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: nht94-4.70OpenTYPE: INTERPRETATION-NHTSA DATE: October 28, 1994 FROM: Richard J. Kinsey -- Manager, Fuel Economy Planning & Compliance, Ford Motor Company TO: Ricardo Martinez -- MD, Administrator, NHTSA TITLE: None ATTACHMT: ATTACHED TO 3/8/95 LETTER FROM PHILIP R. RECHT TO RICHARD J. KINSEY (REDBOOK (2)); PART 583 TEXT: Ford Motor Company requests your concurrence on the following procedure for defining the domestic content and country of origin for foreign-sourced allied and outside supplier components. 40 CFR 583.6(c)(4)(iv) assigns zero domestic content to all passenger motor vehicle equipment which is imported into the territorial boundaries of the United States or Canada from a third country, even if part of its material originated in the United States or Canada. 40 CFR 583.7 allows the supplier to use methodologies that are used for customs purposes to determine the country of origin. Ford expects that for any imported component, both allied and outside, suppliers would report that the domest ic content is zero and the country of origin is the country of manufacture, based on the rules of substantial transformation. Ford can obtain the same information (zero domestic content, country of manufacture, purchase price) expected to be received from our foreign suppliers from our present purchasing systems. Since the process of soliciting the supplier is costly, Ford plans to assign the domestic content and country of origin of the foreign supplied components without soliciting the data from our foreign suppliers. We are concerned that even if Ford did submit the request to foreign suppliers, that suppliers would ha ve to expend additional resources creating a document which Ford already knows the answer. Even if the foreign supplier does not respond, the domestic content and country of origin will not be any different than if they did respond. Ford believes that requiring these suppliers to respond would impose costly and unnecessary burdens on our foreign suppliers. Ford will solicit content information from all first-tier outside suppliers of non-minor parts starting for the 1996 model year calculation. Please contact Ron Peltier at (313) 337-5367 if you have any questions. |
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ID: 07-001825asOpenMr. Howard Seligman Velosolex America, LLC 501 Kennedy Blvd. North Bergen, NJ 07047 Dear Mr. Seligman: This responds to your letter in which you ask whether the National Highway Traffic Safety Administration (NHTSA) is the regulating authority for the Velosolex pedal assisted bicycle (the Velosolex). Based on your description of the product and the analysis presented below, the Velosolex would not be considered a motor vehicle. Therefore, it is subject to the jurisdiction of the Consumer Product Safety Commission (CPSC) rather than NHTSA. By way of background, NHTSA regulates the manufacture, importation, and sale of motor vehicles and motor vehicle equipment. The definition of motor vehicle is given is 49 USC 30102, and reads: [M]otor vehicle means a vehicle driven or drawn by mechanical power and 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 describe the Velosolex as driven primarily by muscular power, and indicate that the engine only supplements the primary driving force. You state that it has a small internal combustion engine, which does not activate until the bicycle reaches a speed of five miles per hour. Furthermore, you state that if the rider does not continue to pedal after the engine is running, the Velosolex will eventually stop, as the engine is not powerful enough to keep the Velosolex moving on its own. Based on your description, including the fact that the engine is not powerful enough to keep the Velosolex moving on its own, it is our opinion that the primary motive force for the Velosolex is muscular power, not mechanical power within the meaning of the definition of motor vehicle. Therefore, the Velosolex is not a motor vehicle under 30102, and it is subject to the jurisdiction of CPSC rather than NHTSA. We note that your product could also be subject to the jurisdiction and regulations of other Federal agencies, including the Environmental Protection Agency. If you have any further questions relating to NHTSA, please contact Ari Scott of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel ref:571 d.9/17/07 |
2007 |
ID: nht75-3.25OpenDATE: 04/30/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Frigiking Inc. COPYEE: ALEX M. CALALUCA -- MOTOR VEHICLE PROGRAMS DIR. TITLE: FMVSR INTERPRETATION TEXT: Your letter of March 7, 1975 to Mr. Alex Calauca, Motor Vehicle Programs Director of the National Highway Traffic Safety Administration's Region 6, has been referred to this office. You wish to be informed of Frigiking's responsibilities under the NHTSA's rules and regulations as a manufacturer of automotive air conditioners for sale to domestic and foreign auto manufacturers, automobile dealers and automobile supply retail outlets. Mr. Calaluca correctly indicated that there is currently no Federal Motor Vehicle Safety Standard which regulates automobile air conditioners. He also correctly informed you that your firm is not deemed a manufacturer by the NHTSA when your product is installed as original equipment. Where the Frigiking air conditioner is installed in a vehicle prior to the first sale of the vehicle the manufacturer of the vehicle is also deemed to be the manufacturer of your product. However, you should understand that in all other cases your company is considered a manufacturer under the NHTSA's rules and regulations. For example, where units are sold under private label to mass merchandising firms for sale and installation to individual automobile owners, or where units are sold through Frigiking's distributor/dealer organization for individual unit retail sales where the sale is other than to a franchised auto dealer for installation prior to the sale of the new car, Frigiking has certain responsibilities under the National Traffic and Motor Vehicle Safety Act of 1966, as amended, notwithstanding the absence of any Safety Standard regulating air conditioners. In the event that the NHTSA determined through its own investigation that an air conditioner produced by your firm contained a defect related to motor vehicle safety, you would be required to give notice of the defect to every person who had purchased the product manufactured during the period when a defect was known to exist. This manufacturing period could extend up to 8 years preceding the notification. In addition you would be required to repair or replace without charge every such defective air conditioner presented to you, and repurchase defective air conditioners from distributors and dealers. Finally, it would be wise for Frigiking to remind manufacturers and dealers who install its air conditioners in motor vehicles prior to first sale that they must account for the addition of an air conditioning unit in certifying that the vehicle conforms to Federal standards and in certifying the Gross Vehicle Weight Rating and Gross Axle Weight Rating as required by the NHTSA regulations contained in 49 CFR Part 567. Please do not hesitate to contact us if we can be of further assistance. Yours truly, UNITED STATES GOVERNMENT U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION MEMORANDUM SUBJECT: Regulations Applicable to Automotive Equipment Suppliers FROM: Regional Administrator -- National Highway Traffic Safety Administration, Fort Worth, Texas TO: Office of Chief Counsel, N40-30 -- National Highway Traffic Safety Administration, Washington, D. C. DATE: March 19, 1975 In his letter dated March 7, 1975, Mr. David M. Holden of Frigiking, Incorporated, discloses that his company's automotive air conditioners are being purchased for installation, in some instances, in vehicles prior to first sale. The purchasers are said to be domestic and foreign manufacturers, automobile dealers, and automotive supply retail outlets. He desires information on motor vehicle regulations applicable to his company's product. I informed him that no Federal Motor Vehicle Safety Standards currently exist that cover automobile air conditioners. I also told him that according to Section 159(D) of Public Law 93-492, his company does not come under the definition of original equipment manufacturer. Any additional information you can provide Mr. Holden would be appreciated. A copy of your response to Mr. Holden to this office is requested. I am forwarding a copy of this memorandum as well as a copy of P.L. 93-492 to Mr. Holden for informational purposes. Alex M. Calaluca -- Motor Vehicle Programs Director; For: E. Robert Anderson -- Regional Administrator Enclosure March 7, 1975 Alex Calaluca -- National Highway Traffic Safety Administration, Region 6 Dear Mr. Calaluca: Your comments this morning in our telephone conversation regarding my company's products and the National Highway Traffic Safety Administration responsibilities were most informative and I thank you. Perhaps this brief outline will adequately aid you in obtaining additional information which will be instructive to us. Frigiking is primarily, but not exclusively, a manufacturer of automobile air conditioners. Frigiking sells its products in the following manner: A. Units are sold to importers of foreign manufactured vehicles and installed at P.O.E., depot or dealer level as original equipment. B. Units are sold to domestic vehicle manufacturers for installation at depot or dealer level, prior to retail sale. C. Units are sold under private label to mass merchandising firms for sale and installation to individual automobile owners. D. Units are sold through Frigiking's distributor/dealer organization for individual unit retail sales. However, in this situation it is not uncommon for units to be sold by a Frigiking dealer to a franchised auto dealer for installation prior to the sale of the new car. I am interested in determining Frigiking's explicit responsibilities in each of these merchandising circumstances as they may be defined under the National Highway Traffic Safety Administration's rules and regulations. I look forward to whatever assistance you may lend me. Sincerely yours, David M. Holden -- Quality Assurance Engineer, FRIGIKING |
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ID: nht92-3.48OpenDATE: September 18, 1992 FROM: William G. Rosoff -- Chief, Entry Rulings Branch, Department of the Treasury, U.S. Customs Service TO: Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 10/5/92 from Paul Jackson Rice to William G. Rosoff (A-40; Part 591) TEXT: We are forwarding a letter and documentation from Dr. Irina Elovaara concerning an extension of 49 CFR 591.5(d). Dr. Elovaara has been in the U.S. doing research at the National Institutes of Health and has recently had her stay extended until December 1992. Dr. Elovaara temporarily imported her car in October of 1991 under 49 CFR 591.5(d). Her one year time limitation will expire next month; she would like an extension of time. The regulation does not provide for time extensions, therefore, Customs does not have authority to grant an extension or an exception. As this is under your jurisdiction we hope that you will be able to assist Dr. Elovaara as quickly as possible. Enclosures DEPARTMENT OF THE TREASURY U.S. CUSTOMS SERVICE September 18, 1992 ENT-6-03-CO:R:C:E 224130 SR Dr. Irina Elovaara Neuroimmunology Branch National Institute of Neurological Disorders and Stroke National Institutes of Health Bldg. 10 Room 5B-16 Rockville Pike 9000 Bethesda, Maryland 20892 Dear Dr. Elovaara: The temporary importation of a vehicle for personal use is regulated by the Department of Transportation and enforced by U.S. Customs. According to the Department of Transportation regulation 49 CFR 591.5(d), vehicles that are imported temporarily for personal use can remain in the country for a time not to exceed one year. The regulations do not provide for any extensions or exceptions. Customs does not have the authority to change the regulation or provide any exceptions to the regulation. We have forwarded your file to the Chief Counsel of the National Highway Traffic Safety Administration for a formal ruling. Sincerely, William G. Rosoff Chief Entry Rulings Branch
National Institutes of Health Bethesda, Maryland 20892 August 26, 1992
Dr. Irina Elovaara Neuroimmunology Branch National Institute of Neurological Disorders and Stroke NIH Bldg. 10 Room 5B-16 Rockville Pike 9000 Bethesda, Maryland Ms. Sheryl Rosenow Commission Ruling Division/Entry Rulings Branch US Customs Service 1301 Constitution Avenue NW Washington, D.C. 20229 Dear Sheryl Rosenow, Referring to our telephone conversation 8.25, please find enclosed the documents related to importation of my car. If there are any questions, please feel free to contact me at 301-496-0519 (work telephone) or 301-718-6424 (home). Sincerely yours Irina Elovaara, M.D.
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service National Institutes of Health Bethesda, Maryland 20892 August 6, 1992 Dr. Irina Elovaara Neuroimmunology Branch National Institute of Neurological Disorders and Stroke National Institutes of Health 9000 Rockville Pike Building 10, Room 5B-16 224130 Bethesda, Maryland 20892 Director, Room 2107 Commission Ruling Division US Customs Service 1301 Constitution Avenue NW Washington DC 20229 Dear Director, My visiting medical fellow appointment (title: special volunteer) at the National Institutes of Health started 1.10.91. At that time my vehicle - Mercedez Benz 190E (VIN#WDB201018F891360) was imported into the United States, whereafter it was insured (10.10.91 Allstate), inspected (10.18.91), and titled (10.21.91 in Gaithersburg MVA). The vehicle also passed the emission inspection test 01.24.92. When the vehicle arrived I had to sign a statement that the vehicle will be exported within one year or when I leave the country (statement of importer). My appointment at the NIH has now been extended until December 1992 (see document from Fogarty International Center). Therefore, I request permission to keep my vehicle in the U.S.A. until my leave i.e. 12.31.92. U.S. Customs Service (Mr. Rososs) informed me on August 6th by phone that generally handling of requests like this takes 120 days. This application, however, could not be done until now, because the extension of my appointment at NIH has been confirmed only recently. I apologize for the delay. In spite of it, I hope that the permission regarding my vehicle is still possible. I hope that this letter does not cause too much inconvenience. Thank you. Sincerely yours Irina Elovaara, M.D. Home address: 4500 Chase Avenue, Bethesda, Maryland 20814 phone: 301-728 6224 phone work: 301-496-0519, fax: 301-402-0373
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service National Institutes of Health Fogarty International Center Bethesda, Maryland 20892
August 7, 1992 To Whom It May Concern: A request for an extension was submitted to the Fogarty International Center, National Institutes of Health, effective October 1, 1992 through December 31, 1992 for Dr. Irina Elovaara (Date and Place of Birth: May 1, 1951, Helsinki, Finland), Special Volunteer at the National Institutes of Health, National Institute of Neurological Disorder and Stroke. Immigration documents have been completed and signed by the Responsible Officer and will be submitted to the Immigration and Naturalization Service (INS) on August 14, 1992. This renewal in contingent upon approval by the INS, Department of Justice, of Dr. Elovaara's continued stay in the United States under all existing immigration regulations. Sincerely, Sincerely, Wanda J. Pifer Immigration Coordinator and Responsible Officer, G-5-0111 International Services and Communications Branch Fogarty International Center |
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ID: 06-4519asOpenMr. Mark Connors U.S. Compliance Specialist / Licensed Customs Broker Buckland Global Trade Services, Inc. Peace Bridge Plaza, Dock Area Buffalo, NY 14213 Dear Mr. Connors: This letter is in response to your request for clarification of 49 CFR 583.6, Procedure for determining U.S./Canadian parts content. This section is used for the determination of the percentage of U.S./Canadian Parts Content for each carline on a model year basis, a determination necessary for automobile parts content labeling. Specifically, you inquired whether the use of value in 49 CFR 583.6(c)(1) and total value of the material in 49 CFR 583.6(c)(4)(ii)(A)(1) for outside suppliers represents the outside suppliers selling prices to the manufacturer (including labor, overhead, and profit), or just the suppliers material costs. As explained below, this office interprets value, as used in these sections, to mean the outside suppliers selling price to the final manufacturer. This would include labor, overhead, and profit. We would use this meaning of value in determining the value added and the total value of the material. By way of background, Congress enacted the American Automobile Labeling Act, Pub.L. 102-388 (Oct. 6, 1992), in part to regulate the labeling of vehicle components sold in the United States. In implementing this Congressional mandate, National Highway Traffic Safety Administration (NHTSA) issued a final rule on September 15, 1995 regulating the labeling of certain motor vehicle parts and requiring manufacturers to specify how much domestic value has been added to motor vehicle components. One of Congress goals in enacting the American Automobile Labeling Act was for manufacturers to label the country of origin of vehicle engines and transmissions, so that American consumers would know if the major automobile components had been manufactured domestically. In determining the country of origin, if an assemblage was made in multiple countries, Congress stated that the country of origin means the country in which 50 percent or more of the dollar value added of an engine or transmission originated (106 Stat. 1558). The definition of value added is given in 49 U.S.C. 32304(A)(15), which reads: "value added in the United States and Canada" means a percentage determined by subtracting the total purchase price of foreign content from the total purchase price, and dividing the remainder by the total purchase price, excluding costs incurred or profits made at the final assembly place and beyond (including advertising, assembly, labor, interest payments, and profits)
This definition can be broken down into two relevant parts. The first is the total purchase price of foreign content, which is the price that the parts supplier paid for the materials. The second is the total purchase price, which is the actual price paid by the vehicle manufacturer to the parts supplier. By subtracting the total purchase price of foreign content from the total purchase price, what remains is the cost of labor, overhead, profit, and additional material that the outside supplier has provided. This is the value added in the United States or Canada. To convert that into a percentage, take the value added figure and divide it by the total purchase price, then multiply by 100. The methodology for calculating the value added was further explained in the Federal Register notice issued by NHTSA when it promulgated the final rule. In that notice, NHTSA stated: The final rule (583.6(c)(4)(ii)) therefore specified that, in determining the value added in the United States or Canada of passenger motor vehicle equipment produced or assembled within the territorial boundaries of the United States or Canada, the cost of all foreign materials is subtracted from the total value (e.g., the price paid at the final assembly plant) of the equipment. The procedures specified that material is considered foreign to whatever extent part or all of the cost of the material is not determined to represent value added in the United States or Canada, traced back to raw materials.[1] Note that this text explicitly refers to the total value as the price paid at the final assembly plant, which would include labor, overhead, and profits.
In summation, here is a short recap of the terms you requested clarification of:
Total value of the material, as described in 49 CFR 583.6(c)(4)(ii)(A)(1), is the outside suppliers selling price to the vehicle manufacturer.
Value added, as described in 49 CFR 583.6(c)(1), is the total value of the material minus the outside suppliers material costs. To turn that figure into a percentage, divide the value added by the total value of the material, and multiply by 100.
If you have any questions, please contact Ari Scott of my staff at (202) 366-2992.
Sincerely,
Anthony M. Cooke Chief Counsel
ref:583 d.1/22/07
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2007 |
ID: 1985-02.15OpenTYPE: INTERPRETATION-NHTSA DATE: 04/16/85 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Mr. Alexander E. Nagy TITLE: FMVSS INTERPRETATION TEXT:
Mr. Alexander E. Nagy 19015 132nd Avenue Sun City West, AZ 85375
Dear Mr. Nagy:
This responds to your letter to this agency, as supplemented by a March 11, 1985 telephone conversation between yourself and Steve Kratzke of my staff. You indicated that you plan to produce golf carts, which would be designed primarily for use on golf courses, but would also be used to transport golfers on the public roads from their homes to the golf course and back. You asked what Federal safety requirements the golf carts would have to meet. As explained below, if your golf carts are used on public highways, have a top speed of 20 mph or less, and have a configuration which readily distinguishes them from other vehicles, they would not be motor vehicles, and therefore would not be subject to this agency's safety standards.
Section 102(3) of the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1391 (3)) defines a "motor vehicle" as any 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. This agency's safety standards apply only to vehicles which are "motor vehicles" within the meaning of this definition. Vehicles such as forklifts and mobile construction equipment which are sold primarily for off-road use, but which incidentally use the public roads to travel from one job site to another are not considered motor vehicles. On the other hand, vehicles which regularly use the public roads and stay off-road for only limited periods of time are motor vehicles and are subject to our safety standards. NHTSA has generally said that golf carts are not motor vehicles because their use on public roads is intermittent and incidental to their use on golf courses.
However, you stated in your letter and emphasized in the telephone conversation that you intend your golf carts to be regularly used on the public roads to transport golfers and their equipment to and from their homes. Accordingly, the agency's past reasoning as to whether golf carts are motor vehicles (intermittent use on the public roads, which use is purely incidental to use on golf courses) would not apply to these golf carts.
This agency has stated in many prior interpretations that even vehicles which will be used regularly on the public roads will not be considered motor vehicles if such vehicles have a maximum attainable speed of 20 miles per hour (mph) or less and have an abnormal configuration which readily distinguishes them from other vehicles. Golf carts generally have a vehicle configuration which readily distinguishes them from other vehicles, since they do not have doors, a windshield, windshield wipers, and the like. Hence, even if your golf carts are intended to be used on the public roads, they would not be considered motor vehicles if they have a configuration similar to most other golf carts and if their maximum attainable speed is 20 mph or less.
If you decide to build your golf carts so that they would not be classified as motor vehicles, you may wish to contract the Consumer Product Safety Commission to learn if they have any Federal safety regulations applicable to golf carts. Their address is: Office of the General Counsel, U.S. Consumer Product Safety Commission, Washington, D.C. 20207. If you decide to build your golf carts so that they would be;classified as motor vehicles, I have enclosed an information sheet which explains how to obtain copies of this agency's regulations.
Finally, you noted that you may build these golf carts in versions powered by a gasoline engine, an electric motor and batteries, and a hybrid version powered by a gasoline engine and electric motor. You asked if the electric and hybrid versions would have to meet any additional safety requirements. If your golf carts are motor vehicles, and therefore subject to this agency's safety standards, the same safety standards apply regardless of whether the vehicle is driven by a gasoline, electric, or hybrid engine, and there are no additional safety requirements applicable to electric and hybrid vehicles . If your golf carts are not motor vehicles, I must again refer you to the Consumer Product Safety Commission for a response. If you have any further questions or need further information on this subject, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992.
Sincerely,
Original Signed By
Jeffrey R. Miller Chief Counsel
Enclosure
Alexander E. Nagy 19015 132nd. Ave. Sun City West, AZ 85375
Dept. of Transportation NHTSA Office of Rule Making 400 7th St., SW Washington, D.C. 20590
Dear Sir:
I an planning on designing, developing and manufacturing golf cars. What federal safety requirements will the cars have to meet? Some will be driven by a gasoline engine, others by and electric motor and batteries. In addition, I may also develop a golf car employing a hybrid type power plant, a combination gasoline engine and electric motor. What additional federal safety requirements, if any, would they have to meet?
The golf cars will be designed primarily to traverse golf courses, however, they will also be utilized to transport the golfer from his residence to the golf course and base home.
May I hear from you soon? Thank you.
Yours sincerely,
Alexander E. Nagy Phone #: 602 975-2050 |
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ID: nht93-2.17OpenDATE: March 16, 1993 FROM: Steve Thomas -- General Manager, Texas Bragg Enterprises TO: Walter Meyers -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 4-14-93 from John Womack to Steve Thomas (A41; Std. 119; Std. 120) TEXT: I have several of my dealers that are wanting to buy their trailers from me without tires or without tires and wheels. I am reasonably sure that they do not have fourteen (14) customers at a time wanting to put their own tires and wheels on their trailers. I do believe that they will be installing used tires or used tires and wheels on these trailers once they got them to their places of business. Since I know this is against the law can I legally sale the trailers to my dealers like this and if so, do I need them to sign some kind of waiver or a form stating they bought the trailers from me without tires or wheels? |
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ID: nht92-1.26OpenDATE: 12/11/92 FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA TO: HERR O. SCHMIDT -- HELLA KG HUECK & CO ATTACHMT: ATTACHED TO LETTER DATED 11-20-92 FROM O. SCHMIDT TO RICHARD L. VAN IDERSTINE (OCC 8049) TEXT: This responds to your letter of November 20, 1992, to Richard L. Van Iderstine of this agency asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Please address your future requests for interpretation to the Chief Counsel. You have asked for confirmation that the requirement that a center highmounted stop lamp "provide access for convenient replacement of the bulb without the use of special tools" does not exclude sealed lamps "where long life light sources like long life bulbs, LED's and neon tubes are provided." We are pleased to provide the confirmation you request. Although the agency has used the term "the bulb", the term is not meant to exclude more than one bulb, or a light source other than a bulb, for the center lamp. Sealed units (entire lamps) are permissible as long as such a lamp is replaceable without the use of special tools. |
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ID: 8049Open Herr O. Schmidt Dear Herr Schmidt: This responds to your letter of November 20, 1992, to Richard L. Van Iderstine of this agency asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Please address your future requests for interpretation to the Chief Counsel. You have asked for confirmation that the requirement that a center highmounted stop lamp "provide access for convenient replacement of the bulb without the use of special tools" does not exclude sealed lamps "where long life light sources like long life bulbs, LED's and neon tubes are provided." We are pleased to provide the confirmation you request. Although the agency has used the term "the bulb", the term is not meant to exclude more than one bulb, or a light source other than a bulb, for the center lamp. Sealed units (entire lamps) are permissible as long as such a lamp is replaceable without the use of special tools. Sincerely,
Paul Jackson Rice Chief Counsel ref:108 d.12/11/92 |
1992 |
ID: 1734yOpen Mr. Robbie Folino-Nazda Dear Mr. Folino-Nazda: We have received a copy of your letter of December l9, l988, to Commissioner Young of the Food and Drug Administration, forwarded to us by the Consumer Product Safety Commission. You have asked whether the "vehicle safety device" you described (with samples enclosed) are subject to any restrictions which would prevent importation of the device. The device provides an "ultrasonic animal warning." At a speed "over 30 mph air flow produces a high pitch whistle which animals try to avoid." It is designed for owner installation on "bumpers, grills, fenders, mirrors and roofs" of motor vehicles. Because the device is intended solely as an accessory to motor vehicles, it is an item of motor vehicle equipment subject to the jurisdiction of this agency under the National Traffic and Motor Vehicle Safety Act. However, there are no Federal motor vehicle safety standards that apply to this type of equipment. You should also be aware that if the device's manufacturer ("manufacturer" includes both the maker as well as any importer for resale) or this agency were to determine that the device contains a safety-related defect, importers of this foreign-made device would be required by the Vehicle Safety Act to recall the device and remedy the defect or replace the device without charge. We are returning your samples to you. Sincerely,
Erika Z. Jones Chief Counsel / VSA d:3/l3/89 |
1970 |
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.