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
| Interpretations | Date |
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ID: aiam1624OpenDavid J. Humphreys, Esq., Paulson and Humphreys, 1140 Connecticut Avenue, N.W., Washington, DC 20036; David J. Humphreys Esq. Paulson and Humphreys 1140 Connecticut Avenue N.W. Washington DC 20036; Dear Mr Humphreys: This responds to your October 8, 1974, requesting in behalf of Chinoo International that the NHTSA specify the requirements established for side-facing seats in multipurpose passenger vehicles (MPV's) which are designated seating positions. You also ask if the final-stage manufacturer of a vehicle would be solely responsible for compliance with any applicable Federal motor vehicle safety standards and for any safety-related defect later found in the side-facing seats.; Standard No. 207, *Seating systems*, applies to MPV's but it specifie no requirements for the side-facing seats you describe unless they have a hinged or folding back. Section S4.2 specifically excludes side-facing seats from all seat strength requirements. Section S4.3 specifies requirements only for 'a hinged or folding occupant seat or occupant seat back.' Section S4.4 only requires labeling of 'seats not designated for occupancy.'; Standard No. 208, *Occupant crash protection*, applies to MPV's an requires MPV's manufactured during the period from January 1, 1972 to August 14, 1975, to have a Type I or Type II seat belt installed at each designated seating position. A Type I or II seat belt assembly means that the belt assembly must conform to the requirements of Standard No. 209, *Seat belt assemblies*. Further requirements would apply to a designated seating position that includes the windshield header within the head impact area.; Standard No. 210, *Seat belt anchorages*, also applies to MPV's Paragraph S4.1 requires that seat belt anchorages be installed for each designated seating position, including side-facing seats. Paragraph S4.2 specifically excludes the anchorages provided at side-facing seats from any strength requirements. Paragraph S4.3 specifies certain location requirements for the placement of seat belt anchorages on side-facing seats.; Part 567, *Certification*, requires that, in the case of vehicl manufactured in two or more stages, the final-stage manufacturer (defined in Part 568 as a person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle) must certify compliance of the vehicle with all applicable Federal motor vehicle safety standards by affixing a label to the vehicle (S 567.5), unless the incomplete vehicle manufacturer or intermediate vehicle manufacturer assumes legal responsibility. The fact that Toyota retains title to the vehicle does not affect a determination of legal responsibility. As described in your letter, Chinook would be the final-stage manufacturer responsible for compliance with all applicable safety standards. In discharging this responsibility, he may rely on data furnished by the incomplete vehicle manufacturer.; We are unable to state flatly that Chinook, as the final-stag manufacturer, would be solely responsible for defects in side-facing seats. We have authority over a manufacturer of motor vehicle equipment and could therefore pursue any safety-related defect with the seating manufacturer (which may or may not be Chinook). As for seat strength, I cannot at present envision a situation in which the incomplete vehicle manufacturer would be responsible for safety- related defects in the side-facing seats built by Chinook.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam3619OpenMr. Robert C. Craig, Quality Control Manager, Cosco, 2525 State Street, Columbus, IN 47201; Mr. Robert C. Craig Quality Control Manager Cosco 2525 State Street Columbus IN 47201; Dear Mr. Craig: This responds to your letter of August 13, 1982, concerning th application of the belt buckle requirements of Standard No. 209, *Seat Belt Assemblies*, to child restraints meeting Standard No. 213, *Child Restraint Systems*. As explained in the enclosed letters of interpretation of May 12, 1981, and May 21, 1981, the only requirements of Standard No. 209 that apply to child restraint belt buckles are the corrosion resistance requirement of S4.3(a) and the temperature resistance requirement of S4.3(b). The buckle release requirements of S4.3(d) and the buckle latch requirements of S4.3(g) do not apply to child restraints.; Because of reports of problems relating to difficulty in operatin child restraint buckles, the agency is considering issuance of a proposal to apply the requirements of S4.3(d)(2) and S4.3(g) to child restraint system belt buckles. Any such proposal would be published in the *Federal Register* to provide all interested parties with notice and opportunity to comment.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4426OpenWilliam J. Henrick, Esq. Assistant General Counsel General Tire One General Street Akron, Ohio 44329; William J. Henrick Esq. Assistant General Counsel General Tire One General Street Akron Ohio 44329; "Dear Mr. Henrick: This is in response to your letter of June 3, 1988 seeking an interpretation of Part 574, Tire Identification and Recordkeeping. Specifically, you stated that your company has reached an agreement with two foreign tire manufacturers to jointly produce a radial medium truck tire in one of your domestic facilities. You anticipate that all three entities will use the same 'green' or 'uncured' tires. Although your letter is not clear on this point, I am assuming that the sidewall on a given tire will contain the name and the respective tire identification mark of only one company. You asked whether each of the three companies involved in this joint venture may secure its own identification mark required by Part 574 to identify its tires. The answer to your question is yes. 49 CFR /574.5 requires that 'Each tire manufacturer shall conspicuously label on one sidewall of each tire it manufactures . . . by permanently molding into or onto the sidewall, in the manner and location specified in Figure 1, a tire identification number containing the information set forth in paragraphs (a) through (d) of this section.' The purpose of the tire identification number requirements is to facilitate the effective recall of tires from the public if the tires are found not to comply with the applicable safety standards or if the tires contain a safety related defect. To best effectuate the recall of noncomplying or defective tires, the agency recommends but cannot require each production plant to have its own tire identification number. If the company that produced the tires in its molds (General in this case) wished to put its tire identification number on all of the tires produced for this joint venture, /574.5 would not prohibit it from doing so, since that company could certainly be considered the manufacturer of all of the tires. However, if that company were to do so, it would be responsible for any recalls of these tires, including the tires sold by the other partners in the joint venture. On the other hand, /574.5 does not prohibit each of the three partners in the joint venture from putting its own tire identification number on those tires produced for it by the joint venture. Each partner could be considered the 'manufacturer,' for purposes of /574.5, of those tires that it markets under its name. Each partner would then be responsible for any recalls of those tires produced by the joint venture on which its identification number appears. I am enclosing 49 CFR Part 551 which requires all manufacturers headquartered outside of the United States to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. The agent may be either an individual or a business entity. Part 551 specifies that the designation of agent must contain the following six items of information: 1. A certification that the designation is valid in form and binding on the foreign company under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made, 2. The full legal name, principal place of business and mailing address of the foreign company, 3. Marks, trade names, or other designations of origin of any of the tires which do not bear the name of the foreign company. 4. A statement that the designation shall remain in effect until withdrawn or replaced by the foreign company, 5. A declaration of acceptance duly signed by the agent appointed by the foreign company, and the agent may be an individual, firm, or United States corporation, and 6. The full name and address of the designated agent. I hope this information is helpful. If you have any further questions on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam4133OpenJoan O'Connell, Esq., DNA-People's Legal Services, Inc., P.O. Box 967, Shiprock, NM 87420; Joan O'Connell Esq. DNA-People's Legal Services Inc. P.O. Box 967 Shiprock NM 87420; Dear Ms. O'Connell: This is in response to your letter of April 23, 1986. You asked whethe New Mexico has sought the approval of the National Highway Traffic Safety Administration to use its certificate of title or other motor vehicle ownership documents as a substitute for the Federal odometer mileage statement prescribed by 49 CFR S580.6.; New Mexico has not sought the approval of this Agency to use th certificate of title, but did submit a separate odometer mileage statement it wished to implement. We granted our approval to use that statement. However, when we subsequently learned that New Mexico was no longer using the form, we advised New Mexico's transportation Department in a letter dated November 28, 1983, that the certificate of title could not be used in lieu of the separate odometer disclosure statement. I have enclosed a copy of that letter.; I have reviewed a sample of New Mexico title contained in *The Origina Peck's Title Book* which is revised periodically and supplemented as changes occur in the state title laws. The New Mexico title, as it appears in *Peck's*, indicates that the title has not been revised since 1982. Therefore, for the reasons stated in our November 28, 1983 letter, the New Mexico title cannot be used in lieu of a separate odometer disclosure statement.; Sincerely, Kathleen C. DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam1331OpenMr. Adolph Kunasicwicz, 5644 Forest Avenue, Otter Lake, MI 48464; Mr. Adolph Kunasicwicz 5644 Forest Avenue Otter Lake MI 48464; Dear Mr. Kunasicwicz: Your request for information concerning the existence of penalties fo removal of the required certification label from a motor vehicle has been forwarded to us by the Federal Trade Commission.; The National Traffic and Motor Vehicle Safety Act requires that certification label, which under NHTSA regulations includes the name of the manufacturer and the date of manufacture, be permanently affixed to the motor vehicle. Although removal of this label does not carry a criminal penalty of either fine or imprisonment, a civil penalty of up to $1,000 is specified in certain situations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4563OpenBill Whiteside, Subcontract Manager Harris Corporation Government Electronics Systems Division P. O. Box 96000 Melbourne, FL 32902; Bill Whiteside Subcontract Manager Harris Corporation Government Electronics Systems Division P. O. Box 96000 Melbourne FL 32902; "Dear Mr. Whiteside: This responds to your letter asking for a interpretation of 49 CFR Part 567, Certification, and 49 CFR Part 568, Vehicles Manufactured in Two or More Stages, as those regulations apply to the certification of certain trailers. Your letter follows an earlier request for interpretation from Telex Communications. In the letter from Telex, your company, Harris Corporation, was identified as Company XYZ. Telex's question was whether it or your company had 'ultimate responsibility for DOT certification' pursuant to 49 CFR Parts 567 and 568. NHTSA responded to Telex in a letter dated March 1, 1988. Because the information provided in the incoming letter from Telex was somewhat sketchy, and we had to make certain assumptions about whether your company was the end user or intended to resell the trailer, we could not provide a definitive answer to them. Your letter and a telephone conversation between Larry Little of Harris Corporation and Dorothy Nakama of my staff have given us the following additional information. Your company has a contract with Telex under which Telex is required to deliver trailers to your company. According to your letter, Telex designs, integrates and/or fabricates all 'transport related' features of the trailer, including structure, wheels, axles, brakes, running lights, towing package, and other parts. You state that in your specifications, Telex is 'required to comply with the Code of Federal Regulations in the design and fabrication of the trailer.' After Harris receives a trailer from Telex, other parties in a contractual relationship with Harris permanently mount hardware, such as generators and radio equipment, onto the trailer. You asserted that this additional equipment does not result in exceeding or modifying the GAWR or GVWR of the trailer, which comes from Telex. After the vendors have mounted the hardware onto the trailer, Harris delivers the finished trailer to the Federal Emergency Management Agency (FEMA) pursuant to a Federal contract with that agency. My answers to the questions posed in your letter are based on the above understanding of the facts. I will now address the specific questions posed in your letter. Questions One and Two: Is Telex the complete vehicle manufacturer of this trailer? What process(es) are proper for certification of the trailer? Response: Based on the information provided in your letter, it appears that the trailers delivered to Harris by Telex are 'completed vehicles' within the meaning of 49 CFR 568.3. That section defines a 'completed vehicle' as: a vehicle that requires no further manufacturing operations to perform its intended function other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting. The determination of whether a vehicle meets this definition is made at the time it is delivered to the purchaser. In this case, the vehicles delivered to Harris by Telex are trailers which, according to your letter, already have the body structure, wheels, axles, brakes, lights, towing package, and all other components that are necessary for the trailer to be used as is without any further manufacturing operations. Assuming this is the case, these vehicles are completed vehicles because they do not require any further manufacturing operations to perform their intended function as trailers. Hence, Telex must certify that each of its completed vehicles conforms to all applicable Federal motor vehicle standards, as specified in 49 CFR 567.4. This certification should appear on the trailer at the time it is delivered to Harris. However, Telex is not the only party that must certify that the trailers conform to applicable safety standards. Based on the information you have provided, it appears that the parties that permanently mount hardware to these trailers are 'alterers,' and must affix their own certifications that the trailers conform to all applicable safety standards affected by the alteration, after they have mounted the hardware to the trailer. Alterers that are required to affix certification labels in accordance with 567.7 are defined in that section as follows: A person who alters a vehicle that has previously been certified in accordance with 567.4 or 567.5, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, ... before the first purchase of the vehicle in good faith for purposes other than resale, ... * * * * * The parties that permanently mount hardware to the trailers delivered by Telex are altering previously certified vehicles before the first purchase of the trailer in good faith for purposes other than resale. The only conditions in which these alterers would not be required to affix their own certification labels to each trailer on which they permanently mount hardware would be: 1. The hardware consisted of 'readily attachable components,' or 2. Permanently mounting this hardware is only a 'minor finishing operation.' Based on the information you have provided, neither of these exceptions would apply to these parties. Equipment of the sort described in your letter (generators, powerful radio antennas, communications equipment, etc.) are not 'readily attachable components.' Similarly, the operations performed by these parties appear to be far more sophisticated than 'minor finishing operations.' Since the requirements set forth in 49 CFR 567.7 appear to apply to these parties, the parties must make the certification specified in that section. To summarize, alterers must allow the certification labels affixed by the original manufacturer (Telex, in this case) to remain in place and affix their own certification labels in accordance with 567.7. The alterers' certification label must identify the alterer and the month and year in which the alterations were performed, and state that the vehicle as altered conforms to all applicable safety standards affected by the alteration. The information you have provided suggests that your company simply purchases the trailers from Telex and delivers the trailers to the two parties to be altered. Assuming that your company does not itself either manufacture or alter these trailers before delivering them to FEMA, your company is not required to make any certification pursuant to 49 CFR Part 567. However, since the parties that are altering the Telex trailers are doing so under contract to Harris, Harris could, if it chooses to do so, assume the certification responsibilities for the parties with whom it has contracted. In that case, Harris would have to affix a certification label in accordance with 567.7 that identifies Harris as the alterer of the trailers. Question Three: If you rule that Telex has certification responsibility for the trailer, do we have any recourse through your office to enforce certification of the trailer? Assuming that the facts presented in your letter and our understanding of those facts are correct, Telex must certify that the trailers it delivers comply with all applicable safety standards and each party that has mounted hardware inside the trailer must certify that the trailer complies with all applicable safety standards affected by the alteration. If you believe that you have information showing that some party has failed to comply with its certification responsibilities or any other requirement in our regulations or safety standards, we would appreciate it if you would forward that information to our Office of Vehicle Safety Compliance at this address. That office will investigate the matter and take appropriate action. I hope this information is helpful. Please let me know if we can be of further assistance. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam0873OpenMr. Heinrich von Wimmersperg, Development Engineer, 15929 Grand River Avenue, Detroit 27, MI; Mr. Heinrich von Wimmersperg Development Engineer 15929 Grand River Avenue Detroit 27 MI; Dear Mr. von Wimmersperg: Thank you for your letter of October 2, 1972, concerning the For 'Tot-Guard' and your child restraint patents.; The consumer complaints that we have received on the Ford Tot-Guar have been complaints focussing on the fit of the device for minimum recommended size children. The comments relate both to the ease with which small children may climb out of the device and slide under it, as well as to the vision restriction problem for the small child.; The Tot-Guard has proven to perform well in 30 mph frontal impacts wit the three- year-old child dummy in our research programs, but can be improved in lateral protection capability and in performance with the 50-pound child dummy.; We have just completed a research program to develop new concepts i child restraints and will very shortly be making these designs available for any manufacturer who chooses to produce one of these advanced design restraints.; A copy of your letter will be placed in the public docket along wit plans for the restraints developed on our child restraint development contract.; We are interested in reviewing and placing in the public docket copie of your designs for the infant car bed, which you mention in hopes of stimulating the production of a crashworthy design for such a device.; We appreciate your letter and are looking forward to hearing from yo in the near future.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam1761OpenMr. Lee C. Golder,2090 Union Avenue,North Bend, Oregon 97459; Mr. Lee C. Golder 2090 Union Avenue North Bend Oregon 97459; Dear Mr. Golder:#Please forgive the delay on responding to the reques in your letter of October 15, 1974, for information on the applicability of the banding requirements of Federal Motor Vehicle Safety Standards No. 106-74, *Brake Hoses*, to your fleet accounts.#S5.2.4 of Standard No. 106-74, in its present form, requires each fleet owner who makes up brake hose assemblies for his own use to label each assembly with a band ant to file a designation that identified him as the manufacturer of the assembly with the Office of Standards Enforcement. An amendment of this requirement is under active consideration, and the issue will be dealt with a forthcoming notice in the Federal Register.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4099OpenMr. Koji Tokunaga, Manager, Engineering, Isuzu Motors America, Inc., 21415 Civic Center Drive, Southfield, MI 48076- 3969; 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 a 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) should appear. I regret the delay in replying to your letter.; You ask whether either of two specific locations within the passenge 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 upo 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 you letter that your concern is whether a VIN or a plat 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 i 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 its 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 you 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 repair 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 hoo 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 readability requirement of S4.6.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4830OpenMr. Terry Rowe President Show Trucks U.S.A., Inc. 114 National Drive Rockwall, Texas 75087; Mr. Terry Rowe President Show Trucks U.S.A. Inc. 114 National Drive Rockwall Texas 75087; "Dear Mr. Rowe: This responds to your letter asking whether you company would be considered a vehicle 'alterer,' within the meaning of 49 CFR Part 567 Certification, and Part 568 Vehicles Manufactured in Two or More Stages. I apologize for the delay in this response. Based on the statements in your letter that your company modifies only new vehicles before delivery to customers and that the modifications performed by your company do not affect the vehicles' gross axle or gross vehicle weight ratings, your company would be considered an 'alterer,' and would be subject to additional certification requirements, if the modifications involve something more than the addition, substitution, or removal of 'readily attachable' components. A more complete explanation of your responsibilities under NHTSA's laws and regulations follows. 567.7 imposes additional certification requirements on 'a person who alters a vehicle that has previously been certified in accordance with 567.4 or 567.5, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, ...' You stated in your letter that your company can provide features such as a 3-piece seating system, removable headrest, custom walnut steering wheel, and tinted windows. Your company is an 'alterer' subject to the requirements of 567.7 to the extent that your modifications do not involve 'readily attachable' components. A determination of whether modifications involve 'readily attachable' components depends on the degree of difficulty in attaching these components. To ascertain whether the installation involves 'readily attachable' components, the agency in the past has looked at such factors as the intricacy of installation and the need for special expertise must be taken into consideration. Absent extraordinary ease of installation, NHTSA would not consider modifications involving the addition or substitution of seats, headrests, and steering wheels to involve 'readily attachable' components. To the extent your company is involved in such modifications, then, it would have to affix an additional certification label pursuant to 567.7. Further, an alterer is considered a 'manufacturer' for the purposes of notification and remedy for defects or noncompliances with the safety standards, and is subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports. You should also note that the National Traffic and Motor Vehicle Safety Act sets forth certain prohibitions and requirements that would apply to these vehicle modifications, even if the modifications involved only 'readily attachable' components. For example, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits the sale, offer for sale, introduction into interstate commerce or importation of any vehicle that does not comply with all applicable Federal motor vehicle safety standards. This provision of Federal law means that all of the vehicles modified by your company must continue to comply with all applicable safety standards after the modifications have been made. In addition, under section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)), no manufacturer, distributor, dealer, or motor vehicle repair business may knowingly 'render inoperative,' in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. For your information, I have enclosed an information sheet which identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of those regulations. Again I apologize for the delay in this response. If you have any further questions or need any additional information, please feel free to contact Dorothy Nakama of may staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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.