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: aiam3578OpenRegal Tire Corporation, 4309 County Line Road, Chalfont, PA 18914; Regal Tire Corporation 4309 County Line Road Chalfont PA 18914; Dear Sir: At the request of the office of the Honorable Peter Peyser, M.C., w are writing this letter to you to explain the significance of certain items of information molded on the sidewall of new tires.; Part 574, *Tire identification and recordkeeping* (49 CFR 574) requires that each new tire to be sold in the United States have a serial number molded on one of its sidewalls. That number identifies the tire's manufacturer, date of manufacture, and size. This information is designed to ensure the proper identification of all tires subject to a recall by the manufacturer for correction of a safety-related defect or of a failure to comply with a safety standard. The serial number is not a guarantee of quality or of compliance with any safety standard.; Each new tire is also required by Federal Motor Vehicle Safet Standards Nos. 109, *New pneumatic tires*, and 119, *New pneumatic tires for vehicles other than passenger cars* (49 CFR 571.109 and 571.119), to have the symbol 'DOT' appear on one of its sidewalls. This symbol is a certification by the tire's manufacturer that the tire fully complies with all requirements of the applicable safety standard. The symbol does not guarantee the quality of a tire in areas of performance unregulated by the safety standards.; Neither the serial number nor the DOT symbol constitute representation that a tire is free from any safety- related defect.; If you have any questions regarding these matters, please contact me. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4747OpenMr. Raymond D. Strakosch President Safety Premiums 87 Broadway P. O. Box 1031 Newburgh, NY 12550; Mr. Raymond D. Strakosch President Safety Premiums 87 Broadway P. O. Box 1031 Newburgh NY 12550; "Dear Mr. Strakosch: Thank you for your letter to John Messera, of ou Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 125, Warning Devices (49 CFR 571.125). You indicated that you have for many years produced and sold a 'Signal Glo Car Door Mirror Clip On,' which you described as a 'dangling safety tag which attaches to the car mirror to alert passersby of emergency needs.' These warning devices are made of a reflective plastic material designed with a clip attachment, and come in eight different shapes, including a triangular configuration. These products are slightly more than four inches high. You also stated that, pursuant to a request from a customer, your company has developed a larger size warning triangle for mounting on a car mirror. You have provided a prototype of this new larger size 'Lite at Nite' Reflective Auto Triangle, that is approximately 6' at the base and 5 1/2' in height. You stated that, as your warning triangle gets larger, you 'wish to make sure it is not confused with the roadside truck version described in Standard No. 125.' Additionally, you stated that you wanted to be certain that the instructions for this larger size warning triangle 'in no way conflict with the standard.' I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. This agency has exercised this authority to establish Standard No. 125. Section S3 of Standard 125 states that the standard 'applies to devices, without self-contained energy sources, that are designed to be carried in motor vehicles, and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.' (Emphasis added.) This language in S3 of Standard No. 125 makes clear that the standard's requirements are not limited to devices used by large trucks, that is, Standard No. 125 does not apply only to a 'roadside truck version' of a warning device. Instead, the standard applies to all devices designed to be carried in any motor vehicle, from the smallest motorcycle to the largest truck, if the device satisfies the other conditions set forth in S3 of the standard. One of the conditions set forth in S3 is that the device must be designed to be used to 'warn approaching traffic of a stopped vehicle.' Devices that are not intended to warn approaching traffic of a stopped vehicle, but only to alert passing traffic of the stopped vehicle's need for assistance, are not subject to Standard No. 125. Examples of such devices include a rag tied on a radio antenna and a 'HELP' message printed on a folding cardboard sunshade. By the time approaching traffic sees one of these non-warning devices, the traffic would already be aware that the vehicle displaying such a device was stopped. Your 'Signal Glo Car Door Mirror Clip On' product appears to be designed and to function in the same way other non-warning devices do, i.e., it does not appear to be intended to warn approaching traffic of a stopped vehicle, but to alert passing traffic that the stopped vehicle needs assistance. If this is the case, the 'Signal Glo Car Door Mirror Clip On' would not be subject to Standard No. 125. However, the larger 'Lite at Nite' Reflective Auto Triangle may be designed to be used to 'warn approaching traffic of a stopped vehicle.' It appears from the promotional material enclosed in your letter that this larger triangle is intended to serve the same purpose as what you call 'truck warning triangles.' We assume that you are describing warning devices that are certified as complying with Standard No. 125. If your larger triangle is to serve this function, it would be subject to Standard No. 125 and would have to conform to all the requirements of the standard. From the enclosed copy of Standard No. 125, you will see that some of the specific requirements with which the larger triangle must conform include minimum size, durability, material, container, labeling, configuration, color, reflectivity, luminance, and stability. When the agency has issued an applicable safety standard, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) provides that no person shall 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any new motor vehicle or new item of motor vehicle equipment unless the vehicles or equipment are in conformity with the applicable standard. Further, the Safety Act provides that NHTSA has no authority to approve, certify, or otherwise endorse any commercial product. Instead, section 114 of the Safety Act (15 U.S.C 1403) establishes a self-certification process under which every manufacturer is required to certify that each of its products meet all applicable Federal safety standards. To comply with any applicable legal obligations, especially in connection with the manufacture of the larger size warning triangle, I suggest that you carefully examine the requirements of Standard 125 and consider the design, marketing, and intended use of the new larger warning triangle. You should also be aware that the Safety Act establishes a civil penalty of $1,000 for each violation of a safety standard and a maximum penalty of $800,000 for a series of violations. In addition, the Act requires manufacturers to notify purchasers and remedy any items of motor vehicle equipment, such as warning devices, that do not conform with any applicable safety standards. I have also enclosed an information sheet for new manufacturers of motor vehicles and motor vehicle equipment, that briefly summarizes our laws and regulations and explains how to get copies of those laws and regulations. If you have any further questions or need additional information on this subject, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures"; |
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ID: aiam3082OpenMr. D. Black, Alfa Romeo, 250 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. D. Black Alfa Romeo 250 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Black: This responds to your request for written confirmation of statement made by Mr. Ralph Hitchcock of the National Highway Traffic Safety Administration during a meeting with your representative, Mr. Bernstein. That meeting concerned the requirements of Safety Standard No. 208 and Safety Standard No. 216 as they apply to convertibles. The discussion below follows sections 'I' and 'V' of the transcript enclosed in your letter, which involve legal questions.; (I.) Convertibles, like all other passenger cars, must comply with th automatic restraint requirements of Safety Standard No. 208 beginning in 1981, 1982 or 1983, depending on vehicle wheelbase size. This means that convertibles will have to meet the frontal crash protection requirements of S5.1 by means that require no action by vehicle occupants and, either meet the lateral and roll-over requirements of S5.2 and S5.3 by means that require no action by vehicle occupants or, at the option of the manufacturer, have a Type I or Type II seat belt assembly at each front designated seating position (and meet the frontal requirements of S5.1 with these belts fastened around the test dummies).; In the second part of your first question, you asked whether convertible may meet the requirements of Safety Standard No. 216, *Roof Crush Resistance*, as an optional means of complying with the roll-over requirements of Standard No. 208. The answer to your question is yes. Convertibles are not required to meet the requirements of Standard No. 216 but may do so, at the option of the manufacturer, as an alternative to meeting the automatic roll-over requirements of Standard No. 208. Please note that compliance with Standard No. 216 would not excuse convertibles from compliance with the automatic lateral protection requirements of Standard No. 208. As stated above, however, installation of a lap belt at front designated seating positions would excuse all passenger cars from both the lateral and the roll-over requirements. Therefore, a convertible that meets the frontal crash protection requirements of the standard by means that require no action by vehicle occupants and that also has lap belts installed, does not have to meet the requirements of Standard No. 216. I am enclosing a letter of interpretation that was issued last year which discusses the relationship between Safety Standard No. 208 and Safety Standard No. 216, in light of the automatic restraint requirements.; In the final part of your first question, you asked whether you coul manufacture convertibles with fold-down tops, removable tops or removable hard-tops that would comply with Safety Standard No. 216, as an optional means of complying with the roll-over requirements of Safety Standard No. 208. The answer to this question is also yes. While our regulations do not include a formal definition of 'convertible,' the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) or by a fixed, rigid structural member. Therefore, if any of the vehicle designs you mentioned meet this criteria and also comply with Safety Standard No. 216, they would not be required to comply with the roll-over requirements of Safety Standard No. 208.; (V.) Section V of your transcript includes a discussion of the growin aftermarket convertible industry (removing hard-tops from vehicles) and the increasing number of kit-car convertibles. You asked about the legal requirements for these vehicles. Any new vehicle that is manufactured or assembled from a kit-car must comply with all applicable Federal motor vehicle safety standards and regulations. Likewise, a person who alters a new vehicle prior to its first purchase in good faith for purposes other than resale (by converting a hard-top vehicle to convertible, for example) is required to place an additional label on the vehicle certifying that, as altered, the vehicle remains in compliance with all applicable safety standards. This means that all of these vehicles would have to be in compliance with the automatic restraint requirements of Safety Standard No. 208 (after those requirements become effective).; Mr. Hitchcock's statement that removing the top of a vehicle that is i compliance with Safety Standard No. 216 would be prohibited by Federal law is incorrect. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (sic) 1974, does provide that no manufacturer, dealer, distributor or motor vehicle repair business may knowingly render inoperative any device or element of design installed in compliance with a Federal motor vehicle safety standard, and this is the law that Mr. Hitchcock referred to. The agency has stated in the past, however, that conversion of one vehicle type to another vehicle type (e.g., hard-top to convertible) does not violate this provision, as long as the converted vehicle complies with all safety standards that would have been applicable to it if it had originally been manufactured as the new type. Therefore, removal of a passenger car's hard-top does not render inoperative the vehicle's compliance with Standard No. 216 since a new convertible would not have been required to comply with that standard.; I hope this letter has responded fully to the legal questions raised i your discussions with Mr. Hitchcock. If you have any further questions, please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2739OpenMr. Dick Rechlicz, Executive Secretary, Wisconsin School Bus Association, 2830 No. Brookfield Road, Box 403, Brookfield, WI 53005; Mr. Dick Rechlicz Executive Secretary Wisconsin School Bus Association 2830 No. Brookfield Road Box 403 Brookfield WI 53005; Dear Mr. Rechlicz: This responds to your October 16, 1977, letter requesting again tha the National Highway Traffic Safety Administration (NHTSA) reinterpret its 20-inch measurement of occupant seat spacing in Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; Mr. Levin indicated in an earlier response to your letter that sea spacing is measured at the point of greatest distance separating the seats. This measurement is used to ensure that impact forces do not exceed the forces the seat is designed to sustain or absorb. To measure as you suggest would require redesigning school bus seats to ensure their ability to sustain or absorb increased impact loads.; The NHTSA has received a number of complaints on seat spacing in schoo buses manufactured in compliance with the subject regulations. We have met with most of the major school bus manufacturers discussing production seat spacings and the Federal requirements. The agency has found that manufacturers are producing buses with seat spacings which are, in some cases, 3 inches less than the maximum specified by the regulations. These large reductions in seat spacing result principally from manufacturers' choices in designing the seats. Such seat spacing reductions are not found in all seats designed to meet the regulations.; Through its monitoring of the standard's implementation, the NHTSA ha discovered that manufacturers are not achieving the maximum seat spacing that the agency had contemplated at the time the regulation was issued. The installation of seats in school buses cannot be done with the precision that the NHTSA had anticipated. Accordingly, manufacturers in their attempts to ensure that they do not violate the 20-inch space requirement must design seat spacing as much as an inch short of the 20-inch spacing allowance. The result is seat spacing which is less than the agency contemplated. The NHTSA has taken expeditious action to alleviate this problem.; On December 20, 1977, NHTSA issued an Interim Final Rule amendin Federal Motor Vehicle Safety Standard No. 222 by increasing the maximum allowable distance from the seating reference point to the seat back from 20 to 21 inches. The agency intended that the measurement be approximately 20 inches. A seat spacing specification of 21 inches permits 20- inch spacing by taking manufacturing tolerances into account. A Notice of Proposed Rulemaking (NPRM) proposing this change in the rule was also issued on December 20, 1977.; Sincerely, Joan Claybrook |
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ID: aiam0704OpenMr. Harvey Livingston, Livingston's Tire Shop, North Main Street, Hubbard, Ohio 44425; Mr. Harvey Livingston Livingston's Tire Shop North Main Street Hubbard Ohio 44425; Dear Mr. Livingston: This is in reply to your letter of May 2, 1972, requesting a lette from NHTSA to the effect that tire manufacturers are free to sell you new repairable tires which you plan to repair and sell. We have assumed that the manufacturers of the tires do not believe that they conform to Motor Vehicle Safety Standard No. 109. 'New Pneumatic Tires,' and that they have not certified conformance to the standard, as this is apparently the reason for their reluctance to sell you these tires.; Paragraph S6. of Standard No. 109 provides, among other things, tha passenger car tires that are not certified, defined as 'reclassified tires,' must bear a label (specified in the standard) stating that they are not to be sold for use on passenger cars.; If you wish to purchase reclassified tires, repair them, and resel them for passenger car use, you must ensure that they conform to the performance requirements of Standard No. 109 (paragraphs S1. through S5.). and relabel and certify them in accordance with paragraph S4.3.; You should be aware that the NHTSA has proposed, in a notice date November 27, 1971 (36 F.R. 22688, copy enclosed) to prohibit the sale for any purpose of reclassified tires.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1816OpenMr. Hironori Tanaka, Toyoda Gosei Co., Ltd., 9, 1-chomee, Nishiyabushitacho, Nishiku, Nagoya, Japan; Mr. Hironori Tanaka Toyoda Gosei Co. Ltd. 9 1-chomee Nishiyabushitacho Nishiku Nagoya Japan; Dear Mr. Tanaka:#This responds to your letter of February 15, 1975 requesting an interpretation of the adhesion requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*.#You have presented a diagram of multilayer air brake hose and suggested that S7.3.7 of the standard applies only to the adhesion between the outer cover and the upper braid of the hose. That interpretation is incorrect. The requirement of S7.3.7 is that:>>>An air brake hose shall withstand a tensile force of 8 pounds per inch of length before separation of adjacent layers (S8.6).<<<#The NHTSA interprets this requirements as applying to each pair of adjacent layers of the hose, not merely to the outermost pair.#Yours truly, James C. Schultz, Chief Counsel; |
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ID: aiam5506OpenMajor Glen Gramse Minnesota State Police 444 Cedar Street St. Paul, MN 55101; Major Glen Gramse Minnesota State Police 444 Cedar Street St. Paul MN 55101; "Dear Major Gramse: It has been brought to our attention by Mr. R.C Rost of Minnesota Body and Equipment that there is a question regarding Minnesota's law concerning buses used for Head Start programs. According to Mr. Rost, Minnesota prohibits these buses from being equipped with flashing lights and stop signal arms. He requested the National Highway Traffic Safety Administration (NHTSA) to clarify any inconsistencies between the Federal and State law. As explained below, to the extent there is a conflict between Federal and State law, Federal law would prevail in this matter. All manufacturers and sellers of new school buses must comply with the Federal law by manufacturing and selling vehicles that are equipped with school bus lights and stop signal arms. By way of background, Congress has directed this agency to issue Federal motor vehicle safety standards, which apply to the manufacture and sale of new motor vehicles. NHTSA has issued a number of FMVSSs for school buses, including ones requiring these buses to have warning lights and stop arms. The Federal law requires that each person selling a new bus (defined in our regulations as a vehicle designed for 11 or more persons) to a primary, preprimary, or secondary school must sell a bus that is certified to the FMVSSs for school buses. State law cannot change this requirement. NHTSA's longstanding position is that Head Start programs are primarily educational in focus rather than custodial, and are therefore 'schools' under NHTSA's statute. Accordingly, buses transporting students to and from Head Start facilities are defined as school buses under Federal law and are therefore subject to the Federal school bus safety standards. Any manufacturer that omits the warning lamp system required by paragraph S5.1.4 of Standard No. 108 or the stop signal arm required by paragraph S5 of Standard No. 131 (or that delivers a bus with these devices inoperative), is in violation of Federal law, and subject to recall provisions and civil penalties. The effect of the statute's preemption provision is that a State may not adopt or enforce a standard or requirement that regulates the same aspect of safety performance as one of the Federal standards unless that State standard or requirement is identical to the Federal one. While the statute also permits a State to establish a higher standard of performance for vehicles procured for its own use, we would not view an exemption from the warning light or stop arm requirements as a higher standard of performance. Thus, regardless of how a State defines 'School bus,' a State cannot prohibit a van, with seating capacity large enough to be defined as a school bus under Federal law, from being equipped with warning lights or stop arms. Although each State has the authority to establish laws for the use of vehicles on its roads (including the equipment on the vehicles), those State laws may not override Federal laws for what type of safety equipment must be installed on new vehicles. I hope this information will be useful. If you have any further questions or desire any further information, please feel free to contact Mr. Walt Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam2369Open*AIRMAIL*, William K. Rosenberry, Esq., Attorney at Law, Parkway Central Plaza, 611 Ryan Plaza Dr., Suite 713, Arlington, TX, 76011; *AIRMAIL* William K. Rosenberry Esq. Attorney at Law Parkway Central Plaza 611 Ryan Plaza Dr. Suite 713 Arlington TX 76011; Dear Mr. Rosenberry: This is in reply to your letter of July 14, 1976, to George Shifflet of the Office of Standards Enforcement, on behalf of a client who intends to install a different type of seat, carpeting, and headliner in a pick-up truck, which would then be sold to the general public. You asked whether a fabric supplier must test each fabric lot for flammability before certification to Motor Vehicle Safety Standard No. 302 can be given, and whether your client 'may rely on the warranty of a fabric manufacturer that the fabric sold meets the requirements' of Standard No. 302.; You are correct in your understanding that the provisions of th National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et* *seq*) apply to your client. His basic responsibility is to ensure that the vehicles he modifies are in compliance with the Federal standards when delivered to dealers for sale to the public. (15 U.S.C. 1397(a)(1)(A)) A temporary noncompliance during modifications is permissible if the vehicle is not used on the public roads while noncompliant (15 U.S.C. 1397 (a)(2)(A)). Standards which would appear to be affected by your client's modifications include: Standard No. 207 *Seating Systems*, No. 208 *Occupant Crash Protection*, No. 210 *Seat Belt Assembly Anchorages* and No. 302 *Flammability of Interior Materials*.; As a person who alters a certified vehicle other than by the additio of readily detachable components, your client is also required to attach his own certification of compliance to each modified truck (49 CFR 567.7). Should a noncompliance be discovered as a result of an alterer's modification, the alterer would be liable for a civil penalty unless he could establish that he did not have actual knowledge of the noncompliance, and that he did not have reason to know in the exercise of due care that the vehicle did not comply (15 U.S.C. 1397(b)(2)).; With respect to Standard No. 302, there is no requirement that a fabri supplies 'test each fabric lot for flammability before certification.' In point of fact, 49 CFR 571.302 Motor Vehicle Safety Standard No. 302 does not apply to suppliers but only to vehicle manufacturers (or alterers) and it is they who are required to certify compliance with Standard No. 302. Generally, at a minimum, a vehicle manufacturer will require by contract with the supplier that the fabric meets Standard No. 302. In the exercise of 'due care' the manufacturer may wish to examine the basis for the supplier's assurance of compliance, and to require periodic testing of the fabric being supplied him. Since there is no requirement that each fabric lot be tested, such testing as is conducted should be sufficient to demonstrate in the event of a noncompliance that the vehicle manufacturer has exercised due care. As to whether your client may rely on the 'warranty' of his supplier, it has been our experience that simple reliance is insufficient to establish a 'due care' defense. That manufacturer should examine the supplier's test results to insure that the margin of compliance of the test fabric is great enough that production variables do not result in noncompliance. Some manufacturers even conduct their own tests independent of the supplier.; Your client would also be responsible for conducting a notification an remedy campaign (15 U.S.C. 1411 *et* *seq*) if a noncompliance of safety-related defect occurs in the truck as a result of the alterations.; I enclose copies of the Act, 49 CFR Part 567, and Standards Nos. 207 208, 210, and 302 for your information.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0354OpenMr. William J. Henrick, Assistant Counsel, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. William J. Henrick Assistant Counsel The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Henrick: This is in response to your letter of May 17, 1971, concerning th applicability of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.; As you mentioned in your letter, under the regulation, a vehicle deale has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.; The Tire Identification and Record Keeping Regulation and th Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2693OpenMr. John W. Kourik, Chief Engineer, Wagner Electric Corporation, 11444 Lackland Road, St. Louis, MO 63141; Mr. John W. Kourik Chief Engineer Wagner Electric Corporation 11444 Lackland Road St. Louis MO 63141; Dear Mr. Kourik: This responds to Wagner Electric Corporation's October 26, 1977 request for confirmation that S5.6.4 of Standard No. 121, *Air Brake Systems*, does not prohibit the use of a two-valve sequential means to release the parking brakes on a towed vehicle.; I have enclosed for your information an interpretation that addresse this question, stating that a two-valve sequential release is permissible under S5.6.4.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.