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 |
|---|---|
ID: aiam3447OpenMr. Thomas D. Turner, Blue Bird Body Company, Manager, Engineering Services, P. O. Box 937, Fort Valley, GA 31030; Mr. Thomas D. Turner Blue Bird Body Company Manager Engineering Services P. O. Box 937 Fort Valley GA 31030; Dear Mr. Turner: This responds to your July 13, 1981, letter asking whether the joint in your school buses that fall within the rear cargo compartment or rear engine compartment must comply with Standard No. 221, *School Bus Body Joint Strength*.; Standard No. 221 applies to joints that connect body panels to bod components. Body panels are defined to include those components that enclose the bus' occupant space. The agency has stated in the past that those portions of a bus falling below the floor level would not be considered as having a function in enclosing occupant space, and accordingly, joints in those area would not be required to comply with the standard's requirements.; Applying the standard to the joints that you question, it appears tha they would not be required to comply with the standard. The agency would consider the walls separating the cargo area or the engine from the remainder of the occupant compartment to be a continuation of the bus floor. Accordingly, joints falling behind and below those walls would not be required to comply with the standard. We do note, however, that the joints along the walls themselves must comply with the standard, since the wall panels enclose the occupant space and provide the separation of the engine or cargo area from the occupant space.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam4382OpenMr. K. Shimamura, Executive Vice President and General Manager, Mazda (North America), Inc., Research & Development Center 1203 Woodbridge Avenue, Ann Arbor, MI 48105; Mr. K. Shimamura Executive Vice President and General Manager Mazda (North America) Inc. Research & Development Center 1203 Woodbridge Avenue Ann Arbor MI 48105; Dear Mr. Shimamura: This responds to your letter requesting an interpretation of Standar No. 101, *Controls and Displays*. You described a proposed integrated steering column/dashboard display and asked whether controls mounted on such a unit must be illuminated. As discussed below, the answer to your question is no.; By way of background information, the National Highway Traffic Safet Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.; Section S5.3.1 of Standard No. 101 states that '(e)xcept fo foot-operated controls or hand-operated controls mounted upon the floor, floor console, or steering column, or in the windshield area, the identification required by S5.2.1 or S5.2.2 of any control . . . shall be illuminated . . . .'; The primary issue raised by your letter is whether the controls mounte on your proposed steering column/dashboard display come within section S5.3.1's exception for controls mounted upon the steering column and therefore need not be illuminated. You described your proposed design as follows:; >>>'. . . In addition to the usual plastic trim molding that currentl enclosed the steering column between the instrument panel and the actual steering wheel, the new design adds an integrated upper section accommodating the vehicle's gauges and displays (such as speedometer and tachometer). The upper section is completely integrated into the lower, usual column trim molding and the unit is a single molded part.; 'Several controls are to be placed on the upper section. The tur signal and automatic speed control are to be mounted on the front face. The master lighting switch and wiping system controls will be positioned on either side of the upper section. The hazard warning control will be at the base on the upper section and on top of the lower column. . . .'<<<; A drawing enclosed with a subsequent letter indicates that the uppe section described above is mounted by brackets onto the energy absorbing shaft, below the steering wheel and above the pivot used to adjust the steering wheel. Thus, as the steering wheel is adjusted, the upper section is also adjusted, maintaining the same relative position to the steering wheel.; You suggest that the proposed integrated unit can be considered to be 'steering column,' citing the definition of that term used in Standard No. 204. We note that Standard No. 204's definition of 'steering column' does not apply to Standard No. 101. Moreover, the upper section itself need not be considered a steering column in order to come within Standard No. 101's exception. IN a Federal Register notice published on May 4, 1971, NHTSA stated the following about similar language in an earlier version of Standard No. 101:; >>>Ford has asked whether steering-wheel- mounted controls are exemp from illumination requirements. Since the steering wheel itself is mounted on the steering column, the exemption from the illumination requirements for steering column-mounted controls extends to those mounted on the steering wheel as well. 36 FR 8297, Mary 4, 1971.<<<; Since the upper section in your proposed design is, at the least mounted on the steering column, the exemption from the illumination requirements for steering column-mounted controls extends to those mounted on the upper section as well. Therefore, controls mounted on the upper section need not be illuminated. We note that it is unnecessary for us to reach a determination of whether the upper section can be considered to be a steering column for purposes of Standard No. 101.; Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam4697OpenRichard A. Kulics, Esq. 401 S. Woodward - Suite 370 Birmingham, MI 48009; Richard A. Kulics Esq. 401 S. Woodward - Suite 370 Birmingham MI 48009; "Dear Mr. Kulics: This is in reply to your letter of December 5, l989 to the attention of Taylor Vinson of this Office, on behalf of your clients Liphardt Associates and Pierre Enterprises, Inc. You have informed us that Liphardt is an Independent Commercial Importer (ICI) under EPA regulations. The vehicles it imports are modified by Pierre. Both entities have the identical mailing address. This location is within a Foreign Trade Zone. You have also informed us that Liphardt/Pierre (L/Pe) will apply for status as a Registered Importer under 49 CFR Part 592. It is the practice of L/PE to transport its nonconforming vehicles directly from the vessel into the Zone, to perform conformance modifications in the Zone, and then file a consumption entry, post bond, and submit conformance documentation to DOT. After DOT and EPA have released the vehicle, it is delivered to its owner. You have requested that L/Pe 'be allowed to submit conformity packets to your agency prior to the submission of the consumption entry package, i.e., upon submission of the FTZ entry transportation of the vehicle into the Zone , so that it may enter the vehicle as 'conforming.'' Under this plan, the current method of operation would remain much the same, except that L/Pe would prepare an HS-7 Declaration Form at the time the vehicle is transported into the Zone. This Form would be submitted to DOT along with a conformity package, for review and release, if appropriate. Then, when the actual consumption entry is filed, the vehicle would be entered as 'conforming' merchandise. The purpose of this request 'is to eliminate the costs associated with posting a special bond purely for DOT purposes', and to speed 'up the process of importation, thus reducing the costs associated with storage.' As you state, 'What L/Pe proposes is that it be allowed to close out the obligation while the vehicle is still in the custody of the Customs Service.' In substantiation of your request, you have called our attention to certain provisions of l9 CFR Part l46 Foreign Trade Zones, specifically section 146.2 outlining the obligations of Customs' supervision, section 146.10 providing for examination of merchandise necessary to facilitate the proper administration of any law that Customs is authorized to enforce, and section 146.31 stating that admission of merchandise into a Zone is subject to the regulations of the Federal agency concerned. Under the facts as stated in your letter, we have concluded that your clients must provide a DOT bond under the National Traffic and Motor Vehicle Safety Act of l966 (l5 U.S.C. 1381 et seq.), as amended by the Imported Vehicle Safety Compliance Act of l988 (P. L. 100-562), but that there is no legal reason why its obligations to DOT may not be satisfied before the conformed vehicle enters the customs territory of the United States. As we understand it, the Foreign Trade Zone Act of l934 (l9 U.S.C. 81a et seq.) is intended to establish areas into which merchandise may be imported temporarily, 'without being subject to the customs laws of the United States', before being sent 'into customs territory of the United States' (section 81c(a)). A Zone therefore is a legal fiction established solely for the administration of customs laws. Section 2(a) of the l988 Act repealed the authority of the Customs Service over the importation of vehicles subject to the l966 Act. Accordingly, the new regulation governing the importation of nonconforming motor vehicles on and after January 31, l990, 49 CFR Part 591, is not a 'customs law' (unlike the existing regulation which is a joint regulation with DOT that specifically applies to importation into the customs territory of the United States (19 CFR 12.80(b)). In pertinent part, section 108(a)(1)(A) of the l966 Act (l5 U.S.C. 1397(a)(10(A)) prohibits the importation 'into the United States' of nonconforming vehicles. Although a Zone is not generally considered customs territory, in this instance they are both within the United States, and an arrangement which defines the 'United States' as comprising both customs territory and foreign trade zones has been upheld as valid (Klockner, Inc., v. United States (1984) 8 CIT 3, 590 F. Supp. 1266). Under section 108(c)(1) of the l966 Act, as amended (l5 U.S.C. 1397(c)(1)), a nonconforming vehicle 'shall be refused entry into the United States' unless 'an appropriate bond' has been furnished to ensure that the vehicle will be brought into conformity within a reasonable time after such importation.' Therefore, because 49 CFR Part 591 is not a 'customs law', any distinction between a Zone and customs territory is legally irrelevant for purposes of the l966 Act. Further, because both a Zone and the customs territory are physically within the boundaries of the United States, an importation of a nonconforming vehicle into either a Zone or the customs territory requires an accompanying DOT conformance bond. Nevertheless, the l988 Act does not impose any restrictions upon either DOT or your clients that prohibits them from entering conformed vehicles into customs territory. However, we see the procedure a bit differently than the one you discussed. The HS-7 Form and its accompanying bond must be completed not later than the admission of the vehicle into the Zone. Customs retains its role of sending these documents to DOT. When conformance work is completed, L/Pe provides certification to DOT. Because of the current low volume of nonconforming imports, we anticipate that our review will be completed within two weeks of receipt of the certification. If the certification is acceptable, the bond is released, and L/Pe may then enter the vehicle as no longer subject to DOT conformance regulations (or, as you express it, 'conforming merchandise'). Thus, L/Pe will be able to close out its obligation while the vehicle remains in the custody of Customs, even though it is not freed from the bond requirement. As a final comment on the time factor, we intend to require complete documentation only for the initial make, model, and model year (assuming that the initial submission is acceptable). Although L/Pe must keep verification records on each vehicle it conforms, certifications subsequent to an initial submission need not be accompanied by documents, and could be transmitted by FAX. As we see it, these simple certifications would not require extensive review, improving our ability to respond in a more timely manner. Sincerely, Stephen P. Wood Acting Chief Counsel /"; |
|
ID: aiam3152OpenMr. Hisakazu Murakami, Nissan Motor Co., Ltd., Suite 707, 1919 Pennsylvania Avenue, N.W., P.O. Box 57105, Washington, D.C. 20037; Mr. Hisakazu Murakami Nissan Motor Co. Ltd. Suite 707 1919 Pennsylvania Avenue N.W. P.O. Box 57105 Washington D.C. 20037; Dear Mr. Murakami: This is in confirmation of the discussion with Mr. Schwartz of m office when you met with him on September 10, 1979, as well as further confirmation of the telephone conversation between you and Mr. Schwartz in response to the letter from Mr. Maeda of your company dated February 9, 1979. As you may remember, the questions raised in this letter were substantially answered in the Agency's response of February 13, 1979, to a previous letter from your firm. In addition, I have enclosed a copy of the Agency's letter of Volvo on the same subject as requested.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification Number) States that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree of commonality in construction, such as body, Chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line', denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; Your particular concern relates to the division of a particular Datsu model into several series based on the amount and type of optional equipment with which it is sold.; Based on the facts presented, it is apparent that Datsun models wit different optional equipment packages could each be designated a 'series' if Nissan desired. Nonetheless, the definition of 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If the differences between the potential series are superficial and a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality, the agency will not require such a designation.; Examples of series include Chrysler Plymouth Fury I, Fury II and Fur III.; You also wish to know which types of restraint systems need to b distinguished within the VIN. Active belts, passive belts, and air bags must each be separately designated. Please note that if all the vehicles of a particular model utilize one restraint system type, that type must be reported to the Agency, but need not be directly encoded in the VIN itself.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam1495OpenMr. D. L. Massy, Chief Engineer, American Snowblast Corporation, 4695 Ironton Street, Denver, CO 80239; Mr. D. L. Massy Chief Engineer American Snowblast Corporation 4695 Ironton Street Denver CO 80239; Dear Mr. Massy: In response to your May 13, 1974, question whether Standard No. 121 *Air brake systems*, has been delayed one year for vehicles which have 'drive on the front axle and front axle load of 18,000 pounds or more,' I would like to summarize our recent amendment of the standard.; On May 14, 1974, we delayed the effective date of the standard for al trucks and buses until March 1, 1975. Thereafter, trucks manufactured before September 1, 1975, that have a front steerable axle with a GAWR of 16,000 pounds or more, or a front steerable drive axle, need not meet certain stopping distance requirements if their brakes meet the retardation formula and values found elsewhere in the standard. These vehicles must still stay in the 12-foot lane and, during service brake stops, their wheels must not lock-up except for antilock-controlled lock-up. After September 1, 1975, the standard applies in full to this category of trucks.; There have been several additional changes in the standard which woul affect your products. They were published May 17, 1974, in the *Federal Register* (39 FR 17750).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3502OpenJerry Manzagol, Director, New Mexico Transportation Department, Motor Vehicle Division, Manuel Lujan Senior Building, Santa Fe, NM 87503; Jerry Manzagol Director New Mexico Transportation Department Motor Vehicle Division Manuel Lujan Senior Building Santa Fe NM 87503; Dear Mr. Manzagol: This is in response to your letter of October 13, 1981, requesting th approval of the New Mexico odometer disclosure form for use in lieu of the Federal odometer disclosure form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the state must obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the *Federal Register* notice of August 1, 1977, which amended the disclosure regulations, we gave examples of shortened forms that would be acceptable. A state document can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The agency has reviewed New Mexico's proposed odometer disclosur statement and has determined that it cannot be substituted for the Federal disclosure statement. New Mexico's proposed statement contains four alternate certifications concerning the accuracy of the mileage from which the seller must select the appropriate certification. The third alternate certification requires the seller to certify that the odometer reading is the mileage since the odometer was reset and to disclose the mileage before the odometer was reset. This certification permits conduct that violates the Federal odometer law.; The Motor Vehicle Information and Cost Savings Act ('Act') prohibit resetting the odometer with the intent to change the miles except as provided by the Act, 15 U.S.C. 1984, 1985. The Act permits resetting the odometer during the lawful repair or replacement of the odometer but specifically requires that the odometer reading be reset to either the mileage before repair or replacement or to zero. The third alternate certification suggests that the odometer can be rest to any reading and for other than repair purposes. Since such conduct violate the Act, the certification should be rephrased to permit resetting the odometer reading only in accordance with the repair and replacement provisions of the Act.; In addition, the New Mexico form does not provide for the signature o the transferee as required by the regulations. 49 CFR 580.4(e). The transferee's signature substantiates that the buyer has seen the odometer disclosure statement and is aware of the mileage that the vehicle has been driven and, therefore, must be included on the state odometer disclosure statement.; If the third alternate certification is rephrased to comport with th repair and replacement provisions of the Act and the transferee's signature is added, New Mexico's disclosure statement can be substituted for use in lieu of the Federal form. However, if New Mexico adopts language in its disclosure statement that varies from that contained in the August 1, 1977, *Federal Register* notice, please submit the disclosure statement to the agency for approval.; Sincerely, David W. Allen, Assistant Chief Counsel |
|
ID: aiam2743OpenJestyn G. Payne, Rhoda, Stoudt, & Bradley, P.O. Box 877, Reading, PA 19603; Jestyn G. Payne Rhoda Stoudt & Bradley P.O. Box 877 Reading PA 19603; Dear Mr. Payne: This is in response to your letter of December 23, 1977, requestin clarification as to whether the modified Odometer Disclosure Form which you prepared would meet the Federal requirements. Specifically, you are requesting permission to inform the buyer of the vehicle that the mileage is unknown because the vehicle was subject to a commercial lease. It has been the position of the National Highway Traffic Safety Administration that if the seller does not know that the mileage indicated is wrong, he should not state that the mileage is unknown. More than mere lack of knowledge is necessary to check the mileage unknown box. The seller is not, however, precluded from adding a statement that the vehicle was subject to a commercial lease or otherwise outside of his control.; It appears from the form which you submitted that you are modifying th disclosure statement which is no longer to be used. The form was substantially changed, with those amendments to be effective as of January 1, 1978. For your information, I have enclosed a copy of the Federal Register notice of the amendments. Your client must certify to the accuracy of the odometer to the best of his or her knowledge under the amendments, however, as I stated before, he or she is free to add additional statements explaining the vehicle's history.; Sincerely, John Womack, Assistant Chief Counsel |
|
ID: aiam5086OpenLawrence A. Beyer, Esq. 674 Lake Road Webster, N.Y. 14580; Lawrence A. Beyer Esq. 674 Lake Road Webster N.Y. 14580; "Dear Mr. Beyer: This responds to your FAX of September 22, 1992, t Taylor Vinson of this Office with reference to your request to become a Registered Importer ('RI'). We interpret your letter as seeking an opinion on your eligibility to submit an application to become an RI under 49 CFR 592. Because of your representation of RIs, you are familiar with the record keeping mechanisms and other regulatory requirements of this agency. Your intent is to perform modifications on those Canadian vehicles which require only minor modifications, and you have a 3-car garage, tools including pneumatics, and storage space. You would have in your employ several people qualified to perform the modifications required. You are aware that, in promulgating Part 592, NHTSA specificaly rejected a proposal to allow RIs to designate agents to perform conformance work, thus you would not accept vehicles requiring major modifications, but would refer those to the other RIs. Section 592.5 sets forth the requirements for registration as an RI. According to paragraph 592.5(a), 'any person' may file an application. An application must contain the information specified by the subparagraphs of paragraph (a). We note no restrictions upon who is eligible to apply for RI status. We therefore see no legal impediment to your submitting an application under section 592.5. The Office of Vehicle Safety Compliance (OVSC) has the authority to grant or deny applications for RI status. Your application must, therefore, contain arguments sufficient to convince OVSC of your ability to perform the limited modifications that you contemplate. We advise you, therefore, to set out with specificity in your application the Federal motor vehicle safety standards for which you have the capability to conform vehicles, and the standards for which you have not. We would like to make clear that, in the event a vehicle requires major modifications, our regulations would not allow you to bring the vehicle into partial conformance before transfering the vehicle to another RI for to complete the conformance process. An RI must certify the conformance work to NHTSA, and paragraph 592.6(e) requires the RI's certification to state that 'it is the person legally responsible for bringing the vehicle into conformity.' We interpret that as meaning that the certifier itself performed all the conformance work and did not resort to an agent. Sincerely, Paul Jackson Rice Chief Counsel"; |
|
ID: aiam3851OpenMr. David A. White, Senior Safety Engineer, Grumman Olson, 70180 Centerville Road, Sturgis, MI 49091; Mr. David A. White Senior Safety Engineer Grumman Olson 70180 Centerville Road Sturgis MI 49091; Dear Mr. White: This responds to your letter of May 3, 1984, asking about Standard No 101, *Controls and Displays*. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listed in that table. You asked whether the symbols are required to be illuminated or whether it is permissible instead to illuminate the identifying words without illuminating the symbols. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.; By way of background information, I would note that the Nationa Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.; Section S5.2.1 of Standard No. 101 generally requires that 'an hand-operated control listed in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol.' The section states further that '(s)uch a control may, in addition, be identified by the word heating fan, windshield wiper and washer, and defroster system, all are listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.; Section S5.3.1 of Standard No. 101 states: >>>Except for foot-operated controls or hand-operated controls mounte upon the floor, floor console, or steering column, or in the windshield header area, the *identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield....(Emphasis added.)<<<; As discussed above, the identification required by section S5.2.1 fo the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word 'yes' in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated. It is thus not permissible to illuminate the identifying words without also illuminating the symbols.; I would note that your letter does not provide sufficient informatio to determine whether the controls in your proposed design could come within any of Standard No. 101's exceptions to the illumination requirements.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam0284OpenMr. William R. Graham, Bus and Truck Supply Co., 315 Continental Avenue, Dallas, TX 75207; Mr. William R. Graham Bus and Truck Supply Co. 315 Continental Avenue Dallas TX 75207; Dear Mr. Graham: This is in reply to your letter of December 30, 1970, requesting a interpretation of Motor Vehicle Safety Standard No. 205, 'Glazing Materials,' as it applies to the forward-facing window above the windshield of a particular bus, a picture of which you enclosed.; Because the window in question is a forward-facing window, we canno conclude that it is an 'opening in the roof' under the standard. We apologize for the inconvenience caused by any implication to the contrary that you may have been given on your visit here.; Based upon the picture submitted, and your statement that the windo 'is not adjacent to passenger seating,' we conclude that this location is one that is not specifically designated by the standard. As such, the use of AS2 glazing, which you indicated you plan to use, or alternatively AS1, AS3, AS10, or AS11 glazing, would be appropriate.; If you have further questions, we will be happy to answer them for you. Sincerely, Rodolfo A. Diaz, Acting Associate Administrator, Moto Vehicle Programs; |
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.