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: nht93-7.7OpenDATE: October 1, 1993 Est. FROM: Bob Carver TITLE: None ATTACHMT: Attached to letter dated 11/22/93 from John Womack to Bob Carver (A41; Part 571; Std. 217) TEXT: I'm an engineer at Wayne Wheeled Vehicles, a commercial and school bus manufacturing company. My job here is to see ensure compliance to FMVSS 217, effective May 1994. I have a question for you in which I need an official ruling concerning FMVSS 217 S5.5.3(c): Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white, or yellow in color, that when tested under the conditions specified in S6.1 of 571.131 meets the criteria specified in Table 1. If an emergency roof exit is required, is it necessary to outline it with the retroreflective tape even though it is not visible unless the bus is tilted on its side? Also, Charles Hott at NHTSA said that the width requirement will be revised to 1 inch. Can you confirm this? Thanks in advance for your prompt consideration and assistance concerning this matter. |
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ID: nht95-2.3OpenTYPE: INTERPRETATION-NHTSA DATE: March 14, 1995 FROM: Takashi Adachi -- Manager, Ichikoh Industries, Ltd. TO: Richard L Van Iderstin -- Visibility and Controls Group, Office of Vehicle Safety Standards, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO 5/9/95 LETTER FROM JOHN WOMACK TO TAKASHI ADACHI (A43; STD. 108) TEXT: Dear Mr. Van Iderstein, I am writing this letter to ask you a view with regard to conformity of the reflex reflector included in rear lamp that our company are consider to design. Structure of design are described on the attachment. My questions are related to conformity to FMVSS 108, as follows. 1. Does this structure of the reflex reflector conform to FMVSS 108? 2. Shall the reflex reflector meet the photometric performance requirement in the whole area of the reflex reflector? 3. Or shall each area (upper and lower) of the reflex reflector meet the photometric requirement individually? Thank you in advance, I will call you later to listen your reply. Enclosed: figure 1 (rear of lamp) shows clear and red outer lens, reflex reflector and opaque area. (Figure omitted.) |
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ID: nht71-1.11OpenDATE: 03/29/71 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: American Motors Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 12, 1971, to Mr. Lewis C. Owen of this office concerning an interpretation on your lens assembly, SF-3610703. Federal Motor Vehicle Safety Standard No. 108 requires a minimum effective projected illuminated area for Class A turn signal lamps of 12 square inches on motor vehicles other than passenger cars and motorcycles. The subject lens assembly used in a turn signal lamp assembly with the opaque ornament does not appear to meet the 12 square inches minimum requirement. The calculations for the area, as determined by the method contained in our October 28, 1970, letter to Mr. E. W. Bernitt, were based on measurements of the ornament, because the detail dimensions were not supplied. The backup lamp design you discussed in a telephone conversation with Mr. Owen also apparently does not meet the requirements of FMVSS No. 108. If you would like an interpretation on this backup lamp, please furnish information on the design similar to that supplied with the subject letter. |
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ID: nht71-1.42OpenDATE: 07/22/71 FROM: E. T. DRIVER -- NHTSA OFFICE OF OPERATING SYSTEMS MOTOR VEHICLE PROGRAMS TO: LOUIS C. LUNDSTROM -- DIRECTOR, AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS ENVIRONMENTAL STAFF TITLE: NONE TEXT: Dear Mr. Lundstrom: This is in reply to your letter of July 12, 1971, to Mr. Douglas W. Toms, Acting Administrator, concerning replacement equipment covered in FMVSS No. 108, effective January 1, 1972. The requirements for original and replacement equipment in FMVSS No. 108 cover those items listed in Tables I and III, namely: Headlamps Turn signal operating units Tail lamps Turn signal flashers Stop lamps Vehicular hazard warning signal License plate lamps operating units Reflex reflectors Vehicular hazard warning signal Parking lamps flashers Side marker lamps Identification lamps Backup lamps Clearance lamps Turn signal lamps Intermediate side marker lamps Intermediate reflex reflectors In addition the requirements cover the following items specified in the text of the standard: School bus warning lamps Headlamp beam switching devices Headlamp upper beam indicator lamps Turn signal pilot indicator lamps Hazard warning signal pilot indicator lamps Plastic lenses Sincerely, |
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ID: nht91-2.27OpenDATE: March 12, 1991 FROM: Rueben K. Brown -- Product Engineer, Crane Carrier Company TO: Chief Counsel -- Office of Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 3-29-91 from Paul Jackson Rice to Rueben K. Brown (A37; Std. 105) TEXT: I am employed as a product engineer with Crane Carrier and am currently involved in FMVSS 105 testing of our school bus chassis. I am unclear on the applicability of the spike stop requirement for school buses greater than 10,000 lb. GVWR. There appears to be some confusion in the industry on this subject. (I have previously spoken with Zack Fraser, of NHTSA, who referred me to your office for an expert opinion.) Please provide an interpretation of FMVSS 105 regarding spike stops on school buses greater than 10,000 lb. GVWR. You can reach me at the Bendix Automotive Proving Grounds, New Carlisle, Indiana 46552 (219-654-7400) for approximately the next 2-3 weeks. After that I can be reached at the address shown above for Crane Carrier. Thanking you in advance for your cooperation in this matter. |
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ID: 05-009244drnOpenMr. Mike Pruzin Chief Engineer Hitachi Cable Indiana, Inc. 5300 Grant Line Road New Albany, IN 47150 Dear Mr. Pruzin: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 106, Brake Hoses (49 CFR 571.106). You asked whether a change in the company manufacturing brake hoses necessitates a change in the manufacturer designation on the hose. As discussed below, under certain circumstances, brake hose may be labeled with the designation of a company which is the sponsor/manufacturer of the hose rather than the company which fabricates it. You informed us that Hitachi Cable Limited (HCL), a Japanese company, previously manufactured brake hose that it labeled HCL and supplied it to your company, Hitachi Cable Indiana, Inc. HCL subsequently entered into a licensing agreement with LG Cable, a Korean company, to, as you state: manufacture our hose using our designs and material specs. You wish to know if LG Cable can label the hose it manufactures with the same designation (HCL) used by HCL on the hose it manufactured, instead of labeling the hose with its own designation, LGC. Although you did not specify the brake hose type at issue, we assume that it is hydraulic brake hose. S5.2.2 of FMVSS No. 106 requires that each hydraulic brake hose be labeled, or cut from bulk hose that is labeled, with specified information. The specified information includes, among other things, a designation that identifies the manufacturer of the hose. The term "manufacturer" is defined by statute as "a person manufacturing or assembling motor vehicles or motor vehicle equipment; or importing motor vehicles or motor vehicle equipment for resale." 49 U.S.C. 30102. On several occasions, in the context of considering whether a particular entity may be considered the manufacturer of a motor vehicle, we have interpreted the term manufacturer broadly. In the 1985 notice of proposed rulemaking for the phase-in of the new automatic restraint requirements of FMVSS No. 208, Occupant Crash Protection, the agency acknowledged that there were instances in which a vehicle arguably could have more than one manufacturer. See 50 Fed. Reg. 14589, 14596 (April 12, 1985). The example we gave in explaining our position was a company, which we refer to as a "sponsor," that contracts with another manufacturer to produce a design exclusively for the sponsor. However, the agency went on to state, "the mere purchase of vehicles for resale by a company which is also a manufacturer of motor vehicles does not make the purchaser the manufacturer of those vehicles." Other examples are discussed in a December 10, 1992 letter to Erika Z. Jones, Esq. A copy of this letter is enclosed. We believe that the rationale of our interpretations regarding motor vehicle manufacturers is applicable to the situation you describe regarding motor vehicle equipment manufacturers. In particular, given the facts you provide, HCL may be considered the manufacturer of the brake hose at issue. HCL is not merely purchasing brake hose from LG Cable, but has entered into a licensing agreement with that company to manufacture hose using HCLs designs and material specs. Because HCL may be considered the sponsor/manufacturer of the brake hose, and assuming HCL has agreed to its being so designated, the hose may be labeled with HCLs designation. We note that, to the extent HCL provides for the hose to be labeled with its designation, it would be accepting responsibility as the manufacturer of the hose for purposes of NHTSAs regulations. This would include the responsibility to conduct any recall that may become necessary with regard to the hose. LG Cable would also be responsible as it would also be a manufacturer of the hose, since it is the entity that actually fabricates the hose. I hope this information is helpful. If you have any questions, please contact Dorothy Nakama at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel Enclosure ref:106 NCC-112:DNakama:mar::62992:OCC 009244 Cc: NCC-110 Subj/Chron, Docket Std. 106 NCC112:DNakama:mar:62992:OCC#05-009244 cc: NCC-112 Subj/chron, DN NVS-200, NVS-100 rewrittenEG [U:\NCC20\INTERP\106\009244drn-5.doc] Interps: Std. No. 106, Redbook (2) |
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ID: 07-004353--21 Aug 07--rlsOpenMr. Terry Wagar State of New York Department of Motor Vehicles Office of Vehicle Safety and Clean Air 6 Empire State Plaza Albany, NY 12228 Dear Mr. Wagar: This responds to your request for our interpretation of whether A. 4687, a legislative bill proposing to amend Section 375-35 of the New York State Vehicle and Traffic Law, would be preempted by federal law. A. 4687 would amend Section 375-35 to prohibit tires from being manufactured, distributed, offered for sale or sold in New York for use on passenger vehicles, multi-purpose passenger vehicles, or light trucks unless a date of manufacture is clearly molded on both sides of the tire in a non-coded fashion.[1] Based on the information you have provided and the analysis below, we believe that the changes proposed to the Vehicle and Traffic Law by A. 4687, would be preempted by federal law. The National Traffic and Motor Vehicle Safety Act, 49 U.S.C. 30103(b), expressly preempts State standards that differ from Federal motor vehicle safety standards in effect under the Act. Section 30103(b) states in relevant part: When a motor vehicle safety standard is in effect under this chapter, a State or a political subdivision of a State may prescribe or continue in effect a standard applicable to the same aspect of performance of a motor vehicle or motor vehicle equipment only if the standard is identical to the standard prescribed under this chapter. Federal Motor Vehicle Safety Standard No. 139, (FMVSS) New Pneumatic Radial Tires for Light Vehicles (49 CFR 571.139), requires each tire to be labeled in the manner specified in Part 574, Tire Identification and Recordkeeping. S5.5.1 of FMVSS No. 139 states that for tires manufactured before September 1, 2009, Each tire must be labeled with the tire identification number required by 49 CFR part 574 on a sidewall of the tire, and that on the other sidewall, the tire must be labeled with either the tire identification number or a partial tire identification number containing all characters . . . except the date code and, at the discretion of the manufacturer, any optional code. S5.5.1(a). For tires manufactured on or after September 1, 2009, the requirements are similar, except that the full tire identification number is required on the intended outboard sidewall of the tire, unless there is no intended outboard sidewall. S5.5.1(b). Part 574 contains requirements for identifying tire manufacture dates. Under 574.5, Tire identification requirements, tire manufacturers must permanently mold or laser etch into or onto the sidewall of each tire an identification number containing certain information. Among that information is a section with four numerical symbols representing the week and year of manufacture. Section 574.5(d) states in relevant part that: The first two symbols must identify the week of the year by using 01 for the first full calendar week in each year, 02 for the second full calendar week, and so on. The third and fourth symbols must identify the year. Example: 0101 means the 1st week of 2001, or the week beginning Sunday, January 7, 2001 and ending Saturday, January 13, 2001. The language of A. 4687 requiring the date to be molded in a non-coded fashion and on both sides of the tire apparently specifies a labeling scheme that is not identical to that required by FMVSS No. 139. Since the State requirement would not be identical to the Federal requirement, we would consider A. 4687s proposed amendment to Section 375-35 of the New York Vehicle and Traffic Law to be preempted under 49 U.S.C. 30103(b). I hope this information is helpful. If you have any further questions, please do not hesitate to contact Rebecca Schade of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel NCC-112:RSchade:mar:8/21/07:62992:OCC 07-004353 Cc: NCC-110 Subj/Chron S:\INTERP\574\07-004353--21 Aug 07--rls.doc |
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ID: Lewis.2OpenMr. William Heath Lewis Dear Mr. Lewis: This responds to your July 29, 2004, e-mail to George Feygin in which you ask whether your companys products, truck clearance lamps with "clear application" (presumably emitting a white light), meet the requirements of the regulations of the National Highway Traffic Safety Administration (NHTSA) and how you would go about obtaining DOT approval for those products. Your e-mail attached four photographs of trucks that have a series of lamps on the cab roof, immediately above the windshield. As these depicted vehicles are equipped with both clearance lamps and identification lamps, this letter addresses the requirements for both types of lamps. I am pleased to have the opportunity to explain our regulations and to discuss how they may affect your products. By way of background, NHTSA is authorized to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment, nor do we issue permits. Instead, it is the responsibility of manufacturers to certify that their products conform to all applicable safety standards before they can be offered for sale (see 49 CFR Part 571). NHTSA enforces compliance with the standards by inspecting and testing vehicles and equipment, and we also investigate possible safety-related defects. The requirements for lighting equipment are contained in FMVSS No. 108, Lamps, Reflective Devices, and Associated Equipment (see 49 CFR 571.108). The standard sets performance requirements for clearance and identification lamps, including color. Specifically, Table I requires multipurpose passenger vehicles (MPVs), trucks, trailers, and buses that are 80 or more inches in overall width to be equipped with 2 amber clearance lamps and 2 red clearance lamps. Table I also requires those vehicles to be equipped with 3 amber identification lamps and 3 red identification lamps. These lamps must emit amber or red light, respectively. Table II of FMVSS No. 108 specifies location requirements for clearance and identification lamps. Specifically, the standard requires two amber clearance lamps on the front and two red clearance lamps on the rear to indicate the overall width of the vehicle. The clearance lamps must be located, one on each side of the vertical centerline, at the same height, and as far apart as practicable. Table II also requires covered vehicles to be equipped with identification lamps on the front and rear of the vehicle. The standard requires three amber lamps on the front and three red lamps on the rear of the vehicle. The identification lamps are to be located as close as practicable to the top of the vehicle, at the same height, as close as practicable to the vertical centerline, and with lamp centers spaced not less than 6 inches or more than 12 inches apart. Alternatively, the front lamps may be located as close as practicable to the top of the cab. These requirements related to the color of clearance and identification lamps apply to both original equipment and replacement (aftermarket) lighting equipment. Paragraph S5.8.1 of the standard provides that " each lamp, reflective device, or item of associated equipment manufactured to replace any lamp, reflective device, or item of associated equipment on any vehicle to which this standard applies shall be designed to conform to this standard. " In light of the above and based upon the location of the lighting equipment in the photographs accompanying your correspondence, the standard requires your clearance lamps (or identification lamps) to emit amber light. However, we note that manufacturers are not required to use an amber lens to comply with the color requirements for an amber lamp. Rather, they may use any plastic material that complies with the requirements of paragraph S5.1.2, as long as the light emitted from the completed lamp complies with the applicable color requirements. For your further information, I am enclosing a fact sheet we prepared titled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment. I hope you find this information useful. If you have further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman Enclosure |
2004 |
ID: nht88-1.39OpenTYPE: INTERPRETATION-NHTSA DATE: 02/12/88 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Allan J. Lameier -- Defense Electronics Supply Center TITLE: FMVSS INTERPRETATION ATTACHMT: 7/1/80 letter from Frank Berndt to E.C. Elliott TEXT: Mr. Allan J. Lameier Quality Assurance Specialist, Defense Logistics Agency Defense Contract Administration Services Management Area, Dayton C/O Defense Electronics Supply Center Dayton OH 45444 RE: A. Lameier 513-684-3915
This is in response to your letter requesting clarification concerning the classification of a Davey mobile compressor. You state that the manufacturer of the compressor indicates that the wheeled compressor need not comply with Standard No. 108, Lamps, reflective devices and related equipment, because the compressor is not a trailer. Based on the information provided with your letter, we believe that the compressor is not a motor vehicle and is therefore not subject to the requirements of Standard No. 108 or any other Federal motor vehicle safety standards. By way of background, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act: 15 U.S.C. 1381 et seq.) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. The Nati onal Highway Traffic Safety Administration (NHTSA) does not approve motor vehicles or motor vehicle equipment. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its product s meet all applicable safety standards. A "trailer" is defined at 49 CFR 5571.3 as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle." The mobile compressor shown in the brochure enclosed with your letter appea rs to be designed for carrying property (the compressor) and for being drawn by a motor vehicle. The answer to your question of whether this compressor is a trailer, then depends on whether the compressor is a "motor vehicle" within the meaning of the Sa fety Act. Section 102(3) of the Safety Act (15 U.S.C 1391(3)) defines a "motor vehicle" as 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. We have interpreted this language as follows. Vehicles such as forklifts and mobile construction equipment which are sold primarily for off-road use, but which incidentally use the public roads to travel from one job site to another, are not considered m otor vehicles. On the other hand, vehicles which regularly use the public roads and stay off-road for only limited periods of time are motor vehicles and are subject to our safety standards. The agency has previously concluded in a July 1, 1980 letter to Mr. E.C. Elliott (copy enclosed) that his company's portable air compressors were not motor vehicles, based on statements that these devices spend the bulk of their useful lives on construct ion sites and are seldom drawn over public roads by mechanical power. If the Davey portable compressors are used in the same fashion as the compressors discussed in the July 1, 1980 letter, we believe that the Davey compressors were properly classified b y the manufacturer as something other than a "motor vehicle". This means that the Davey compressors are not subject to any of the federal motor vehicle safety standards. I hope this information has been useful. My apologies for the delay in responding to your letter. Sincerely, Erika Z. Jones Chief Counsel Enclosure IN REPLY REFER TO: A. LAMEIER 513-684-3915 SUBJ: APPLICABILITY OF FMVSS #108 TO PORTABLE CONSTRUCTION EQUIPMENT TO: ERIKA Z. JONES 1. Enclosed is a photocopy of a brochure showing a compressor being bought on navy contract DLA-700-86-C-8263. This contract requires compliance with " All Applicable Federal Motor Vehicle Safety Standards (FMVSS) in effect on the Date of manufacture." 2 . Davey Co. insists STD#108 (Lighting and Reflectors) is not applicable because a wheeled compressor is not a "Trailer." 3. Please send me copies of any rulings or opinions which would clarify this requirement. Allan J. Lameier Quality Assurance Specialist Attch 1 Photocopy omitted. |
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ID: nht78-1.3OpenDATE: 12/05/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: U. S. Suzuki Motor Corporation TITLE: FMVSS INTERPRETATION TEXT: NOA-30 Mr. F. Michael Petler Assistant Manager Safety & Legislation Department U.S. Suzuki Motor Corporation P.O. Box 2107 Santa Fe Springs, California 90670 Dear Mr. Petler: This is in response to your letter of August 11, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 127, Speedometers and Odometers. Standard 127 does not specify that the number "0" appear on the face of the speedometer. It is permissible for you to reletter the "0" mph position to read "5" mph, as the lowest measured speed indicated. This would solve the problem you indicate regarding the relationship of the graduation distance between the 0 and 10 mph to that between 10 and 20, 20 and 30, etc. The NHTSA has received petitions for reconsideration requesting that the 10 percent deviation requirement be eliminated. A determination will be made at a later date whether to grant the petitions. Sincerely, Joseph J. Levin, Jr. Chief Counsel August 11, 1978
Joseph J. Levin, Esquire Chief Counsel National Highway Traffic Safety Administration Room 5219 400 7th Street, S.W. Washington, D.C. 20590 Re: Request for interpretation, FMVSS #127, Speedometers and Odometers Dear Mr. Levin, We have been requested by our parent Company, Suzuki Motor Company, Ltd. to request from your agency an interpretation concerning a speedometer faceplate they wish to use. To assist you in understanding our comments we have attached a drawing. I apologize that it is not to the scale of the faceplate. Further, this past July 11, we left a sample faceplate with Mr. Carson of your Crash Avoidance Division, which you might want to examine. Our opinion requests are as follows: Opinion Request No. 1 -- The area we are concerned with is directed to the speed zone indication area of from 0-10 mph. As you will notice, there are two graduations between 0-20 mph. They represent 10 and 15 mph, no 5 mph graduation is shown. Suzuki has determined that movement of the speedometer indicator needle does not begin to travel from the "0" point until the vehicle has reached approximately "5" mph. As you can see, there is relatively little travel area between the 0-10 mph graduations. We recognize that the graduation distance between 0-10 is not the same as the equal graduations from 10 to 80 mph. We were advised that to relocate the 0 position by removing the needle "0" stop pin could result in possible damage to the unit over an extended period of time, therefore we would pre- fer to be able to retain the faceplate as it is, if it is acceptable to your agency. We believe that the 0-10 mph range is not as critical to the safe operation of the vehicle as those speeds above 10 mph are, and for this reason we request relief in the area of 0-10 mph speed graduation requirements. If, however, this faceplate, in its current form, is unacceptable to your agency, we would then request your opinion on another possible solution that we believe we might be able to utilize. Opinion Request No. 2 In reviewing Docket No. 76-06, Notice 5 (F.R.Vol.43, N0.145, 7/27/78, page 32422) we noted your agencies comments regarding "Suppressed zero needle". Our question is, since our needle does not move until the vehicle achieves a speed of 5mph, and by applying the suppressed zero needle approach, would Suzuki be permitted to reletter the "0" mph position to "5" mph, as the lowest measured speed indicated on the face of the speedometer. We again feel that the 5 mph starting position would not be critical to the safe operation of the vehicle.
We would appreciate your review of this faceplate design and interpretation as to whether this faceplate would be acceptable in its current state, Opinion Request No. 1 or Opinion Request No. 2, to meet the requirements effective September 1, 1979. If you are in need of any additional information please feel free to contact us. Thank you for your assistance in this matter. Sincerely, F. Michael Petler Assistant Manager Safety & Legislation Deparpment FMP/ph |
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.