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: aiam1849OpenMr. Robert Marx, State Representative, District No. 34, Polk-Benton, House of Representatives, Salem OR 97310; Mr. Robert Marx State Representative District No. 34 Polk-Benton House of Representatives Salem OR 97310; Dear Mr. Marx: This is in response to your letter of March 10, 1975, requestin information concerning correspondence from one of your constituents, Mr. Jim Lee Martin, commenting on a proposed amendment to the Federal Bumper Standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1970 (sic) model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two ageny- sponsore (sic) studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Martin has directed his comments to what he believes to be proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face (plastic) systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2766OpenMr. William J. Wood, Nebraska Dept. of Motor Vehicles, Statehouse Station 94612, Lincoln, NE 68509; Mr. William J. Wood Nebraska Dept. of Motor Vehicles Statehouse Station 94612 Lincoln NE 68509; Dear Mr. Wood: This responds to your January 16, 1978, letter asking several question about the applicability of the school bus regulations to school buses manufactured after April 1, 1977, transporting 10 or more students to or from school or related events.; You first ask whether these buses must be painted yellow and hav school bus lighting and markings. The answer to your question is yes. Any vehicle that transports 10 or more students to or from school or related events is a school bus and must have the painting, marking, and lighting of a school bus.; Your second question is whether smaller school buses (vans) ar permitted to have van-type seats or must comply with the requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*. A vehicle that transports 10 or more students must comply with all of the Federal school bus regulations, including the seating standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5109OpenMr. Rodney T. Nash, P. E. Vice President Engineering Collins Industries, Inc. 421 East 30th Avenue Hutchinson, KS 67502-2493; Mr. Rodney T. Nash P. E. Vice President Engineering Collins Industries Inc. 421 East 30th Avenue Hutchinson KS 67502-2493; "Dear Mr. Nash: This responds to your letter to the Administrator National Highway Traffic Safety Administration (NHTSA), received in this office on November 18, 1992, and your telephone conversation of November 30, 1992 with Walter Myers of this office, regarding the proper classification of an ambulance. You indicated that Wheeled Coach Industries of Orlando, Florida, a subsidiary of Collins Industries, produces ambulances that are built on truck chassis. You stated that in the past those vehicles have been classified as trucks, but that Ford Motor Company auditors told you that they should be classified as multipurpose passenger vehicles (MPV). You said that you needed to know how to classify ambulances, observing that it appeared to you that the final stage manufacturer was free to choose between the two classifications, truck or MPV. NHTSA has long considered ambulances to be multipurpose passenger vehicles, which are defined in 49 Code of Federal Regulations (CFR) 571.3 as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' Your company's ambulances fit this definition very well: they are mounted on a truck chassis and are designed to carry ten persons or less. As you pointed out in your letter, it is true that an ambulance may carry more weight in special equipment than it carries in patients, and it may operate half its life with no patient on board. Nevertheless, NHTSA believes that whether or not a patient is on board or how much equipment is carried, the vehicle is primarily designed for the transportation and/or care of ill or injured persons, as well as the transportation of paramedic personnel to wherever they are needed. This is in contrast to a truck which is defined also in 49 CFR 571.3 as 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment'. Thus, although an ambulance carries special purpose equipment, NHTSA believes that the equipment is only ancillary to the primary function of an ambulance which is the transportation of persons. Accordingly, an ambulance falls within the definition of MPV rather than truck. I hope this will help clarify this issue for you. Should you have any further questions in this regard, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Assistant Chief Counsel for Rulemaking"; |
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ID: aiam3287OpenMr. R. W. Hildebrandt, Group Director, Engineering, Heavy Vehicle Systems Group, The Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hildebrandt Group Director Engineering Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hildebrandt: This responds to your April 8, 1980, letter asking for a interpretation of section 5.2.1.1 of Standard No. 121, *Air Brake Systems*. In particular, you ask whether your system complies with the provisions of that section which require that vehicles have a reservoir capable of releasing the parking brakes in the event of an emergency failure of the service brake system. You indicate that your system is in compliance with the intent of this section but may not be in technical compliance with the actual requirements. Nonetheless, you believe that your system complies based upon a letter of interpretation made by the agency to Berg Manufacturing Company dated August 27, 1979.; The August letter to Berg to which you refer in your letter wa conditioned upon our reading of the facts as stated by Berg in their letter. That letter as it applied to section 5.2.1.1 was not an interpretation of the standard, but rather an assessment by the agency as to whether we believed that the Berg system would comply with the requirements. At that time and based upon the given facts, we stated to Berg that we felt that their system would comply.; The agency has always been reluctant to issue such letters, because i is impossible to determine compliance based upon a manufacturer's description of its vehicles or from vehicle drawings. It is necessary for the agency to conduct tests to be certain whether a vehicle will comply. Accordingly, the agency always indicates in its letters that any assessment of compliance is contingent upon the description made in the manufacturer's letter, and that our opinions only reflect our engineering expertise and in no way bind the agency should we test the vehicle and find a noncompliance. In fact, we have frequently indicated to manufacturers that these letters are of little or no value to them.; Subsequent to the issuance of the Berg letter, the agency has receive a clearer picture of how the Berg system operates. We have notified that company that their system does not comply with the requirements of the standard. Berg has indicated to the agency that they consider their system to be as good as any that is in complete compliance with the standard and has petitioned the agency to amend the standard in a way that would permit their system. The agency is now looking into the Berg request. We suggest that you closely follow that rulemaking action.; With respect to your system, it appears that it too would not compl with the technical requirements of the standard, because your system does not have a reservoir capable of releasing the parking brakes in the event of service brake failure. Although the agency appreciates your argument that your system meets the intent of the standard for the release of parking brakes when the service brake system fails, nonetheless the standard is specific in its requirement that a reservoir be provided that is capable of releasing the parking brakes. We cannot by interpretation remove the reservoir requirement. Our rulemaking effort with respect to the Berg petition will address the question of whether the reservoir requirement remains necessary in the standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4542OpenMr. Steve Zlotkin Overland Parts, Inc. 48368 Milmont Dr. Fremont, CA 94538; Mr. Steve Zlotkin Overland Parts Inc. 48368 Milmont Dr. Fremont CA 94538; "Dear Mr. Zlotkin: This is in response to your letter seeking a interpretation of Standard No. 205, Glazing Materials (49 CFR 571.205). Specifically, your letter stated that your company would like to import some non-laminated windshields into the United States. I apologize for the delay in our response. As explained below, your company is prohibited by Federal law from importing or selling this type of windshield because it does not comply with the requirements of Standard No. 205. Standard No. 205 establishes performance and marking requirements for all glazing installed in motor vehicles. The standard incorporates by reference the requirements of Standard ANS Z-26, 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' of the American National Standard Institute. Standard ANS Z-26 requires that glazing materials for windshields must pass a specified group of test requirements. ANS Z-26 specifies that glazing materials that comply with these test requirements for windshields must be marked AS-1. To date, the only glazing materials that have been marked AS-1 have been laminated safety glass. Unless your non-laminated windshields can meet the requirements for AS-1 glazing and are marked AS-1, they do not comply with the requirements for windshields specified in Standard ANS Z-26 or Standard No. 205. You also should be aware that Standard No. 205 permits glass-plastic glazing. The importation and sale of noncomplying glazing would be a violation of the National Traffic and Motor Vehicle Safety Act ('Safety Act'), the statute under which Standard No. 205 was issued. Section 108(a)(1)(A) of the Safety Act provides: No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle standard takes effect under this title unless it is in conformity with such standard... Your letter set forth two interpretations of the law under which you suggested that your company might be able to import noncomplying windshields. Your first interpretation relied on the fact that these windshields can only be installed in vehicles that were manufactured between 1953 and 1967. Since Standard No. 205's requirements for windshields did not become effective until January 1, 1968, you suggested that the provisions of section 108(a)(1)(A) of the Safety Act might not apply, because no safety standards were applicable to these vehicles. This suggestion is incorrect. All windshields manufactured on or after January 1, 1968 must comply with the requirements of Standard No. 205, regardless of the year of manufacture of the vehicle on which the windshield is designed to be installed. In fact, safety standards relating to components such as brake hoses, lighting equipment, tires, glazing materials, seat belt assemblies, and wheel covers are applicable to components manufactured on or after January 1, 1968, even if those components are manufactured for motor vehicles manufactured before that date. In a January 16, 1987 interpretation letter to Mr. Peter Cameron-Nott (copy enclosed), the agency stated that the above listed component parts including glazing materials that were manufactured on or after January 1, 1968, would have to comply to the relevant safety standards (in the case of glazing, Standard No. 205) even though the underlying motor vehicle was a 1965 Jaguar. Assuming that the non-laminated windshields that were the subject of your letter were in fact manufactured after January 1, 1968, Standard No. 205 applies to those windshields. As already noted, Section 108(a)(1)(A) of the Safety Act prohibits your company from importing any windshields that are subject to Standard No. 205 that do not comply with that standard. Your second suggestion is that your company would be willing to place a sticker on these windshields to warn purchasers that the windshields do not comply with Standard No. 205. The Safety Act contains no exception to section 108(a)(1)(A)'s prohibition for noncomplying equipment, even if it were to be labeled as noncomplying. Hence, section 108(a)(1)(A) prohibits the importation of noncomplying windshields without regard to any warning labels on the windshields. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam0852OpenMr. W.G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley GA 31030; Mr. W.G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of August 24, 1972, requesting a opinion as to appropriate steps to take in certifying vehicles you complete when the chassis, as delivered to you, are equipped with tires which are inadequate for the loads the vehicles are intended to carry. You state you are presently certifying the vehicles on the basis of the load ratings of correct tires, arranging for these tires to be installed by the dealer, and requesting a notarized statement from him to that effect. As a basis for this procedure, you refer to our previous correspondence to you dated March 24, 1972, in which we authorized a somewhat similar procedure involving certain school buses.; As stated to you in our letter of March 24, the procedure outline therein 'is allowed only as to chassis that have already been received by Blue Bird as of the receipt of this letter . . .' Blue Bird is the final-stage manufacturer, and is responsible for the weight ratings applied to the vehicles presently in question. These ratings must be consistent with the definitions of those terms in the regulations, and must reflect the characteristics of the vehicles at the time of their sale to the consumer, assuming further manufacturing does not occur. Although you receive assurances from a dealer that he will change the tires, this will not absolve you from responsibility under the regulations should the dealer fail to do so. We are of the opinion that the best procedure for Blue Bird to follow is to replace the tires before delivery to the dealer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1740OpenMr. J. L. Brown, President, Brown Truck and Trailer Mfg. Co., P.O. Box 1281, Charlotte, NC 28201; Mr. J. L. Brown President Brown Truck and Trailer Mfg. Co. P.O. Box 1281 Charlotte NC 28201; Dear Mr. Brown: This responds to your December 11, 1974, question whether Standard No 121, *Air brake systems*, or any other Federal brake regulation applies to trailers that are equipped with electric brakes. In a January 2, 1975, telephone conversation with Mr. Herlihy of this office, you indicated that the brake system on your products is entirely electrical.; No Federal braking standards apply to your electrically-brake trailers. Standard No. 121 applies only to trucks, buses, and trailers that the manufacturer chooses to equip with an air brake system.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4811OpenMr. Richard Cahalan Director of Core Services Commonwealth of Massachusetts Executive Office of Human Services Department of Mental Retardation 160 North Washington Street Boston, MA 02114; Mr. Richard Cahalan Director of Core Services Commonwealth of Massachusetts Executive Office of Human Services Department of Mental Retardation 160 North Washington Street Boston MA 02114; "Dear Mr. Cahalan: This responds to Mr. Oscar Harrell's lette requesting information about Federal regulations concerning the modification of vehicles to accommodate mentally retarded individuals. According to that letter, in response to conversations about this issue with Mr. George Shifflett of this agency's Office of Vehicle Safety Compliance, Mr. Harrell received copies of interpretation letters from my office to Mr. Vincent Foster dated September 4, 1986 and to Mr. W.G. Milby dated November 26, 1979. These letters express NHTSA's policy concerning modifications of vehicles to accommodate the special needs of handicapped individuals and the requirement in 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibiting commercial businesses from knowingly rendering inoperative any elements of design installed on a vehicle in compliance with a Federal motor vehicle safety standard. Given the public interest against restricting the mobility of the handicapped, it is the agency's policy, depending on the particular situation, to consider certain violations of that section as technical ones justified by public need. In a telephone conversation with Marvin Shaw of my staff, you explained that a van conversion company modified new Dodge Maxi-vans for your agency before they were purchased. Among the steps taken by the converter to accommodate handicapped individuals are the removal of the 'top,' the addition of a new 'bottom,' and the installation of a wheelchair lift. According to Mr. Harrell's letter, the converter, when contacted last year, stated that the vehicles, after being converted, comply with State and Federal regulations. You indicated, however, that the converter failed to certify that the vans, as altered, comply with Federal motor vehicle safety standards. I am pleased to have this opportunity to explain our laws and regulations to you. I apologize for the delay in our response. The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards applicable to new motor vehicles and new motor vehicle equipment. Each manufacturer is required to certify that its products meet all applicable safety standards. Based on your letter and the telephone conversation with my staff, it appears that the van converter would be considered an 'alterer' for purposes of of Part 567, Certification (copy enclosed). Section 567.7 defines 'alterer' as 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, or who alters the vehicle in such a manner that its stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale... As an alterer, section 567.7 requires the vehicle converter to do the following: (1) Supplement the certification label affixed by the original manufacturer by affixing an additional label stating that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards. This supplemental label must state the name of the alterer and the month and the year in which the alterations were completed (see 567.7(a)), (2) Provide the modified values for the gross vehicle weight ratings or any of the gross axle weight ratings of the vehicle as altered if they are different from those shown on the original certification label (see 567.7(b)), and (3) Provide the type classification, if the vehicle as altered has a different type classification from that shown on the original certification (see 567.7(c). If the converter did not comply with these requirements, then it did not fulfill its certification responsibilities under Part 567. From what you have written to us, we assume that is the case. However, this does not in itself mean that the vehicles, as altered, do not comply with applicable safety standards or are otherwise unsafe. If you believe that the conversion of these vehicles poses a safety problem, you should contact this agency's Office of Enforcement and explain the specific safety problem. If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0501OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P. O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P. O. Box 898 Sacramento CA 95804; Dear Mr. Heath: Your inquiry concerning the certification required of seat belt installed in motor vehicles manufactured after January 1, 1972, has been brought to our attention. Motor Vehicle Safety Standard No. 208, which governs the installation of seat belts, requires belts to conform to Standard No. 209. Since Standard No. 209 is amended effective January 1, 1972, your question is whether a vehicle manufactured after that date must have seat belts that are certified as conforming to the new provisions of Standard No. 209.; We construe Standard No. 208 to require only that the belts conform t Standard No. 209 as it was at the time of their manufacture. Thus, a belt manufactured before January 1 that conforms to the contemporaneous (pre-amendment) version of Standard No. 209 may be installed in a vehicle manufactured after that date. A belt manufactured after January 1, must, of course, conform to the amended version of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5353OpenMr. Randolph Schwarz 141 North Madison Drive South Plainfield, NJ 07080; Mr. Randolph Schwarz 141 North Madison Drive South Plainfield NJ 07080; "Dear Mr. Schwarz: This responds to your letter to Mr. John Messera o NHTSA, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 116, Motor vehicle brake fluids. Your letter has been referred to my office for a response. As a consumer retrofitting your vehicle with DOT 5 brake fluid, you had several questions concerning the possible effects that an ingredient in the brake fluid might have on elastomers used in brake systems. Your questions are answered below. You mentioned 'seal swelling additives' added to DOT 5 brake fluid, that contact various elastomers in the brake system. Your first question was, when brake fluid manufacturers combine additives with brake fluid, should consumers be concerned with the combined fluids' compatibility with various elastomers used in braking systems? Standard No. 116 defines, at S4. Definitions, brake fluid as a liquid designed for use in a motor vehicle hydraulic brake system where it will contact elastomeric components made of: styrene and butadiene rubber (SBR), ethylene and propylene rubber (EPR), polychlorophene (CR) brake hose inner tube stock, or natural rubber (NR). In order to minimize failures in hydraulic braking systems, Standard No. 116 specifies minimum performance standards for brake fluids. These performance standards include tests for styrene and butadiene rubber cups, the most common type of elastomer in a hydraulic brake system. The brake fluid manufacturer must certify that the brake fluid complies with Standard No. 116. (See S5.2.2(d).) While DOT 5 brake fluid must meet Standard No. 116, the specific ingredients in the fluid are not regulated by the standard. The brake fluid manufacturer is expected to be aware that in addition to SBR, its brake fluid may contact EPR, CR, and NR elastomers in the brake system. Thus, the brake fluid manufacturers must ensure that contact between the fluid and the above stated elastomers would not result in a safety-related defect under the National Traffic and Motor Vehicle Safety Act. Sections 151-159 of the Safety Act concern the recall and remedy of products with defects related to motor vehicle safety. In the event that the brake fluid manufacturer or NHTSA determines that the brake fluid contains a safety related defect, the brake fluid manufacturer would be responsible for notifying purchasers of the defective brake fluid and remedying the problem free of charge. Your second question was whether DOT 5 brake fluid's compliance with Standard No. 116 ensures compatibility with elastomers. The answer is yes, for SBR elastomers. Further, besides Standard No. 116, the brake fluid manufacturer is subject to sections 151-159 of the Safety Act, that were previously discussed. At this time, NHTSA is not aware of safety related defects resulting from other ingredients used with brake fluid. Your third question was whether Standard No. 116 only addresses SBR compatibility with brake fluid. Standard No. 116, at S4, addresses brake fluid that contacts four elastomer types. However, the tests specified in the standard are only of the most commonly used SBR cups. Your fourth question was, if Standard No. 116 only mentions SBR elastomer, would it be advisable to add other elastomers to the specification, or to discuss elastomer compatibility on the brake fluid container? Information discussing the elastomer compatibility of the brake fluid, or other ingredients, may be voluntarily placed on brake fluid containers. Standard No. 116 specifies information that brake fluid containers must carry. However, Standard No. 116 does not prohibit manufacturers from noting on brake fluid containers, compatibility of the silicone brake fluid, or other ingredients, with various elastomers. Finally, you asked what Standard No. 116 specifies as the maximum viscosity for DOT 5 brake fluid, at -40 degrees Fahrenheit. Standard No. 116 specifies, at S5.1.3(c), that the maximum viscosity is 900 centistokes (cSt). I hope that this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting 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.