NHTSA's Interpretation Files Search
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ID: aiam3366OpenMr. M. Ogata, Branch Manager, Mazda, Toyo Kogyo U.S.A. Representative Office, Detroit Branch, 23777 Greenfield Road, Southfield, MI 48075; Mr. M. Ogata Branch Manager Mazda Toyo Kogyo U.S.A. Representative Office Detroit Branch 23777 Greenfield Road Southfield MI 48075; Dear Mr. Ogata: Thank you for your July 24, 1980, letter concerning your efforts t improve defogging performance. We share your concern about providing optimum driving visibility and are pleased with your efforts to improve this safety feature.; Your letter requested an interpretation of Federal Motor Vehicle Safet Standard 103, asking whether it is permissible to designate an intermediate blower fan speed (instead of the maximum speed) as the speed to be used when defrosting, if some caution or direction about the necessity for using that intermediate speed for defrosting purposes is provided in the Owner's Manual. The purpose of taking that step would be to cause the intermediate speed instead of the maximum blower speed to be used in testing the performance of the defrosting system under the standard. If this was permissible, you could increase the speed of the fan at the maximum position, thereby improving performance of the defogging function, while still being able to meet the performance requirements of the defrosting function at the intermediate speed (but not at the new maximum speed).; Paragraph S4.3 of the standard states that ' t he passenger ca windshield defrosting and defogging system shall be tested in accordance with the portions of paragraphs 4.1 through 4.4.7 of SAE Recommended Practice J902, August 1964, or SAE Recommended Practice J902a, March 1967, applicable to that system,' with certain exceptions not applicable to your question.; Section 4.2(g) of SAE Recommended Practice J902 specifies as one of th testing conditions that the defroster system air be 'On full, Blower on high.' Similarly, section 4.2(g) of SAE Recommended Practice J902a specifies that the defroster system air be 'On full. Blower on high speed.' We therefore conclude that it would not be permissible under the standard as currently drafted to install a defrosting system which fails to meet the standard when the blower is set to its highest speed even if the system meets the standard at a lower blower speed and that lower blower speed is labeled as the maximum defrosting position. This conclusion would not be changed by the inclusion of directions in the Owner's Manual or words or symbols on the control panel.; If you are unable to resolve the problem in another way, i.e. improving the performance of the heating element, you may wish to petition the National Highway Traffic Safety Administration for an amendment to FMVSS 103. It is our inclination, however, that a defrosting system which operated optimally at a lower blower speed would cause considerable consumer confusion. Drivers would normally expect to obtain both optimum defrosting performance and optimum defogging performance at the highest blower speed. Even if the system was clearly labeled to indicate that the blower speed should be set to medium for defrosting and high for defogging, many consumers do not know the difference between defrosting and defogging. We would also have to consider the amendment's effect on Standard 101, since there is only one symbol for the defrosting and defogging system. If you should decide to petition for an amendment to Standard 103, we would like to see these issues addressed.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5318OpenR. Mark Willingham, Esquire Thornton, Summers, Biechlin, Dunham & Brown, L.C. 114 Lost Creek Boulevard, Suite 215 Austin, TX 78746; R. Mark Willingham Esquire Thornton Summers Biechlin Dunham & Brown L.C. 114 Lost Creek Boulevard Suite 215 Austin TX 78746; "Dear Mr. Willingham: This responds to your February 1, 1994, letter t me about the National Highway Traffic Safety Administration's (NHTSA's) consumer information regulation for utility vehicles (49 CFR 575.105, Utility Vehicles). The regulation, Part 575.105, requires manufacturers to permanently affix a prescribed sticker in a prominent location of each utility vehicle to alert drivers of the handling differences between utility vehicles and passenger cars. You asked about the meaning of the word 'permanent' as used in Part 575.105. In a May 1984 final rule establishing Part 575.105 (copy enclosed), NHTSA said that the label 'should be of a permanent nature' and concurred with a comment on the proposed rule that the label should be permanently affixed so that, among other reasons, subsequent vehicle owners are made aware of the utility vehicle's handling characteristics. NHTSA believed specifying precisely how the label is to be permanently affixed would be design restrictive. However, we stated in the enclosed final rule that stickers such as the placard required by paragraph S4.3, Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims, would be considered adequate. You also asked 'to whom is Part 575.105 directed (i.e., manufacturer, distributor, dealership)... or a seller of a used vehicle.' The regulation applies to the manufacturer and seller of a new vehicle, not to a seller of a used vehicle. The regulation was issued under sections 103, 112 and 119 of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1381, et seq. (hereinafter Safety Act). Section 103 authorizes NHTSA to issue and amend Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. Section 112(d) (15 U.S.C. 1401(d)) authorizes NHTSA: ' T o require the manufacturer (of motor vehicles and motor vehicle equipment) to give such notification of such performance and technical data as the Secretary determines necessary to carry out the purposes of this Act in the following manner -- (1) to each prospective purchaser of a motor vehicle or item of equipment before its first sale for purposes other than resale . . ., and (2) to the first person who purchases a motor vehicle or item of equipment for purposes other than resale . . . . Section 119 confers general rulemaking authority to issue rules to effectuate the express grants of authority and the obligations imposed by the Safety Act. Sections 103, 112 and 119 of the Safety Act authorize NHTSA to require the consumer information label up to the delivery of the new vehicle to the consumer who first purchases the vehicle 'for purposes other than resale'. NHTSA cannot require sellers of used vehicles to restore missing labels prior to sale of the used vehicles, or prohibit a vehicle owner from removing or defacing the label. You also asked for documents regarding the drafting and interpretation of Part 575.105. Please find enclosed copies of the following: Notice of Proposed Rulemaking, dated December 30, 1982 (47 FR 58323), final rule, dated May 11, 1984 (49 FR 20016), final rule, response to petitions for reconsideration, dated August 10, 1984 (49 FR 32069), and letter to Lawrence F. Henneberger, Esq., dated August 15, 1984. For future reference, copies of NHTSA's interpretation letters can be obtained from the agency's docket section. The address for the docket is 400 Seventh St., S.W., room 5108, Washington, D.C., 20590, telephone (202) 366-4949. I hope this information is helpful to you. Should you have any further questions or need any further information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam2127OpenMr. Kenneth J. Bena, Safety Advisor, The Cleveland Electric Illuminating Co., Illuminating Bldg., Public Square, Cleveland, OH 44101; Mr. Kenneth J. Bena Safety Advisor The Cleveland Electric Illuminating Co. Illuminating Bldg. Public Square Cleveland OH 44101; Dear Mr. Bena: This is in further response to your letter of June 11, 1975, to Mr Kenneth Bowman, Area Director, Cleveland, Ohio, concerning the legal responsibilities of a person who modifies a motor vehicle.; >>>IMPACT OF FEDERAL LAW<<< A person who performs work on a vehicle prior to the first purchase o a the vehicle in good faith for purposes other than resale may be subject to the regulations of the National Highway Traffic Safety Administration (NHTSA) either as an alterer of a completed vehicle or as a final-stage manufacturer of an incomplete vehicle. A vehicle is 'complete' only if it bears a certification label stating conformity to all applicable Federal regulations.; In addition, the National Traffic and Motor Vehicle Safety Act provide that; >>>'No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, 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.' (Sec. 108(a)(2)(A), Pub. L. 93-492, 88 Stat. 1470, 15 U.S.C. S 1397(a)(2)(A))<<<; This prohibition applies both before and after the first purchase of motor vehicle, but does not apply to work performed on a vehicle by the individual owner of the vehicle. In addition, exceptions are provide to permit the rendering inoperative of safety belt interlocks and continuous buzzers after the first purchase of the vehicle, and in certain circumstances just before first purchase.; >>>VEHICLE ALTERATION<<< The regulations of the NHTSA cover two types of vehicle alterations The first is an alteration of a completed vehicle by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting which do not alter the vehicle's stated weight rating (49 CFR S 567.6). This type of alteration does not involve any additional responsibilities by the alterer.; The second type of alteration is an alteration of a certified vehicl by means other than the addition, substitution, or removal of readily attachable components or minor finishing operations, or alteration in such a manner that the vehicle's stated weight ratings are no longer valid (49 CFR S 567.7). This type of alteration, if done prior to the first purchase of the vehicle for purposes other than resale, must include, in addition to the certification label, a label stating that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards and containing the firm or individual name of the alterer (49 CFR S 567.7).; >>>COMPLETION OF VEHICLE MANUFACTURE<<< If a vehicle (such as a chassis-cab) requires further manufacturin operations in order to become a completed vehicle, the completion of the vehicle constitutes final manufacture and necessitates compliance with the certification requirements of 49 CFR SS 567.5 and 568.6. The name of the final-stage manufacturer must appear on the certification label as the manufacturer, unless the incomplete vehicle manufacturer assumes legal responsibility for the vehicle as finally manufactured (49 CFR SS 567.5, 568.6 and 568.7).; To aid the final-stage manufacturer, the incomplete vehicl manufacturer is required to furnish with the incomplete vehicle a statement including the weight ratings of the vehicle if completed as intended, descriptions of the Federal motor vehicle safety standards applicable to the vehicle, and the conditions under which final completion of the vehicle will comply with such standards (49 CFR S 568.4). If the final-stage manufacturer follows these instructions and conditions, the liability for non- compliance with a safety standard will be on the incomplete vehicle manufacturer. Although the certification requirements may be modified as a result of litigation, the NHTSA will consider compliance with the published requirements to meet any manufacturer's responsibilities under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1403 *et seq*.).; Final- stage manufacturers are also subject to the manufacture identification rules of 49 CFR S 566, which require manufacturers to submit to the NHTSA identifying information and descriptions of the items they produce. A final-stage manufacturer may also be subject to the defect reporting requirements of 49 CFR S 573, which concern a manufacturer's responsibilities to report safety- related defects. Enclosed are copies of section 108 of the National Traffic and Motor Vehicle Safety Act, and Parts 566, 567, 568 and 573 of the NHTSA's regulations. In addition, we are enclosing a copy of 'Standards', a summary description of the Federal motor vehicle safety standards.; If you have any questions concerning the foregoing regulations or an Federal motor vehicle safety standard, we suggest you write; >>>Chief Counsel, National Highway Traffic Safety Administration, 40 Seventh Street, S.W., Washington, D.C. 20590<<<; We hope that this information has been of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2577OpenMrs. Floyd J. Caron, Caron Service Center, Route 5, Box 16, Faribault, MN 55021; Mrs. Floyd J. Caron Caron Service Center Route 5 Box 16 Faribault MN 55021; Dear Mrs. Caron: This responds to your April 1, 1977, letter asking where you can obtai vehicle certification forms and a permit to undertake modifications of trucks to lengthen and shorten their frames.; The National Highway Traffic Safety Administration (NHTSA) promulgate regulations pertaining to vehicle safety. It is the responsibility of manufacturers to comply with the requirements of the agency. The NHTSA does not license manufacturers or alterers. Accordingly, you need not obtain a Federal permit to alter trucks in the manner you propose. Similarly, the NHTSA does not supply forms for vehicle certification. You may have these forms printed in the form provided by Part 567, *Certification*, of our regulations (copy enclosed). The type of manufacturing operation you describe would place upon you responsibility, as an alterer of the vehicle prior to first purchase for purposes other than resale, to ensure that the vehicle continues to comply with all applicable safety standards after your modifications. Under Part 567 of our regulations, you must attach a label to the vehicle that states that, as altered, the vehicle continues to conform to the standards.; I am enclosing an information sheet detailing where to obtain moto vehicle safety standards and regulations.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2062OpenMr. William J. Kronschnabel, Imperial-Eastman Corporation, 1440 North 24th Street, Manitowoc, Wisconsin 54220; Mr. William J. Kronschnabel Imperial-Eastman Corporation 1440 North 24th Street Manitowoc Wisconsin 54220; Dear Mr. Kronschnabel: #This is in response to your letter of May 28 1975, in which you petitioned for the replacement of the 'permanent' labeling requirement for brake hose in Standard No. 106-74 with a 'weather resistant' test requirement. You also asked whether a series of dots may be included after the required date information on the hose, to indicate in coded form the day of manufacture. #With respect to your petition, this agency is reconsidering the permanency requirement for the labeling, and a notice is planned for issuance shortly on that subject. We do not find an additional test requirement for the labeling to be justified, on the basis of data presently before the agency, since the usefulness of the labeling is limited primarily to the preassembly period. Therefore, in the strict sense, your petition is hereby denied. You may find, however, that the changes now being developed in our rulemaking proceedings will resolve your problems in this area. #The standard does not permit the use of coded dots indicating production date in the location specified for the required information. S5.2.2(c) specified the following information as part of the required label: #>>>The month, day and year, or the month an year of manufacture, expressed in numerals. For example, 10/1/74 means October 1, 1974.<<<# Our interpretation of S5.2 (as incorporated in S7.2) is that the required information may not be interrupted by optional information. Therefore, the day of manufacture, if indicated as part of the S5.2.2 legend, must be expressed in numerals. You may, of course, use the coded dots if they appear on the opposite side of the hose. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs; |
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ID: aiam2598OpenMr. Jefferson D. Keith, Executive Vice President, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Jefferson D. Keith Executive Vice President National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington DC 20005; Dear Mr. Keith: This is in reference to our letter to you dated September 17, 1976 denying your requested rulemaking on Part 574, *Tire Identification and Recordkeeping*. It has been brought to our attention that you interpret our letter to require that tire dealers actually complete the tire information forms themselves.; Section 158 of the National Traffic and Motor Vehicle Safety Act (th Act) (15 U.S.C. 1381, 1418) requires that; >>>'[e]very manufacturer of motor vehicles and tires shall cause th establishment and maintenance of records of the name and address of the first purchaser of each motor vehicle and tire produced by such manufacturer.... The Secretary may, by rule, specify the records to be established and maintained, and reasonable procedures to be followed by manufacturers in establishing and maintaining such records, including procedures to be followed by distributors and dealers to assist manufacturers to secure the information ....'<<<; This section of the Act, therefore, places the responsibility fo ensuring the establishment of these records upon the manufacturer who may be assisted by the dealer. Part 574 requires dealers to submit first purchaser information to manufacturers. The information that must be supplied to each manufacturer need not be entered on the required form by the dealer. The dealer may present the registration form to the purchaser and allow him to fill in the required information before he takes possession of the tire. Thus, the purchaser would complete the form prior to leaving the store, thereby obviating the need for additional store personnel to complete the forms. It is the dealer's responsibility, however, to ensure that the forms are filled out in their entirety.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2432OpenMr. Robert H. Gaines, 210 East 73rd Street, New York, New York 10021; Mr. Robert H. Gaines 210 East 73rd Street New York New York 10021; Dear Mr. Gaines: This is in response to your letter of August 3, 1976, requestin information concerning National Highway Traffic Safety Administration (NHTSA) regulation of motor-driven cycles (moped) and in amplification of the telephone conversation between you and Mr. Schwartz of this office. We are sorry for the delay in our response, but your letter was misdirected.; The NHTSA has authority to regulate mopeds under two statutes. th National Traffic and Motor Vehicle safety Act (15 U.S.C. 11381, et seq.) authorizes the NHTSA to establish Federal motor vehicle safety standards that apply to motor vehicles. Section 102(5) (15 U.S.C. 1391(5)) of the Act defines a 'manufacturer' of a motor vehicle to include 'any person importing motor vehicles or motor vehicle equipment for resale.' In those instances where the foreign manufacturer itself has not complied, the importer would therefore be responsible for the compliance of the vehicle with Federal motor vehicle safety standards, and with the requirements imposed on manufacturers.; The principal standards and regulations applying to the manufacture an sale of motorcycles, of which the motor-driven cycle is a subcategory, can be found in the following sections of the Code of Federal Regulations:; >>>49 CFR Part 551 - Procedural Rules 49 CFR Part 566 - Manufacturer Identification 49 CFR Part 567 - Certification 49 CFR 571.106 - Standard No. 106-74, Brake hoses 49 CFR 571.108 - Standard No. 108, Lamps, reflective devices, an associated equipment; 49 CFR 571.112 - Standard No. 112, Headlamp concealment devices 49 CFR 571.116 - Standard No. 116, Motor vehicle brake fluids 49 CFR 119 - Standard No. 119, New Pneumatic tires for vehicles othe than passenger cars; 49 CFR 571.122 - Standard No. 122, Motorcycle brake systems 49 CFR 571.123 - Standard No. 123, Motorcycle controls and displays 49 CFR 571.205 - Standard No. 205, Glazing materials 49 CFR Part 573 - Defective Reports 49 CFR Part 574 - Tire Identification and Record Keeping 49 CFR Part 575 - Consumer Information Regulation 49 CFR Part 576 - Record Retention 49 CFR Part 577 - Defect Notification<<< Generally, a moped must meet requirements which apply to motorcycle except when a provision of a standard sets forth a lesser requirement for motor-driven cycles. Currently, these lesser requirements are found in Federal Motor Vehicles Safety Standard Nos. 108, 122, and 123 (49 CFR 571.108, 571.122, and 571.123).; The NHTSA also has the authority to regulate the operation of moped under the provision of the Highway Safety Act (23 U.S.C. 401, et seq.). This legislation provides that each State shall have a highway Safety program designed to reduce traffic accidents and deaths, injuries, and property damage resulting therefrom. Each State program shall be in accordance with uniform standards promulgated by the NHTSA. The NHTSA has not yet used its authority to issue standards regulating moped licensing, inspection, insurance, or other highway safety program areas related to moped operation and use. Many States, however, have established their own requirements.; The NHTSA on November 28, 1975, published a notice in the *Federa Register* requesting comments from the public concerning the safety aspects of motorized bicycles. We are currently reviewing the comments which have been submitted, but have reached no decision to initiate rulemaking or to issue a directive to regulate mopeds in the highway safety program area. No hearings have been held relative to mopeds, but the written comments to the docket are available at a cost of 25 cents for the first page and 5 cents for each page thereafter. Information may be obtained by writing to:; >>>Docket Section National Highway Traffic Safety Administration Room 5108 400 Seventh Street, SW Washington, D.C. 20590<<< and referring to Docket Number 75-29. I trust this information is helpful. Should you have further questions please do not hesitate to contact me.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3673OpenMr. J. N. Uranga, Cummins Engine Company, Inc., Box 3005, Columbus, IN 47201; Mr. J. N. Uranga Cummins Engine Company Inc. Box 3005 Columbus IN 47201; Dear Mr. Uranga: This responds to your January 28, 1983, letter asking about th responsibilities of an original equipment manufacturer for compliance with Part 573, *Defect and Noncompliance Reports*, and other agency recall-related regulations. In particular, you ask questions concerning a hypothetically defective original equipment fan that is a component of an original equipment engine that you manufacture. You ask whether your company would be responsible for compliance with agency regulations if you notified the fan manufacturer of a defect in its product and if that manufacturer refused to report to the National Highway Traffic Safety Administration.; Part 579, *Defect and Noncompliance Responsibility*, states clearl that original equipment is the responsibility of the vehicle manufacturer. As such, the manufacturer(s) of the vehicles in which the equipment is installed would be responsible for recalling and remedying the defective fan. However, Part 573 states that in the case of original equipment, defect reports shall be submitted by either the equipment or the vehicle manufacturer when the defective equipment has been supplied to only one vehicle manufacturer. On the other hand, where such equipment is supplied to more than one manufacturer, both the vehicle manufacturers and the original equipment manufacturer must submit the required reports.; Your hypothetical situation further complicates the reports questio because the original equipment is a component of the original equipment that you manufacture. The agency concludes that in the situation that you posit, the manufacturer of the fan and the manufacturer of all of the vehicles in which the fan is installed would be required to supply the necessary defect reports. Failure to do so would subject all manufacturers to the penalties provided by law. If the fan manufacturer refuses to submit the required reports, it would be the responsibility of your company to issue the report to the agency, since you would also be considered an original equipment manufacturer and the defective component would be part of your equipment. The agency would not require both your company and the fan manufacturer to report. A report submitted by either company would be considered compliance by both companies. However, failure of both companies to report could result in the imposition of penalties on both.; I trust this fully answers your question. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2961OpenMr. Charles J. Calvin, President, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin President Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: We regret the delay in responding to your April 18, 1978, lette criticizing the National Highway Traffic Safety Administration's (NHTSA) interpretation concerning the responsibility of a manufacturer for ensuring that its vehicles will not be overloaded when transporting materials for which they are designed. In that interpretation, the agency indicated that a vehicle whose tank cargo volume is of such size that it misrepresents the assigned GVWR and GAWR values of that vehicle, thus, inviting overloading might be considered to have a safety related defect. Please permit me to qualify the interpretation in the light of your criticism.; The NHTSA realizes that overloading is a problem created for the mos part by the operator of a vehicle. Accordingly, it is not intended by the agency's interpretation or regulations to hold a vehicle manufacturer responsible for every situation in which a vehicle is overloaded. Most any type truck can be overloaded by the user. An operator should be aware of this possibility, however, given the amount of space on that vehicle on which cargo can be loaded and the broad range of cargo that can be transported by that vehicle. If a truck designed for the transportation of one specific cargo were misused by the operator to transport another type of cargo not intended by the vehicle manufacturer, then any resultant overloading would be the responsibility of the operator not of the manufacturer. However, when a vehicle designed to transport a specific cargo can be overloaded when filled to its capacity with that cargo, the NHTSA has determined this to be a problem created by the vehicle manufacturer and would consider taking action against a manufacturer to correct the problem. This agency's interpretation that a vehicle be able to safely transport its intended design cargo when fully loaded is an objective and unambiguous requirement and simply places the burden upon a manufacturer to ensure that the design cargo does not exceed the GAWR and GVWR.; Specifically we are concerned that a tank of fixed volumetric capacit could be loaded to exceed the vehicle's GAWR and GVWR values when filled with a commodity of design density simply because of the tank being too large.; When there is reason to believe that the density of a cargo likely t be transported could present a vehicle overloading problem, the manufacturer has a duty to provide a warning and information as a precaution in averting the potential hazard. The NHTSA does not object to the practice of partial loading of tankers and tank compartments for remaining within safe loading limits provided guidelines are furnished by manufacturers for performing approved loading operations. Prescribed precautions hopefully will counteract any tendency to perceive volume as the load limiting criterion. We would agree that loading information as contained in your enclosure would be a satisfactory means of conveying safety information and could be referenced on a conspicuous vehicle label.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3389OpenMr. John M. Klinger, Sales Manager, Medallion Instruments, Inc., 917 W. Savidge Street, Spring Lake, Michigan 49456; Mr. John M. Klinger Sales Manager Medallion Instruments Inc. 917 W. Savidge Street Spring Lake Michigan 49456; Dear Mr. Klinger: This responds to your letter of December 10, 1980, to Joan Griffin o my staff regarding Safety Standard No. 127, *Speedometers and Odometers*. In your letter, you state that you manufacture speedometers and odometers for replica car manufacturers. You ask whether you can be exempted from the requirements of Standard No. 127 in light of the small number of speedometers and odometers that you sell.; The National Highway Traffic Safety Administration (NHTSA) has n authority to exempt manufacturers of motor vehicle equipment from compliance with the Federal Motor Vehicle Safety Standards. Thus, your Speedometers and odometers must comply with the requirements of Standard No. 127 that are in effect at the time of manufacture.; We hope you find this information helpful. Please contact this offic if you have any questions.; Sincerely, Frank Berndt, Chief Counsel |