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: aiam0935OpenMr. J. Patrick Roney, Hatch Imports, Inc., P. O. Box 413, Van Nuys, CA 91408; Mr. J. Patrick Roney Hatch Imports Inc. P. O. Box 413 Van Nuys CA 91408; Dear Mr. Roney: This is in reply to your letter of December 5, 1972, concernin approvals required by the Federal Government regarding the sale of safety glazing materials.; No approval by the Federal Government is required. Certification o conformance to Federal Motor Vehicle Safety Standard No. 205 and Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966.; If you are not aware of State approvals, you may want to contact Mr Armand Cardarelli, of the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, DC 20036; |
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ID: aiam4425OpenMr. John S. Crockenberg 156 Holland Road Ormond Beach, FL 32074; Mr. John S. Crockenberg 156 Holland Road Ormond Beach FL 32074; "Dear Mr. Crockenberg: This is in response to your letter of Februar 26, 1988, concerning antiglare plexiglass shields. I regret the delay in our response. You asked whether Standard No. 103, Windshield Defrosting and Defogging Systems, Standard No. 111, Rearview Mirrors, or any other Federal Motor Vehicle Safety Standard applies to your product, a 4' x 6' x 1/8' parallelogram with rounded corners made of transparent bronze plexiglass with an attached 1/2' diameter suction cup. You noted that this device, which adheres to the interior of automobile windows, deflects obstructive sunglare where conventional sun visors cannot be placed. You also asked what other agency's regulations you should be aware of before you begin to manufacture and market this device, if none of our standards apply. You are correct in assuming that Standard No. 103 and Standard No. 111 do not apply to your product. The only Federal Motor Vehicle Safety Standard that is relevant to your product is Standard No. 205, Glazing Materials. S2 states that one purpose of this standard is to 'ensure a necessary degree of transparency in motor vehicle windows for driver visibility.' S1 and S3 note that Standard No. 205 applies to glazing materials in both motor vehicles and motor vehicle equipment. I am enclosing an agency 'fact sheet,' which concerns the tinting of motor vehicles and motor vehicle equipment. I also am enclosing two previous NHTSA interpretation letters, which concern products similar to your antiglare shield. These letters to Susan House on December 20, 1985 and to Jeffrey Richard on April 16, 1985 explain the effect of Standard No. 205 on a manufacturer of such a product. In response to your second question, I have enclosed a copy of an information sheet for new manufacturers of motor vehicles and motor vehicle equipment. This identifies other agencies whose regulations might be applicable to a new manufacturer's products. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel Enclosures"; |
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ID: aiam0466OpenMr. W. G. Milby, Chairman, Defect Report Committee, Blue Bird Body Company, Fort Valley, GA 31030; Mr. W. G. Milby Chairman Defect Report Committee Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of September 13, 1971, concerning th Defect Reports regulations (49 CFR Part 573). You request a ruling concerning S573.7, which requires manufacturers to submit a copy 'of all notices, bulletins, and other communications, other than those required to be submitted under S573.4(c)(8), sent to more than one dealer or purchaser of his vehicles regarding any defect, whether or not safety related, in such vehicles.'; You ask whether this requirement includes letters that your compan writes that are of a personal nature concerning possible defects, when the letters deal with more than one item, but have at least one item in common. If these letters are included in the requirement, you request that we specify a time span for which you would be responsible.; The intent of S573.7 is for manufacturers to provide the NHTSA wit certain information each time a defect other than a defect under S573.4(c)(8) is found to exist in more than one vehicle. Thus, assuming the defect is not one on which information has been submitted pursuant to S573.4(c)(8), you may satisfy the requirement of S573.7 by submitting a copy of any one letter that pertains to a defect found in more than one vehicle, as long as the letter is appropriately marked so that we can determine for which defect it is being submitted.; The regulation does not limit the time span for which manufacturers ar responsible, and manufacturers must be sufficiently familiar with their repair programs so that if a defect appears at two or more points in time, the necessary information can be submitted.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4976OpenCharles W. O'Connor, Esq. Assistant Secretary Echlin Inc. 100 Double Beach Road Branford, CT 06405; Charles W. O'Connor Esq. Assistant Secretary Echlin Inc. 100 Double Beach Road Branford CT 06405; Dear Mr. O'Connor: This responds to your letters of December 26, 1991 and February 25, 1992, with respect to various interpretive letters of this office on the Commander and Voyager Electronic Brake Control ('Control'). The Control is manufactured by your subsidiary, Tekonsha Engineering Company. For the reasons enunciated in your December letter, you have asked us to 'rule that all three of your letters i.e., the November 22 and May 23, 1991, letters to Mr. Lewandoski and your letter of September 10, 1990, to Mr. Henneberger are all void from the beginning.' We are replying on the basis of information presented by representatives of Tekonsha, Mr. Henneberger, and yourself in a meeting with representatives of NHTSA on March 18, 1992, rather than on the basis of your December letter. This meeting brought forth facts, previously unknown to us, and which did not, therefore, form a basis for the three previous letters on this subject mentioned above. We now understand that the Control is motor vehicle equipment which is added to the towing vehicle by the seller of the towed vehicle, at a time subsequent to the first purchase of the towed vehicle for purposes other than resale. The Control has no effect upon the stop lamp system of the towing vehicle. The Control in ordinary operation has no effect upon the stop lamp system of the towed vehicle. When hand-activated in an emergency mode, the Control applies a modulated pressure to the service brakes of the towed vehicle, without activating the stop lamps on the towed vehicle. It is theoretically possible that the Control will never be operated during the life of the towing vehicle. It is our opinion that the applicable Federal law in this situation is that which pertains to the operation of vehicles in use, rather than the Federal motor vehicle safety standards that apply to motor vehicles before their first purchase for purpose other than resale. This means that we do not view this as a question of compliance with Federal Motor Vehicle Safety Standard No. 108 or a matter concerning the preemption of State statues by Standard No. 108. Under the statues and regulations we administer, the applicable law is 15 U.S.C. Section 1397 (a) (2) (A). This Section states in pertinent part: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with the applicable Federal motor vehicle safety standard ....' The question therefore is whether the installation of the Control on the towing vehicle by the dealer of the towed vehicle renders the stop lamps (installed on the towed vehicle in compliance with Standard No. 108) inoperative in whole or in part within the meaning of Section 1397 (a) (2) (A). We note that the installation per se of the Control has no effect of any sort n the stop lamps of the vehicle on which it is installed, or on the vehicle that is towed. Therefore, the dealer has not rendered any stop lamps inoperative by the act of installing the Control. It is the use of the Control that may have an effect upon the stop lamps. In ordinary use, the Control has no effect upon the stop lamps of either the towing or the towed vehicle. However, when the hand control of the device is activated in the emergency mode on the towing vehicle, to slow the swaying of the towed vehicle through application of the only set of brakes on the towed vehicle (its service brakes), the stop lamps will not be activated. In the conscious act of activating the emergency feature, the operator has knowingly rendered the stop lamps on the towed vehicle inoperative for the duration of such activation (unless or until the operator applies the service brake of the towing vehicle). However, Section 1397 (a) (2) (A) does not apply to operators, thus the activation and use of the Control is not prohibited under our Statues and regulations. On the basis of the facts presented in the meeting on March 18, it now appears that the sale of the Control is not in violation of the National Traffic and Motor Vehicle Safety Act. Sincerely, Paul Jackson Rice Chief Counsel cc:Larry Henneberger Bill Lewandoski California Highway Patrol; |
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ID: aiam0036OpenMr. David A. Phelps, Jr., Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps: This is in response to your letter of November 10, 1967, in which yo requested a clarification of the use of the term 'combined optically' as used in Motor Vehicle Safety Standard No. 108, Sections S3.3(c) and S3.4.4.3.; S3.3(c)>>>*Lamp Combinations and Equipment Combinations*. Two or mor lamps, reflective devices, and items of associated equipment may be combined if the requirements for each lamp, reflective device, and item of associated equipment are met, except that --; (c) No clearance lamp may be combined optically with any taillamp o identification lamp.<<<; This means that no clearance lamp my be combined to use a lense (sic that is common to any other lamp such as a taillamp or identification lamp. The clearance lamp shall have a unique lense (sic).; S3.4.4.3>>>Stoplamps that are combined optically with turn signal lamp need not be operable when the combination is in use as a turn signal or as a vehicular hazard warning signal.<<<; This means that stoplamps that have a lense (sic) that is common wit the turn signal lamps do not have to be operable when the combined stoplamp and turn signal lamp is used primarily as a turn signal or as a hazard warning signal. Stoplamps need not be operable when the combined stoplamp and turn signal lamp unit is used as a hazard warning or turn signal indicator.; We trust these comments will be of assistance in clarifying you problems.; Sincerely, Andrew K. Ness, Acting Director, Office of Performanc Analysis; |
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ID: aiam5234OpenMr. Scott R. Dennison Vice-President - Production Excalibur Automobile Corporation 1735 South 108th Street Milwaukee, WI 53214; Mr. Scott R. Dennison Vice-President - Production Excalibur Automobile Corporation 1735 South 108th Street Milwaukee WI 53214; "Dear Mr. Dennison: Thank you for your letter of April 27, 1993 clarifying your FAX of March 12 to which I responded on April 19. We appreciate your goal of helping people comply with the Federal Motor Vehicle Safety Standards (FMVSS) and those of EPA. We can well understand why, as you put it, 'at times I do not feel I have the right answers for some of these manufacturers.' The regulation of kit cars and vehicles combining old and new parts is a complicated subject, and our opinions usually depend upon the specific facts of individual cases with the result that one may differ in degree from another. Because these are legal opinions, the Office of Chief Counsel is the proper Office within NHTSA to address questions of this nature, rather than the agency's Enforcement office. We are sorry that some of your inquirers 'are afraid to call NHTSA for fear of reprisal.' By this, I think you mean that a call from a small manufacturer might cause NHTSA to initiate enforcement action concerning nonconformance with the FMVSS or agency regulations. The potential of an enforcement action should be sufficient to encourage those engaged in the manufacturing or assembling of motor vehicles to discern their responsibilities under the National Traffic and Motor Vehicle Safety Act and to comply with them. We are willing to assist manufacturers in interpreting the Act and regulations. If they do not wish to write or call us, they can review our interpretation letters which are available to the public in NHTSA's Technical Reference Division. Also, they can consult a private attorney. You enclosed a copy of the 'EPA Kit Car Policy' which we have reviewed, comparing it with NHTSA policy. In most respects, the two policies are congruent. Paragraph 1 of the EPA document fairly expresses NHTSA policy, fully assembled kit cars, and complete kit car packages are 'motor vehicles' under the Act, required to be certified by the manufacturer or kit supplier. If they are not certified, they must be imported by a NHTSA-registered importer (the counterpart to EPA's Independent Commercial Importer), or one who has a contract with a registered importer to certify the kit car (an allowance that we understand does not exist under EPA regulations). I shall return to Paragraph 2 later. Paragraph 3 differs from NHTSA policy, although automotive bodies are not 'motor vehicles' under either EPA or NHTSA's definitions, they are 'motor vehicle equipment' for purposes of NHTSA's jurisdiction. Paragraph 4 essentially states NHTSA policy, kit car body/chassis combinations may be imported as automotive equipment and are subject to NHTSA's regulations. Similarly, any attempt to circumvent the Act or import regulations may be viewed as a violation subject to enforcement. However, NHTSA will also regard as a 'manufacturer' any person importing kits or kit cars for resale, as well as the actual fabricator or assembler of a kit. Paragraph 2 reflects the fact that EPA regulates only engines and emission- related components. A vehicle 'will be considered to be a rebuilt vehicle of a previously certified configuration and will be considered to be covered by that configuration's original EPA certification of conformity' if the engine and all emission-related components and settings conform to those of the previously certified configuration, and if the weight of the completed kit vehicle is not more than 500 pounds greater than that of the originally certified configuration. Under EPA policy, a 'rebuilt vehicle' could be a motor vehicle all of whose parts were new and unused except for its engine and engine-related components. NHTSA has no definition of 'rebuilt vehicle' which would permit a similar interpretation, and while a vehicle as I have described could be covered by the previously existing EPA certification, NHTSA very likely would regard it as a newly manufactured motor vehicle which must be certified as meeting all contemporary FMVSS. It is here that the two agencies most diverge because of the breadth of NHTSA's regulatory authority which encompasses all motor vehicle equipment, and motor vehicles assembled from that equipment. You cite as an example of difficulty 'the treatment of FMVSS with regards to a '23 T-Bucket Hot Rod'. The first question to answer is whether the car has been manufactured primarily for use on the public roads. Factors to consider in this determination are whether the Hot Rod is intended solely for use on closed race tracks, whether it must be trailered from race to race, and whether a State would license it for on road use. If the car has not been manufactured primarily for on road use, then it is not a 'motor vehicle' as defined by the Vehicle Safety Act, and not subject to the FMVSS. If the car is a 'motor vehicle' and entirely assembled from parts from a disassembled motor vehicle or vehicles previously in use, then it is considered a 'used' vehicle, and also not subject to the FMVSS (but subject to state and local standards). On the other hand, if the kit car is entirely comprised of previously unused parts, then it is a new motor vehicle that is required to comply with, and be certified as complying with, the FMVSS (and its manufacturer may be eligible to apply for a temporary exemption from one or more of those standards under 49 CFR Part 555). If the kit car is comprised of parts both previously used and unused, NHTSA's examination of the list of components in each category will enable it to advise whether the kit car must comply with the FMVSS that apply to new vehicles. In addition, we also receive inquiries from those who wish to construct vehicles which use a 'host' chassis from a previously certified vehicle. The Act permits a manufacturer to modify a previously certified vehicle in any manner as long as it does not knowingly render inoperative in whole or in part any device or element of design installed by the original manufacturer in accordance with a Federal motor vehicle safety standard. We interpret this as meaning that, if the manufacturer removes the original body, at the end of the conversion process the resulting motor vehicle must continue to comply with the FMVSS that were in effect when it was originally manufactured. However, a certain divergence from original vehicle compliance is permitted. For example, if a 1982 enclosed passenger car is modified to become a convertible, at the end of the conversion process it is no longer required to meet enclosed car FMVSS but must comply with those that applied to l982 convertibles. The Act does not require that such vehicles be certified but the manufacturer should be prepared to substantiate that it has not rendered inoperative any of the vehicle's original safety equipment, either directly or indirectly (such as a substantial increase in the weight of the vehicle that might affect its crash protection characteristics) in the event NHTSA should so ask. Finally, we note your remark that NHRA and SEMA are debating whether a policy can 'be developed which will allow these builders to produce an authentic replica and stay within the standards.' As I discussed above, the FMVSS would not appear to apply to a replica vehicle such as a Miller racing car from the 1920's that could not be licensed for on road use. However, the FMVSS do apply to vehicles composed of newly manufactured parts that replicate the look of older vehicles. For this reason, 100% authenticity cannot be achieved for a replica required to meet the current FMVSS because of equipment such as the center highmounted stop lamp, side marker lamps and reflectors, and head and other occupant restraints required for safety today. As a general rule, we would not provide temporary exemptions from these standards. In our view, the only viable candidate for an authentic replica is one that is constructed on a 'host' chassis of a vehicle manufactured before January 1, 1968, the date that the first FMVSS became effective, or entirely from used parts. I would also note that much authenticity could result from use of a 'host' chassis manufactured during calendar year l968. Although the appearance of the interior would be affected by compliance with certain FMVSS, the FMVSS requiring side marker lamps and reflectors and head restraints did not become effective until January 1, 1969. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3533OpenMr. Chris Tuerck, Assistant Chief Engineer, K-D Lamp Company, 1910 Elm Street, Cincinnati, Ohio 45410; Mr. Chris Tuerck Assistant Chief Engineer K-D Lamp Company 1910 Elm Street Cincinnati Ohio 45410; Dear Mr. Tuerck: This responds to your letter asking whether your sample turn signal an hazard switch design complies with the labeling requirements of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*.; By way of background information, I would point out that the agenc does not give advance approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to determine whether its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicle or equipment comply with all applicable standards. The following interpretation only represents the agency's opinion based on the information provided in your letter.; Your letter states that the switch is used primarily on Class 7 an Class 8 trucks and truck tractors. We therefore assume that it would only be used on trucks with a GVWR of 10,000 pounds or more. We make that assumption because Standard No. 101-80 includes requirements for a vehicle's displays in addition to its controls if it has a GVWR of less than 10,000 pounds. As explained below, it is our opinion that the sample switch does comply with the labeling requirements of Standard No. 101-80.; The sample turn signal and hazard switch is designed to be clamped ont a vehicle's steering column to the left of the driver and looks something like a box. We assume that the box is to be installed so that the side of the box which has two pushbuttons on it, marked 'R' and 'L,' is on the left. Pressing the 'R' pushbutton, which is located toward the back, activates the right turn signal. Pressing the 'L' pushbutton, which is located toward the front, activates the left turn signal. Both buttons must be pushed simultaneously for the hazard warning signal. Most of the identification for the switch is located on top of the box. Just above the right turn pushbutton is a thick black arrow pointing to the right. Just above the left turn pushbutton is a thick black arrow pointing to the left. Above each pushbutton there is also a triangle outlined in black, i.e., the hazard warning symbol specified by Table 1 of Standard No. 101-80. Between those identifications is located a pushbutton, identified by the use of both words and symbols, which clears the turn signal or hazard warning signal. The top of the box also includes three jewel-type pilot indicators which indicate when the turn signals or hazard warning signal are activated and additional labeling explaining the method of operation for the hazard warning signal.; Section S5.2.1 of Standard No. 101-80 states in relevant part: >>>Vehicle controls shall be identified as follows: (a) Except as specified in S5.2.1(b), any hand-operated control liste in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol. Such a control may, in addition, be identified by the word or abbreviation shown in column 2. Any such control for which no symbol is shown in Table 1 shall be identified by the word or abbreviation shown in column 2. Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. The identification shall be placed on or adjacent to the control. The identification shall, under the conditions of S6, be visible to the driver and , except as provided in S5.2.1.1 and S5.2.1.2, appear to the driver perceptually upright.<<<; Both the turn signal and the hazard warning signal are listed in colum 1 of Table 1 and have symbols designated in Column 3. Therefore, Standard No. 101-80 requires that those controls be identified by the designated symbols.; The primary issue raised by your design is whether the turn signa control symbol specified by Table 1, a pair of arrows, may be split where there are independent controls for the left and right turn signals. As explained below, it is our opinion that the pair of arrows may be split in that particular circumstance.; The symbol for the turn signal control is the same as the symbo specified by Table 2 for the turn signal display. A footnote to Table 2 explains that while the pair of arrows is a single symbol, the two arrows will be considered separate symbols when the indicators for the left and right turn operate independently and may be spaced accordingly.; Table 1 does not include that footnote for the turn signal control. turn signal control would normally be expected to consist of one button or lever and would be required to be identified by the pair of arrows as one symbol. It is our interpretation, however, that the two arrows may be considered separate symbols where there are independent controls for the left and right turn signals, as in your sample switch. Separating the two arrows in such an instance has the advantage of indicating the direction of the signal activated by each pushbutton.; Table 2 also includes a footnote that indicates that the framed area of the turn signal display symbol may be filled in. While Table 1 has a footnote that indicates that the framed areas of several symbols may be filled in, the turn signal control is not among those listed. It is our interpretation, however, in light of the footnote in Table 2, that a manufacturer may fill in the framed areas of the turn signal symbol whether it is used for control or a display.; Thus, the symbols used on the sample switch for the turn signa controls are those specified by Standard No. 101-80.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3163OpenMr. W. G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your October 9, 1979, letter relating to the prope classification of school buses on certification labels.; Your letter is accurate in that school buses may be designated a 'school buses' on their certification labels. The agency thinks that for the purpose of clarity the term 'school bus' should be included on the label to further clarify the particular design of the bus. All other buses that comply only with standards applicable to non-school buses must be certified as 'buses'.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3499OpenMr. L.J.A. Mills, G & C Mills Plastics, Inc., 2309 Langdale Avenue, Suite 5, Los Angeles, CA 90041; Mr. L.J.A. Mills G & C Mills Plastics Inc. 2309 Langdale Avenue Suite 5 Los Angeles CA 90041; Dear Mr. Mills: It has come to our attention that your are distributing auxiliary win deflectors for use on motor vehicles which may not be in compliance with Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*. You received a letter from this agency dated July 13, 1979, and a later letter from the Department of Commerce which may have misled you concerning your responsibilities for complying with Standard No. 205.; This matter was brought to our attention by Mr. Paul Hingtgen who tol the agency you had shown him the correspondence referred to above. I am enclosing copies of two letters we sent to Mr. Hingtgen which explain why and how the previous letter to you from this agency was misleading. From those letters, you will see that auxiliary wind deflectors are considered to be pieces of 'motor vehicle equipment' and, as such, they must be made from glazing materials that are in compliance with Standard No. 205. We hope you will ensure that any wind deflectors you sell or distribute are in compliance with the standard, since you could be subject to substantial civil penalties if you fail to do so. I am also enclosing a copy of Standard No. 205.; If after reviewing the enclosed letters you have any questions, pleas contact Mr. Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2322OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, New Jersey 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: This is in response to your February 23, 1976, letter concerning th rim marking requirements of S5.2 of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; In its present form, S5.2 requires a rim to which the standard applie to be marked with its size designation and, if it is a multi-piece rim, its type designation as well. There is no prohibition on the marking of additional information beyond that which is required. Therefore, the marking of single piece rims with a type designation is permitted.; Please note that, in a notice published on Mary 6, 1976 (41 FR 18659 Docket No. 71-19, Notice 4), the National Highway Traffic Safety Administration delayed the effective dates of several of the standard's requirements. In particular, the effective date of S5.2, *Rim Marking*, was delayed until August 1, 1977. A copy of this notice is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant 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.