NHTSA Interpretation File Search Overview Search Tool Request an Interpretation

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

Displaying 15431 - 15440 of 16490

Interpretations	Date

ID: aiam5500 Open Mr. Richard J. Kinsey Manager, Fuel Economy Planning & Compliance Ford Motor Company The American Road Dearborn, Michigan 48121; Mr. Richard J. Kinsey Manager Fuel Economy Planning & Compliance Ford Motor Company The American Road Dearborn Michigan 48121; "Dear Mr. Kinsey: This responds to your letter requesting ou concurrence on a procedure for determining the domestic content and country of origin for foreign-sourced allied and outside supplier components. I apologize for the delay in our response. You stated that you would like to obtain the relevant information from your present purchasing systems rather than by soliciting the information from your foreign suppliers. You stated that both processes will result in the same information, and that you believe requiring your foreign suppliers to respond to requests for information would impose costly and unnecessary burdens on those suppliers. We are now in the process of completing our response to several petitions for reconsideration of the final rule on domestic content labeling. Your question is sufficiently related to some of the issues raised by the petitions that we believe it should be addressed in the context of that response, rather than in a separate letter. We realize, however, that manufacturers and suppliers have an immediate need for guidance regarding the procedures for making content determinations for the 1996 model year. In a recent letter (copy enclosed) to the American Automobile Manufacturers Association, we advised that NHTSA had decided to give manufacturers and suppliers for model year 1996 the same alternative they had last year, i.e., in lieu of following the required procedures, they may use other procedures that are expected to yield similar results. Therefore, your planned approach will not raise any concerns for model year 1996. I hope this information has been helpful. If you have any other questions or need some additional information in this area, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure";
ID: aiam1539 Open Mr. J.R. Farron,Bendix Corporation,401 Bendix Drive,South Bend, Indiana 46620; Mr. J.R. Farron Bendix Corporation 401 Bendix Drive South Bend Indiana 46620; Dear Mr. Farron:#This responds to your May 28, 1974, question whether short neoprene connector of two steel vacuum brake lines in the Bendix Hydrovac unit is subject to Standard No. 106, Brake hoses.#The neoprene connector functions as a brake hose under the definition set out in the standard:#>>>'Brake hose' means a flexible conduit that transmits or contains the fluid pressure or vacuum used to apply force to a vehicles brakes.<<<#The determination of the 'flexibility' of a particular brake line material is a difficult but important decision. Flexibility is required in brake lines for at least two reasons. First and most important is the flexibility required to accommodate large amounts of relative motion in service, in frame-to-axle applications for example. Less obvious but important is the flexibility required in event a brake line is displaced during repair or alteration of the brake system or other nearby vehicle components. A mechanic's decision to bend a brake line during repairs may depend on whether it 'looks' flexible, and therefore appearance becomes an important element of the determination. On this basis the NHTSA has concluded that copper and steel chassis plumbing, for example, do not invite bending during repairs because their appearance makes their relative inflexibility obvious.#In contrast, plastic air brake chassis plumbing and small sections of hose used to connect steel or copper tubing, are examples of 'flexible conduits' that invite bending in order to make repairs. To ensure that these 'flexible conduits' are not damaged when they are displaced, they are considered brake hose subject to the bend and deformation requirements of the standard. In the case of the Hydrovac, the presence of the neoprene connector would appear to permit flexibility to compensate for component misalignment and to permit removal and repair of the steel tubing. It therefore is considered a brake hose under this standard.#Sincerely yours,Robert L. Carter,Associate Administrator,Motor Vehicle Programs;
ID: aiam2429 Open Mr. Jackson Decker, Chief Product Engineer, E. D. Etnyre & Company, 200 Jefferson Street, Oregon, IL 61061; Mr. Jackson Decker Chief Product Engineer E. D. Etnyre & Company 200 Jefferson Street Oregon IL 61061; Dear Mr. Decker: This is in belated response to your letters of June 22, 1976 concerning the availability of NHTSA interpretation letters and the assignment by vehicle manufacturers of Gross Axle Weight Ratings.; Letters written by this agency that interpret the Federal Motor Vehicl Safety Standards or accompanying regulations are regularly compiled by standard or regulation number and placed in a public file (the 'redbooks') in the Docket Section at Room 5108, 400 Seventh Street, S.W., Washington, D.C. Copies of these letters are distributed informally by various trade associations, as you have noted. However, there is currently no subscription service available directly from the NHTSA. I recommend that you periodically (bimonthly, perhaps) telephone the Docket Section (202 426-2768) to find out whether entries have recently been made in the Redbooks under the standards and regulations that are of particular concern to you.; You have also asked several questions concerning the relationshi between an axle's Gross Axle Weight Rating (GAWR) and the overloading of that axle when the vehicle is in use. GAWR is defined in 49 CFR 571.3 as; >>>the value specified by the vehicle manufacturer as the load carrying capacity of a single axle system, as measured at the tire-ground interfaces.<<<; It is thus a rating assigned by the manufacturer at the time o manufacture. A vehicle whose axle weight ratings are likely to be exceeded under the manufacturer's intended or reasonably forseeable conditions of usage would probably be considered to contain a safety-related defect. Such a vehicle would be subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1392 et seq.).; We cannot prescribe specific steps that a vehicle manufacturer mus take to ensure that a GAWR would not be found so low that it would be a safety-related defect. For example, if a warning in the owner's manual against loading in a certain manner is likely to be ignored, then such a warning would not, by itself, be sufficient. The NHTSA expects the vehicle manufacturer to take reasonable steps, short of refraining from production, to minimize the likelihood of vehicle misuse through overloading.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam4133 Open Joan O'Connell, Esq., DNA-People's Legal Services, Inc., P.O. Box 967, Shiprock, NM 87420; Joan O'Connell Esq. DNA-People's Legal Services Inc. P.O. Box 967 Shiprock NM 87420; Dear Ms. O'Connell: This is in response to your letter of April 23, 1986. You asked whethe New Mexico has sought the approval of the National Highway Traffic Safety Administration to use its certificate of title or other motor vehicle ownership documents as a substitute for the Federal odometer mileage statement prescribed by 49 CFR S580.6.; New Mexico has not sought the approval of this Agency to use th certificate of title, but did submit a separate odometer mileage statement it wished to implement. We granted our approval to use that statement. However, when we subsequently learned that New Mexico was no longer using the form, we advised New Mexico's transportation Department in a letter dated November 28, 1983, that the certificate of title could not be used in lieu of the separate odometer disclosure statement. I have enclosed a copy of that letter.; I have reviewed a sample of New Mexico title contained in The Origina Peck's Title Book which is revised periodically and supplemented as changes occur in the state title laws. The New Mexico title, as it appears in Peck's, indicates that the title has not been revised since 1982. Therefore, for the reasons stated in our November 28, 1983 letter, the New Mexico title cannot be used in lieu of a separate odometer disclosure statement.; Sincerely, Kathleen C. DeMeter, Assistant Chief Counsel for General Law
ID: aiam2901 Open Mr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro:#This is in response to your letter of September 20 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.#Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.#Section 5.2.3 of the standard provides that 'any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3.' There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;
ID: aiam2903 Open Mr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro:#This is in response to your letter of September 20 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.#Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.#Section 5.2.3 of the standard provides that 'any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3.' There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;
ID: aiam4303 Open Prof. P. Soardo, Istituto Elettrotecnico Nazionale, Galileo Ferraris, Strada delle Cacce, 91, 10135 Torino Italy; Prof. P. Soardo Istituto Elettrotecnico Nazionale Galileo Ferraris Strada delle Cacce 91 10135 Torino Italy; Dear Prof. Soardo: This is in reply to your letter of January 16, 1987, to the agency wit reference to the 'homologation in the U.S.A. of a headlamp - optically combined - capable of performing the function of auxiliary driving lamp or as an alternative to the function of the front fog lamp.' You have told us that the device is intended principally for the aftermarket and will use a two- filament H4 bulb, the main filament providing the 'driving beam,' and the secondary filament performing 'the 'fog' function.' When it is mounted on the vehicle it will 'meet the specific aiming requirements contained in the relevant SAE standard, for both light beams.'; As you may know, there are two types of laws in the United States tha pertain to motor vehicle lighting equipment, the laws of the United States government ('Federal' law), and those of the 50 individual States ('Local' law). One of these laws is Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Standard No. 108 specifies requirements for original equipment, and, as a general rule, only aftermarket equipment that is intended to replace original equipment. There are no original equipment requirements in Standard No. 108 for a combination driving-fog lamp such as you discuss, and hence there are no Federal aftermarket requirements for it either. Provided that this lamp does not impair the effectiveness of required front lamps, Standard No. 108 allows a vehicle manufacturer to install the driving-fog lamp as original equipment. Because Standard No. 108 does not allow use of the H4 bulb in headlamps for four-wheeled vehicles, it could not serve as a headlamp. There are no Federal restrictions preventing the sale of this device in the aftermarket as a supplementary lamp.; However, the lamp would be subject to local law, and some of the State may require approval of it before it is offered for sale. The approval of one State does not signify approval by another, so there would not be 'homologation' permitting sale in all States based upon approval by only one State. Even if a Local law does not require approval of a driving-fog lamp, it may forbid its use. We are unable to advise you on Local laws but you may wish to write the American Association of Motor Vehicle Administrator for an opinion. The address of this organization is 1201 Connecticut Avenue, N.W., Washington, D.C. 20036.; Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam0566 Open Mr. Harry T. Armington, General Manager, universal Tire Apparatus Corporation, 613 Center, Logansport, IN 46947; Mr. Harry T. Armington General Manager universal Tire Apparatus Corporation 613 Center Logansport IN 46947; Dear Mr. Armington: This is in reply to your letter of November 12, 1971, in which yo state that you place a fire pump and body on a chassis which you purchase, and ask whether you are required to place a certification label or 'vehicle alteration label' on the vehicle.; It is unclear to us to what you refer by 'vehicle alteration label. However, based on the very limited information you have provided, it appears that you are a final- stage manufacturer under section 568.3 of the regulations covering 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). As such you are required, pursuant to Section 568.6 to complete the vehicle so that it conforms to all applicable motor vehicle safety standards, and to certify compliance to those standards by affixing a certification label in the manner set forth in section 567.5 of the Certification regulations (49 CFR Part 567).; Copies of both the Certification regulations and regulations governin 'Vehicles Manufactured in Two or More Stages' are enclosed.; If you have further questions please write. Sincerely, Richard B. Dyson, Assistant Chief Counsel
ID: aiam2994 Open Mr. C. J. Goode, Chief Engineer, Leyland Cars, P.O. Box 2, Meteor Works, Lode Lane, Solihull, West Midlands B92 8NW, England; Mr. C. J. Goode Chief Engineer Leyland Cars P.O. Box 2 Meteor Works Lode Lane Solihull West Midlands B92 8NW England; Dear Mr. Goode:#I regret the delay in responding to your July 17, 1978 letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.#You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.#You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those items. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.#Sincerely, Michael M. Finkelstein, Associate Administrator for Rulemaking;
ID: aiam2995 Open Mr. C. J. Goode, Chief Engineer, Leyland Cars, P.O. Box 2, Meteor Works, Lode Lane, Solihull, West Midlands B92 8NW, England; Mr. C. J. Goode Chief Engineer Leyland Cars P.O. Box 2 Meteor Works Lode Lane Solihull West Midlands B92 8NW England; Dear Mr. Goode:#I regret the delay in responding to your July 17, 1978 letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.#You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.#You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those items. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.#Sincerely, Michael M. Finkelstein, Associate Administrator for Rulemaking;

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.

Interpretations	Date

ID: aiam5500 Open Mr. Richard J. Kinsey Manager, Fuel Economy Planning & Compliance Ford Motor Company The American Road Dearborn, Michigan 48121; Mr. Richard J. Kinsey Manager Fuel Economy Planning & Compliance Ford Motor Company The American Road Dearborn Michigan 48121; "Dear Mr. Kinsey: This responds to your letter requesting ou concurrence on a procedure for determining the domestic content and country of origin for foreign-sourced allied and outside supplier components. I apologize for the delay in our response. You stated that you would like to obtain the relevant information from your present purchasing systems rather than by soliciting the information from your foreign suppliers. You stated that both processes will result in the same information, and that you believe requiring your foreign suppliers to respond to requests for information would impose costly and unnecessary burdens on those suppliers. We are now in the process of completing our response to several petitions for reconsideration of the final rule on domestic content labeling. Your question is sufficiently related to some of the issues raised by the petitions that we believe it should be addressed in the context of that response, rather than in a separate letter. We realize, however, that manufacturers and suppliers have an immediate need for guidance regarding the procedures for making content determinations for the 1996 model year. In a recent letter (copy enclosed) to the American Automobile Manufacturers Association, we advised that NHTSA had decided to give manufacturers and suppliers for model year 1996 the same alternative they had last year, i.e., in lieu of following the required procedures, they may use other procedures that are expected to yield similar results. Therefore, your planned approach will not raise any concerns for model year 1996. I hope this information has been helpful. If you have any other questions or need some additional information in this area, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure";
ID: aiam1539 Open Mr. J.R. Farron,Bendix Corporation,401 Bendix Drive,South Bend, Indiana 46620; Mr. J.R. Farron Bendix Corporation 401 Bendix Drive South Bend Indiana 46620; Dear Mr. Farron:#This responds to your May 28, 1974, question whether short neoprene connector of two steel vacuum brake lines in the Bendix Hydrovac unit is subject to Standard No. 106, Brake hoses.#The neoprene connector functions as a brake hose under the definition set out in the standard:#>>>'Brake hose' means a flexible conduit that transmits or contains the fluid pressure or vacuum used to apply force to a vehicles brakes.<<<#The determination of the 'flexibility' of a particular brake line material is a difficult but important decision. Flexibility is required in brake lines for at least two reasons. First and most important is the flexibility required to accommodate large amounts of relative motion in service, in frame-to-axle applications for example. Less obvious but important is the flexibility required in event a brake line is displaced during repair or alteration of the brake system or other nearby vehicle components. A mechanic's decision to bend a brake line during repairs may depend on whether it 'looks' flexible, and therefore appearance becomes an important element of the determination. On this basis the NHTSA has concluded that copper and steel chassis plumbing, for example, do not invite bending during repairs because their appearance makes their relative inflexibility obvious.#In contrast, plastic air brake chassis plumbing and small sections of hose used to connect steel or copper tubing, are examples of 'flexible conduits' that invite bending in order to make repairs. To ensure that these 'flexible conduits' are not damaged when they are displaced, they are considered brake hose subject to the bend and deformation requirements of the standard. In the case of the Hydrovac, the presence of the neoprene connector would appear to permit flexibility to compensate for component misalignment and to permit removal and repair of the steel tubing. It therefore is considered a brake hose under this standard.#Sincerely yours,Robert L. Carter,Associate Administrator,Motor Vehicle Programs;
ID: aiam2429 Open Mr. Jackson Decker, Chief Product Engineer, E. D. Etnyre & Company, 200 Jefferson Street, Oregon, IL 61061; Mr. Jackson Decker Chief Product Engineer E. D. Etnyre & Company 200 Jefferson Street Oregon IL 61061; Dear Mr. Decker: This is in belated response to your letters of June 22, 1976 concerning the availability of NHTSA interpretation letters and the assignment by vehicle manufacturers of Gross Axle Weight Ratings.; Letters written by this agency that interpret the Federal Motor Vehicl Safety Standards or accompanying regulations are regularly compiled by standard or regulation number and placed in a public file (the 'redbooks') in the Docket Section at Room 5108, 400 Seventh Street, S.W., Washington, D.C. Copies of these letters are distributed informally by various trade associations, as you have noted. However, there is currently no subscription service available directly from the NHTSA. I recommend that you periodically (bimonthly, perhaps) telephone the Docket Section (202 426-2768) to find out whether entries have recently been made in the Redbooks under the standards and regulations that are of particular concern to you.; You have also asked several questions concerning the relationshi between an axle's Gross Axle Weight Rating (GAWR) and the overloading of that axle when the vehicle is in use. GAWR is defined in 49 CFR 571.3 as; >>>the value specified by the vehicle manufacturer as the load carrying capacity of a single axle system, as measured at the tire-ground interfaces.<<<; It is thus a rating assigned by the manufacturer at the time o manufacture. A vehicle whose axle weight ratings are likely to be exceeded under the manufacturer's intended or reasonably forseeable conditions of usage would probably be considered to contain a safety-related defect. Such a vehicle would be subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1392 et seq.).; We cannot prescribe specific steps that a vehicle manufacturer mus take to ensure that a GAWR would not be found so low that it would be a safety-related defect. For example, if a warning in the owner's manual against loading in a certain manner is likely to be ignored, then such a warning would not, by itself, be sufficient. The NHTSA expects the vehicle manufacturer to take reasonable steps, short of refraining from production, to minimize the likelihood of vehicle misuse through overloading.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam4133 Open Joan O'Connell, Esq., DNA-People's Legal Services, Inc., P.O. Box 967, Shiprock, NM 87420; Joan O'Connell Esq. DNA-People's Legal Services Inc. P.O. Box 967 Shiprock NM 87420; Dear Ms. O'Connell: This is in response to your letter of April 23, 1986. You asked whethe New Mexico has sought the approval of the National Highway Traffic Safety Administration to use its certificate of title or other motor vehicle ownership documents as a substitute for the Federal odometer mileage statement prescribed by 49 CFR S580.6.; New Mexico has not sought the approval of this Agency to use th certificate of title, but did submit a separate odometer mileage statement it wished to implement. We granted our approval to use that statement. However, when we subsequently learned that New Mexico was no longer using the form, we advised New Mexico's transportation Department in a letter dated November 28, 1983, that the certificate of title could not be used in lieu of the separate odometer disclosure statement. I have enclosed a copy of that letter.; I have reviewed a sample of New Mexico title contained in The Origina Peck's Title Book which is revised periodically and supplemented as changes occur in the state title laws. The New Mexico title, as it appears in Peck's, indicates that the title has not been revised since 1982. Therefore, for the reasons stated in our November 28, 1983 letter, the New Mexico title cannot be used in lieu of a separate odometer disclosure statement.; Sincerely, Kathleen C. DeMeter, Assistant Chief Counsel for General Law
ID: aiam2901 Open Mr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro:#This is in response to your letter of September 20 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.#Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.#Section 5.2.3 of the standard provides that 'any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3.' There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;
ID: aiam2903 Open Mr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro:#This is in response to your letter of September 20 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.#Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.#Section 5.2.3 of the standard provides that 'any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3.' There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;
ID: aiam4303 Open Prof. P. Soardo, Istituto Elettrotecnico Nazionale, Galileo Ferraris, Strada delle Cacce, 91, 10135 Torino Italy; Prof. P. Soardo Istituto Elettrotecnico Nazionale Galileo Ferraris Strada delle Cacce 91 10135 Torino Italy; Dear Prof. Soardo: This is in reply to your letter of January 16, 1987, to the agency wit reference to the 'homologation in the U.S.A. of a headlamp - optically combined - capable of performing the function of auxiliary driving lamp or as an alternative to the function of the front fog lamp.' You have told us that the device is intended principally for the aftermarket and will use a two- filament H4 bulb, the main filament providing the 'driving beam,' and the secondary filament performing 'the 'fog' function.' When it is mounted on the vehicle it will 'meet the specific aiming requirements contained in the relevant SAE standard, for both light beams.'; As you may know, there are two types of laws in the United States tha pertain to motor vehicle lighting equipment, the laws of the United States government ('Federal' law), and those of the 50 individual States ('Local' law). One of these laws is Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Standard No. 108 specifies requirements for original equipment, and, as a general rule, only aftermarket equipment that is intended to replace original equipment. There are no original equipment requirements in Standard No. 108 for a combination driving-fog lamp such as you discuss, and hence there are no Federal aftermarket requirements for it either. Provided that this lamp does not impair the effectiveness of required front lamps, Standard No. 108 allows a vehicle manufacturer to install the driving-fog lamp as original equipment. Because Standard No. 108 does not allow use of the H4 bulb in headlamps for four-wheeled vehicles, it could not serve as a headlamp. There are no Federal restrictions preventing the sale of this device in the aftermarket as a supplementary lamp.; However, the lamp would be subject to local law, and some of the State may require approval of it before it is offered for sale. The approval of one State does not signify approval by another, so there would not be 'homologation' permitting sale in all States based upon approval by only one State. Even if a Local law does not require approval of a driving-fog lamp, it may forbid its use. We are unable to advise you on Local laws but you may wish to write the American Association of Motor Vehicle Administrator for an opinion. The address of this organization is 1201 Connecticut Avenue, N.W., Washington, D.C. 20036.; Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam0566 Open Mr. Harry T. Armington, General Manager, universal Tire Apparatus Corporation, 613 Center, Logansport, IN 46947; Mr. Harry T. Armington General Manager universal Tire Apparatus Corporation 613 Center Logansport IN 46947; Dear Mr. Armington: This is in reply to your letter of November 12, 1971, in which yo state that you place a fire pump and body on a chassis which you purchase, and ask whether you are required to place a certification label or 'vehicle alteration label' on the vehicle.; It is unclear to us to what you refer by 'vehicle alteration label. However, based on the very limited information you have provided, it appears that you are a final- stage manufacturer under section 568.3 of the regulations covering 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). As such you are required, pursuant to Section 568.6 to complete the vehicle so that it conforms to all applicable motor vehicle safety standards, and to certify compliance to those standards by affixing a certification label in the manner set forth in section 567.5 of the Certification regulations (49 CFR Part 567).; Copies of both the Certification regulations and regulations governin 'Vehicles Manufactured in Two or More Stages' are enclosed.; If you have further questions please write. Sincerely, Richard B. Dyson, Assistant Chief Counsel
ID: aiam2994 Open Mr. C. J. Goode, Chief Engineer, Leyland Cars, P.O. Box 2, Meteor Works, Lode Lane, Solihull, West Midlands B92 8NW, England; Mr. C. J. Goode Chief Engineer Leyland Cars P.O. Box 2 Meteor Works Lode Lane Solihull West Midlands B92 8NW England; Dear Mr. Goode:#I regret the delay in responding to your July 17, 1978 letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.#You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.#You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those items. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.#Sincerely, Michael M. Finkelstein, Associate Administrator for Rulemaking;
ID: aiam2995 Open Mr. C. J. Goode, Chief Engineer, Leyland Cars, P.O. Box 2, Meteor Works, Lode Lane, Solihull, West Midlands B92 8NW, England; Mr. C. J. Goode Chief Engineer Leyland Cars P.O. Box 2 Meteor Works Lode Lane Solihull West Midlands B92 8NW England; Dear Mr. Goode:#I regret the delay in responding to your July 17, 1978 letter petitioning for reconsideration of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. You requested that the standard be amended to add three ISO symbols so that British Leyland could adopt common specifications in satisfaction of both FMVSS 101-80 and EEC directive 78/316. Your petition is in effect granted in part and is denied in part.#You asked that the ISO symbol (an illuminated light bulb) for the Master Lighting Switch be either substituted for Headlamp and Tail Lamp symbol (an illuminated headlamp) specified in Table 1 of FMVSS 101-80 or added as an option to that specified symbol. This aspect of your petition is denied. If a vehicle contains a master lighting control in addition to a headlamp and tail lamp control, the Master Lighting Switch symbol may be used for the master lighting control. We recognize, however, that most vehicles presently sold in this country have one control that operates all lights, including the headlamps and tail lamps. On vehicles having one control for all lights, the control must be identified by the Headlamp and Tail Lamp symbol. We believe that this is appropriate since the headlamps and tail lamps are the most important lights controlled by a master light control. Further, we believe that the Headlamp and Tail Lamp symbol is more easily recognized than the Master Lighting Switch symbol.#You also asked that the ISO symbol for the Manual Choke be added to Table 1 and the ISO symbol for the Brake System be added to Table 2. No amendment of the standard is necessary to permit your use of these two symbols since FMVSS 101-80 does not specify any requirements regarding symbols for those items. Amendment of the standard to require the use of those symbols would require a new proposal to be issued since such an amendment would be beyond the scope of the October 12, 1976, proposal which led to the June 26, 1978 final rule. Treating this part of your petition as a petition for rulemaking instead of a petition for reconsideration, we grant it. It should be understood that granting the petition does not necessarily mean that an amendment will ultimately be adopted.#Sincerely, Michael M. Finkelstein, Associate Administrator for Rulemaking;

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