NHTSA's Interpretation Files Search
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ID: nht76-1.33OpenDATE: 04/07/76 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Trans-Continental Tire Sales, Inc. TITLE: FMVSS INTERPRETATION TEXT: I am writing to confirm your March 19, 1976, telephone conversation with Mark Schwimmer of this office concerning Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars. Standard No. 119 requires that the symbol "DOT" appear on the sidewall of a non-passenger car tire, as a certification that the tire meets all of the standard's performance and labeling requirements. Assuming that the tire in question does meet those requirements and is so certified, there is no prohibition in the standard against additional labeling such as "Blem" or "A.B.O." I hope this clarifies the status of your tires. Sincerely, ATTACH. March 9, 1976 Frank Berndt -- Acting Chief Counsel, N.H.T.S.A. Dept. of Transportation Re: Federal Motor Vehicle Safety Standards Sec. 119. Dear Mr. Berndt, Can you clarify that truck tires marked "A.B.O." or "Blem" are safe for highway use on the front end of commercial over the road vehicles? The tires in question do meet D.O.T. highway specifications for manufacturers safety, in so for as they are free from defects in workmanship and materials. Please rush clarification as soon as possible. Thank You. Respectfully Yours, Raymond Oleisky, Operations Manager |
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ID: 2860oOpen Mr. Robert Cuzzi Dear Mr. Cuzzi: This responds to your letter asking whether buses with a gross vehicle weight rating (GVWR) greater than 10,000 pounds are excluded from coverage under Federal Motor Vehicle Safety Standard No.301, Fuel System Integrity. I regret the delay in responding to your letter. The answer to your question is yes. Safety Standard No. 301 applies to new passenger cars, multipurpose passenger vehicles, trucks, and buses having a GVWR of 10,000 pounds or less and to all new school buses. The buses you manufacture for sale as municipal transit buses are excluded from Standard No. 301 because their GVWR is greater than the 10,000 pound limit established for the standard. You asked also whether there are any other Federal standards that might apply to the fuel tanks on your transit buses. I have forwarded a copy of your letter to the Federal Highway Administration (FHWA) and the Urban Mass Transit Administration (UMTA) for their direct reply as to the applicability of any FHWA or UMTA regulations to your transit vehicles. You might also contact the Environmental Protection Agency (EPA) to see whether that agency has any requirements affecting the fuel tanks on your buses. The general telephone number for the EPA is (202) 382-2090. Sincerely,
Erika Z. Jones Chief Counsel ref:301 d:6/17/88 |
1988 |
ID: nht75-5.6OpenDATE: 12/24/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Conti Rubber Products TITLE: FMVSR INTERPRETATION TEXT: This is in response to your October 29, 1975, letter concerning the applicability of Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles other than Passenger Cars, to moped tires. Mopeds are classified under 49 CFR 571.3 as "motor-driven cycles", a subcategory of "motorcycles", for the purposes of the National Highway Traffic Safety Administration's regulations. Therefore, tires designed for use on mopeds are tires designed for use on motorcycles and, as such, are subject to Standard No. 119. The NHTSA is considering an amendment of Standard No. 119 which would modify the requirements applicable to such tires, and expects to issue a notice of proposed rulemaking on this subject in the near future. Yours truly, ATTACH. Conti RUBBER PRODUCTS INC. October 29, 1975 Frank Berudt -- Acting Chief Council, National Highway Traffic Safety Administration Dear Mr. Berudt: We would appreciate receiving a ruling whether MOPED tires in the sizes 2-17 and 2 1/4-17 fall under MVSS119. A MOPED is a motorized bicycle with a maximum speed of 30 miles per hour. We would appreciate your fastest possible reply. Very truly yours, George H. Schildge -- Exec. Vice President |
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ID: nht94-4.66OpenTYPE: INTERPRETATION-NHTSA DATE: October 27, 1994 FROM: Lois Castillo -- President, Travel Tray, Inc. TO: Joan Womack -- NHTSA; John Womack TITLE: NONE ATTACHMT: Attached to 1/9/95 letter from Philip Recht to Lois Castillo (A43; Std. 213) TEXT: Dear Joan Womack: My name is Lois Castillo. I represent a new company called Travel Tray, Inc. based in Utah. Our tray fits across children's carseats and is easily attached and removed. I have enclosed one of our brochures that describes our tray. I need your help in obtaining any information you might have regarding safety regulations pertaining to a tray such as this. We are in preparation to start manufacturing and have been advised to seek information from your department first. I have spoken with Craig Allred, Director of the State of Utah Division of Highway Safety and showed him my tray. He felt the tray was okay, but suggested that I should apply a disclaimer clause and warning that the tray should not be used as part of the safety apparatus. That it is only to be used as a convenience item - like a toy - for the child. My patent attorney also suggested thi s. Please let me know what you think and any information you might have regarding this. Thank you in advance for your time. Enclosure (Brochure omitted.) |
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ID: nht88-2.48OpenTYPE: INTERPRETATION-NHTSA DATE: 06/10/88 FROM: T. BAILEY -- LEGISLATION ENGINEER, INTERNATIONAL AUTOMOTIVE DESIGN TO: NHTSA TITLE: FMVSS 104 Windshield WIPING & WASHING SYTEMS ATTACHMT: MEMO DATED 11-3-88, TO T.P. BAILEY, FROM ERIKA Z. JONES, STD. 104 TEXT: As an automotive design consultancy we need a clear understanding of this Standard, particularly the requirements of paragraph S4.1.2, Wiped Area. We have a problem with this and would appreciate some advice. Firstly, can you confirm this paragraph is only applicable to passenger cars. Secondly, the hypothetical results for a windscreen are shown on attachment 1. In this, Area A on one side extends to the DLO, on the other, overlaps it. (The DLO is taken to start at the inner edge of the obscuration band). As drawn, the correct perce ntage wiped area is still achieved. Should Area A be wholly:- 1. On exterior surface of glass, inside a perimeter line drawn one inch from edge of daylight opening. 2. On exterior surface of glass, inside the DLO. 3. On exterior surface of glass (ie. whole surface visible from outside vehicle including the obscuration band). 4. On total exterior surface of glass (ie. including the part normally hidden under trim and mouldings). Thank you for your attention. I look forward to hearing from you. See Illumtation on original |
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ID: bmw102-1.pjaOpenMr. Karl-Heinz Ziwica Dear Mr. Ziwica: This responds to your request for an interpretation of Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect. Specifically, you ask whether a park control that is actuated by a separate control instead of by the movement of the transmission shift lever is part of the transmission shift lever sequence. You also ask whether such a park position must be located at the end, adjacent to reverse. Paragraph S3.1.1 of Standard No 102, Location of transmission shift lever positions on passenger cars, states, in part " . . . If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position." [emphasis added.] Paragraph S3.1.1 explicitly limits the requirement to those park positions included within the "shift lever sequence." It is our interpretation that if park is not selected by the movement of the shift lever, then the park control is not part of the shift lever sequence. In this case, the sentence quoted above does not apply, and the park control does not have to be located at the end, adjacent to reverse. I hope this information is helpful. If you have any questions, please contact Paul Atelsek of my staff at (202) 366-2992. Sincerely, |
1998 |
ID: 1930yOpen Mr. Ted Aston Dear Mr. Aston: This is in reply to your letter with respect to your wish to import motor vehicle parts from England, to be used in the construction of a kit car for your own use. I regret the delay in responding. You have informed us that you are not importing parts controlled by the Federal motor vehicle safety standards, such as "lights, tires, brake hoses, glazing materials," or "the engine, transmission, wheels, instruments, and miscellaneous items that are readily available here". Instead, you will be importing "body parts, frame parts, suspension and some steering parts, some electrical parts and the gas tank." From your description, we believe that your intention is to import motor vehicle equipment and not a motor vehicle. The only items of motor vehicle equipment which are covered by the Federal motor vehicle safety standards, and hence must comply or be brought into compliance with those standards are: brake hoses, brake fluid, lighting and reflective devices, passenger car tires, retreaded tires, tires and rims for vehicles other than passenger cars, wheel covers, warning devices, glazing, seat belt assemblies, and child seating systems. If the motor vehicle equipment you are importing includes none of these items, then the equipment may be entered without the necessity of giving a bond for the production of a statement that it has been brought into compliance. I hope that this letter is helpful to you. Sincerely,
Stephen P. Wood Acting Chief Counsel ref:VSA d:8/7/89 |
1989 |
ID: 1982-2.20OpenDATE: 07/21/82 FROM: Frank Berndt; NHTSA TO: Arnold P. Fuchs TITLE: FMVSS INTERPRETATION TEXT: This letter is to confirm your view, expressed in a telephone call with Edward Glancy of this office, that the requirements of Standard No. 206, Door Locks and Door Retention Components, are not applicable to a replacement latch for a truck built in l969. The requirements of Standard No. 206 are applicable to passenger cars, multipurpose passenger vehicles and trucks. See S2 of that Standard. However, its requirements are not applicable to replacement parts for installation in used vehicles of these types. Further, the "render inoperative" provisions of the National Traffic and Motor Vehicle Safety Act are not relevant to the installation of such a latch. Under section 108(a)(2)(A) of that Act, a business such as a garage must make sure that it does not knowingly render inoperative the compliance of a vehicle with any applicable safety standard. With respect to a 1969 truck and Standard No. 206, there is no compliance which could be rendered inoperative since the Standard was never applicable to that truck. That Standard applies only to trucks manufactured on or after January 1, 1972. I would note that even in the absence of an applicable safety standard, the defect provisions of the Act may be applicable. Sections 151 et seq. of the Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge. |
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ID: nht76-1.36OpenDATE: 02/26/76 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: E.T.R.T.O. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of January 26, 1976, which inquired about the status of the E.T.R.T.O. petition for an amendment of Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, concerning tires for low-power motorcycles with restricted speed capability. We expect to issue a Federal Register notice on this subject in the near future. Yours truly, ATTACH. The Director -- National Highway Traffic Safety Administration, U.S. Department of Transportation JANUARY 26, 1976 ETRTO SUBMISSION No. 6/119 TYRES FOR LOW-POWER MOTORCYCLES WITH RESTRICTED SPEED CAPABILITY Dear Sir, The above Submission was made in ETRTO letter ref. RD/MS 048/75 dated February 5, 1975 and in a letter dated March 4, 1975, ref. N40-30 MS, signed by Mr. R.B. DYSON, Assistant Chief Counsel, receipt of the Submission was acknowledged with the advice that it was under consideration. Since then, as far as is known, there has been no further communication from NHTSA and no notice referring to the Submission has appeared in the Federal Register. News of the current status of this Submission would be greatly appreciated. Yours faithfully, J. TRIMBLE Secretary General cc: R.P. Monier, Chairman of the ETRTO Road Safety Sub-Committee. |
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ID: 2860yyOpen Mr. Billy S. Peterson Dear Mr. Peterson: This is in reply to your letter of February 7, l99l, to the Office of Chief Counsel asking for a clarification of allowable mounting locations and photometric output requirements for tail/stop lamps on passenger cars. One of your clients wishes to mount "two-part" stop/tail lamps "so that one lamp is mounted on the fixed quarter panel and a duplicate lamp is mounted on the trunk lid." Each part of the two-part lamp is a combination tail/stop lamp. You have asked whether the minimum photometric requirements must be met by "the lamp mounted to the quarter panel or may the portion mounted on the trunk lid count toward the photometric requirements." Your "two-part lamp" would be treated as two separate lamps. For purposes of compliance, only one of these two adjacent lamps must be designed to conform to Standard No. l08, and this conformance must be independent of any "contribution" by the adjacent lamp. Although Standard No. l08 permits either the deck or the body mounted lamp to be the complying lamp, it would be our preference that the body mounted lamp be the one that complies, so that the benefit of a conforming stop/tail lamp would be realized during those occasions when the lid may be raised. Sincerely,
Paul Jackson Rice Chief Counsel /ref:l08 d:3/8/9l |
2009 |