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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 2091 - 2100 of 2914

Interpretations	Date

ID: aiam2589 Open Mr. Don W. Vierimaa, Engineering Manager, TTMA, 2430 Pennsylvania Avenue, N.W., Washington, D.C. 20037; Mr. Don W. Vierimaa Engineering Manager TTMA 2430 Pennsylvania Avenue N.W. Washington D.C. 20037; Dear Mr. Vierimaa: This responds to your March 16, 1977, letter in which you ask for a interpretation of the certification label requirements of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, as they apply to trailers.; In your first question, you ask whether a trailer manufacturer ma conform with the certification requirements in any one of three ways: list the GVWR and GAWR with the corresponding tires, rims, and inflation pressure with which the trailer is equipped, list all suitable combinations with the required information as shown in the example appearing in Standard No. 120, or list only the maximum GVWR and maximum GAWR with the proper tires, rims, and inflation pressure, plus the GVWR and GAWR of the trailer with the tires, rims, and inflation pressure with which it is equipped.According to the requirements of Standard No. 120, any of the three methods outlined above would appear to be acceptable. Your second question presents a sample certification plate which lists all of the axles on the trailer. You ask whether it is permissible, where the data for all axles is identical, to list the proper tires, rims, and inflation pressure for the front axle then merely state 'Same as Front' for the remaining axles rather than repeat the same data for all axles. The label requirements of the standard do not permit the approach you suggest. You must list all data for each axle. You should note that there is a proposal to amend Part 567, Certification, to permit a simplification of label requirements when the data for all axles is identical. I am enclosing a copy of this proposal for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam1748 Open Honorable Charles Wilson, House of Representatives, Washington, DC 20515; Honorable Charles Wilson House of Representatives Washington DC 20515; Dear Mr. Wilson: This responds to your request for consideration of Mr. J. M. Chandler' December 31, 1974, request for reconsideration of Standard No. 121, Air brake systems, because of its costs.; Standard No. 121 requires that newly- manufactured air-braked vehicle stop from speeds of up to 60 mph on wet and dry surfaces in the loaded and unloaded condition, without leaving a 12-foot-wide lane and without lockup of wheels above 10 mph. These performance requirements are based on a safety need for improved braking performance on air brake- equipped highway vehicles. Controlled stopping within the traffic lane is particularly important to tractor-trailer combinations to avoid 'jackknife' skids. The incompatibility of vehicle sizes can be reduced significantly by establishing equal stopping distances for trucks and passenger cars.; We have analyzed the costs and benefits to be gained in upgradin truck, bus, and trailer braking performance and have concluded that the savings in lives, injury, and property damage justify the incremental costs of this standard. Standard 121 does not require retrofit of vehicles manufactured prior to the standard's effective date.; From a cost standpoint, it is noteworthy that the arguments fo increased weight limits for commercial vehicles relied, in part, on the increased braking performance of vehicles which meet Standard No. 121. A major reason for the heavier vehicles would be to reduce the costs of transportation, and Standard No. 121 contributes directly to that goal.; As you may be aware, the NHTSA has in fact proposed postponement of th standard due to the current economic situation. Based on several hundred comments, there was persuasive evidence that a delay at this late date would create far greater dislocation in the automotive industry than would a January 1, 1975, implementation. A copy of our decision not to postpone the standard is enclosed.; Yours truly, Richard B. Dyson, Acting Chief Counsel
ID: aiam2104 Open Mr. John B. White, Engineering Manager, Technical Information Dept., Michelin Tire Corporation, P.O. Box 3467, New Hyde Park P.O., New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation P.O. Box 3467 New Hyde Park P.O. New York 11040; Dear Mr. White: This is in response to your letter of October 17, 1975, concerning th importation into the United States of tires that will be mounted on trucks intended for export from the United States.; 49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic an Motor Vehicle Safety Act of 1966 specify that no Federal Motor vehicle Safety Standards (FMVSS) apply to; >>> a motor vehicle or item of motor vehicle equipment intended solel for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.<<<; Therefore, tires which Michelin manufactures for sale directly to truck manufacturer who will mount them on trucks which are intended solely for export need not comply with Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars. When imported and shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. Importation of such tires is permitted by 19 CFR 12.80(b)(1)(ii), provided they are so labeled. A label need not remain on the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.; Because these tires are not subject to any FMVSS and are beyond th scope of any expected defect notification and remedy program, Michelin Tire Corporation is not subject to the requirements of 49 CFR Part 574, Tire Identification and Recordkeeping, with respect to them.; Sincerely, Frank A. Berndt, Acting Chief Counsel
ID: aiam3145 Open Mr. William E. Barry, Chief, Cleveland Fire Department, 1645 Superior Avenue, Cleveland, OH 44114; Mr. William E. Barry Chief Cleveland Fire Department 1645 Superior Avenue Cleveland OH 44114; Dear Mr. Barry: This is in response to your letter of July 2, 1979, in which you aske for copies of any current or recommended standards concerning the use of plastic auxiliary fuel tanks. May I apologize for the delay in this response.; I have enclosed a copy of a letter, which was sent to a company whic planned to manufacture auxiliary fuel tanks and to do some installation, that details the ways in which the safety standards and statutes administered by this agency apply to the manufacture of auxiliary fuel tanks of all types. In addition, I have enclosed a copy of an advance notice of proposed rulemaking that this agency issued with respect to a proposal to issue performance standards applicable to nonmetallic fuel tanks.; At this time the agency does not have any standards applicable to th use of auxiliary fuel tanks. However, several months ago we issued a consumer advisory warning against carrying fuel in portable containers in the trunks of cars. We consider this advisory applicable not only to portable containers but to any fuel container mounted in an area not normally consigned to such use. I have enclosed a copy of this advisory for your information. In addition, we are planning to issue a press release in the near future specifically addressed to the dangers of using auxiliary fuel tanks.; If you have any reports, case histories, photographs, or other materia concerning any fires or fire problems caused by the use of auxiliary fuel tanks we would be most grateful if you would allow us to examine them. Your concern in this area of vehicle safety is deeply appreciated.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2328 Open Mr. Richard L. Rogers, President, Little Dude Trailer Company, Inc., P.O. Box 4513, Fort Worth, Texas 76106; Mr. Richard L. Rogers President Little Dude Trailer Company Inc. P.O. Box 4513 Fort Worth Texas 76106; Dear Mr. Rogers: This is in response to your March 26, 1976, letter concerning th certification label requirements in S5.3 of Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.; You have pointed out that the example shown in S5.3 presents rim inflation, and maximum speed information after the Gross Vehicle Weight Ratings (GVWRs) as well as after the Gross Axle Weight Ratings (GAWRs). You have suggested that the text of S5.3 merely requires such information to appear after the GAWRs and urged such an interpretation. It appears that you have misunderstood the text.; In its present form, S5.3 requires each listed GVWR and GAWR to b followed by the information specified in paragraphs S5.3(a) through (d). Paragraph (a) is divided into subparagraphs (a)(1) and (a)(2) in order to specify different items to follow GVWR and GAWR, respectively. Paragraphs (b) through (d) (which specify rim, inflation, and maximum speed information) are not subdivided because the same items are intended to follow GVWR and GAWR.; Several petitions for reconsideration of the standard have requeste and amendment of S5.3 to eliminate the requirements that tire and rim information appear after the GVWR. Your suggestions on this matter, as well as the other suggestions in your letter, are being considered by the National Highway Traffic Safety Administration in the preparation of its response to those petitions.; Please note that the effective dates of several of the standard' requirements, including that of S5.3, were delayed in a Federal Register notice published on May 6, 1976 (41 FR 18659, Docket No. 71-19, Notice 4). A copy of that notice is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel
ID: aiam2627 Open Mr. John B. White, Engineering Manager, Technical Information Dept., Michelin Tire Corporation, New Hyde Park P.O., P.O. Box 3467, New York, New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation New Hyde Park P.O. P.O. Box 3467 New York New York 11040; Dear Mr. White: This responds to Michelin's March 23, 1977, letter concerning it February 20, 1976 petition for reconsideration of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. Your petition for reconsideration was responded to on February 7, 1977 (42 Fr 7140). By this letter, you attempt to resubmit your petition for reconsideration.; Petitions for reconsideration must be received by the agency within 3 days of the publication of a notice. Since the resubmission of your petition is untimely, it has been considered a petition for rulemaking as required by Part 553,35 of our regulations (Code of Federal Regulations, Volume 49). The National Highway Traffic Safety Administration (NHTSA) denies your requested rulemaking.; Your petition suggests that consumers will be confused by the tir label information if the vehicle is not equipped with the tires identified on the label. The agency has determined that confusion will be minimized by the use if the optional heading 'Suitable Tire-Rim Choice.'; Your petition raises a second problem concerning tires of identica size designations manufactured by different companies. These tires may have different inflation pressures even though their sizes are identical. The agency understands that this difference in inflation pressure could result in confusion. Manufacturers, however, con avoid this problem through the use of the manufacturers's name on the tire information label as part of the tire information. Use of the manufacturer's name on the label should distinguish between two otherwise similar tires.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam4822 Open Mr. S.V. Kaaria 70 E. Heather #3 Midvale, UT 84047; Mr. S.V. Kaaria 70 E. Heather #3 Midvale UT 84047; Dear Mr. Kaaria: Our Denver Regional Office has forwarded your lette of January 3, l99l, to this Office for reply. You are 'the designer of the taillights placed near the rear window of passenger cars.' In attempting to negotiate a settlement with vehicle manufacturers, you have been informed that because 'elevated brake lights' are required by our agency, the government 'should negotiate with me for l% of replacement cost of these taillights.' You have asked that we clarify our position in this matter. Federal Motor Vehicle Safety Standard No. 108 requires that every passenger car manufactured on or after September 1, l985, be equipped with a high-mounted stop lamp, mounted on the rear vertical centerline of the vehicle. The only requirement relating to design is that the lens have an effective projected luminous lens area of not less than 4 1/2 square inches, but the standard does not specify the shape of the lens. Within these parameters, manufacturers have located their lamps both inside and outside of the car, from the roof to the deck, and have equipped them with circular and rectangular lenses of varying sizes. Our standards are generally expressed in performance terms so that manufacturers have the freedom to design their vehicles in the manner most suited to them to meet the performance requirements, and so that a specification that appears to favor a proprietary device (e.g., mandating a specific design solution to a standard's requirements) is avoided. Because of the latitude in design that Standard No. 108 affords, we do not regard the lamp as having any single inventor or designer. While it is possible that you have designed a lamp with some proprietary elements, your search for recovery is properly directed towards lamp and vehicle manufacturers. You have been ill-advised to seek recovery from the government, for you have no legal basis to do so. Sincerely, Paul Jackson Rice Chief Counsel;
ID: aiam1892 Open Honorable Edwin B. Forsythe, House of Representatives, Washington, DC 20515; Honorable Edwin B. Forsythe House of Representatives Washington DC 20515; Dear Mr. Forsythe: This is in response to your letter of March 31, 1975, requestin information concerning correspondence from one of your constituents, Mr. Anthony N. D'Elia, commenting on a proposed amendment to the Federal Bumper Standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register Notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency sponsored studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Another public hearing was held on April 4, 1975, to allow ora presentation of views on the March 12 notice. The agency is currently examining the information gathered at that proceeding in addition to the written comments that have been submitted. The next step in our rulemaking process will be based on all of the data available.; Your interest and that of Mr. D'Elia is greatly appreciated. Sincerely, James C. Schultz, Chief Counsel
ID: aiam1959 Open Mr. George R. Semark, Manager, Vehicle Safety Activities, Sheller-Globe Corporation, 2885 St. Johns Avenue, Lima, OH 45804; Mr. George R. Semark Manager Vehicle Safety Activities Sheller-Globe Corporation 2885 St. Johns Avenue Lima OH 45804; Dear Mr. Semark: This responds to Sheller-Globe's June 16, 1975, request for a statemen of the requirements for 1976-model multi-purpose passenger vehicles (MPV's) specified by Standard No. 208, Occupant crash protection.; Section S4.3 of the standard sets out the requirements for MPV's with gross vehicle weight rating (GVWR) of more than 10,000 pounds. These requirements are the same in the future as at present.; Section S4.2 sets out the requirements for MPV's with a GVWR of 10,00 pounds or less (S4.2.1 for vehicles until August 15, 1975, and S4.2.2 for vehicles on or after August 15, 1975 until August 15, 1977). As the standard is presently effective, S4.2.2 will require that most MPV's of 10,000 pounds or less be equipped with the same seat belts and warning systems as presently installed in passenger cars. I have enclosed a copy of those requirements as they were revised October 29, 1974 (40 FR 38380, October 31, 1974). Also enclosed is a Federal Register notice of December 6, 1974, that sets out the associated warning system reguirements (sic) (40 FR 42692, December 6, 1974). The only MPV's excepted from these requirements are forward control vehicles, convertibles, open-body type vehicles, walk-in van-type trucks, motor homes, and vehicles carrying chassis-mount campers. They will continue to be required to meet the requirements of S4.2.1.2 as presently in effect.; The National Highway Traffic Safety Administration recently propose that a manufacturer have the option of meeting the requirements of S4.2.1 or S4.2.2 until January 1, 1976. I enclose a copy of that proposal, which includes a preamble discussion of the reasons for this proposal. A final determination will appear in the Federal Register.; Sincerely, James C. Schultz, Chief Counsel
ID: aiam4258 Open Mr. William Tackett, 859 South Main, Plymouth, MI 48170; Mr. William Tackett 859 South Main Plymouth MI 48170; Dear Mr. Tackett: This is to follow-up on your phone conversation of December 1, 1986 with Stephen Oesch of my staff concerning how Standard No. 301, Fuel System Integrity, affects the installation of trailer hitches on cars. I hope the following discussion answers your questions.; Standard No. 301 sets performance requirements to reduce fuel syste spillage in a crash. If a trailer hitch is installed on a new car prior to the car being first sold to a consumer, the person installing the trailer hitch would be considered a vehicle alterer under our certification regulation (49 CFR Part 567), a copy of which is enclosed. Under Part 567.7, a vehicle alterer is required to certify that the vehicle, as altered, still conforms with all applicable safety standards.; The installation of a trailer hitch on a used car would be affected b section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) provides that:; >>>No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .<<<; Thus, in installing trailer hitches on a used car, a commercia business must ensure that it has not knowingly compromised the integrity of the fuel system.; In addition, a manufacturer of motor vehicle equipment, such as trailer hitch, is subject to the requirements in sections 151-159 of the Vehicle Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. I have enclosed an information sheet which briefly describes how our defect regulations affect equipment manufacturers.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

Request an Interpretation

You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:

The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590

If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.

Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.

Interpretations	Date

ID: aiam2589 Open Mr. Don W. Vierimaa, Engineering Manager, TTMA, 2430 Pennsylvania Avenue, N.W., Washington, D.C. 20037; Mr. Don W. Vierimaa Engineering Manager TTMA 2430 Pennsylvania Avenue N.W. Washington D.C. 20037; Dear Mr. Vierimaa: This responds to your March 16, 1977, letter in which you ask for a interpretation of the certification label requirements of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, as they apply to trailers.; In your first question, you ask whether a trailer manufacturer ma conform with the certification requirements in any one of three ways: list the GVWR and GAWR with the corresponding tires, rims, and inflation pressure with which the trailer is equipped, list all suitable combinations with the required information as shown in the example appearing in Standard No. 120, or list only the maximum GVWR and maximum GAWR with the proper tires, rims, and inflation pressure, plus the GVWR and GAWR of the trailer with the tires, rims, and inflation pressure with which it is equipped.According to the requirements of Standard No. 120, any of the three methods outlined above would appear to be acceptable. Your second question presents a sample certification plate which lists all of the axles on the trailer. You ask whether it is permissible, where the data for all axles is identical, to list the proper tires, rims, and inflation pressure for the front axle then merely state 'Same as Front' for the remaining axles rather than repeat the same data for all axles. The label requirements of the standard do not permit the approach you suggest. You must list all data for each axle. You should note that there is a proposal to amend Part 567, Certification, to permit a simplification of label requirements when the data for all axles is identical. I am enclosing a copy of this proposal for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam1748 Open Honorable Charles Wilson, House of Representatives, Washington, DC 20515; Honorable Charles Wilson House of Representatives Washington DC 20515; Dear Mr. Wilson: This responds to your request for consideration of Mr. J. M. Chandler' December 31, 1974, request for reconsideration of Standard No. 121, Air brake systems, because of its costs.; Standard No. 121 requires that newly- manufactured air-braked vehicle stop from speeds of up to 60 mph on wet and dry surfaces in the loaded and unloaded condition, without leaving a 12-foot-wide lane and without lockup of wheels above 10 mph. These performance requirements are based on a safety need for improved braking performance on air brake- equipped highway vehicles. Controlled stopping within the traffic lane is particularly important to tractor-trailer combinations to avoid 'jackknife' skids. The incompatibility of vehicle sizes can be reduced significantly by establishing equal stopping distances for trucks and passenger cars.; We have analyzed the costs and benefits to be gained in upgradin truck, bus, and trailer braking performance and have concluded that the savings in lives, injury, and property damage justify the incremental costs of this standard. Standard 121 does not require retrofit of vehicles manufactured prior to the standard's effective date.; From a cost standpoint, it is noteworthy that the arguments fo increased weight limits for commercial vehicles relied, in part, on the increased braking performance of vehicles which meet Standard No. 121. A major reason for the heavier vehicles would be to reduce the costs of transportation, and Standard No. 121 contributes directly to that goal.; As you may be aware, the NHTSA has in fact proposed postponement of th standard due to the current economic situation. Based on several hundred comments, there was persuasive evidence that a delay at this late date would create far greater dislocation in the automotive industry than would a January 1, 1975, implementation. A copy of our decision not to postpone the standard is enclosed.; Yours truly, Richard B. Dyson, Acting Chief Counsel
ID: aiam2104 Open Mr. John B. White, Engineering Manager, Technical Information Dept., Michelin Tire Corporation, P.O. Box 3467, New Hyde Park P.O., New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation P.O. Box 3467 New Hyde Park P.O. New York 11040; Dear Mr. White: This is in response to your letter of October 17, 1975, concerning th importation into the United States of tires that will be mounted on trucks intended for export from the United States.; 49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic an Motor Vehicle Safety Act of 1966 specify that no Federal Motor vehicle Safety Standards (FMVSS) apply to; >>> a motor vehicle or item of motor vehicle equipment intended solel for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.<<<; Therefore, tires which Michelin manufactures for sale directly to truck manufacturer who will mount them on trucks which are intended solely for export need not comply with Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars. When imported and shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. Importation of such tires is permitted by 19 CFR 12.80(b)(1)(ii), provided they are so labeled. A label need not remain on the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.; Because these tires are not subject to any FMVSS and are beyond th scope of any expected defect notification and remedy program, Michelin Tire Corporation is not subject to the requirements of 49 CFR Part 574, Tire Identification and Recordkeeping, with respect to them.; Sincerely, Frank A. Berndt, Acting Chief Counsel
ID: aiam3145 Open Mr. William E. Barry, Chief, Cleveland Fire Department, 1645 Superior Avenue, Cleveland, OH 44114; Mr. William E. Barry Chief Cleveland Fire Department 1645 Superior Avenue Cleveland OH 44114; Dear Mr. Barry: This is in response to your letter of July 2, 1979, in which you aske for copies of any current or recommended standards concerning the use of plastic auxiliary fuel tanks. May I apologize for the delay in this response.; I have enclosed a copy of a letter, which was sent to a company whic planned to manufacture auxiliary fuel tanks and to do some installation, that details the ways in which the safety standards and statutes administered by this agency apply to the manufacture of auxiliary fuel tanks of all types. In addition, I have enclosed a copy of an advance notice of proposed rulemaking that this agency issued with respect to a proposal to issue performance standards applicable to nonmetallic fuel tanks.; At this time the agency does not have any standards applicable to th use of auxiliary fuel tanks. However, several months ago we issued a consumer advisory warning against carrying fuel in portable containers in the trunks of cars. We consider this advisory applicable not only to portable containers but to any fuel container mounted in an area not normally consigned to such use. I have enclosed a copy of this advisory for your information. In addition, we are planning to issue a press release in the near future specifically addressed to the dangers of using auxiliary fuel tanks.; If you have any reports, case histories, photographs, or other materia concerning any fires or fire problems caused by the use of auxiliary fuel tanks we would be most grateful if you would allow us to examine them. Your concern in this area of vehicle safety is deeply appreciated.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2328 Open Mr. Richard L. Rogers, President, Little Dude Trailer Company, Inc., P.O. Box 4513, Fort Worth, Texas 76106; Mr. Richard L. Rogers President Little Dude Trailer Company Inc. P.O. Box 4513 Fort Worth Texas 76106; Dear Mr. Rogers: This is in response to your March 26, 1976, letter concerning th certification label requirements in S5.3 of Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.; You have pointed out that the example shown in S5.3 presents rim inflation, and maximum speed information after the Gross Vehicle Weight Ratings (GVWRs) as well as after the Gross Axle Weight Ratings (GAWRs). You have suggested that the text of S5.3 merely requires such information to appear after the GAWRs and urged such an interpretation. It appears that you have misunderstood the text.; In its present form, S5.3 requires each listed GVWR and GAWR to b followed by the information specified in paragraphs S5.3(a) through (d). Paragraph (a) is divided into subparagraphs (a)(1) and (a)(2) in order to specify different items to follow GVWR and GAWR, respectively. Paragraphs (b) through (d) (which specify rim, inflation, and maximum speed information) are not subdivided because the same items are intended to follow GVWR and GAWR.; Several petitions for reconsideration of the standard have requeste and amendment of S5.3 to eliminate the requirements that tire and rim information appear after the GVWR. Your suggestions on this matter, as well as the other suggestions in your letter, are being considered by the National Highway Traffic Safety Administration in the preparation of its response to those petitions.; Please note that the effective dates of several of the standard' requirements, including that of S5.3, were delayed in a Federal Register notice published on May 6, 1976 (41 FR 18659, Docket No. 71-19, Notice 4). A copy of that notice is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel
ID: aiam2627 Open Mr. John B. White, Engineering Manager, Technical Information Dept., Michelin Tire Corporation, New Hyde Park P.O., P.O. Box 3467, New York, New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation New Hyde Park P.O. P.O. Box 3467 New York New York 11040; Dear Mr. White: This responds to Michelin's March 23, 1977, letter concerning it February 20, 1976 petition for reconsideration of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. Your petition for reconsideration was responded to on February 7, 1977 (42 Fr 7140). By this letter, you attempt to resubmit your petition for reconsideration.; Petitions for reconsideration must be received by the agency within 3 days of the publication of a notice. Since the resubmission of your petition is untimely, it has been considered a petition for rulemaking as required by Part 553,35 of our regulations (Code of Federal Regulations, Volume 49). The National Highway Traffic Safety Administration (NHTSA) denies your requested rulemaking.; Your petition suggests that consumers will be confused by the tir label information if the vehicle is not equipped with the tires identified on the label. The agency has determined that confusion will be minimized by the use if the optional heading 'Suitable Tire-Rim Choice.'; Your petition raises a second problem concerning tires of identica size designations manufactured by different companies. These tires may have different inflation pressures even though their sizes are identical. The agency understands that this difference in inflation pressure could result in confusion. Manufacturers, however, con avoid this problem through the use of the manufacturers's name on the tire information label as part of the tire information. Use of the manufacturer's name on the label should distinguish between two otherwise similar tires.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam4822 Open Mr. S.V. Kaaria 70 E. Heather #3 Midvale, UT 84047; Mr. S.V. Kaaria 70 E. Heather #3 Midvale UT 84047; Dear Mr. Kaaria: Our Denver Regional Office has forwarded your lette of January 3, l99l, to this Office for reply. You are 'the designer of the taillights placed near the rear window of passenger cars.' In attempting to negotiate a settlement with vehicle manufacturers, you have been informed that because 'elevated brake lights' are required by our agency, the government 'should negotiate with me for l% of replacement cost of these taillights.' You have asked that we clarify our position in this matter. Federal Motor Vehicle Safety Standard No. 108 requires that every passenger car manufactured on or after September 1, l985, be equipped with a high-mounted stop lamp, mounted on the rear vertical centerline of the vehicle. The only requirement relating to design is that the lens have an effective projected luminous lens area of not less than 4 1/2 square inches, but the standard does not specify the shape of the lens. Within these parameters, manufacturers have located their lamps both inside and outside of the car, from the roof to the deck, and have equipped them with circular and rectangular lenses of varying sizes. Our standards are generally expressed in performance terms so that manufacturers have the freedom to design their vehicles in the manner most suited to them to meet the performance requirements, and so that a specification that appears to favor a proprietary device (e.g., mandating a specific design solution to a standard's requirements) is avoided. Because of the latitude in design that Standard No. 108 affords, we do not regard the lamp as having any single inventor or designer. While it is possible that you have designed a lamp with some proprietary elements, your search for recovery is properly directed towards lamp and vehicle manufacturers. You have been ill-advised to seek recovery from the government, for you have no legal basis to do so. Sincerely, Paul Jackson Rice Chief Counsel;
ID: aiam1892 Open Honorable Edwin B. Forsythe, House of Representatives, Washington, DC 20515; Honorable Edwin B. Forsythe House of Representatives Washington DC 20515; Dear Mr. Forsythe: This is in response to your letter of March 31, 1975, requestin information concerning correspondence from one of your constituents, Mr. Anthony N. D'Elia, commenting on a proposed amendment to the Federal Bumper Standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register Notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency sponsored studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Another public hearing was held on April 4, 1975, to allow ora presentation of views on the March 12 notice. The agency is currently examining the information gathered at that proceeding in addition to the written comments that have been submitted. The next step in our rulemaking process will be based on all of the data available.; Your interest and that of Mr. D'Elia is greatly appreciated. Sincerely, James C. Schultz, Chief Counsel
ID: aiam1959 Open Mr. George R. Semark, Manager, Vehicle Safety Activities, Sheller-Globe Corporation, 2885 St. Johns Avenue, Lima, OH 45804; Mr. George R. Semark Manager Vehicle Safety Activities Sheller-Globe Corporation 2885 St. Johns Avenue Lima OH 45804; Dear Mr. Semark: This responds to Sheller-Globe's June 16, 1975, request for a statemen of the requirements for 1976-model multi-purpose passenger vehicles (MPV's) specified by Standard No. 208, Occupant crash protection.; Section S4.3 of the standard sets out the requirements for MPV's with gross vehicle weight rating (GVWR) of more than 10,000 pounds. These requirements are the same in the future as at present.; Section S4.2 sets out the requirements for MPV's with a GVWR of 10,00 pounds or less (S4.2.1 for vehicles until August 15, 1975, and S4.2.2 for vehicles on or after August 15, 1975 until August 15, 1977). As the standard is presently effective, S4.2.2 will require that most MPV's of 10,000 pounds or less be equipped with the same seat belts and warning systems as presently installed in passenger cars. I have enclosed a copy of those requirements as they were revised October 29, 1974 (40 FR 38380, October 31, 1974). Also enclosed is a Federal Register notice of December 6, 1974, that sets out the associated warning system reguirements (sic) (40 FR 42692, December 6, 1974). The only MPV's excepted from these requirements are forward control vehicles, convertibles, open-body type vehicles, walk-in van-type trucks, motor homes, and vehicles carrying chassis-mount campers. They will continue to be required to meet the requirements of S4.2.1.2 as presently in effect.; The National Highway Traffic Safety Administration recently propose that a manufacturer have the option of meeting the requirements of S4.2.1 or S4.2.2 until January 1, 1976. I enclose a copy of that proposal, which includes a preamble discussion of the reasons for this proposal. A final determination will appear in the Federal Register.; Sincerely, James C. Schultz, Chief Counsel
ID: aiam4258 Open Mr. William Tackett, 859 South Main, Plymouth, MI 48170; Mr. William Tackett 859 South Main Plymouth MI 48170; Dear Mr. Tackett: This is to follow-up on your phone conversation of December 1, 1986 with Stephen Oesch of my staff concerning how Standard No. 301, Fuel System Integrity, affects the installation of trailer hitches on cars. I hope the following discussion answers your questions.; Standard No. 301 sets performance requirements to reduce fuel syste spillage in a crash. If a trailer hitch is installed on a new car prior to the car being first sold to a consumer, the person installing the trailer hitch would be considered a vehicle alterer under our certification regulation (49 CFR Part 567), a copy of which is enclosed. Under Part 567.7, a vehicle alterer is required to certify that the vehicle, as altered, still conforms with all applicable safety standards.; The installation of a trailer hitch on a used car would be affected b section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) provides that:; >>>No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .<<<; Thus, in installing trailer hitches on a used car, a commercia business must ensure that it has not knowingly compromised the integrity of the fuel system.; In addition, a manufacturer of motor vehicle equipment, such as trailer hitch, is subject to the requirements in sections 151-159 of the Vehicle Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. I have enclosed an information sheet which briefly describes how our defect regulations affect equipment manufacturers.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

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