issue of 'good cause' for a later submission, we note that Lotus was not sold by General Motors until August 1993, and both Lotus and Bugatti requested our opinion concerning submitting a petition within three months of that sale. Under the circumstances, we conclude that, Lotus/Bugatti have, to date, taken reasonable measures to submit a petition in as timely a manner as possible. Therefore, if a petition that meets the requirements of 49 CFR Part 525 is submitted promptly after receipt of this letter, we will consider there to be good cause shown for submitting a late petition for model years 1994-96. I also note that a petition for model year 1997 would be due later this year. I hope this information is helpful. If there are any questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2167OpenMr. LeRoy E. Mueller, President, Wisconsin Trailer Company, Inc., Richfield, WI 53076; Mr. LeRoy E. Mueller President Wisconsin Trailer Company Inc. Richfield WI 53076; Dear Mr. Mueller: This responds to your November 26, 1975, request for confirmation tha the NHTSA permits the establishment of gross axle weight ratings (GAWR) for trailer axles based on use at a speed of less than 60 mph.; Your interpretation is incorrect. In the April 28, 1975, interpretatio letter to Mr. James Srch that was enclosed in the NHTSA's recent letter to you, it was stated that '. . .NHTSA has found it necessary to specify that GAWR's and GVWR's be calculated on the basis of highway speeds and not qualified by reduced speed ratings. . . .'; Since the NHTSA's November 20, 1975, letter to you, the agency ha published a proposal that would amend the definition of GAWR to conform to this interpretation. A copy is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2537OpenMr. Robert B. Kurre, Director Engineering, Wayne Corporation, P. O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director Engineering Wayne Corporation P. O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your oral request of February 17, 1977, for a interpretation of the requirements of Standard No. 210, *Seat Belt Assembly Anchorages*, as they apply to Standard No. 222, *School Bus Passenger Seating and Crash Protection*. In particular, you ask how much force must be used when testing school bus seat belt anchorages for compliance with the standards.; As you may know, the National Highway Traffic Safety Administration initially proposed that seat belt anchorages be installed in all school buses. At that time, we also proposed that each seat belt assembly be tested under a force of 1,500 pounds. A seat containing three seating positions would have had the three seat belt assemblies tested simultaneously with a possible resulting load upon the seat of 4,500 pounds. The requirement of seat belt anchorages in larger buses was dropped from the proposal based upon comments from school bus operators and as a result of our compartmentalization approach to passenger seating safety in school buses.; The present Standard No. 222 requires seat belts and anchorages i small buses and mandates testing of the anchorages as outlined in Standard No. 210. Standard No. 210 requires in S4.2.1 that each seat belt assembly sustain a force application of 5,000 pounds. Where two adjacent seating positions have a common seat belt anchorage mounted on a seat frame, the two seat belt assemblies must simultaneously sustain a 5,000 pound force for a maximum load on the seat of 10,000 pounds.; Standard No. 207, *Seating System*, requires the simultaneous testin of all seat-mounted seat belt assemblies, whether or not they have common anchorages. However, Standard No. 207 is not applicable to school bus seatsconstructed (sic) in accordance with Standard No. 222, and it is not necessary to test simultaneously all seat belt assemblies attached to anchorages mounted on a school bus seat frame.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2022OpenMr. Dennis Replansky, Four Penn Center Plaza, Philadelphia, PA 19103; Mr. Dennis Replansky Four Penn Center Plaza Philadelphia PA 19103; Dear Mr. Replansky: This responds to your recent request for a discussion of wha constitutes the manufacture of a new trailer when used components from an existing trailer are utilized. As you are aware, a newly-manufactured air-braked trailer must, in all but a few cases, be equipped with an air brake system that conforms to Standard No. 121, *Air Brake Systems*.; The use of new components in combination with used components t assemble a complete vehicle is a common practice in both truck and trailer operations. The National Highway Traffic Safety Administration (NHTSA) has recognized this commercial practice by establishing that the use of a new body on a used 'chassis' that has already been certified does not constitute the manufacture of a new vehicle. In contrast, placing a used body on a new chassis that has never been certified as a vehicle has been determined to create a newly-manufactured vehicle that must be certified. This distinction did not present difficulty to trailer manufacturers in the past, when they were only required to meet the lighting requirements of Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Since implementation of Standard No. 121, however, manufacturers hav had to determine whether the particular assembly they undertake contains a used 'chassis' which would not be required to meet the air brake standard. As a general matter, the NHTSA has stated that, as a minimum, the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and main frame of the existing vehicle must be used to qualify as a used 'chassis'. However, the many different types of trailer construction make it difficult to determine what constitutes the main frame of some configurations. The NHTSA has concluded that the load-bearing structural member(s) which run the length of the vehicle and support the trailer will be considered to be the 'main frame'.; In the case of monocoque van construction, the trailer side walls whic constitute the main load-bearing members through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of container chassis, the box frame that consitutes (sic the main load- bearing member through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of a platform trailer, the main frame members which run th length of the trailer must be reused in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of a tank trailer in which the tank serves the purpose o and replaces frame rails, the tank must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle. If a separate frame serves as the load-bearing member through the length of the vehicle, the tank could be replaced without the operation constituting the manufacture of a new vehicle. An inner tank may be replaced without certification as a new vehicle if the inner tank does not serve as a main load-bearing member.; Modifications of existing trailers to increase or decrease volumetri capacity or vehicle length are generally permitted without recertification. For example, the barrel of a tank trailer may be lengthened in response to the new weight limits without recertification of the vehicle.; In closing, it should be noted that Bureau of Motor Carrier regulation may differ on modification or rebuilding of vehicles in interstate commerce.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2472OpenMr. Michael E. Bufkin, 1136 Gail Lane, Sleepy Hollow, IL 60118; Mr. Michael E. Bufkin 1136 Gail Lane Sleepy Hollow IL 60118; Dear Mr. Bufkin: This responds to your November 12, 1976, question whether a tire bran name owner is required by S 574.7(b) of Part 574, *Tire Identification and Recordkeeping*, to establish and maintain specified purchaser information on its tires if the distributor or dealer fails to provide that information as specified by S 574.8 of the regulation. You also ask whether a tire registration form with dimensions other than those specified in Figure 3 of the regulation may be provided to tire distributors and dealers.; Section 158(b) of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S 1418(b)) mandates the tire manufacurer's (sic) (including brand name owner's) responsibility to establish and maintain the purchaser information, independent of the distributor's or dealer's cooperation:; >>>S 158(a)(1) * * * * * (b) Every manufacturer of motor vehicle or tires shall cause th establishment and maintenance of records of the name and address of the first purchaser of each motor vehicle and tire produced by such manufacturer * * *<<<; Thus, the brand name owner's responsibility is a statutory one independent of any interpretation of Part 574.; With regard to the size of the tire registration form, S 574.7(a permits the use of any size form unless a dealer requests forms that conform to the universal format set forth in Figure 3. The agency has interpreted the requirement for provision of the universal format to not apply in the case of a dealer that sells only one brand of tire.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2188OpenMr. Stuart R. Perkins, Director, Vehicle Safety, Jeep Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. Stuart R. Perkins Director Vehicle Safety Jeep Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Perkins: This responds to Jeep Corporation's October 16, 1975, petition t initiate rulemaking to amend the present definition of 'Unloaded vehicle weight' (49 CFR S571.3) which reads:; >>>'Unloaded vehicle weight' means the weight of a vehicle with maximu capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants.<<<; Jeep requests that the definition be amended to 'indicate that th unloaded vehicle [weight] does not include work-performing accessories which may be available as original equipment accessories.' The Jeep petition argues that the impracticality of conducting some dynamic testing with 'work-performing accessories' in place may force the discontinuance of some factory-installed accessories although factory installation may be more safe than a subsequent aftermarket installation.; The Jeep Corporation petition is denied. As a general matter, the NHTS has established that a vehicle which is designed to accept an optional component must be capable of meeting all applicable standards with the component installed. The NHTSA has evaluated the potential problems of dynamic testing with heavy or protruding accessories in place and concludes that a decision on the practicality and wisdom of so doing should be made on a 'standard-by-standard' basis. As you noted, the NHTSA has provided for removal of work-performing accessories in conducting compliance tests under Standard No. 219, *Windshield Zone Intrusion*. If Jeep considers dynamic testing in other standards to be unjustifiably burdensome because of the necessity of testing with all accessories in place, it would be appropriate to petition for rulemaking to amend the standard in question.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2921OpenMr. Dominic S. Piacenza, Franklin Pierce Law Center, 2 White Street, Concord, NH 03301; Mr. Dominic S. Piacenza Franklin Pierce Law Center 2 White Street Concord NH 03301; Dear Mr. Piacenza: This is in response to your letter of November 9, 1978, asking whethe a memorandum of understanding exists between the National Highway Traffic Safety Administration (NHTSA) and the Federal Trade Commission (FTC) concerning the apparent overlapping jurisdiction regarding tire marketing practices created by Section 203 of the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act)(15 U.S.C. 1423). You ask whether NHTSA's jurisdiction extends solely to safety- related issues.; NHTSA's authority is not confined solely to the area of motor vehicl and traffic safety. For example, under the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901) the agency has been given authority over the areas of fuel economy and economic losses to consumers as they relate to automobiles. While the Safety Act is primarily concerned with safety issues, Section 203 of that law does provide NHTSA with limited authority over tire marketing practices. The Uniform Tire Quality Grading Standards (49 CFR 575.104), issued by NHTSA under the authority of Section 203, provide information to consumers in tire performance areas relating to both safety and economic issues.; While the FTC is aware of and supports NHTSA's efforts in the field o tire grading, no memorandum of understanding exists with regard to the scope of NHTSA's activities. Section 205 of the Safety Act (15 U.S.C. 1425) does state that, in the event of conflict between orders or regulations issued under the Safety Act concerning motor vehicle tires and FTC orders or interpretations, the orders or regulations issued under the Safety Act shall prevail.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3633OpenMr. Matt Guzzetta, Vice President, Don Vesco Products, Inc., 7565 North Avenue, Lemon Grove, CA 92045; Mr. Matt Guzzetta Vice President Don Vesco Products Inc. 7565 North Avenue Lemon Grove CA 92045; Dear Mr. Guzzetta: This is in reply to your letter of September 15, 1982, asking about th legality of 'covering of a headlamp on a motorcycle with a clear cover.'; You reported that manufacturers of motorcycles and fairings ar producing such covers. The National Highway Traffic Safety Administration views this practice as prohibited and will take appropriate steps to make its views known. The legal authority for this is based upon a requirement of the SAE incorporated by reference in Motor Vehicle Safety Standard No. 108 or, alternatively, paragraph S4.1.3 of that standard.; SAE Standard J580 (both a and b versions), *Sealed Beam Headlam Assembly*, is incorporated by reference in Tables I and III of Standard No. 108 as one of the standards pertaining to headlamps for use on passenger cars, trucks, buses, and multipurpose passenger vehicles. A paragraph in each version states that, 'When in use, a headlamp shall not have any styling ornament or other feature, such as a glass cover or grill, in front of the lens.' SAE J580a applies to all sealed beam headlamps, while the scope of J580b is considerably narrower, including only those not covered by SAE J579c.; The principal referenced SAE material for motorcycle headlamps is J584 *Motorcycle Headlamps*. As options, both J584 and S4.1.1.34 of Standard No. 108 allow, in effect, a motorcycle to be equipped with one half of any sealed beam system permissible on four-wheeled motor vehicles.; Paragraph S4.1.3 of Standard No. 108 forbids the installation o additional equipment 'that impairs the effectiveness of lighting equipment required' by Standard No. 108. Because of moisture accumulation, discoloration, cracks, etc., a glass or plastic cover might tend over a period of time to diminish or distort the headlamp beam. This is of particular concern with reference to the unsealed headlamps implicitly permitted by SAE J584 because of the tendency of the reflector to deteriorate with age.; For the reasons stated above, the agency has concluded that no headlam may have a glass or plastic shield in front of it when in use, regardless of the type of vehicle on which it is used.; As for the turn signals, no part of the vehicle may impair thei visibility through horizontal angles 45 degrees to the right and left of the vehicle (for right and left turn signals respectively) measured at the longitudinal axis of the vehicle. An unobstructed illuminated area of outer lens surface of at least 2 square inches excluding reflex is necessary to meet this requirement. You will have to judge for yourself whether the turn signal requirements are met with your planned cover in place.; If you have any further questions, we shall be happy to answer them. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3263OpenMr. R.W. Strauss, Stewart-Warner Corporation, Washington Offices, 425 - 13th Street, N.W., Washington, D.C. 20004; Mr. R.W. Strauss Stewart-Warner Corporation Washington Offices 425 - 13th Street N.W. Washington D.C. 20004; Dear Mr. Strauss: This responds to your letter of January 24,, 1980, which requeste approval of an odometer design developed by Stewart-Warner in order to comply with section 4.2.3 of Federal Motor Vehicle Safety Standard No. 127, *Speedometers and Odometers*. Based on our understanding of the information that you have supplied, it appears that Stewart-Warner's design, which incorporates either a seventh wheel or a sixth wheel (for odometers which do not register tenths of a mile) printed with a series of the numeral 1 to indicate that the vehicle has traveled in excess of 99,999 miles or kilometers, would comply with section 4.2.3 of Safety Standard No. 127.; Section 4.2.3 of Safety Standard No. 127 requires that each odomete other than a motorcycle odometer:; >>>'clearly indicate to the vehicle driver by a sixth wheel or digi registering whole miles or kilometers or by a permanent means such as inking, when the number of whole miles or whole kilometers, as appropriate, has exceeded either at the manufacturer's option 89,999 or 99,999.'<<<; Stewart-Warner's design, as described in your letter, would registe whole miles or kilometers from 100,000 to 199,999. Once the vehicle in which the odometer was installed had traveled 200,000 miles or kilometers, or more, the additional wheel on the Stewart-Warner design would no longer register whole miles or kilometers but it would indicate that the vehicle milage had exceeded 99,999. Thus, the Stewart-Warner design, as we understand it, would apparently comply with section 4.2.3's requirement that each odometer indicate that such mileage has been exceeded.; Finally, I would emphasis that this letter only represents the agency' opinion based on the information supplied in your letter and the model that you provided. The National Highway Traffic Safety Administration does not pass approval on any vehicle design or design for vehicle equipment prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles or items of vehicle equipment comply with all applicable safety standards and regulations and to certify its vehicles or items of vehicle equipment in accordance with that determination.; I hope that you will find this response helpful and have not bee greatly inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3799OpenMr. Ben Barbie, Stapleton Public Schools, P.O. Box 125, Stapleton, NE 69163; Mr. Ben Barbie Stapleton Public Schools P.O. Box 125 Stapleton NE 69163; Dear Mr. Barbie: This is in further reply to your phone call of February 13, 1984, t the National Highway Traffic Safety Administration, regarding the remanufacture of school buses using older model bus bodies on new chassis. You asked whether the school bus safety standards apply to a school bus manufactured with a 1976 model year body mounted on a new chassis.; The applicability of Federal Motor Vehicle Safety Standards i determined by the date of manufacture of the motor vehicle. For vehicles that are completed in several stages, the manufacturer can treat as the date of manufacture the date of the incomplete vehicle, the date of final completion of the vehicle, or a date between those two dates. An 'incomplete vehicle' is defined in 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*, as:; >>>an assemblage consisting, as a minimum, of frame and chassi structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle.<<<; The effective date of the school bus safety standards was April 1 1977. Since the date of manufacture of the school bus chassis is after April 1, 1977, and the date of completion of the vehicle is after April 1, 1977, the completed school bus must meet the requirements of the school bus safety standards. It is extremely unlikely that the 1976 model year body will comply with the school bus standards since the body was manufactured before the effective date of the school bus standards. If your completed vehicle does not comply with the safety standards, your manufacturer, distributor, or dealer cannot certify it as conforming to such standards.; Sincerely, Frank Berndt, Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.