NHTSA Interpretation File Search Overview Search Tool Request an Interpretation

NHTSA Interpretation File Search

Overview

NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.

Understanding NHTSA’s Online Interpretation Files

NHTSA makes its letters of interpretation available to the public on this webpage.

An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.

Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
Some combination of the above, or other, factors.

Searching NHTSA’s Online Interpretation Files

Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.

Single word search

Example: car
Result: Any document containing that word.

Multiple word search

Example: car seat requirements
Result: Any document containing any of these words.

Connector word search

Example: car AND seat AND requirements
Result: Any document containing all of these words.

Note: Search operators such as AND or OR must be in all capital letters.

Phrase in double quotes

Example: "headlamp function"
Result: Any document with that phrase.

Conjunctive search

Example: functionally AND minima
Result: Any document with both of those words.

Wildcard

Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).

Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).

Not

Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”

Complex searches

You can combine search operators to write more targeted searches.

Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).

Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”

Search Tool

NHTSA's Interpretation Files Search

Displaying 2151 - 2160 of 2914

Interpretations	Date

ID: aiam2006 Open Mr. Fred Long, South Texas Tire Test Fleet, Drawer J, Devine, TX 78016; Mr. Fred Long South Texas Tire Test Fleet Drawer J Devine TX 78016; Dear Mr. Long: This is to confirm your telephone conversation of July 31, 1975, wit Mark Schwimmer concerning the treadwear test procedures specified in 49 CFR Part 575.104, Uniform Tire Quality Grading Standards (UTQGS).; You had previously pointed out that the A78-13 and other tires ar available neither as original equipment nor as recommended replacement options on any 1975 model passenger cars, although they are available as replacement options for the 1974 Ford Pinto. You had asked whether it is permissible for a tire manufacturer to conduct treadwear testing for such tires on a 1975 Pinto, in light of the National Highway Traffic Safety Administration's (NHTSA) statement that; >>>tires will be tested for compliance only on vehicles for which the are available as original equipment or recommended replacement options. (40 FR 23076, May 28, 1975)<<<; As Mr. Schwimmer explained to you, the UTQGS rules does not dictate th method by which a tire manufacturer must conduct his testing to assign grades. It merely specifies the procedures which the NHTSA will follow when testing tires for compliance with the rule. While the surest way for the tire manufacturer to be confident of compliance would be to follow these procedures in every detail, he is not legally obligated to do so. His obligation is simply to ensure that, when tested by the NHTSA according to the specified procedures, his tires are capable of achieving the grades which he has assigned to them. He may fulfill this obligation by whatever means he believes reliable and necessary. Thus, for example, he might choose a 1975 Pinto to test an A78-13 tire, if he is confident that the model year change in the Pinto will have no effect on the tire's treadwear performance. This decision is his, however. The NHTSA, in its compliance testing, would test such a tire on a 1974 Pinto or on some other passenger car for which it is original equipment or a recommended replacement option.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam1850 Open Mr. Robert Marx, State Representative, District #34, Polk- Benton, House of Representatives, Salem, OR 97310; Mr. Robert Marx State Representative District #34 Polk- Benton House of Representatives Salem OR 97310; Dear Mr. Marx: This is in response to your letter of March 10, 1975, requestin information concerning correspondence from one of your constituents, Mr. Jim Lee Martin, 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 then be 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Martin has directed his comments to what he believes to be proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face (plastic) systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1888 Open Honorable Birch Bayh, United States Senate, Washington, DC 20510; Honorable Birch Bayh United States Senate Washington DC 20510; Dear Senator Bayh: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, 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-sponsore 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1885 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, 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-sponsore 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1081 Open Mr. T. Hiramine, Director, Takata Kojyo Co., Ltd., No. 10 Mori Building, 28 Sakuragawa-Cho, Nishikubo, Shiba, Minato-Ku, Tokyo, Japan; Mr. T. Hiramine Director Takata Kojyo Co. Ltd. No. 10 Mori Building 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan; Dear Mr. Hiramine: Thank you for your letter of February 24, 1973, to Mr. Franci Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.; Your first question, referenced to Figure No. 1 of the enclosure wit your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard N0. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.; Your second question, referenced to Figure 2 of the enclosure, relate to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), equivalent hardware' is permissible in lieu of the 7/16 inch bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than on the individual components (bolts).; With respect to your third question, concerning the acceptability o belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in Ford v. NHTSA, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1843 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, 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-sponsore 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).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety- related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1842 Open Honorable Les AuCoin, House of Representatives, Washington, DC 20515; Honorable Les AuCoin House of Representatives Washington DC 20515; Dear Mr. AuCoin: This is in response to your letter of March 11, 1975, forwarding comment from one of your constituents, Mr. Keith A. Burbidge, on the proposed weakening of the 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 then have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore 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).; Mr. Burbidge appears to be directing his comments to what he believe to be a proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; We have placed Mr. Burbidge's letter in the appropriate docket. Sincerely, James C. Schultz, Chief Counsel
ID: aiam2812 Open Mr. Doug Mills, Rt. 1 Box 149, Tellico Plains, TN 37385; Mr. Doug Mills Rt. 1 Box 149 Tellico Plains TN 37385; Dear Mr. Mills: This responds to your recent letter asking additional question concerning the responsibilities of a person converting a pick-up truck into a dump truck, under Federal motor vehicle safety standards and regulations. This office explained the general responsibilities of a person who alters a certified vehicle in a letter to your associate, Mr. Henry Brown, dated February 1, 1978. You now ask questions regarding specific aspects of the conversion operating and whether they can be accomplished without destroying a vehicle's compliance with safety regulations.; Unfortunately, it is impossible for the National Highway Traffic Safet Administration (NHTSA) to answer your specific questions. It is the responsibility of the manufacturer or vehicle alterer to determine whether his vehicle is in compliance with applicable safety standards and to certify that vehicle. The NHTSA cannot review an alteration procedure such as the one with which you are concerned and state that it can or cannot be done in compliance with Federal regulations. There are no safety regulations which require a specific number of bolts or specific bolt locations, for instance. Likewise, Safety Standard No. 301-75, Fuel System Integrity, is specified only in terms of performance requirements, so the NHTSA cannot tell you whether a modified fuel filler neck will destroy a vehicle's compliance with the standard.; As stated in our previous letter, a person who alters a pick-up truc to convert it to a dump truck must certify that the truck remains in compliance with all applicable safety standards. Further, the person who makes the conversion must assure that the alterations do not result in any 'safety related defects' whether or not there is a specific safety standard that is applicable. Therefore, you must determine for yourself whether the number of bolts you use, the bolt strengths and the bolt locations will result in safety hazards.; I can answer your question number 8 regarding possible liability fo removal and alteration of the truck bumper. The Federal safety standard for bumpers is only applicable to passenger cars, so you may alter a truck bumper with impunity provided the action does not result in a safety related defect.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3829 Open Mr. Joel S. Premack, Research and Development Laboratories, U.S. Postal Service, Rockville, MD 20852-8101; Mr. Joel S. Premack Research and Development Laboratories U.S. Postal Service Rockville MD 20852-8101; Dear Mr. Premack: This responds to your March 7, 1984 letter to Roger Fairchild of thi office regarding Federal Motor Vehicle Safety Standard (FMVSS) 111, Rearview Mirrors. In particular, you asked whether the covering of the rear and rear-side windows on Postal Service Vehicles would be consistent with the requirements of FMVSS 111.; FMVSS 111 (copy enclosed) establishes requirements regarding rearvie mirror systems on new motor vehicles. New Postal Service vehicles would be required to employ one of three optional mirror systems. The first system is a system permitted for use on passenger cars, and includes an inside rearview mirror with a specified field of view and a plane, driver's side exterior mirror also having a specified field of view. The second permissible system is also a passenger car system and is identical to the first system, except that the inside mirror need not provide the specified field of view and an additional passenger side plane or convex rearview mirror must be provided to compensate for the more restricted field of view of the inside mirror. The third system has two plane mirrors of 19.5 square inches reflective surface area each, one mounted on each side of the vehicle.; Based on the materials you provided with your letter, it appears tha Postal Service DJ-5G Models employ the second system described above. In that case, further reduction of the field of view of the inside rearview mirror would not affect compliance with our standard, since an additional passenger side mirror is provided.; If the proposed covering of the rear windows is to be accomplished as modification to vehicles already delivered to the Postal Service, these modifications may not be subject to FMVSS 111 at all. Modifications to vehicles must be consistent with safety standards only to the extent those modification are performed by a vehicle manufacturer, distributor, dealer, or private motor vehicle repair business which knowingly renders inoperative safety equipment installed on the vehicle. See 15 U.S.C. 1397(a)(2)(A). Thus, if the window covering is done by the Postal Service itself, FMVSS requirements are not applicable.; If you have any further questions on this matter, please feel free t contact us.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2218 Open Georgette A. Sears, Route 2, Box 133c, Keymar, Maryland 21757; Georgette A. Sears Route 2 Box 133c Keymar Maryland 21757; Dear Ms. Sears: This is in response to your letter of January 6, 1976, requestin information as to the Federal Standards and regulations that are applicable to the manufacture of an '18 inch pull type horse/stock trailer combination.'; Manufacturers of trailers of the type you describe must certify tha their product is in compliance with Federal Motor Vehicle Safety Standard No. 108, Lamps, reflective Devices, and Associated Equipment, 49 CFR 571.108, and Standard No. 120, *Tire Selections and Rims for Vehicles Other Than Passenger Cars, 40 CFR 571.120. Please note, however, that Standard No. 120 is not effective until August 1, 1976, for the rim marking requirements (S5.2), and September 1, 1976, for the remaining requirements, so trailers manufactured before these times will not have to be certified as being in compliance with Standard No. 120.; The procedure for certification is specified in 49 CFR Part 567, an requires the manufacturer to affix a label to his product certifying that it is in compliance with the requirements of applicable Federal regulations. You should check the trailer that you purchase to make certain there is a certification label. Part 567.4(d) specifies that the certification label for trailers shall be affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.; There are no Federal regulations concerning the connection of trailer to trucks or other vehicles. Nevertheless, from a safety stand point it is important that you ascertain the hauling capacity of your truck-trailer system in order to avoid overloading that could create potential safety hazards. You should obtain information from the manufacturer concerning the 'tongue weight' of the trailer when fully loaded, and relate it to the gross axle wight ratings of your towing vehicle, found on its certification label on the door or door post. The trailer manufacturer may also have further recommendations as to the capacity of the vehicle needed to tow one of his trailers safely.; Please contact us if we can be(sic) of any further assistance. Yours truly, Richard B. Dyson, Assistant 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: aiam2006 Open Mr. Fred Long, South Texas Tire Test Fleet, Drawer J, Devine, TX 78016; Mr. Fred Long South Texas Tire Test Fleet Drawer J Devine TX 78016; Dear Mr. Long: This is to confirm your telephone conversation of July 31, 1975, wit Mark Schwimmer concerning the treadwear test procedures specified in 49 CFR Part 575.104, Uniform Tire Quality Grading Standards (UTQGS).; You had previously pointed out that the A78-13 and other tires ar available neither as original equipment nor as recommended replacement options on any 1975 model passenger cars, although they are available as replacement options for the 1974 Ford Pinto. You had asked whether it is permissible for a tire manufacturer to conduct treadwear testing for such tires on a 1975 Pinto, in light of the National Highway Traffic Safety Administration's (NHTSA) statement that; >>>tires will be tested for compliance only on vehicles for which the are available as original equipment or recommended replacement options. (40 FR 23076, May 28, 1975)<<<; As Mr. Schwimmer explained to you, the UTQGS rules does not dictate th method by which a tire manufacturer must conduct his testing to assign grades. It merely specifies the procedures which the NHTSA will follow when testing tires for compliance with the rule. While the surest way for the tire manufacturer to be confident of compliance would be to follow these procedures in every detail, he is not legally obligated to do so. His obligation is simply to ensure that, when tested by the NHTSA according to the specified procedures, his tires are capable of achieving the grades which he has assigned to them. He may fulfill this obligation by whatever means he believes reliable and necessary. Thus, for example, he might choose a 1975 Pinto to test an A78-13 tire, if he is confident that the model year change in the Pinto will have no effect on the tire's treadwear performance. This decision is his, however. The NHTSA, in its compliance testing, would test such a tire on a 1974 Pinto or on some other passenger car for which it is original equipment or a recommended replacement option.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam1850 Open Mr. Robert Marx, State Representative, District #34, Polk- Benton, House of Representatives, Salem, OR 97310; Mr. Robert Marx State Representative District #34 Polk- Benton House of Representatives Salem OR 97310; Dear Mr. Marx: This is in response to your letter of March 10, 1975, requestin information concerning correspondence from one of your constituents, Mr. Jim Lee Martin, 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 then be 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Martin has directed his comments to what he believes to be proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face (plastic) systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1888 Open Honorable Birch Bayh, United States Senate, Washington, DC 20510; Honorable Birch Bayh United States Senate Washington DC 20510; Dear Senator Bayh: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, 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-sponsore 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1885 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, 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-sponsore 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1081 Open Mr. T. Hiramine, Director, Takata Kojyo Co., Ltd., No. 10 Mori Building, 28 Sakuragawa-Cho, Nishikubo, Shiba, Minato-Ku, Tokyo, Japan; Mr. T. Hiramine Director Takata Kojyo Co. Ltd. No. 10 Mori Building 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan; Dear Mr. Hiramine: Thank you for your letter of February 24, 1973, to Mr. Franci Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.; Your first question, referenced to Figure No. 1 of the enclosure wit your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard N0. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.; Your second question, referenced to Figure 2 of the enclosure, relate to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), equivalent hardware' is permissible in lieu of the 7/16 inch bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than on the individual components (bolts).; With respect to your third question, concerning the acceptability o belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in Ford v. NHTSA, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1843 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, 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-sponsore 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).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety- related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1842 Open Honorable Les AuCoin, House of Representatives, Washington, DC 20515; Honorable Les AuCoin House of Representatives Washington DC 20515; Dear Mr. AuCoin: This is in response to your letter of March 11, 1975, forwarding comment from one of your constituents, Mr. Keith A. Burbidge, on the proposed weakening of the 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 then have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore 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).; Mr. Burbidge appears to be directing his comments to what he believe to be a proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; We have placed Mr. Burbidge's letter in the appropriate docket. Sincerely, James C. Schultz, Chief Counsel
ID: aiam2812 Open Mr. Doug Mills, Rt. 1 Box 149, Tellico Plains, TN 37385; Mr. Doug Mills Rt. 1 Box 149 Tellico Plains TN 37385; Dear Mr. Mills: This responds to your recent letter asking additional question concerning the responsibilities of a person converting a pick-up truck into a dump truck, under Federal motor vehicle safety standards and regulations. This office explained the general responsibilities of a person who alters a certified vehicle in a letter to your associate, Mr. Henry Brown, dated February 1, 1978. You now ask questions regarding specific aspects of the conversion operating and whether they can be accomplished without destroying a vehicle's compliance with safety regulations.; Unfortunately, it is impossible for the National Highway Traffic Safet Administration (NHTSA) to answer your specific questions. It is the responsibility of the manufacturer or vehicle alterer to determine whether his vehicle is in compliance with applicable safety standards and to certify that vehicle. The NHTSA cannot review an alteration procedure such as the one with which you are concerned and state that it can or cannot be done in compliance with Federal regulations. There are no safety regulations which require a specific number of bolts or specific bolt locations, for instance. Likewise, Safety Standard No. 301-75, Fuel System Integrity, is specified only in terms of performance requirements, so the NHTSA cannot tell you whether a modified fuel filler neck will destroy a vehicle's compliance with the standard.; As stated in our previous letter, a person who alters a pick-up truc to convert it to a dump truck must certify that the truck remains in compliance with all applicable safety standards. Further, the person who makes the conversion must assure that the alterations do not result in any 'safety related defects' whether or not there is a specific safety standard that is applicable. Therefore, you must determine for yourself whether the number of bolts you use, the bolt strengths and the bolt locations will result in safety hazards.; I can answer your question number 8 regarding possible liability fo removal and alteration of the truck bumper. The Federal safety standard for bumpers is only applicable to passenger cars, so you may alter a truck bumper with impunity provided the action does not result in a safety related defect.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3829 Open Mr. Joel S. Premack, Research and Development Laboratories, U.S. Postal Service, Rockville, MD 20852-8101; Mr. Joel S. Premack Research and Development Laboratories U.S. Postal Service Rockville MD 20852-8101; Dear Mr. Premack: This responds to your March 7, 1984 letter to Roger Fairchild of thi office regarding Federal Motor Vehicle Safety Standard (FMVSS) 111, Rearview Mirrors. In particular, you asked whether the covering of the rear and rear-side windows on Postal Service Vehicles would be consistent with the requirements of FMVSS 111.; FMVSS 111 (copy enclosed) establishes requirements regarding rearvie mirror systems on new motor vehicles. New Postal Service vehicles would be required to employ one of three optional mirror systems. The first system is a system permitted for use on passenger cars, and includes an inside rearview mirror with a specified field of view and a plane, driver's side exterior mirror also having a specified field of view. The second permissible system is also a passenger car system and is identical to the first system, except that the inside mirror need not provide the specified field of view and an additional passenger side plane or convex rearview mirror must be provided to compensate for the more restricted field of view of the inside mirror. The third system has two plane mirrors of 19.5 square inches reflective surface area each, one mounted on each side of the vehicle.; Based on the materials you provided with your letter, it appears tha Postal Service DJ-5G Models employ the second system described above. In that case, further reduction of the field of view of the inside rearview mirror would not affect compliance with our standard, since an additional passenger side mirror is provided.; If the proposed covering of the rear windows is to be accomplished as modification to vehicles already delivered to the Postal Service, these modifications may not be subject to FMVSS 111 at all. Modifications to vehicles must be consistent with safety standards only to the extent those modification are performed by a vehicle manufacturer, distributor, dealer, or private motor vehicle repair business which knowingly renders inoperative safety equipment installed on the vehicle. See 15 U.S.C. 1397(a)(2)(A). Thus, if the window covering is done by the Postal Service itself, FMVSS requirements are not applicable.; If you have any further questions on this matter, please feel free t contact us.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2218 Open Georgette A. Sears, Route 2, Box 133c, Keymar, Maryland 21757; Georgette A. Sears Route 2 Box 133c Keymar Maryland 21757; Dear Ms. Sears: This is in response to your letter of January 6, 1976, requestin information as to the Federal Standards and regulations that are applicable to the manufacture of an '18 inch pull type horse/stock trailer combination.'; Manufacturers of trailers of the type you describe must certify tha their product is in compliance with Federal Motor Vehicle Safety Standard No. 108, Lamps, reflective Devices, and Associated Equipment, 49 CFR 571.108, and Standard No. 120, *Tire Selections and Rims for Vehicles Other Than Passenger Cars, 40 CFR 571.120. Please note, however, that Standard No. 120 is not effective until August 1, 1976, for the rim marking requirements (S5.2), and September 1, 1976, for the remaining requirements, so trailers manufactured before these times will not have to be certified as being in compliance with Standard No. 120.; The procedure for certification is specified in 49 CFR Part 567, an requires the manufacturer to affix a label to his product certifying that it is in compliance with the requirements of applicable Federal regulations. You should check the trailer that you purchase to make certain there is a certification label. Part 567.4(d) specifies that the certification label for trailers shall be affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.; There are no Federal regulations concerning the connection of trailer to trucks or other vehicles. Nevertheless, from a safety stand point it is important that you ascertain the hauling capacity of your truck-trailer system in order to avoid overloading that could create potential safety hazards. You should obtain information from the manufacturer concerning the 'tongue weight' of the trailer when fully loaded, and relate it to the gross axle wight ratings of your towing vehicle, found on its certification label on the door or door post. The trailer manufacturer may also have further recommendations as to the capacity of the vehicle needed to tow one of his trailers safely.; Please contact us if we can be(sic) of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel

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