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: aiam1365OpenIrvin Jacobs, M.D., Corner Sterling & Machell Avenues, Dallas, Pennsylvania 18612; Irvin Jacobs M.D. Corner Sterling & Machell Avenues Dallas Pennsylvania 18612; Dear Mr. Jacobs: This is in reply to your letter of November 21, 1973 to 'U.S. Bureau o Safety' expressing your view that 'the automobile industry should ... have some type of clutch to reverse action when the closing motion of the (power) window meets any resistance.'; I enclose a copy of Federal Motor Vehicle Safety Standard No. 11 *Power-operated Window Systems* which has applied to all passenger cars and multipurpose passenger vehicles with power windows manufactured since February 1, 1971. The objective of the standard is to minimize the likelihood of injury or death occurring when a person is caught between a closing window and its frame, channel, or seat. The NHTSA determined that the most cost-effective way to accomplish this objective was by prohibiting operation of power windows when the ignition key is either in the ignition 'off' position or removed. As you will see from the enclosure, consideration was given to mechanisms that would reverse the direction of the window.; We appreciate your interest in motor vehicle safety. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3358OpenMr. Paul R. Hingtgen, 7104 San Bartolo, Carlsbad, California 92008; Mr. Paul R. Hingtgen 7104 San Bartolo Carlsbad California 92008; Dear Mr. Hingtgen: This is in reply to your letter of August 13, 1980, requestin information concerning all Federal Motor Vehicle Safety Standards relevant to the manufacture and sale of an auxiliary wind deflector.; The National traffic and Motor Vehicle Safety Act of 1966, as amende (the Act), authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal Motor Vehicle Safety Standards which are applicable to motor vehicles or motor vehicle equipment. Based upon the information you have provided, it is our opinion that you wind deflector is subject to Safety Standard No. 205, 'Glazing Materials' (copy enclosed). Incorporating by reference 'ANSZ26,' the American National Standard's Safety Code for Glazing Materials, Safety Standard No. 205 specifies performance requirements for various types of glazing and also the location in vehicles in which each type of glazing may be used. Under the requirements of this standard, an auxiliary wind deflector to be used on a passenger vehicle at levels requisite for driving ability may be manufactured out of either Item 1, Item 2, Item 4, Item 10, or Item 11 glazing materials, depending upon its proposed location on the vehicle (the various types of glazing are designated as 'Items' in the standard). Thus the material you propose to use is acceptable since it is Plexiglass or Acuylite having an Item 4 rating, which may be used as a wind deflector placed on the side window of a vehicle. Such AS-4 glazing material must of course meet Test No. 2, 'Luminous Transmittance,' which requires that the material 'show regular (parallel) luminous transmittance of not less than 70 percent of the light, at normal incidence, both before and after irradiation.'; Safety Standard No. 205 also sets forth specific certification an marking requirements. The requirements for prime glazing material manufacturers (those who fabricate, laminate, or temper the glazing material) are set out in paragraphs S6.1-S6.3. While not Explicitly stated in you letter, it appears that you do not manufacture the glazing you use in your deflector, but instead purchase it from a prime glazing manufacturer and then cut it youself(sic). If this assumption is correct, then you are set out in Paragraphs S6.4 and S6.5. By reference to section 6 of ANS Z26, you are required under this paragraph to mark any section of glazing that you cut with the same words, designations, characters, and numerals as the piece of glazing from which it was taken. This means that you would stamp your product with markings identical to those found on the acrylic sheets you purchased. Each item must also be certified pursuant to section 114 of the Act. Section 114 provides that an item of motor vehicle equipment may be certified by means of a label or tag on the item or on the outside of a container in which the equipment is delivered. The label or tag must state that the item of motor vehicle equipment complies with all applicable motor vehicle safety standards, which in this case would be Safety Standard No. 205.; Under Section 108(a)(1)(A) and (b)(1) of the Act, new motor vehicl equipment such as wind deflectors must comply with applicable safety standards prior to its first purchase by someone for purposes other than resale. The manufacture or installation of a wind deflector that does not conform to the standard, or the installation in a new vehicle in a location that is not provided for in Standard No. 205, would be a violation of section 108(a)(1)(A). Under Section 109, anyone who violates section 108(a)(1)(A) is subject to a civil penalty up to $1,000 for each violation.; After the first purchase of the equipment for purposes other tha resale, i.e., its purchase by a consumer, tampering with the equipment is limited by Section 108(a)(2)(A). This section prohibits certain entities an persons from knowingly removing, disconnecting, or reducing performance of equipment or elements of design installed on a vehicle in accordance with applicable safety standards. The prohibition applies only to manufacturers, distributors, and dealers of motor vehicles and motor vehicle equipment, and to motor vehicle repair businesses. There is no prohibition against an individual person modifying his or her own vehicle or equipment. Section 109 provides a civil penalty of up to $1,000 for each violation of this section.; Manufacturers of motor vehicle equipment also have responsibilitie under the Act regarding safety defects. Under Section 151 *et seq*., such manufacturers must notify purchasers about safety-related defects and remedy such defects free of charge. Again, Section 109 imposes a civil penalty of up to $1,000 upon any person who fails to provide notification of or remedy for a defect in motor vehicle equipment.; We hope you find this information helpful. Please contact this offic if you have any more questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4167OpenMs. Connie Hafenstine, Chief, Bureau of Personnel Services, Mr. Noble Morrell, Assistant Personnel Director, Kansas Department of Transportation, State Office Building, Topeka, KS 66612-1568; Ms. Connie Hafenstine Chief Bureau of Personnel Services Mr. Noble Morrell Assistant Personnel Director Kansas Department of Transportation State Office Building Topeka KS 66612-1568; Dear Ms. Hafentine and Mr. Morrell: This responds to your February 19, 1986, letter to the National Highwa Traffic Safety Administration (NHTSA) concerning a school district's modification of its 1985 school bus to accommodate a handicapped student. You asked for our opinion on the district's plan to remove the bench seat located directly behind the driver's seat. This modification is proposed in order to provide necessary leg room for a handicapped child who would occupy the bench seat rearwards of the removed seat.; While you explained that the work on the school bus would probably b performed by the school district itself, you requested us to clarify our requirements for commercial parties modifying used vehicles. The National Traffic and Motor Vehicle Safety Act, which authorizes NHTSA to issue safety standards applicable to the manufacture and sale of new motor vehicles, includes section 108(a)(2)(A) regulating the modification of safety systems on used motor vehicles. Section 108(a)(2)(A) prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard. This means that Federal law would prohibit a commercial business from degrading or removing the level of safety provided by the equipment or designs of your school bus.; You explained that your school bus was certified as meeting ou 'compartmentalization' requirements for school bus passenger protection. Compartmentalization provides occupant protection by seat spacing, padding and strength requirements. It is therefore likely that removing a school bus seat would render inoperative the vehicle's compliance with the requirements for compartmentalization since school bus seats are central to that system of occupant protection. As a result, a commercial business would violate S108(a)(2)(A) by removing the bench seat in question if no properly padded restraining device were provided within the distance specified in Standard No. 222 for seat spacing. Violation of S108(a)(2)(A) is subject to a maximum civil penalty of $1,000 for each violation.; NHTSA is aware that situations may exist where a vehicle must b modified by a commercial facility to accommodate the special needs of a handicapped person. We have been willing to consider some of those modifications and resultant violations of S108(a)(2)(A) as being justified by public need, and have exercised our discretion not to take any enforcement action. Such an exception would be made in your situation if removing the school bus seat were necessary to accommodate a student's physical handicaps. However, we urge you to label the bench seat rearward of the removed seat in some manner that will identify it is appropriate only for transporting a handicapped student and distinguish it from a regular school bus seat. Further, if the seat would be capable of being used by other school children, we strongly recommend that a mode of occupant protection be provided to all occupants of the seat, and that the level of protection is as safe as that originally provided by the school bus before the modification was made.; Section 108(a)(2)(A) applies only to commercial-type businesses whic modify used vehicles. It does not apply to an owner, such as a state or a school district, modifying its own vehicles. Accordingly, Federal law would not prohibit the school district from removing the bench seat on its school bus nor restrict the removal in any manner. Again, however, we do strongly recommend that you ensure that the bench seat rearward of the removed seat is labeled and that an appropriate mode of occupant protection is provided to all children who would occupy it.; The modification of the bus would, of course, still have to comply wit any applicable state laws. You should contact your attorney and insurance company to discuss the effect of state law on your modification as well as private liability issues, since your planned modification might affect the vehicle's compliance with safety standards.; I hope this information is helpful. If you have any further questions please contact my office.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2119OpenMr. Frank W. Linnell, Linnell, Choate & Webber, Attorneys at Law, 83 Pleasant Street, Auburn, ME 04210; Mr. Frank W. Linnell Linnell Choate & Webber Attorneys at Law 83 Pleasant Street Auburn ME 04210; Dear Mr. Linnell: This is in further reply to your letter of October 7, 1975, concernin regulations applicable to vehicles which a client of yours proposes to manufacture. A copy of your letter was forwarded to the National Highway Traffic Safety Administration (NHTSA) by the Federal Highway Administration's Bureau of Motor Carrier Safety.; The NHTSA issues Federal motor vehicle safety standards to which moto vehicles must conform. In addition, the agency requires the manufacturer to certify that the vehicle as completed complies with applicable safety standards. A pamphlet summarizing the Federal motor vehicle safety standards is enclosed, along with a copy of the regulations governing vehicle certification and an information sheet entitled 'Where to Obtain Motor Vehicle Safety Standards and Regulations.' The safety standards themselves are set forth in their entirety in Part 571 of Volume 49 of the Code of Federal Regulations.; The NHTSA also investigates safety-related defects and noncompliance with safety standards in motor vehicles and items of motor vehicle equipment. If the agency or the manufacturer determine that a safety-related defect or noncompliance exists, the manufacturer is obligated to notify the vehicle owners and remedy the problem without charge. A copy of the provisions of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, which deal with the responsibilities of manufacturers for safety-related defects and noncompliances in their motor vehicles or item of vehicle equipment (15 U.S.C. SS 1411-1420) is also enclosed.; If you have any questions concerning a specific regulation or standard please write.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0124OpenMr. John F. Floberg, Vice President, Firestone Tire and Rubber Company, Akron, Ohio 44317; Mr. John F. Floberg Vice President Firestone Tire and Rubber Company Akron Ohio 44317; Dear Mr. Floberg: This will acknowledge your letters of July 12, 1968, October 10, 1968 and October 31, 1968, to the National Highway Safety Bureau requesting the addition of three 50 Series Centilevered Sidewall tire size designations to Federal Motor Vehicle Safety Standard No. 109.; On the basis of the data submitted indicating compliance with th requirements of Federal Motor Vehicle Safety Standards Nos. 109 and 110 and other information submitted in accordance with the procedural guidelines set forth in *Federal Register* Volume 33, No. 195, Page 14964, dated October 5, 1968, the E50C-16, F50C-16 and H50C-17 tire size designations will be listed within a new table to be established in Appendix A of standard No. 109 and the 3 1/2 inch rim size will be listed within Table I od the Appendix to Standard No. 110. These changes will be published in the *Federal Register* in the near future.; The addition of new tire size designations to the tables i accomplished through an abbreviated procedure consisting of the publication in the *Federal Register* of the petitioned tire sizes or tables. If no comments are received, the amendment becomes effective after 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.; Sincerely, H.M. Jacklin, Jr., Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam5326OpenMr. Steve J. Brooks Program Manager IAD West Coast, Inc. 5761 McFadden Avenue Huntington, Beach CA 92649; Mr. Steve J. Brooks Program Manager IAD West Coast Inc. 5761 McFadden Avenue Huntington Beach CA 92649; "Dear Mr. Brooks: This responds to your letter asking about th operation and classification of a commercial vehicle you wish to manufacture. The vehicle will carry fewer than 10 passengers and its GVWR will be 11,500 pounds. You were particularly interested in the type of operator's license that would be required of the driver. Driver licensing requirements for vehicle operators are determined by state law. Since the vehicle's GVWR will be less than 26,000 lbs, and the vehicle will presumably be designed to carry fewer than 15 passengers, the driver will not be required, under the Federal Highway Administration's (FHWA's) Commercial Driver Licensing (CDL) regulations, 49 CFR part 383, to qualify for a commercial driver license. However, some states require that drivers obtain a commercial driver license to drive vehicles that have lower GVWRs. The driver licensing requirements of the state in which the vehicle is registered, will apply. For more information about the CDL requirements, you can contact the FHWA Chief Counsel's office at (202) 366-0834. Vehicle classification is relevant for the regulations and standards of our agency. The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and motor vehicle equipment. Each FMVSS for motor vehicles applies to one or more particular types of vehicles, e.g., a standard might apply to passenger cars, buses, trucks, and/or trailers. To determine which FMVSSs apply to their vehicles, manufacturers classify their vehicles using the definitions in 49 CFR part 571.3 of NHTSA's regulations. Under part 571.3 (copy enclosed), your vehicle, which you said is built in a bus/truck chassis, appears to be a 'truck' or a 'multipurpose passenger vehicle.' Under part 567, a manufacturer must state the vehicle classification on the vehicle's certification label and certify that its motor vehicle complies with all applicable FMVSSs. NHTSA may take issue with a manufacturer's vehicle classification in an enforcement proceeding if the agency does not agree with the manufacturer's classification. 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, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam2549OpenMr. Peter Cooper, 1228 Frick Building, Pittsburgh, PA 15219; Mr. Peter Cooper 1228 Frick Building Pittsburgh PA 15219; Dear Mr. Cooper: This responds to your March 1, 1977, question whether your client, retail tire dealer, would be in violation of the regulations of the National Highway Traffic Safety Administration (NHTSA) if he were to sell tires which do not contain an identification number as required by the NHTSA.; Paragraphs S4.3.1 and S4.3.2 of 49 CFR 571.109, Motor Vehicle Safet Standard No. 109, *New Pneumatic Tires*, requires passenger car tires to be labelled in accordance with Part 574. The absence of an identification number means that the tire is not in compliance with the requirements of Standard No. 109. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) (15 U.S.C. 1381 et seq.) provides in part that no person shall sell any item of motor vehicle equipment that is not in conformity with applicable standards. Since your client would be selling nonconforming tires, he would be in violation of our Act and, therefore, subject to the penalties imposed thereunder. Section 109(a) of the Act establishes a penalty of up to $1,000 for each violation of the Act, not to exceed $800,000 for any related series of violations.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0574OpenMr. W. M. Self, Marketing Manager, Downs-Clark, P.O. Box 1386, Brownwood, TX 76801; Mr. W. M. Self Marketing Manager Downs-Clark P.O. Box 1386 Brownwood TX 76801; Dear Mr. Self: This is in reply to your letter of December 30, 1971, concernin whether you must comply with the Certification regulations (49 CFR Part 567) in cases where you 're-barrel' or 're-deck' trailers. You describe these processes as installing a new tank (re-barreling) or platform deck (re- decking) on a used trailer under construction furnished by your customer, which includes axles, tires, wheels, springs, hangers, and internal brake assemblies, in serviceable condition.; You are not required to certify these vehicles as they are manufacture on used chassis and are considered by this agency to be used vehicles under section 108(b)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1397(b)(1)).; We are pleased to be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4864OpenGary P. Toth, Esq. General Motors Corporation Legal Staff New Center One Building 3031 West Grand Blvd. P.O. Box 33122 Detroit, MI 48232; Gary P. Toth Esq. General Motors Corporation Legal Staff New Center One Building 3031 West Grand Blvd. P.O. Box 33122 Detroit MI 48232; "Dear Mr. Toth: This responds to your request for an interpretation o how the requirements of Standard No. 209, Seat Belt Assemblies (49 CFR 571.209) would affect some dual-spring retractor designs GM is considering. Your letter said that these dual-spring retractors are designed so that a spring with a lower retraction force is or can be engaged when the safety belt is being worn by an occupant. When the safety belt is removed, a spring with a higher retraction force is engaged to effectively stow the belt webbing. Your letter also said that the retractor for the shoulder belt portion of the lap/shoulder belts on which these designs would be used is an emergency locking retractor (ELR). The minimum and maximum retractor force requirements for ELRs are set forth in S4.3(j)(5) and (6) of Standard No. 209. Those sections specify minimum and maximum retractor force requirements when the retractors 'are tested in accordance with the procedures specified in paragraph S5.2(j).' S5.2(j) specifies that, for the purposes of measuring the retractor forces, the webbing shall be fully extended from the retractor and then retracting the webbing to 75 percent extension plus or minus 2 inches. Your letter stated that your dual-spring retractor designs will comply with the minimum retractor force requirements when tested under the conditions specified in S5.2(j). This is because the higher retraction force will always be engaged under those conditions. It appears that, when the higher retraction force is engaged in these dual-spring retractor designs, the retractors will comply with the minimum retractor force requirements. However, when the lower retraction force is engaged, the retractor force is less than the minimum retractor force requirement. Because these dual-spring retractors comply with the retractor force requirements when tested under the conditions specified in S5.2(j) of Standard No. 209, your company is ready to certify these designs as complying with Standard No. 209. You are, however, concerned with the implications of a February 16, 1984 NHTSA interpretation addressed to Mr. Frank Pepe. In that instance, Mr. Pepe stated that the ELR had two tension modes that were activated by the vehicle door. The subject retractor operated in a high tension mode when the vehicle door was open, and in a lower tension mode when the vehicle door was closed. The agency concluded that, because Standard No. 209 does not distinguish between tension modes, the subject retractors would have to comply with all the requirements of the standard, including the minimum and maximum retraction force requirements, in both tension modes. Your letter asked us to reevaluate the conclusions reached in our February 16, 1984 letter to Mr. Pepe. We believe that the facts presented in your letter are significantly different than those that were presented in the Pepe letter, so the conclusions reached in the Pepe letter are not the same we would reach for your company's dual-spring retractors. In the case of the Pepe letter, the starting point for our analysis of whether the retractors would comply with the minimum and maximum retractor force requirements was the language of S4.3(j) in Standard No. 209, which directed us to the test conditions set forth in S5.2(j) of Standard No. 209. However, the test conditions in S5.2(j) complete extension of the webbing, followed by subsequent retraction to 75 percent extension did not adjust the Pepe retractors to either the high or low tension mode. Some additional action beyond the conditions specified in S5.2(j) had to be taken to select either the high or low tension mode. Since the selection of the high or low tension mode was not specified in S5.2(j) or elsewhere in Standard No. 209, NHTSA concluded that the retractor would have to be certified as complying with the retractor force requirements when adjusted to either the high or low tension mode. The GM retractors present a significantly different situation. According to your letter, the conditions set forth in S5.2(j) will adjust the GM retractors in a way so that the higher retraction force will always be engaged. Assuming this to be the case, no adjustments beyond the conditions specified in S5.2(j) would be necessary to select a tension mode for the retractors. In these circumstances, compliance with the minimum retractor force requirements would be determined only under the conditions specified in S5.2(j). Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5263OpenMr. Dennis G. Moore President Sierra Products Inc. 1113 Greenville Road Livermore, CA 94550; Mr. Dennis G. Moore President Sierra Products Inc. 1113 Greenville Road Livermore CA 94550; "Dear Mr. Moore: We have received your letter of September 29, 1993 with reference to the location requirements of Standard No. 108 for identification (i.d.) lamps. Table II of the standard in pertinent part specifies the following location for i.d. lamps: 'On the rear - 3 lamps as close as practicable to the top of the vehicle at the same height, as close as practicable to the vertical centerline . . . .' You reference at least two instances in the past 20 years or longer in which 'NHTSA has allowed the slight misalignment of I.D. lights because of `Practical' circumstances,' and have asked for copies of these interpretations. We are unaware of these interpretations. In their absence, you have asked for an interpretation of the phrase 'at the same height' that would permit the mounting height of the center lamp to deviate slightly from the height of the two lamps that flank it, as shown in your letter. You depict two other possible configurations in which the three lamps are mounted at identical heights. In one configuration, the lower edges of the outboard lamps hang below the frame 'making them vulnerable to being damaged or knocked off' in your opinion. In the second configuration, the lamps are raised and protected, but the center lamp is somewhat obscured by the 'typical roller or protective pad.' You deem these configurations undesirable for safety reasons. The question to be answered is whether the configuration you prefer is 'as close as practicable to the top of the vehicle at the same height' (note the absence of a comma between 'vehicle' and 'at'). The determination of practicability is initially that of the manufacturer. Unless it is clearly erroneous, NHTSA will not question it. In the absence of a superstructure, the frame location may be regarded as being 'as close as practicable to the top of the vehicle. . . .' Because 'at the same height' is part of the same phrase, practicability also governs placement of the lamps at the same height. A manufacturer may determine that, for the sake of practicability, i.d. lamps may be mounted at a height sufficient to protect them from breakage (the outboard lamps) and to ensure compliance with photometric requirements (the center lamp). The configuration you depict is sufficiently close to the literal reading of the phrase 'at the same height' that NHTSA would not question the manufacturer's determination of practicability with respect to the mounting height of the center i.d. lamp. Sincerely, John Womack Acting Chief Counsel "; |
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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.