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.”
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NHTSA's Interpretation Files Search
| Interpretations | Date |
|---|---|
ID: 1982-2.22OpenDATE: 07/23/82 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Regal Tire Corporation TITLE: FMVSS INTERPRETATION TEXT:
July 23, 1983
Regal Tire Corporation 4309 County Line Road Chalfont, PA 18914
Dear Sir:
At the request of the office of the Honorable Peter Peyser, M.C., we are writing this letter to you to explain the significance of certain items of information molded on the sidewall of new tires. Part 574, Tire identification and recordkeeping (49 CFR 574), requires that each new tire to be sold in the United States have a serial number molded on one of its sidewalls. That number identifies the tire's manufacturer, date of manufacture, and size. This information is designed to ensure the proper identification of all tires subject to a recall by the manufacturer for correction of a safety-related defect or of a failure to comply with a safety standard. The serial number is not a guarantee of quality or of compliance with any safety standard.
Each new tire is also required by Federal Motor Vehicle Safety Standards Nos. 109, New pneumatic tires, and 119, New pneumatic tires for vehicles other than passenger cars (49 CFR 571.109 and 571.119), to have the symbol "DOT" appear on one of its sidewalls. This symbol is a certification by the tire's manufacturer that the tire fully complies with all requirements of the applicable safety standard. The symbol does not guarantee the quality of a tire in areas of performance unregulated by the safety standards. Neither the serial number nor the DOT symbol constitute a representation that a tire is free from any safety-related defect. If you have any questions regarding these matters, please contact me.
Sincerely,
Frank Berndt Chief Counsel June 2, 1982
Ms. Carol Walls U. S. Dept. of Transportation Office of Congressional Relations 400 7th Street, SW Room 10408 Washington, D.C. 20590
Dear Ms. Walls:
Attached is the request for certification about which we spoke today. Regal Tire is interested in receiving a letter or other appropriate document on DOT letterhead confirming the intent of the DOT serial number on the tires themselves.
Thank you for your help in this matter.
Sincerely,
F. H. Brewer, III Administrative Assistant to the Congressman
FHB/lb
CERTIFICATE
TO WHOM IT MAY CONCERN:
WE CONFIRM THAT TIRES MANUFACTURED IN U.S.A. HAVING D.O.T. SERIAL NUMBERS BRANDED ON SIDEWALL MEANS FOLLOWING:
A. EACH TIRE MEETS OR EXCEEDS U. S. DEPARTMENT OF TRANSPORTATION SAFETY STANDARDS.
B. EACH TIRE HAS BEEN TESTED AND GUARANTEED BY MANUFACTURER TO THE U.S. DEPARTMENT OF TRANSPORTATION THAT IT IS FREE FROM ANY DEFECT AND OF FIRST QUALITY. |
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ID: 11704.WKMOpen Richard E. Trachtenberg, Esq. Dear Mr. Trachtenberg: This responds to your letter of March 27, 1996 addressed to Walter Myers of my staff. You provide what you think may be tire identification number (TIN) 5R5691439T and ask us to verify that the number is a TIN and if so, provide you the information that it represents. You also state that the tire may be a retreaded tire. Our answer is that this number does not appear to be a TIN. Title 49, Code of Federal Regulations, Part 574.5 establishes the requirement for TINs and specifies the information to be contained therein as well as the format and sequence of such information. Part 574.5 requires that the TIN be composed of four groups of symbols, letters and/or numbers. The first grouping, composed of two or three symbols, represents the manufacturer's identification mark assigned by this agency in accordance with Part 574.6. The second and third groupings identify the tire size and significant characteristics of the tire respectively, both at the option of the manufacturer. The fourth grouping of three symbols shows the week and year of manufacture. The series of numbers and letters in question, 5R5691439T, do not comply with the requirements of Part 574.5. The first two or three characters, A5R@ or A5R5, have not been assigned by this agency. New tires are assigned a two-character code which may be either two letters or a number and a letter, for example ABA@ or A1B.@ Retreaded tires are assigned a three-letter code, such as ACJX.@ The numbers "439" could represent the manufacturing date, for example the 43d week of 1989, but there is no provision in the regulation for a "T" at the end of the TIN. Thus, these numbers and letters do not comply with the TIN requirements of Part 574.5, and this agency has no record of or information on this particular series of numbers and letters.
I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely,
Samuel J. Dubbin Chief Counsel Ref:574 d:5/1/96
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1996 |
ID: 11704R.WKMOpen Richard E. Trachtenberg, Esq. Dear Mr. Trachtenberg: This letter supersedes my letter to you of May 1, 1996, which contains a transcription error. This responds to your letter of March 27, 1996, addressed to Walter Myers of my staff. You provide what you think may be tire identification number (TIN) 5R5691439T and ask us to verify that the number is a TIN and if so, provide you the information that it represents. You also state that the tire may be a retreaded tire. Our answer is that this number does not appear to be a TIN. Title 49, Code of Federal Regulations, Part 574.5 establishes the requirement for TINs and specifies the information to be contained therein as well as the format and sequence of such information. Part 574.5 requires that the TIN be composed of four groups of symbols, letters and/or numbers. The first grouping, composed of two or three symbols, represents the manufacturer's identification mark assigned by this agency in accordance with Part 574.6. The second and third groupings identify the tire size and significant characteristics of the tire respectively, both at the option of the manufacturer. The fourth grouping of three symbols shows the week and year of manufacture. The series of numbers and letters in question, 5R5691439T, do not comply with the requirements of Part 574.5. The first two or three characters, A5R@ or A5R5, have not been assigned by this agency. New tires are assigned a two-character code which may be either two letters or a number and a letter, for example ABA@ or A1B.@ Retreaded tires are assigned a three-letter code, such as ACJX.@ The numbers "439" could represent the manufacturing date, for example the 43d week of 1989, but there is no provision in the regulation for a "T" at the end of the TIN. Thus, these numbers and letters do not comply with the TIN requirements of Part 574.5, and this agency has no record of or information on this particular series of numbers and letters. I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely,
Samuel J. Dubbin Chief Counsel ref:574 d:6/18/96 2
|
1996 |
ID: 06-005956asOpenMr.Carl Dietrich CEO/CTO Terrafugia, Inc. 25 Mason Street, Somerville, MA 02144 Dear Mr. Dietrich: This is in response to your letter of August 29, 2006, in which you asked if the Transition roadable aircraft would be classified as a motor vehicle. As explained below, our answer is yes. By way of background, the National Highway Traffic Safety Administration (NHTSA) has the authority under the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. 30101 et seq.) to regulate motor vehicle safety. The Safety Act at 30102(a)(6) defines "motor vehicle" as: A vehicle driven or drawn by mechanical power manufactured primarily for use on public streets, roads and highways, but does not include a vehicle operated only on a rail line. In your letter, you state that the Transition is an airplane that is capable of folding its wings and driving down the road to the pilots home or destination. In addition, the illustrations you provide with your letter show the Transition driving on a public highway with other traffic. As it is both capable of and intended for use on the public streets, roads and highways (public roads), the Transition would be considered a motor vehicle and subject to the applicable safety regulations. You indicate in your letter that you believe the Transition should not be considered a motor vehicle because motor vehicles are manufactured primarily for use on public streets, while on the typical trip of 350 miles a Transition would spend only 18% of its time on land, spending the rest of the time in the air. Thus, you claim that the Transition is manufactured primarily for flight and not primarily for use on public roads. We take a broader interpretation of the word primarily. Whether a vehicle is a motor vehicle under the Vehicle Safety Act depends on its intended or likely use on the public roads, and not on whether use on public roads constitutes a majority of its operating time. The word primarily refers to use on public roadways as a primary purpose of the vehicle, as opposed to on-road use that is merely incidental. It is clear from the design of the Transition and from your letter that the on-road use of the vehicle is one of the primary functions for which the vehicle was manufactured. As this vehicle will spend a substantial amount of time on public roads, and was manufactured to do so, NHTSA will consider the Transition a motor vehicle. This vehicle is intended for use in two modes of transportation, i.e. highway and aviation. The statute excludes on those vehicles that are used exclusively on a rail line. When on the ground, the vehicle is driven by mechanical power and, unlike other vehicles capable of flight that are intended to be driven only on runways and taxiways, the primary purpose of this vehicles being driven is for use on public roads. This interpretation is consistent with others issued by this office in the past. A February 16, 1982, letter to Mr. Roger Olander stated that a three-wheel flying car was a motor vehicle under the Safety Act. Our January 24, 2006, letter to Mr. Paul Larkin stated that an amphibious vehicle was considered a motor vehicle. Copies of these letters are enclosed. If you have any additional questions, please contact Ari Scott of my staff at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel 2 Enclosures ref:571 d.10/26/06 |
2006 |
ID: nht90-3.26OpenTYPE: Interpretation-NHTSA DATE: July 23, 1990 FROM: Timothy Murphy -- Chairman Engineering Committee - Lights, Transportation Safety Equipment Institute, Peterson Manufacturing Company TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated August 31, 1990 from P.J. Rice to T. Murphy (A36; Std. 108) TEXT: The Engineering Committee of the Transportation Safety Equipment Institute (TSEI) has reviewed your letter of February 26, 1990 to the Bargman Company. This specific letter was in response to a question from Bargman dated December 13, 1989 in which they specifically asked if an amber reflex reflector was permitted as an additional reflector on the rear of vehicles covered by FMVSS108. Your conclusion was that the installation of an amber tail lamp lens with an amber reflector would not constitute a noncompliance with Standard No. 108. We respectfully disagree for the reasons stated below. You are correct in your statement that no additional reflective device may be installed that impairs the effectiveness of reflective equipment required by Standard No. 108. You then state, "It does not appear to us that an amber tail lamp lens with an a mber reflector would create an impairment." While amber is a permissible color for rear turn signal lamps, the referenced rear turn signal lamp is a flashing device. We are unaware of any state law or federal law which permits a steady burning amber signal to the rear and, therefore, your interpr etation is a distinct departure from past practice. We respectfully suggest that a steady burning lamp or reflector to the rear clearly would create confusion for following drivers. For example, on vehicles under 80 inches wide, the only devices required on the rear are two tail lamps and two rear red re flectors which are, in effect, operable at all times. That is, they are steady burning and represent a continuous signal. If one now introduces two additional amber reflectors, following motorists would then see the two required red tail lamps and two amber reflectors which would be about 2 1/2 times brighter than the required red reflectors if we consider the luminous tran smission difference between the red and amber colors. In short, the amber auxiliary add-on reflectors would normally be much brighter (by a factor of 2 1/2 times) than the required red reflector. It is our strong and unanimous conclusion that this woul d certainly represent an impairment of a required device. The states of California, Michigan, Minnesota, Pennsylvania, and many other states, clearly specify that reflectors, visible from the rear of a vehicle, shall be red. We know of no instance where amber rear reflex is specifically permitted by any state. The last sentence in your February 26th letter to the Bargman Company states, "This agency presently has no plans to specify yellow as an alternate color for rear reflex reflectors." We suggest that an agency interpretation letter which permits yellow o r amber reflex reflectors on the rear of a vehicle could be the source of considerable confusion. For example, a manufacturer might elect to install an auxiliary amber reflex on the rear of a vehicle manufactured in a state where the law is silent on th e subject of rear reflex color. However, when the user then travels to one of the many states which clearly prohibit steady burning amber lamps or reflex to the rear, they may find themselves subject to violations of specific state laws. You should als o consider that if amber rear reflex is permitted as an auxiliary add-on device, the next logical step might well be a steady burning amber auxiliary lamp on the rear of vehicles. We submit that such color to the rear would create an obvious impairment of the required devices. For the reasons outlined above, we would ask that you review the February 6, 1990 interpretation. |
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ID: 8589rOpen Dr. Thomas Lckemeyer FAX 07142/73 28 95 Dear Dr. Lckemeyer: As you have requested, we are responding by FAX to your FAX letter of June 25, 1993, to Taylor Vinson of this Office. Our FAX letter to you of May 28, 1993, provided an interpretation of SAE J588 NOV84, incorporated by reference in Federal Motor Vehicle Safety Standard No. 108. You mention the l990 SAE Ground Vehicle Lighting Manual which refers to SAE J588 September l970, and ask which is the correct SAE reference. Standard No. 108 was amended with an effective date of December 1, 1990, to substitute "SAE J588 NOV84" for "SAE J588 September 1970" as the U.S. Federal requirement for turn signal lamps used as original equipment on passenger cars and other motor vehicles with an overall width of less than 80 inches overall width. Turn signal lamps may still be manufactured to the requirements of "SAE J588 September 1970" if they are intended to replace original equipment turn signal lamps that were manufactured in accordance with "SAE J588 September 1970." We understand that your earlier letter asked for an interpretation of Standard No. 108 as it related to the design of lamps for future production, and trust that this answers your question. As you have requested, we are also FAXing a copy of Table III. Sincerely,
John Womack Acting Chief Counsel ref:108 d:7/8/93 |
1993 |
ID: 3263oOpen Mr. A.J. Ackley Dear Mr. Ackley: This is in response to your letter of May 26, 1988, in which you asked whether this agency anticipated any legal problems with the design of your proposed safety triangle. You noted in your letter and in an accompanying diagram that the design of your product might differ from the typical design of a warning triangle because you intended to include a company's logo (the letter "T" in a star) within the safety triangle. I apologize for the delay in our response. Your proposed product would be subject to Safety Standard No. 125, Warning Devices (49 CFR 571.125, Copy enclosed). This standard establishes requirements for devices that are designed to be carried in motor vehicles, and used to warn approaching traffic of the presence of a stopped vehicle. Paragraph S5.2.6 states that The device shall consist entirely of the triangular portion and attachments necessary for its support and enclosure, without additional visible shapes or attachments. (emphasis added) The standard's express prohibition against "additional visible shapes or attachments" indicates that your proposal to include a logo in the center of the warning device would violate the safety standard. As a result, you could not legally market this product. The Safety Act provides for a civil penalty of $1,000 for each violation of a safety standard and a maximum penalty of $800,000 for a series of violations. In addition, the Safety Act requires manufacturers to remedy their products if they fail to comply with all applicable safety standards. I hope this information is helpful. Sincerely,
Erika Z. Jones Chief Counsel Enclosure ref:125 d:l2/8/88 |
1988 |
ID: 3316oOpen Mr. A.J. Ackley Dear Mr. Ackley: This is in response to your letter of May 26, 1988, in which you asked whether this agency anticipated any legal problems with the design of your proposed safety triangle. You noted in your letter and in an accompanying diagram that the design of your product might differ from the typical design of a warning triangle because you intended to include a company's logo (the letter "T" in a star) within the safety triangle. I apologize for the delay in our response. Your proposed product would be subject to Safety Standard No. 125, Warning Devices (49 CFR 571.125, Copy enclosed). This standard establishes requirements for devices that are designed to be carried in motor vehicles, and used to warn approaching traffic of the presence of a stopped vehicle. Paragraph S5.2.6 states that The device shall consist entirely of the triangular portion and attachments necessary for its support and enclosure, without additional visible shapes or attachments. (emphasis added) The standard's express prohibition against "additional visible shapes or attachments" indicates that your proposal to include a logo in the center of the warning device would violate the safety standard. As a result, you could not legally market this product. The Safety Act provides for a civil penalty of $1,000 for each violation of a safety standard and a maximum penalty of $800,000 for a series of violations. In addition, the Safety Act requires manufacturers to remedy their products if they fail to comply with all applicable safety standards. I hope this information is helpful. Sincerely,
Erika Z. Jones Chief Counsel Enclosure /ref:125 d:12/8/88 |
1988 |
ID: nht78-2.49OpenDATE: 01/05/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Kelsey-Hayes Company TITLE: FMVSS INTERPRETATION TEXT: This responds to Kelsey-Hayes' September 2, 1977, request to know whether Standard No. 121, Air Brake Systems, allows a burnish of the brake friction elements immediately prior to the parking brake tests of S5.6, and whether the service line air pressure limitation of 100 p.s.i. specified in S5.4.2.1 can be exceeded monentarily. A burnish prior to the parking brake test is not permitted by Standard No. 121, except that S6.1.8 specifies burnish of the parking brake friction elements before testing in those cases where the parking brake system does not utilize the service brake friction elements. The National Highway Traffic Safety Administration (NHTSA) would consider a provision to deal with the condition of the brake linings prior to the parking brake test upon receipt of technical data showing justification for such an action. Section S5.4.2.1 of the standard specifies a procedure that states "[the] service line air pressure shall not exceed 100 p.s.i. during any deceleration." You describe a condition in which the service line pressure exceeds 100 p.s.i. for a short period (typically 0.1 seconds), which might be traced to characteristics of the friction material, brake mechanism, dynamometer, or instrumentation. The NHTSA recognizes that peak pressure may be momentarily increased by the initial rush of air pressure into the brake chamber, or by other anomolies. In the case of such momentary pressure increases, the NHTSA interprets S5.4.2.1 to mean that the source of air pressure for applying the brake must never exceed 100 p.s.i. Thus, it would be permissible to experience momentary pressures above 100 p.s.i. in the service line as long as the pressure source never exceeds that level. Sustained periods of pressure above 100 p.s.i. would not be permissible. SINCERELY, KELSEY-HAYES COMPANY September 2, 1977 Joseph J. Levin, Jr. National Highway Traffic Safety Administration RE: Request for Interpretation FMVSS-121, Air Brake Systems @ 5.3.1 Stopping Distance-Trucks and Buses Kelsey-Hayes Company, a domestic manufacturer of motor vehicle equipment including antilock systems, requests an interpretation of the above referenced section of Standard 121. It is the nature of newly manufactured braking systems to have residual coatings of various materials deposited upon the brake components together with surface irregularities as a result of the manufacturing process. FMVSS-121, as well as FMVSS-105, allow for this by providing burnish stops to remove foreign substances and to condition brake linings at the outset of the testing sequence. In addition to the initial burnish, some test procedures including FMVSS-105 specify burnishing at specific intervals during the test. Reburnishes at specific intervals are provided in recognition of the fact that a rapid series of test stops will generate high temperatures and cause surface glazing on the brake lining material. To accurately gauge the effectiveness of the braking system, FMVSS-105 allows the brakes to be reburnished before the parking brake test. While perhaps not intended by FMVSS-105, the snub burnish procedure has the effect of paralleling actual vehicle use as it is normal to expect a driver to apply the service brakes in a routine fashion prior to parking the vehicle. No identical language appears in FMVSS-121, although Table 1-Stopping Sequence does provide for a burnish in its initial step. The authors of FMVSS-105 recognized the abnormal conditions which develop during the harsh testing sequence. Further, they recognized that lining surface glazing will impair the holding characteristics of a braking system, perhaps to the extent that an otherwise completely adequate design will fail this standard for an unintended reason. It is with these thoughts in mind that Kelsey-Hayes Company respectfully requests an interpretation by the NHTSA as to whether step 1 of Table 1 of FMVSS-121 will allow a burnish of the parking brakes immediately prior to step 5-parking brake test. Thank you for your consideration. David M. Thompson |
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ID: nht76-4.13OpenDATE: 06/29/76 FROM: AUTHOR UNAVAILABLE; John Womack for F. Berndt; NHTSA TO: Peterbilt Motors Company TITLE: FMVSS INTERPRETATION TEXT: This responds to Peterbilt Motor Company's June 9, 1976, questions whether Standard No. 121, Air Brake Systems, contains a permanent exclusion for "auto transporters" and whether "auto transporter" would include a truck-trailer vehicle combination that includes a dromedary forward of the fifth wheel to hold empty tin cans that are loaded by means of the trailer. I would like to note that I am unaware of "discussion and interpretive rulings suggested through telephone contact" with this office. Your interpretation is not correct that the exclusion for "auto transporters" is permanent. Some confusion may arise from the words used in S3 to describe the exclusion until September 1, 1977. The phrase "or to any vehicle which" that appears at the end of the second sentence in S3 will shortly be modified to "or that" to improve the structure and clarity of the sentence. Your question whether a "can hauler" qualifies as an "auto transporter" appears to be based on the proposed wording of this definition that was modified in final form. As defined in the standard, "auto transporter" means: . . . a truck and a trailer designed for use in combination to transport motor vehicles, in that the towing vehicle is designed to carry cargo at a location other than the fifth wheel and to load this cargo only by means of the towed vehicle. It is clear from this definition that a "can hauler" would not qualify as an "auto transporter" subject to the exclusion. Sincerely, ATTACH. Peterbilt MOTORS COMPANY June 9, 1976 OFFICE OF CHIEF COUNSEL -- National Highway Traffic Safety Administration Re: FMVSS 121 Air Brake Systems Gentlemen: Peterbilt Motors Company is the manufacturer of the custom built, heavy duty, Class 8 trucks and truck-tractors identified by the "Peterbilt" nameplate. As such, we have received inquiries regarding the constructing of specialized vehicles concerning which we find conflicting information stipulated in FMVSS 121. This letter is to substantiate and record the substance of discussion and interpretive rulings suggested through telephone contact with your office. As we interpret the wording of S3. Application, vehicles referred to as "auto transporter" are exempt from the requirements of FMVSS 121. However, S5.3 Service Brakes - Road Tests specifies that auto transporters manufactured after September 1, 1976 shall meet the requirements of S5.3.1. Please clarify the total applicability of FMVSS 121 to vehicles defined as "auto transporter". Additionally, we wish to have clarified the scope of vehicles to which the definition "auto transporter" can be applied. Section S4. Definitions defines "auto transporter" as a truck and trailer designed for use in combination, in that the towing vehicle, with fifth wheel mounted, is designed to carry cargo at a location other than the fifth wheel and that this cargo is loaded by means of the towed vehicle. This definition describes a vehicle combination which is commonly referred to as a "can hauler". This vehicle combination consists of a truck and trailer, which truck has a fifth wheel mounted at the end of the frame and has a van body (dromedary) mounted forward of the fifth wheel. This forward cargo area is loaded by means of the towed vehicle, which is a van body that opens at both ends. The truck and trailer remain connected in combination for both loading and unloading through the rear of the towed vehicle. The application of the "can hauler" vehicle combination further parallels that of an "auto transporter" in that the cargo being carried is a low density, high bulk commodity (empty "tin cans"). We, therefore, respectfully request an interpretation from your office regarding the applicability of the definition of "auto transporter" for inclusion of the "can hauler" as a thereby controlled identity. We will appreciate your thoughtful consideration of these questions. Sincerely, Arlen E. Riggs -- Executive Engineer |
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.