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 |
|---|---|
ID: aiam3379OpenMr. B. G. Ridgway, Chief Car Safety and Regulation Engineer, Rolls-Royce Motors Ltd., Car Division, Crew, Cheshire CW1 3PL, England; Mr. B. G. Ridgway Chief Car Safety and Regulation Engineer Rolls-Royce Motors Ltd. Car Division Crew Cheshire CW1 3PL England; Dear Mr. Ridgway: This responds to your letter concerning the labeling requirements o Standard No. 105 applicable to a separate indicator lamp concerning reservoir level. Your letter asked whether it is permissible to use words other than 'Brake Fluid' for vehicles which use hydraulic system mineral oil rather than conventional brake fluid. As explained below, the answer is yes.; Section S5.3.5 of Standard No. 105 states in relevant part: >>>...If separate indicator lamps are used for one or more of th various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word 'Brake' and appropriate additional labeling (use 'Brake Pressure,' 'Brake Fluid' for S5.3.1(a) and S5.3.1(b) except that if a separate parking indicator lamp is provided, the single word 'Park' may be used....<<<; As your letter pointed out, conventional brake fluid and hydrauli system mineral oil are not compatible. Safety Standard No. 116, *Motor Vehicle Brake Fluids*, differentiates between 'brake fluid' and hydraulic system mineral oil.'; We interpret section S5.3.5 to require the use of the words 'Brak Fluid' only for vehicles which use conventional brake fluid. The section's use of the word 'appropriate, ' prior to its statement that 'Brake Fluid' be used for S5.3.1(b), indicates that the labeling set forth in the parentheses need only be used where it adequately describes the fluid being used. For vehicles which use hydraulic system mineral oil, or other types of non-conventional brake fluid which might be developed in the future, the general requirement for the word 'Brake' and appropriate additional labeling is applicable.; We are concerned, however, about your proposed use of the words BRAK HSMO/LHM, since we doubt that many persons would understand that HSMO/LHM is an abbreviation for hydraulic system mineral oil/liquide hydraulique minerale. We suggest that you consider using the words 'BRAKE MINERAL OIL' or similar language that more persons would understand.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam4146OpenThe Honorable Harold Rogers, U.S. House of Representatives, Washington, DC 20515; The Honorable Harold Rogers U.S. House of Representatives Washington DC 20515; Dear Mr. Rogers: Thank you for your letter on your constituent's behalf to former Chie Counsel Frank Berndt asking several specific questions about our motor vehicle safety standards for school buses. I hope this information is helpful to you in responding to your constituent. If you or your constituent need further clarification about how our requirements apply in a specific situation, please let me know.; Your questions were as follows: >>>1. Can a vehicle designed, manufactured, and sold as a truck, eve be considered a 'school bus' unless remanufactured, modified, or converted by a manufacturer or a manufacturer's dealer or distributor and certified as a school bus?<<<; The answer to your question depends on whether you are asking about vehicle being considered a 'school bus' under State or Federal law. Under Federal law, which applies to the manufacture and sale of new motor vehicles, the answer is no. A vehicle is certified only once, when manufactured as a new vehicle. With the one exception discussed below, there is no provision in our statutes or regulations for recertification of a used vehicle which has been modified so that it falls into a different category of vehicles. The National Traffic and Motor Vehicle Safety Act and regulations issued thereunder require manufacturers to classify their new motor vehicles and certify that their vehicles meet all Federal motor vehicle safety standards applicable to the vehicle type. Those determinations are only made by the manufacturer at the time the vehicle is originally manufactured. Since both the physical attributes underlying the vehicle types and the applicable safety requirements differ from type to type, a vehicle can be classified only as a single type. Therefore, a new vehicle manufactured and sold as a 'truck' is certified as meeting our safety standards for trucks and cannot be certified also as a vehicle meeting safety standards for school buses.; Our regulations do not prohibit used trucks from being modified fo pupil transportation purposes. Since our certification requirements apply only to the manufacture or alteration of new motor vehicles, the person performing the modification does not recertify the vehicle as a 'school bus' unless the modification of the vehicle is so extensive as to constitute a manufacture of a new vehicle. For example, a used truck chassis lacking requisite systems required by our regulations might be combined with a new school bus body. The completed school bus would be considered newly manufactured, and would have to be certified as a 'school bus.'; Used trucks which have been modified to carry school children might b considered 'school buses' under State law. State definitions of school buses determine the applicability of school bus operational requirements to vehicles. If the modifications to a truck bring it within a State's definition of 'school bus,' then the vehicle would be considered a school bus under State law and would have to comply with State requirements for school buses in order to be properly used as a school bus in that State.; >>>2. Do Federal Motor Vehicle Safety Standards apply only t manufacturers, their dealers and distributors?<<<; The answer to your question is no, because our motor vehicle safet standards apply to anyone who manufactures, distributes or sells new motor vehicles. Federal law requires manufacturers of new school buses to certify that their vehicles comply with all applicable school bus safety standards. In addition, distributors and sellers of new school buses must ensure that only complying school buses are sold. While new school buses are typically sold by their manufacturers or manufacturers' distributors and dealers, the responsibility to sell complying school buses rests with any person selling new school buses.; The Vehicle Safety Act applies also to persons who perfor manufacturing operations on previously certified *new* vehicles prior to the vehicles' first purchase in good faith for purposes other than resale.; Such persons are considered 'alterers' under our regulations and ar subject to requirements that they certify compliance with Federal Motor Vehicle Safety Standards. Alterers who significantly affect the configuration of a new motor vehicle previously certified to applicable safety standards must certify that the new vehicle, as altered, conforms to all applicable safety standards affected by the alteration in effect on the date of manufacture of the original vehicle or on the date the alterations were completed.; In addition, the Vehicle Safety Act applies to commercial businesse performing operations on *new and used* motor vehicles. Section 108(a)(2)(A) of the Vehicle Safety Act (copy enclosed) states, in part:>>>No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .<<<; Thus, the requirements of our motor vehicle safety standards affec those aforementioned parties modifying or repairing new or used motor vehicles, by setting limits on the operations performed on those vehicles. Those persons are prohibited from either removing, disconnecting or degrading the performance of safety equipment installed in compliance with an applicable safety standard. There is no prohibition against an individual owner modifying his or her own vehicle.; >>>3. What is the difference between a tamperer and a modifier as the relate to Federal Motor Vehicle Safety Standards?<<<; Our regulations do not define the terms 'modifier' and 'tamperer. However, the terms are commonly used to describe persons who make changes to vehicles. The term 'modifier' is often used to describe persons making changes to new or used vehicles. As explained above, persons modifying a new motor vehicle prior to its first purchase are considered 'alterers' under our regulations and are subject to requirements that they recertify the vehicle. Commercial parties involved with modifying new or used vehicles are subject also to the 'render inoperative' prohibitions of Section 108(a)(2)(A).; 'Tamperers' often refer to persons modifying or removing safety system or equipment on used vehicles. Commercial parties involved in tampering are subject to the 'render inoperative' prohibitions of Section 108(a)(2)(A). Violations of section 108(a)(2)(A) are punishable by civil penalties up to $1,000 per violation. Again, our regulations do not apply to individual owners modifying their own vehicles. Such modifications, however, would have to comply with State law.; >>>4. Who can make the certification that a vehicle meets applicabl Federal Motor Vehicle Safety Standards?<<<; Under the Vehicle Safety Act, manufacturers of new motor vehicle certify that their vehicles comply with all applicable motor vehicle safety standards. As suggested above, 'alterers' are considered to be motor vehicle manufacturers and therefore are also subject to certification requirements. Alterers certify that the vehicle, as altered, conforms to applicable safety standards affected by the alteration.; >>>5. Does the date of manufacture of a vehicle determine the specifi Federal Motor Vehicle Safety Standards that the vehicle has to meet?<<<; In general, the answer to this question is yes. The date of manufactur is one factor determining applicability of our motor vehicle safety standards. Each motor vehicle manufactured on or after the effective date of a safety standard is subject to requirements of that standard if, of course, the standard applies to that vehicle type. However, as explained above, 'alterers' affecting compliance with Federal safety standards by their alteration may choose the completion date of the alterations as the date by which to certify.; >>>6. Are passenger restraint systems required on school buses with manufacture date prior to April 1, 1977?<<<; In 1974, Congress directed NHTSA to issue motor vehicle safet standards for various aspects of school bus safety. Pursuant to that mandate, we issued Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which requires school buses to provide a passenger restraint system through a concept called 'compartmentalization.' The standard became effective on April 1, 1977, and applies to each school bus manufactured on or after that date. School buses manufactured prior to April 1, 1977, are not subject to compartmentalization requirements.; >>>7. Are there any Federal Motor Vehicle Safety Standards applicabl only to school buses prior to April 1, 1977?<<<; The answer is no. There are three safety standards that we issue exclusively for school buses, i.e., Standards No. 220, *School Bus Rollover Protection*, No. 221, *School Bus Body Joint Strength*, and No. 222, *School Bus Passenger Seating and Crash Protection*. Those standards became effective April 1, 1977.; >>>8. Do school buses manufactured prior to April 1, 1977, have to mee FMVSS No. 217 and FMVSS No. 222?<<<; Standard No. 217 became effective September 1, 1973. School buse manufactured on or after that date and prior to April 1, 1977, had to meet Standard No. 217 *if* push- out windows or other emergency exits were provided. Pursuant to the 1974 Congressional mandate, NHTSA amended Standard No. 217 to require school buses manufactured on or after April 1, 1977, to contain additional emergency exits and set special requirements for those exits.; Standard No. 222 became effective on April 1, 1977. School buse manufactured prior to that date do not have to meet that standard.; Again, please contact my office if you or your constituent have an further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam3683OpenMr. Richard H. Attenhofer, Technical Manager, O.E., Dunlop Tire Company, Box 1109, Buffalo, NY 14240; Mr. Richard H. Attenhofer Technical Manager O.E. Dunlop Tire Company Box 1109 Buffalo NY 14240; Dear Attenhofer: This responds to your recent letter to Mr. Kratzke of my staff requesting an interpretation of 49 CFR Part 574, *Tire Identification and Recordkeeping*. Specifically, you asked if Dunlop could use a print type called OCR-A for the DOT symbol and the tire identification number.; Note 1 to Figure 1 of Part 574 specifies only four different prin types which may be used for the DOT symbol and identification number, none of which are OCR-A. However, Note 4 to Figure 1 states that other print type will be permitted if approved by this agency. We have examined the print type shown in the diagram attached to your letter and have no objections to your company printing the required information in OCR-A type.; In the final rule establishing Part 574 (35 FR 17257, November 10 1970), the agency explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The OCR-A print type shown in the diagram attached to your letter is easily readable and thus satisfies our concerns in that regard. Accordingly, that print type is hereby approved.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam2991OpenMr. Kei Matsui, Manager, Development Administration Division, Toyo Kogyo C., Ltd., P.O. Box 18, Hiroshima, 730-91 JAPAN; Mr. Kei Matsui Manager Development Administration Division Toyo Kogyo C. Ltd. P.O. Box 18 Hiroshima 730-91 JAPAN; Dear Mr. Matsui: This is in response to your letter of February 2, 1979, requestin confirmation that all three of the speedometer faces shown on the attached sheet comply with the requirements of Federal Motor Vehicle Safety Standard No. 127. There is no requirements that a specific lower limit appear on the face of the speedometer, either by number or by markings. Your interpretation is, therefore, correct.; Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam2138OpenMr. Robert L. Webber, Vice President, American Sports Co. Inc., P. O. Box 5603, 2970 East Maria Street, Compton, CA 90221; Mr. Robert L. Webber Vice President American Sports Co. Inc. P. O. Box 5603 2970 East Maria Street Compton CA 90221; Dear Mr. Webber: This is in response to your request of November 21, 1975, for a opinion regarding requirements for certifying universal sized helmets pursuant to Federal Motor Vehicle Safety Standard No. 218.; The requirements of Standard No. 218, *Motorcycle Helmets*, apply t helmets that fit headform size C. This includes the case where, by means of an adjusting mechanism supplied by the manufacturer for the purpose of permitting adjustment to headform size C, the helmet can readily be made to fit headform size C. Thus, any helmet that the manufacturer intends for use by persons with heads in the size C range must meet the requirements of the standard, including the requirement to affix the label required by section 5.6.1 of the standard.; The 'universal' helmet described in your letter seems to fall withi these guidelines in that it is intended to fit, *inter* *alia*, the size C headform. Therefore, notwithstanding the fact that it may also be adjusted to fit other size headforms, it should meet the requirements of FMVSS No. 218, including the labeling requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0105OpenMr. Harry G. Seitz, Driver Education Coordinator, Cleveland Public Schools, 1380 East Sixth Street, Cleveland, OH 44114; Mr. Harry G. Seitz Driver Education Coordinator Cleveland Public Schools 1380 East Sixth Street Cleveland OH 44114; Dear Mr. Seitz: Your letter of July 3, 1968, addressed to Mr. George C. Nield, of th National Highway Safety Bureau has been forwarded to my office for reply.; The installation of dual controls on driver education cars is not *pe se* in violation of the Federal motor vehicle safety standards. However, the secondary equipment must meet the same safety standards established for the primary controls. The secondary steering column must fulfill the same requirements made for the primary column as set forth in Federal Motor Vehicle Safety Standards Nos. 203 and 204. The installation of an additional foot brake must not affect compliance with Standard No. 105. However, duplicate compliance with the control location and identification requirements of Standard No. 101 is not required since the 'driver' of such a vehicle remains the person seated behind the primary controls. For the same reason the 'driver' mirror requirements of Standard No. 111 apply only with respect to the person seated at the primary controls.; Changes may be made to original equipment when necessary fo installation of secondary controls but none of the standards requirements specified may be eliminated or adversely affected by the alteration.; You may make available copies of this letter to dealers and intereste parties.; Sincerely, Eugene B., Laskin, Acting Director, Office of Standard Preparation; |
|
ID: aiam5307OpenMr. Carl Haywood Operations Manager Emergency Response Specialists 2251 Happy Top Road Morris, Alabama 35116; Mr. Carl Haywood Operations Manager Emergency Response Specialists 2251 Happy Top Road Morris Alabama 35116; "Dear Mr. Haywood: This responds to your letter of December 21, 1993 requesting information about seating requirements for emergency response units you are designing to respond to chemical spills. The response units are tractor trailer combinations which can be driven in and out of the cargo bay of C-130 Hercules aircraft which are used to transport the units to the site. You further describe the response units as follows: Our response units are designed to transport all six (6) of our response team members, for over the highway transportation three (3) of our team members will ride in the tractor and the remaining three (3) will ride in the trailer. During air transportation all six (6) team members will ride in the trailer. By providing seating with lap and shoulder restraints in the response unit for both ground and air transportation we eliminate the need for special crew cabins for air transportation, and extra vehicles for ground transportation. This conserves the limited space available on the C-130 allowing us to carry all the equipment needed to respond effectively to large scale chemical releases. You requested information on the regulation of the seating in the response units. You have already contacted several Department of Transportation agencies, including the Federal Aviation Administration. I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. Our agency is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act), to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. The Safety Act defines the term 'motor vehicle' as follows: any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. If a vehicle is a 'motor vehicle' under the definition, then the vehicle must comply will all applicable safety standards, including those related to seating and occupant restraint. However, if a vehicle is not a motor vehicle under this definition, then the vehicle need not comply with the agency's safety standards because such a vehicle is outside the agency's scope of authority. Applying this definition to the response units, NHTSA believes the response units are motor vehicles within the meaning of the Safety Act. In determining whether a vehicle which has both on-road and off-road uses is a motor vehicle, the agency looks at whether the vehicle uses public roads on a necessary and recurring basis. Applying this criteria to the response units, we believe that the response units have a primary function of highway transportation of personnel and equipment to the chemical spill site. NHTSA's safety standards specify different requirements for different types of motor vehicles. Therefore, in order to determine the occupant seating requirements for the response units, it is necessary to determine how these vehicles are classified under our regulations. NHTSA defines a 'truck' as 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment.' The tractor portion of the response unit has seating capacity for at least three passengers, but its primary use appears to be to draw the trailer. Therefore, it appears that this vehicle is a 'truck' for the purpose of Federal regulations. NHTSA defines a 'trailer' as 'a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle.' NHTSA believes the trailer portion of the response units would be considered trailers for the purpose of Federal regulations. NHTSA has exercised its authority under the Safety Act to issue four safety standards relevant to occupant seating and restraint: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, and Standard No. 210, Seat Belt Assembly Anchorages. Standard No. 207 establishes strength and other performance requirements for all 'occupant seats' in passenger cars, multipurpose passenger vehicles, and trucks, and for the driver's seats in buses, except that the requirements do not apply to side-facing seats. Therefore, all 'occupant seats' in tractor portion of the response units must meet the requirements of Standard No. 207. Standard No. 207 does not apply to trailers, therefore, the seats in the trailer portion of the response units are not subject to the requirements of Standard No. 207. Standard No. 208 specifies occupant protection requirements based on vehicle type and seating position within the vehicle. Different requirements also apply depending on the GVWR of the vehicle. The discussion which follows is limited to vehicles with a GVWR greater than 10,000 pounds. As explained below, trucks are required to have, at a minimum, a lap belt at every designated seating position. As with Standard No. 207, Standard No. 208 does not apply to trailers. Therefore, the seats in the trailer portion of the response units are not required to have any type of safety belt at any seating position. The requirements for trucks with a GVWR of 10,000 pounds or more are contained in section S4.3 of Standard No. 208. Vehicle manufacturers have a choice of two options for providing occupant crash protection in trucks manufactured on or after September 1, 1990. Option 1 requires vehicle manufacturers to provide an automatic protection system at all seating positions that meets the frontal and lateral crash protection and rollover requirements. Option 2 requires vehicle manufacturers to install lap or lap/shoulder belts at every seating position. If a manufacturer chooses to comply with Option 2, the lap belt or pelvic portion of a lap/shoulder belt must have either an emergency locking retractor or an automatic locking retractor. Standard No. 209 sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. This standard applies to all seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. Thus, if seat belts are voluntarily installed at the seats in the trailer portion of the response units, the seat belts would be required to be comply with Standard No. 209. Standard No. 210 establishes strength and location requirements for seat belt anchorages installed in vehicles, where seat belts are required by Standard No. 208. Therefore, anchorages are required for the lap belts in the tractor, but are not required in the trailer. Although all of the safety standards cited in this letter do not apply to each seating position in your proposed emergency response unit, the agency nevertheless encourages additional consideration and application of those performance requirements that are appropriate to a safe design. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
|
ID: aiam2568OpenHonorable John W. Wydler, House of Representatives, Washington, DC 20515; Honorable John W. Wydler House of Representatives Washington DC 20515; Dear Mr. Wydler: Thank you for your letter of April 21, 1977, requesting informatio concerning Federal regulations regarding school bus safety on behalf of your constituent, Mrs. Peter Peugeot of Rockville Centre, New York.; I have enclosed a document, 'Summary Description of Motor Vehicl Safety Standards Applicable to Buses,' which should be helpful to Mrs. Peugeot. I have also enclosed an information summary, 'Where to Obtain Motor Vehicle Safety Standards and Regulations,' along with a set of forms from our Technical Reference Branch indicating how specific information may be retrieved through computer assisted literature searches along with an outline of fees for this service.; In addition to the above material, I have enclosed an order form fo the entire set of Federal motor vehicle safety standards and regulations, in case Mrs. Peugeot desires this specific volume. I would call her attention to the fact that although this document is relatively expensive, it is furnished in looseleaf form and is updated periodically for an indefinite period with the latest amendments and changes at no additional cost.; I trust this information and material will be of value to Mrs. Peugeot If I can be of further assistance, please do not hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
|
ID: aiam0555OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, Ohio 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati Ohio 45202; Dear Mr. Pieratt: This is in reply to your letters of September 25 and October 19, 1972 In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the regulations therefore apply to them.; Your letter of October 19 asks whether a person who installs a fift wheel in a pickup truck is considered a 'remanufacturer.' Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22800, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2092OpenMr. Richard L. Kreutziger, Coach and Equipment Sales Corp., P.O. Box 36, Penn Yan, NY 14527; Mr. Richard L. Kreutziger Coach and Equipment Sales Corp. P.O. Box 36 Penn Yan NY 14527; Dear Mr. Kreutziger: This is in response to your letter of July 30, 1975, to Mr. Schwartz o this office, seeking an interpretation of Federal Motor Vehicle Safety Standard No. 205.; FMVSS No. 205 requires that the prime glazing manufacturer certify eac piece of glazing covered by the standard by marking it with the letters DOT, the manufacturers code mark assigned by the Department of Transportation and the markings required by section 6 of A.N.S.Z-26. The latter markings are the 'AS' number, the model number and the manufacturer's distinctive designation or trademark. The distributor who cuts a section of glazing material to which the standard applies is required to mark the material in accordance with section 6 of A.N.S.Z-26. Thus, each of the rectangular lites should be marked with the manufacturer's model number and trademark in addition to the AS number, but not with the letters DOT or the prime glazing manufacturer's DOT number.; Section 114 of the National Traffic and Motor Vehicle Safety Act o 1966 requires that you, as the vehicle manufacturer, certify that your product conforms to all applicable Federal motor vehicle safety standards. This would, of course, include FMVSS No. 205.; I hope I have fully answered your questions. If you have any furthe need for information please do not hesitate to write.; Sincerely, Frank A. Berndt, Acting 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.