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: aiam0048OpenMr. C. de Castelet, Assistant Director of Research and Development, Renault, Billancourt - Seine, Paris, France; Mr. C. de Castelet Assistant Director of Research and Development Renault Billancourt - Seine Paris France; Dear Mr. de Castelet: Thank you for your letter of December 1, 1967, concerning tests make o the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.; We recognize the validity of a system which takes advantage of th energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing an energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash situation. Therefor any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test as specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.; Your second point concerns the need for a more explicit definition o translational motion. SAE J944 states that the body-block *contracts* the wheel in translational motion. It does not say that this motion must continue after impacting the wheel Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a simulation of an actual crash restrained in translational motion *after* impact. Since the body motion in an actual crash situation will vary somewhat the Bureau feels that a more explicit definition of translational motion is unnecessary.; The third series of test as described in Report No. 207.397 using rigid test fixture and the free flying body-block are compatible with the SAE J944 test procedure.; Your interest in motor vehicle safety is appreciated. Sincerely, William Haddon, Jr., M.D., Director |
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ID: aiam2075OpenMrs. Helen Ginley, 8706 Orchard Avenue, Brooklyn, OH 44144; Mrs. Helen Ginley 8706 Orchard Avenue Brooklyn OH 44144; Dear Mrs. Ginley: This is in response to your letter asking whether the odomete disclosure statement which you enclosed has been properly completed.; 49 CFR Part 580, *Odometer Disclosure Requirements*, which wa promulgated by the National Highway Traffic Safety Administration (NHTSA) under the authority of section 408 of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513), prescribes the content and proper procedure for executing mileage disclosure statements at the time vehicles are transferred from one owner to another.; The form of the statement provided to you by Tommy Barrett, Inc appears in compliance with the provisions of Part 580. The person who completed the statement, however, failed to disclose the vehicle's last plate number. In order to meet the requirements of section 408 of the Cost Savings Act and Part 580, this information must be disclosed in writing to the vehicle purchaser. Although the transferor's address was not correctly filled in, the form has been stamped with what appears to be an appropriate address.; Failure to fulfill the requirements of the Cost Savings Act may subjec the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages, whichever is greater.; Since the license number may have been inadvertently omitted, I woul suggest that you contact Mr. Barrett and inform him of the deficiency in the statement he provided you. You will probably want him to add the information that is currently missing.; For your information, I have enclosed copies of the relevant portion of the Act and regulation.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4772OpenMr. David J. Blackwell Operations Manager Liquidus Limited 37A Shorncliffe Road Toronto, Ontario 48Z 5K2, Canada; Mr. David J. Blackwell Operations Manager Liquidus Limited 37A Shorncliffe Road Toronto Ontario 48Z 5K2 Canada; "Dear Mr. Blackwell: This is in response to your letter asking whethe a certain vehicle that you plan to export to the United States would be subject to the Federal Motor Vehicle Safety Standards. You state that Liquidus has 'designed a system' by customizing an existing road tanker for 'overhead' loading. The vehicle you plan to export would be used for 'aircraft de-icing storage' and 'loading of aircraft de-icing tarmac vehicles while in a fixed location.' The road tanker used in your system was originally built in Canada by a firm that has since gone out of business. I am pleased to have this opportunity to explain our statute and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) authorizes this agency to issue safety standards for new 'motor vehicles' and new items of 'motor vehicle equipment.' Accordingly, your vehicle is subject to the safety standards only if it is considered within the definition of 'motor vehicle' under the Safety Act. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. We have interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Tractors and other agricultural equipment are also not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., certain airport runway vehicles and underground mining vehicles) are not considered motor vehicles, even though they may be operationally capable of highway travel. In addition, items of mobile construction equipment which use the highways only to move between job sites and which typically spend extended periods of time at a single job site are not considered motor vehicles. On the other hand, vehicles that use the public roads on a necessary and recurring basis are motor vehicles. For instance, utility vehicles like the Jeep are plainly motor vehicles, even though they are equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, NHTSA has treated it as a motor vehicle. Further, if a vehicle is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, NHTSA has treated the vehicle as a motor vehicle. This finding was made with respect to dune buggies, notwithstanding the manufacturers' statements that the vehicles were not intended to be used on the public roads. NHTSA has also stated in many prior interpretations that even vehicles that will regularly be used on the public roads will not be considered motor vehicles for the purposes of the Safety Act, if the vehicles have a maximum attainable speed of 20 miles per hour (mph) or less and have an abnormal configuration that readily distinguishes them from other vehicles on the road. We would apply these principles to the vehicle identified in your letter as follows. Your letter stated that this vehicle will be immobilized after it reaches the airport. Assuming this immobilization occurs, this vehicle would appear to be designed and sold solely for off-road use, just like certain other airport runway vehicles. In this case, it would not be a motor vehicle, even though it is operationally capable of highway travel before the immobilization. However, if the vehicle were not subsequently immobilized, and were moved from airport to airport with only a limited stay at any job site, this vehicle might be considered a 'motor vehicle.' This conclusion would be even more likely if a significant percentage of the vehicle's purchasers were to use the vehicle by moving it from airport to airport, notwithstanding your company's intent that the vehicles not be so used. This situation would be analogous to the classification of dune buggies. I hope that this information is helpful. If you have any additional questions, please contact John Rigby of this office by mail at the above address or by telephone at 202-366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1570OpenMr. James P. Coughlin, Vice President - Marketing, Bell Helmets Inc., 2850 East 29th Street, Long Beach, CA 90806; Mr. James P. Coughlin Vice President - Marketing Bell Helmets Inc. 2850 East 29th Street Long Beach CA 90806; Dear Mr. Coughlin: This is in reply to your letter of July 25, 1974, asking whether th statement 'Make no modifications' included in the labeling requirements of Standard 218, *Motorcycle Helmets*, would prohibit the after-market installation of a quick release device which may be attached to a helmet's retention strap. You included an illustration of such a device in your letter.; The answer is no. The statement does not restrict after-marke modifications by a first purchaser for purposes other than resale. It only serves to warn the consumer of the danger of making such modifications.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4288OpenMr. Karl-Heinz Ziwica, Manager, Environmental Engineering, BMW of North America, Inc., Montvale, NJ 07645; Mr. Karl-Heinz Ziwica Manager Environmental Engineering BMW of North America Inc. Montvale NJ 07645; Dear Mr. Ziwica: This letter concerns your request for an interpretation of Federa Motor Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*, as it applies to the antitheft device BMW intends to install on the Carline 7 passenger car line for model year 1988. We apologize for the delay in responding to your inquiry.; On October 9, 1986, NHTSA published a notice in the Federal Registe granting BMW's petition for an exemption from the marking requirements of the vehicle theft prevention standard, based on its determination that an effective antitheft device will be installed on those lines as standard equipment. (51 FR 3633.) However, because NHTSA wished to further consider the compliance of the double- lock aspect of the central locking system with Standard No. 206, we granted the petition while reserving decision on that issue. We have completed our evaluation of the double-lock system and have determined it is permitted by the standard.; In its petition for exemption from the marking requirements of th Theft Prevention Standard, BMW described an antitheft device which, among other things, prevents entry into the vehicle by affecting the door locks in the following manner:; >>>The inside locking mechanism operating means is a vertical plunge on each door, and the plungers on the front doors override the two rear door plungers. To prevent locking the keys in the car upon exiting, the front doors can only be locked with a key. For Convenience, this also locks all other doors, if they are open at the time of locking, they lock when closed.<<<; >>>The locks in the front doors have three-positions cylinders - off 45 degrees, and 90 degrees. Upon exiting, if the key is turned 45 degrees and removed from the lock, the doors, trunk and gas filler door are locked. If, however, the key is rotated 90 degrees and removed, the car's burglar alarm is armed and the doors are 'double locked', after the plungers move downward, the central locking system is deactivated and the door locks are mechanically inhibited. Thus locked, neither an outside nor inside handle, nor a locking plunger can be used to unlock a door - the doors can only be unlocked and the alarm disarmed using a key in a front door lock... Disconnecting the battery does not unlock the doors or change the 'double locked' mode... In the event of an accident, an inertia switch automatically unlocks all doors.<<<; The requirements of Standard No. 206 for door locks are as follows: >>>S4.1.3 Door locks. Each door shall be equipped with a lockin mechanism with an operating means in the interior of the vehicle.<<<; >>>S4.1.3.1 Side front door locks. When the locking mechanism i engaged, the outside door handle or other outside latch release control shall be inoperative.<<<; >>>S4.1.3.2 Side rear door locks. In passenger cars and multipurpos passenger vehicles, when the locking mechanism is engaged both the outside and inside door handles or other latch release controls shall be inoperative.<<<; The standard was amended on April 27, 1968, to include the door loc requirements described above. An objective of the amendment was to ensure retention of occupants within the vehicle during and subsequent to an impact by reducing inadvertent door openings due to impact upon or movement of inside or outside door handles, and to afford occupants of the rear of a vehicle a method of unlocking the rear door from inside the vehicle (i.e., a reasonable means of escape) in the postcrash phase of an accident.; Your inquiry raises the issue of the permissibility under S4.1. through S4.1.3.2 for negating the capability of the operating means to disengage requisite door locking mechanisms. As explained below, based on our review of the purpose of Standard No. 206 and past NHTSA interpretations of the standard, we conclude that the standard prohibits only additional locking systems which interfere with the capability of the operating means to *engage* the locking system required by the standard. Since, according to your letter of September 24, 1986, BMW's double-lock feature does not interfere with the interior operating means' engagement of the required door locks, the secondary locking system is permitted.; The answer to your question about the double lock system is dependen on whether the system interferes with an aspect of performance required by Standard No. 206. We have determined that the answer is no, because the requirements of S4.1.3.1 and S4.1.3.2 of the standard are written in terms of what must occur when the required locking system is engaged and impose no requirements for the effects of disengaging the system. Thus, the aspect of performance required by S4.1.3 for the interior operating means for the door locks is that it be capable only of *engaging* the required door locking mechanisms. The aspect of performance required by S4.1.3.2 for door locks on the rear doors is that the inside and outside door handles be inoperative when the locking mechanism is *engaged.* Since we have determined that S4.1.3 through S4.1.3.2 do not address the effects of disengaging the required door locks, we conclude that the required aspect of performance in S4.1.3 for door locking mechanisms is that the interior operating means be capable only of engaging the locks. We thus conclude that the standard permits an additional door locking device which might interfere with the disengagement of the required locking system. The additional system, however, must *not* interfere with the capability of the operating means to engage the required door locks.; In determining that the performance requirements of Standard No. 20 address only the effects of engaging the required door locks, we noted that the purpose of the standard is to 'minimize the likelihood of occupants being thrown from the vehicle as a result of impact.' Throughout the rulemaking history of the standard, NHTSA has limited application of the standard's performance requirements only to doors that are provided for the purpose of retaining the driver and passengers in collisions. Because the standard is narrowly focused on occupant retention in a vehicle and specifies no performance requirements for occupant egress, we concluded that there is no requirement in the standard that prohibit a device which negates the capability of the inside operating means for the door locks to disengage the locks, provided that the device does not interfere with the engagement of the required door locking system.; This letter interprets Standard No. 206 in a manner that clarifies pas agency statements on issues raised by secondary locking systems. To the extent that the statements contained herein conflict with interpretations issued in the past, the previous interpretations are overruled.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4322OpenMr. Paul Utans, Vice President, Government Affairs, Subaru of America, P.O. Box 6000, Cherry Hill, NJ 08034-6000; Mr. Paul Utans Vice President Government Affairs Subaru of America P.O. Box 6000 Cherry Hill NJ 08034-6000; Dear Mr. Utans: This responds to your letter of April 21, 1987, concerning the Part 58 Bumper Standard. You asked whether a vehicle equipped with a suspension system whose height is adjustable by the driver is tested at the manufacturer's engine- on and engine-off nominal design height.; On May 6, 1986, I responded to a similar request that you made for a interpretation. My letter (copy enclosed) stated that it is our interpretation that a vehicle must be capable of meeting the standard's damage criteria at any height position to which the suspension can be adjusted.; Your current request for an interpretation does not provide ne arguments which indicate that our earlier interpretation was incorrect. Therefore, I must reaffirm that earlier opinion.; As we indicated in the May 6, 1986 letter, we appreciate your concer that the very reason that the adjustable height is provided (increased ground clearance and ramp angle for special operations) is partially negated by requiring bumpers to extend low enough to provide Part 581 protection at the elevated settings. The letter stated, however, that if the agency were to consider establishing special provisions in Part 581 for vehicles with adjustable suspension height control systems, it would need to be done in rulemaking. See section 102(c)(1) of the Motor Vehicle Information and Cost Savings Act.; I would also note that in a meeting in March of this year, a member o my staff advised your representatives that your company could submit a petition for rulemaking requesting an amendment to Part 581. The procedures for submitting a petition for rulemaking are set forth at 49 CFR Part 552. If you should submit a petition, the agency would decide whether to grant it in accordance with statutory criteria.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1120OpenMr. W. H. Blaine, Manager, Southern California Edison Company, Automotive; Mr. W. H. Blaine Manager Southern California Edison Company Automotive; Dear Mr. Blaine: This is in response to your letter of April 13, 1973, in which you as whether the installation of a truck body or derrick on a new chassis-cab by your company for its own use makes it a final-stage manufacturer subject to the identification and certification provisions implementing the Highway Traffic and Motor Vehicle Safety Act, Public Law 89- 563.; The answer to your question is yes. The completion of a motor vehicl by a manufacturer for its own use does not relieve it of responsibility for certification.; As a final-stage manufacturer, you are required to submit th information specified in 49 CFR Part 566, Manufacturer Identification. I am enclosing a copy of Part 566 for your information. No specific format is required, and a letter report will suffice.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5163OpenMr. Jeff Gerner Product Engineering Manager Banner Welder, Inc. N117 W18200 Fulton Drive Germantown, WI 53022; Mr. Jeff Gerner Product Engineering Manager Banner Welder Inc. N117 W18200 Fulton Drive Germantown WI 53022; "Dear Mr. Gerner: This responds to your inquiry about whether th mobile screening and shredding equipment that you manufacture would have to comply with Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems. In a telephone conversation with Mr. Marvin Shaw of my staff, you explained that your equipment is designed to be used primarily in off-road environments such as compost sites similar to landfills, but may be towed over the public roads to multiple sites. You stated that most purchasers of your equipment use it at an off-road site for extended time periods, but occasionally the equipment will be moved from one off-road to another off-road site on a more frequent basis. You stated that it would be inconvenient for your equipment to comply with Standard No. 121's emergency braking requirements because a truck with an air brake system would be needed at all times to move your equipment. I am pleased to have this opportunity to explain our regulations to you. By way of background information, this agency interprets and enforces the National Traffic and Motor Vehicle Safety Act under which the Federal Motor Vehicle Safety Standards are promulgated. The Act defines the term 'motor vehicle' as follows: 'any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.' If a vehicle is a motor vehicle under the definition, then the vehicle must comply with all applicable Federal motor vehicle safety standards. However, if a vehicle is not a motor vehicle under this definition, then the vehicle need not comply with the agency's safety standards because such a vehicle is outside the agency's scope of authority. Whether the agency will consider a construction vehicle, or similar equipment, to be a motor vehicle depends on its use. It is the agency's position that this statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. In instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time, such vehicles are considered motor vehicles for purposes of the Safety Act, since the on- highway use is more than 'incidental.' Based on the literature provided in your letter and the subsequent telephone conversation, the agency believes that the on-highway use of your equipment is merely incidental and not the primary purpose for which they were manufactured. Accordingly, it appears that your mobile screener and shredder are not 'motor vehicles' within the meaning of the Safety Act. Therefore, they would not be subject to the Federal Motor Vehicle Safety Standards. This conclusion is based on the assumption that your equipment generally spends extended periods of time at a single construction site and only uses the public roads infrequently to move between job sites. We note that while your letter stated that your equipment may be moved 'daily or weekly' on the public roads to other sites, you stated in the telephone conversation that such frequent movement is rare and that this equipment is primarily for off-road purposes. The agency would reconsider this determination if it obtained information indicating that the equipment's on-highway use is more than 'incidental.' I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1989OpenMr. Manuel M. Ellenbogen, Supervisor, Export Sales & Licensing, International-Automotive, The Budd Company, 2450 Hunting Park Avenue, Philadelphia, PA 19132; Mr. Manuel M. Ellenbogen Supervisor Export Sales & Licensing International-Automotive The Budd Company 2450 Hunting Park Avenue Philadelphia PA 19132; Dear Mr. Ellenbogen: This is in response to your letter of July 8, 1975, asking whic standards might be affected by the mounting of a tail lamp in the elastic skin of a bumper.; Motor Vehicle Safety Standard No. 215, *Exterior Protection* prescribes barrier and pendulum impact tests to which vehicles must be subjected without incurring certain types of damage. Included in the list of safety systems that must remain undamaged are lamps and reflective devices. S5.3.1 of Standard 215 states that each lamp or reflective device, except license plate lamps, must remain free of cracks and comply with the applicable visibility requirements of S4.3.1.1 of Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; The manufacturer should be aware that placement of a tail lamp in th elastic skin of a bumper might expose it to damage during Standard 215 compliance testing.; For your information, I have enclosed copies of the current Standar No. 215, the proposed Part 580 bumper damageability standard, and Standard No. 108.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0361OpenMr. David A. Phelps, Jr., Group Supervisor, Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Group Supervisor Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps: This letter is to further clarify an interpretation contained in ou letter of May 6, 1971, concerning the Tire Identification and Record Keeping Regulation.; We wish to make it clear that although the final-stage manufacturer ma designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .' (49 C.F.R. 568.7). In such a case, the responsibilities for maintaining the records required by the Act and by the Tire Identification and Record Keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final-stage manufacturer will be relieved of all liability for maintaining the records.; We would also point out that the Tire Identification and Record Keepin Regulation was not meant to preclude the use of multiple designees for the maintenance of the required records. See the enclosed interpretation issued on May 28, 1971 (36 F.C. 9780).; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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.