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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 171 - 177 of 177
Interpretations Date
 search results table

ID: 10-000638_Bradley_trailer_tail2

Open

Mr. David H. Bradley

Canadian Trucking Alliance

Butterworth House

324 Somerset St. West, Suite 100

Ottawa, ON Canada K2P 0J9

Dear Mr. Bradley:

This responds to your letter concerning an aerodynamic device manufactured by Advanced Transit Dynamics, Inc. (ATDynamics) called a boat tail or trailer tail that some of your member motor carriers would like to install on their van trailers to reduce the fuel consumption of their vehicles. (In this letter, we will refer to these aerodynamic devices generally as trailer tails and to the device manufactured by ATDynamics as the ATDynamics TrailerTail.) You state that use of trailer tail technology would help meet a California Air Resources Board regulation that requires all U.S. and Canadian 53-foot van trailers to achieve a 5 percent overall reduction in greenhouse gas emissions by 2016.

Background

In your letter, you ask for our acceptance of an October 10, 2008 letter from the Director of the Federal Highway Administrations (FHWAs) Office of Freight Management and Operations to ATDynamics, a copy of which you enclosed. (October 10, 2008 letter from Anthony Furst to ATDynamics Andrew Smith.)

In the letter, Mr. Furst discusses FHWA regulation 23 CFR 658.16, Exclusions from length and width determinations. Subsection (b) of 658.16 sets forth exclusions from either the measured length or width of commercial motor vehicles, as applicable, and lists aerodynamic devices in subpart (4).

Mr. Furst states in the letter that FHWA regulation 23 CFR 658.16(b)(4) excludes an aerodynamic device from the measured length of a commercial motor vehicle provided: (1) the device is not capable of carrying cargo; (2) the device does not extend beyond 5 feet of the rear of the vehicle; (3) the device does not obscure tail lamps, turn signals, marker lamps, identification lamps, or safety devices such as hazardous material placards or conspicuity markings; and, (4) the device has neither the strength, rigidity nor mass to damage a vehicle, or injure a passenger in a vehicle that strikes a vehicle so equipped from the rear.

Mr. Furst concludes that FHWA has determined that the ATDynamics TrailerTail meets the conditions of 23 CFR 658.16(b)(4). He states that FHWA--

acknowledges that ATDynamics Trailer Tail was tested by an independent laboratory, KARCO Engineering, and was found to be in compliance with all elements of 23 CFR 658.16(b) (4). Therefore, in accordance with Federal regulations, the ATDynamics Trailer Tail aerodynamic device should be excluded from the length measurements for commercial motor vehicles.

KARCO Engineering determined that the ATDynamics Trailer Tail aerodynamic device Passed all of the conditions listed in the regulation, and FHWA accepts those results.

Mr. Furst also states that FHWA shared the test results with staff from the National Highway Traffic Safety Administration (NHTSA) for review. Mr. Furst states: NHTSA identified a conspicuity marking issue[and] ATDynamics has taken care of the issue in the manner NHTSA recommended.

With that background in mind, in your letter to us you ask for clarification from NHTSA with regard to the process for defining compliance with 23 CFR 658.16(b)(4) on aerodynamic devices. In other words, as we understand your letter, you ask us to confirm that use of the ATDynamics TrailerTail would not violate Federal laws administered by NHTSA.

We note that Transport Canada has also contacted us for our views on trailer tails.

NHTSAs Framework

It would be helpful in answering your question to begin with a discussion of NHTSAs authority under the National Traffic and Motor Vehicle Safety Act (49 U.S.C. Chapter 301, Vehicle Safety Act).

NHTSA is authorized under the Vehicle Safety Act to issue Federal motor vehicle safety standards (FMVSSs) applying to the manufacture and sale of new motor vehicles and items of motor vehicle equipment. Manufacturers are required to self-certify that their products conform to all applicable FMVSSs in effect on the date of manufacture. This agency does not provide approvals of new motor vehicles or of modifications of used vehicles.

NHTSA has exercised its rulemaking authority to establish a number of standards that apply to new trailers. Those standards include FMVSS No. 108, Lamps, reflective devices, and associated equipment (49 CFR 571.108), which requires trailers to have specified systems to provide adequate illumination of the roadway and to improve the conspicuity of the vehicles. Another standard applying to trailers is FMVSS No. 224, Rear impact protection (49 CFR 571.224). Standard No. 224 requires trailers to have rear impact guards to reduce the harm to occupants of light duty vehicles impacting the rear of the trailer. Each new trailer with a trailer tail sold in the U.S. must be certified by its manufacturer as complying with all applicable standards, including FMVSS No. 108 and No. 224.

After the first purchase of a vehicle for purposes other than resale, the Vehicle Safety Act limits modifications that may be made to the vehicle by commercial entities. 49 U.S.C. 30122 states:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard prescribed under this chapter.

In the case of the motor carriers mentioned in your letter, this provision would prohibit a commercial business from installing a trailer tail on a motor carriers new or used vehicle in a manner that would negatively affect the vehicle's compliance with FMVSS No. 108 or No. 224 or any other safety standard.[1], [2]

Discussion

The question posed by your letter is whether installing the ATDynamics TrailerTail on a new or used vehicle would be permitted under NHTSAs regulations.

Unfortunately, we cannot provide a sweeping answer that covers all installations of the ATDynamics TrailerTail. NHTSA assesses the compliance of new vehicles and administers the make inoperative provision of the Vehicle Safety Act concerning new or used vehicles independently from other agencies. We do not approve motor vehicles or processes undertaken by manufacturers.

A possible violation of the FMVSSs or the make inoperative provision is evaluated by NHTSA according to the facts of each particular case. Thus, NHTSA would evaluate, among other matters, the design and construction of a particular ATDynamics TrailerTail, the manner in which the trailer tail was attached, and whether the trailer tail impaired the effectiveness of the trailers lamps and other devices installed pursuant to FMVSS No. 108. We cannot prospectively and categorically affirm that all future uses of the ATDynamics device would be acceptable to this agency.

However, we recognize and appreciate the effort that has been made seeking the agencies input in exploring possible safety issues related to the ATDynamics TrailerTail. In view of those efforts, we make the following observations based on the KARCO Engineering (KE) test.

KE conducted a 35 mile per hour rear offsest crash test for ATDynamics. ATDynamics installed a TrailerTail on a 1991 Pine Trailer. The test vehicle and set-up was prepared by KE. The impacting vehicle was a 1994 Ford Econoline 350 Van. Two Hybrid III 50th percentile adult male test dummies equipped with head triaxial accelerometers to measure head injury accelerations were placed in the driver and right-front passenger seating positions. KEs report on the test states (Laboratory Test Report, Rear-Mounted Aerodynamic Device, TrailerTail mounted to a 1991 Pine Trailer, Prepared for Advanced Transit Dynamics, Inc., July 22, 2008, KARCO Engineering):

(a) Inspection of pre- and post-test photographic data showed no appreciable deformation of any structural component of the impacting vehicle attributable to the trailer tail (not including glass, plastic lenses, or trim components);

(b) The head injury criterion of neither test dummy exceeded a value of 1,000 as a result of direct contact with the trailer tail; and

(c) There was no evidence from either post-test inspection of the transfer of chalk applied to the test dummies or from still or high speed photography that the trailer tail or any resilient component of the impacting vehicle made contact with any portion of the test dummies as a result of contact of the impacting vehicle with the trailer tail.

In addition, the report indicates that the open geometry of the ATDynamics TrailerTail does not allow it to carry cargo, and that the vehicles lamps and conspicuity markings would meet FMVSS No. 108.

The test data from the KE test indicate that the ATDynamics TrailerTail did not negate the vehicles ability to meet FMVSS No. 224[3] and that the rear impact guard on the vehicle was not made inoperative by the ATDynamic TrailerTail. Thus, there is no basis for NHTSA to conclude at this time that installation of the ATDynamics TrailerTail is prohibited.

Please note that NHTSA is interested in Transport Canadas on-going work evaluating the safety and performance of trailer tails. NHTSA will evaluate the outcome of Canadas research to see if we should undertake further work on trailer tails.

If you have any other questions, please contact Deirdre Fujita of my staff at this address or by phone at (202) 366-2992.

Sincerely,

O. Kevin Vincent

Chief Counsel

1/24/2011




[1] The make inoperative provision applies to a manufacturer, distributor, dealer, or repair business installing a trailer tail, and not to a vehicle owner that modifies its own vehicle. However, States have the authority to regulate the operation of vehicles in their jurisdictions, and may have restrictions on the type of modifications owners may make.

[2] The Vehicle Safety Act also requires manufacturers of motor vehicles and motor vehicle equipment to ensure that their products are free of safety-related defects. A trailer tail would be considered motor vehicle equipment under the Vehicle Safety Act.

[3] That is, it appears that the trailer tail would qualify as a nonstructural protrusion under FMVSS No. 224. See S4, definition of rear extremity.

ID: nht91-4.42

Open

DATE: July 8, 1991

FROM: Ken Hanna -- Lectric Limited Inc.

TO: Richard Van Iderstine -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7-29-91 from Paul Jackson Rice to Ken Hanna (A38; Std. 108)

TEXT:

In reference to our last conversation regarding the manufacturing of sealed beam bulbs for antique cars. As per your suggestion, we are gathering data so that we may submit a comprehensive petition with all pertinent information included requesting reinstatement of SAE J579A.

Since it may take up to two years to reinstate SAE J579A and we are anxious to get our sealed beam headlight project underway, we would like to manufacture bulbs in the interim which meet J579C specifications in terms of candlepower and photometrics. However, since these bulbs will lack various identification nomenclature on the face of the lenses which are required by SAE J579C we would like to market these bulbs with clear identification on the packaging identifying them "for display purposes only and not approved for highway use". I discussed this possibility with you in our last conversation and as I recall you felt that NHTSA had no jurisdiction over products which are not intended for highway use and do not fall under the same regulations and specifications required of products which are intended for highway use.

Please let me know as soon as possible whether or not we will be violating any NHTSA restrictions by manufacturing and marketing these bulbs in this manner.

ID: 2844o

Open

Oral Interpretation of Standard No. l08:
Optical Combination

Z. Taylor Vinson Senior Staff Attorney

Interpretations Files

Recently a lamp manufacturer phoned to ask whether a replacement lighting device it had developed for installation on trucks and trailers in use would be allowable under Standard No. l08.

The lamp as described is an amber-lensed wrap-around lamp incorporating a clearance lamp to the front and a marker lamp to the side, with one bulb for each function. I replied that the prohibition in S4.4. applicable to clearance lamps forbade their combination only with identification lamps and stop lamps, and that if his combination lamp met photometric and mounting requirements applicable to each function, it appeared to be permissible under Standard No. l08.

# ref:108 d:4/6/88

1988

ID: 1983-2.5

Open

TYPE: INTERPRETATION-NHTSA

DATE: 05/11/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Truck-Lite Co. Inc. -- John E. Bennett, Director, Research & Engineering

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John E. Bennett Director - Research & Engineering Truck-Lite Co., Inc. 310 East Elmwood Avenue Falconer, New York 14733

Dear Mr. Bennett:

This in response to your letter of April 12, 1983, asking for interpretation of paragraph S4.6(b) of Motor Vehicle Safety Standard No. 108.

This paragraph states in pertinent part that "means may be provided to flask...side marker lamps for signalling purposes." You have first asked whether the rear side marker can be made to flash. You have also asked whether this language may be interpreted as allowing both front and rear side marker lamps to be flashed. The answer to both questions is yes. In the absence of restrictive language, paragraph S4.6 may be interpreted as allowing flashing of either front or rear side marker lamps, or both sets of lamps.

You have also asked whether, where the rear side marker and taillamp used the same optical source ("minor filament of a 1157 or similar bulb"), it is acceptable to have an overriding signal lamp is actuated. The answer is yes. The standard's prohibition against optical combinations (paragraph S4.1.1) does not preclude this design.

We hope that this answers you questions.

Sincerely,

Frank Berndt Chief Counsel

April 12, 1983

Attention: Office of Chief Counsel (Room 5219)

Subject: Request for interpretation of an element of FMVSS-108

Dear Sir:

In our endeavor to continue the advancements of vehicle lighting devices, which is a continuing assignment within our company, and offer specialized products to our customers with inherent benefits to the consumers, we have under consideration a new product which requires an interpretation of Section S4.6 Item (b), FMVSS-108, before we finalize our programs.

This section (S4.6) of FMVSS-108 requires.. "when activated:

a. Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall flash; and b. All other lamps shall be steady burning, except that means may be provided to flash headlamps and side marker lamps for signalling purposes."

Our questions are in reference to the rear side marker lamp and item (b) above. They are stated as follows:

a. Can the rear side marker be made to flash? Is Section S4.6, Item (b) to be interpreted as both front and rear side marker lamps may be flashed for signalling purposes? We know of only one current production (Jeep CJ) vehicle which the rear side marker lamp might be so viewed.

b. In a design where the rear side marker function and the rear tail lamp use the same optical source (minor filament of a 1157 or similar bulb), is it acceptable to have an overriding-flashing signal visible through the rear side marker lens when the signal lamp is actuated?

We are attempting to market a new product within the near future and do not wish to proceed until the above is cleared. Therefore we would appreciate your response to your questions as soon as possible.

Kindly accept our thanks for your prompt attention to this request. Do not hesitate to contact me if I can be of additional assistance.

Sincerely,

TRUCK-LITE CO., INC.

John E. Bennett Director - Research & Engineering JEB:h cc: R. Kotsi

ID: 21871.ztv

Open



    Mr. Thomas C. Bliss
    3M Traffic Control Materials Division
    3M Center
    St. Paul, MN 55144-1000



    Dear Mr. Bliss:

    This is in reply to your letter of June 30, 2000, asking for interpretations of S5.7, Retroreflective Sheeting, of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

    Several of your customers would like "to incorporate their company logo directly into the conspicuity markings used on their vehicles." You understand that "our customer is permitted to use their logo on markings placed on the vehicle in excess of the amount required to satisfy the minimum coverage stated in the regulation," and you ask that we confirm that interpretation.

    S5.7.1.4.2(a) requires that a strip of retroreflective sheeting, "originating and terminating as close to the front and rear as practicable," be applied to the side of trailers, but that "the strip need not be continuous as long as not less than half of the length of the trailer is covered. . . ." This exception is intended to accommodate different trailer configurations by allowing breaks in the conspicuity material where the features of the trailer are such that it may not be feasible to install continuous sheeting. A manufacturer must comply when half the trailer length is covered, but if it wishes to add more conspicuity material to the portion of the trailer length that is not covered, the material must comply with S5.7. We view the installation of nonconforming material on the side as subject to the prohibition in S5.1.3 that no additional reflective material or other motor vehicle equipment shall be added that impairs the effectiveness of lighting equipment required by the standard. For this reason, the appropriate question is, as you have asked in your first question, "do conspicuity markings that incorporate a logo conform to FMVSS 108?"

    First, because the standard requires conspicuity markings to be either red or white, the introduction of a third color (or white on a red section and vice versa) would not conform to Standard No. 108. Thus, any logo must be red or white. Assuming the logo is red or white, the answer is similar to that which we have provided inquirers as to whether logos are acceptable on the lens of the center high-mounted stop lamp. Both the lamp and retroreflective sheeting must meet the color and photometric requirements that are specified for each. If the sheeting meets the color, photometric, and all other requirements with the logo in place, then retroreflective sheeting incorporating a logo would comply with Standard No. 108. This, of course, would permit a logo that straddles red and white segments of retroreflective sheeting as well as a logo that is contained entirely within either a red or white segment. However, because the standard requires segments of red and white, a red logo could not appear in a white segment and vice versa. A logo (or portion of a logo) in a red segment could, however, be shown in a different shade of red, and a logo (or portion) in a white segment could be shown in a different shade of white, provided that both shades of red and both shades of white complied with the red and white color specifications of SAE J578c.

    Your next question is whether conspicuity markings that incorporate a logo would "qualify as conspicuity markings under FMVSS 108." S5.7 prescribes dimensions for the width of the sheeting and the length of the individual segments. As noted above, a logo could be inserted in otherwise conforming sheeting if the sheeting meets the photometric, color, and all other requirements with the logo in place.

    You have also asked whether "conspicuity markings that incorporate a logo [are] taken into account when assessing conformance to FMVSS standard 108." The coefficients for retroreflection of each segment of red and white sheeting must be not less than the minimum values specified in Fig. 29 of Standard No. 108. In determining conformance with S5.7, if a logo prevented a segment of sheeting from complying with the photometric or any other requirement, we would consider that the segment failed to comply with Standard No. 108. Thus, the answer to this question is yes.

    Finally, you have asked whether "a 48mm (2 inch) wide marking with a logo [which] conforms to the performance requirements necessary for DOT -C2, can . . . be considered DOT-C2 marking." The answer is no. S5.7.1.3(d) requires DOT -C2 sheeting to have a width of not less than 50mm. The sheeting in your question is 2mm too narrow to be DOT-C2, even if it meets the photometric requirements for DOT -C2 sheeting with the logo in place.

    If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).



    Sincerely,

    Frank Seales, Jr.
    Chief Counsel

    ref:108
    d.10/6/00



2000

ID: 1983-1.2

Open

TYPE: INTERPRETATION-NHTSA

DATE: 01/07/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Stanley Electric Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 23, 1982, to Mr. Elliott of this agency asking whether you may distinguish between U.S. and Japanese-manufactured lighting equipment subject to Federal Standard No. 108 by marking the lenses "U.S.A. DOT" and "JAPAN DOT", rspectively.

As you know, the National Highway Traffic Safety Administration has not adopted the SAE standard on equipment marking, J759c. This means that the only marking subject to Standard No. 108 is that which certifies compliance to all applicable Federal motor vehicle safety standards, the DOT symbol. We believe that the intended proximity of the words "Japan DOT" in your Japanese-manufactured equipment might create the impression that Stanley was certifying compliance to the requirements of the Japanese Ministry of Transport, rather than to those of the U.S. Department of Transportation. Therefore, we suggest that you place the word "Japan" at the end of the line rather than adjacent to the "DOT" symbol.

SINCERELY,

STANLEY ELECTRIC CO., LTD.

November 23, 1982

Att.: Marx Elliott Office of Rulemaking

National Highway Traffic Safety Administration

Dear Mr. Elliott,

We, Stanley Electric Co., Ltd. corporated in Japan (hereafter reffered to as STANLEY-JPN) have estblished Stanley Electric U.S. Co., Inc. corporated in London, Ohio (hereafter reffered to as STANLEY-US) with 100 % investments, and we are in process of preparing to start producing, beginning with the lighting equipments for 1984 model vehicles.

In the work we are proceeding, we are faced with a problem, the first case for us, which relates to the identification marking to be indicated on the lighting devices. So, we would like to ask you whether or not our view is right.

Honda Motor Co., LTD. (Japan) will manufacture the same type of vehicles both in Japan and in U.S.A (HONDA OF AMERICA). Therefore, their lighting devices of the same design will be manufactured by STANLEY-JPN and by STANLEY-US, and supplied to the Honda plant in each area.

Because these lighting devices are of the same design (STANLEY-JPN keeps the original drawings. And only STANLEY-JPN takes proceedings for their modifications.), we intend to indicate the same indentification making to the products made in Japan and made in U. S. A. However, in order to make a country of origin clear, it is our intention to add the marking "JAPAN" or U.S.A." to the identification marking, though it is not explained in Lighting Identification Code-SAE J759c.

The following is an example:

For products made in Japan : "STANLEY 043-6371 SAE AIST 80 JAPAN DOT"

For products made in U.S.A.: "STANLEY 043-6371 SAE AIST 80 U.S.A. DOT"

Please let us know whether or not the above view has no problem.

Thanking you in advance,

H. Miyazawa Director, Automotive Lighting Engineering Dept.

ID: 1652y

Open

Mr. Leonard M. Perkins
213 S. Pleasant
Prescott, AZ 86303

Dear Mr. Perkins:

Secretary Burnley has asked me to respond to your letter of September 7, 1988, with respect to your lighting device. In essence, this is a center high-mounted stop lamp, with turn signal lamps adjacent to it. You believe that high-mounted turn signals "joined with the rear window brake light should have a dramatic effect on rear and side collisions", but you have been told that "this conception is at present illegal."

Paragraph S4.4 of Federal Motor Vehicle Safety Standard No. l08 states that "no high-mounted stop lamp shall be combined with any other lamp or reflective device." We interpret this as prohibiting lamps or reflective devices that share a single lens or compartment with the center highmounted lamp. Your device shows lamps adjacent to the center highmounted lamp but not combined with it. Therefore, your device is not prohibited by that paragraph of the standard if you wish to market this device as original equipment. The next question to ask is whether it impairs the effectiveness of required lighting equipment (paragraph S4.1.3), principally the center stoplamp. For example, if the yellow turn signals were too bright or if the color of the turn signal were red, these lamps might "impair the effectiveness" of the center stoplamp. However, this is a determination to be made, in the first instance, by the manufacturer of the vehicle who must certify compliance with Standard No. l08.

If you wish to sell your device in the aftermarket, it is acceptable under Federal law if its installation does not adversely affect the operation of motor vehicle equipment installed in accordance with a Federal motor vehicle safety standard so that the equipment would no longer comply with the standard. Assuming that the installation does not have this effect, the legality of installing or using such a device must then be determined according to the laws of any State in which a vehicle so equipped is registered or operated, and these auxiliary lamps must comply with any State requirements. We cannot advise you on State laws. One source of advice is the American Association of Motor Vehicle Administrators, 4600 Wilson Blvd., Arlington, Va. 22203.

Sincerely,

Erika Z. Jones Chief Counsel

ref:108 d:l/l8/89

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.