NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam0540OpenMr. R.A.C. Dandy, Senior Engineer, Head of Mechanical Section, British Standards Institution, Hemel Hempstead Centre, Maylands Avenue, Hemel Hempstead, Herts, England; Mr. R.A.C. Dandy Senior Engineer Head of Mechanical Section British Standards Institution Hemel Hempstead Centre Maylands Avenue Hemel Hempstead Herts England; Dear Mr. Dandy: This is in reply to your letter of July 26, 1972, on the subject o seat belt retractor testing under S5.2(k) of Motor Vehicle Safety Standard No. 209.; Your outline of the emergency locking retractor test procedure i essentially correct. During the initial 5,000 cycles, however, the belt is to be retracted completely, even though some vehicle installations may prevent complete retraction. The assumption in (3)(ii) of your letter is therefore incorrect.; The remaining points in your interpretation are correct. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5312OpenMr. Bob Carver Product Engineering Wayne Wheeled Vehicles 13311 Industrial Parkway Marysville, OH 43040; Mr. Bob Carver Product Engineering Wayne Wheeled Vehicles 13311 Industrial Parkway Marysville OH 43040; "Dear Mr. Carver: This responds to your letter of January 8, 1994 asking two questions concerning a recent amendment to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413, November 2, 1992). Your questions and the response to each follow. 1. There's some confusion here in our engineering department regarding the interpretation of the 'Daylight Opening' and 'Unobstructed Opening' as it applies to the new side emergency door specification in FMVSS 217. Page 2 shows the allowable obstruction and the context in which 'Daylight Opening' and 'Unobstructed Opening' are used. Page 3 shows some measurements of our seats placed according to the '30 cm minimum' shown on page 2. Page 4 shows four different interpretations of the 'Unobstructed Opening' area. Depending on the interpretation, between 9 and 15 people may be accommodated by a side emergency door. My question is this: of the four possibilities shown, which definition of the 'Unobstructed Opening' area is correct? Mr. Hott indicated definition 4. The term 'daylight opening' is defined in the Final Rule as 'the maximum unobstructed opening of an emergency exit when viewed from a direction perpendicular to the plane of the opening.' An obstruction in this context would include any obstacle or object that would block, obscure, or interfere with, in any way, access to that exit when opened. In determining the 'maximum unobstructed opening of an emergency exit,' we would subtract, from the total area of the opening, the area of any portions of the opening that cannot be used for exit purposes as a result of the obstruction. The area measurements would be taken when viewed from a direction perpendicular to the plane of the opening. Your question specifically concerns how the 'maximum unobstructed opening' of a side door is measured when the opening is partially obstructed by a seat. In the case of the illustrated door exit, occupants would use the exit by movement along the floor. This would be considered in determining the extent of an obstruction. None of the four examples you enclosed with your letter correctly illustrates the area that would be credited for the illustrated exit. The following regions would not be credited for this exit: (1) the area visually obstructed by the seat, (2) your region A2, an area bounded by a horizontal line tangent to the top of the seat back, a vertical line tangent to the rearmost portion of the top of the seat, the upper edge of the door opening, and the edge of the door forward of the seat, (3) your region A5, an area bounded by the seat back, a horizontal line tangent to the top of the seat back, and the edge of the door forward of the seat, and (4) your region A8, an area bounded by the seat leg, the floor, the lower edge of the seat bottom, and the edge of the door forward of the seat. Because the seat would make the last three regions unusable as exit space for a person traveling along the floor of the bus towards the exit, they would not be credited for that exit. You should be aware that the agency published a notice of proposed rulemaking to amend Standard No. 217 on December 1, 1993 (58 FR 63321). The notice proposed two alternate means for determining the maximum amount of area that will be credited for all types of emergency exits on school buses. The agency is currently reviewing the comments received in response to this notice. I am enclosing a copy of this notice. 2. Here is an excerpt from FMVSS 217 S5.5.3(a): 'Each school bus ....shall have the designation 'Emergency Door' or 'Emergency Exit' as appropriate, .... For emergency exit doors, the designation shall be located at the top of, or directly above, the emergency exit door on both the inside and outside surfaces of the bus..... For emergency window exits, the designation shall be located at the top of, or directly above, or at the bottom of the emergency window exit on both the inside and outside surfaces of the bus.' I've seen a two-sided sticker used by other bus manufacturers. It is applied on the inside surface of a window and the same image 'Emergency Door' or 'Emergency Exit' can be read from both inside and outside the bus. Is it permissible for us to use this sort of decal, assuming it meets all other (i.e., FMVSS 302)? The answer to your question is yes. The agency addressed this issue in an October 2, 1978, letter to Mr. E.M. Ryan of Ward Industries, Inc. I am enclosing a copy of this letter. I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam0110OpenWarren M. Heath, Commander, Engineering Section, California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Warren M. Heath Commander Engineering Section California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Commander Heath: This is in response to your letter of August 19 inquiring as to th certification responsibility of manufacturers of assemblers of dune buggy kits with respect to conformance with the Federal Motor Vehicle Safety Standards. But the issue you raise is far broader and involves the whole area of owner-assembled motor vehicles.; You have stated:>>>It is our interpretation that Federal Standard 10 is not applicable to dune buggies that are owner-constructed or reconstructed for the builders personal use.'<<<; This interpretation is incorrect. It is a violation of sectio 108(a)(1) of the National Traffic and Motor Vehicle Safety Act of 1966 for any person to:; >>>'...introduce or deliver for introduction in interstat commerce...any motor vehicle...manufactured [or assembled] on and after the date any applicable Federal motor vehicle safety standard takes effect...unless it is in conformity with such standard...'<<<; This means that the final assembler of a dune buggy, whoever he is must insure that the completed vehicle conforms to all applicable Standards including No. 108. In the case of dune buggies, this means Standards applicable to multipurpose passenger vehicles since a dune buggy is 'constructed...with special features for occasional off-road operation.' (23 C.F.R. S255.3(b)).; It is our understanding that a dune buggy consists of a newl manufactured body mounted on the modified chassis of a passenger car previously in use. An issue is raised by the facts that dune buggies are assembled from both new and used items of motor vehicle equipment and that there is language in the Act which appears to exempt 'any motor vehicle or item of motor vehicle equipment after the first purchase of it in good faith for purposes other than resale' (section 108(b)(1). However, since the modification involving used components goes far beyond customizing a used vehicle and results in the end product having a different classification under the Federal Standards and a different purpose than the original vehicle a dune buggy is a 'new' motor vehicle for purposes of the Act.; Continuing your interpretation you further state: >>>'However, those sold as kits or by a manufacturer are required t comply with Federal Standard 108.'<<<; Only assembled vehicles are required to conform to most Federa Standards including No. 108, and there is no legal requirement under the Act that a kit seller furnish lighting equipment meeting the various SAE requirements specified in that Standard. Some Federal Standards, however, do establish requirements applicable to equipment items as well as to assembled vehicles. If a kit manufacturer furnishes hydraulic brake hoses (Standard No. 105), new pneumatic tires (Standard No. 109), glazing materials (Standard No. 205), seat belt assemblies (Standard No. 209), and wheel discs, wheel covers, or hub caps (Standard No. 211), then these items must conform to the applicable Standard.; Finally, there appears to be some misunderstanding of the certificatio required by section 114 of the Act. This certification is required to be furnished only by a manufacturer, or distributor, and only to a distributor or dealer upon delivery of a motor vehicle or equipment item to which a Standard or Standards are applicable. No certification is required to be given by a manufacturer to a party not a distributor or dealer. Nor is there any requirement that the assembler per se certify the vehicle. This of course, does not relieve the assembler of his independent obligation to insure that the assembled vehicle meets Federal Standards.; I hope this answers your questions. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam1958OpenHonorable G. William Whitehurst, House of Representatives, Washington, DC 20515; Honorable G. William Whitehurst House of Representatives Washington DC 20515; Dear Mr. Whitehurst: A reply to your inquiry of June 5, 1975, concerning grade labellin regulations for new passenger car tires was transmitted to you on June 13 by Mr. James H. Cromwell of the Department of Transportation. Mr. Cromwell also referred your inquiry to me for additional comments.; As you are undoubtedly aware, the original impetus for th establishment of a uniform quality grading system for motor vehicle tires was provided by the National Traffic and Motor Vehicle Safety Act of 1966, which established this agency. The Congress, cognizant of the problems which beset the consumer when he attempts to make an informed choice of motor vehicle tires based on the relative merits of tire brands, included a specific Section 203 in the aforementioned Safety Act of 1966 which states that, 'In order to assist the consumer to make an informed choice in the purchase of motor vehicle tires . . .the Secretary shall . . . prescribe by order, and publish in the 'Federal Register*, a uniform quality grading system for motor vehicle tires.'; The benefits of such a system, while difficult to quantify, represen an enormous potential since some 200,000,000 motor vehicle tires are produced per year and are presently sold to consumers without adequate quantitative measures of their performance. It is expected that, by facilitating increased and more meaningful competition, the quality grading information will enable the tire consumer to obtain more value per dollar than he has in the past. The rule will enable the consumer to judge relative tire performance from a simple grading system, and thereby select a tire which provides him with the optimum solution to his driving needs.; For your review and information, I am enclosing a copy of the Unifor Tire Quality Grading Standards (UTQGS) which was issued in the *Federal Register* dated May 28, 1975. The rule provides quantitative grading measures for three important tire properties -- i.e., treadwear, traction, and temperature resistance.; I trust the above information satisfies your needs. Should you have an further questions, I shall be glad to attempt to provide answers.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam4609OpenMr. H. Hasegawa Automotive Lighting Engineering Control Section Stanley Electric Co. Ltd.; Mr. H. Hasegawa Automotive Lighting Engineering Control Section Stanley Electric Co. Ltd.; FAX 03-792-0007 (Japan) Dear Mr. Hasegawa: This is in reply to your FA letter of May 22, l989, to Richard Van Iderstine of this agency. You have two questions with respect to the amendment to Standard No. l08 published on May 9, l989 (Docket No. 85-15, Notice 8). Your first question is the effective date of paragraph S7.7.5.1.(a), which you point out was not previously a requirement of Standard No. l08. You suggest the need for a delayed effective date (but give no reason why one may be needed). Paragraph S7.7.5.1(a) will be effective June 8, l989. Although the requirement is a new one (the restriction on motion of a headlamp when an external aiming device is applied to it), it was proposed as part of the December 29, l987 NPRM, and no comments received indicated a need for a delayed effective date. Your supposition is correct, S7.5.5.1 will apply to all headlamps with an external aiming system, including those incorporating replaceable bulbs. Your second question relates to paragraph S7.7.5.l(b), and you ask 'whether the requirement of '0.1 in. max.' will be determined, either during the test or after the test'. In pertinent part, subsection (b) states 'nor shall the lamp recede more than 0.1 in. (2.5 mm) after being subjected to an inward force....' This means that the measurement is determined after the test. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam3436OpenMr. J. E. Bingham, British Standards Institution, Maylands Avenue, Hemel Hempstead, Herts HP2 4QS, England; Mr. J. E. Bingham British Standards Institution Maylands Avenue Hemel Hempstead Herts HP2 4QS England; Dear Mr. Bingham: This responds to your letter of June 8, 1981, concerning Standard No 209, *Seat Belt Assemblies*. You are correct that my letter of June 1, 1981, on the abrasion test procedure of the standard should have referred to section 5.1(d), instead of to section 5.2(d).; You also suggested that in the process of clarifying the standard' abrasion requirements, the agency should consider possible modifications to sections 4.2(e) and (f) of the standard. In the process of reviewing the abrasion test requirements, the agency will also examine those other sections to determine what changes should be made.; Finally, you raised the issue of whether the standard, as with othe national and international standards, should have a requirement that conditioned webbing must retain a certain percentage of its unconditioned strength and must also meet the minimum strength requirement for unconditioned webbing. The agency is not aware of any data indicating that our current conditioned strength requirements are insufficient.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4259OpenFrank E. McCarthy, Executive Vice-President, National Automobile Dealers Association, 8400 Westpark Drive, McLean, VA 22101; Frank E. McCarthy Executive Vice-President National Automobile Dealers Association 8400 Westpark Drive McLean VA 22101; Dear Mr. McCarthy: It has come to our attention that a recent Alabama Supreme Cour decision has led some dealers to question the appropriate certification to make when issuing odometer disclosure statements. Although we have not received any inquiries from your members at this time, we have been contacted by others in the industry. The purpose of this letter is to advise you of the National Highway Traffic Safety Administration's position concerning the certifications to be made on odometer disclosure statements.; Congress found that purchasers rely on mileage as an indicator of th value and condition of vehicles and enacted Title IV of the Motor Vehicle Information and Cost Savings Act, 15 U.S.C. S1981 *et seq*. Section 1988(a) of the Act requires the Secretary of Transportation to prescribe rules requiring any transferor to give a written disclosure (1) of the cumulative mileage registered on the odometer or (2) that the actual mileage is unknown, if the odometer reading is know to the transferor to be different from the number of miles the vehicle has actually travelled. To carry out this mandate, Federal regulation 49 C.F.R. Part 580 was promulgated. Furthermore, Section 1988(a) states that no transferor shall violate any rule prescribed under the section or give a false statement to a transferee in making any disclosure required by such rule.; A Senate report interprets Section 1988 as placing duty on auto dealer to alert purchasers of irregularities in odometers when, in the exercise of reasonable care, they would have reason to know the odometer reading is inaccurate. S. Rep. No. 92-413, (92nd Cong., 2nd Sess.), 1972 U.S. Code Cong. & Ad. News 3971-3972. If a purchaser receives an odometer statement in which his transferor certified that the odometer reading does not reflect the actual mileage and should not be relied upon, that purchaser, when selling the vehicle, should certify the same. However, if a purchaser receives an odometer statement in which his transferor certified that to the best of his knowledge the odometer reading reflects the actual mileage the vehicle has been driven, and he has no reasonable suspicion that the reading is inaccurate, when selling the vehicle, he should not certify that the reading is inaccurate. If transferors certify the reading as inaccurate in the latter situation, it is the position of the National Highway Traffic Safety Administration that they violate the regulations prescribed under Section 1988, 49 C.F.R. S580.4.; The Federal regulations provide for the inclusion of two sets o certifications on odometer disclosure statements. If the dealers truly wish to insulate themselves from liability when they have a reasonable suspicion that the mileage on the odometer has been altered, they *should* certify that the reading is not accurate, and check the third statement in the first set of certifications. However, none of the three statements in the second set covers a situation where a transferor suspects that an odometer reading is inaccurate, but the odometer was not altered, set back or disconnected in his possession. The Agency allows a transferor to check the first statement and cross out the lines which read, 'and I have no knowledge of anyone else doing so' provided that though crossed out it can still be read. Alternatively, we have no objection to a transferor writing and checking a fourth statement which would read:; >>>I hereby certify that the odometer of said vehicle was not altered set back, or disconnected while in my possession.; << |
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ID: aiam3066OpenMr. D. J. Arneson, Box 141, Southbury, CT 06488; Mr. D. J. Arneson Box 141 Southbury CT 06488; Dear Mr. Arneson: This is in reply to your letter of June 27, 1979, which inquire whether there are any regulations governing the installation of a propane-fueled engine, or the conversion of a gasoline-fueled engine to a propane-fueled engine, in vehicles registered for use on Federal, State, and local highways.; To date, the National Highway Traffic Safety Administration (NHTSA) ha not exercised its authority pursuant to the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381 *et seq*.) (the Act), to issue a safety standard applicable to propane-powered vehicles. Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity*, applies only to vehicles which use fuel with a boiling point above 32 degrees F., and propane has a boiling point well below this temperature. Despite the absence of safety standards specifically applicable to propane-powered engines, however, an installer of these systems may be subject to other Federal requirements.; Under NHTSA safety regulations, a person who alters a new vehicle prio to its first purchase in good faith for purposes other than resale is required to attach an additional label to the vehicle certifying that, as altered, the vehicle remains in compliance with all applicable safety standards (49 CFR 567.7). This requirement would apply to a person who alters a new vehicle to install a propane fuel system. (See the enclosed pamphlet listing the Federal motor vehicle safety standards and an information sheet explaining where to obtain copies of the standards.) Additionally, should a noncompliance or safety-related defect be discovered in such a vehicle, as a result of the modification, the alterer could be liable for a civil penalty unless he or she could establish that he or she did not have actual knowledge of the noncompliance and that he or she did not have reason to know in the exercise of due care that the vehicle did not comply. (Section 108(b)(2)) Defects in the propane-fueled engines or in components used for converting a gasoline-fueled engine would be the responsibility of their manufacturers, regardless of whether they were installed in new or used vehicles. Upon discovery of a safety-related defect by either the Secretary of Transportation, the NHTSA Administrator or the manufacturer himself, the manufacturer would be required to notify vehicle owners, purchasers, and dealers and provide a remedy for the defect.; A person who installs a propane- fueled engine or converts th gasoline-fueled engine in a used vehicle is not required to affix an alterer's label. However, if that person is a manufacturer, distributor, dealer, or motor vehicle repair business, he must not in the course of installing the propane components knowingly render inoperative any device or element of design originally installed in the vehicle in compliance with applicable Federal motor vehicle safety standards. (Section 108(a)(2)(A) of the Act); I hope that you will find this response helpful and have not bee inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4873OpenMr. Dan P. Strauser Manager - Research and Development Elgin Sweeper Company 1300 W. Bartlett Road P.O. Box 537 Elgin, IL 60121-0537; Mr. Dan P. Strauser Manager - Research and Development Elgin Sweeper Company 1300 W. Bartlett Road P.O. Box 537 Elgin IL 60121-0537; "Dear Mr. Strauser: This responds to your letter of March 25, 199 regarding the applicability of this agency's safety standards to a number of models of Elgin and Ravo street sweepers. In general, all vehicles classified as 'motor vehicles' are subject to safety standards. Section 102(3) of the National Traffic and Motor Vehicle Safety Act (the Act) defines the term 'motor vehicle' as follows: 'Motor vehicle' means any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. Under a longstanding policy, this agency has regarded vehicles not to be 'motor vehicles' within the meaning of the Act and therefore not subject to safety standards, despite their use on the highways, if they (1) have an unusual body configuration which sets the vehicles apart from typical highway traffic and (2) have a maximum speed capability of 20 mph or less. Based upon the literature you provided, the Pelican 'SE' and Pelican 'P' 3-wheel street sweepers appear to meet these criteria. If the advertised speed ('Up to 20 mph') is the maximum speed these vehicles are capable of, these vehicles would not be considered 'motor vehicles' and therefore would not be required to comply with the safety standards. Since the advertised speed of the Whirlwind, Crosswind, and Eagle 4-wheel street sweepers, and the Ravo Model 5000 street sweeper exceeds 20 mph (or the description, i.e., 'legal highway speeds', suggests that the vehicle is capable of exceeding 20 mph), these vehicles would be considered 'motor vehicles.' The information you enclosed on the Ravo Model 4000 street sweeper did not indicate its maximum speed capability. If this vehicle is capable of speeds in excess of 20 mph, it would also be considered a 'motor vehicle.' Street sweepers which are considered to be 'motor vehicles' would be classified as 'trucks' and required to comply with all safety standards applicable to trucks. The Federal motor vehicle safety standards are contained in Title 49 of the Code of Federal Regulations (CFR), Part 571. You may find a copy of 49 CFR Part 571 at a Federal Depository Library in your State. If you so choose, you may purchase a copy of the volume of Title 49 which includes Part 571 from the United States Printing Office (GPO), Washington, D.C., 20402, (202) 783-3238. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0099OpenMr. Paul L. Nine, Manager, Product Regulations, Chrysler Corporation, Office of Civic Affairs, Detroit, MI 48231; Mr. Paul L. Nine Manager Product Regulations Chrysler Corporation Office of Civic Affairs Detroit MI 48231; Dear Mr. Nine: Thank you for your letter of August 9, 1968, containing literature o 'Super-Lite' which will be an optional lighting device on the 1969 Dodge Polara and Monaco Models.; According to the literature, 'Super-Lite' is an auxiliary o supplemental light to be used in conjunction with the low beams of the regular headlamps.; For many years, all lighting devices used on motor vehicles registere in New Jersey have been required to be approved by the New Jersey Division of Motor Vehicles. Lighting devices are added to our approved list after a sample has been submitted along with a report from an independent testing laboratory showing that the device meets the standards of the Society of Automotive Engineers. We will also add a motor vehicle lighting device to our approved list after we receive an Approval Certificate from the American Association of Motor Vehicle Administrators showing that the device meets the SAE Standards.; Electric Supplementary Lamps, such as the 'Super- Lite' are covered b SAE Standard No. J582. Perhaps you have submitted a sample light and the necessary test report to the AAMVA, but as yet, we have not received a copy of the Approval Certificate.; In case you desire to have us approve the 'Super- Lite' on the basis o New Jersey alone, please send us a sample and test report, as mentioned above.; Unless the 'Super-Lite' is on our approved list at the time moto vehicles equipped with the lighting device are going through our inspection stations, the vehicles will have to be rejected.; New Jersey R.S. 39:3-51 concerns the mounting and aiming of auxiliar driving lights. A copy of this section is enclosed for your information.; Very truly yours, John A. McLaine, Chief, Automotive Engineerin Standards; |
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.