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: aiam3476OpenMr. Morris Wiant, Coleman Company, Inc., 250 North St. Francis, Wichita, KS 67202; Mr. Morris Wiant Coleman Company Inc. 250 North St. Francis Wichita KS 67202; Dear Mr. Wiant: This is in response to your telephone conversation of September 17 wit Roger Fairchild of this office, in which you requested written confirmation that your company's vehicle identification number system as described in your June 8 letter to this agency complies with Federal Motor Vehicle Safety Standard No. 115.; The National Highway Traffic Safety Administration does not giv advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4219OpenMr. Paul Meeker, Senior Product Designer, Century Products, Inc., 1366 Commerce Drive, Stow, OH 44224-1793; Mr. Paul Meeker Senior Product Designer Century Products Inc. 1366 Commerce Drive Stow OH 44224-1793; Dear Mr. Meeker: This responds to your letter to Mr. Vladislav Radovich of ou Rulemaking division, seeking an interpretation of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). Specifically, you noted that Collier-Keyworth now sells a child seat with a movable shield that is not spring- loaded. A movable shield that is not spring loaded will remain in position in front of the child seat occupant, even if the crotch strap attached to the shield is not properly fastened. You stated that your company would like to build a child seat with a movable shield that is not spring-loaded, and stated your opinion that shields need not be spring-loaded to comply with the requirements of Standard No. 213.; Your opinion is correct if read narrowly, because no provision o Standard No. 213 requires or ever has required movable shields on child restraints to be spring-loaded. However, if a child restraint incorporates a movable shield, section S.6.1.2.1.2 of Standard No. 213 specifies that the child restraint must be certified as complying with test configuration II. In test configuration II, the child restraint is subjected to a 20 mile per hour frontal crash. Section S6.1.2.3.1(c) provides that none of the child restraint belts are to be attached during this test, *unless* the belts are an integral part of the movable shield. Because of this requirement and the agency's interpretations thereof, child restraints have generally incorporated spring-loaded movable shields. This agency discussed these provisions and their applicability to the Collier-Keyworth non-spring-loaded shields at length in a July 3, 1985, letter to Mr. Frederick Locker. I have enclosed a copy of this letter for your information.; If you have any further questions about this subject after reviewin the letter to Mr. Locker, please contact Mr. Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3026OpenMr. Don M. Carnahan, Superintendent of Public Instruction, Old Capitol Building, Olympia, WA 98504; Mr. Don M. Carnahan Superintendent of Public Instruction Old Capitol Building Olympia WA 98504; Dear Mr. Carnahan: This responds to your May 10, 1979, letter asking about modification of buses to reduce seating capacity so that they no longer must comply with school bus safety standards.; First, let me clarify several points. In applying motor vehicle safet standards, we define a 'school bus' as a bus that transports children to or from school or related events. Our regulations further define 'bus' as a vehicle designed for carrying more than 10 persons. The phrase 'more than 10 persons' includes the driver. Accordingly, any vehicle that transports 11 people is a bus.; Your first problem appears to involve how to determine whether vehicle is designed to carry more than 10 persons. You indicate, for example, that some manufacturers have attached labels to their vehicles stating that they are designed to transport 15 passengers. However, some of the vehicles only have 8 or 9 seats. The National Highway Traffic Safety Administration measures vehicle capacity by the number of designated seating positions. Therefore, a vehicle that has 8 designated seating positions is not a bus. Such a vehicle would be a multipurpose passenger vehicle. If you are unsure of the vehicle type, refer to the vehicle certification label located on the door pillar post or on the inside of the door. That label lists the vehicle type as established by its manufacturer.; Any vehicle that is sent from its manufacturer and certified i compliance with multipurpose passenger vehicle (MPV) standards may be used to transport school children. These vehicles, since they are not buses, need not comply with the school bus safety standards. On the other hand, any vehicle that is certified as a bus, but not a school bus, should not be used to transport school children.; You ask whether a bus can be modified by removing seats so that i would no longer be of a passenger capacity that would require it to comply with the school bus safety standards. In theory such a modification is permissible. If a dealer makes such a modification, it must attach an alterer's label in accordance with Part 567.7, *Certification*, of our regulations. Since the dealer would be changing the vehicle type (from bus to MPV), it must make sure that the vehicle complies with all of the standards applicable to the new vehicle type. This might be difficult since some different standards apply to multipurpose passenger vehicles than apply to buses. However, it is conceivable that the initial vehicle manufacturer might be able to assure the dealer that the vehicle was built in compliance with all necessary standards. In such a case, the dealer could attach a label, and the vehicle would be properly certified.; If a school modifies its own vehicles, it need not attach a label Also, it need not assure that the vehicles comply with any standards. In the event of an accident, however, a school could incur substantial liability if it were operating a vehicle that was not in compliance with the appropriate safety standards.; In your final question you ask what agency enforces the standard against dealers and manufacturers. The National Highway Traffic Safety Administration enforces all of the motor vehicle safety standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3532OpenMr. Karl-Heinz Ziwica, Manager, Safety and Emission Control engineering, BMW of North America, Inc., Montvale, NJ 07645; Mr. Karl-Heinz Ziwica Manager Safety and Emission Control engineering BMW of North America Inc. Montvale NJ 07645; Dear Mr. Ziwica: This responds to your letter asking several questions about the use o informational readout displays in relation to FMVSS 101-80 *Controls and Displays*, 105 *Hydraulic Brake Systems* and 208 *Occupant Crash Protection*.; Each of your questions assumes the use of informational readou displays as telltales. The light intensity requirements of Standard No. 101- 80 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section requires that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; The agency has recently issued a notice of proposed rulemaking (NPRM that would permit informational readout displays to be used as telltales. We have enclosed a copy of that notice.; I would like to point out the following statement in the NPRM: >>>Various amendments may be necessary to Standard No. 101-80, as wel as to several other safety standards which include requirements for warning indicators, to permit fuller use of informational readout displays. The amendments proposed by this notice are a first step in that direction.<<<; We would welcome any comments that you might have on this matter t assist us in future rulemaking. You may also wish to consider submitting a petition for rulemaking on any changes that you believe should be made.; The following discussion explains the effect that the proposal woul have on your questions.; *Question 1* Your first question asks whether the words 'Fasten Seat Belts' may b used in an informational readout display instead of the seat belt warning symbol under FMVSS 101-80 and 208.the answer would be yes under the proposal. The NPRM states:; >>>Sections S4.5.3.3(b) and S7.3 of S571.208 would be amended to permi the words 'Fasten Belts' or Fasten Seat Belts' as an alternative to the seat belt warning symbol in informational readout displays.<<<; *Question 2* Your second question concerns the possibility of allowing cancellatio of telltales by voluntary action on the part of the driver. The question asks whether it is permissible to provide a push button that enables drivers to cancel telltales. The answer to this question, which is not dealt with in the NPRM, is no.; While the question is asked separately for the seat belt telltale an telltales not required by any safety standard in the first place, the answer is not dependent of that distinction. Section S5.3.3 of Standard No. 101-80 requires that the light intensity of each telltale shall not be variable and shall be such that, when activated the telltale and its identification are visible to the driver under all daytime and nighttime conditions. We interpret this section to mean that a telltale cannot be cancellable. If it were cancellable, the telltale would not meet requirements that it not be variable and that it be visible to the drive under all daytime and nighttime conditions.; We note that the activation requirements for the seat belt telltal depend on whether it is for a manual belt or automatic belt. For a manual belt, section S7.3 of Standard No. 208 states that the seat belt assembly provided at the driver's seating position must be equipped with a warning system that activates for a period of not less than 4 seconds and not more than 8 seconds a continuous or flashing light. Thus, while a manufacturer has the discretion to provide an activation time of between 4 and 8 seconds, the telltale still may not be cancellable.; Section S4.5.3.3 requires a different type of warning system fo automatic belts. While the audible signal must be activated for a period of not less than 4 seconds and not more than 8 seconds, the visual warning light must be activated for as long as the belt is not fastened.; *Question 3* Your third question asks whether it is permissible to use a information readout display to meet the visual brake warning system requirements of Standard NO. 105. The answer would be yes under the proposal.; Section S5.3.5 of Standard No. 105 states: >>>Each indicator lamp shall have a lens labeled in letters not les than 1/8-inch high, which shall be legible to the driver in daylight when lighted. The lens and letters shall have contrasting colors, one of which is red....<<<; It is our interpretation that the illuminated pattern of letters an glazing of an information readout display would constitute a 'lens labeled in letters.' This interpretation leaves unanswered other questions about whether a particular informational readout display would meet other requirements of Standard No. 105, such as the color requirement of section S5.3.5.; *Question 4* Your fourth question asks whether an informational readout displa specifying specific brake problems constitutes separate indicator lamps under the language of Standard NO. 105, if a brake warning lamp is present which separately fulfills the requirements of S5.3.5 of Standard No. 105. The answer is no.; Section S3 of Standard No. 105 specifies various performanc requirements for brake system indicators lamps. Under section S3.5, a manufacturer may meet the requirements either by a single common indicator or by separate indicator lamps.; It is our interpretation that if a manufacturer separately meets th requirements of section S3 by a single common indicator lamp, additional indicator lamps that are added voluntarily by the manufacturer are not subject to Standard No. 105's requirements.; *Question 5* Your fifth question asks about the requirements for an informationa readout display which is a telltale. The NPRM proposes the following language:; >>>S5.3.3.2 Telltales and gauges incorporated into informationa readout display--<<<; >>>(a) Shall have not less than two levels of light intensity, a highe one for day and a lower one for nighttime conditions.<<<; >>>(b) In the case of telltales and gauges not equipped with a variabl light intensity control, shall have a light intensity at the higher level provided under paragraph (a) of this section whenever the headlamps are not illuminated.<<<; >>>(c) In the case of telltales and gauges equipped with a variabl light intensity control, shall be visible to the driver under all daytime and nighttime conditions when the illumination level is set to its lowest level.<<<; The agency does find the system that you are considering developin very interesting. If you do submit a petition for rulemaking, there is one issue that we would appreciate your addressing. Our initial reaction to the idea of permitting drivers to cancel telltales is one of concern, since drivers might either cancel a telltale inadvertently or simply forget that they have done so. An informational readout display which flashed its warnings in sequence might answer those concerns. We would appreciate your addressing the safety consequences of those and any other alternatives that your might be considering.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3162OpenMr. W. G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your October 9, 1979, letter relating to the prope classification of school buses on certification labels.; Your letter is accurate in that school buses may be designated a 'school buses' on their certification labels. The agency thinks that for the purpose of clarity the term 'school bus' should be included on the label to further clarify the particular design of the bus. All other buses that comply only with standards applicable to non-school buses must be certified as 'buses'.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3498OpenMr. Ricky L. Newmayer, Mr. Jerry A. Corbett, Newbuilt Enterprises, 540 California Avenue, Sand City, CA 93955; Mr. Ricky L. Newmayer Mr. Jerry A. Corbett Newbuilt Enterprises 540 California Avenue Sand City CA 93955; Dear Messrs. Newmayer and Corbett: This responds to your letter of May 26, 1981, regarding Safety Standar No. 205, *Glazing Materials*. Please accept my apologies for the lateness of our response. You request permission to install a 'Ballistic Cube 2000' in 500 motor vehicles over a two-year period for experimental purposes. The 'Ballistic Cube 2000' is a protective cubicle made of Lexgard that is installed inside a vehicle. Lexgard, a bullet-resistant material, does not comply with all the requirements of Standard No. 205. You urge us to grant your request on the basis that the data generated from such an experiment would be relevant to a rulemaking proceeding initiated by General Electric. (General Electric has petitioned NHTSA to amend Standard No. 205 to permit the use of protective bullet- resistant shields in vehicles. The agency granted this petition on November 28, 1980.); Standard No. 205 is an equipment standard which applies to all glazin materials used in passenger cars, buses, trucks, and multipurpose passenger vehicles. all automotive glazing materials, including those used in the Ballistic Cube 2000, must conform to the standard's requirements. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) provides in part that no person shall sell or manufacture for sale any item of motor vehicle equipment that does not comply with any applicable Federal motor vehicle safety standard in effect on the date of the item's manufacture. Thus, if you were to manufacture for sale or sell a Ballistic Cube 2000 made of Lexgard or any other glazing material that does not comply with Standard No. 205, you would be in violation of section 108(a)(1)(A). (Section 108(b)(5) establishes that section 108(a)(1)(A) does not apply when the motor vehicle or item of motor vehicle equipment is intended solely for export and is so labeled.) Section 109 imposes a civil penalty up to $1,000 for each violation of Section 108.; We believe that installation of the Ballistic Cube 2000 in moto vehicles could possibly generate test data that could be valuable to the agency in the previously mentioned rulemaking proceeding. Unfortunately, however, NHTSA does not have the legal authority to grant you permission to make such an installation. NHTSA does not have statutory authority to exempt an equipment manufacturer from the requirements of Section 108(a)(1)(A) as it relates to motor vehicle equipment.; Section 123 of the Act authorizes the exemption of motor vehicles fro the safety standards. However, it does not authorize the exemption of motor vehicle equipment from equipment standards. As noted above, Standard No. 205 is an equipment standard applicable to glazing. Consequently, no exemption can be granted under section 123 that would excuse manufacturing, offering for sale or selling noncomplying glazing as part of the vehicles you wish to modify and sell, since you would also be considered an equipment manufacturer.; While the agency cannot grant you an exemption, it is pursuing th request made by G.E. regarding Lexgard. The agency anticipates issuing a notice of proposed rulemaking before the end of this year. If a final rule permitting the use of Lexgard were issued, you could commence manufacturing and installation of the Ballistic Cubes upon the effective date of that rule.; Even if that rule is issued, there may be other standards which must b considered. As we understand your materials, the installation of the Ballistic Cube 2000 in motor vehicles may affect the compliance of those vehicles with FMVSS No. 103, *Windshield Defrosting and Defogging Systems*, and FMVSS No. 201, *Occupant Protection in Interior Impact.* If you were to install a Ballistic Cube in a new vehicle, i.e., one that had not yet been purchased for purposes other than resale, you would violate section 108(a)(1)(A) if the vehicle no longer complied with one of those standards. Of course, since Standard Nos. 103 and 201 are vehicle standards, you could apply for an exemption from those standards. Section 108(a)(2)(A) of the Act would prohibit you from installing the Ballistic Cube in a used vehicle if such installation would destroy the vehicle's compliance with Standards 103 and 201.; The agency cannot definitively state whether installation of your cub in a motor vehicle would affect the compliance of the vehicle with Standards Nos. 201 or 103. NHTSA does not offer prior approval of compliance of any vehicle or equipment design with any safety standards before the manufacturer's certification of its product. It is the manufacturer's responsibility under the Act to determine whether its vehicle or equipment complies with all applicable safety standards and regulations and to certify its vehicle or equipment in accordance with that determination. The agency is willing to offer an opinion on whether a vehicle or motor vehicle equipment complies with a particular rule. Such an opinion is not binding on the agency or on the manufacturer. However, the information you have provided in your letter does not give us a sufficient basis on which to form an opinion. It would probably be difficult for the agency to offer an opinion concerning your compliance with Standard 203 regardless of the information you supplied, since that standard involves a dynamic performance test.; Apart from the requirements imposed by section 108(a)(1)(A) regardin compliance of safety standards, manufacturers of motor vehicle equipment also have general responsibilities under the Act regarding safety defects. Under sections 151 *et seq*., such manufacturers must notify purchasers about safety-related defects and remedy such defects free of charge. 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.; I am sorry we are unable to accommodate you in this matter. However since it is beyond our legal authority to do so, we have no choice but to make the decision set forth in this letter. Please contact this office if you have any questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2323OpenMr. Don Ellenberger, Volkswagen of America, 818 Sylvan Avenue, Englewood Cliffs, N.J. 07632; Mr. Don Ellenberger Volkswagen of America 818 Sylvan Avenue Englewood Cliffs N.J. 07632; Dear Mr. Ellenberger: I am writing to confirm your May 19, 1976, telephone conversation wit Mark Schwimmer of this office, concerning the effective dates of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.*; You were particularly concerned with one paragraph in the preamble o Notice 4 (41 FR 18659, May 6, 1976, Docket No. 71-19). That notice delayed the effective dates of certain requirements of the standard. The paragraph in question is:; >>>Manufacturers should note that, apart from the changed effectiv date for the requirement in S5.1.1 that vehicles be equipped with properly marked rims, there is no delay in the September 1, 1976, effective date of the standard's basic requirements, S5.1 (*Tire and Rim Selection*).<<<; Section S5.2, *Rim Marking*, is the only section of the standard tha applies directly to rims. Section S5.1 applies directly to vehicles. As Mr. Schwimmer explained, however, two aspects of S5.1 (both found in S5.1.1) involve rims as well.; The first sentence of S5.1.1 includes a 'suitability' requirement: >>>...each vehicle...shall be equipped with...rims that are listed b the manufacturer of the tires as suitable for use with those tires...<<<; The second sentence, as amended by Notice 4, reads: >>>On and after September 1, 1979, each such vehicle shall be equippe with rims that meet the requirements of this standard.<<<; The paragraph in question is simply a reminder that the 'suitability requirement, among others, is effective September 1, 1976, as originally established in Notice 3 (41 FR 3478, January 23, 1976).; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam3861OpenMr. John A. Russo, Mr. Jerome Ramsey, Legal Services of Eastern Missouri, Inc., P.O. Box 4999A, Field Station, 625 N. Euclid Avenue, St. Louis, MI (sic) 63108; Mr. John A. Russo Mr. Jerome Ramsey Legal Services of Eastern Missouri Inc. P.O. Box 4999A Field Station 625 N. Euclid Avenue St. Louis MI (sic) 63108; Dear Mr. Russo and Mr. Ramsey: This is in response to your letter of August 10, 1984, concernin Missouri's odometer disclosure requirements.; The Missouri disclosure form fails to meet federal disclosur requirements. If Missouri wants to use its Certificate of Title in lieu of the separate Federal form, it must refer to the Motor Vehicle Information and Cost Savings Act, 15 U.S.C. S 1981 *et seq*., state the date of the transfer and provide a space for the purchaser's signature. The National Highway Traffic Safety Administration (NHTSA) considers this signature to be essential. It is an acknowledgment that the purchaser was aware of the mileage and prevents the purchaser from later alleging the contrary.; In addition, the Missouri title certificate fails to meet th requirements of 49 C.F.R. S 580.4(c). While it does provide a space for the odometer mileage, it fails to state that the transferor certifies 'that to the best of his knowledge the odometer reading reflects the actual miles or kilometers the vehicle has been driven.' Furthermore, the form must provide alternate statements that the odometer reading reflects the mileage in excess of 99,999 miles or kilometers or that the mileage is not actual and should not be relied upon.; Please be advised that, to date, Missouri has not requested approva from NHTSA for use of its Certificate of Title as a substitute for the Federal form. If you have any additional questions, please do not hesitate to contact Judy Kaleta of my staff at (202) 426-2992.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam2773OpenJanine M. Schulte, North Central Tank Repair, Box 300, Holdingford, MN 56340; Janine M. Schulte North Central Tank Repair Box 300 Holdingford MN 56340; Dear Ms. Schulte: This responds to your January 13, 1978, letter asking several question about a manufacturer's certification responsibilities under Part 568, *Vehicles Manufactured in Two or More Stages*.; In your letter, you enclosed a copy of a TBEA form and ask whether i complies with Federal regulations and where you can obtain copies. This form is supplied by TBEA to assist manufacturers in their own recordkeeping. It is not required by any Federal regulation. You should consult TBEA for copies of the form.; Secondly, you ask whether Standard No. 120, *Tire Selection and Rim for Motor Vehicles Other Than Passenger Cars*, has altered the responsibilities of the intermediate manufacturer. An intermediate manufacturer's responsibility for compliance with Standard No. 120 is the same as his responsibility for compliance with any other Federal motor vehicle safety standard.; In your third question, you ask whether the addition of a 'tag' o 'pusher' axle to a used chassis requires compliance with Standard No. 121, *Air Brake Systems*. The addition of one axle to a used chassis does not constitute the manufacture of a new chassis. Therefore, if the chassis were manufactured prior to the time that Standard No. 121 became effective, modification of the chassis would not need to comply with the standard. If the chassis already complies with the standard, you would be prohibited from rendering inoperative the compliance of the vehicle with the standard.; You ask what the penalties are for violation of the Federa certification requirements. Under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et seq*.) violations of the Act or regulations are punishable by $1,000 per violation up to a maximum of $800,000 for a related series of violations.; In your last question you ask whether the incomplete vehicle documen should remain with the intermediate or final stage manufacturer on completion of a vehicle. The final stage manufacturer should retain the incomplete vehicle document.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2289OpenMr. Robert M. Brodkey, President, Intercraft Corporation, P.O. Box 4854, Washington, D.C. 20008; Mr. Robert M. Brodkey President Intercraft Corporation P.O. Box 4854 Washington D.C. 20008; Dear Mr. Brodkey: This is in response to your March 29, 1976, letter concernin regulations applicable to farm tractor tires whose importation is contemplated by one of your clients.; Farm tractors are not 'motor vehicles' as that term is defined in th National traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et Seq.). Accordingly, tires designed exclusively for use on farm tractors are not 'motor vehicle equipment.' Therefore, the importation of such tires and tubes is not subject to Federal motor vehicle safety standards or other regulations issued by the National Highway Traffic Safety Administration. We are unaware of any other regulations of the Department of Transportation concerning such tires.; Yours truly, Stephen P. Wood, Assistant 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.