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: aiam3182OpenMr. Steven J. Kalies, Union Springs Central School District, Union Springs, NY 13160; Mr. Steven J. Kalies Union Springs Central School District Union Springs NY 13160; Dear Mr. Kalies: During our telephone conversation, I envisioned the device yo described being covered by our Federal Motor Vehicle Safety Standard (FMVSS) 209, Seat Belt Assemblies. By the description on the price sheet you enclosed in your letter of 1/8/80, I am now not too sure. This device may not be covered under our FMVSS 213, Child Restraint(sic); After a conversation with the NHTSA's Office of Chief Counsel, I a taking the liberty of forwarding your letter to them for their review and response. It would be helpful if a brochure or picture of this device could be sent to our Washington Office. If available, mail it to: NHTSA, Office of Chief Counsel (NOA-30), 400 7th Street, S.W., Washington, D.C. 20590, ATTN: Mr. Stephen L. Oesch.; Thank you for bringing this matter to our attention. Sincerely, Irving Rodness, Motor Vehicle Program Specialist |
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ID: aiam0889OpenMr. Dwight A. Warren, Personnel Aide - Safety, Personnel Department, 500 Municipal Building, 251 West Washington, Phoenix, AZ 85003; Mr. Dwight A. Warren Personnel Aide - Safety Personnel Department 500 Municipal Building 251 West Washington Phoenix AZ 85003; Dear Mr. Warren: Your letter of September 18, 1972, to our Regional Administrator i Region IX, was referred to this office for a direct reply.; The information you desire is contained in the enclosed copy of Federa Motor Vehicle safety Standard (FMVSS) No. 215, Exterior Protection.; The standard applies to new vehicles manufactured for sale in th United States. It is my understanding that push-bar type bumpers are installed after the vehicles have been purchased from the manufacturer. This type of installation is not in conflict with the requirements of FMVSS No. 215.; Thank you for your interest in motor vehicle safety, and if we can b of further assistance, please let us know.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1005OpenMr. Konen, Johann und Konen, 53 Bonn-Beul 1, Rosenbach, Ortsteil Putachen, GERMANY; Mr. Konen Johann und Konen 53 Bonn-Beul 1 Rosenbach Ortsteil Putachen GERMANY; Dear Mr. Konen: Your letter of February 1, 1973, concerning warning devices, has bee forwarded to my office for review and response.; The National Highway Traffic Safety Administration does not issu authorization for testing institutes to approve our Federal Motor Vehicle Safety Standards (FMVSS). Each manufacturer must be responsible for assuring that his products meet the standard, and no submittals are to be made to this Administration. However, we are enclosing a list of foreign laboratories who are capable of determining whether warning devices meet the requirements of FMVSS No. 125.; The side length of the warning device should be interpreted as th direct length over the outside radii.; If any further information is necessary, please let us know. Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam4851OpenMs. Jessie M. Flautt 4405 Lafayette Street Bellaire, TX 77401; Ms. Jessie M. Flautt 4405 Lafayette Street Bellaire TX 77401; "Dear Ms. Flautt This responds to your letter to Mr. Steve Kratzke o my staff, requesting that the National Highway Traffic Safety Administration (NHTSA) grant permission to a repair business to modify your motor vehicle. You explained that you are under five feet, two inches and legally blind in one eye. You further explained that, due to the increased size of headrests in recent years, you are unable to locate a 1991 automobile which does not have headrests which impede your field of vision. You wish to arrange to have the size of the headrests in a 1991 automobile reduced. You asked if you could obtain permission from this agency to permit this modification. I hope the following discussion explaining our regulation will be of assistance to you. I would like to begin by clarifying that there is no procedure by which persons petition for and are granted permission from NHTSA to arrange to have a motor vehicle repair business modify their motor vehicle. Repair businesses are permitted to modify vehicles without obtaining permission from NHTSA to do so, but are subject to certain regulatory limits on the type of modifications they may make. In certain limited situations, we have exercised our discretion in enforcing our regulations to provide some allowances to a repair business which cannot conform to our regulations when making modifications to accommodate the special needs of persons with disabilities. Since your situation is among those given special consideration by NHTSA, this letter should provide you with the relief you seek. Our agency is authorized to issue Federal Motor Vehicle Safety Standards (FMVSS) that set performance requirements for new motor vehicles and items of motor vehicle equipment. Manufacturers are required by the National Traffic and Motor Vehicle Safety Act (Safety Act) to certify that their products conform to our safety standards before they can be offered for sale. Manufacturers, distributors, dealers and repair businesses modifying certified vehicles are affected by 108(a)(2)(A) of the Safety Act. It prohibits those businesses from knowingly rendering inoperative any elements of design installed on a vehicle in compliance with a FMVSS. In general, 108(a)(2)(A) would require repair businesses which modify motor vehicles to ensure that they do not remove, disconnect or degrade the performance of safety equipment installed in compliance with an applicable safety standard. Violations of 108(a)(2)(A) are punishable by civil fines up to $1,000 per violation. In situations such as yours where a vehicle must be modified to accommodate the needs of a particular disability, we have been willing to consider any violation of 108(a)(2)(A) a purely technical one justified by public need. I can assure you that NHTSA would not institute enforcement proceedings against a repair business that modifies the headrest on your vehicle to accommodate your condition. We caution, however, that only necessary modifications should be made to the headrest to accommodate your condition and we urge your dealer to modify your vehicle in such a manner that would not degrade from the safety currently provided by your vehicle. Many manufacturers are currently installing headrests in vehicles which exceed the minimum dimensions required by FMVSS No. 202, Head Restraints. I urge you not to have your headrest reduced below these dimensions if it is not necessary for your field of view. If you have further questions or need some additional information in this area, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5392OpenMr. Dan Neaga and Ms. Dianna Sabo Johnson Controls, Inc. 49200 Halyard Dr. P.O. Box 8010 Plymouth, MI 48170; Mr. Dan Neaga and Ms. Dianna Sabo Johnson Controls Inc. 49200 Halyard Dr. P.O. Box 8010 Plymouth MI 48170; Dear Mr. Neaga and Ms. Sabo: This responds to your letter asking abou a requirement of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, 'Child Restraint Systems,' for built- in child restraints that use 'the same seat back surface as the adult occupant.' I apologize for the delay in responding. Before I begin, I would like to reference a May 26, 1994 telephone call to you from Ms. Deirdre Fujita of my staff, about your letter's statement that the information you sent us is confidential. Ms. Fujita explained that letters requesting interpretations of our FMVSSs are public information, but suggested that we could return your sketches to you and make publicly available only your cover letter. You agreed this would satisfy your concerns about not disclosing your design concepts. Accordingly, Ms. Fujita has mailed your sketches to you. By way of background, the National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment or pass on the compliance of a vehicle or item of equipment outside the context of an actual enforcement proceeding. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the facts set forth in your letter. You ask if your understanding is correct that 'lateral support of the side of the child's torso is not required by FMVSS 213.' The answer is yes. The torso impact protection requirement of S5.2.2.1(b) of Standard 213 specifies requirements for ' e ach system surface provided for support of the side of the child's torso' (emphasis added). The preamble for the final rule adopting S5.2.2.1(b) explains: 'The specifications do not require manufacturers to incorporate side supports in their restraints, they only regulate the surfaces that the manufacturer decides to provide so that they distribute crash forces over the child's torso.' 44 FR 72131, 72135, December 13, 1979. Please note that NHTSA determines independently from the manufacturer whether a particular surface is provided for side support. The determination is based on factors such as the design and intended use of the restraint, and the advertising literature for the restraint. Accordingly, a manufacturer cannot avoid complying with S5.2.2.1(b) simply by asserting that a side surface was not provided for side support. However, with regard to a built-in restraint such as yours that uses the same seat back surface as the adult occupant and where 'no lateral support other than the one offered to the adult occupant is provided,' it does not appear that the child restraint incorporates side supports subject to S5.2.2.1(b). If you have any questions, please call Ms. Fujita at (202) 366-2992. Again, my apologies for the delay in responding. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam5482OpenMr. Allan E. McIntyre Engineering and Product Development Sprague Devices, Inc. P. O. Box 389 Michigan City, IN 46360; Mr. Allan E. McIntyre Engineering and Product Development Sprague Devices Inc. P. O. Box 389 Michigan City IN 46360; "Dear Mr. McIntyre: This responds to your letter to the Federal Highwa Administration asking for an interpretation of Federal Motor Vehicle Safety Standard No. 104, Windshield washing and wiping systems. Since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering the Federal motor vehicle safety standards (FMVSS) , including Standard No. 104, your letter was referred to my office for reply. I regret the delay in this response. Your letter concerns a standard issued by the Society of Automotive Engineers (SAE) and referenced in S4.2.2 of Standard No. 104. S4.2.2 specifies that each multipurpose passenger vehicle, truck and bus shall have a windshield washing system that meets the requirements of SAE Recommended Practice J942, November 1965 (as modified). You explain that you chair an SAE subcommittee that developed a new Recommended Practice J1944, 'Truck & Bus Multipurpose Vehicle Windshield Washer System,' that you believe is more suitable for testing 'commercial vehicles.' You ask whether NHTSA would 'allow for documentation of compliance to FMVSS 104 through use of the new J1944 recommended practice or is it necessary to evaluate per J942 as specifically written.' Your question raises two issues, both of which concern how a test procedure specified in the Federal motor vehicle safety standards may vary in practice from that described in the standard. The first issue is whether a vehicle manufacturer is obligated to test its vehicle only in the manner specified in Standard No. 104, i.e., only by using J942 and not the newly developed J1944. The answer is no. Each of NHTSA's safety standards specifies the test conditions and procedures that this agency will use to evaluate the performance of the vehicle or equipment being tested for compliance with the particular safety standard. However, NHTSA does not require a manufacturer to test its products only in the manner specified in the safety standards. A manufacturer may choose any means of evaluating its products to determine whether the vehicle or item of equipment complies with the requirements of Standard No. 104, provided, however, that the manufacturer assures that the vehicle will comply with the standard when tested by NHTSA. If NHTSA's compliance test of Standard No. 104 were to show an apparent noncompliance of a vehicle with the standard, the vehicle manufacturer would be asked to show the basis for its certification that its vehicle complies with the standard. If in fact there is a noncompliance, the manufacturer would be subject to civil penalties unless it can establish that it exercised 'reasonable care' in the manufacture of the product and in the checks (through actual testing, computer simulation, engineering analyses, or other means) to ensure compliance. We cannot tell you at this time whether a manufacturer's use of J1944 to certify a vehicle's compliance with Standard No. 104 would constitute 'reasonable care.' NHTSA is unable to judge what efforts constitute 'reasonable care' outside of the course of a specific enforcement proceeding. What constitutes 'reasonable care' in a particular case depends on many factors, including such things as the limitations of current technology, the availability of test equipment, the size of the manufacturer, and above all, the diligence exercised by the manufacturer. The second issue raised by your question is whether NHTSA is required to use J942 in the agency's compliance tests. The answer is yes, as long as J942 is incorporated into the test procedure of Standard No. 104. When conducting its compliance testing, NHTSA must precisely follow each of the specified test procedures and conditions set forth in the safety standard. If a different procedure or condition is desirable, the agency must undertake rulemaking to amend the standard to incorporate the desired change. You ask in your letter about the procedure for amending Standard No. 104. NHTSA has a process whereby you can petition for a change to the FMVSS, including Standard No. 104. The petitioning procedure is outlined at 49 CFR part 552 Petitions for rulemaking, defect, and noncompliance orders (copy enclosed). Very briefly, section 552.4 states that a petition should be addressed and submitted to: Administrator, NHTSA, 400 Seventh Street, SW, Washington, DC 20590. Each petition must be written in English, have a heading that includes the word 'Petition,' set forth facts which it is claimed establish that a change to the regulation is necessary, set forth a brief description of the substance of the revised regulation which it is claimed should be issued, and contain the name and address of the petitioner. After receiving the petition, NHTSA conducts a technical review to determine whether there is a reasonable possibility that the requested regulatory change will be issued at the end of the appropriate rulemaking proceeding. You state that J1944, the newer SAE standard, is overall a 'tougher' document than J942. You should be aware that NHTSA cannot automatically incorporate a 'tougher' version of an incorporated document into the FMVSS. Before NHTSA incorporates an upgraded standard, NHTSA examines whether there is a safety need for the newer requirements. In its examination, NHTSA considers data from all sources, including the petitioner. If you decide to submit a petition, you ought to explain the safety need for the new requirements and provide an analysis of the increased costs likely to be associated with the new requirements. I hope this information is helpful. If you have any further questions. please contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam3598OpenMr. Fukuo Takata, Manager, Certifications Regulations Section, Ichikon Industries, Ltd, 80 Itado, Isehara City, Kanagawa 259-11, JAPAN; Mr. Fukuo Takata Manager Certifications Regulations Section Ichikon Industries Ltd 80 Itado Isehara City Kanagawa 259-11 JAPAN; Dear Mr. Takata: This is in reference to your letter of June 30, 1982, to Mr. Elliott o this agency concerning the effective luminous lens area of a front turn signal lamp under Federal Motor Vehicle Safety Standard (FMVSS) No. 108 with respect to three proposed designs.; We assume that you wish to know what is the effective projecte luminous lens area for a front turn signal on vehicles less than 80 inches in overall width. The SAE Standard No. J588e, 'Turn Signal Lamps,' which you quote, imposes no additional requirements for a two compartment front turn signal lamp. Thus, it appears that so long as you meet the minimum of 3.5 square inches for a single compartment lamp, your proposed designs (Case 1 and 2) meet the necessary requirements of FMVSS No. 108. Case 3 would not conform as neither of the two section compartments meets the 3.5 square inch minimum.; Sincerely, Courtney M. Price, Associate Administrator for Rulemaking |
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ID: aiam5575OpenMr. Yoshiaki Matsui Manager Automotive Equipment Legal & Homologation Section Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153 Japan; Mr. Yoshiaki Matsui Manager Automotive Equipment Legal & Homologation Section Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Matsui: This responds to your letter of June 23, 1995, askin questions about neon high mounted stop lamps. The National Highway Traffic Safety Administration answered these questions in the preamble to a notice of proposed rulemaking that was published on June 19, 1995. We assume that you had not received it by the 23rd, and enclose a copy for your information. You will see (center column, page 31940) that Federal Motor Vehicle Safety Standard (FMVSS) No. 108 allows neon tubes as light sources for the center highmounted lamp. Under our interpretation of paragraph S5.1.1.16, FMVSS No. 108 also allows testing of a neon lamp with or without its ballast, in accordance with the directions of that paragraph. If you have any questions, you may refer them to Taylor Vinson of this Office. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam5459OpenVincent Ugoletti, Chief Engineer Great Lakes Communications, Inc. 3514 State St. P.O. Box 860 Erie, PA 16512; Vincent Ugoletti Chief Engineer Great Lakes Communications Inc. 3514 State St. P.O. Box 860 Erie PA 16512; "Dear Mr. Ugoletti: This responds to your September 7, 1994 letter t this office in which you stated your intention to modify a 'conversion' van into a 'production' van by replacing the original front seats with seats that swivel. You stated in an October 4 telephone conversation with Walter Myers of my staff that the vehicle in question is a 1994 cargo van. The vehicle has two front seats, and a gross vehicle weight rating (GVWR) of 9,680 pounds (lbs.). You also explained that the work will be done by a commercial vehicle modification shop. You asked us about the requirements for swivel front seats. By way of background, 49 U.S.C. 30101, et seq. authorizes this agency to issue Federal motor vehicle safety standards (FMVSSs) applicable to new motor vehicles and new items of motor vehicle equipment. Under 49 U.S.C. 30112, each person selling a new vehicle must ensure that the vehicle is certified as complying with all applicable FMVSSs. NHTSA has five safety standards, described below, applicable to motor vehicle seats. The original seats and seat belts on your van were required to meet the requirements of those standards when the new van was sold to you. The five standards set performance criteria ensuring that seats and seat belts provide safety benefits in a crash. Standard No. 207, Seating systems (49 CFR section 571.207), establishes strength and other performance requirements for vehicle seats. The standard does not prohibit the installation of swivel seats in vans. Standard No. 208, Occupant Crash Protection (49 CFR 571.208), specifically section S4.2.3, sets forth occupant protection requirements at the various seating positions in vehicles such as yours manufactured after September 1, 1991, and with a GVWR not greater than 10,000 lbs. Standard No. 209, Seat Belt Assemblies (49 CFR 571.209), sets strength, durability, and other requirements for seat belts. Standard No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210), establishes strength and location requirements for seat belt anchorages. Standard No. 302, Flammability of Interior Materials (49 CFR 571.302), specifies the flammability resistance of the seats and seat belts. Copies of those standards are enclosed, as well as a fact sheet explaining how to obtain copies of all FMVSSs. Generally speaking, once a motor vehicle is sold to its first retail purchaser, its use and any modifications made to it become a matter of state interest. Thus, owners of used vehicles may personally make any modifications or alterations they want to their vehicles without regard to the FMVSSs, subject only to applicable state requirements. There is, however, a limitation on modifications of used vehicles by commercial entities. 49 U.S.C. 30122 provides that a manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any device or element of design installed on or in a motor vehicle or equipment in compliance with an FMVSS. Since the seats and their safety belts are devices or elements of design that were installed in your van in compliance with applicable FMVSSs (particularly the five standards listed above), a business listed in section 30122 cannot modify the vehicle in such a manner as to remove the seats and/or safety belts from compliance. Accordingly, the vehicle modifier should ensure that the swivel seats and any seat belts it installs are installed in accordance with the requirements of the standards. You indicated that Great Lakes Communications wishes to maintain the safety of the original seats and seat belts. We commend that decision. NHTSA urges vehicle owners not to degrade the performance of the safety systems on their vehicles. I hope this information is helpful. Should you have any further questions or need additional information, feel free to contact Walter Myers or Mary Versailles of my staff at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam5584OpenTerrence S. Lockman, Investigator Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. Attorneys-at-Law P.O. Box 12308 226 South Palafox Place Pensacola, FL 32581; Terrence S. Lockman Investigator Levin Middlebrooks Mabie Thomas Mayes & Mitchell P.A. Attorneys-at-Law P.O. Box 12308 226 South Palafox Place Pensacola FL 32581; "Dear Mr. Lockman: This responds to your request for an interpretatio whether a Model Year (MY) 1981 Versa Sweeper road sweeper is a 'motor vehicle' and therefore subject to the Federal Motor Vehicle Safety Standards (FMVSSs) that were in effect when the vehicle was manufactured. Further, you ask whether the Versa Sweeper had to comply with requirements for an occupant restraint system or for rollover protection. You explained that you are conducting an investigation, and that 'At the time in question, the vehicle was being used in a construction zone, to sweep debris off the roadway.' I note, before beginning, that your letter had asked for certain information under the Freedom of Information Act (FOIA). NHTSA separately answered your FOIA request by letter dated May 22, 1995, from Ms. Heidi Coleman of my staff, Assistant Chief Counsel for General Law. Yours is an unusual interpretation request. Typically, questions concerning whether a vehicle is a motor vehicle are raised around the time of manufacture of a vehicle or its importation into the country, and by a person knowledgeable about the intended use of the vehicle, such as the vehicle's manufacturer. In contrast, your question asks about another entity's vehicle 14 years after the vehicle's manufacture, which makes our response more difficult. We cannot say for certain what principles would have applied in 1981 concerning the Versa Sweeper, and our knowledge of the vehicle is limited to the information you provided. Thus, a conclusive answer is beyond our reach. We can make the following observations, however. NHTSA applies several principles when making a determination of whether a vehicle is a motor vehicle. Section 102(3) of the National Traffic and Motor Vehicle Safety Act defined a motor vehicle as 'a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways . . . .' We are not certain, based on the information you provided, that the Versa Sweeper was manufactured for use on public highways. The literature you sent indicates that the Versa Sweeper is intended for 'road maintenance sweeping and highway preparation cleaning.' It appears that the vehicle might be a construction vehicle. Moreover, you indicated that the vehicle was being used in a construction zone 'at the time in question.' Construction-related vehicles generally are 'motor vehicles' for purposes of our statute if they frequently use the highway going to and from job sites and stay at a job site for only a limited time. With regard to the 1981 Versa Sweeper, its use of the highway is unclear. Assuming the Versa Sweeper had regularly used the highway, NHTSA's longstanding position has been that vehicles of unusual configuration that are incapable of obtaining speeds greater than 20 miles per hour (mph) are not required to comply with the FMVSSs. It is unclear how this principle applies to a 1981 Versa Sweeper. The material you enclosed indicates that the Versa Sweeper has 'Infinitely variable speeds from 0-30 miles per hour....' It is unclear whether this means each Versa Sweeper can attain a speed of 30 mph or whether some, but not all, can. A Versa Sweeper that had a maximum speed of less than 20 mph is excluded. One that went over 20 mph might not have been. You ask about requirements for occupant restraints and rollover protection. The agency has stated that 'street sweepers'--that are motor vehicles--are trucks. In 1981, FMVSS No. 208, Occupant Crash Protection (49 CFR 571.208), required open-bodied light trucks to have a lap belt system. There was no rollover requirement. If you have any further questions, please contact Ms. Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack 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.