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: aiam4911OpenMr. Kenneth M. Bush Regulations Manager, Government Relations American Suzuki Motor Corporation 3251 E. Imperial Hwy. P.O. Box 1100 Brea, CA 92622-1100; Mr. Kenneth M. Bush Regulations Manager Government Relations American Suzuki Motor Corporation 3251 E. Imperial Hwy. P.O. Box 1100 Brea CA 92622-1100; "Dear Mr. Bush: This responds to your letter of September 6, 1991, t Mr. Vinson, asking whether a vehicle you are developing would be classified as a multipurpose passenger vehicle for the purposes of the Federal motor vehicle safety standards. I am pleased to be able to explain our law and regulations for you. At the outset, I would like to make clear that the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) places the responsibility for classifying a particular vehicle in the first instance on the vehicle's manufacturer. For this reason, NHTSA does not approve or endorse any vehicle classification before the manufacturer itself has classified a particular vehicle. NHTSA may reexamine the manufacturer's classification during the course of any enforcement actions. We will, however, tentatively state how we believe we would classify this vehicle for the purposes of our safety standards. It is important that you understand that these tentative statements of classification are based entirely on our understanding of the information presented in your letter to us. These tentative statements about the vehicle's classification may change after NHTSA has had an opportunity to examine the vehicle itself or otherwise acquire additional information about the vehicle. With those caveats, we believe that the vehicle referenced in your letter could be classified as a multipurpose passenger vehicle for the purposes of our safety standards. The term 'multipurpose passenger vehicle' is defined in 49 CFR 571.3 as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' In your letter, you state that the vehicle's chassis should be considered a truck chassis because it 'was originally designed to provide cargo-carrying capability as well as to permit rough road and off the road vehicle operation.' Additionally, you state that the approach and departure angles and the running clearance dimensions for this vehicle are more similar to other vehicles which have been classified by their manufacturers as multipurpose passenger vehicles than vehicles that have been classified as passenger cars. Based upon this description, it appears to us that this vehicle could be classified as a multipurpose passenger vehicle. I hope you find this information helpful. The version of your letter that has been placed in the public docket has all the information for which you requested confidential treatment deleted from it. 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: aiam3692OpenMr. Anthony Lauro, President, VREDUSA, P.O. Box 279, Somerset, NJ 08873; Mr. Anthony Lauro President VREDUSA P.O. Box 279 Somerset NJ 08873; Dear Mr. Lauro: This responds to your recent letter asking if you can legally sel certain tires you have imported from the Netherlands. These truck tires have a DOT symbol on the sidewall but do not have a maximum load rating and corresponding inflation pressure labeled on the sidewall.; Under Federal law, these tires cannot be sold or otherwise introduce into interstate commerce because they do not comply with all requirements of Safety Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.119). Paragraph S6.5(d) of Standard No. 119 (copy enclosed) requires that a maximum load rating and corresponding inflation pressure be labeled on both sidewalls of each tire subject to the standard. The tires described in your letter plainly do not meet this requirement. Hence, the DOT symbol on those tires is misleading, since that symbol is supposed to be a manufacturer's certification that the tires comply with all requirements of Standard No. 119.; Section 108 of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. 1397) specifies that no person shall sell or introduce into interstate commerce any item of motor vehicle equipment (which includes tires) unless the item is in conformity with all applicable safety standards. Section 109 of the Safety Act (15 U.S.C. 1398) sets forth a civil penalty of up to $1000 for each violation of section 108, and each of these nonconforming tires would be treated as a separate violation of section 108 if they were offered for sale or introduced into interstate commerce.; At this point, you have two legal courses of action open to you. Yo may have the tire manufacturer file a petition requesting an exemption from the noncompliance of these tires, arguing that the noncompliance is inconsequential as it relates to the safety of the tires. The procedures to be followed in filing a petition for an inconsequential noncompliance are set forth in the enclosed copy of 49 CFR Part 556, *Exemption for Inconsequential Defect or Noncompliance*. I cannot state at this time that the absence of maximum load information would be viewed as inconsequential, but we would certainly give full consideration to any petition the manufacturer might submit. If the petition were granted, you could sell these tires.; The other course of action available to you is to ship these tires bac to the manufacturer in the Netherlands and explain that they do not satisfy the requirements of Standard No. 119. I appreciate your efforts to ensure that you are complying with all applicable Federal regulations with respect to the sale of tires you import.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4383OpenMr. Y. Osaki, Manager, Truck Engineering, MMC Services, Inc., 3000 Town Center, Suite 501, Southfield, MI 48075; Mr. Y. Osaki Manager Truck Engineering MMC Services Inc. 3000 Town Center Suite 501 Southfield MI 48075; Dear Mr. Osaki: This responds to your letter asking about the relationship between th maximum load ratings for the tires on a medium duty truck and the gross vehicle weight rating (GVWR) specified for that truck pursuant to 49 CFR Part 567, *Certification*. Specifically, you asked if the GVWR specified for a truck could slightly exceed the sum of the gross axle weight ratings specified for the truck. While none of our regulations prohibit your company from assigning a GVWR that exceeds the sum of the gross axle weight ratings for this medium duty truck, we recommend that you not do so, for the reasons explained below.; Your letter correctly notes that paragraph S5.1.2 of Standard No. 120 *Tire Selection and Rims for Motor Vehicles other than Passenger Cars* (49 CFR S571.120) requires that the sum of the maximum load ratings of the tires fitted to each truck axle shall be not less than the gross axle weight rating (GAWR) for the axle system, as specified on the vehicle certification label required by Part 567. However, Part 567 does not limit the GVWR that can be assigned to the sum of the GAWR's specified for a vehicle. Instead, S567.4(g)(3) requires that the vehicle certification label specify the GVWR of the truck and requires only that the specified GVWR 'shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity.'; Although Part 567 does not prohibit such a practice, we note tha assigning a GVWR to a vehicle that exceeds the sum of the GAWR's assigned to the vehicle (other than a semitrailer) would be encouraging the user of that vehicle to overload it. If the axles of a medium duty truck cannot safety bear the load specified in the GVWR, the vehicle will be overloaded whenever it is loaded to the specified GVWR. Such overloading poses a serious safety hazard for the affected vehicle in particular and for the motoring public in general. Several past interpretations on this subject have stated if a vehicle suffers a hazardous malfunction while in use that can be traced to the overloading of its axle systems, its manufacturer may be liable both under the defect provisions of the National Traffic and Motor Vehicle Safety Act and under common law product liability doctrines. To avoid giving rise to a potential safety hazard and the accompanying liability, we recommend that you specify a GVWR not greater than 17,196 pounds for the medium duty truck in question.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2518OpenMr. Jack Gromer, Vice President - Engineering, 5990 N. Washington Street, Denver, Colorado 80216; Mr. Jack Gromer Vice President - Engineering 5990 N. Washington Street Denver Colorado 80216; Dear Mr. Gromer: This responds to Timpte's January 11, 1977, question whether NHTS regulations prohibit sale and delivery of a trailer to the first purchaser equipped with two used tires in place of the eight tires that are specified for the vehicle and which would form the basis of certification under Part 567, *Certification* and the basis of compliance with Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars*.; As you are aware, Part 567 of our regulations requires a statement b the vehicle manufacturer of the gross axle weight rating (GAWR) for each axle on any motor vehicle it manufacturers (S567.4(g) (4)). The term 'GAWR' is defined in S571.3 of our regulations as the value specified by the manufacturer as the load-carrying capacity of the axle system, measured at the tire-ground interfaces. This clearly means that the tires and wheels on an axle must be taken into account in assigning a GAWR value for certification purposes.; Standard No. 120 specifies that 'each vehicle...shall be equipped wit tires that meet [specified requirements]' (S5.1.1) but makes provision for the installation of used tires owned by the purchaser if the maximum load ratings of the tires on an axle system are at least equal to the GAWR assigned to the axle system by the vehicle manufacturer (S5.1.3). Section S5.1.3 reflects the agency's view that existing commercial practices for delivery of vehicles with safe used tires has not created a significant safety problem to date.; In recognition of varying commercial practices for the delivery o vehicles, the agency has interpreted S5.1.1 of Standard No. 120 to prohibit the installation of tires that do not meet certain performance requirements, but not as a requirements that the tires be fitted to every axle of a vehicle prior to certification and sale. A copy of this interpretation is enclosed for your information. The interpretation makes clear that, while the agency interprets Standard No. 120 (and by implication Part 567) to permit the assignment of a GAWR on the basis of tires listed on the certification plate, the assignment of an arbitrarily high (or low) GAWR for purposes such a avoiding a Federal motor vehicle safety standard could constitute a violation of law.; With regard to the practice you describe of delivering an empty ne trailer to the purchaser on fewer tires than necessary to confirm to the GAWR listed on the certification plate and the minimum requirements of S5.1.1 and S5.1.2 of Standard No. 120, the agency interprets its motor vehicle safety standard and S567.4(g) (4) to permit such a good faith delivery practice. In the event any pattern of avoidance of Federal requirements becomes apparent, however, the agency would reconsider this interpretation.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5156OpenMr. Donald L. Anglin 706 Rose Hill Drive Charlottesville, VA 22903; Mr. Donald L. Anglin 706 Rose Hill Drive Charlottesville VA 22903; "Dear Mr. Anglin: This responds to your letter in which you aske whether removing the self- adjusters on a motor vehicle's drum brakes constitutes a violation of the 'anti-tampering' provisions of several Federal laws, including the National Traffic and Motor Vehicle Safety Act. I am pleased to have this opportunity to explain this agency's regulations. You will need to contact the Environmental Protection Agency for an interpretation of the Clean Air Act. By way of background information, the National Traffic and Motor Vehicle Safety Act ('Safety Act') requires this agency, the National Highway Traffic Safety Administration (NHTSA), to promulgate motor vehicle safety standards that specify performance requirements for new motor vehicles and items of motor vehicle equipment. Among the standards issued by NHTSA are Standard No. 105, Hydraulic Brake Systems and Standard No. 121, Air Brake Systems. Standard No. 105 specifies requirements for hydraulic service brake and associated parking brake systems, and applies to new passenger cars, multipurpose passenger vehicles, trucks, and buses equipped with hydraulic brake systems. Standard No. 121 establishes performance and equipment requirements for braking systems on vehicles equipped with air brake systems, and applies to almost all new trucks, buses, and trailers equipped with air brake systems. NHTSA recently amended these standards to require vehicles to be equipped with automatic brake adjusters. (57 FR 47793, October 20, 1992) This rule takes effect on October 20, 1993 for vehicles equipped with hydraulic brakes and on October 20, 1994 for vehicles equipped with air brakes. Until these effective dates, a vehicle is not required to be equipped with automatic brake adjusters. You specifically asked about the agency's 'anti-tampering' provisions. While the agency has no provision called this, the Safety Act does include a provision known as the 'rendering inoperative' provision which is set forth in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits manufacturers, distributors, dealers, and repair shops from knowingly 'rendering inoperative,' in whole or in part, any device or element of design installed on or in a vehicle in compliance with an applicable safety standard. For vehicles manufactured on or after the effective date of the new requirements for automatic adjusters, manufacturers, distributors, dealers and repair businesses will be prohibited by section 108(a)(2)(A) from rendering the devices inoperative. For vehicles manufactured before that time, such an entity should ensure that removal of the adjusters does not otherwise render inoperative the compliance of the vehicle with a safety standard. I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel "; |
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ID: aiam3955OpenMr. L. D. Pitts, Jr., P. O. Box 52592, Houston, TX 77002; Mr. L. D. Pitts Jr. P. O. Box 52592 Houston TX 77002; Dear Mr. Pitts: Thank you for your letter of March 12, 1985, asking about the effect o our regulations on a product you would like to manufacture. I hope the following discussion explains that effect.; You described your product, which you call a glare- shield, as 1/8-inch thick sheet of 'Lexan' plastic with a special scratch resistant coating. Your product is designed to be mounted inside a motor vehicle, as close to the windshield as possible, to reduce glare-related vision problems caused by the sun. You stated that your product would cover the entire windshield and is designed to be held in place by three or six latches. The latches can be released by the driver and the shield can be removed from the car.; Pursuant to the National Traffic and Motor Vehicle Safety Act, we hav issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials,* (49 CFR 571.205) which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; Any manufacturer, dealer or other person who installs tinting films o other sun screen devices, such as the one described in your letter, in *new* vehicles must certify that the vehicle as altered continues to comply with the requirements of the standard. Thus, for example, the light transmittance through the combination of the sun-screening material and the glazing must be at least 70 percent in the case of glazing used in windows requisite for driving visibility. Similarly, the combination must also meet the other applicable requirements of the standard, such as the abrasion resistance requirements.; After a vehicle is sold to the consumer, owners may themselves alte their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, an owner may install any device regardless of whether the installation adversely affects light transmittance. The agency does, however, urge owners not to install equipment which would render inoperative the compliance of a vehicle with our standards. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from using sun screens on their vehicles.; If a manufacturer, dealer, distributor or motor vehicle repair busines installs the sun screen device for the owner of a used vehicle, then S108(a)(2)(A) of the Vehicle Safety Act may apply. That section provides that none of those persons may knowingly render inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a Federal motor vehicle safety standard. Violation of the 'render inoperative' provision can result in Federal civil penalties of up to $1,000 for each violation.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam3289OpenMr. Robert Slagle, Parts Manager, Brown Motors Volkswagen, 5 West 18th Street at National City Boulevard, National City, CA 92050; Mr. Robert Slagle Parts Manager Brown Motors Volkswagen 5 West 18th Street at National City Boulevard National City CA 92050; Dear Mr. Slagle: This responds to your recent letter requesting information concernin the Federal requirements that would be applicable to the manufacture and installation of auxiliary diesel fuel tanks in passenger cars. I am enclosing a copy of a letter of interpretation the agency issued last August which discusses the general implications of such installations under Federal law.; Your letter asked whether it will be necessary for you to crash tes vehicles that have the auxiliary tanks installed. As indicated in the enclosed interpretation, if the tank is added to a new vehicle prior to its first purchase for purposes other than resale, the person making the alteration will have to certify that the vehicle continues to be in compliance with all Federal motor vehicle safety standards, including Standard No. 301-75. The National Traffic and Motor Vehicle Safety Act requires a manufacturer (including an alterer) to exercise due care to assure that a vehicle it certifies is in fact in compliance with all safety standards (15 U.S.C. 1397). It is up to the manufacturer to determine how he will establish due care and, in this case, whether he will crash test a vehicle or use some other method to ensure compliance of the vehicle. The test procedures in Safety Standard No. 301-75 are not obligatory, only the performance requirements. The test procedures do, however, state how the agency will test a vehicle to determine compliance.; In answer to your question number 4, I can state that it will not b necessary for you to crash test each vehicle which has a tank installed in order to establish due care. If by your question you meant one car of each car 'model,' once again, it is up to the manufacturer how he establishes due care.; In answer to your question number 3, the information contained in th enclosed interpretation includes discussions of all the Federal safety requirements that would be applicable to your company's activities. There may, of course, be other general Federal laws regarding the conducting of a business which would be pertinent. For example, Federal Trade Commission regulations regarding advertising could affect your activities. You are probably aware of these general regulations, however, since you are already an established business enterprise.; Regarding your final question, all vehicle manufacturers, both domesti and foreign, have performed crash tests to determine compliance with Safety Standard No. 301-75. Since your company is a Volkswagen dealership, I suggest you contact Volkswagen regarding its compliance testing program for Safety Standard No. 301-75.; If you have any further questions after reviewing this information please contact Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5176OpenSt. F. Steiner Consultant AET Network 2190 3rd Street San Francisco, CA 94107; St. F. Steiner Consultant AET Network 2190 3rd Street San Francisco CA 94107; "Dear Sir or Madam: We have received your 'Dear Mr. Van Orden' lette of May 4, 1993, which was addressed to me. You wish to import 3- and 4-wheeled vehicles from Europe 'for research and exploration', and have asked several questions relating to U.S. laws and D.O.T. requirements. Your first question is: 'Are there any safety standards and regulations for the above mentioned automobiles?' The answer is yes. All 3-wheeled motor vehicles are considered 'motorcycles' for purposes of compliance with the Federal motor vehicle safety standards that apply to motorcycles. Depending upon their configuration, but not upon their weight, 4-wheeled vehicles are either 'passenger cars', 'multipurpose passenger vehicles', 'trucks', or 'buses' for purposes of the safety standards. However, motor vehicles intended solely for purposes of research may be imported without the necessity of conforming them to the safety standards under the terms and conditions that the agency has set out in 49 CFR Part 591. Your second and third questions are whether there is a minimum speed standard regulation or weight limitations for the vehicles you wish to import. The answer is no. However, a motorcycle with 5-horsepower or less is considered a 'motor-driven cycle', and some of the motorcycle standards impose lesser requirements for motor-driven cycles, and motor-driven cycles whose speed attainable in l mile is 30 mph or less. Your fourth question relates to the conversions required to meet U.S. specifications and standards. As indicated previously, no conversion is required when the importation is solely for the purpose of research. If you wish to import vehicles that have been originally manufactured to meet the Federal motor vehicle safety, bumper, and theft prevention standards, the manufacturer will find those standards at 49 CFR Parts 571, 581, and 541, respectively. If you wish to import nonconforming vehicles for conversion after importation, then the agency must determine that the vehicles are eligible for entry pursuant to 49 CFR Part 593, and importation and conversion accomplished through a Registered Importer pursuant to 49 CFR Part 592. Your final question is whether the vehicles will be permitted on highways. This is a question that is not answerable under Federal law. Each State determines the criteria for licensing motor vehicles for use on the roads under its jurisdiction. If a State does not license a vehicle for on-road use (all terrain vehicles, minibikes, golf carts are examples), a basis exists for a manufacturer to determine that its vehicles are not 'motor vehicles.' If a vehicle is not a motor vehicle, i.e. one manufactured primarily for on-road use, then no Federal safety standards apply to it. If you have any further questions about the importation process, you should refer them to Mr. Van Orden at our Office of Vehicle Safety Compliance, Office of Enforcement. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam4988OpenMr. George F. Reuss Reuss Engineers, Inc. P.O. Box 22 Waltz's Mills Madison, PA 15663; Mr. George F. Reuss Reuss Engineers Inc. P.O. Box 22 Waltz's Mills Madison PA 15663; "Dear Mr. Reuss: This responds to your letter addressed to Barr Felrice, NHTSA's Associate Administrator for Rulemaking, concerning your recently patented vehicle that is designed to transport passenger cars. You requested information about which specific regulations and standards would be applicable to your vehicle. I am pleased to have this opportunity to explain our regulations. I am also enclosing the agency's general information fact sheet for new manufacturers and a booklet entitled 'Federal Motor Vehicle Safety Standards and Procedures,' which summarizes the basic requirements of our safety standards and shows which standards apply to various vehicle types. You explained that your vehicle consists of a chassis with a gross vehicle weight rating (GVWR) greater than 10,000 pounds and a structural frame between the cab and rear wheels. This frame includes moveable forks that can be extended from the framework and inserted beneath a passenger car's tires. The forks can be raised and retracted into the framework, thus allowing your vehicle to transport the passenger car. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A), the Safety Act) authorizes this agency to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards. Manufacturers of motor vehicles must certify compliance of their products in accordance with 49 CFR Part 567, Certification. I note that you may be considered a 'final-stage manufacturer' under Part 568, Vehicles Manufactured in Two or More Stages, because you purchase the chassis. Section 102(3) of the Safety Act defines the term 'motor vehicle' as follows: '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.' Based on the description in your letter, it appears that your vehicle is a motor vehicle under the Safety Act. More specifically, it appears that your vehicle would be considered a 'truck' under the agency's regulations. The term 'truck' is defined, at 49 CFR Part 571.3, as 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment.' Accordingly, your vehicle must comply with all Federal motor vehicle safety standards that are applicable to trucks with a GVWR greater than 10,000 pounds and be certified as conforming to those standards. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0493OpenMr. Louis P. Spitz, Executive Director, American Association of Motor Vehicle Administrators, 1828 L Street, N.W., Suite 500, Washington, DC 20036; Mr. Louis P. Spitz Executive Director American Association of Motor Vehicle Administrators 1828 L Street N.W. Suite 500 Washington DC 20036; Dear Mr. Spitz: Thank you for your letter of November 9, 1971, in which you expresse concern over the requirement in our Certification regulations (36 F.R. 19593, October 8, 1971) that all vehicles, including those manufactured in two or more stages, have a vehicle identification number on their certification label.; You stated that your major concern was that the manufacturers would b 'confused', and 'would further add to the problems of vehicle identification experienced by the Motor Vehicle Administrators.' Your letter did not, however, specify how or why our regulations would 'add to the problems.' With reference to a telephone conversation of November 4 with Mr. Dyson of our Chief Counsel's Office, you declined a request that you supply specific suggestions for modification of the regulation, on grounds that 'this could be ultimately viewed as presumptive on our part.'; I would like to clarify some points concerning this requirement. Th requirement of placing a vehicle identification number on each certification label has existed since our first Certification regulations went into effect on September 1, 1969, and the amended regulations that become effective January 1, 1972 (to which you refer) contain no change whatever in that requirement. The reason why the VIN came to your attention as a separate proposal was that our March 17, 1970 notice, in which we proposed changes in the way we regulate multistage vehicles, had omitted the requirement, largely through oversight. The legal requirements for public notice required us to issue a notice of proposed rulemaking, in order to retain the VIN on the labels, where it has been since September 1969.; We have not attempted in this motor vehicle safety regulation t regulate the form of the vehicle identification numbers on vehicles other than passenger cars. We have, in effect, left the situation exactly as it has been since September 1, 1969, when the Certification regulations first went into effect: we require that each vehicle have on its permanent label a 'vehicle identification number.' We chose then (as we have since) to leave the form of the number to the manufacturer, in the first instance, subject to whatever State regulations might be in force, and in accordance with whatever guidelines he might choose to follow. While this policy has not solved the problems of the motor vehicle administrators, it is not at all clear to us how it could have added to them.; As you know, we are working closely with State officials on the proble of standardizing vehicle identification numbers, in connection with our highway safety program standard on motor vehicle registration. We would like very much to have your ideas on how we can deal with these problems through our Traffic Safety Programs.; Sincerely, Douglas W. Toms, Administrator |
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.