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
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ID: aiam3422OpenMs. Judith I. Robey, Executive Vice President, Devlin Associates, Inc., 1150 First Avenue, Suite 795, King of Prussia, PA 19406; Ms. Judith I. Robey Executive Vice President Devlin Associates Inc. 1150 First Avenue Suite 795 King of Prussia PA 19406; Dear Ms. Robey: This responds to your April 28, 1981, letter asking for informatio relating to the agency's recordkeeping requirements.; I have enclosed copies of the agency's major recordkeeping regulation and portions of one statute that requires the retention of information. This information describes the types of records to be retained and the periods that retention is required. The agency has not specified the form or location for record retention, but it has stated that records must be readily retrievable when necessary. The agency has not imposed a penalty for accidental loss of records. I can see no instance in which a penalty would be imposed for such an accidental loss.; Finally, you ask for any recommendations that we might have wit respect to record retention. We only suggest that records be maintained in an easily accessible manner so that they can be used effectively in removing dangerous vehicles or equipment from the highway. Other than this general recommendation, the actual recordkeeping techniques that a company should use would depend upon the size and sophistication of the company.; If you have any questions concerning any of the materials that I hav provided you, you may contact Roger Tilton of my staff (202-426-9511).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4308OpenMr. Paul Miller, Arizona Bus Sales, Inc., P.O. Box 21226, Phoenix, AZ 85036; Mr. Paul Miller Arizona Bus Sales Inc. P.O. Box 21226 Phoenix AZ 85036; Dear Mr. Miller: This responds to your April 14, 1987 letter to us asking about Federa requirements applicable to the sale of new school buses. You enclosed a copy of a bid from a school bus dealer offering to sell a 48-passenger activity bus to a school district. The bid describes options for changing the school bus paint and deleting 'school options.' You ask whether a bid with 'an option to modify paint, and delete school bus options' accords with our school bus regulations.; The answer to your question depends on the nature of the 'schoo options' which the bid makes nonobligatory. It is unclear from the bid whether the reference is to the school bus performance requirements mandated by our Federal motor vehicle safety standard, or to the way the school bus is painted and marked. If the 'school options' are the features required by Federal school bus safety standards, the answer to your question is no--i.e., the dealer may not sell a new school bus that fails to comply with those standards. On the other hand, Federal law does not prohibit school districts from changing the color or markings of their school buses. Instead, requirements for the identification of school buses are set by each State.; Our agency has two sets of regulations for school buses. The first set issued under the authority of the National Traffic and Motor Vehicle Safety Act, applies to the manufacture and sale of new motor vehicles and includes our motor vehicle safety standards for school buses. Those standards set performance requirements that all new school buses must meet, including standards for passenger crash protection, emergency exits, rollover protection and fuel systems. The Safety Act requires manufacturers of school buses to certify that their vehicles comply with all applicable Federal school bus safety standards. The Act also requires school bus dealers to ensure that only complying school buses are sold. These requirements, set by Federal law, apply to *each* school bus manufacturer and seller.; A school bus dealer cannot elect whether to comply with thos requirements and choose to sell a new activity bus that does not comply with our school bus safety standards.; Our second set of school bus 'regulations,' issued under the Highwa Safety Act, include recommendations for identifying school buses. These recommendations are set forth in Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed). While the 'standard' recommends that activity buses should be painted yellow and marked 'School Bus,' the decision to adopt its recommendations is made by each State. Therefore, questions you might have about activity bus identification should be addressed to your State officials.; I hope this information is helpful. Please contact me if you hav further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3137OpenMr. K. W. Schang, Director, Vehicle Safety Programs, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. K. W. Schang Director Vehicle Safety Programs American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Schang: This responds to your letter of October 11, 1979, requesting ou opinion concerning the proper designated seating capacity of the rear seat in your 1981-model AMC Spirit.; You state that the planned 1981 Spirit rear seat will hav approximately 43 inches of hip room. The amended definition of designated seating position specifies that any position likely to be used as a seating position while the vehicle is in motion will be considered a designated seating position, and includes a caveat that bench or split-bench seats having greater than 50 inches of hip room shall have not less than three designated seating positions. Since the hip room in the rear seat of the 1981 Spirit will be well below the 50-inch caveat in the amended definition, and since you state that the rear seat will be contoured for two persons with distinct recessed areas for each person's buttocks, we conclude that this particular seat would qualify as a two-passenger seat. Under the definition, whether a particular position is 'likely to be used' is determined by the overall seat configuration and design and vehicle design. Given the limited amount of hip room and the configuration of the planned 1981 Spirit rear seat, it is not likely that more than two persons will occupy the seat.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4758OpenMr. Charles T. Thomas Prestige Travel 10333 Richmond Avenue, Suite 170 Houston, Texas 77042; Mr. Charles T. Thomas Prestige Travel 10333 Richmond Avenue Suite 170 Houston Texas 77042; "Dear Mr. Thomas: This is in reply to your recent undated letter askin for a waiver of one of the requirements of 49 CFR 591.5(g) for persons working outside the United States and seeking to import a nonconforming vehicle, i.e., the requirement that 'the importer's assigned place of employment has been outside the United States at all times between October 31, l988, and the date the vehicle is entered into the United States.' You are able to meet the other requirements of paragraph (g), but you returned to the United States in September l988 after a 12-year employment abroad, and your l985 Jaguar remains in Germany. We are sorry that we are unable to provide the waiver you seek. This specific requirement was established by Congress as part of an exception to more rigorous requirements that became effective on, and applicable to, vehicles imported on and after January 31, l990, of this year. Further, Congress did not provide us with any authority to waive this requirement. These provisions were added to the National Traffic and Motor Vehicle Safety Act by the Imported Vehicle Safety Compliance Act of 1988, Public Law 100-562. However, our inability to waive this requirement does not mean that you will be unable to import your car. Under its new authority, the agency has tentatively determined that l985 Jaguar automobiles are eligible for importation (as well as a number of other cars). Public comments on the tentative determinations were due in mid-May. After a final determination is made, and assuming that it is favorable, you may then import your Jaguar pursuant to the requirements of 49 CFR 591.5(f). In other words, you may import the vehicle either through an importer registered with this agency as one who will certify compliance of the Jaguar with Federal safety standards, or by yourself upon demonstration that you have a contract with a registered importer. I enclose a copy of Part 591 for your information, as well as a list of registered importers approved as of April 13. We anticipate a final determination on vehicle eligibility this summer. If you wish to inquire as to the status of the determination, or to obtain an updated list of registered importers, please address your further correspondence to Director, Office of Vehicle Safety Compliance, National Highway Traffic Safety Administration, Washington, D.C. 20590. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam3567OpenMr. J. Mack Shively, Grebe, Bross, Jensen & Peek, P.C., 1530 S.W. Taylor Street, Portland, OR 97205; Mr. J. Mack Shively Grebe Bross Jensen & Peek P.C. 1530 S.W. Taylor Street Portland OR 97205; Dear Mr. Shively: This is in response to your letter of May 11, requesting our views a to the applicability of vehicle identification number requirements and certification label requirements to a semi-trailer to be manufactured by Cranston Diversified Industries. This trailer would have three interchangeable sections.; You are correct in your interpretation of the manner in which ou requirements would be applied to the trailers in question. Only one vehicle identification number and one certification label are required. Affixing the label to the left side of the front section would be consistent with our regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5519OpenMr. Paul Pinoski Project Engineer SLP Engineering, Inc. 1501 Industrial Way North Toms River, NJ 08755; Mr. Paul Pinoski Project Engineer SLP Engineering Inc. 1501 Industrial Way North Toms River NJ 08755; "Dear Mr. Pinoski: This responds to your letter to me in which yo requested an interpretation of the term 'vehicle capacity weight,' as defined in Federal motor vehicle safety standard (FMVSS) No. 110, Tire selection and rims (49 CFR 571.110). I apologize for the delay in our response. FMVSS No. 110 applies to passenger cars. Section S4.3 of the standard requires a placard to be placed on the door of the glove compartment or other accessible place on which shall be displayed, among other things, the 'vehicle capacity weight.' This term is defined in S3 as meaning 'the rated cargo and luggage load plus 150 pounds times the vehicle's designated seating capacity.' You asked how to obtain the 'rated cargo and luggage load,' so that you can calculate vehicle capacity weight. The agency does not define the term 'rated cargo and luggage load' or otherwise regulate how that load is determined. The term simply refers to the vehicle manufacturer's determination of the cargo and luggage carrying capacity of the vehicle. The choice of methodology to be used in making that determination is left to the discretion of the vehicle manufacturer. From a safety standpoint, the important issue is the overall value specified by the vehicle manufacturer as the loaded weight of a vehicle. That value is also known as the gross vehicle weight rating (GVWR). The GVWR informs a vehicle owner how heavily he or she can load a vehicle. The only express regulatory limitation on the GVWR manufacturers may assign to their vehicles is set forth in 49 CFR 567.4(g)(3), which provides that the assigned GVWR 'shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity.' (Emphasis added.) 'Rated cargo load' and 'rated cargo and luggage load' are interchangeable terms. I hope this information is helpful to you. Should you have further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Acting Chief Counsel Enclosure"; |
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ID: aiam2726OpenMr. Michael Flowers, Manager, Electric Products Division, General Engines Company, 591 Montana Boulevard, Jewell, N.J. 08080; Mr. Michael Flowers Manager Electric Products Division General Engines Company 591 Montana Boulevard Jewell N.J. 08080; Dear Mr. Flowers: This is in reply to your letter of November 4, 1977, asking for a interpretation of Federal Motor Vehicles Safety Standard No. 123 *Motorcycle Controls and Displays* as it applies to electricity-powered motor driven cycles that you manufacture.; "Paragraph S5.1 of Standard No. 123 requires each motorcycle to b equipped with a supplemental engine stop control. Your Electroped GX 2000 is operated through a 'uni-control lever' which, when released, turns off the power j source 'thereby acting as an automatic motor stop in the event of an accident.' Your Electroscooter is operated through a twist-grip throttle and when it is released 'the motor is completely off.' You have asked how S5.1 applies to your vehicles."; In our opinion, Standard No. 123 was not drafted wit electricity-powered motorcycles in mind. Unlike a motorcycle powered by an internal combustion engine, the driving force (i.e. current) of an electricity-powered motorcycle is terminated when the force control is released, and no supplemental engine stop control or 'emergency kill button' is required. In other words, S5.1 does not appear to be an appropriate requirements for an electricity-powered vehicle.; however, until Standard 123 can be amended appropriately your vehicle are required to be equipped with the supplemental engine stop control. In other instances where manufacturers have found conflicts between the safety standards and electricity-powered vehicles they have applied for a temporary exemption from such standards.; Work is in progress on your request to be exempted from Standard No 120, and by including your letter and this interpretation to it in the docket, we can include in the *Federal Register* notice a request to be exempted from S5.1 as well. Please confirm that this is acceptable to you.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3834OpenJohn R. Bailen, Esq., Bane, Allison, Saint & Ehlers, P.C., 200 West Front Street, Fifth Floor, Bloomington, IL 61701; John R. Bailen Esq. Bane Allison Saint & Ehlers P.C. 200 West Front Street Fifth Floor Bloomington IL 61701; Dear Mr. Bailen: This responds to your letter to this office asking about th requirements of Federal Motor Vehicle Safety Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). Specifically, you represent a client who will be manufacturing seat covers which would be attached to the seat of the child restraint system. You stated that you had spoken with Mr. Radovich of our Rulemaking Division, and he had indicated his opinion that the only requirements to which these seat covers might be subject would be the flammability requirements. You asked if this is correct, and if any other requirements were applicable, noting a particular interest in whether any labeling requirements might apply to these seat covers. There are no labeling requirements promulgated by this agency applicable to those seat covers. Further, the flammability requirements incorporated in Standard No. 213 are applicable only if your client wishes to have those covers installed on child restraint systems by manufacturers, dealers, distributors, or repair shops.; Standard No. 213 specifies information which must appear on a labe affixed to each child restraint system. However, none of that information relates to the materials used in the seat covers. Hence, Standard No. 213 does not impose any labeling requirements which might be applicable to seat covers for child restraint systems.; Further, Standard No. 213 applies to child restraint systems prior t their first purchase in good faith for purposes other than resale, and not to aftermarket accessories for use with or on the child restraint system. Generally those aftermarket accessories may be added to the child restraint system, even if the addition of those accessories causes the child restraint to no longer comply with Standard No. 213, without violating the requirements of the standard.; This general rule is, however, limited by the application of th provisions of section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (hereinafter 'the Safety Act', 15 U.S.C. 1397(a)(2)(A)). That section specifies: 'No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative...any device or element of design installed on or in...an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard,....' Section S5.7 of Standard No. 213 requires that each material used in a child restraint system conform to the requirements of section S4 of Standard No. 302, *Flammability of Interior Materials* (49 CFR S571.302). If a party were to add a seat cover which did not meet the flammability requirements of Standard No. 302 to a child restraint which was previously certified as meeting those flammability requirements, that act would be interpreted by this agency as rendering inoperative the flammability resistance installed on the child restraint in compliance with an applicable Federal safety standard. If such an act were performed by a manufacturer, dealer, distributor, or repair business, it would be a violation of section 108(a)(2)(A) of the Safety Act, and such a violation would subject the offender to a civil penalty of $1,000 for each violation, as specified in section 109 of the Safety Act (15 U.S.C. 1398).; You should note that the prohibitions in section 108(a)(2)(A) of th Safety Act do not apply to a consumer who renders inoperative some element of design of the child restraint system, and therefore your client's seat cover need not satisfy the flammability requirements for child restraint systems if it is intended to be sold to and installed by consumers. You might wish to inform your client about potential liability under State and common law if the seat covers do not comply with those flammability requirements, in the event those seat covers catch fire.; You may also wish to inform your client about the potentia consequences of an item of motor vehicle equipment which is determined to contain a safety-related defect. Should these seat covers catch fire in situations where seat covers which comply with Standard No. 302 would not catch fire, the non-complying seat covers might well be found to contain a safety-related defect. Sections 151-154 of the Safety Act (15 U.S.C. 1411-1414) require that, when an item of motor vehicle equipment contains a safety-related defect, the manufacturer of the item must recall and repair or replace the defective equipment without charge to the purchaser.; If you have any further questions or need more information on thi subject, please feel free to contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1809OpenMr. Harold D. Shall, Legal Counsel, Dana Corporation, P.O. Box 1000, Toledo, OH 43697; Mr. Harold D. Shall Legal Counsel Dana Corporation P.O. Box 1000 Toledo OH 43697; Dear Mr. Shall: This responds to Dana Corporation's January 1, 1975, question whethe the exception found in S5.3.1(a) and S5.3.2(a) of Standard No. 121, *Air brake systems*, which permits 'controlled lockup of wheels allowed by an antilock system' is available in the case of a wheel which is not 'sensed' by the antilock system through a wheel sensor. You indicate that a statement in our November 1, 1974, letter to Dana Corporation appears to permit the exception for wheels that are not equipped with a antilock valve and logic system.; The answer to this question is no. The statement in our November 12 1974, letter states that 'the manufacturer may choose the number of wheel speed sensors and logic modules that he includes in his antilock system.' This statement simply recognizes that the standard does not require an antilock system, and that the number of wheel speed sensors and logic modules in any antilock system employed by a manufacturer is also not specified.; The standard does require 'no lockup' of any wheel above 10 mph excep 'controlled lockup allowed by an antilock system.' It is clear that a manufacturer who wishes to make use of this exception must provide an antilock system and that it must control lockup at the wheel in question. We pointed out in our November 12, letter that an antilock system would not control lockup of a wheel unless a sensor located on that wheel signaled the logic module of the lockup condition. It would not be sufficient that an antilock system controlled the air available to the wheels' brake system without the ability to sense that wheel's lockup.; To summarize, a manufacturer may choose whether to utilize an antiloc system, and whether to equip each wheel with a sensor. However, a manufacturer must equip each wheel with a sensor in order to take advantage of the controlled lockup exception at that wheel.; Yours truly, James C. Schultz, Acting Chief Counsel |
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ID: aiam5149OpenMr. Marty D. Pope President Wheels 'R' Rollin, Inc. 6702 North Highway 66 Claremore, OK 74017; Mr. Marty D. Pope President Wheels 'R' Rollin Inc. 6702 North Highway 66 Claremore OK 74017; "Dear Mr. Pope: This responds to your February 18, 1993 letter t Walter Myers of this office. You stated in your letter and in telephone conversations with Mr. Myers that your firm obtains used wheels from salvage yards, mostly passenger car wheels, refurbishes them by sandblasting and refinishing them, then sells them to manufacturers of utility trailers. You asked how to 'bring the wheels manufactured before 1977 up to standards' (referring to Federal Motor Vehicle Safety Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars), and whether it is possible to 'stamp the wheels previous to 1977 with a regulation code to approve their usability.' 'Wheels' refers to the wheel rim and the hub to which the rim is attached. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) (Safety Act) to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles (including trailers) and new items of motor vehicle equipment (including tires and wheels). The purpose of Standard 120 is to provide safe operational performance by ensuring that vehicles to which it applies are equipped with tires of adequate size and load rating and with rims of appropriate size and type designation. The standard applies to new trailers, and to rims manufactured on or after August 1, 1977. Violations of any of the standards are punishable by civil fines of up to $1,000 per violation, with a maximum fine of up to $800,000 for a related series of violations. You ask about our requirements for the rims of the wheels you refurbish. The answer depends on whether the rim is intended to be installed on a new trailer or intended as a replacement rim for a used trailer. If the rim is intended for a new trailer, the new trailer manufacturer must certify that the vehicle complies with Standard 120. Standard 120 establishes two requirements for the vehicle. First, S5.1.1 requires that the rims on a new trailer be listed by the manufacturer of the tires mounted on the trailer as suitable for use with those tires. Second, the rims on a new trailer must meet the rim marking requirements of S5.2 of Standard 120. Since the rims you refurbish were originally passenger car rims, they will not have the required markings, regardless of date of manufacture, because Standard 120 does not apply to passenger car rims. Therefore, trailer manufacturers may not install passenger car rims on new trailers unless those rims are marked in accordance with Standard 120. If the rim is intended as a replacement rim on a used trailer, different requirements apply. The rim marking requirements of S5.2 of Standard 120 apply only to new rims manufactured on or after August 1, 1977. Refurbished wheels sold for used trailers are considered used wheels instead of new wheels for purposes of Standard 120, and are thus not subject to the rim marking requirements of the standard. As pointed out above, however, a new or refurbished rim installed on a new trailer must meet the rim selection and marking requirements of Standard 120 (S5.1.1 and S5.2). Relatedly, you ask about marking a used rim with the information required by Standard 120 for new rims. Any rim, new or used, that is installed on a new vehicle must be marked with the 'regulation code' (i.e., the 'DOT' symbol constituting the manufacturer's certification of compliance with Standard 120) and the other information required by the standard. However, a rim manufactured prior to August 1, 1977, that is sold as a replacement rim must not be marked with the DOT symbol. NHTSA has long held that manufacturers may not show the DOT certification on items of motor vehicle equipment to which no Federal motor vehicle safety standard applies. The reason for that decision is that such a certification would be false and misleading to NHTSA and to consumers who might assume that the item was subject to and met a Federal safety standard. Thus, since Standard 120 does not apply to rims manufactured prior to August 1, 1977, such rims cannot now be marked with the DOT symbol. You should also be aware of two other provisions of the Safety Act. The first provision is 108(a)(2)(A), which provides that no manufacturer, distributor, dealer, or motor vehicle repair business may knowingly render inoperative, in whole or in part, any device or element of design installed on or in a new or used motor vehicle or item of motor vehicle equipment in compliance with an applicable FMVSS. This means that a person in these categories cannot remove the label information required by Standard 120 during the refurbishing process. Second, under 151-157 of the Safety Act, manufacturers of motor vehicles and items of motor vehicle equipment (e.g., wheel rims) are responsible for safety- related defects in their products. If a manufacturer or NHTSA determines that a safety-related defect exists, the manufacturer must notify purchasers of the product and remedy the problem free of charge. (This responsibility is borne by the vehicle manufacturer in cases in which a defective wheel rim is installed on a new vehicle by or with the express authorization of that vehicle manufacturer.) A refurbished rim that had been previously damaged (e.g., cracked, bent, or pitted) might not be capable of performing safely while in service. For your further information, I am enclosing a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations and a fact sheet entitled Where to Obtain NHTSA's Safety Standards and Regulations. The pamphlet briefly summarizes each of our Federal motor vehicle safety standards and the fact sheet advises where to obtain the full text of those standards and our other regulations. You may also find helpful the attached fact sheet entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment. We also note that the Occupational Safety and Health Administration (OSHA) has a regulation on the refurbishing of damaged rim components. You can contact OSHA at (202) 219-7202, ATTN: Mr. Richard Sauger, for information about that regulation. I hope this information is will be of assistance to you. Should you have any further questions, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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.