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: nht94-2.13OpenTYPE: Interpretation-NHTSA DATE: April 1, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: William J. MacAdam -- President and CEO, trans2 Corporation (Farmington Hills, MI) TITLE: None ATTACHMT: Attached to two letters dated 11/3/93 from William J. MacAdam to John Womack (OCC 9283) TEXT: This responds to your request for an interpretation that an electric vehicle that trans2 plans to manufacture is not a "motor vehicle" within the meaning of the National Traffic and Motor Vehicle Safety Act (Safety Act). Your counsel, Mr. James Freeman, informed Ms. Dorothy Nakama of my staff that you do not object to the manner in which this letter describes the trans2 vehicle. We have determined that the trans2 electric vehicle is not a "motor vehicle" under the Safety Act. "Motor vehicle" is defined at Section 102(3) of the Act as: (A)ny vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. It is unclear from your letter whether the trans2 vehicle is manufactured for on-road use. However, NHTSA has stated in past interpretations that vehicles that regularly use the public roads will not be considered "motor vehicles" if such vehicles have a maximum attainable speed of 20 miles per hour or less and have an abnormal configuration that readily distinguishes them from other vehicles. These criteria appear to be met by trans2's vehicle. You stated that the top speed of the vehicle is 20 miles per hour. Photographs of trans2's vehicle show that it is approximately the size and height of a golf cart. From the side, the passenger comp artment appears to be an oval. From the rear, the vehicle has tail lights built into the two headrests. These unusual body features make the trans2 vehicle readily distinguishable from "motor vehicles." Accordingly, we determine that trans2's vehicle is not a "motor vehicle" within the meaning of the Safety Act. Since the trans2 vehicle is not a motor vehicle, none of NHTSA's regulations or standards apply to it. Please note that except for the features of the trans2's vehicle described herein, the remaining vehicle specifications described in your letter of November 3, 1993 are protected under Exemption 4 of the Freedom of Information Act. The protection will c ontinue until trans2 discloses details of its vehicle to the public. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. |
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ID: nht94-7.11OpenDATE: April 1, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: William J. MacAdam -- President and CEO, trans2 Corporation (Farmington Hills, MI) COPYEE: James Freeman, Esq. -- Hogan and Hartson TITLE: None ATTACHMT: Attached to two letters dated 11/3/93 from William J. MacAdam to John Womack (OCC 9283) TEXT: This responds to your request for an interpretation that an electric vehicle that trans2 plans to manufacture is not a "motor vehicle" within the meaning of the National Traffic and Motor Vehicle Safety Act (Safety Act). Your counsel, Mr. James Freeman, informed Ms. Dorothy Nakama of my staff that you do not object to the manner in which this letter describes the trans2 vehicle. We have determined that the trans2 electric vehicle is not a "motor vehicle" under the Safety Act. "Motor vehicle" is defined at Section 102(3) of the Act as: (A)ny vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. It is unclear from your letter whether the trans2 vehicle is manufactured for on-road use. However, NHTSA has stated in past interpretations that vehicles that regularly use the public roads will not be considered "motor vehicles" if such vehicles have a maximum attainable speed of 20 miles per hour or less and have an abnormal configuration that readily distinguishes them from other vehicles. These criteria appear to be met by trans2's vehicle. You stated that the top speed of the vehicle is 20 miles per hour. Photographs of trans2's vehicle show that it is approximately the size and height of a golf cart. From the side, the passenger compartment appears to be an oval. From the rear, the vehicle has tail lights built into the two headrests. These unusual body features make the trans2 vehicle readily distinguishable from "motor vehicles." Accordingly, we determine that trans2's vehicle is not a "motor vehicle" within the meaning of the Safety Act. Since the trans2 vehicle is not a motor vehicle, none of NHTSA's regulations or standards apply to it. Please note that except for the features of the trans2's vehicle described herein, the remaining vehicle specifications described in your letter of November 3, 1993 are protected under Exemption 4 of the Freedom of Information Act. The protection will continue until trans2 discloses details of its vehicle to the public. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. |
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ID: 9283Open Mr. William J. MacAdam Dear Mr. MacAdam: This responds to your request for an interpretation that an electric vehicle that trans2 plans to manufacture is not a "motor vehicle" within the meaning of the National Traffic and Motor Vehicle Safety Act (Safety Act). Your counsel, Mr. James Freeman, informed Ms. Dorothy Nakama of my staff that you do not object to the manner in which this letter describes the trans2 vehicle. We have determined that the trans2 electric vehicle is not a "motor vehicle" under the Safety Act. "Motor vehicle" is defined at Section 102(3) of the Act as: [A]ny vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. It is unclear from your letter whether the trans2 vehicle is manufactured for on-road use. However, NHTSA has stated in past interpretations that vehicles that regularly use the public roads will not be considered "motor vehicles" if such vehicles have a maximum attainable speed of 20 miles per hour or less and have an abnormal configuration that readily distinguishes them from other vehicles. These criteria appear to be met by trans2's vehicle. You stated that the top speed of the vehicle is 20 miles per hour. Photographs of trans2's vehicle show that it is approximately the size and height of a golf cart. From the side, the passenger compartment appears to be an oval. From the rear, the vehicle has tail lights built into the two headrests. These unusual body features make the trans2 vehicle readily distinguishable from "motor vehicles." Accordingly, we determine that trans2's vehicle is not a "motor vehicle" within the meaning of the Safety Act. Since the trans2 vehicle is not a motor vehicle, none of NHTSA's regulations or standards apply to it. Please note that except for the features of the trans2's vehicle described herein, the remaining vehicle specifications described in your letter of November 3, 1993 are protected under Exemption 4 of the Freedom of Information Act. The protection will continue until trans2 discloses details of its vehicle to the public. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel cc: James Freeman, Esq. Hogan and Hartson Columbia Square 555 13th St., NW Washington, DC 20004-1109 ref:VSA d:4/1/94 |
1994 |
ID: nht69-2.38OpenDATE: 09/05/69 FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA TO: International Harvester Company COPYEE: SUBJ. FILE OAA; CHRON. FILE OAA; CHRON. FILE MVSPS; SUBJ. FILE 409; CHRON. FILE 409; SCHNEIDER, RM. 512, DONOHOE; FISTE, RM. 302A, DONOHOE; FHWA EX. SEO.(2); FHWA CONTROL #55 TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of June 26, 1969, to the Administrator, Federal Highway Administration, concerning the activation of stop lamps and hazard warning signal lamps. Your letter poses three basic questions as follows: 1. Are spring brakes, which backup a primary air brake system, considered "emergency" brakes within the meaning of paragraph S3.4.4 of Federal Motor Vehicle Safety Standard No. 1087 2. Under Standard No. 108, does the Bureau prefer (a) a wiring system whereby the stop lamps override the hazard warning lamps, or (b) a wiring system whereby the hazard warning lamps override the stop lamps? 3. Are both of the above wiring systems permissible? In answer to the first question, spring brakes, which back-up a primary air brake system, are not considered "emergency" brakes within the meaning of paragraph S3.4.4 of Standard No. 108. The basis for this opinion is the same as that contained in Mr. Fay's letter of April 25, 1968, to the Blue Bird Body Company. The Bureau now has under development a proposed standard for brakes which will be applicable to trucks. If under this standard, spring brakes are defined as emergency brakes, then the requirement of paragraph S3.4.4 of Standard No. 108 will be applicable. In answer to the second and third questions, the Bureau has no well-founded research data to prove or disprove the effectiveness of the two different wiring systems for all vehicles covered by Standard No. 108. Use of either of the systems is permitted under Standard No. 108. However, the regulations of the Federal Highway Administration's Bureau of Motor Carrier Safety (49 CFR 392.22(a) and 392.23(a)) require flashing of the turn signal lamps as a vehicular traffic hazard warning signal whenever a vehicle is stopped under certain conditions. These regulations therefore do not allow overriding of the warning signal by the stop lamps. It is our belief that a flashing light, rather than a steady-burning light, conveys a more effective warning of a stopped vehicle. Consequently, trucks, buses, and trailers which after sale may be subject to Bureau of Motor Carrier Safety regulations should be manufactured so that the stop lamps will not override the hazard warning signal. Consideration is being given to rule making(Illegible Word) which would make this mandatory for all trucks, buses, and trailers. |
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ID: aiam2303OpenMr. Marvin L. Hancks, Chief, Procurement Law Division, Headquarters, U.S. Army Armament Command, Department of the Army, Rock Island, Illinois 61201; Mr. Marvin L. Hancks Chief Procurement Law Division Headquarters U.S. Army Armament Command Department of the Army Rock Island Illinois 61201; Dear Mr. Hancks: This responds to your April 13, 1976, request for written confirmatio that the requirements of paragraph S5.2.2.2 of Standard No. 116, *Motor Vehicle Brake Fluids*, do not preclude the use of brake fluid dispensing devices which are used without attachment to the brake fluid container.; Paragraph S5.2.2.2 of Standard no. 116 specifies the information tha packagers of brake fluids are required to place on the outside of the brake fluid container. Subsection (g) of this paragraph specifies four warnings that must be marked on the container. There labeling requirements apply only to the brake fluid container. The requirements do not apply to use of the brake fluid, and therefore do not create duties on the part of the user to abide by the warnings. The purpose of these requirements is only to ensure that purchasers are warned of potential safety hazards that can result from improper use and storage of the product.; Sincerely, Stephen P. Wood, Assistant Chief Counsel |
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ID: nht89-3.52OpenTYPE: INTERPRETATION-NHTSA DATE: 12/09/89 FROM: LOWELL W. SUNDSTROM TO: OFFICE OF THE CHIEF COUNSEL -- NHTSA TITLE: 571.302 STANDARD NO. 302; FLAMMABILITY OF INTERIOR MATERIALS. ATTACHMT: ATTACHED TO LETTER DATED 3-22-90 TO LOWELL SUNDSTROM FROM STEPHEN P. WOOD, NHTSA; [A35; VSA 108 (A)(2); STD. 302] TEXT: I am Lowell W. Sundstrom Jr., inventor of several products, one of which may require your approval. It is named the "HOOD LOCKER" (HL). Two pictures of the HL are enclosed. The HL box will be made of Polyethelene or Polypropolene, the same plastics used in making a battery case. The unit has a tightly fitted lid to keep water and dust out of the box as well as to keep the unused tissue paper inside, dry and clean. The purpose of the HLis to allow the consumer to have at his or her optimum location, a small tissue paper dispenser wherein the tissues may be used for wiping off the engine crankcase dipstick when checking the crankcase oil. The HL can be mounted near or on the vehicle fender well, onto the under side of the hood, onto the side or top of the air cleaner, etc. in order to place the HL as conveniently to the crankcase oil dip-stick as is possible. I have researched the NHTSAdmin., DOT: 571.302. It appears to me that it does not refer to this product because: 1- it will not be placed within the occupant compartments of motor vehicles. 2- it will not be placed within 1/2" of any occupants air space. I hope your findings are similiar to mine as I feel this is a helpful and safe product that will give the consumer considerable convenience at little expence. If you think, for any reason, that I can help to expedite your research of the HOOD LOCKER, please feel free to call any time. (Graphics omitted) |
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ID: Warning letter re electronic devices (Prospeedo)OpenCERTIFIED MAIL RETURN RECEIPT REQUESTED
Dwayne Bitz Prospeedo 1178 N Grove St., Suite D Anaheim, CA 92806-2125 Re: Marketing and Use of Devices Prohibited by Federal Odometer Law
Dear Mr. Bitz: The National Highway Traffic Safety Administration (NHTSA) is actively investigating potential violations of Federal odometer law. Federal law prohibits the marketing for sale and sale of devices that are capable of accessing a motor vehicles computer system to alter the mileage displayed on the vehicles odometer. These devices make odometers register a mileage different from the mileage the vehicle was driven, whether or not the device is actually used to do so, and thus their marketing and sale violates the prohibition. Pursuant to 49 U.S.C. 32703: A person may not(1) advertise for sale, sell, use, install, or have installed, a device that makes an odometer of a motor vehicle register a mileage difference from the mileage the vehicle was driven, as registered by the odometer within the designed tolerance of the manufacturer of the odometer. Federal law also makes it illegal to disconnect, reset, alter, or have disconnected, reset, or altered an odometer of a motor vehicle intending to change the mileage registered by the odometer. 49 U.S.C. 32703(2).[1] A person that violates Federal odometer law is subject to criminal and civil penalties, as set forth in 49 U.S.C. 32709. Based upon information, products, and services advertised for sale on your websites, http://www.prospeedo.com/, http://www.socalspeedometer.com/, and http://www.speedodepot.com/, NHTSA believes that Prospeedo is engaged in activity in violation of Federal odometer law. Specifically, Prospeedo advertises for sale three products that alter odometer readings. These are the BIG 3 OBD, the PRO 9.0, and the 9S12/912. Prospeedo also advertises services, including: We can Reset the Mileage Reading to your Requirement.
Prospeedo must immediately cease and desist all activity in violation of Federal odometer law. In addition, within three weeks after receipt of this letter, you are directed to send to my office a list of every customer (including names and addresses): (1) who purchased a BIG 3 OBD, PRO 9.0, 9S12/912, or other product that alters odometer readings; and/or (2) for whom Prospeedo altered an odometer reading. For each such customer, identify the product or service that you provided to that customer and the date. Sincerely, O. Kevin Vincent Chief Counsel Dated: 8/6/13 Warning letter re: electronic devices (Prospeedo).docx [1] A person may service, repair, or replace an odometer of a motor vehicle if the mileage registered by the odometer remains the same as before the service, repair, or replacement. 49 U.S.C. 32704(a). If the mileage cannot remain the same(1) the person shall adjust the odometer to read zero; and (2) the owner of the vehicle or agent of the owner shall attach a written notice to the left door frame of the vehicle specifying the mileage before the service, repair, or replacement and the date of the service, repair, or replacement. 49 U.S.C. 32704(a). |
2013 |
ID: nht94-4.29OpenTYPE: INTERPRETATION-NHTSA DATE: September 16, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Harleigh Ewell, Esq. -- Regulatory Affairs Division, Office of the General Counsel, Consumer Product Safety Commission TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 01/27/94 FROM H. EWELL TO DAVID ELIAS (OCC 9615) TEXT: This letter responds to your inquiry whether gasoline pump nozzle/hose assemblies (referred to collectively in this letter as "gas nozzles") are an item of motor vehicle equipment. The answer is no. To answer your question, we conducted a detailed exam ination of our past interpretations of what constitutes "motor vehicle equipment" under our statute. As you are aware, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA's authority was recently recodified in titl e 49 of the U.S. Code. Section 30102(a) (7) (formerly section 102 (4) of the National Traffic and Motor Vehicle Safety Act of 1966) defines the term "motor vehicle equipment" as: (A) any system, part, or component of a motor vehicle as originally manufactured; (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component, or as any accessory or addition to a motor vehicle ; or (C) any device or an article . . . that is not a system, part, or component of a motor vehicle and is manufactured, sold, delivered, offered, or intended to be used only to safeguard motor vehicles and highway users against risk of accident, injury, or death. (Emphasis added.) The only portion of this definition that gas nozzles could even conceivably fall within is the term "accessories." Proceeding by the process of elimination, a gas nozzle is neither a "system, part, or component" of a motor vehicle as originally manufactu red nor as a replacement or improvement for or to a system, part or component because a gas nozzle never becomes part of the vehicle and cannot realistically be considered part of the vehicle's fuel system. For the same reason, it is not an "addition" t o a motor vehicle. A gas nozzle is not a "device, article, or apparel" because it is not exclusively used as a safeguard from risk of accident, injury, or death. The sole remaining possibility is that gas nozzles may be an "accessory." This question is addressed below. The agency has typically used two criteria in determining whether a device is an "accessory." These criteria were discussed extensively in a May 25, 1990 letter to Susan Birenbaum, at the time the Acting General Counsel of your commission. The first crit erion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that r etails the product, as well as available information about the actual use of the product. The second criterion is whether the product is intended to be used principally by ordinary users of motor vehicles. If a product satisfied both criteria, then the product has been considered to be an "accessory." An allied concept that has been implicit in NHTSA's interpretations is that the item be purchased or owned by the consumer. This concept reinforces the "ordinary user" concept in the second criterion of the test by generally restricting accessories to c onsumer items that we believe Congress intended us to regulate. Examples of items that, without the purchase concept, might be accessories include self-serve car wash equipment, and air pumps and even gas pumps themselves. In making this concept explic it, NHTSA will be stating the criteria for determining whether an item is an accessory as follows: (1) A substantial portion of its expected uses are related to the operation or maintenance of motor vehicles; and (2) it is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. Applying these criteria to gas nozzle/hose assemblies, we conclude that they are not accessories. While gas nozzles have a principal use that is arguably related to the operation and maintenance of motor vehicles, gas nozzles fail the second criterion o f the test. While they are used by ordinary users of motor vehicles, they are not purchased or acquired by those users. It is therefore our opinion that gas nozzles are not motor vehicle equipment. I hope this information is helpful. If you have any further questions, please feel free to contact us at this address or by telephone at (202) 366-2992. |
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ID: 9615aOpen Harleigh Ewell, Esq. Dear Mr. Ewell: This letter responds to your inquiry whether gasoline pump nozzle/hose assemblies (referred to collectively in this letter as "gas nozzles") are an item of motor vehicle equipment. The answer is no. To answer your question, we conducted a detailed examination of our past interpretations of what constitutes "motor vehicle equipment" under our statute. As you are aware, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA's authority was recently recodified in title 49 of the U.S. Code. Section 30102(a)(7) (formerly section 102(4) of the National Traffic and Motor Vehicle Safety Act of 1966) defines the term "motor vehicle equipment" as: (A) any system, part, or component of a motor vehicle as originally manufactured; (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component, or as any accessory or addition to a motor vehicle; or (C) any device or an article ... that is not a system, part, or component of a motor vehicle and is manufactured, sold, delivered, offered, or intended to be used only to safeguard motor vehicles and highway users against risk of accident, injury, or death. (Emphasis added.) The only portion of this definition that gas nozzles could even conceivably fall within is the term "accessories." Proceeding by the process of elimination, a gas nozzle is neither a "system, part, or component" of a motor vehicle as originally manufactured nor as a replacement or improvement for or to a system, part or component because a gas nozzle never becomes part of the vehicle and cannot realistically be considered part of the vehicle's fuel system. For the same reason, it is not an "addition" to a motor vehicle. A gas nozzle is not a "device, article, or apparel" because it is not exclusively used as a safeguard from risk of accident, injury, or death. The sole remaining possibility is that gas nozzles may be an "accessory." This question is addressed below. The agency has typically used two criteria in determining whether a device is an "accessory." These criteria were discussed extensively in a May 25, 1990 letter to Susan Birenbaum, at the time the Acting General Counsel of your commission. The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is intended to be used principally by ordinary users of motor vehicles. If a product satisfied both criteria, then the product has been considered to be an "accessory." An allied concept that has been implicit in NHTSA's interpretations is that the item be purchased or owned by the consumer. This concept reinforces the "ordinary user" concept in the second criterion of the test by generally restricting accessories to consumer items that we believe Congress intended us to regulate. Examples of items that, without the purchase concept, might be accessories include self-serve car wash equipment, and air pumps and even gas pumps themselves. In making this concept explicit, NHTSA will be stating the criteria for determining whether an item is an accessory as follows: (1) A substantial portion of its expected uses are related to the operation or maintenance of motor vehicles; and (2) it is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. Applying these criteria to gas nozzle/hose assemblies, we conclude that they are not accessories. While gas nozzles have a principal use that is arguably related to the operation and maintenance of motor vehicles, gas nozzles fail the second criterion of the test. While they are used by ordinary users of motor vehicles, they are not purchased or acquired by those users. It is therefore our opinion that gas nozzles are not motor vehicle equipment. I hope this information is helpful. If you have any further questions, please feel free to contact us at this address or by telephone at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:VSA d:9/16/94
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1994 |
ID: aiam5112OpenMr. Guy Boudreault 340 7th Avenue, #1 Ile Perrot, P.Q. J7V 4T6 CANADA; Mr. Guy Boudreault 340 7th Avenue #1 Ile Perrot P.Q. J7V 4T6 CANADA; Dear Mr. Boudreault: This responds to your letter expressing concern about certain working conditions that you have experienced as a driver of a commercial vehicle, and asking about rules and regulations that apply to the adjustment of brakes on commercial vehicles. I am pleased to have this opportunity to respond to you. By way of background information, this agency, the National Highway Traffic Safety Administration, is authorized by the National Traffic and Motor Vehicle Safety Act to issue Federal motor vehicle safety standards applicable to new motor vehicles and motor vehicle equipment. We have issued a number of safety standards that apply to heavy vehicles, including ones on brakes and lighting. This agency does not have the authority to regulate the use of motor vehicles. Your letter concerns in-service safety requirements for commercial vehicles and drivers, rather than safety requirements that apply to new motor vehicles. Within the U.S. Department of Transportation, the Federal Highway Administration, Office of Motor Carriers, has the authority to issue motor carrier safety regulations for interstate motor carriers and drivers. Ordinarily I would refer your letter to that agency, however, your letter indicates that you sent the same letter to the Office of Motor Carriers as you sent to this agency. I hope this information is helpful. If you have any 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; |
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.