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
| Interpretations | Date |
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ID: 1916yOpen Dear : This is in reply to your letter of June 30, l989, to John Donaldson of this Office titled "Request for Interpretation", submitted on behalf of your client. You request "that all identifying references to myself, my firm and [my client] in this letter and the responsive letter of interpretation" be deleted. Your request is granted on the basis that it relates to confidential business information and may be withheld under applicable Departmental regulations, 49 CFR Part 512. You describe a lamp system as follows: "The product is a headlamp consisting of a plastic lens and reflector, arc tubes (two each for high and low beam) and electronics for instant start and re-start of the headlamps as well as management of the operating current. A 12 volt connection is supplied for connection of vehicle line voltage". You have asked for a letter "confirming" that this lamp system is designed to conform to the integral beam headlamp requirements of paragraph S7.4 of Federal Motor Vehicle Safety Standard No. l08, "subject only to compliance with the appropriate photometric requirements of FMVSS l08." A headlighting system of the nature described must be designed to conform to all the pertinent requirements of S5.5, S7.1, S7.2, and S7.7, as well as S7.4, including mechanical aim and environmental requirements. However, since this headlamp does not use filaments for converting the electrical energy to light energy, certain configurations of such systems may not conform, because some requirements are predicated upon the existence of filaments (e.g., S5.5.9 and S7.4(f)). If the headlamp you describe meets all requirements, then it would appear to be an integral beam headlighting system designed to conform to S7.4. Whether the headlamp in fact meets those requirements is for the lamp manufacturer to determine, as it must assure the manufacturer of the vehicle on which it is installed that he may certify compliance of the vehicle with Standard No. l08. Further, the headlamp manufacturer itself must certify compliance of replacement equipment. If the headlamp is incompatible with these requirements and cannot meet them, then it would not appear to be an integral beam system. In that case, rulemaking would be required to accommodate it within the framework of Standard No. l08. Sincerely,
Stephen P. Wood Acting Chief Counsel / ref:l08 d:7/2l/89 |
1970 |
ID: headstart3OpenHelen H. Taylor, Associate Commissioner Dear Ms. Taylor: This responds to your request that this agency revise its interpretation of the term "school" to exclude Head Start Programs. This would allow the Department of Health and Human Services (HHS) to implement a rule requiring that Head Start children be transported in vehicles that meet the Federal school bus safety standards other than those requiring traffic control devices. I regret the delay in responding to your request. You based your request on the Coats Human Services Reauthorization Act of 1998. In that Act, Congress amended section 636 of the Head Start Act (42 U.S.C. 9831) to provide that "[i]t is the purpose of this subchapter to promote school readiness by enhancing the social and cognitive development of low-income children through the provision, to low-income families, of health, educational, nutritional, social, and other services that are determined, based on family needs assessments, to be necessary." You believe that by employing the term "school readiness," Congress was distinguishing Head Start programs from school programs. In considering your request, we reviewed the basis for our existing interpretation of Head Start as a "school." That interpretation was based on the former National Traffic and Motor Vehicle Safety Act (now codified at 49 U.S.C. 30101 et seq. ("the Vehicle Safety Act")). The Vehicle Safety Act defines "schoolbus" to mean a passenger motor vehicle designed to carry a driver and more than 10 passengers, that the Secretary of Transportation decides is likely to be used significantly to transport preprimary, primary, and secondary school students to or from school or an event related to school. (49 U.S.C. 30125(a)(1)) In applying the term to Head Start, we equated the provision of educational services with the status of being a school, and concluded that Head Start programs were functioning as preprimary schools. On December 29, 1977, NHTSA issued an opinion that Head Start facilities are functioning as preprimary schools, and that buses transporting children to and from those schools are functioning as school buses, under the Vehicle Safety Act and accordingly are subject to the Federal school bus safety standards. Specifically, the letter stated: NHTSA interprets the term "school" broadly, because the agency believes that this is the intent of the Motor Vehicle and School Bus Safety Amendments of 1974 (Pub. L. 93-492) which directed the creation of the school bus safety standards. Since the Head Start program is basically an educational program for preprimary students, the agency had determined that those facilities are schools and buses transporting children to and from them must comply with the Federal school bus safety requirements if they transport 10 or more passengers. Subsequently, in a May 10, 1982, opinion, we distinguished day care centers from Head Start facilities on the basis that "facilities which are essentially custodial, even though they have some educational components, are not considered to be schools." In light of the 1998 amendment to section 636 of the Head Start Act, we have concluded that the linkage we have made in the case of Head Start between educational services and schools is no longer valid. We believe that it is clear from the language of that section that Congress has made a distinction between Head Start programs and school programs. Accordingly, we are revising our interpretation of "school" to exclude Head Start. Consistent with the evident intent of section 636, we conclude that a Head Start agency is not operating a "school" for the purposes of the Vehicle Safety Act. This means that buses sold to transport children to and from a Head Start site will no longer be required under the Vehicle Safety Act to meet the Federal motor vehicle safety standards applicable to school buses. In revising our interpretation, we act with the knowledge that HHS intends to implement a rule requiring that Head Start children be transported in vehicles meeting the Federal school bus safety standards other than those for traffic control devices. This will serve to ensure the children's safety. Sincerely, Frank Seales, Jr. ref:VSA |
2000 |
ID: nht92-1.18OpenDATE: 12/17/92 FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA TO: DOUGLAS BERG -- PRESIDENT, ASCEND PRODUCTIONS ATTACHMT: ATTACHED TO LETTER DATED 10-12-92 FROM DOUGLAS BERG TO PAUL J. RICE (OCC 7896) TEXT: This responds to your letter asking whether Standard No. 125, Warning Devices, applies to your product, the "Hazard Helper Safety Sign." In an earlier letter to the agency, you stated that this reversible device attaches to the driver's window and displays either a help needed symbol (a stick figure with extended arms and legs) or a hazard alert symbol (a triangle). In my July 28, 1992 response, I explained that your device was subject to the Standard and that it appeared not to comply with certain provisions in the Standard. In a subsequent letter, you explain that you have added a cyalume light stick to your product to illuminate the warning sign. As explained below, you are correct in your belief that your warning device containing a light stick would no longer be subject to Standard No. 125. As you correctly stated, Standard No. 125 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; see section S3) In other words, Standard No. 125 does not apply to warning devices with self-contained energy sources. In an August 10, 1982 interpretation to Dwight Hicks, Jr., the agency determined that the phrase "self-contained energy sources" includes such things as cyalume light sticks. Accordingly, a warning device to which a cyalume light stick was added would not be subject to Standard No. 125 I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. |
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ID: 7896Open Mr. Douglas Berg Dear Mr. Berg: This responds to your letter asking whether Standard No. 125, Warning Devices, applies to your product, the "Hazard Helper Safety Sign." In an earlier letter to the agency, you stated that this reversible device attaches to the driver's window and displays either a help needed symbol (a stick figure with extended arms and legs) or a hazard alert symbol (a triangle). In my July 28, 1992 response, I explained that your device was subject to the Standard and that it appeared not to comply with certain provisions in the Standard. In a subsequent letter, you explain that you have added a cyalume light stick to your product to illuminate the warning sign. As explained below, you are correct in your belief that your warning device containing a light stick would no longer be subject to Standard No. 125. As you correctly stated, Standard No. 125 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; see section S3) In other words, Standard No. 125 does not apply to warning devices with self-contained energy sources. In an August 10, 1982 interpretation to Dwight Hicks, Jr., the agency determined that the phrase "self-contained energy sources" includes such things as cyalume light sticks. Accordingly, a warning device to which a cyalume light stick was added would not be subject to Standard No. 125. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely,
Paul Jackson Rice Chief Counsel ref:125 d:12/17/92 |
1992 |
ID: nht71-5.31OpenDATE: 12/27/71 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Crane Carrier Company TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of November 16 and 30, 1971, concerning the application of Federal Motor Vehicle Safety Standard No. 206 to heavy duty trucks. You reported that you are unlikely to be able to bring the side door locks and latches on your truck into conformity with the standard until mid-1972. In your first letter, you asked whether the standard will apply to all trucks or only those having a GVWR of more than 10,000 pounds. The standard will apply, beginning January 1, 1972, to all trucks without regard to their GVWR. In your second letter, you requested for your trucks a temporary exemption of 180 days from the standard. We regret that we are unable to consider your request, since our authority under section 123 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410) to grant such exemptions expired in April of this year. Beginning January 1, 1972, the manufacture of any truck not in compliance with Standard 206 will be prohibited. Section 108(a) of the Act provides that "No person shall manufacture for sale . . . any motor vehicle . . . manufactured on or after the date any applicable . . . standard takes effect . . . unless it is in conformity with such standard . . ." (15 U.S.C. 1397) This prohibition is enforceable by civil penalties under section 109 (15 U.S.C. 1398) and injunction under section 110 (15 U.S.C. 1399). In addition, in the event that a noncompliance were determined to be a safety-related defect, notification of the defect would have to be furnished under section 113 (15 U.S.C. 1402). Let us know if we may be of further assistance. |
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ID: Cardinali1OpenMr. Alex Cardinali Office of Government Affairs Nissan North America, Inc. 196 Van Buren Street, Suite 450 Herndon, VA 20170 Dear Mr. Cardinali: This responds to your e-mail requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. Specifically, you asked which version of the Society of Automotive Engineers (SAE) Recommended Practice J941, Motor Vehicle Drivers Eye Locations, is applicable for compliance purposes. As you correctly observed, S3.2(c) of FMVSS No. 205 incorporates by reference SAE J100 (rev. June 1995), Class A Vehicle Glazing Shade Bands, which in turn subreferences SAE J941 without mentioning any specific version. Accordingly, you stated that you are unsure whether you should use the latest version of SAE J941 (rev. September 2002) or the earlier version (rev. June 1997). As explained below, because a specific revision of that SAE standard is not cited or otherwise discussed in the rulemaking, the applicable version of SAE J941 for compliance purposes would be the version in effect at the time the comment period closed on the notice of proposed rulemaking (NPRM) proposing to incorporate SAE J100 into the standard (i.e., rev. June 1997). By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment. One of those standards is FMVSS No. 205, which specifies performance requirements for various types of glazing. We further note that under 49 CFR 571.5(a), our regulations provide, in pertinent part, For materials subject to change, only the specific version approved by the Director of the Federal Register and specified in the standard are incorporated. Once approved, copies of such materials are kept on file by the Office of the Federal Register. In the present case, the agency published an NPRM in the Federal Register on August 4, 1999, that proposed to upgrade Standard No. 205, one aspect of which involved incorporation by reference of SAE J100 (rev. June 1995)(see 64 FR 42330, 42335). The comment period on that NPRM lasted until October 4, 1999. Subsequently, a final rule was published in the Federal Register on July 25, 2003, which included the amendment incorporating SAE J100 (rev. June 1995) into the standard (see 68 FR 43964, 43972). Again, SAE J100 subreferences SAE J941 without a specific revision date. No public comments were received on this issue. As you are aware, NHTSA routinely draws upon the technical expertise of SAE and other standards, as appropriate. SAE (a group comprised of technical experts, including ones from industry) develops and maintains a system of standards which are constantly being revised and updated to reflect changing technologies and scientific understanding. We note, however, that compliance with an SAE standard is voluntary, unless the standard is adopted by a government agency. Furthermore, it is our understanding that, in light of that organizations procedures for regular updates of its standards, SAE decided not to cite specific revision dates for subreferenced standards, instead intending the most current revised version to be used. In contrast, NHTSA adopts binding regulatory requirements, which may include all or parts of standards incorporated by reference from other sources. The agency adopts requirements only after an opportunity for public notice and comment. Consistent with the requirement of 49 CFR 571.5(a) mentioned above, the agency cites the specific version of the materials to be incorporated by reference into our standards in order to provide certainty to regulated parties regarding applicable regulatory requirements. Otherwise, subsequent revisions to SAE standards (or similar standards) would impermissibly allow outside organizations to modify our FMVSSs through changes in their documents. With that said, we now turn to the specific issue raised in your letter. In the case where a subreferenced SAE standard does not identify a specific, relevant version, we conclude that the correct version for compliance purposes would be the most recent version of that standard in effect at the close of the comment period of the NPRM proposing the incorporation by reference. Our reasoning is as follows. In light of the ambiguity surrounding which version of a subreferenced SAE standard is to be used, it is logical to expect the agency and the public to have consulted the latest version of the subreferenced standard as they respectively develop and comment on the NPRM. This principle recognizes both SAEs intention for stakeholders to use the most recent version of its standards, and the agencys need to avoid incorporation of any subsequent version which would not have been available to receive the benefit of public comment (e.g., one adopted in the time period between publication of the NPRM and the final rule, or thereafter). We note, however, that if public commenters did raise the issue of the revision date of any standard incorporated by reference (e.g., either an earlier version, or a soon-to-be-published version available in draft), the agency could choose a different version in the final rule, although it would likely do so explicitly. In light of the above, the June 1997 revision of SAE J941 is the applicable version for purposes of FMVSS No. 205, because it was the one in effect at the end of the comment period for the proposal to incorporate SAE J100 by reference into that standard. As a related matter, we note that in analyzing the issues presented in your e-mail, we discovered an inconsistency in the version of SAE J100 incorporated by reference under S3.2(c) (i.e., rev. June 1995) and the version recited in the requirements of S5.3.1 (i.e., rev. November 1999). We understand that these two versions are substantively identical, with the latter version simply being a reaffirmation of the earlier standard pursuant to SAEs periodic review process. The agency plans to issue a correcting amendment in the near future to resolve this discrepancy. If you have any further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel ref:205 d.11/13/06 |
2006 |
ID: 21067.ztvOpenJohn F. Letchford, Esq. Dear Mr. Letchford: This is in reply to your letter of November 30, 1999, with respect to whether "a device that causes the backup lamps to steadily burn for a few seconds upon actuation of the horn would violate" 49 CFR 571.108 ( Federal Motor Vehicle Safety Standard No. 108). Specifically, the device would cause the upper beam of a vehicle's headlamps to flash and "backup lights to illuminate and burn steadily" for three seconds or less, when the vehicle's horn is sounded. The purpose of the device is to provide a visual warning to others in front of or behind a vehicle of a potential danger or threat requiring an audible warning, i.e, use of the horn. You have cited S5.5.10(b) of Standard No. 108 which permits headlamps to be wired to flash for signaling purposes, but you are concerned with S5.5.10(d) that requires all other lamps to be wired to be steady burning. S4 of Standard No. 108 defines "flash" as a "cycle of activation and deactivation of a lamp by automatic means . . . ." We would not regard a backup lamp that illuminated steadily for three seconds or less to be a lamp that is not steady burning within the meaning of S5.5.10(d), or flashing, within the definition of S4. However, the determinative question is whether a backup lamp can be used for purposes other than to indicate a reverse movement of the vehicle. The answer is no. See SAE Standard J593c, Backup Lamps, February 1968, which Tables I and III of Standard No. 108 incorporate by reference (copy enclosed). Paragraph 2 of Installation Requirements states that "Backup lamps shall not be lighted when the vehicle is in forward motion." It is clear that the device you discuss is intended to be used under normal operating conditions of the vehicle on the public roads, and that its installation would create a noncompliance with Standard No. 108. We appreciate your client's interest in motor vehicle safety and regret that we cannot provide the letter you requested. If you have any questions, you may call Taylor Vinson of this Office (202-366-5263). Sincerely, |
2000 |
ID: 21269.ztvOpenMr. Michael Borbath Dear Mr. Borbath: We are responding to your letter of February 2, 2000, to our agency, asking several questions relating to importation of an Indian Enfield motorcycle from India. You relate that you are "almost certain that Enfield has no documentation that proves their bikes adhere to US DOT specs." In order to enter the United States, a motorcycle must have been manufactured to conform with all applicable Federal motor vehicle safety standards (FMVSS), and bear the manufacturer's certification of compliance with those standards. The process of importing a machine that was not manufactured to conform is not impossible, but it is cumbersome, time consuming, and expensive. First, you will have to contract with a registered importer to act on your behalf. The registered importer must then petition us for a determination that the Enfield is capable of being conformed to meet all applicable FMVSS. If we agree that the Enfield is capable of conversion, you may then import the Enfield under bond, and the registered importer must then conform and certify the vehicle within 120 days of entry. When the registered importer certifies to us that the Enfield has been brought into compliance, it must hold the vehicle until we release the bond, or until 30 days pass, whichever first occurs. At that time, the registered importer can release the vehicle. If we do not agree that the Enfield is capable of conversion, it cannot be imported permanently (If you are only temporarily in the United States before reassignment outside the country, it may be possible for you to import a non-conforming Enfield for the duration of your stay here, provided that it is not longer than one year). I enclose a list of registered importers who have had experience in filing petitions for conformance capability determinations, and some information on the FMVSS that apply to motorcycles. You also asked about "the conditions for importing a 'classic or historic bike' from India" and how we define those terms. Any motor vehicle that is at least 25 years old, including a motorcycle, is not required to conform to the FMVSS. This means that Enfields manufactured in 1975 and earlier may be directly imported by their owners. We have recently been given the statutory authority to allow permanent importation of noncomplying vehicles for purposes of "show or display" without the necessity of conforming them to the FMVSS. This would apply to vehicles manufactured in 1976 and later. In this circumstance, an importer is not required to use the services of a registered importer, and may directly ask us for approval. We are interpreting this authority as permitting admission of vehicles only of technological or historical significance, according to such arguments as the prospective importer wishes to make. Further, we are not allowing importation under "show or display" of vehicles still in production unless the importer is the manufacturer itself. Under certain circumstances, we will also approve limited use of a "show or display" vehicle on the public roads (e.g., up to 2,500 miles a year). I have provided you a summary of our programs. If you would like further details on these programs, please call Taylor Vinson of this Office (202-366-5263). You may also e-mail him at Tvinson@nhtsa.dot.gov Sincerely, |
2000 |
ID: 8578Open Mr. Patrick P. Radice Dear Mr. Radice: We have received your undated letter with respect to certification of aftermarket flashers. You understand that manufacturers of aftermarket turn signal flashers and hazard warning signal flashers must certify that the flashers comply with the applicable requirements of Federal Motor Vehicle Safety Standard No. 108 prior to sale. However, when a vehicle is equipped with a combination turn signal/hazard warning signal flasher, you ask whether the manufacturer of the replacement flasher must certify compliance with requirements for both flashers, or can certify the flasher to "meet either the turn signal flasher or hazard warning signal flasher of FMVSS-108 but not both?" Paragraph S5.8.1 (formerly S5.7.1) of Standard No. 108 requires that each item of lighting equipment manufactured to replace any item of lighting equipment on any vehicle to which Standard No. 108 applies shall be designed to conform to Standard No. 108. Therefore, a combination turn signal/hazard warning signal flasher that is manufactured to replace a combination turn signal/hazard warning signal flasher must be designed to conform to requirements applicable to both turn signal flashers and hazard warning signal flashers. Paragraph S5.8.2 permits replacement lighting equipment to be labelled with the symbol DOT, constituting a certification of compliance to applicable Federal motor vehicle safety standards (although the manufacturer may certify by a label or tag affixed to the flasher or the container in which it is shipped). The "applicable Federal motor vehicle safety standards" for a combination turn signal/hazard warning signal flasher are those portions of Standard No. 108 that specify requirements for turn signal flashers and hazard warning signal flashers. The manufacturer's certification must therefore cover both. I hope this explains the matter for you. Sincerely,
John Womack Acting Chief Counsel ref:108 d:4/5/93 NCC-20 ZTVinson:mar:4/26/93:62992:OCC 8578 cc: NCC-0l Subj/Chron ZTVinson Interps/.Std. 108 8578; ztv; U:\ncc20\interp\108\8578.ztv |
1993 |
ID: nht93-7.1OpenDATE: September 29, 1993 FROM: Nicholas S. Copass -- Sales Manager, Titeflex Industrial Americas TO: David Elias -- Chief Counsel, Department of Transportation TITLE: None ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Nicholas S. Copass (A42; Std. 106), letter dated 3/6/91 from Anthony Lalikos to Vernon G. Bloom, and letter dated 3/18/91 from Arthur H. Neill, Jr. to Anthony J. Lalikos TEXT:
Enclosed per our phone conversation on September 29th, is the information discussed pertaining to our licensed assembler of, Department of Transportation qualified break hoses, Federal Motor Vehicle Safety Standard MVSS 106. Titeflex is the manufacturer of he referenced Teflon break line assembly that has been recognized and accepted by the Department of Transportation, Arthur H. Neill, Jr. Chief Crash Avoidance Division, Vehicle Safety Standards. Reference: "stylized logo" (=T with hose tail). T Titeflex has a licensed agreement with Russell Performance to provide fabrication of the said Teflon break line assemblies with the required Titeflex components. At time of agreement Russell Performance provided completed assemblies to Titeflex for verification of compliance to the Department of Transportation Standard MVSS 106. Compliance verification has since been completed and documented. License will use the Titeflex "stylized logo" on all assemblies and on all packaging in accordance with the guidelines of the Department of Transportation, MVSS 106. The essence of the above information is to receive a written response in regards to our licensed fabricator having to register their logo or become registered by the Department of Transportation. Titeflex understands the nature of being the manufacture of the above product and claims its responsibility. Copies of Titeflex logo and acceptance are included for your convenience. Again, thank you for your considerable time and cooperation.
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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.