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: aiam0190OpenMr. J. C. Eckhold, Automotive Safety Director, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold Automotive Safety Director Ford Motor Company The American Road Dearborn MI 48121; >>>Re: Consumer Information<<< Dear Mr. Eckhold: This is in response to your telegram of December 15 concerning th submission of consumer information on passenger cars produced by your associated company in England. You stated, 'This data will be submitted to the Bureau thirty (30) or more days in advance of any of these cars being offered for sale in the United States as required by section 375.6 as published on October 22, 1969.'; The regulation (49 CFR S 375.6(b))requires information to be mad available to prospective purchasers, on or after January 1, 1970, on 'each of the vehicles offered for sale' at the dealer showroom. The general applicability of the information is to vehicles manufactured on or after January 1, 1970. The intent of the regulation is to provide prospective vehicle buyers with information on all the various types of vehicles currently being manufactured and available for purchase after that date.; You apparently are assuming that, within the meaning of the regulation no vehicles are 'offered for sale' to prospective purchasers except those that are physically present in the dealer showroom. This certainly does not reflect the practice of most manufacturers, whose dealers, while keeping a representative stock of vehicles on hand, offer for sale (and enter into contracts for sale of) the manufacturer's complete line of vehicles. This interpretation would, furthermore, tend to defeat the main reason for providing information to prospective purchasers, since a dealer would never be obligated to provide information on vehicles other than those that happened to be in his possession at a given moment.; We advise you, therefore, that the term 'vehicles offered for sale' i the prospective purchaser requirement, 49 CFR S 375.6(b), refers to all the types of vehicles that a manufacturer represents, or the dealer represents with the permission of the manufacturer, as being available for purchase by the general public at a particular dealer location. The regulation requires that consumer information be provided to prospective purchasers on each of there (sic) vehicles on or after January 1, 1970, and to the Administrator 30 days in advance of its availability to prospective purchasers.; Sincerely, Lawrence R. Schneider, Acting Assistant Chief Counsel fo Regulations; |
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ID: aiam5392OpenMr. Dan Neaga and Ms. Dianna Sabo Johnson Controls, Inc. 49200 Halyard Dr. P.O. Box 8010 Plymouth, MI 48170; Mr. Dan Neaga and Ms. Dianna Sabo Johnson Controls Inc. 49200 Halyard Dr. P.O. Box 8010 Plymouth MI 48170; Dear Mr. Neaga and Ms. Sabo: This responds to your letter asking abou a requirement of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, 'Child Restraint Systems,' for built- in child restraints that use 'the same seat back surface as the adult occupant.' I apologize for the delay in responding. Before I begin, I would like to reference a May 26, 1994 telephone call to you from Ms. Deirdre Fujita of my staff, about your letter's statement that the information you sent us is confidential. Ms. Fujita explained that letters requesting interpretations of our FMVSSs are public information, but suggested that we could return your sketches to you and make publicly available only your cover letter. You agreed this would satisfy your concerns about not disclosing your design concepts. Accordingly, Ms. Fujita has mailed your sketches to you. By way of background, the National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment or pass on the compliance of a vehicle or item of equipment outside the context of an actual enforcement proceeding. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the facts set forth in your letter. You ask if your understanding is correct that 'lateral support of the side of the child's torso is not required by FMVSS 213.' The answer is yes. The torso impact protection requirement of S5.2.2.1(b) of Standard 213 specifies requirements for ' e ach system surface provided for support of the side of the child's torso' (emphasis added). The preamble for the final rule adopting S5.2.2.1(b) explains: 'The specifications do not require manufacturers to incorporate side supports in their restraints, they only regulate the surfaces that the manufacturer decides to provide so that they distribute crash forces over the child's torso.' 44 FR 72131, 72135, December 13, 1979. Please note that NHTSA determines independently from the manufacturer whether a particular surface is provided for side support. The determination is based on factors such as the design and intended use of the restraint, and the advertising literature for the restraint. Accordingly, a manufacturer cannot avoid complying with S5.2.2.1(b) simply by asserting that a side surface was not provided for side support. However, with regard to a built-in restraint such as yours that uses the same seat back surface as the adult occupant and where 'no lateral support other than the one offered to the adult occupant is provided,' it does not appear that the child restraint incorporates side supports subject to S5.2.2.1(b). If you have any questions, please call Ms. Fujita at (202) 366-2992. Again, my apologies for the delay in responding. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam2457OpenMr. John F. McCuen, Kelsey-Hayes Company, Romulus, Michigan 48174; Mr. John F. McCuen Kelsey-Hayes Company Romulus Michigan 48174; Dear Mr. McCuen: This responds to Kelsey-Hayes' April 21, 1976, question whether moto vehicle rims that are labeled in conformity with the requirements of Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars, May be installed on passenger cars.; The requirements of S5.2 of Standard No. 120 for labeling of rims fo use on multipurpose passenger vehicles, trucks, busses, trailers, and motorcycles do not affect the use of those rims on passenger cars. This situation would change if Standard No. 110, *Tire Selection and Rims*, is modified in the future to prohibit one or more of the items required by S5.2, but such an eventuality is considered to be unlikely.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4429OpenMr. Paul Utans Vice President, Governmental Affairs Subaru of America Subaru Plaza P.O. Box 6000 Cherry Hill, NJ 08034-6000; Mr. Paul Utans Vice President Governmental Affairs Subaru of America Subaru Plaza P.O. Box 6000 Cherry Hill NJ 08034-6000; "Dear Mr. Utans: This responds to your request for an interpretation o Standard No. 210, Seat Belt Assembly Anchorages (49 CFR /571.210). Specifically, you stated that Subaru would like to offer lap/shoulder belts at the rear outboard seating positions on mid-1989 model year station wagons sold in the United States. Standard No. 210 requires these station wagons to be equipped with an anchorage for the upper end of the upper torso portion of a lap/shoulder belt assembly at each forward-facing outboard seating position (S4.1.1) and requires such anchorages to be located within a specified range (S4.3.2). You stated that the subject station wagons would have such an anchorage located in the specified area. However, the upper torso portion of the lap/shoulder belt assemblies would not be attached to the required anchorages in the subject vehicles. Instead, Subaru would provide another anchorage outside of the range specified in Standard No. 210, and the upper torso portion of the rear seat lap/shoulder belt assemblies would be attached to these additional anchorages. You stated your belief that, since Standard No. 208, Occupant Crash Protection (49 CFR /571.208) does not require manufacturers to install lap/shoulder belts in rear seating positions of passenger cars, Subaru's voluntary installation of rear seat lap/shoulder belts and additional anchorages for those belts is not subject to any of this agency's regulations, provided that the voluntarily installed items do not impair the functioning of any devices or elements of design required to be installed in the vehicles. Your belief is correct. The anchorage location requirements in Standard No. 210 apply to all anchorages required by the safety standards, except for those anchorages explicitly exempted by S4.3 of Standard No. 210 (anchorages for automatic and dynamically tested manual belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208). The question then becomes whether the upper anchorage to which the rear seat shoulder belts will actually be attached in these vehicles is required by the safety standards. If that upper anchorage were required by the safety standards, it would have to comply with the location requirements set forth in S4.3.2 of Standard No. 210. However, we conclude that that anchorage is not required by any safety standard. If Standard No. 208 required rear outboard seating positions in passenger cars to be equipped with lap/shoulder belts, it would require that the point at which the upper end of the shoulder belt was actually attached to the vehicles comply with the anchorage strength and location requirements set forth in Standard No. 210. This is because S3 of Standard No. 210 defines a 'seat belt anchorage' as 'the provision for transferring seat belt assembly loads to the vehicle structure.' The point at which the upper end of the shoulder belt is attached to the vehicle is necessarily a part of the 'provision' for transferring belt loads to the vehicle structure. Thus, the attachment point of the upper end of the shoulder belt to the vehicle would have to comply with all applicable requirements of Standard No. 210, if the shoulder belt were required to be provided at that seating position by Standard No. 208. However, Standard No. 208 does not currently require rear outboard seating positions in passenger cars to be equipped with lap/shoulder belts. Instead, section S4.1.2.3.1(c) of Standard No. 208 requires that rear seating positions in passenger cars be equipped with either Type 1 (lap belts) or Type 2 (lap/shoulder belts) belt assemblies. Even though Standard No. 208 does not require lap/shoulder belts to be installed at rear outboard seating positions in passenger cars, section S4.1.1 of Standard No. 210 requires shoulder belt anchorages to be installed for each forward-facing rear outboard seating position in passenger cars. When lap belts only are installed at these seating positions, the shoulder belt anchorage required by S4.1.1 is not, strictly speaking, a provision for transferring shoulder belt loads to the vehicle structure, since there are no shoulder belt loads to transfer to the vehicle structure. Accordingly, the requirement of S4.1.1 was interpreted as meaning that an anchorage point capable of transferring shoulder belt loads to the vehicle structure had to be provided for such seating positions, and that anchorage point had to comply with the applicable requirements of Standard No. 210. According to your letter, your station wagons would be equipped with an anchorage point capable of transferring shoulder belt loads to the vehicle structure, and that point would comply with the anchorage strength and location requirements set forth in Standard No. 210. Accepting this as true, we believe that Subaru could satisfy all the requirements of the safety standards by installing lap belts only at the rear outboard seating positions in these cars. Subaru's decision to install lap/shoulder belts at these seating positions and an additional anchorage point for the shoulder belts is a voluntary choice, not a response to any regulatory requirement. NHTSA has long said that systems or components installed in addition to required safety systems are not required to comply with Federal safety standards, provided that the additional systems or components do not destroy the ability of the required safety systems to comply with the safety standards. In a December 1, 1986 letter to Mr. Francois Louis (copy enclosed), I said that manufacturers are permitted to locate the anchorages for voluntarily-installed lap belts outside of the area specified in Standard No. 210 for lap belts required to be installed by Standard No. 208, provided that the voluntarily installed lap belts do not destroy the ability of the required belt systems to comply with the requirements of the safety standards. The same reasoning would apply in this situation. That is, manufacturers are permitted to locate the anchorage for the upper end of voluntarily installed shoulder belts outside of the area specified in S4.3.2 of Standard No. 210, provided that the voluntarily installed anchorages and shoulder belts do not destroy the ability of the required anchorages and lap belts to comply with the requirements of the safety standards. There is no reason to believe that shoulder belts and the additional anchorages would in any way impair the ability of required equipment to comply with the requirements of the safety standards. You are already aware of the fact that NHTSA has initiated a rulemaking to require rear seat lap/shoulder belts, 52 FR 22818, June 16, 1987. You should note that if the agency adopts a final rule requiring rear seat lap/shoulder belts in passenger cars, the shoulder belts that are the subject of this interpretation would no longer be voluntarily installed. If such a final rule were issued, the point at which the upper end of the shoulder belt is attached to the vehicle would have to comply with both the anchorage location requirements of S4.3.2 of Standard No. 210 and the anchorage strength requirements of S4.2.2 of Standard No. 210, as explained above. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam3616OpenMr. J. L. Campbell, Jr., 12813 95th Avenue, N.E., Kirkland, WA 98033; Mr. J. L. Campbell Jr. 12813 95th Avenue N.E. Kirkland WA 98033; Dear Mr. Campbell: I have recently received a copy of your letter to Senator Gorto concerning the difficulties small manufacturers of motor vehicles have in complying with Federal standards. To alleviate these difficulties, you suggested that blanket exemptions from the bumper regulations and the Federal motor vehicle safety standard on side door strength be granted to all 4-wheel vehicles under 800 pounds dry weight.; As explained more fully below, this agency does not have authority fro Congress to grant an exemption from the bumper standard for the ultra-lightweight vehicles you describe. Such authority would require new legislation. However, we do have authority either to exclude all of those vehicles from the side door strength standard or to exempt particular manufacturers of those vehicles from that standard.; Congress set forth the guidelines under which this agency could issu exemptions from the bumper standards in section 102(c)(1) of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1912(c)(1). Exemptions may be granted only to passenger motor vehicles manufactured for a special use. While neither the Cost Savings Act nor this agency has defined 'special use', the Cost Savings Act is explicit that a vehicle can be exempted only if two conditions are met: (1) the vehicle is manufactured for a special use, (2) compliance with the bumper standard would unreasonably interfere with that use. The example Congress cited for such a vehicle was a Jeep with snow removal equipment on the front. The agency believes that the purpose of an ultra-lightweight passenger vehicle is essentially the same as that of a lightweight vwehicle such as the Toyota Starlet, Honda Civic or Ford Escort, i.e., to carry passengers. The agency does not view that purpose to be a special use within the meaning of section 102. Further, even if the first condition could be met, it is not clear that the second one could be. Hence, an amendment to the Cost Savings Act would have to be made by the Congress before we could grant an exemption from the bumper standard to your ultra-lightweight passenger motor vehicles.; Concerning your request regarding Standard No. 214, side door strength NHTSA formerly excepted motor vehicles (other than trailers and motorcycles) of 1,000 pounds or less curb weight from all safety standards. However, that exception was eliminated in 1973 (38 F.R. 12808, May 16, 1973). At that time, the agency stated that manufacturers seeking relief from compliance problems peculiar to these vehicles could either petition for amendments to individual standards or petition for an exemption under section 123 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410).; These options remain the ones available to manufacturers o ultra-lightweight vehicles. Thus, one option is to submit a petition for rulemaking under 49 CFR Part 552 requesting the agency to amend Standard No. 214 to exclude those vehicles from that standard's applicability provision. I should point out that few, if any, petitions of this type have been submitted since the agency's May 1973 notice and none have been granted. Also, you should be aware that the rulemaking process is often a lengthy one.; The other option is for a manufacturer to submit a petition for th exemption of his vehicles from a particular standard. I have enclosed a copy of 49 CFR Part 555 which sets forth the information that a manufacturer must include in its petition. Exemption petitions are not uncommon and are often granted at least in part. Also, because fewer procedural steps are necessary, the exemption process is typically much faster than the amendment process. Should you wish to submit an exemption petition, you may find useful the enclosed copies of section 123 of the Safety Act and Standard No. 214, *Side Door Strength* (49 CFR S 571.214).; If you need any further assistance or information on either of thes subjects, please do not hesitate to contact me. We try to minimize the regulatory difficulties experienced by small manufacturers to the extent we can do so consistent with our legislative authority.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0939OpenMr. James Tydings, Chief Engineer, Thomas Built Buses, Inc., 1408 Courtesy Road, P. O. Box 1849, High Point, NC 27261; Mr. James Tydings Chief Engineer Thomas Built Buses Inc. 1408 Courtesy Road P. O. Box 1849 High Point NC 27261; Dear Mr. Tydings:#This is in response to your recent inquiries t Berkley Sweet concerning Federal Motor Vehicle Safety Standards Nos. 101 and 108.#You ask whether S4.2.2 of Standard No. 101 applies to push-pull switches. This paragraph requires identification for the extreme positions of any heating and air conditioning system control that regulates a function over a quantitative range, and you state that you currently do not indicate the quantitative range for the heater switches.#S4.2.2 does apply to push-pull switches, and I enclose a notice that the agency published on December 3, 1971, clarifying our intent. A legend such as 'push off' and 'pull high' would be sufficient to meet the requirements of Standard No. 101. You would not have to redesign your switch cabinet to provide a slide or lever-type switch.#You also asked whether the school bus lighting description on your attached pages numbered 34 and 35 is 'legal'. The system as described conforms to the requirements of Standard No. 108 for the items listed.#Sincerely, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam2904OpenMr. Walter J. Kulpa, Yankee Metal Products Corp., Norwalk, CT 06852; Mr. Walter J. Kulpa Yankee Metal Products Corp. Norwalk CT 06852; Dear Mr. Kulpa:#This is in response to your letter of September 18 1978, requesting a clarification of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The National Highway Traffic Safety Administration concurs in your interpretation of S5.3.1 that any hand operated control which is mounted on the steering column does not have to meet the illumination requirements of Column 4 of Table 1.#Sincerely, Joseph J. Levin, Jr., Chief Counsel; |
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ID: aiam1781OpenHonorable William L. Scott, United States Senate, Washington, DC 20510; Honorable William L. Scott United States Senate Washington DC 20510; Dear Senator Scott: This is in response to your letter of January 28, 1975, requestin information concerning correspondence from the Virginia Automobile Dealers Association urging the issuance of a 2.5 mph bumper impact requirement by February 15, 1975.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) published a Federal Register notice proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph. The proposal was based primarily on the results of two agency- conducted studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost-beneficial. The aim of the proposed reduction in the bumper impact requirements is to allow manufacturers to produce lighter bumpers, which NHTSA studies indicate would have a favorable effect on the cost-benefit ratio.; No agreement was made with the motor vehicle industry concerning th proposal. The proposed reduction in the bumper requirements does not constitute a final statement of the NHTSA's position. All comments and data submitted in response to the proposal will be thoroughly considered before any final decision is reached.; Petitions have been received from various motor vehicle manufacturers insurance groups, and members of Congress requesting extensions of the period allowed for the submission of comments to the proposal. Although the motor vehicle manufacturers limited their request for an extension to that portion of the proposal that would not take effect until 1978, sufficient interest has been shown to indicate that more time is needed for the preparation of comments. Therefore, the comment period has been extended until March 3, 1975.; In addition, in order to allow the airing of all views, we have decide that a public hearing would be desirable. The hearing has been scheduled for February 18 and 19, 1975, at which time all interested persons are invited to present their views on the proposed amendment. I cordially invite the Virginia Automobile Dealers Association to attend and present its thoughts on this subject. We feel that the time schedule for the hearing and the comment closing date will permit the presentation of all sides of the questions involved, and enable the agency to make a final decision in time for the motor vehicle manufacturers to act with respect to the 1976 model year.; For your information, I have enclosed a copy of the Federal Registe notice scheduling the public hearing and extending the comment period. Your interest and that of the Virginia Automobile Dealers Association is greatly appreciated.; Sincerely, Barmin |
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ID: aiam4079OpenMr. M. Hayashibara, Managing Director, Certification Business Division, Mazda (North America), Inc., 24402 Sinacola Court, Farmington Hills, MI 48018; Mr. M. Hayashibara Managing Director Certification Business Division Mazda (North America) Inc. 24402 Sinacola Court Farmington Hills MI 48018; Dear Mr. Hayashibara: This responds to your letter seeking an interpretation of certain term used in Standard No. 110, *Tire selection and rims - passenger cars* (49 CFR S571.110). Specifically, you asked about the definitions of the terms 'curb weight', 'accessory weight', and 'production options weight'. These terms are defined in Standard No. 110 as follows.; The 'curb weight' of a vehicle is calculated by adding the weight o the vehicle with all of its standard equipment, including its maximum capacity of fuel, oil, and coolant to the weights of two optional items of equipment, *if the vehicle is equipped with these optional items*. The items whose weight is included in calculating the curb weight, if present on the vehicle, are air conditioning and the additional weight of an optional engine. No other optional items are included in calculating a vehicle's curb weight, even if the vehicle is equipped with such options.; The 'accessory weight' of a vehicle means the combined weight (i excess of the weight of the standard equipment items that may be replaced) of automatic transmission, power steering, power brakes, power windows, power seats, radio, and heater to the extent that these items are available as factory-installed options on that vehicle, *regardless of whether these options are actually present on the vehicle in question*. No other items of optional equipment are included in calculating the accessory weight, even if the vehicle is equipped with such options.; The 'production options weight' means the combined weight of all item of optional equipment that meet all of the following criteria:; (1) The weight of the item of optional equipment is more than fiv pounds greater than the weight of the item of standard equipment that it replaces,; (2) The optional equipment is present on the vehicle in question, and (3) The weight of the optional equipment has not previously bee considered in either the curb weight or the accessory weight.; Section S3 of Standard No. 110 lists the following examples of items o optional equipment whose weight might be considered when calculating the production options weight: heavy duty brakes, ride levelers, roof rack, heavy duty battery, and special trim. However, any item of optional equipment that meets the three criteria listed above *would* be included in calculating the production options weight, even if that item were not listed in the examples. Therefore, Mazda's understanding is correct that the weight of four-wheel drive components, aerodynamic accessories, special body styling panels, and sunroofs *are* included when calculating the production options weight.; If you have any further questions on this subject, or need mor information, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426- 2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0893OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letters of September 25 and October 19, 1972 In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (S 573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the regulations therefore apply to them.; Your letter of October 19 asks whether a person who installs a fift wheel in a pickup truck is considered a 'remanufacturer.' Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22600, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.; Yours truly, richard B. Dyson, Assistant 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.