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: nht92-2.29OpenDATE: 11/16/92 FROM: DONALD RAY MCCRAY -- 620694, DARRINGTON UNIT TO: ANDREW H. CARD -- SECRETARY OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 2-9-93 FROM JOHN WOMACK TO DONALD RAY MCCRAY (A40; STD. 207) TEXT: MY NAME IS DONALD RAY MCCRAY, I HOPE THIS LETTER FINE YOU WITH A LITTLE TIME TO READ AND UNDERSTAND WHY THIS LETTER HAVE BEEN ADDRESS, TO-WIT IN MAKING YOU AWARE OF THE VIOLATION AND BRAKING OF STATE AND FEDEROL LAW: BY THE TEXAS DEPARTMENT, OF CRIMINAL JUSTICE, TRANSPORATION, DIVISION. ON THE 2ND DAY OF NOVEMBER, 1992, THE DAY I WAS TRANSFERED FROM THE WALLS UNIT IN HUNTSVILLE, TEXAS TO THE DARRINGTON UNIT IN ROSHARON, TEXAS. I WAS TRANSFERED IN BUS UNIT #51261, LIC 501-900, TO-WIT HAD N SEAT COVERS OR PADS, THE SEATS WARE MADE OF MEDAL AND COOL, THIS UNIT PROVIDED NO HEAT. I AND OTHER INMATES WAS TRANSPORTED IN THIS UNIT AT A SPEED OF 70 TO 80 MILES PER HOURS, FOR THREE (3) HOURS OR MORE. IN THE EVENT OF AN ACCIDENT, THIS UNIT #51261, LIC #501-900, WOULD IMMEDIATELY BECOME A KNIFE TO-WIT A DEADLY WEAPON. WEREFORE IN CLOSING: DUE TO THE FACT THAT THE TEXAS DEPARTMENT OF CRIMINAL JUSTICE TRANSPORTATION DIVISION IS IN VIOLATION OF STATE AND FEDEROL LAWS, AND HOUSE BILL 2335, STATE POLICY. I HAVE TAKING THE LIBERTIE IN NOTIFYING THE STATE GOVERNMENT CONCERNING THIS MATTER. AFTER RIDEING IN THIS UNIT, I EXPERIENCE (BUTT AND LOW BACK [Illegible Words] HAVING STATEMENT OF INFORMATION CONCERNING[Illegible Word] [Illegible Word] COULD INCLUDE THE FOLLOWING: OFFICE OF THE GOVERNOR [Illegible Word] OF CRIMINAL JUSTICE AUSTIN, TEXAS TEXAS DEPARTMENT OF CRIMINAL JUSTICE INSTITUTIONAL DIVISION HUNTSVILLE, TEXAS THE TEXAS DEPARTMENT OF PUBLIC SAFETY (DPS) AUSTIN, TEXAS |
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ID: aiam0459OpenMr. Robin A. C. Dandy, Senior Engineer, Head of Mechanical Section, British Standards Institution, Hemel Hempstead Centre, Marylands Avenue, Hemel Hempstead, Herts, England; Mr. Robin A. C. Dandy Senior Engineer Head of Mechanical Section British Standards Institution Hemel Hempstead Centre Marylands Avenue Hemel Hempstead Herts England; Dear Mr. Dandy: Your letter of 4 October 1971 encloses drawings of several seat bel buckle installations that show the locations at which you propose to apply the buckle crush forces specified in Standard No. 209. As to each of the buckles depicted, we consider the force lines to be correctly drawn for purposes of the buckle crush test.; Please advise us if we can be of further assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: nht92-2.27OpenDATE: November 16, 1992 FROM: Terry W. Wagar -- Technical Services Bureau, State of New York, Department of Motor Vehicles, Division of Vehicle Safety Services TO: Paul Jackson Rice -- Chief Council, NHTSA TITLE: None ATTACHMT: Attached to letter dated 1/22/93 from John Womack to Terry Wagar (A40; Std. 205) TEXT: I am writing to you regarding the repair of automotive safety glazing. I would like to know what the NHTSA's legal position is on the repair of glazing on in service motor vehicles that were originally designed to comply with FMVSS 571.205. The company "Ultra B-0-N-D, Inc.", 11151 Pierce Street, Riverside, CA 92505 (1-800-347-2820) requests that the New York State Department of Motor Vehicles establish that windshield glazing repair be accepted and repaired glass meet New York State inspection criteria. The Ultra B-0-N-D repair process is applied to line cracks small bruises and star cracks. Equipment is attached to the glass with suction cups to open the crack. A liquid is injected through the entire crack. Equipment is removed. A lamp is used to cure the chemical. Finally the repaired area is scraped with a razor blade then cleaned with window cleaner. When repaired, the crack is "not as visible". Please guide us with your agencies opinion in this matter. If you have any questions, you may reach me at (518) 474-5176. |
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ID: nht71-3.21OpenDATE: 06/24/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: 707 Tire Service Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of June 15, 1971, concerning the Tire Identification and Record Keeping Regulation (49 CFR Part 574). As stated in the interpretation published in the Federal Register of May 28, 1971, under section 113(f) of the National Traffic and Motor Vehicle Safety Act, "it is the tire manufacturer who has ultimate responsibility for maintaining the records of first purchasers". Under the Act and the Regulation, we have no authority to require a tire manufacturer to choose someone as his designee. I have asked Goodyear's counsel for their position with regard to the possible use of tire dealers customer's lists and was forwarded a letter dated June 8, 1971, from the Goodyear Tire and Rubber Company which sets forth the company's policy with regard to the prohibition in the regulation. I enclose the letter for your information. ENCLOSURE |
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ID: aiam1079OpenMr. Barry Kulik, 114 West 30 Street, New York, NY 1001 (sic); Mr. Barry Kulik 114 West 30 Street New York NY 1001 (sic); Dear Mr. Kulik: This is in response to your letter of March 9, 1973, requesting ou confirmation of an opinion given you by phone concerning the method of testing the sensitivity of seat belt warning systems under Motor Vehicle Safety Standard No. 208.; We hereby confirm our previous statement that the weight sensin provisions of sections S7.3 and S7.4 do not require the use of a specified test dummy. The sections refer to 'persons' of specified weights, thereby implying some distribution of the weight, but they do not reference the test dummy used in other sections of the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: nht71-1.40OpenDATE: 05/21/71 FROM: Lawrence R. Schneider; NHTSA TO: Jack Lewis; Legislative Assistant, U.S. Senate TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your telephone conversation of May 19, 1971 with a member of this office concerning Pert 574 - Tire Identification and Record Keeping. In your conversation you asked what the position of the National Highway Traffic Safety Administration would be if a retreader could establish he was unable to obtain, by May 22, 1971, the effective date of the regulation, the necessary tin plate for placing the required tire identification number on his retreaded tires. Of course, each case would be considered individually, but if a retreader could demonstrate that good faith attempts had been made to obtain the tin plate by May 22, 1971, and due to circumstances beyond his control he was unable to mark tires manufactured after May 22, 1971 with the required identification number, the National Highway Traffic Safety Administration would not take enforcement section against the retreader. |
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ID: 11-002613 drn.docOpenLawrence A. Beyer, Esq. 674 Lake Road Webster, NY 14580 Dear Mr. Beyer: This responds to your letter asking us whether the Goldhofer Modular Trailer Model THP SL (Model THP SL) is a motor vehicle within the meaning of 49 U.S.C. Chapter 301. As explained below, the answer is no. By way of background information, NHTSA interprets and enforces the laws under which the Federal motor vehicle safety standards are promulgated. NHTSAs statute at 49 U.S.C. Section 30102(a)(6) defines the term motor vehicle as follows: a vehicle driven or drawn by mechanical power manufactured primarily for use on public streets, roads, and highways, but does not include a vehicle operated only on a rail line. Further, if a vehicle is a motor vehicle, it must comply with all applicable Federal motor vehicle safety standards in order to be sold or imported into the United States (49 U.S.C. 30112(a)). Description of the Goldhofer Modular Trailer Model THP SL In your letter, you state that the Model THP SL is designed for ultra heavy duty applications for short distance transportation of goods from 80 to 10,000 tons (160,000 to 20,000,000 pounds) on uneven and/or constricted locations. The Model THP SL is described as being 9 feet 10 inches (118 inches or 3 meters) wide. Each module has six or eight independently controlled axles with four tires per axle. Each axle is controlled for steering, height and angle. Each axle can be raised by 16 inches and tilted 60 degrees independently, in order to ensure load stability. These actions can be either automatic or controlled by a Tillerman who monitors the movement of the unit. The units are designed to be operated singly or in combination with other units, either following each other or side to side, depending on the material being transported. We note that two units transported side by side take up a width of at least 236 inches, or almost 20 feet. You state that when loaded, the maximum speed of the trailers is 20 miles per hour. You included a series of photographs depicting the Model THP SL by itself, and showing the types of loads the Model THP SL carries in an open field, and in what appear to be shipyards or ports. Intended Uses of the Goldhofer Modular Trailer Model THP SL You state that your clients use for the Model THP SL is short distance transport of unusually large cargo on job sites such as petrochemical refineries, power plants, utility substations, shipping ports and rail sidings. Your client estimates that well over 90 percent of the use will be at those locations. You stated that those uses will be limited due to logistics and expense. In order to travel on the public roads, permits must be issued, there must be road closures, police escorts, utility equipment (power lines) must be relocated, and there are weight restrictions. You state that even crossing a street requires road closing and permits and can take most of a day. You state that the payloads are typically located at large facilities located adjacent to locations engaged in long distance shipping such as ship yards and rail-heads. As an example, you provide the situation where a new steam turbine is delivered via ship. The turbine itself is too heavy and cumbersome to be lifted out of the hold of the ship with a crane. However, the Model THP SLs specialized design allows it to be positioned on the ship to take on and transport a load that no other equipment can. The turbine is then transported to another means of transport such as rail or a barge. The Model THP SL is then used to move the turbine from the intermediate transporter to the final destination, the generator. Due to its design, the Model THP SL is able to be placed directly adjacent to the turbine for relatively easy loading. The Model THP SL is able to be maneuvered to the desired location for its placement at the generator facility. You state that this sort of job would take well over a week to complete. You state that when the Model THP SL is not in use (presumably, when it is not carrying a load), it is typically transported to and from the job site on a semi-trailer. Finally, you state that the Model THP SL can also be used as a mobile construction platform. The Model THP SL can locate a temporary electric generator or substation near a unit which requires service, thus minimizing service disruption. The Model THP SL can also be used to remove broken equipment from one area to be repaired on site. NHTSAs Analysis As we have stated in other interpretation letters, whether the agency will consider vehicles, including vehicles that can be used in construction, or similar equipment, to be motor vehicles depends on their use.[1] It is the agency's position that the statutory definition of motor vehicle does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. Even if the Model THP SL may, on occasion, travel on public roads, such on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. There are instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time. Such vehicles are considered motor vehicles for purposes of the Safety Act, since the on-highway use is more than "incidental." Clearly the intended uses of the Model THP SL are not analogous to how dump trucks are used. Based on the information provided with your letter, we believe that the on-highway use of your clients product to be merely incidental and is not the primary purpose for which it was manufactured. Therefore, we do not consider the Goldhofer Modular Trailer Model THP SL to be a motor vehicle. Please note that the views expressed in this letter are limited to the Goldhofer Modular Trailer Model THP SL. This letter is not generally applicable to all Goldhofer vehicles. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely yours, O. Kevin Vincent Chief Counsel Ref: Part 571 8/17/2011
[1] See, for example, the interpretation letter of October 20, 2003 to Schiller International Corp, signed by Jacqueline Glassman, NHTSA Chief Counsel. |
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ID: nht90-4.8OpenTYPE: Interpretation-NHTSA DATE: September 14, 1990 FROM: Loren Thomson -- Thomson & Weintraub TO: Dorothy R. Nakama -- Rule Making Attorney, United States Department of Transportation TITLE: None ATTACHMT: Attached to letter dated 3-14-91 from Paul Jackson Rice to Loren Thomson (A37; Std. 205; VSA 108(a)(2)(A)) TEXT: I represent the Glass Specialty Companies. They, as well as others in the glass repair and replacement industry have concerns with the types of repair being afforded by some members of the industry and with the replacement of original equipment, automob ile glass, with substandard glass. Edward H. Barnes, the president of Glass Specialty with whom you have talked, indicates to me that you've indicated that the Federal Motor Vehicle Standard, No. 205, is not specific upon standards with respect to the repair or replacement of automobile g lass. The only standard being that the repair or replacement must not leave the vehicle, "inoperable," or render it so. Our position is that if a windshield or a side glass is likely to shatter or distort the vision of an operator, the vehicle is indeed "inoperable." We would respectfully request an interpretive letter from your department of what the term "render inoperable" means in safety standard no. 205 as regards a chipped, cracked, or broken windshield. If you have any questions on the matter, please direct them to me. |
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ID: 17028.ztvOpenMr. Gary Starr Dear Mr. Starr: This is in reply to your letter of January 21, 1998, asking for an interpretation that "three devices are not motor vehicles or motor vehicle equipment for purposes of the regulations of the National Highway Traffic Safety Administration." You have described these devices as follows: "Device 1: ZAP Power System The Zap power system is a kit that is sold to electrify a bicycle or tricycle. It is sold by ZAP alone and is not part of a transaction involving the sale of a bicycle or tricycle." We have previously advised you that a bicycle with a power assist is a motor vehicle if the vehicle is capable of traveling without the input of muscular power. On the other hand, if a bicycle with power assist cannot travel without the input of muscular power, it will not be considered a motor vehicle. The statute that defines "motor vehicle equipment" is 49 U.S.C. Sec. 30102(a)(7). This definition includes "(A) any system, part, or component of a motor vehicle as originally manufactured." If combining the ZAP power system and a bicycle creates a motor vehicle under our previous interpretations, then the ZAP power assist would appear to be "motor vehicle equipment" under the statutory definition. Moreover, in that case, the individual or entity that made the combination would be considered the manufacturer of the motor vehicle, and would be required to assure that the vehicle complied with all applicable Federal motor vehicle safety standards in effect at that time, and issue a certification that the vehicle so complied. On the other hand, the ZAP power system would not be motor vehicle equipment if the bicycle cannot travel without the input of muscular power despite the presence of the power assist. "Device 2: ZAP Bicycle Bicycles manufactured by ZAP are similar to the bicycles manufactured by the Electric Transportation Company (ETC). These bicycles are bicycles with a power assist and must be pedaled to activate the motor and therefore the pedal assist system will not operate on its own in the absence of muscular effort." Your letter is not clear as to whether the power assist system is sufficient to power the bicycle without any further input of muscular power once muscular power has started the power assist system. As we have advised, if the pedal assist system will not operate on its own in the absence of muscular effort (after it may have been started by muscular power), the bicycle on which it is installed will not be deemed to be a "motor vehicle" subject to the regulations of this agency. On the basis of the information you have provided, the ZAP Bicycle would not appear to be a "motor vehicle" since it cannot be driven exclusively by mechanical power. "Device 3: Zappy The Zappy is an electric powered device that is similar to the TWIP scooter in which it has a maximum speed of 14 mph, has an abnormal configuration, that is, it has no seat, and folds down flat to make it portable." We agree that the Zappy appears similar to the TWIP, which was described as having a maximum top speed of about 9 miles per hour, and a driver's seat that folded down apparently to make the scooter more portable. On October 5, 1993, we advised the prospective importer of the TWIP, Bernhard Peer, that the TWIP met the criteria we use to exclude certain vehicles from regulation, For similar reasons, we do not consider the Zappy to be a "motor vehicle." If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, |
1998 |
ID: nht87-1.55OpenTYPE: INTERPRETATION-NHTSA DATE: 03/30/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Jack H. Whitney TITLE: FMVSS INTERPRETATION TEXT: Mr. Jack H. Whitney 80 Hammersmith Bridge Road London W6 9DB England This is in reply to your letter of November 14, 1986, with reference to the Asquith van that you wish to import into the United States from England and sell commercially. You have asked the following questions: "1. Does U.K. laminated glass meet D.O.T. regulations:" Since the U.S. and U.K. glazing standards are not identical, U.K. laminated glass does not necessarily meet the U.S. Federal motor vehicle safety standards (FMVSS). Some glass manufactured in U.K. does meet our standard. It bears the required "AS" symbol and numerical designation (e.g., "AS-1" for windshields) and is incorporated in such British cars as Rolls-Royce and jaguar that their makers certify as complying with the FMVSS. Glazing manufactured in England without the AS symbol and numerical design ator presumptively does not comply. "2. Can I carry passengers?" "3. Can I haul goods in the back?"
Federal safety standards do not regulate your use of the vehicle; thus, as far as our standards are concerned, you are free to decide whether to carry passengers, haul cargo, or both. However, certain design aspects of the vehicle may affect the category of the vehicle for purposes of compliance with the Federal motor vehicle safety standards. We define a truck as a vehicle "designed primarily for the transportation of property or special purpose equipment." Load-carrying vehicles are generally certifie d as "trucks" and comply with safety standards applicable to that category. A multipurpose passenger vehicle" is one that is "designed to carry 10 persons or less and which is constructed either on a truck chassis or with special features for occasional off-road operation. Many vans in the U.S. are certified as "multipurpose passenger vehicles." If a vehicle is neither constructed on a truck chassis nor has features for off-road use, but is designed for carrying 10 passengers or less it is a "passenger or less it is a "passenger car." 4. Once the van passes all D.O.T. and E.P.A. regulations, can it still be used on the road like any other vehicle? Whether a vehicle nay be used on the public roads is a matter determinable under State law -- specifically the laws of any State where it will be licensed or driven. Generally, when a vehicle complies with D.O.T. and E.P.A. regulations, there should be n o problem in registering and operating it. However, we are not familiar with State laws covering replica vehicles like the Asquith. "5. Without the engine assembly is my van considered a van, kit car or what?" For purposes of importation into the United States, a vehicle without an engine is considered an assemblage of items of motor vehicle equipment. Any items in the assemblage that are directly covered by a Federal motor vehicle safety standard (i.e., brake hoses, brake fluid, lighting equipment, tires, glazing, seat belt assemblies, and wheel covers) must meet, and be certified as meeting, the applicable U.S. standard. In reply to your final request, there are no printed forms for petitions for exemptions from the Federal safety standards. An applicant is expected to provide the information specified in 49 C.F.R. Part 555, in the order given. This regulation is contain ed in the volume referenced in our correspondence with Mr. Reed of May 2, 1986. The following is a listing of those requirements that must be completed before shipments begin. You must: 1. Appoint an agent for service of process in accordance with Title 49, Code of Federal Regulations, Part 551 (49 CFR 551).* 2. Assign a vehicle identification number to your vehicles as required by 49 CFR 565 and Federal Motor Vehicle Safety Standard (FMVSS) No. 115.* 3. Provide information as specified in 49 CFR 566, "Manufacturer Identification."* 4. Certify conformity by adding a label meeting the form, order, and location requirements of 49 CFR 567. 5. Maintain a list of first purchasers for purposes other than resale of your vehicles (section 158(b) of the National Traffic and Motor Vehicle Safety Act, 15 USC 1418(b)). 6. Build to conform to applicable Federal Motor Vehicle Safety and Bumper Standards. Passenger cars must also meet theft prevention standards, if applicable. 7. Maintain a record of tires on your vehicles (49 CFR 574)."* 8. Provide consumer information (49 CFR 575), if applicable. 9. File a form HS-7 with the U.S. Customs Service at the port of entry. Only one form with each shipment is required. 10. Provide "Automotive Fuel Economy Reports" (49 CFR 537 ), if applicable. If you determine in good faith that any vehicle manufactured by you does not conform with an applicable FMVSS or contains a safety-related defect, section 151 (15 USC 1411) of the Act requires that you furnish notification to the Secretary and to owners in accordance with section 153 (15 USC 1413) and to remedy without cost the failure to conform or defect in accordance with 154 (15 USC 1414). Details are contained in 49 CFR 573, 576 and 579. We do not have "application forms." Those regulations requiring information from your company are identified by an asterisk. We are enclosing the following pertinent publications: 1. The Act 2. 19 CFR 12.80, "Regulations for Motor Vehicle Importation" 3. "Order Form" for Title 49, Code of Federal Regulations, Parts 400-999 4. "Where to Obtain Motor Vehicle Safety Standards and Regulations" 5. 49 CFR 551, "Procedural Rules" 6. 49 CFR 573, "Defect and Noncompliance Reports" 7. 49 CFR 576, "Record Retention" 8. 49 CFR 579, "Defect and Noncompliance Responsibility" 9. Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment If we may be of further assistance, please let us know. Sincerely, Erika Z. Jones Chief Counsel Ms. Erika Z. Jones Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A. Dear Ms. Jones, Mr. Crispin Reed gave me your name. I am purchasing and importing one of their Shire'vans. Hopefully the vehicle will arrive in Florida in April of next year. The vehicle will solely belong to me and will arrive without an engine, transmission, exhaust system, etc. I then, with the help of the Ford Motor Company, have installed, a new Ford Mustang engine assembly so I will comply with all EPA regulations. I have been appointed an agent of the Asquith Motor Carriage Co. to sell future Shire vans to the U.S. market. Because of the excellent quality of these vehicles and the potential sales and advertising abilities, I am now receiving help from the Florida Dept. of Commerce and the Broward Economic Development Board. The first van will have two front seats and one large back seat. All the glass will be laminated and it will have a bulkhead separating the passenger area from the back cargo area. It will have winkers front, back and all sides. The chassis and hub and b rake assembly will be the brand new Ford Transit 100LWB. The question I have on my van will certainly help to cut costs, time and save from doing thing incorrectly or twice, to meet current D.O.T. safety regulations: 1) Does U.K. laminated glass meet D.O.T. regulations? 2) Can I carry passengers? 3) Can I hau l goods in the back? I will be manufacturing furniture in Florida. 4) Once the van passes all D.O.T. and E.P.A. regulations, can it still be used on the road like any other vehicle? 5) Without the engine assembly is my van considered a van, kit car or what?
As for the other future vans, I would be grateful if you could send me (by air mail) the necessary forms required (exemption petitions) so the manufacturer and I can fill them out now, because of the four month waiting period mentioned in your letter dat ed May 2nd. I want to do this thing correctly cause I would hate to be stuck with a $40,000 van that I couldn't drive. On the other future vans, Mr. Reed has given me all of your past correspondence and the microfiches you kindly sent him. I shall be looking at them this week. I assure you have our brochure. The van is 78" wide & 16 1/2 foot long. *Not for hire. Yours Sincerely, Jack H. Whitney |
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.