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: aiam3485OpenMr. Richard F. Gordon, President, IPD Co. Inc., 2762 N.E. Broadway, Portland, OR 97232; Mr. Richard F. Gordon President IPD Co. Inc. 2762 N.E. Broadway Portland OR 97232; Dear Mr. Gordon: Secretary Lewis has referred your letter of October 6, 1981, to thi office for reply. You have requested, in essence, a 'waiver' pursuant to the Regulatory Flexibility Act of the requirements of Motor Vehicle Safety Standard No. 108 that vehicle headlamps be of sealed beam construction.; There is no legal way such a request could be implemented through th Regulatory Flexibility Act itself. That Act urges regulatory agencies to use their existing statutory authority to accommodate small businesses where appropriate to do so. Modifications of regulations issued pursuant to the National Traffic and Motor Vehicle Safety Act occur through normal rulemaking procedures conducted in accordance with the Administrative Procedure Act. This agency has no current plan to engage in rulemaking allowing importation and sale in the aftermarket of European-type unsealed headlamps, and has consistently denied petitions for such rulemaking over the last few years. Further, we have no authority to grant exemptions or other waivers to manufacturers or importers of motor vehicle equipment.; However, the agency is always interested in new headlighting ideas, an I enclose a copy of a Notice of Request for Comments which we recently issued, that I think you will find of interest.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4340OpenMr. Hisashi Tsujishita, Chief Co-ordinator, Technical Administration Department, Daihatsu Motor Co., Ltd., 1. Daihatsu- cho, Ikeda City, Osaka Prefecture, JAPAN; Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Department Daihatsu Motor Co. Ltd. 1. Daihatsu- cho Ikeda City Osaka Prefecture JAPAN; Dear Mr. Tsujishita: Thank you for your letter requesting an interpretation of th requirements of three of our safety standards. This letter responds to your question concerning Standard No. 101, *Controls and Displays.* A response to your question concerning Standard 219 was sent to you earlier, and we expect to respond to your question concerning Standard No. 201 shortly.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.; You asked whether Standard No. 101's illumination requirements apply t controls and displays not otherwise regulated by the standard. You quoted section S5.3.3's requirements for the light intensities of informational readout systems and asked whether those requirements apply to the following such items: digital clock using liquid crystals, radio employed digital frequency indicator using liquid crystals, and miscellaneous illuminations for conventional analog clock, cigar lighter, ashtray, and radio control switches, etc., which are lighted only when the headlights or parking light are activated.; I would like to note that Standard No. 101's requirements for ligh intensities were amended in a final rule published in the Federal Register (52 FR 3244) on February 3, 1987. An effective date of March 5, 1987, was adopted for most of the amendments. Subsequently, in response to petitions for reconsideration, NHTSA amended 49 CFR Part 571 to permit compliance with either the earlier version of the standard, reissued as Standard No. 100, or the amended standard until September 1, 1989. 52 FR 7150, March 9, 1987. I have enclosed copies of those notices for your convenience.; In answering your question, I will separately discuss the requirement for vehicles manufactured on or after September 1, 1989, and vehicles manufactured before that date.; *Vehicles manufactured on or after September 1, 1989* Vehicles manufactured on or after September 1, 1989, must meet th requirements of the current version of Standard No. 101. Secton S5.3.5 provides:; >>>S5.3.5 Any source of illuminating within the driver's forward fiel of view which is not used for the controls and displays regulated by this standard, and which is capable of being illuminated while the vehicle is in motion, must have either a variable intensity, a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or a means of being turned off. This requirements shall not apply to buses that are normally operated with the passenger compartment illuminated.<<<; As noted in your letter, the items you listed are not among th controls and displays generally regulated by Standard No. 101. However, if sources of illumination for those items are within the driver's forward field of view and are capable of being illuminated while the vehicle is in motion, they must meet the requirements of section S5.3.5.; *Vehicles manufactured before September 1, 1989* Standard No. 100, i.e. the earlier version of Standard No. 101, applie only to vehicles manufactured before September 1, 1989. The application section of Standard Nos. 100 and 101 make it clear that manufacturers have the option of meeting the requirements of either standard for any control, display or illumination until September 1, 1989. Also, the application section of Standard No. 101 provides that if no requirements are specified in Standard No. 100 for a control, display, or illumination, none need be met as a result of Standard No. 101 for motor vehicles manufactured before September 1, 1989.; Section S5.3.3 of Standard No. 100 provides: >>>Light intensities for controls, gauges, and their identificatio shall be continuously variable from: (a) A position at which either there is no light emitted or the light is barely discernible to a drive who has adapter to dark ambient roadway conditions to (b) a position provided illumination sufficient for the driver to identify the control or display readily under conditions of reduced visibility. Light intensities for informational readout systems shall have at least two values, a higher one for day, and a lower one for nighttime conditions. *The intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable in a manner that complies with this paragraph.* (Emphasis added.)<<<; In considering manufacturer options under Standards No. 100 and 101 for vehicles manufactured before September 1, 1989, the following points should be noted:; >>>(1) Some illumination covered by the highlighted language o Standard No. 100 are not covered by section S5.3.5 of Standard No. 101. An example is a control located in the rear seating area that is illuminated only when the headlights are activated. Since a manufacturer may meet the requirements of either Standard No. 100 or Standard 101 for any illumination and no requirement need be met for such illuminations.; (2) Some illuminations not covered by the highlighted language o Standard No. 100 are covered by section S5.3.5 of Standard No. 101. An example is a clock, located in the driver's forward field of view, which is always illuminated as a result of utilizing light emitting diodes. No requirement need be met for such illuminations (for vehicles manufactured before September 1, 1989).; (3) Some illuminations covered by the highlighted language of Standar No. 100 are also covered by section S5.3.5 of Standard No. 101. For these illuminations, the requirements of section S5.3.5 of Standard No. 101 are more flexible. While the highlighted language of Standard No. 100 provides that such illuminations must, depending on the illumination, be either continuously variable or have at lest two values, one for day and one for night, section S5.3.5 of Standard No. 101 provides three options for all such illuminations. Such illuminations must have either a variable intensity, i.e., at least two levels of intensity, as single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or a means of being turned off.<<<; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1142OpenMr. David J. Humphreys, RVI Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC, 20006; Mr. David J. Humphreys RVI Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: This is in reply to your letter of April 27, 1973, regarding th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to mattress covers. You ask whether 'mattress covers', listed under Paragraph S4.1 of the standard, includes a cover 'that is used generally to enclose a mattress for cleanliness or sanitary purposes *or* only the ticking which encloses the mattress filling or core *or* both items . . .'; We consider that mattress ticking and a cover enclosing a mattress fo sanitary purposes are both 'mattress covers' within the meaning of the standard, and both items must meet the requirements of the standard.; Thank you for sending us the copy of your memorandum, 'Department o Commerce Standards Issued Under the Flammable Fabrics Act.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1457OpenMr. Tatsuo Kato, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood, NJ 07632; Mr. Tatsuo Kato Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood NJ 07632; Dear Mr. Kato: This is in response to your letter of April 5, 1974, requestin interpretations of two sections of Federal Motor Vehicle Safety Standard No. 301 (39 FR 10588).; Your first question was whether dummies are required to be positione at each front outboard seating position even if such dummies are not specified for testing under Standard No. 208. The answer to your question is yes. Standard No. 301 provides for testing with dummies at each front outboard seating position regardless of the Standard No. 208 testing provisions. Where, however, Standard No. 208 specifies additional tests for dummies, such dummies are to be included in the vehicle for Standard No. 301 testing.; Your second question was whether the dummies are to be restrained b belt systems until passive restraint systems become mandatory under Standard No. 208. The answer to this question is no. The dummies are to be restrained for testing under Standard No. 301 only by systems that require no action by the vehicle occupant. Therefore, dummies are not to be restrained during testing by belt systems, but only by the passive means, if any, that are employed in the vehicle.; Thank you for your inquiry. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4655OpenMr. John K. Moody Moody & Moody Enterprises 1027 Lochmont Drive Brandon, FL 33511; Mr. John K. Moody Moody & Moody Enterprises 1027 Lochmont Drive Brandon FL 33511; Dear Mr. Moody: This is in reply to your letter of August 30, l989, t Taylor Vinson of this Office with respect to your forward direction brake application indicator. The device will be available as an aftermarket kit. The two front turn signal lamps are wired to be activated in a steady-burning mode when the brake pedal is depressed. If the turn signals are activated when the brake pedal is depressed, the lamp indicating the direction of the turn will switch from the steady-burning mode to the turn signal mode, while the other turn signal lamp remains steady-burning. This will provide an indication at the front of a motor vehicle as to whether or not the driver is attempting to apply the brakes. You have asked whether vehicles equipped with the device would be in conflict with the existing vehicle lighting standards of this agency. There is no Federal motor vehicle safety standard that applies to aftermarket lighting equipment of the nature that you describe. However, installation of the device would involve modifications to a vehicle certified as meeting the Federal standards, most particularly Standard No. 108, the vehicle lighting standard. Under the National Traffic and Motor Vehicle Safety Act, a vehicle owner may alter his vehicle with impunity, however, modifications to certified vehicles by manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to the restriction that they not render inoperative, in whole or in part, equipment installed pursuant to a Federal motor vehicle safety standard. We have two comments on your device. The first is that you have not described its effect, if any, on the hazard warning system. This system operates through the turn signal lamps, and is activated by a switch that is separate from the turn signal switch. When activated, the hazard warning switch causes the front and rear turn signal lamps to flash. The front turn signal lamps in the hazard warning system, when activated, must flash, even when the brake pedal is applied. If they do not do so when your device is installed, they would be 'inoperative' within the meaning of the prohibition. Our second comment concerns the fact that in the turn signal mode the unused turn signal lamp would continue to be illuminated when the brake pedal is applied. Thus, an observer would see a flashing turn signal and a steady burning one, whereas with an ordinary vehicle, the observer would see only the flashing turn signal. Whether the presence of the steady burning turn signal on the side of the vehicle opposite the flashing turn signal would detract from the effectiveness of the flashing turn signal, and by obscuring its message make it 'partially inoperative', is difficult to judge. Certainly, when a vehicle is signaling a turn, it does not appear necessary to also indicate, to the front, that it is stopping. These remarks also serve as some comments of this Office as to 'safety benefits' that might result from vehicles equipped with your device. Certainly, no standard lighting equipment on vehicles today indicate from the front that the brake pedal is being applied. This is an interesting concept, and we appreciate your interest in enhancing motor vehicle safety. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam3190OpenThe Yokohama Rubber Co., Ltd., Hiratsuka Plant, P. O. box 20, Hiratsuka-shi, Kanagawa-ken 254, Japan; The Yokohama Rubber Co. Ltd. Hiratsuka Plant P. O. box 20 Hiratsuka-shi Kanagawa-ken 254 Japan; Dear Sirs: Your September 10, 1979, letter to our Tire Division has been referre to me for reply, since you are requesting an interpretation of Federal Motor Vehicle Safety Standard No. 119 (49 CFR S 571.119)/ You asked two questions in your letter. First, you asked whether the definition you offered for 'maximum speed' was correct. If it was correct, you stated that the tire could exceed the speed restriction shown o the tire at a lighter load, ad showed how the information could be set forth on the tire. The listing of varying maximum loads at different maximum speeds is not permitted to appear on the tire. Second, you asked if speed restricted tires could specify a speed restriction other than the 35, 50, and 55 mile per hour (mph) restrictions shown in the endurance test schedule of Standard No. 119. The answer to this question is no.; Regarding you first question, you defined a tire's maximum speed as the highest speed at which a tire can carry the maximum single load that is molded on the tire sidewall.' This definition is an acceptable one for tires with a speed restriction listed for them. However, you went on to note that if this definition was acceptable, the a tire could list varying maximum loads at varying maximum speeds. Such a listing is expressly prohibited by the language of Standard No. 119.; S6.5 of Standard No. 119 specifies that each tire subject to th Standard shall be marked with the information that is set forth in the (sic) following paragraphs. Paragraph (d) of S6.5 requires the maximum load rating and corresponding inflation pressures for single load tires, the type of tire about which you are inquiring, to appear as: Max load * * lbs. at * *psi cold. Paragraph (e) of S6.5 requires that a speed restriction on the tire appear only as: max speed * *mph. Hence, a single load tire can be labeled with only one maximum load and only one maximum speed.; Your second question was whether a manufacturer could restrict th speed of a tire subject to Standard No. 119 to a speed other than the three speed restrictions shown in Table III of the Standard. Paragraph S6.1 requires all ties to pass the endurance test requirements of the Standard, and Table II shows the load and speeds to which the tires will be subjected during the endurance test. If the tire being subjected to the endurance test does not qualify for the special speeds and load as one of the three speed restricted tires shown in the table or as a motorcycle tire, the tire would be tested at the speed and load shown under the heading 'All other'. This would mean that the tire's speed restriction would be ignored for purposes of the endurance test, and it would be tested as if it were a non-sped restricted tire. Such conditions, and no tire which fails to pass the endurance test can be sold in the United States. As a practical matter, therefore, speed restrictions other than the three shown in Table III of the Standard are not recognized by this agency.; The three speed restrictions shown in Table III of the Standard wer adopted from descriptions of three types of speed restricted tires sued by the United States tire industry in 1972, when the agency was initially promulgating Standard No. 119. If your company would like to add another speed restriction to those shown in Table III, you should file a petition for rulemaking with this agency requesting an amendment to Standard No. 119.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1007OpenMr. Louis C. Lundstrom,Director, Automotive Safety Engineeri- ng,Environmental Activities Staff,General Motors Corporation,Warren, Michigan 48090; Mr. Louis C. Lundstrom Director Automotive Safety Engineeri- ng Environmental Activities Staff General Motors Corporation Warren Michigan 48090; Dear Mr. Lundstrom:#This is in reply to your request of February 1 1973, for an interpretation of paragraph S5.4.1 of Motor Vehicle Safety Standard No. 105a. You have asked if 'a master cylinder with a dam at the 25 percent capacity level' would meet the requirements of the standard.#The paragraph in question requires a 'reservoir compartment for each service brake subsystem serviced by the master cylinder' with the further requirement that 'loss of fluid from one compartment shall not result in a complete loss if brake fluid from another compartment'. in our view, a master cylinder with a dam at the 25 percent level would be compartmentalized within the meaning of S5.4.1.#Sincerely,Robert L. Carter,Associate Administrator for Motor Vehicle Programs; |
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ID: aiam4205OpenMr. H. Tsujishita, Chief Co-ordinator of Technical Administration Dept., Daihatsu Motor Co., Ltd., 1. Daihatsu-Cho, Ikeda City, Osaka Prefecture, Japan; Mr. H. Tsujishita Chief Co-ordinator of Technical Administration Dept. Daihatsu Motor Co. Ltd. 1. Daihatsu-Cho Ikeda City Osaka Prefecture Japan; Dear Mr. Tsujishita: This responds to your letter requesting an interpretation of several o our standards. First, I would like to apologize for the delay in this response to your letter. I have set forth the responses in the order you asked the questions in your letter.; 1. Standard No. 105, *Hydraulic Brake Systems*. Paragraph S5.2.1 of this standard provides that the parking brak system on a passenger car and some school buses shall be capable of holding the vehicle stationary (*to the limit of traction on the braked wheels*) for 5 minutes in both a forward and reverse direction on a 30 percent grade. You stated that your understanding of this provision was as follows. During the tests to determine compliance with this provision, the axles of the subject vehicle must be locked by the parking brake. Your understanding is that the vehicle is permitted to slide down the 30 percent grade, and would be considered as complying with this provision of Standard No. 105 no matter how it slides as long as the vehicle's axles do not turn. This understanding is correct.; The parenthetical note in section S5.2.1 was included in the standar to address the situation where a particular 30 percent grade might have a low traction coefficient. In this situation, a vehicle might slide down the grade even though its parking brake system had held the vehicle axles locked for the required amount of time. NHTSA did not intend vehicle sliding because of a loss of traction by the tires to be considered a failure of the parking brake system. To make this intent clear, section S5.2.1 specifies that the parking brake system must hold the vehicle stationary only 'to the limit of traction on the braked wheels.' This language allows the standard not to specify the traction coefficient for the 30 percent grade. Since no particular traction coefficient is specified, compliance testing may be conducted on *any* 30 percent grade that satisfies the requirement of S6.9. That section requires that the parking brake test surface be clean, dry, smooth Portland cement concrete.; 2. Standard No. 110, *Tire Selection and Rims*. Paragraph S4.3 of this standard specifies that a placard containin certain safety performance indication shall be permanently affixed to 'the glove compartment door or an equally accessible location.' You asked if the door latch post, the inner surface of the glove compartment box, and the inward-facing surface of the driver's side door would be considered 'equally accessible locations.' Each of these locations could be equally accessible locations.; In several past interpretations, we have explained that locations fo the placard would be considered equally accessible if two conditions were met. These were:; >>>1. The alternative location must result in the placard bein positioned so that the vehicle operator can readily refer to it, and; 2. The alternative location must keep the placard relatively free fro exposure to substances that could destroy the placard or render it illegible.<<<; If you position the placard on any of your three alternative location so that the vehicle operator can easily refer to it and where the placard would be protected from substances that could destroy it, we would consider each of those alternative locations as 'equally accessible locations' for the purposes of Standard No. 110.; 3. Standard No. 302, *Flammability of Interior Materials*. Paragraph S4.1 of Standard No. 302 sets forth a listing of th components of vehicle occupant compartments that must be certified as complying with the flammability resistance requirements of paragraph S4.3. You listed nine components not specifically listed in paragraph S4.1 and asked whether those components were required to be certified as meeting the flammability resistance requirements. The answer to your question depends on whether the components are designed to absorb energy on contact by occupants in the event of a crash.; Paragraph S4.1 represents a complete listing of all components in ne vehicles that must comply with the flammability resistance requirements. Any component not identified in paragraph S4.1 is not subject to the flammability resistance requirements. The only item on that listing that might be applicable to the nine components about which you asked is 'any other interior materials, including padding and crash- deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.' Thus, you must determine which of the nine components you asked about are so designed. We would assume that knee bolsters are designed to absorb energy on contact by occupants in the event of a crash. These and any other of the nine components so designed must be certified as complying with the flammability requirements of Standard No. 302. Any of the nine components not designed to absorb energy are not required to comply with the flammability requirements.; 4. Part 575.101. *Consumer Information Regulations, Vehicle Stoppin Distance*.; You noted that S575.101 requires vehicle manufacturers to disseminat information about the minimum stopping distance for groups of passenger cars. Section 575.101(c) requires that each passenger car in the group to which the stopping distance information applies shall be capable of performing at least as well as the information indicates, *under the test conditions and procedures specified in S6 and S7 of Standard No. 105. This specification was added in an amendment published on January 6, 1976 (41 FR 1066). Before that amendment, S575.101 had specified separate test conditions and procedures for the stopping distance information. Those conditions specified that the vehicle's brakes were to be burnished and then the stopping distance was to be measured. In place of those conditions, S575.101(c) now specifies that the stopping distance information should express the *minimum* stopping distances that can be met or exceeded by each vehicle in the group to which the information applies, using the test conditions and procedures of Standard No. 105. Since stopping distances decrease after burnish, the post-burnish results represent the *minimum* stopping distances that can be met or exceeded by the vehicles. Therefore, the pre-burnish stopping distances need not be reflected in the stopping distance information manufacturers make available to consumers.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0246OpenMr. Fred C. Zimmer, Evans, Gentithes and Meermans, 220 East Market Street, Warren, Ohio 44481; Mr. Fred C. Zimmer Evans Gentithes and Meermans 220 East Market Street Warren Ohio 44481; Dear Mr. Zimmer: Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 15 USC 1381 et. seq., the National Highway Safety Bureau issued Federal Motor Vehicle Safety Standard 109 (FMVSS-109). This standard set forth strength, bead unseating, endurance, high speed and labeling requirements for passenger car tires manufactured on or after January 1, 1968, for use on cars manufactured after 1948. This standard does not apply to other types of tires. A copy of FMVSS-109 is enclosed. A manufacturer self-certifies that the tire meets the minimum requirements of the standard by molding the symbol 'DOT' into the tire. Subsequent identification of the tire as a 'second' would not negate the certification.; The National Highway Safety Bureau is currently testing many bran /size tires to verify their conformance to Federal Motor Vehicle Safety Standard No. 109. The tests are conducted at independent laboratories under contract to the Government. Results of these tests are released to the public in a monthly summary.; The test results does not reflect the Bureau's position on the matter Favorable test results should not be interpreted as necessarily establishing that a specific tire is in conformity with the standard, similarly, unfavorable test results should not be interpreted as establishing nonconformance.; Copies of individual test reports con be obtained, for a fee of $3.0 per publication, from the Clearinghouse for Federal Scientific and Technical Information, Springfield, Virginia 22151. Should sufficient data be left remaining on the tire in question for proper identification you may wish to avail yourself of this service.; There is an organization which could possibly furnish you with the nam of an individual capable of analyzing the causes of tire failures. Their name and address is: America Council of Independent Laboratories, Incorporated. 1714 West Capitol Avenue, Houston, Texas 77007.; I trust this information will be useful to you, and I appreciate thi opportunity to be of assistance.; Sincerely, Francis Armstrong, Director, Office of Compliance, Moto Vehicle Programs; |
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ID: aiam2781OpenF. W. Flowers, Jr., General Engines Co., Inc., Interstate 295, Thorofare, NJ 08086; F. W. Flowers Jr. General Engines Co. Inc. Interstate 295 Thorofare NJ 08086; Dear Mr. Flowers: This responds to your January 13, 1978, letter asking whether prior t September of 1976, the National Highway Traffic Safety Administration (NHTSA) required the GAWR determination to be based upon an 'unrestricted' speed of 60 miles per hour.; The NHTSA requires that a vehicle's GAWR be based upon an unqualifie speed of 60 miles per hour. This GAWR computation is then inserted on a vehicle's certification plate by the manufacturer to inform users of the safe GAWR. However, it is permissible to then list at the bottom of a certification plate different GAWR's based upon reduced speeds. If you intended one of your vehicles to operate under a reduced speed with a higher GAWR, you should have marked the correct GAWR on the certification label computed at 60 miles per hour and listed the higher GAWR's for the reduced speeds at the bottom of the plate.; The 1976 amendment to which you refer, Standard No. 120, continues t require the same approach to GAWR as has been the agency's practice for many years. The only difference incorporated by the 1976 amendment is that those vehicles that are unable to attain speeds of 50 miles per hour in 2 miles need not base their determination on the 60 miles per hour figure. These vehicles may compute their GAWR's at a reduced speed. Nonetheless, they are still permitted to list at the bottom of the certification plate higher GAWR's for further reduced speeds.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.