United States Department of TransportationNHTSA 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: aiam1053OpenMr. J. L. Foster, Office Manager, The Procter and Gamble Distributing Company, Post Office Box 60114, New Orleans, LA 70160; Mr. J. L. Foster Office Manager The Procter and Gamble Distributing Company Post Office Box 60114 New Orleans LA 70160; Dear Mr. Foster: This is in response to your request for odometer disclosure form applicable to the State of Florida. The letter appears to be a blanket request for forms from all the states in which you do business.; The Motor Vehicle Information and Cost Savings Act and the accompanyin regulations were purposely made flexible and simple to permit the states and affected transferors maximum latitude in conforming to the Act. In fact, the States have no duties under the Act. Many of the States that you have contacted will probably indicate that no changes will be made to their laws and regulations. Some states may change their Title forms or their disclosure forms to accomodate (sic) the federal statement.; It is the transferor's responsibility to make the required disclosur and again maximum latitude is permitted. No federally-printed form is required nor is one available. A transferor may write his own form, make use of a state form which conveys the same information, or use one of the commercially printed forms now available. So far as the federal requirements are concerned you may use an identical form in all the states. An example of an acceptable format is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4601OpenThe Honorable Harry Reid United States Senate Washington, D.C. 20510; The Honorable Harry Reid United States Senate Washington D.C. 20510; "Dear Senator Reid: Thank you for your letter to the Department o Transportation, on behalf of the City of Sparks, Nevada. That city's police department has received six new patrol cars equipped with air bags. According to the City Attorney for Sparks, the city police cars are often required to push disabled vehicles out of travel lanes of highways and the police officers are afraid that the air bags will be activated during these pushing operations. You asked if the Department of Transportation would authorize the Sparks police department to disconnect the air bags on its patrol cars. I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (the Safety Act) authorizes this agency to issue safety standards applicable to new vehicles and new items of motor vehicle equipment. We have exercised this authority to issue Standard No. 208, Occupant Crash Protection (49 CFR /571.208). Standard No. 208 requires all 1990 model year cars to be equipped with automatic crash protection, and specified percentages of each manufacturer's 1987, 1988, and 1989 model year cars to be so equipped. Chrysler, the manufacturer of the patrol cars in question, has chosen to comply with the requirement for automatic crash protection by installing air bags in these police cars. When a safety standard like Standard No. 208 is in effect and applicable to new passenger cars, the Safety Act prohibits any person from manufacturing, selling or offering for sale, importing, or introducing in interstate commerce any new car that does not comply with the safety standard. However, the Safety Act provides that these prohibitions do not apply after the first purchase of the car 'in good faith for purposes other than resale.' Hence, the Federal requirement that the cars comply with all applicable safety standards ceased to apply when the Sparks city police department purchased these cars, since the police department bought these cars in good faith to use them as police patrol cars, not to resell them. After the first purchase of a car in good faith for purposes other than resale, the Safety Act prohibits any manufacturer, distributor, dealer, or repair business from 'rendering inoperative' any device or element of design installed in the car in compliance with an applicable safety standard. Obviously, disconnecting air bag systems would have that effect. Accordingly, Federal law prohibits any manufacturer, distributor, dealer, or repair shop from disconnecting the air bag systems on the Sparks police department cars. Please note that the Safety Act does not prohibit individual vehicle owners from rendering inoperative safety features on their own vehicles. Hence, the City of Sparks does not need any sort of 'authorization' from this agency to disconnect the air bag systems on the city's police cars. The City of Sparks is permitted to disconnect the air bags on its own vehicles without violating any Federal law, just as any resident of Sparks can remove any safety equipment they like from their own vehicles without violating Federal law. Such removals may, however, violate the laws of the State of Nevada. I recommend that the city carefully consider the effects of disconnecting the air bag systems in its police cars, even though Federal law does not prohibit the city from doing so. The air bags in those cars are an effective means of protecting vehicle occupants in frontal crashes. As to the possibility of inadvertent deployment of air bags in police cars, I note that the agency has entered into a contract under which police cars have been retrofitted with air bag systems, without a single reported instance of an air bag detonation while pushing a disabled vehicle. Enclosed is a report with some additional information on this contract. Particularly since the City of Sparks police officers face the possibility of becoming involved in high speed pursuit situations, we believe those police officers deserve the benefits of automatic crash protection in their police cars. I hope this information is helpful. Please do not hesitate to contact us if you have any further questions or need additional information on this subject. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam1403OpenMr. Robert W. Borgert, Spartan Design Inc., 24151 Telegraph Road, Southfield, MI 48075; Mr. Robert W. Borgert Spartan Design Inc. 24151 Telegraph Road Southfield MI 48075; Dear Mr. Borgert: This is in reply to your letter of January 21, 1974, asking for ou comments on your defect notification letter.; In describing the defect (your third paragraph) as required by Sectio 577.4(c), you should state specifically that the placement of the lamps fails to conform to Federal Motor Vehicle Safety Standard No. 108, and indicate, in general terms, what is the appropriate location. In addition, section 577.4(c) requires the inclusion of precautions the purchaser can take. We believe one precaution that should be included where a lighting problem is concerned is to recommend that night driving be limited as much as possible.; When we have received a corrected copy, we will close our files in thi matter.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam5440OpenMr. C.N. Littler Motor Coach Industries Administrator Regulatory Affairs 1558 Wilson Place Winnipeg, Manitoba R3T 0Y4 CANADA; Mr. C.N. Littler Motor Coach Industries Administrator Regulatory Affairs 1558 Wilson Place Winnipeg Manitoba R3T 0Y4 CANADA; "Dear Mr. Littler: This responds to your letter concerning whether New York State law addressing the in-use stopping ability of privately owned motor coaches is preempted by Federal law. I apologize for the delay in our response. The New York law states that a vehicle must be capable of stopping 'at a rate of deceleration equivalent to a stop within 22.2 feet from a speed of 20 miles per hour.' You believe that 103(d) of the National Traffic and Motor Vehicle Safety Act ('Safety Act') preempts the New York law, since the state law is not identical to Federal motor vehicle safety standard No. 121, Air Brake Systems. Please note that the Safety Act has been codified at 49 U.S.C. 30101 et seq. and that the citation for 103(d) is now 49 U.S.C. 30103. As explained below, Standard No. 121 currently does not have stopping distance requirements in effect, therefore, the New York law is not currently preempted by a Federal safety standard. Nevertheless, the agency has issued a proposal to reinstate stopping distance requirements in Standard No. 121. (58 FR 11003, February 23, 1993). If the agency issues a final rule to reinstate stopping distances, then any more stringent requirements in the New York law (addressing the same aspects of performance as Standard No. 121) would be preempted. Title 49 U.S.C. 30103 states: Whenever a Federal motor vehicle safety standard ... is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard. That provision preempts New York's law if there is a Federal safety standard in effect, the state law covers the same aspect of performance as that Federal standard, and the State law is not identical to the Federal safety standard. While you are correct that Standard No. 121 refers to stopping performance in S5.3.1, you apparently were not aware of a provision in S3 that states Notwithstanding any language to the contrary, sections S5.3.1, S5.3.1.1, S5.3.2, S5.3.2.1, S5.3.2.2, S5.7.1, S5.7.3(a) and S5.7.3(b) of this standard are not applicable to trucks and trailers, and section S5.3.1 of this standard is not applicable to buses. The agency amended the standard to include this provision as the result of a ruling in PACCAR v. NHTSA, 573 F.2d 632, (9th Cir. 1978), cert. denied, 439 U.S. 862 (1978), in which a Federal Court of Appeals invalidated Standard No. 121's stopping distance requirements until the agency obtains 'more probative and convincing data evidencing the reliability and safety of vehicles that are equipped with antilock.' While the provision did not originally cover buses other than school buses, NHTSA extended the provision to non-school buses in 1987. See 52 FR 20602. Because there are no Federal stopping distance requirements in effect, the New York law is not preempted. As noted above, NHTSA has issued a notice proposing to reinstate stopping distance requirements for air braked vehicles. The agency is currently reviewing comments to that proposal, and may issue a final rule reinstating stopping distance requirements. If the agency decides to amend Standard No. 121 to include such requirements, then any more stringent requirements in the New York law (addressing the same aspects of performance as Standard No. 121) would be preempted. I note that the New York law applies to vehicles in use, while Standard No. 121 applies to new vehicles. In general, State laws governing the operation of vehicles are not preempted by inconsistent Federal motor vehicle safety standards unless the State law is more stringent than the Federal standard (with respect to the same aspect of performance). A more stringent law would be preempted, since it would preclude the sale of vehicles that comply with Federal standards. I also note that the in-use braking performance of many motor coaches is regulated by the Federal Highway Administration. We have referred your letter to that agency's Office of Motor Carrier Standards concerning the issue of whether its regulations preempt the New York law. 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. If you wish to contact someone in the Federal Highway Administration's Office of Chief Counsel concerning the motor carrier standards, please call Charles Medalen at (202) 366-1354. Sincerely, John Womack Acting Chief Counsel Enclosure "; |
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ID: aiam2385OpenMr. J. J. Cowley, Imperial Chemical Industries Limited, P.O. Box No. 90, Wilton Middlesborough, Cleveland TS6 8JE, England; Mr. J. J. Cowley Imperial Chemical Industries Limited P.O. Box No. 90 Wilton Middlesborough Cleveland TS6 8JE England; Dear Mr. Cowley: This responds to your July 2, 1976, question whether evaluation of th lubricity of DOT 4 brake fluid by the Society of Automotive Engineers (SAE) modified stroking test (SAE J1703f) is consistent with the requirements of Standard No. 116, *Brake Fluids*.; Standard No. 116 specifies that the stroking properties of DOT 4 brak fluids be tested by use of the apparatus described in SAE Standard J1703b. This is the procedure that would be used in a determination of whether a certain brake fluid conforms to the requirements of Standard No. 116. Section 571.5 of our regulations (49 CFR Part 571) provides that materials subject to change are incorporated into a standard as provided in the standard or, if no indication is made, as of the date of adoption of Part 571. In this case, the standard indicates that J1303b is the version of the SAE practice that has been incorporated.; This does not mean that you cannot use the modified SAE procedure fo purposes of your certification testing. Your obligation as a manufacturer is to ensure that your certification of compliance is not false or misleading in a material respect, and that you have exercised due care in manufacturing to conform to Standard No. 116 (15 U.S.C. S 1397(b) (2)). A manufacturer is not required to follow specifically the test procedures of the standards. Rather, he must ascertain, in the exercise of due care, that his product will conform to the requirements of the standard when it is tested by the stated methods. The NHTSA cannot approve a manufacturer's test procedure as the basis of due care in advance of the actual events that underlie certification.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1950OpenMr. Carl H. Johnson, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. Carl H. Johnson The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Johnson: Please refer to Mr. Ronald W. Mohler's letter of September 6, 1974 (copy enclosed) and Mr. Snyder's telephone conversation with you on January 23, 1975, regarding the transfer of tread code mark 'BFK' from the 'Griffin General Tire Service, Inc.' retread company operated by Mr. James W. Griffin to the 'Griffin General Tire Service' company operated by The General Tire and Rubber Company.; The enclosed copy of the May 17, 1973, letter to Mr. Daniels of th Daniels Tire Service, Inc. company outlines the conditions which must prevail for this company and the 'Griffin General Tire Service, Inc.' company to use the same code mark BFK. With respect to the 'Griffin General Tire Service, Inc.' the various limiting conditions prevailing at that time and which we understand will continued by your acquired company are:; >>>1. Recordkeeping procedures must be internal, i.e., within th specific company.; 2. Production is limited. Mr. Griffin advised us that production i 1973 was approximately five truck tires per day.; 3. The plant serves only local trade in the vicinity of Hornell, Ne York.<<<; Please advise us whether our understanding is correct that thes conditions will be met by the 'Griffin General Tire Service' company operating under the control of The General Tire and Rubber Company. If not, a new code number must be assigned to this plant.; We further wish to advise you that the conditional usage of code mar BFK will not be extended to any future disposition of the 'Griffin General Tire Service' company. To perpetuate the abnormal condition where two retread plants use the same code mark is highly undesirable due to the potential confusion, the extra necessary control effort, as well as the personal supervision required at our computer operation.; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam0642OpenMr. W. G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in response to your letter of February 7, 1972, in which yo discussed some problems that you have encountered with the regulation on vehicles manufactured in two or more stages (49 CFR Part 568), as applied to the school buses of which you are the final-stage manufacturer. Since the receipt of your letter, Mr. Rumph of your company and Mr. Sweet of the Truck Body and Equipment Association met with Mr. Dyson of this office to discuss the issues raised in your letter. Also, on March 8 you sent a sample letter that you proposed to send to your customers.; As we understand the problem from your letter and the subsequen discussion, it is essentially that you are receiving chassis-cowls from school bus buyers, for mounting of your bodies as a final-stage manufacturer, which are inadequate for the purpose according to the gross vehicle and gross axle weight ratings now included with the incomplete vehicles under our multistage vehicle regulations, 49 CFR Part 568. The problem as you describe it appears to have arisen in the negotiation between the school bus buyers and the dealers from whom they bought the incomplete vehicles, in that the dealers sold chassis that were too lightly equipped with tires and axles for the loaded weight implicit in the buyer's specification, under both our certification regulations and accepted industry practice. You state that your company bears the immediate burden of the problem, because you have invested in the production of several dozen bodies whose installation is held up pending resolution of the problem.; From your discussion we assume that all parties are agreed that th bodies that the customers ordered (and you have built) are the ones that are to be used, and that the chassis that have been furnished to you can be economically modified to meet the requirements of our regulations and be safe for their intended use.; With these assumptions, we suggest the following course of action o your part:; 1. Complete each vehicle as planned. 2. Affix a certification label to each vehicle as you normally do stating on the label weight rating figures that will satisfy our regulations (Part 567) and the axle capacity requirements of the vehicle.; 3. Deliver the vehicle, but concurrently send a written statement b certified mail to the vehicle buyer to the effect that the vehicle *must be modified* in order to conform to the GVWR and GAWR figures on the certification label, both for purposes of safety and to conform to Federal regulations. The letter should advise the buyer to take the vehicle to a dealer of the chassis manufacturer for these modifications immediately upon receiving it. The sample letter you sent on March 8 will be satisfactory if you modify the second and third paragraphs to read as follows:; >>>'Federal Regulations 49 CFR Part 567, *Certification*, requires Blu Bird to certify the front and rear gross axle weight rating (GAWR) and the gross vehicle weight rating (GVWR) of completed vehicles, and specifies a minimum GVWR based on seating capacity.; 'Your vehicle may be shipped as it is, however, the values of GAWR an GVWR shown on the certification plate will be contingent on the chassis modifications indicated above. These changes *must*, in the interest of safety, be made before the vehicle is placed into service, and you should take the vehicle to your chassis dealer as soon as you receive it.'<<<; 4. Send copies of each such statement to (a) Office of Standard Enforcement, National Highway Traffic Safety Administration, Washington, D.C. 20590, (b) the manufacturer of the chassis that was delivered to you, and (c) the dealer from whom the buyer ordered the chassis, if any and where known to you.; This procedure is allowed only as to chassis that have already bee received by Blue Bird as of the receipt of this letter, and it should not be viewed as precedent for future action by any other persons. In the future, Blue Bird as the final-stage manufacturer must take responsibility for the vehicle as completed by it, to the extent of its knowledge of relevant facts.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam5010OpenMr. Timothy C. Murphy Chairman, TSEI Engineering Committee (Lights) Transportation Safety Equipment Institute P.O. Box 1638 Englewood Cliffs, NJ 07632-0638; Mr. Timothy C. Murphy Chairman TSEI Engineering Committee (Lights) Transportation Safety Equipment Institute P.O. Box 1638 Englewood Cliffs NJ 07632-0638; "Dear Mr. Murphy: This responds to your letter of April 30. 1992 requesting an interpretation of Motor Vehicle Safety Standard No. 108. You have asked 'whether the lens leg of various lamp assemblies may be included in the calculation' of the minimum effective projected luminous lens area required of certain lamps by Standard No. 108. Specifically, you have enclosed 'Figure 1' which 'shows that the last optic against the lens leg projects light outward beyond the lens leg and yet the light may be beneficial to meeting the twenty degree outward test points for stop, tail, turn lamps.' Accordingly you have concluded 'that this light, though low in intensity due to its distance from the filament, may be significant as far as meeting the photometric requirements of the lamp.' NHTSA adopted a definition of 'effective projected luminous lens area' on May 15, 1990 (55 FR 20158), to mean 'that area of the projection on a plane perpendicular to the lamp axis of that portion of the light-emitting surface that directs light to the photometric test pattern. . . .' No exceptions were made to the definition. In rejecting a petition for reconsideration to include lens parts, such as the rim (or leg), in the calculation of lens area in those instances where the rim transmits unobstructed light, NHTSA explained on December 5, 1990 (55 FR 50182), that areas that do not contribute 'significantly' to light output should not be included in the lens area calculation. It commented that 'the optical parts of the reflector and lens are designed to achieve that purpose', and that 'lens rims or legs do not contribute to the optical design' but instead 'take up surface area that can reduce the area of the optically designed part of the lens if they are allowed to be included in the computation of minimum lens area.' In the comments that both you and we have quoted above, NHTSA has tried to differentiate between optical parts that are specifically designed to contribute to the optical design of a lamp and those whose contribution is only incidental and secondary. Those comments express clearly the agency's opinion that a lens leg, such as shown in your Figure 1, is an optical part that contributes only incidentally to the optical design of a lamp. However, the agency's opinions, as expressed in the preambles on this subject, are not the most definitive answer to your question. Instead, with reference to Figure 1, whether the additional lens area may be included in the computation of the minimum effective projected luminous lens area is determined by the definition of that term set forth in S4 of Standard No. 108. If the lens leg in Figure 1 meets that definition, it may be included in the computation. If not, it may not be included in the computation. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0212OpenMr. Royal Leeman, Project Engineer, FWD Corporation, Clintonville, WI 54929; Mr. Royal Leeman Project Engineer FWD Corporation Clintonville WI 54929; >>>Re: *Petition for Rulemaking*<<< Dear Mr. Leeman: This is in reply to your letter of October 16, 1969, requesting a exception from Paragraph S3.1 of Federal Motor Vehicle Safety Standard No. 205 ('Glazing Materials - Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses'), to allow the use of *Lexan* and *Plexiglas* in certain specified locations in twenty-one (21) fire fighting vehicles to be delivered to the City of New York.; You state the purpose of your request is to provide better protectio for occupants of these fire fighting vehicles from objects thrown at them when, for example, the vehicles are enroute to a fire. Further, you state the use of these materials would eliminate replacing safety glass, which can be broken when hit by small objects. Because you are requesting a change in an existing standard your letter has been treated as a petition for rulemaking to amend Standard No. 205, pursuant to the provisions of 49 CFR SS 353.31, 353.33. For the reasons stated below, your petition is denied.; It is not completely clear from your letter and the enclosed drawin where the interior or canopy partitions in which you wish to use *Lexan* and *Plexiglas* are located. Standard No. 205 presently permits the use of rigid plastics in interior partitions of fire fighting vehicles if these materials meet the requirements for plastics designated AS4 and AS5 (the latter can only be used when not requisite for driving visibility) in American Standards Association Test Z26.1-1966, July 15, 1966. We understand that *Plexiglas* meets these requirements and may therefore be used in this location. We also understand, however, that *Lexan* does not, failing specifically to meet certain chemical and abrasion resistance requirements applicable to AS4 and AS5 rigid plastics under the Standard. If our understanding regarding Lexan is correct, we believe its failure to meet these minimum requirements renders it unsuitable for use in areas of motor vehicles where a possible loss of transparency may affect the safe operation of the vehicle.; With reference to glazing in side and door windows of fire fightin vehicles, Standard No. 205 allows the use of glazing specified AS1, AS2, and AS10 in ASA Test Z26.1-1966 and also allows the use of AS11 and AS3 glazing at levels not requisite for driving visibility. This glazing may be either laminated, tempered, or bullet resistant safety glass meeting the applicable requirements. Plastics meeting AS4 and AS5 requirements, while appropriate for certain locations such as partititions (sic), are not considered appropriate for use in side and door windows as they do not possess chemical and abrasion resistance qualities necessary for exterior glazing and which the types of safety glass specified above possess. The occupant protection which you desire can be provided by using AS10 (and AS11 where appropriate) bullet resistant glass which contains both structural advantages over normally used safety glazing and satisfactory chemical and abrasion resistance for use in side and door windows.; Sincerely, F. C. Turner, Federal Highway Administrator |
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ID: aiam1815OpenMr. A.J. Burgess, Vice President (Technical), Joseph Lucas North America Inc., Two Northfield Plaza, Troy, Michigan 48084; Mr. A.J. Burgess Vice President (Technical) Joseph Lucas North America Inc. Two Northfield Plaza Troy Michigan 48084; "Dear Mr. Burgess: This is in response to your letter o j February 7, 1975, in which you ask whether the control lever/throttle arm of diesel fuel injection equipment is considered part of the pump mechanism or part of the 'linkage,' *i.e.* the accelerator control system, within the meaning of Standard No. 124."; The control lever/throttle is similar to the throttle lever referred t in Docket 69-20, Notice 5 (copy attached). In that notice, we established that the throttle lever is not part of the 'driver-operated accelerator control system', but rather part of the fuel metering device and therefore does not fall within the ambit of Standard No. 124.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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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.