Departamento de Transporte - USNHTSA 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: aiam1657OpenMr. Thomas S. Pieratt, Jr., Executive Director, Truck Equipment and Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Director Truck Equipment and Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of October 1, 1974, in which you as whether a manufacturer who modifies a certified flat-bed trailer by adding beverage compartments and required lamps and reflectors may use the certification date of the trailer for determining conformity to applicable safety standards, rather than the date on which the modifications are completed.; We question your description of the trailer as certified by lacking floor, for this characterization would be unusual under the definitions provided in Part 568. It is difficult for us to envision a trailer being a 'completed vehicle' (requiring no further manufacturing operations to perform its intended function) if it lacks a floor, unless the floor is considered to be a readily attachable component, which we also view as unlikely. If, however, that is the case, the situation you describe is covered specifically in the requirements for vehicle alterers (49 CFR SS 567.7, 568.8). Section 567.7 of the Certification Regulations provides that a person who alters a vehicle that has been previously certified can certify the conformity of the altered vehicle as of any date between the date of manufacture of the original vehicle and the date the alterations are completed. This makes it unnecessary, unless the alterer chooses otherwise, for the vehicle to conform to standards which become effective after the date of the original certification.; This provision was intended to place the responsibility of alterers o a par with that of final-stage manufacturers for determining conformity to applicable standards. Some discussion of this point is contained in the preamble to the notice in which the vehicle alterer requirements were issued, and a copy is enclosed for your information.; The only other situation we can envision in which a trailer can b certified and still lack a floor would be one arising under S568.6, 'Requirements for manufacturers who assume legal responsibility for the vehicle.' If the incomplete or intermediate manufacturer has assumed responsibility for the vehicle, then the person adding the floor and beverage compartments, although a final-stage manufacturer, would be under no obligation to further certify the vehicle.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0945OpenMrs. Lewis Polin, 1912 Nester Street, Philadelphia, PA 19115; Mrs. Lewis Polin 1912 Nester Street Philadelphia PA 19115; Dear Mrs. Polin: This is in reply to your letter to our Region III office in which yo requested information on infant car seats and regulations affecting the manufacture of such seats.; Enclosure 1 is a copy of Federal Motor Vehicle Safety Standard No. 213 Child Seating Systems, along with a recent amendment to the standard. The effective date of this standard was April 1, 1971. All child car seats which both seat and restrain a child in a motor vehicle are now required by law to comply with the requirements of this standard. This regulation requires the date of manufacture to be placed on each seat along with recommendations for its use. Child seating systems are recommended for use by children from approximately eight to nine months to three to four years of age.; The National Highway Traffic Safety Administration is presentl developing a proposed amendment to the existing standard which will require dynamic tests of all child restraints and will regulate infant restraints which are not presently covered by Standard No. 213. However, it is not anticipated that this amendment will become effective in the near future.; Enclosures 2 and 3 are copies of press releases notifying consumers o devices which have failed to pass Standard No. 213, and of the action the manufacturers are taking to correct the situation. Additionally, we are enclosing a copy of a consumer information booklet entitled, 'What To Buy In Child Restraint Systems.' We hope this information will assist you.; We do not endorse or advocate any specific product, but rather develop issue, and enforce minimum safety standards for consumer protection. In the final analysis, the consumer should select a restraint which best fits his particular needs. Many practical considerations may affect the usage of a device, for example, the activity level of the child, portability of the device, and ease of attachment. These are all factors which the buyer of a child restraint system should consider in making his selection.; Thank you for your interest in motor vehicle safety. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2978OpenMr. Michael J. Schmitt, Counsel, Engineering Division, Yamaha Motor Corporation USA, P.O. Box 6620, Buena Park, CA 90622; Mr. Michael J. Schmitt Counsel Engineering Division Yamaha Motor Corporation USA P.O. Box 6620 Buena Park CA 90622; Dear Mr. Schmitt: This is in reply to your letter of February 22, 1979, with respect t Yamaha's plan to equip its motorcycles with a hazard warning signal system.; You have cited S4.5.5 of Standard No. 108 which requires that th hazard warning signal 'operate independently of the ignition or equivalent switch'. Because of the ease with which such a switch can be operated on an open vehicle such as a motorcycle by a person other than the vehicle operator, you would like to integrate the warning system with the ignition switch, so that it will flash when the ignition is in the 'on' or 'off' position, but not the 'off-lock' position unless the key is inserted.; As you noted, the Standard does not require that a motorcycle b equipped with a hazard warning system. Should you voluntarily install the system on a motorcycle, there is no legal requirement that it conform to the requirements specified in Standard No. 108. Because of this, although we appreciate your wish to meet the requirements of the standard, we offer no opinion on your system and are willing to defer to your judgment in this matter.; We are confident that Yamaha would not install such a system withou insuring that the charging system has an adequate capacity, otherwise, the turn signal system might be viewed as 'additional ... motor vehicle equipment ... that impairs the effectiveness' of required lighting equipment, within the prohibition of S4.1.3.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3390OpenMr. Richard A. Rechlicz, N88 W16414 Main Street, Menomonee Falls, WI 53051; Mr. Richard A. Rechlicz N88 W16414 Main Street Menomonee Falls WI 53051; Dear Mr. Rechlicz: This responds to your December 18, 1980, letter asking severa questions about the application of Standard No. 217, *Bus Window Retention and Release*, to school buses.; First, you refer to paragraphs (a) and (b) of S5.2.3.1 and questio which paragraph establishes the minimum safety level. Since paragraph (a) was first proposed and subsequently modified by the addition of paragraph (b), you believe that paragraph (a) defines the minimum level of safety while paragraph (b) meets or exceeds that level of safety. This reading of the standard is not completely accurate. Paragraph (a) of that section was the first part of the section to be proposed. Before the rule became effective, however, the proposal was amended to include paragraph (b). Accordingly, both paragraphs must be read together as defining the minimum mandatory safety performance requirement.; Second, you ask for our opinion of the preemption clause in th National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392(d)). You state that your interpretation is that no State or local government may adopt a safety standard applicable to the same aspect of performance as a Federal standard unless it is identical to the Federal standard. An exception exists for standards applicable to vehicles purchased for the State's or the local government's own use. This is an accurate reading of the preemption clause, however, a major area of contention frequently arises around what constitutes the same aspect of performance as a Federal standard.; Third, you ask whether the Federal government, through Standard No 217, has preempted States from regulating unobstructed openings for purposes of emergency exits. As you are aware, the standard states that the emergency exit opening must be of a certain size. Further, the standard specifies the location of one of the seats at the forwardmost side of the emergency exit. These are the agency's only requirements relating to the unobstructed emergency exit opening. With respect to whether a State could regulate further in this area, it would depend upon the type of regulation the State adopted. For example, a regulation that governed the size of the opening or the location of the forwardmost seat would probably be preempted. However, a regulation that required an aisle leading to the side emergency door would not likely be preempted, since the Federal government does not regulate aisles in buses.; Your fourth question asks us to comment on whether a Wisconsin statut requires aisles in school buses. The agency does not issue interpretations of State statutes. You should contact appropriate State officials for this information.; Finally, you recite a Wisconsin definition of emergency door zone whic states that it is 'the area inside the vehicle required by FMVSS 217 to be unobstructed at the emergency exit...' You then ask whether there are any such zones on buses constructed with side emergency exits. The agency, as stated above, requires an unobstructed opening at each exit (S5.2.3.1). If Wisconsin defines this as a zone, then such a zone exists in buses for purposes of the Wisconsin statute.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4455OpenMs. Joanne Salvio Fire Research Corporation 26 Southern Blvd. Nesconset, NY 11767; Ms. Joanne Salvio Fire Research Corporation 26 Southern Blvd. Nesconset NY 11767; "Dear Ms. Salvio: This responds to your November 10, 1987, lette asking whether the 'Guardian Gate' your company manufactures for firefighting vehicles is subject to Safety Standard No. 206, Door Locks and Door Retention Components. The answer to your question is yes, if the Gate is installed on new vehicles and if the area into which the door leads contains one or more seating positions. The advertising material you enclosed states that the Guardian Gate 'is designed to help firefighters while they are riding to fires in the jump seat of apparatus sic .' The advertisement said that the unique feature of the Guardian Gate is its locking mechanism which enables the gate to be locked 'on both its sides to the vehicle, the cab side, as well as the pump panel side.' The advertisement said this 'dual locking' feature is intended to minimize the likelihood that the gate will be opened either unintentionally or because of 'hazardous conditions' (an explanation of which the advertisement did not include). Paragraph S4 of Standard No. 206 states: 'Components on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard. ...' (S4 exempts certain types of doors from Standard No. 206, but these are doors that are readily removable or that are not provided for retaining occupants. Since the Guardian Gate falls into neither of these two categories, the exemptions are not relevant to your inquiry.) From the information you provided in your letter and in telephone calls between you and Ms. Hom of my staff, we understand that the standing area on the firefighting vehicle enclosed by the Guardian Gate contains a jump seat. Because 'seating accommodations' referred to in S4 include jump seats, a Guardian Gate that is installed to enclose a jump seat area on a new firefighting vehicle must comply with Standard No. 206. This determination is consistent with an August 13, 1980 letter from NHTSA to Mr. L. Steenbock of the FWD Corporation (copy enclosed), in which this agency stated that a door leading to a standing area that contains no seating position would not have to comply with Standard No. 206. Because Standard No. 206 applies to passenger cars, multipurpose passenger vehicles and trucks (e.g., firefighting vehicles), and not to replacement parts for installation in used vehicles of these types, you may sell the Guardian Gate to vehicle owners without regard as to whether the Gate complies with the performance requirements of the standard. However, we urge you to consider meeting those requirements voluntarily, to ensure that the Gate will perform to specified levels for the safety of firefighters riding in the 'jump seat area' of the vehicle. You should also be aware that you are responsible under the National Traffic and Motor Vehicle Safety Act, as a manufacturer of motor vehicle equipment, to ensure that your product contains no defect relating to motor vehicle safety. If you or this agency determines that a safety related defect exists, you must notify purchasers of your product of the defect and remedy the problem free of charge. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam1207OpenMr. Robert B. Hirsch, Adams Rite Products, Inc., 540 West Chevy Chase Drive, Glendale, CA 91209; Mr. Robert B. Hirsch Adams Rite Products Inc. 540 West Chevy Chase Drive Glendale CA 91209; Dear Mr. Hirsch: This is in response to your July 25, 1973, request for copies of th Federal regulations concerning door locks and latches.; Federal Standard 206, *Door Locks and Door Retention Components*, i enclosed. It regulates passenger cars, multipurpose passenger vehicles, and trucks. These categories include ambulances and 'motor homes', which are self-propelled units with sleeping accommodations, generally constructed on a light truck chassis. Most other 'mobile homes' are not self- propelled and they qualify as trailers, which are not subject to this standard.; For your information, paragraph 9.1.2 of *Ambulance Design Criteria has also been enclosed. This publication specifies the criteria which an ambulance must meet to qualify for Federal funding under the Highway Safety Program S 402.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4005OpenSpencer Manthorpe, Esq., Chief Counsel, Bureau of Motor Vehicles, Pennsylvania Department of Transportation, Harrisburg, PA 17122; Spencer Manthorpe Esq. Chief Counsel Bureau of Motor Vehicles Pennsylvania Department of Transportation Harrisburg PA 17122; Dear Mr. Manthorpe: Thank you for your June 17, 1985 letter concerning this agency' regulations for school buses. I hope the following information is of assistance.; We are aware that Pennsylvania recently amended its definition of 'bus' in Act 1984-146 to adopt the Federal definition of that term. As a result of that change in definition, school vehicles that are capable of carrying 11 persons (including the driver) are now considered 'school buses' under Pennsylvania law and must conform to the State's requirements for school buses. Those vehicles had not been previously considered as school buses, and there are apparently a large number of those vehicles used to carry school children which do not comply with Pennsylvania's requirements.; In letters from your Department to school districts and school bu contractors, it was suggested that seats could be removed or blocked off to restrict a vehicle's seating capacity to fewer than 10 passengers. In that way, the altered vehicle would no longer be a 'school bus' under Pennsylvania State law subject to State school bus regulations. You asked us whether those modifications would be acceptable under Federal law.; Some background on applicable Federal law may be helpful. The Nationa Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) authorizes this agency to establish safety standards for *new* motor vehicles. Under our regulations, a new vehicle designed for carrying more than 10 persons (including the driver) is considered a 'bus,' and is considered to be a 'school bus' if sold for school-related purposes. 49 C.F.R. 571.3(b). A 'school bus' must meet all Federal safety standards applicable to buses, and also those specifically applicable to 'school buses,' including Standard No. 220, *School Bus Rollover Protection*, Standard No. 221, *School Bus Body Joint Strength*, and Standard No. 222, *School Bus Passenger Seating and Crash Protection*. 49 C.F.R. 571.220, 571.221, 571.222. If a new vehicle is designed for carrying 10 or fewer persons, it is considered under our regulations to be either a 'passenger car' or a 'multipurpose passenger vehicle' (MPV), 49 C.F.R. 571.3(b), and must meet safety standards applicable to its vehicle type.; Under Federal law, the consequences of removing a seat from 10-passenger bus depend on when the seat is removed and on the person who removes it. If a manufacturer or dealer restricts the passenger capacity of a *new* bus to less than 10 before the vehicle is sold or delivered to the owner, then that manufacturer or dealer is considered an 'alterer' under our regulations. The requirements for alterers are set forth in 49 C.F.R. 567.7, *Requirements For Persons Who Alter Certified Vehicles*. The person who reduces the passenger capacity of a bus to nine or fewer before the vehicle's first sale changes the vehicle's classification to that of a MPV. As a result, the person modifying the new vehicle would be required to certify that the vehicle complies with all of the standards applicable to MPV's. Among other things, this would entail the installation of safety belts at all seating positions. (49 C.F.R. 571.208 S4.2, S4.3.); If the modifications were made after the vehicle's first purchase, ou regulations on vehicle alteration would no longer apply. However, there are still statutory restrictions on the types of modifications that may be made. Section 108(a)(2)(A) of the Vehicle Safety Act (15 U.S.C. S1397(a)(2)(A)) provides: 'No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative...any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard...' In the case of a vehicle sold as a school bus, this provision means that a commercial alterer (in those specified categories) may remove a passenger seat, but must assure that the vehicle continues to comply with all applicable school bus standards after the seat has been removed. Section 109 of the Vehicle Safety Act (15 U.S.C. S1398) specifies a civil penalty of up to $1,000 for any person who violates section 108(a)(2)(A).; The prohibition against rendering inoperative in section 108(a)(2)(A of the Vehicle Safety Act does not apply to an owner, such as a school or a State, which modifies its own vehicles. The regulations we issued under the Vehicle Safety Act would not restrict, in any manner, how an owner may use its vehicle. Therefore, school bus owners may restrict the seating in their vehicles without regard to any Federal regulation administered by this agency.; Since NHTSA's authority under the Vehicle Safety Act extends primaril to the manufacture and sale of new motor vehicles, and not to motor vehicle use, the States retain the authority to determine the requirements under which motor vehicles may operate. If the State determines that vehicles originally manufactured to carry 10 or more school children may be operated as school vehicles when modified to carry only nine or fewer children, then there are no Federal statutory or regulatory impediments to owner modifications of this type. However, it remains our position that a school bus meeting the Federal school bus safety standards is the safest means of transportation for school children. While school buses have always been among the safest methods of transportation, the safety record of school buses has further improved in the years since buses began to be manufactured in accordance with the school bus safety standards. We therefore urge the States to carefully consider the benefits of assuring continued compliance with those standards for larger vehicles (i.e., those originally manufactured to carry more than 10 persons).; I hope this information is helpful. Please feel free to contact thi office if we can be of further assistance.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0046OpenMr. Roger K. Howsmon, American Quality Coach Corporation, P.O. Box 1348, Blytheville, AR 72315; Mr. Roger K. Howsmon American Quality Coach Corporation P.O. Box 1348 Blytheville AR 72315; Dear Mr. Howsman (sic): Thank you for your letter of January 8, 1968, to the Federal Highwa Administration, requesting regulations relating to motor vehicle safety requirements.; The type of vehicle that you have described appears to be a bu accordingly (sic) to the statutory meaning of Part 255.3, Initial Federal Motor Vehicle Safety Standards. Accordingly, Standards 102, 107, 205 and 209 would be applicable to your vehicles manufactured after January 1, 1968. We invite your attention to Section 114 of Public Law 89-563 and the notice of Certification Requirement.; In addition to the existing Federal Motor Vehicle Safety Standards an Public Law 89-563, we are enclosing information concerning proposed rule making that may affect future regulations.; We trust this information will be of assistance to you. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam5244OpenMr. Karl-Heinz Ziwica General Manager, Environmental Engineering BMW of North America, Inc. BMW Plaza Montvale, NJ 07645-1866; Mr. Karl-Heinz Ziwica General Manager Environmental Engineering BMW of North America Inc. BMW Plaza Montvale NJ 07645-1866; "Dear Mr. Ziwica: This responds to your request for an interpretatio regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 206, with respect to a new design for a door lock and latch mechanism that BMW is planning to introduce in the United States. It appears that your proposed door lock and latch mechanism would comply with FMVSS No. 206. Based on information provided in your letter, the new locking mechanism will be placed on side rear doors, and will consist of a door handle that serves the dual function of acting as a door locking mechanism and door latch release. When the side door is locked, a rear seat passenger would pull the door handle once to disengage the locking mechanism. The passenger would have to pull the door handle a second time to open the side rear door. Based on additional information received from a demonstration given to David Elias of my office, I understand that the side rear doors, themselves, cannot be individually locked by the rear passengers. The doors can be locked only when the driver or front seat passenger lock all the car doors via the vehicle's electronic locking mechanism. The internal mechanisms are located at the rear part of the driver's and front seat passenger's armrests located on the front doors, which are reached fairly easily by belted rear seat passengers. The door handle on the side rear door, as noted above, is the mechanism by which the locking mechanism is disengaged. S4.1.3 requires that each door be equipped with a locking mechanism with an operating means in the interior of the vehicle. Your proposed operating means for engaging the locking mechanism in each door is inside the vehicle, even though the four individual door locking mechanisms are controlled by the two operating means located on the armrest on the side front doors. S4.1.3 requires only that the operating means for the locking mechanisms be located inside the vehicle, and does not require that each door have its own, independent operating means for engaging the locking mechanism. Thus, it would seem that your proposed locking mechanism complies with S4.1.3. S4.1.3.2 requires that inside and outside door handles be inoperative when the locking mechanism is engaged. An issue concerning your system is whether the inside door handle is 'inoperative' even though it can operate to disengage the door locking mechanism when the locking mechanism is engaged. We conclude the answer is yes. S4.1.3.2 is intended, in part, to reduce inadvertant door openings in a crash due to impact on or movement of inside door handles. Thus, 'inoperative,' as used in S4.1.3.2, refers to the operation of opening the door. When the locking mechanism is engaged, the door handle cannot open the door, which meets the requirement of S4.1.3.2. I hope this information has been helpful. If you have any further questions, please feel free to contact Mr. Elias at the above address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2581OpenMr. F. Michael Petler, Assistant Manager, Safety and Legislation Department, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, California 90670; Mr. F. Michael Petler Assistant Manager Safety and Legislation Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs California 90670; Dear mr. Petler: This is in reply to your letter of May 6, 1977, asking whether it i permissible to label motorcycle tachometers with the symbol 'r/min' instead of 'RPM.'; Paragraph S5.2.3 of Motor Vehicle Safety Standard No. 123 *Motorcycl Controls and Displays* requires that motorcycle tachometers be identified by the letters 'R.P.M.' at a minimum, and provides that 'appropriate words may be spelled in full.' This means that the required identification must be either 'R.P.M.' or 'revolutions per minute.' S5/2/3 would not allow substitution of 'r/min' as the only identification of a tachometer. However, we have no legal objection to your furnishing that symbol as an additional means of identification of 'R.P.M.' if you so wish.; Yours truly, Frank Berndt, Acting 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.