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: 07-002490drnOpenMs. Julie Laplante Les Entreprises Michel Corbeil, Inc. 830, 12 ime Avenue Saint-Lin-Laurentides (Qubec) J5M 2V9 CANADA Dear Ms. Laplante: This responds to your letter asking about Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release. You ask for guidance whether Corbeil should follow the school bus floor plan of a potential customer, and place a wheelchair securement position in front of an emergency exit window. We believe that school buses should not have a wheelchair anchorage position placed in a position that blocks an emergency exit. However, the exit you ask about is not a mandatory school bus emergency exit. Background In your letter, you state that a client wishes to purchase a new school bus with one emergency exit window on each side. A floor plan provided with your letter shows that the school bus is designed to have four wheelchair anchorage positions and two seat benches, both of which are 36 inches in length. You state that on the right hand side of the bus, there are only wheelchair positions (two wheelchair anchorage positions), so a wheelchair or wheelchair and passenger tiedowns must be placed in front of an emergency exit. You further state that neither FMVSS No. 217 nor State law requires the side emergency exit windows. You wish to know whether to agree with your clients request to place a wheelchair anchorage position in front of an emergency exit window, with the DO NOT BLOCK label. The Emergency Exit Windows Are Beyond What Is Required In response, I note that the seating capacity of the school bus at issue is fewer than 45 passengers because there are four wheelchair positions[1] plus two benches. Thus, no additional emergency exit beyond the rear emergency exit door is required. (See S5.2.3.1(a) and (b).) Any emergency exit windows provided on the school bus at issue would therefore be considered voluntarily provided.
Our longstanding interpretation of FMVSS No. 217 with regard to labeling requirements for voluntarily provided emergency exits in school buses can be found in an interpretation letter of July 6, 1979 to Mr. Robert B. Kurre (copy enclosed). In that letter, NHTSA stated that exits installed in school buses beyond those required by S5.2.3.1 need not comply with the exit requirements applicable to school bus exits. Instead, NHTSA interpreted the standard as requiring all additional exits to meet the requirement in the standard applicable to non-school buses. Thus, for the school bus you ask about, any side emergency exit window provided need not be marked DO NOT BLOCK. However, if side emergency exit windows are provided, they must be marked in accordance with S5.5.1 of FMVSS No. 217, which requires the designation Emergency Exit followed by concise operating instructions describing each motion necessary to unlatch and open the exit, located within 16 centimeters of the release mechanism. In addition, S5.5.1 states that when a release mechanism is not located within an occupant space of an adjacent seat, a label meeting the requirements of S5.5.2 that indicates the location of the nearest release mechanism shall be placed within the occupant space. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Please note that our address has changed. Our new address is: Office of the Chief Counsel, National Highway Traffic Safety Administration, 1200 New Jersey Avenue, SE, Mail Code: W41-227, Washington, DC 20590. Sincerely yours, Anthony M. Cooke Chief Counsel Enclosure ref:217 d.7/24/07 [1] Pursuant to the definition of designated seating position at 49 CFR Section 571.3, each wheelchair position in the school bus is regarded as four designated seating positions. Therefore, the four wheelchair positions in the school bus can be regarded as totalling 16 designated seating positions. Since the two benches at issue are both 36 inches long, each would represent 2 designated seating positions, or a total of 20 passengers. |
2007 |
ID: ES09-007169 213OpenThe Honorable Diana DeGette Member, U.S. House of Representatives 800 Grant Street, Suite 202 Denver, CO 80203 Dear Congresswoman DeGette: Thank you for your letter on behalf of Mr. Glenn Aaron of Denver, regarding the National Highway Traffic Safety Administrations (NHTSAs) requirements for child restraint systems and Mr. Aarons vehicle harness restraint systems. Mr. Aaron has asked you to contact NHTSA to overturn their rulemaking of non-compliance. NHTSA is authorized (49 U.S.C. 30101 et seq.)(the Safety Act) to issue Federal motor vehicle safety standards that establish performance requirements for new motor vehicles and items of motor vehicle equipment. We have used this authority to issue Federal Motor Vehicle Safety Standard (Standard) No. 213, Child Restraint Systems (49 CFR 571.213). NHTSA regulates the manufacture and sale of new child restraints and requires all new child restraint systems imported into or sold in this country to be certified as meeting Standard No. 213. Mr. Aaron has separately written to NHTSA asking about our requirements for child harness systems. We have responded by a separate letter, a copy of which is enclosed. In our response, we explain that Standard No. 213 would apply to the harnesses Mr. Aaron wishes to manufacture. Unfortunately, it appears that Mr. Aarons harnesses would not meet a number of requirements of the standard. To increase the likelihood that child restraints are correctly used, Standard No. 213 standardizes the means of attachment of child restraints, including harnesses. The standard requires harnesses to attach to a vehicle seat by means of a Type 1 seat belt assembly (i.e., a vehicle lap belt). Mr. Aarons harnesses do not comply with Standard No. 213 because the harnesses are not capable of being installed on a vehicle seat by the lap belt system. Although Mr. Aaron did not describe his harnesses in detail in his letter to NHTSA or to your office, agency staff has seen photographs of a rear-facing child harness on the website he once had. It appeared to NHTSA staff viewing the website that the top of the rear-facing restraint was slung like a hammock from the head restraint of the front passenger seat to a ceiling anchor in the rear. As explained in our letter to Mr. Aaron, anchoring a restraint to or hanging it from the head restraint is not permitted by FMVSS No. 213. There could be
Page 2 The Honorable Diana DeGette excessive forces imposed by the child restraint on the forward seat, and dangerous crash forces transmitted to a child suspended from the head restraint of the vehicle seat. These and other potential conflicts with FMVSS No. 213 are discussed in the enclosed letter. Because Mr. Aarons harnesses would not meet the requirements of the standard, they can not be certified as meeting FMVSS No. 213 and can not be sold in this country. Interested persons may petition NHTSA to initiate rulemaking to amend the FMVSS (49 CFR Part 552). However, the agency denies petitions that are not in the interest of motor vehicle safety. Mr. Aaron has asked for information regarding the toxicity of the material used in the plastic frames of conventional child restraints. This agency does not have information indicating a problem relating to motor vehicle safety. I hope this information will prove useful to you and your constituent. If you have any questions, please have your staff contact me or O. Kevin Vincent, NHTSAs Chief Counsel, at (202) 366-9511. Sincerely yours, David L. Strickland Enclosure Dated: 2/18/2010 |
2010 |
ID: nht95-1.42OpenTYPE: INTERPRETATION-NHTSA DATE: February 2, 1995 FROM: Philip R. Recht -- Chief Counsel, NHTSA TO: Lori A. Hawker TITLE: NONE ATTACHMT: Attached to 11/29/94 letter from Lori A. Hawker to NHTSA Chief Council (OCC 10536) TEXT: Dear Ms. Hawker: This responds to your letter asking about safety regulations for a product you wish to manufacture. You describe the product as "bunting" that fits inside an infant-only car seat. (An infant-only seat is lightweight and is easily used as an infant carr ier to carry an infant to and from the car.) The bunting is intended as a substitute for a blanket. You state that the bunting has slots through which the harness on the car seat is threaded and the buckle of the harness is attached to the car seat. Yo u believe that, when properly installed, "the bunting in no way interferes with the adjustment or function of the safety straps or buckle mechanism." By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, appro ve or certify any vehicles or items of equipment. The following represents our opinion based on the information in your letter. There is currently no Federal motor vehicle safety standard (FMVSS) that directly applies to your product. Our standard for "child restraint systems," FMVSS 213, applies to "any device except Type I or Type II seat belts, designed for use in a motor veh icle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." (S4 of FMVSS 213) The standard does not apply to child seat accessories that are sold separately from the child seats, such as car seat pillows, pads and bunting. While no FMVSS applies to the bunting, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. @@ 30118-30121 concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be resp onsible for notifying purchasers of the defective equipment and remedying the problem free of charge. In addition, while it is unlikely that the bunting would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, 49 U.S.C. @ 30122 prohibits those businesses from installing the device if the installation "makes inoperative" compliance with any safety standard. Standard 213 specifies flammability resistance requirements for infant seats. Any person listed in @ 30122 who installs the bunting must ensure that the product does not vitiate the seat's compliance with those fla mmability resistance requirements. The prohibition of @ 30122 does not apply to individual owners who install equipment in their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to degrade the safety of their vehicles. I would like to close with the following remarks. It is crucial for the safety of an infant that the straps of its infant seat retain the baby's torso in a crash. Excessive slack in the straps due to the straps binding up on a fabric liner in the seat (such as bunting material), or because of excessive compression of the liner, can cause shoulder straps to move off an infant's shoulders. As a consequence, the infant can be ejected from the seat. We know that you recognize the importance of the strap s in a crash, and that you believe that the bunting will not interfere with their adjustment or function. We underscore the importance of this feature. Bunting material that degrades the ability of an infant seat to restrain its occupant would be an ob vious safety problem. I hope this information has been helpful. If you have any other questions, please feel free to contact Deirdre Fujita of my staff at this address or by phone at (202) 366-2992. Sincerely, |
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ID: nht87-1.50OpenTYPE: INTERPRETATION-NHTSA DATE: 03/20/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: James R. Mitzenberg -- Project Engineer, The Flxible Corporation TITLE: FMVSS INTERPRETATION TEXT: Mr. James R. Mitzenberg Project Engineer The Flxible Corporation 970 Pittsburgh Drive Delaware, Ohio 43015 This is in reply to your letter of January 22, 1987, asking further questions of permissible lamp operations. With reference to the deceleration warning system discussed previously in our correspondence, you have asked whether there would be a noncompliance with Standard No. 108 if the triple steady burning amber lamps are operated simultaneously with the steady burning rear stop lamps, or with the flashing turn signal lamps (either red or amber). In neither instance do we believe that an impairment of required lighting equipment world result, within the prohibition of paragraph S4.1.3. I hope that this answers your questions. Sincerely, Erika Z. Jones Chief Counsel Dear Ms. Jones The Flxible Corporation has received your interpretation, dated December 8, 1986, concerning the operation of deceleration lights. This interpretation stated that the flashing mode of the amber deceleration lights impaired the effectiveness of the steady burning red stop lamps. Also, the amber deceleration lights must be steady burning in every mode. Two additional issues require an interpretation from NHTSA concerning amber steady burning deceleration lights. The amber deceleratin lights would be activated steady burning when the accelerator is released and deactivated when the accelerator is depres sed. Would a noncompliance with FMVSS 108 result with the simultaneous operation of the amber steady burning deceleration lights with the following required FMKVSS 108 lights? 1. Activation of the steady burning red stop lights. 2. Activation of flashing red or amber (color depending on customer) turn signal lights. In order to assure compliance with FMVSS 108 with an OEM installation of amber steady burning deceleration lights, we request an additional interpretation on their simultaneous operation with the normal rear stop anbd turn signal lights. Sincerely, James r. Mitzenberg Project Engineer |
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ID: nht90-3.69OpenTYPE: Interpretation-NHTSA DATE: August 27, 1990 FROM: William Shapiro -- Manager, Regulations and Compliance, Volvo Cars of North America TO: Paul J. Rice -- Chief Counsel, NHTSA TITLE: Re FMVSS 210, Request for Interpretation ATTACHMT: Attached to letter dated 11-9-90 from P.J. Rice to W. Shapiro (A36; Std. 210) TEXT: Section 4.3.2 of FMVSS 210 sets forth the anchorage location requirements for the upper torso portion of type 2 seat belt assemblies. Section 3 defines seat belt anchorage as the provision for transferring seat belt assembly loads to the vehicle structu re. Volvo is currently designing a type 2 seat belt assembly for the rear seating positions of a proposed vehicle. The retractor is mounted within the seat back, in order to improve the seat belt geometry, to increase the comfort of the occupants, and to al low movement of the seat back. The retractor is located outside of the zone specified in Section 4.3.2, figure 1. However, the shoulder portion of the belt travels from the retractor through a device we are calling a "belt anchor", which is the functio nal equivalent of a d-ring. Kindly see the attached drawings, Appendices A & B, for clarity. The belt anchor is located within the specified zone. Its function is to transfer the seat belt assembly load to the vehicle structure, and to determine the angle the belt crosses the vehicle occupant. This belt anchor complies with the force requirements of the standard. Please see the attached drawings, Appendices C, D & E for the forces in the proposed design. For comparison, Appendices F & G show the forces on a current vehicle. Volvo believes that a correct interpretation of FMVSS 210 in this case is that the belt anchor is the upper anchorage point for this seat belt system. Please confirm this for us. Our engineers must finalize the design by this Fall. As such, we respectfully request that you reply by November 1, 1990. Thank you for your attention to this matter. Should you have any questions, kindly contact Linda Gronlund of my office at 201-767-4815. |
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ID: 86-1.9OpenTYPE: INTERPRETATION-NHTSA DATE: 01/21/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Finbarr J. O'Neill TITLE: FMVSS INTERPRETATION TEXT:
January 21, 1986 Finbarr J. O'Neill, Esq. General Counsel Hydundia Motor America 7373 Hunt Avenue P.O. Box 2669 Garden Grove, CA 92642-2669 Dear Mr. O'Neill: This responds to your letter asking about the requirements of FMVSS No. 101, Controls and Displays, concerning the color of the highbeam telltale. You stated that while Table 2 of the standard indicates that a manufacturer has the option of choosing a green or blue telltale, your review of competitive vehicles shows that virtually all have chosen blue telltales. You asked whether NHTSA has taken any position as to whether one color is preferable to the other. You also asked for comment on whether NHTSA has taken any position as to whether one color is preferable to the other. You also asked for comment on whether NHTSA has any reasonable anticipation of changing this requirement. I would note that in the past NHTSA required the highbeam telltale to be blue. That color was selected primarily to promote international harmonization of standards regulating vehicle controls and displays. Blue is the color requirement of the International Standards Organization, the Economic Commission for Europe, and the European Economic Community. On January 21, 1982, NHTSA amended Standard No. 101 to permit green as an alternative to blue (47 FR 2996). The purpose of the change was to allow the use of light emitting diode technology, which at that time could not produce the color blue. While we do not have a preference as such as to how manufacturers choose to meet our standards, we would note that use of the color blue tends to promote international harmonization. On September 12, 1985, NHTSA published in the Federal Register (50 FR 37240) a notice of proposed rulemaking to amend FMVSS No. 101. Among other things, the proposal concerns color requirements for electronic displays. See 50 FR 37244. We have enclosed a copy of the notice for your convenience. I hope this information is helpful. Sincerely, Original Signed By Erika Z. Jones Chief Counsel |
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ID: nht78-3.19OpenDATE: 04/05/78 FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA TO: Grumman Flxible Corporation TITLE: FMVSS INTERPRETATION TEXT: This responds to your recent letter asking whether Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages, would be applicable to a Type I seat belt assembly used as a securement device for wheelchairs in an urban transit bus. Safety Standard No. 209 is an equipment standard that is applicable to any seat belt manufactured for use on passenger cars, multipurpose passenger vehicles, trucks or buses. Therefore, the seat belt in question would have to comply with the performance requirements of that standard. Safety Standard No. 210, however, only specifies requirements for seat belt anchorages at the driver's position on buses. Since the assembly you are concerned with would be at a passenger seating position in the bus, it would not have to comply with the anchorage requirements of Standard No. 210. SINCERELY, GRUMMAN FLXIBLE CORPORATION February 10, 1978 Office of the Chief Counsel National Highway Traffic Safety Administration Attention: Hugh Oats Dear Mr. Oats: The Grumman Flxible Corporation is using an extra-long, Type 1 seat belt as a wheelchair securement device in association with the wheelchair accessibility option required by 49 CFR 609.15(c) for installation in urban transit buses. This seat belt is used in conjunction with an adjustable, padded arm extending from the vehicle wall area which can be positioned in front of the forward facing wheelchair passenger. Is this seat belt subject to the requirements of FMVSS No. 209, Seat Belt Assemblies? Is the anchorage for this seat belt assembly, installed in a transit bus at a location other than at the driver's position, subject to the requirements of FMVSS No. 210, Seat Belt Assembly Anchorages? We appreciate very much your assistance with the above. R. L. Ratz, P.E. Product Safety Engineering |
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ID: nht94-3.71OpenTYPE: Interpretation-NHTSA DATE: July 15, 1994 FROM: Guy Dorleans -- Legal Compliance Department, Valeo Vision (France) TO: Office of Chief Council, NHTSA TITLE: None ATTACHMT: Attached to letter dated 8/31/94 from John Womack to Guy Dorleans (A42; Std. 108) TEXT: I am inquiring for information and assistance with the interpretation of Section 571.108 of the Federal Traffic Code. The attached sketch shows the front end of a vehicle which incorporates the following features: Lamp A is a highbeam contributor with one monofilament light source. The wiring of the vehicle dies not allow this lamp to be lit alone in highbeam mode. Lamp A is 150 mm high, between level 750 and level 600 above the ground. Lamp B is the lowbeam with one monofilament light source. Its light emitting area is 50 mm high, between level 650 and 700. Lamp C is a combination of parking lamp and turn signal. In highbeam mode, both filaments A and B are energized simultaneously and table 17a of FMVSS 108 is then fulfilled. Lamp D is a foglamp. As an alternative to the above description, we would like to know whether it is permissible to sell new cars in the United States with the foglamp replaced by an auxiliary driving beam. In this case, all three A, B and D filaments would be permanently e nergized together in high beam mode and table 17a of FMVSS 108 is then fulfilled. Lamp D alone, when tested in a laboratory, would satisfy the photometric requirements of SAE J581 June 89. In another variant, two or three filaments could be switched on in highbeam mode depending on the position of a switch on the instrument panel, at the discretion of the driver. Whatever the position of the switch, table 17a of FMVSS 108 shall be fulfill ed. Would this be permissible? Thank you in advance for your cooperation. Graphics omitted. |
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ID: nht94-1.10OpenTYPE: INTERPRETATION-NHTSA DATE: January 6, 1994 FROM: C. N. Littler -- Administrator Regulatory Affairs, MOTOR COACH INDUSTRIES (MANITOBA, CANADA) TO: Mary Versailles -- Office of the Chief Counsel, NHTSA TITLE: NHTSA Pre-emptive Authority With Respect to FMVSS P571 @ 121 ATTACHMT: Attached to Letter Dated 09/07/94 from John Womack to C. N. Littler (A42; STD. 121; VSA 103D) TEXT: I am writing to request a NHTSA legal opinion regarding New York State enforcement of a brake stopping distance standard which is not identical in nature or substance to FMVSS 121. In effect, NYSDOT is currently inspecting and placing out of service privately owned motor coaches which do not stop within 22.2 feet and 20 mph. FMVSS 121 requires a stopping distance of 35 feet at 20 mph on a road surface having a skid pad number of 81. Not only is the New York standard not identical to the Federal standard, (as required under the provisions of Sec. 103(d) of the Motor Vehicle Traffic Safety Act of 1966), it is also unduly restrictive. Recently, the Bus Association of New York met with members of NYSDOT to attempt to resolve this problem. This meeting unfortunately only resulted in an impasse, whereby NYSDOT requested that the vehicle manufacturers write letters to the NYSDOT Compl iance and Enforcement Branch requesting exemptions to the New York standard. We do not feel that this approach is appropriate. This issue is not one of a technical nature. It is, in fact, a legislative issue in that New York State is not in compliance with a Federally mandated standard. Your assistance in providing a legal opinion with respect to this rather urgent matter would be greatly appreciated. I have attached for your reference copies of the standards and statute above named. Please do not hesitate to call me at 204-287-427 4 or FAX 204-453-7356 should you or counsel's office staff required further information. With kindest regards, I remain, ATTACHMENTS: NEW YORK STATE TRANSPORTATION REGULATIONS (TEXT OMITTED) |
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ID: nht94-1.11OpenTYPE: INTERPRETATION-NHTSA DATE: January 6, 1994 FROM: Littler, C.N. -- Administrator Regulatory Affairs, Motor Coach Industries, Manitoba, Canada TO: Versailles, Mary -- Office of the Chief Counsel, NHTSA TITLE: NHTSA Pre-emptive Authority With Respect to FMVSS P571@121 ATTACHMT: Attached To 10/1/94 (EST.) Letter From John Womack To C. N. Littler (A42; VSA 103(D)) TEXT: I am writing to request a NHTSA legal opinion regarding New York State enforcement of a brake stopping distance standard which is not identical in nature or substance to FMVSS 121. In effect, NYSDOT is currently inspecting and placing out of service privately owned motor coaches which do not stop within 22.2 feet and 20 mph. FMVSS 121 requires a stopping distance of 35 feet at 20 mph on a road surface having a skid pad number of 81. Not only is the New York standard not identical to the Federal standard, (as required under the provisions of Sec. 103(d) of the Motor Vehicle Traffic Safety Act of 1966), it is also unduly restrictive. Recently, the Bus Association of New York met with members of NYSDOT to attempt to resolve this problem. This meeting unfortunately only resulted in an impasse, whereby NYSDOT requested that the vehicle manufacturers write letters to the NYSDOT Compl iance and Enforcement Branch requesting exemptions to the New York standard. We do not feel that this approach is appropriate. This issue is not one of a technical nature. It is, in fact, a legislative issue in that New York State is not in compliance with a Federally mandated standard. Your assistance in providing a legal opinion with respect to this rather urgent matter would be greatly appreciated. I have attached for your reference copies of the standards and statute above named. Please do not hesitate to call me at 204-287-427 4 or FAX 204-453-7356 should you or counsel's office staff required further information. With kindest regards, I remain, Attachments (STANDARDS AND STATUTES OMITTED.) |
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.