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: aiam5658OpenJane Thornton Mastrucci, Esq. Thornton, Mastrucci & Sinclair 4699 Ponce de Leon Boulevard Coral Gables, FL 33146-2188; Jane Thornton Mastrucci Esq. Thornton Mastrucci & Sinclair 4699 Ponce de Leon Boulevard Coral Gables FL 33146-2188; "Dear Ms. Mastrucci: This responds to your request for a interpretation as to which passenger vehicles and which multipurpose passenger vehicles (MPVs) meet the Federal Motor Vehicle Safety Standards (FMVSSs). You ask this since Florida law allows transportation of pupils in MPVs that meet 'all federal motor vehicle safety standards for passenger cars.' As explained below, in recent years many of the FMVSSs have been amended to have the same requirements for passenger cars and MPVs. However where differences exist, the only way your client, Dade County School Board, will be able to determine that a specific MPV meets the FMVSSs applicable to passenger cars would be to contact the vehicle's manufacturer. NHTSA is authorized under 49 U.S.C. Chapter 301 Motor Vehicle Safety to issue FMVSSs for new motor vehicles and new items of motor vehicle equipment. The FMVSSs are codified at Title 49 of the Code of Federal Regulations (CFR), Part 571. There are presently 53 FMVSSs. Each FMVSS's applicability section specifies the motor vehicles and/or equipment to which it applies. Under 49 U.S.C. section 30112, a person may not manufacture or sell any motor vehicle unless the vehicle meets all applicable FMVSSs and is so certified. Section 30115 establishes a self-certification system whereby the vehicle manufacturer is responsible for certifying that the vehicle meets the safety requirements in the standards applicable to the vehicle. In the certification, the manufacturer must specify the vehicle type (e.g., passenger car, MPV, truck, bus) of the vehicle. Each vehicle type's definition is found at 49 CFR Part 571.3 Definitions. Thus, a new passenger car sold in the U.S. must be certified by the manufacturer as meeting the FMVSSs applicable to passenger cars, and a new MPV must be certified as meeting the standards applicable to MPVs. In recent years, many FMVSSs have been amended to specify the same requirements for passenger cars and MPVs. For example, for model year 1998 vehicles, Standard No. 208, Occupant crash protection will specify identical requirements for passenger cars and MPVs. For Standard No. 214, Side impact protection, in July 1995, NHTSA issued a final rule in which MPVs manufactured after September 1, 1998 would be required to meet the same dynamic testing requirements as passenger cars. However, some safety standards that apply to both passenger cars and MPVs do not specify identical requirements for each vehicle type. For example, Standard No. 103 Windshield defrosting and defogging systems applies to passenger cars and MPVs, but specifies different requirements for each vehicle type. There is no easy way to determine whether a particular MPV meets the passenger car safety standards. Because of differences in FMVSS requirements for passenger cars and MPVs, for information whether a particular MPV meets the passenger car standards, you should contact the MPV's manufacturer. Please note that for some safety standards such as Standard No. 208, a manufacturer may have phased-in the compliance of its MPVs with the safety standard over several years. Therefore, some MPVs manufactured in a particular year may meet the newer standard but other MPVs may not. For information about whether a specific MPV meets the passenger car standards, the manufacturer should be provided with the MPV's seventeen digit vehicle identification number (VIN), which can be found on the vehicle's certification label on the hinge pillar, the door-latch post, or the door edge that meets the door-latch post, next to the driver's seating position. I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Samuel J. Dubbin Chief Counsel"; |
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ID: aiam2467OpenMr. Byron A. Crampton, Manager of Engineering Services, School Bus Manufacturers Institute, 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services School Bus Manufacturers Institute 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This is in response to your letter of November 2, 1976, in which yo ask for an interpretation of the term 'absorbed' as it is used in Standard No. 222, *School Bus Passenger Seating and Crash Protection*. Further, you request that the NHTSA withdraw its earlier interpretation of the same term made on July 30, 1976, to Thomas Built Buses.; In your letter, you outline data showing that a seat may meet th energy absorbtion requirements of S5.1.3 when recoil energy is included, while failing those same requirements when recoil energy is subtracted from the total energy. You further argue that the NHTSA interpretation of July 30, 1976, which explained the subtraction of recoil energy, is at variance with the wording of the standard, because the standard does not explicitly require the subtraction of recoil energy and speaks only to the application of force upon the seat. Moreover, you suggest that plotting the recoil energy results in insufficient area under the force/deflection curve to meet S5.1.3. For these reasons, you request that the term 'absorbed' be defined as the total energy received by the seat without subtracting energy that is returned through recoil.; The NHTSA declines to adopt the interpretation that you suggest. Th dictionary definition of the term 'absorbed' is 'to receive without recoil.' This definition, when applied to energy absorbed by a seat, contemplates the subtraction of recoil energy in the computation of absorbed energy. The NHTSA intentionally chose the term 'absorbed' to denote exactly this meaning. Therefore, according to the common usage of the term 'absorbed,' the standard does require the subtraction of recoil energy even though those express words are never used.; Your assertion that plotting the recoil energy results in force/deflection curve that falls within the prohibited zones indicates a misunderstanding of the force/deflection zone requirements. The force deflection zone requirements (S5.1.3(a), S5.1.3(b), S5.1.4(a), and S5.1.4(b)) prescribe limits within which the seats must perform only during the force application phase of the test procedure.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5208OpenWayne Ferguson, Research Manager Transportation Research Council Department of Transportation Commonwealth of Virginia Box 8317 University Station Charlottesville, VA 22903; Wayne Ferguson Research Manager Transportation Research Council Department of Transportation Commonwealth of Virginia Box 8317 University Station Charlottesville VA 22903; Dear Mr. Ferguson: Thank you for your letter of April 23, 1993 enclosing a copy of a joint resolution of the Virginia General Assembly to study the use of deceleration lights on trucks in the Commonwealth, with the goal of allowing use of these lamps. The Transportation Research Council has been asked to evaluate potential legal problems regarding state regulation of deceleration lights, especially as they may relate to Federal preemption in the area of vehicle safety equipment. You would like to know whether 'the current federal regulations and standards dealing with various vehicle safety devices pre-empt Virginia's proposal to permit deceleration lights on trucks in the Commonwealth?' If the answer is affirmative, you request advice on 'the proper course of action to obtain federal approval of the use of deceleration lights.' The answer to these questions is dependent upon the preemption provisions of the National Traffic and Motor Vehicle Act (Act) (l5 U.S.C. 1381 et seq.) and the characteristics of any specific warning system. The Act does not permit a State to impose a safety requirement upon a motor vehicle that differs from a Federal motor vehicle safety standard in any area of performance that is covered by the Federal standard (l5 U.S.C. 1392(d)). The applicable Federal standard in this instance is 49 CFR 571.108, Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. We understand that a deceleration warning system is intended to inform a following driver that the vehicle ahead is slowing. Such a system can consist of one or more lamps, red or amber in color, and either flashing or steady-burning in use. Further, such a system can be original motor vehicle equipment or aftermarket equipment. The Federal requirements of Standard No. 108 apply to original equipment in all instances. Two provisions are important with respect to supplementary lighting equipment such as a deceleration warning system. Under S5.5.10(d), unless otherwise provided by S5.5.10, all original motor vehicle lighting equipment, whether or not required by Standard No. 108, must be steady burning in use. It is for this reason that we informed The Flxible Corporation on December 8, 1986, that we had interpreted Standard No. 108 as applying to all lighting equipment on non-emergency vehicles and not just the equipment required by Standard No. 108. Thus, the amber-lamp deceleration warning system that Flxible had been asked to install on transit buses was acceptable to NHTSA in a steady-burning mode but not a flashing one. Similarly, we advised Norman H. Dankert on June 3, 1990, and Bob Abernethy on September 7, 1990, that if a deceleration warning system is one that does not consist of additional lamps but one that operates through the tail or stop lamp system, it must also be steady burning. The second relevant provision is that of S5.1.3, original lighting equipment of a supplementary nature must not impair the effectiveness of the lighting equipment required by the standard. We also informed Flxible that simultaneous use of flashing (amber) and steady-burning (red) lamps have the potential for creating confusion in vehicles to the rear of the bus and impairing the effectiveness of the required stop lamps within the meaning of S5.1.3. On the other hand, the simultaneous use of the Flxible amber and red rear lamps in a steady burning mode would not be precluded by this section. In summary, we conclude that Virginia could permit the use of a red or amber original equipment deceleration warning system operating in a steady burning mode through either original equipment lamps or supplementary ones. A system that is not permissible as original equipment would also not be permissible as an aftermarket system. Although the preemption provisions and the Federal motor vehicle safety standards apply to new motor vehicles and new motor vehicle equipment, the Act also provides, for both new and used vehicles, that no manufacturer, distributor, dealer, or motor vehicle repair business may 'knowingly rendering inoperative, in whole or in part, any device or element of design installed . . . in compliance' with Standard No. 108 or any other Federal safety standard (15 U.S.C. 1397(a)(2)(A)). An action which created an adverse effect upon lamp performance would partially render inoperative the compliance of a vehicle with Standard No. 108. In our view, flashing deceleration lamps would 'render inoperative' the compliant lamps installed by the vehicle manufacturer by potentially confusing following drivers. For this reason, it is our opinion that a manufacturer, distributor, dealer, or motor vehicle repair business that installed a deceleration warning system on a truck in Virginia would be in violation of section 1397(a)(2)(A) if that system consisted of flashing lights, or operated in a flashing mode through lamps that are normally steady burning in use. Since a State may not legitimize conduct that is illegal under Federal law, Virginia could not permit such businesses to install deceleration lamps on vehicles. However, the Act does not prohibit installation of a flashing light system by a person other than a manufacturer, dealer, distributor, or motor vehicle repair business. For this reason, section 1397(a)(2)(A) does not apply to modifications made by owners to their own vehicles. However, we believe that it would be inappropriate for Virginia to encourage such modifications, in view of the potential adverse safety consequences of unexpected flashing lamps. Moreover, because it appears that the many of the vehicles will be operated in interstate commerce, we suggest that you also obtain the views of the Federal Highway Administration (FHWA) to determine whether that agency's regulations affect trucks with deceleration lights. You should direct your inquiry to James E. Scapellato, Director, Office of Motor Carrier Standards, FHWA, Room 3404, 400 7th Street, S.W., Washington, D.C. 20590. You also asked about the proper course of action to obtain Federal approval of the use of deceleration lights. The agency does not 'approve' or 'disapprove' safety systems but will advise, as we do here, whether such systems are permitted or prohibited under Federal law. There appear to be certain types of deceleration warning systems that would not be prohibited under existing Federal law. With respect to systems that would not be allowable under Standard No. 108, these systems could only be permitted if NHTSA were to amend Standard No. 108 through rulemaking. Any person who believes that the standard should be amended may submit a petition for rulemaking. The agency's procedures for petitions for rulemaking are set forth at 49 CFR Part 552. If we can be of further help, our Office of Research and Development may be able to assist you, and I suggest you contact Michael Perel for copies of pertinent research contracts on deceleration warning systems. Mr. Perel may be reached at 202-366-5675. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2037OpenMr. Robert L. Donnelly, Secretary, Armstrong Rubber Company, New Haven, Connecticut 06507; Mr. Robert L. Donnelly Secretary Armstrong Rubber Company New Haven Connecticut 06507; Dear Mr. Donnelly: This responds to your letter of may 30, 1975, concerning the standard applicable to a tire which you manufacture and sell with the designation L78-15LT, Load Range C.; You are mistaken in your assumption that a station wagon is classifie as a multi-purpose passenger vehicle. Because it is constructed neither on a truck chassis nor with special features for occasional off-road operation, a station wagon is a passenger car rather than a multi-purpose passenger vehicle.; If, despite this misunderstanding, the L78-15t tire is question i designated by you as primarily intended for use on lightweight trucks or multi-purpose passenger vehicles, the it is a light truck tire subject to Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*.; Because a station wagon is a passenger car, Standard No. 110 require that its original equipment tires comply with standard No. 109. Standard No. 110 is not applicable to used cars, so there is no prohibition on the use of the L78-15LT tire as replacement equipment on a station wagon. However, because the informational placard on a station wagon would suggest its owner the use of inflation pressures which are dangerously inadequate for light truck tires, we do not wish to encourage the sale of such tires as replacement equipment for use on station wagons.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4049OpenMs. Patricia Hill, 2150 Hacker Road, Howell, MI 48843; Ms. Patricia Hill 2150 Hacker Road Howell MI 48843; Dear Ms. Hill: Thank you for your letter of September 19, 1985, asking about th effect of our regulations on a safety belt design you have seen. You explained that the design uses 'a rigid member to support a webbing guide near the shoulder of a front seat occupant. This rigid member was rigidly attached to the roof of the vehicle.' You asked several questions about this design, which are answered below.; You first asked whether the rigid member would be considered a sea belt anchorage, a piece of attachment hardware or a common component for the purposes of our standards. We cannot provide a definitive answer without having further details about and preferably a drawing of the structure. Based on the information you have provided, it appears that the rigid member would be an anchorage.; Standard No. 210, *Seat Belt Assembly Anchorages*, defines a 'anchorage' as a device that transfers safety belt assembly load to the vehicle structure. Since the rigid member is attached to the roof at one end and to a safety belt webbing guide at the other, it appears to be intended to transfer loads to the vehicle structure. Thus, it would have to meet the strength and location requirements of the standard.; You also asked if one or both ends of the rigid member are required t meet the upper torso restraint location requirements of S4.3.2 of Standard No. 210. If, as discussed above, the rigid member is intended to transfer loads, then it would have to meet the location requirement of S4.3.2. That section states that the 'anchorage for the upper end of the upper torso restraint shall be located within the acceptable range' shown in Figure 1 of the standard. The purpose of the requirement is to specify the angle at which the shoulder belt crosses the occupant's chest. Thus, the portion of the anchorage that controls the angle of the shoulder belt must be within the zone specified in Figure 1.; I hope this information is of assistance to you. If you have an further questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3276OpenMr. F.L. Krall, Manager, Technical legislation, International Harvester Company, 2911 Meyer Road, Fort Wayne, Indiana 46803; Mr. F.L. Krall Manager Technical legislation International Harvester Company 2911 Meyer Road Fort Wayne Indiana 46803; Dear Mr. Krall: This is in response to your letter of April 3, 1980, requestin confirmation of the applicability ofS4.4 of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) solely to light trucks and passenger cars.; Although Standard No. 115 applies to a variety of vehicle types including multipurpose passenger vehicles, the location requirements in S4.4 regarding the placement of the vehicle identification number is of more limited applicability. The section expressly provides that the requirement applies to passenger cars and to trucks with a gross vehicle weight rating (GVWR) of 10,000 pounds or less only. Since Standard No. 115 does not contain any other VIN location requirement, manufacturers of multipurpose passenger vehicles, buses, trailers, incomplete vehicles, and heavy trucks are not limited by that standard in their choice of a VIN location. For definitions of these vehicle types, see 49 CFR 571.3.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4419OpenMr. Robert K. St. Francis, Director, Office of Fleet Management, Delivery Services Department, United States Postal Service, 475 L'Enfant Plaza, SW, Washington, DC 20260-7200; Mr. Robert K. St. Francis Director Office of Fleet Management Delivery Services Department United States Postal Service 475 L'Enfant Plaza SW Washington DC 20260-7200; Dear Mr. St. Francis: This is in reply to your letter of March 26, 1987, regarding deliver vans constructed to Postal Service specifications. You have asked for relief from the requirement that these vehicles be delivered with a license plate lamp because, except in the District of Columbia (DC), the Postal Service is not required to license its vehicles. According to contract specification with the manufacturer of the vehicles, Grumman Allied Industries, Inc., the license plate bracket and lamp assembly are not required, however, the Postal Service has required the wiring and identification of its location for installations for DC service, and for future use after disposal by the Postal Service.; As you know, Federal Motor Vehicle Safety Standard No. 108 *Lamps Reflective Devices, and Associated Equipment* requires motor vehicles to be manufactured with license plate lamps meeting the requirements of SAE Standard J587 OCT81; License Plate Lamps (Rear Registration Plate Lamps)*. Paragraph 2 o SAE J587 defines a license plate lamp as 'a lamp used to illuminate the license plate on the rear of a vehicle.' If a manufacturer knows that the vehicle, as sold it its first purchaser, will not be required to bear a rear registration plate, then it may produce the vehicle without a license plate lamp, and this omission will not constitute a failure to comply with Standard No. 108.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2934OpenMr. Richard D. Phillips, Attorney at Law, P.O. Box 66, Ludowici, GA 31316; Mr. Richard D. Phillips Attorney at Law P.O. Box 66 Ludowici GA 31316; Dear Mr. Phillips: This responds to your December 15, 1978, questions about the status o school buses subject to recall for antilock malfunction now that the 'no lockup' requirement of Standard No. 121, *Air Brake Systems*, has been invalidated in the cases of trucks and trailers. You also ask whether the antilock systems in question must be reconnected, whether the vehicles would thereby be made more or less safe, and what the effect of continued disconnection might be on liability considerations.; I have enclosed the agency's official interpretation of the effect o the invalidation on the operational status of vehicles equipped with antilock. In the case of vehicles subject to recall, we stated that section 154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1414) mandates an 'adequate repair,' and that, in the NHTSA's view, the benefits of 'no lockup' performance mandate the offer of repair and reconnection.; The letter also states that disconnection, consistent with regulation of other authorities and the instructions of the manufacturer, would not violate the Vehicle Safety Act. While the NHTSA finds that the repair would provide desirable 'no lockup' performance, we are unable to counsel you on the Long County Board of Education's liability if the system were not reconnected.; Sincerely, Joseph J. levin, Jr., Chief Counsel |
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ID: aiam0909OpenMr. David J. Humphreys, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; Mr. David J. Humphreys Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: Your letters of September 8 and October 16, 1972, raise a questio concerning the applicability of S4.3 of Standard 207 to certain folding seats in recreational vehicles. Your position is that the typical dinette seat that folds down to form a bed is 'a seat having a back that is adjustable only for the comfort of its occupants' and is therefore excepted from the restraining device requirement of S4.3.; In a letter that we sent to Auto Top, Inc. on September 8, 1972, w distinguished between excepted seats and non-excepted seats on the basis of the degrees of arc through which the back could be adjusted,(sic) A back adjusting only a few degrees would be excepted under this interpretation, while a seat that folded flat to make a bed would not be excepted and would therefore have to have a restraining device. After reconsidering the background of these exceptions, we have decided to modify that interpretation. Although there is likely to be a difference between these seats in the degree of protection they give the occupant, we cannot find that this difference was reflected in the drafting of the S4.3 exceptions.; The S4.3 exceptions were created by a notice of rulemaking publishe April 4, 1967 (32 F.R. 5498). The exception in issue here was adopted in response to a petition by the Rover Company, who requested special treatment for a seat with a back that had a range of adjustment from 77 degrees to the horizontal down to 19 degrees to the horizontal. In granting an exception to the type of seat depicted by Rover, the agency therefore included seats with backs that folded until they were substantially horizontal. We must thus conclude that a seat whose back folds backward with respect to the seat cushion to form a bed is not required under S4.3 to have a device to restrain the backward folding of the seat back.; However, the exemption granted in response to the Rover petition doe not cover the case you have described. A seat having a back that folds for the occupant's comfort but that also folds in another manner is required to have a restraining device for the second folding mode. The usual example of such a seat is a front seat in a two-door sedan that folds forward for entry to the rear and has a back that adjusts through a rearward arc for the occupant's comfort. Such a seat must have a restraining device to prevent forward movement because the adjustment of the back is not 'only' for the occupant's comfort. A dinette seat that has an additional folding or hinging mode must therefore have a restraining device to guard against the effects of the seat's folding in this mode during a crash. For example, a seat whose base is hinged to move the bottom cushion into the space between the dinette seats must be restrained by a device conforming to S4.3.; With specific reference to the type of seat shown in the attachments t your letters, the downward motion of the seat back would be exempt under S4.3, but the motion of the bottom cushion is such that it would have to have a restraining device conforming to S4.3.; As you describe the seat, a restraining device is provided. However without subjecting it to a compliance test under S4.3.2 we are unable to say whether it conforms to S4.3.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3626OpenMr. F. Michael Petler, Head, Administration, Government Relations Department, Suzuki Motor Co., Ltd., P.O. Box 1100, Brea, CA 92621; Mr. F. Michael Petler Head Administration Government Relations Department Suzuki Motor Co. Ltd. P.O. Box 1100 Brea CA 92621; Dear Mr. Petler: This responds to your October 27, 1982, letter asking for permission t place the certification labels for certain motorcycles produced by Suzuki Motor Co. in locations not previously permitted by Part 567, *Certification*.; You request alternative locations, because some motorcycles ar equipped with fairings as standard equipment. These fairings would obscure the certification labels if the labels were to be installed in their required location. You propose, as an alternative, the installation of the labels on the down tubes in front of the engine on either the right or left side. In consideration of the problems of installing the certification labels in their normal positions on vehicles equipped with fairings and since the agency desires that these labels be easily readable, we grant your request to install your labels in these limited instances in the alternative locations that you suggested.; Sincerely, Frank Berndt, 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.