NHTSA Interpretation File Search Overview Search Tool Request an Interpretation

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

Displaying 6361 - 6370 of 16515

Interpretations	Date

ID: aiam3387 Open Mr. Kenneth C. Lenz, Jr., Hendrickson Mfg. Co., Mobile Equipment Division, 8001 West 47th Street, Lyons, IL 60534; Mr. Kenneth C. Lenz Jr. Hendrickson Mfg. Co. Mobile Equipment Division 8001 West 47th Street Lyons IL 60534; Dear Mr. Lenz: This responds to your November 25, 1980, letter asking whether an safety standards have been violated by a truck modification that you perform. In your modification, you alter a chassis to provide right-hand controls. The vehicle is then sent to a final-stage manufacturer for completion.; As an incomplete vehicle manufacturer, you are required to attach th appropriate label to the vehicle in accordance with Part 567, Certification. That label makes certain statements about the compliance of the vehicle with safety standards as a result of your modifications.; You ask whether any safety standards have been violated by you modifications. It is impossible for the agency to determine compliance without testing one of your vehicles. You list several changes that you make to the vehicle, including the addition of: a foot throttle, foot service brake, hand spring brake, turn signal, transmission selector, and steering wheel. The agency has safety standards that govern many of these devices. These standards are found in Volume 49 of the Code of Federal Regulations, in Part 571. It is a manufacturer's responsibility to ensure that its vehicles comply with these standards. The only advice that we can offer is that nothing precludes the type of modifications that you propose. The installation of right-hand controls is permissible as long as the compliance with all safety standards is maintained.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam0952 Open Mr. Richard H. Hardesty, III, Marketing Specialist-Lighting, Plastics Department, E. I. Dupont De Nemours & Company, Wilmington, DE, 19898; Mr. Richard H. Hardesty III Marketing Specialist-Lighting Plastics Department E. I. Dupont De Nemours & Company Wilmington DE 19898; Dear Mr. Hardesty: This is in reply to your letter of October 11, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You ask whether the following components are subject to the requirements of the standard: horn buttons, decorative medallions, control knobs and handles, instrument dials and faces, break resistant mirrors, and lighting fixture lenses or diffusers.; The components that must meet the requirements of the standard ar listed in Paragraph S4.1. None of the components you have asked about are specifically listed in Paragraph S4.1, and normally will not be subject to the requirements. However, components may nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash,' or to the extent that they form part of a component listed under Paragraph S4.1. For example, we might consider a decorative medallion that forms part of the surface of a front or side panel to be incorporated into the panel and therefore subject to the standard.; In answer to your request for 'the text of the proposed amendment...i preparation which will establish numerical size...and some information on when it will be incorporated into MVSS- 302.' I have no public information on this subject at this time.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1640 Open Mr. Jack M. Dubard, Dubard & Vail, P.O. Box 38, Bonneville, MS 38829; Mr. Jack M. Dubard Dubard & Vail P.O. Box 38 Bonneville MS 38829; Dear Mr. Dubard: This responds to your October 11, 1974, letter (JAH:nh) asking whethe a truck body manufactured in part before and in part after the effective date of Standard No. 121, Air brake systems, must conform to the requirements of that standard. Standard No. 121 becomes effective for trailers on January 1, 1975, and for trucks and buses on March 1, 1975.; Standard No. 121 applies to air brake-equipped trucks, buses, an trailers, but not to truck bodies, which we consider to be items of motor vehicle equipment. Therefore, if your client only makes and sells truck bodies, his products are not subject to Standard No. 121.; If your client combines a chassis-cab with a truck body, he may in man cases be manufacturing a new motor vehicle, and as such, be responsible for compliance with Federal motor vehicle safety standards. I have enclosed 49 CFR Parts 567, Certification, and 568, Vehicles manufactured in two or more stages, which set out the certification responsibilities of persons who manufacture vehicles in stages.; Section 568.8 states that a 'final-stage manufacturer' (frequently thi will be one who installs a truck body on a chassis cab) must certify the vehicle as conforming with all standards effective as of the date of manufacture of the 'incomplete vehicle,' the date of final completion, or any date between those two dates. The manufacturer makes this certification based both on documentation furnished by the incomplete vehicle manufacturer under S 568.4, and on the changes he has made to complete the vehicle.; Therefore, if your client completes a truck by adding a truck body t it, he must certify that the vehicle meets all applicable standards as of a date chosen by him within the specified period. For example, a vehicle completed by the addition of a body on March 15, 1975, which used a chassis-cab manufactured on February 1, 1975, could be certified as complying with all standards as of February 1, 1975. In this case, the vehicle would not be subject to Standard No. 121.; Yours truly, Richard B. Dyson, Acting Chief Counsel
ID: aiam3368 Open Mr. G. Montgomery Spindler, Uniroyal, Inc., 1700 K Street, N.W., Washington, DC 20006; Mr. G. Montgomery Spindler Uniroyal Inc. 1700 K Street N.W. Washington DC 20006; Dear Mr. Spindler: This is in response to your letter of October 10, 1980, requestin clarification of the explanation of Treadwear grading in Figure 2 of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR S 575.104). You ask whether the explanation can be interpreted to mean that the relative treadwear performance of different tires on the UTQG test course in San Angelo, Texas will be consistent with the relative performance of the tires when driven under comparable conditions on other roads.; In experimental testing leading to promulgation of the UTQG regulation the National Highway Traffic Safety Administration (NHTSA) tested the treadwear of various tire lines not only on the San Angelo course but on roads in other parts of the country. The agency concluded that the UTQG grades established for different tires in testing on the San Angelo course accurately represent the relative performance of the tires obtainable on roads elsewhere in the United States, assuming that the tires to be compared are run under identical conditions.; The statement in Figure 2 of the UTQG regulation that a tire graded 15 would wear one and one-half times as well on the government course as a tire graded 100 was not intended to suggest that the tire would not wear one and one-half times as well on another course, if conditions of use were controlled. The term 'relative performance' in Figure 2 refers to the performance of tires in comparison to other tires, and the term 'norm' refers to the consistently obtainable relative performance of tires when tested under controlled conditions. Thus, the explanation indicates that, although the relative performance of different tires will be consistent when the tires are tested under controlled conditions, this relative performance may not be obtainable in actual use, if one tire is subjected to more severe road or weather conditions, abusive driving or improper maintenance.; NHTSA will provide confidential treatment for your October 10, 1980 letter.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1355 Open Continental Rubber Products, Inc., Minue Street, Carteret, New Jersey 07008; Continental Rubber Products Inc. Minue Street Carteret New Jersey 07008; Gentlemen: at the request of Continental Tire Company by letter of November 27 1973 (90316 - Ga/MAB/Sc), we are forwarding our response to their questions through you. They asked to know the lettering height to be used in compliance with the labeling requirements of Motor Vehicle Safety Standard No. 119.; The National HIghway Traffic Safety Administration is presentl considering the lettering height to be used for labeling required by Standard 119. Our decision as to lettering size will appear in the Federal Register as soon as possible after it has been made.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam2980 Open Mr. Mark E. Grayson, E. Grayson, Executive Assistant for Government Affairs, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Mark E. Grayson E. Grayson Executive Assistant for Government Affairs National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington DC 20005; Dear Mr. Grayson: This is in response to your letter of March 2, 1979, in which yo request clarification of several points relating to the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104), and the record retention requirements applicable to tire retreaders.; You inquire first as to the obligations of tire dealers under the UTQ regulation. As explained more fully in our recent letter to Mr. Tony Hylton of your organization, the UTQG regulation places the responsibility for supplying tire grading information on vehicle and tire manufacturers and tire brand name owners. These parties must make their own arrangements with tire distributors and dealers to assure that the required tire grading information reaches tire purchasers.; You ask whether bias-ply tires manufactured abroad prior to April 1 1979, but imported into the United States after April 1, must be labeled in accordance with the requirements of paragraph (d)(1)(i)(B) of the UTQG regulation (49 CFR 575.104(d)(1)(i)(B)). Paragraph (d)(1)(i)(B), which becomes effective on April 1, 1979 for bias-ply tires, applies to bias- ply tires manufactured after that date. The date of manufacture rather than the date of importation is controlling in determining whether tires fall within the tread labeling requirements of the UTQG regulation.; You also ask whether tires to which the UTQG labeling requirement apply can be imported into the United States without the required tread labels, provided adequate labels are attached at the tires' point of sale. The purpose of the UTQG labeling requirements is to provide information to assist consumers in tire purchasing decisions. Therefore, the tread labeling requirements of the regulation would be satisfied if labels are attached at the dealership prior to the time the tires are offered for sale. However, manufacturers and brand name owners should be cautioned that they will be held responsible should the dealer incorrectly label the tires or neglect to attach the required labels.; Finally, you inquire whether manufacturers of retreaded tires mus retain tire registration records compiled pursuant to Part 574, Tire Identification and Recordkeeping (49 CFR Part 574), in view of the recent exemption of retreaders from the registration requirements of that part. While the registration requirements of Part 574 no longer apply to the sale of retreaded tires, section 574.7(d) (49 CFR 574.7(d)) nonetheless requires that previously compiled records on retreaded tires be maintained for a period of not less than three years from the date the information was recorded by the tire manufacturer or his designee.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam3692 Open Mr. Anthony Lauro, President, VREDUSA, P.O. Box 279, Somerset, NJ 08873; Mr. Anthony Lauro President VREDUSA P.O. Box 279 Somerset NJ 08873; Dear Mr. Lauro: This responds to your recent letter asking if you can legally sel certain tires you have imported from the Netherlands. These truck tires have a DOT symbol on the sidewall but do not have a maximum load rating and corresponding inflation pressure labeled on the sidewall.; Under Federal law, these tires cannot be sold or otherwise introduce into interstate commerce because they do not comply with all requirements of Safety Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR S571.119). Paragraph S6.5(d) of Standard No. 119 (copy enclosed) requires that a maximum load rating and corresponding inflation pressure be labeled on both sidewalls of each tire subject to the standard. The tires described in your letter plainly do not meet this requirement. Hence, the DOT symbol on those tires is misleading, since that symbol is supposed to be a manufacturer's certification that the tires comply with all requirements of Standard No. 119.; Section 108 of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. 1397) specifies that no person shall sell or introduce into interstate commerce any item of motor vehicle equipment (which includes tires) unless the item is in conformity with all applicable safety standards. Section 109 of the Safety Act (15 U.S.C. 1398) sets forth a civil penalty of up to $1000 for each violation of section 108, and each of these nonconforming tires would be treated as a separate violation of section 108 if they were offered for sale or introduced into interstate commerce.; At this point, you have two legal courses of action open to you. Yo may have the tire manufacturer file a petition requesting an exemption from the noncompliance of these tires, arguing that the noncompliance is inconsequential as it relates to the safety of the tires. The procedures to be followed in filing a petition for an inconsequential noncompliance are set forth in the enclosed copy of 49 CFR Part 556, Exemption for Inconsequential Defect or Noncompliance. I cannot state at this time that the absence of maximum load information would be viewed as inconsequential, but we would certainly give full consideration to any petition the manufacturer might submit. If the petition were granted, you could sell these tires.; The other course of action available to you is to ship these tires bac to the manufacturer in the Netherlands and explain that they do not satisfy the requirements of Standard No. 119. I appreciate your efforts to ensure that you are complying with all applicable Federal regulations with respect to the sale of tires you import.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam4157 Open Mr. Francisco Dee Tan, President, FRG Industrial Corporation, 519 N. Alhambra Ave., #C, Monterey Park, CA 91754; Mr. Francisco Dee Tan President FRG Industrial Corporation 519 N. Alhambra Ave. #C Monterey Park CA 91754; Dear Mr. Tan: This is in reply to your letter of April 15, 1986, asking for ou approval of different types of rear stop lamps you wish to import.; The lighting devices depicted in the brochures that you enclosed ar not intended as original or replacement motor vehicle equipment, and therefore are not covered by Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. If you are required to execute a Form HS-7 at the time of entry, the proper declaration is that provided by Box 1: the equipment was manufactured on a date when no Federal standards applied to it. In any event, this agency has no authority to approve or disapprove items of motor vehicle equipment since the National Traffic and Motor Vehicle Safety Act provides for self- certification by manufacturers of their products subject to Federal standards.; In the absence of Federal requirements, whether the devices you wish t import are legal for installation and use would be determinable under the laws of the individual States where the devices will be sold and installed.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam0817 Open Mr. Russell E. MacCleery, Motor Vehicle Manufacturers Association, 320 New Center Building, Detroit, MI 48202; Mr. Russell E. MacCleery Motor Vehicle Manufacturers Association 320 New Center Building Detroit MI 48202; Dear Mr. MacCleery: This is in reply to your request of August 7, 1972, for the data use to support the conclusions we announced in Notice 20 of Docket 69-7 concerning the ignition interlock for the center front position and the ability of seat belt systems to meet a 60g, 3-millisecond injury criterion in 1975.; In evaluating the petitions for reconsideration of the center sea interlock requirements, we followed the techniques of cost/benefit analysis adopted in our earlier studies of passive restraints (see General Reference items 42, 43, and 99). The anticipated incremental benefit from an interlock at the center position was $9.70 per vehicle, which, when divided by the incremental cost of $7.00 supplied by Ford Motor Company (N16-69- 7-3), produced a favorable ratio of 1.4. Although the analysis was completed, it was used as a rough working paper and was not submitted to the docket. A typed draft of the analysis is being prepared for submission to the docket.; Although we decided to grant interim relief for belt systems from th 60g, 3-millisecond chest injury criterion, several manufacturers submitted data which indicated to us that their present systems were capable of meeting the criterion or that they were close enough that minor modifications would enable them to meet it. The data from your own organization (N13-69-7-16) showed that a number of cars were passing the criterion by comfortable margins. The Chrysler data, for example, revealed that in 9 tests no dummy recorded chest accelerations in excess of 50g's. Although General Motors, in its comment, submitted data on subcompacts which indicated a problem with chest accelerations, the data from their larger vehicles ranged between 38 and 52g's. (N13-69-7-20). Toyota also submitted test results with most accelerations in the range of 45-50g's, with only one test of a Corrolla appearing to show a marginal condition (N13-69-7-23).; From our research contracts, a number of sled tests have been conducte at Cornell Aeronautical Laboratory (General Reference No. 135), and most of these produced accelerations of between 30 and 50g's. From other sources have come data indicating that such improvements in belt design as the use of tear seams can produce significantly lower accelerations (see, e.g., General Reference items 161, 166, and 167).; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam3738 Open Mr. Gary Richards, VIRACON, Inc., 800 Park Drive, Owatonna, MN 55060; Mr. Gary Richards VIRACON Inc. 800 Park Drive Owatonna MN 55060; Dear Mr. Richards: This is to follow-up on your phone conversation with Stephen Oesch o my staff concerning the agency's regulations and standards which would be applicable to a sunroof kit that you plan to manufacture as an item of aftermarket motor vehicle equipment. As I understand it, you only plan to manufacture the sun roof kit and have no plans to install the sun roof in vehicles. You were, however, interested in any regulations or standards affecting the installation of such a sun roof kit.; Safety Standard No. 205, Glazing Materials, specifies performance an location requirements for all glazing materials used on motor vehicles, whether as original equipment or as replacement (aftermarket) equipment. As a manufacturer or fabricator of glazing you would have to certify that the glazing used in your sun roof complies with all applicable requirements of the standard, a copy of which is enclosed.; Manufacturers of motor vehicle equipment also have specifi responsibilities under the National Traffic and Motor Vehicle Safety Act regarding safety-related defects in their products. Sections 151 et seq. of the Act requires manufacturers to notify purchasers about safety-related defects in their product and to remedy such defects without charge. A copy of the Act and the applicable defect regulations are enclosed. In addition, Part 556, Manufacturer Identification, requires vehicle and equipment manufacturers to provide the agency with certain information concerning themselves and the products they manufacture. A copy of Part 556 is enclosed.; If a sun roof is added to a vehicle before sale of the vehicle to it first purchaser, the vehicle alterer is required by Part 567 of our regulations to certify that the vehicle, as altered, complies with all applicable safety standards. A copy of Part 567 is enclosed. If the sun roof is added by a manufacturer, dealer, distributor, or repair shop after the sale of the vehicle to its first purchaser, the vehicle does not have to be recertified. Such businesses are, however, prohibited from knowingly rendering inoperative any device or element of design installed in a vehicle in compliance with any safety standard. Thus, for example, they would have to ensure that they do not install the sun roof in such a way that the vehicle no longer complies with Standard No. 216, Roof Crush Resistance, a copy of which is enclosed.; If you have any further questions, please let me know. Sincerely, Frank Berndt, 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.

Interpretations	Date

ID: aiam3387 Open Mr. Kenneth C. Lenz, Jr., Hendrickson Mfg. Co., Mobile Equipment Division, 8001 West 47th Street, Lyons, IL 60534; Mr. Kenneth C. Lenz Jr. Hendrickson Mfg. Co. Mobile Equipment Division 8001 West 47th Street Lyons IL 60534; Dear Mr. Lenz: This responds to your November 25, 1980, letter asking whether an safety standards have been violated by a truck modification that you perform. In your modification, you alter a chassis to provide right-hand controls. The vehicle is then sent to a final-stage manufacturer for completion.; As an incomplete vehicle manufacturer, you are required to attach th appropriate label to the vehicle in accordance with Part 567, Certification. That label makes certain statements about the compliance of the vehicle with safety standards as a result of your modifications.; You ask whether any safety standards have been violated by you modifications. It is impossible for the agency to determine compliance without testing one of your vehicles. You list several changes that you make to the vehicle, including the addition of: a foot throttle, foot service brake, hand spring brake, turn signal, transmission selector, and steering wheel. The agency has safety standards that govern many of these devices. These standards are found in Volume 49 of the Code of Federal Regulations, in Part 571. It is a manufacturer's responsibility to ensure that its vehicles comply with these standards. The only advice that we can offer is that nothing precludes the type of modifications that you propose. The installation of right-hand controls is permissible as long as the compliance with all safety standards is maintained.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam0952 Open Mr. Richard H. Hardesty, III, Marketing Specialist-Lighting, Plastics Department, E. I. Dupont De Nemours & Company, Wilmington, DE, 19898; Mr. Richard H. Hardesty III Marketing Specialist-Lighting Plastics Department E. I. Dupont De Nemours & Company Wilmington DE 19898; Dear Mr. Hardesty: This is in reply to your letter of October 11, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You ask whether the following components are subject to the requirements of the standard: horn buttons, decorative medallions, control knobs and handles, instrument dials and faces, break resistant mirrors, and lighting fixture lenses or diffusers.; The components that must meet the requirements of the standard ar listed in Paragraph S4.1. None of the components you have asked about are specifically listed in Paragraph S4.1, and normally will not be subject to the requirements. However, components may nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash,' or to the extent that they form part of a component listed under Paragraph S4.1. For example, we might consider a decorative medallion that forms part of the surface of a front or side panel to be incorporated into the panel and therefore subject to the standard.; In answer to your request for 'the text of the proposed amendment...i preparation which will establish numerical size...and some information on when it will be incorporated into MVSS- 302.' I have no public information on this subject at this time.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1640 Open Mr. Jack M. Dubard, Dubard & Vail, P.O. Box 38, Bonneville, MS 38829; Mr. Jack M. Dubard Dubard & Vail P.O. Box 38 Bonneville MS 38829; Dear Mr. Dubard: This responds to your October 11, 1974, letter (JAH:nh) asking whethe a truck body manufactured in part before and in part after the effective date of Standard No. 121, Air brake systems, must conform to the requirements of that standard. Standard No. 121 becomes effective for trailers on January 1, 1975, and for trucks and buses on March 1, 1975.; Standard No. 121 applies to air brake-equipped trucks, buses, an trailers, but not to truck bodies, which we consider to be items of motor vehicle equipment. Therefore, if your client only makes and sells truck bodies, his products are not subject to Standard No. 121.; If your client combines a chassis-cab with a truck body, he may in man cases be manufacturing a new motor vehicle, and as such, be responsible for compliance with Federal motor vehicle safety standards. I have enclosed 49 CFR Parts 567, Certification, and 568, Vehicles manufactured in two or more stages, which set out the certification responsibilities of persons who manufacture vehicles in stages.; Section 568.8 states that a 'final-stage manufacturer' (frequently thi will be one who installs a truck body on a chassis cab) must certify the vehicle as conforming with all standards effective as of the date of manufacture of the 'incomplete vehicle,' the date of final completion, or any date between those two dates. The manufacturer makes this certification based both on documentation furnished by the incomplete vehicle manufacturer under S 568.4, and on the changes he has made to complete the vehicle.; Therefore, if your client completes a truck by adding a truck body t it, he must certify that the vehicle meets all applicable standards as of a date chosen by him within the specified period. For example, a vehicle completed by the addition of a body on March 15, 1975, which used a chassis-cab manufactured on February 1, 1975, could be certified as complying with all standards as of February 1, 1975. In this case, the vehicle would not be subject to Standard No. 121.; Yours truly, Richard B. Dyson, Acting Chief Counsel
ID: aiam3368 Open Mr. G. Montgomery Spindler, Uniroyal, Inc., 1700 K Street, N.W., Washington, DC 20006; Mr. G. Montgomery Spindler Uniroyal Inc. 1700 K Street N.W. Washington DC 20006; Dear Mr. Spindler: This is in response to your letter of October 10, 1980, requestin clarification of the explanation of Treadwear grading in Figure 2 of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR S 575.104). You ask whether the explanation can be interpreted to mean that the relative treadwear performance of different tires on the UTQG test course in San Angelo, Texas will be consistent with the relative performance of the tires when driven under comparable conditions on other roads.; In experimental testing leading to promulgation of the UTQG regulation the National Highway Traffic Safety Administration (NHTSA) tested the treadwear of various tire lines not only on the San Angelo course but on roads in other parts of the country. The agency concluded that the UTQG grades established for different tires in testing on the San Angelo course accurately represent the relative performance of the tires obtainable on roads elsewhere in the United States, assuming that the tires to be compared are run under identical conditions.; The statement in Figure 2 of the UTQG regulation that a tire graded 15 would wear one and one-half times as well on the government course as a tire graded 100 was not intended to suggest that the tire would not wear one and one-half times as well on another course, if conditions of use were controlled. The term 'relative performance' in Figure 2 refers to the performance of tires in comparison to other tires, and the term 'norm' refers to the consistently obtainable relative performance of tires when tested under controlled conditions. Thus, the explanation indicates that, although the relative performance of different tires will be consistent when the tires are tested under controlled conditions, this relative performance may not be obtainable in actual use, if one tire is subjected to more severe road or weather conditions, abusive driving or improper maintenance.; NHTSA will provide confidential treatment for your October 10, 1980 letter.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1355 Open Continental Rubber Products, Inc., Minue Street, Carteret, New Jersey 07008; Continental Rubber Products Inc. Minue Street Carteret New Jersey 07008; Gentlemen: at the request of Continental Tire Company by letter of November 27 1973 (90316 - Ga/MAB/Sc), we are forwarding our response to their questions through you. They asked to know the lettering height to be used in compliance with the labeling requirements of Motor Vehicle Safety Standard No. 119.; The National HIghway Traffic Safety Administration is presentl considering the lettering height to be used for labeling required by Standard 119. Our decision as to lettering size will appear in the Federal Register as soon as possible after it has been made.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam2980 Open Mr. Mark E. Grayson, E. Grayson, Executive Assistant for Government Affairs, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Mark E. Grayson E. Grayson Executive Assistant for Government Affairs National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington DC 20005; Dear Mr. Grayson: This is in response to your letter of March 2, 1979, in which yo request clarification of several points relating to the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104), and the record retention requirements applicable to tire retreaders.; You inquire first as to the obligations of tire dealers under the UTQ regulation. As explained more fully in our recent letter to Mr. Tony Hylton of your organization, the UTQG regulation places the responsibility for supplying tire grading information on vehicle and tire manufacturers and tire brand name owners. These parties must make their own arrangements with tire distributors and dealers to assure that the required tire grading information reaches tire purchasers.; You ask whether bias-ply tires manufactured abroad prior to April 1 1979, but imported into the United States after April 1, must be labeled in accordance with the requirements of paragraph (d)(1)(i)(B) of the UTQG regulation (49 CFR 575.104(d)(1)(i)(B)). Paragraph (d)(1)(i)(B), which becomes effective on April 1, 1979 for bias-ply tires, applies to bias- ply tires manufactured after that date. The date of manufacture rather than the date of importation is controlling in determining whether tires fall within the tread labeling requirements of the UTQG regulation.; You also ask whether tires to which the UTQG labeling requirement apply can be imported into the United States without the required tread labels, provided adequate labels are attached at the tires' point of sale. The purpose of the UTQG labeling requirements is to provide information to assist consumers in tire purchasing decisions. Therefore, the tread labeling requirements of the regulation would be satisfied if labels are attached at the dealership prior to the time the tires are offered for sale. However, manufacturers and brand name owners should be cautioned that they will be held responsible should the dealer incorrectly label the tires or neglect to attach the required labels.; Finally, you inquire whether manufacturers of retreaded tires mus retain tire registration records compiled pursuant to Part 574, Tire Identification and Recordkeeping (49 CFR Part 574), in view of the recent exemption of retreaders from the registration requirements of that part. While the registration requirements of Part 574 no longer apply to the sale of retreaded tires, section 574.7(d) (49 CFR 574.7(d)) nonetheless requires that previously compiled records on retreaded tires be maintained for a period of not less than three years from the date the information was recorded by the tire manufacturer or his designee.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam3692 Open Mr. Anthony Lauro, President, VREDUSA, P.O. Box 279, Somerset, NJ 08873; Mr. Anthony Lauro President VREDUSA P.O. Box 279 Somerset NJ 08873; Dear Mr. Lauro: This responds to your recent letter asking if you can legally sel certain tires you have imported from the Netherlands. These truck tires have a DOT symbol on the sidewall but do not have a maximum load rating and corresponding inflation pressure labeled on the sidewall.; Under Federal law, these tires cannot be sold or otherwise introduce into interstate commerce because they do not comply with all requirements of Safety Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR S571.119). Paragraph S6.5(d) of Standard No. 119 (copy enclosed) requires that a maximum load rating and corresponding inflation pressure be labeled on both sidewalls of each tire subject to the standard. The tires described in your letter plainly do not meet this requirement. Hence, the DOT symbol on those tires is misleading, since that symbol is supposed to be a manufacturer's certification that the tires comply with all requirements of Standard No. 119.; Section 108 of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. 1397) specifies that no person shall sell or introduce into interstate commerce any item of motor vehicle equipment (which includes tires) unless the item is in conformity with all applicable safety standards. Section 109 of the Safety Act (15 U.S.C. 1398) sets forth a civil penalty of up to $1000 for each violation of section 108, and each of these nonconforming tires would be treated as a separate violation of section 108 if they were offered for sale or introduced into interstate commerce.; At this point, you have two legal courses of action open to you. Yo may have the tire manufacturer file a petition requesting an exemption from the noncompliance of these tires, arguing that the noncompliance is inconsequential as it relates to the safety of the tires. The procedures to be followed in filing a petition for an inconsequential noncompliance are set forth in the enclosed copy of 49 CFR Part 556, Exemption for Inconsequential Defect or Noncompliance. I cannot state at this time that the absence of maximum load information would be viewed as inconsequential, but we would certainly give full consideration to any petition the manufacturer might submit. If the petition were granted, you could sell these tires.; The other course of action available to you is to ship these tires bac to the manufacturer in the Netherlands and explain that they do not satisfy the requirements of Standard No. 119. I appreciate your efforts to ensure that you are complying with all applicable Federal regulations with respect to the sale of tires you import.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam4157 Open Mr. Francisco Dee Tan, President, FRG Industrial Corporation, 519 N. Alhambra Ave., #C, Monterey Park, CA 91754; Mr. Francisco Dee Tan President FRG Industrial Corporation 519 N. Alhambra Ave. #C Monterey Park CA 91754; Dear Mr. Tan: This is in reply to your letter of April 15, 1986, asking for ou approval of different types of rear stop lamps you wish to import.; The lighting devices depicted in the brochures that you enclosed ar not intended as original or replacement motor vehicle equipment, and therefore are not covered by Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. If you are required to execute a Form HS-7 at the time of entry, the proper declaration is that provided by Box 1: the equipment was manufactured on a date when no Federal standards applied to it. In any event, this agency has no authority to approve or disapprove items of motor vehicle equipment since the National Traffic and Motor Vehicle Safety Act provides for self- certification by manufacturers of their products subject to Federal standards.; In the absence of Federal requirements, whether the devices you wish t import are legal for installation and use would be determinable under the laws of the individual States where the devices will be sold and installed.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam0817 Open Mr. Russell E. MacCleery, Motor Vehicle Manufacturers Association, 320 New Center Building, Detroit, MI 48202; Mr. Russell E. MacCleery Motor Vehicle Manufacturers Association 320 New Center Building Detroit MI 48202; Dear Mr. MacCleery: This is in reply to your request of August 7, 1972, for the data use to support the conclusions we announced in Notice 20 of Docket 69-7 concerning the ignition interlock for the center front position and the ability of seat belt systems to meet a 60g, 3-millisecond injury criterion in 1975.; In evaluating the petitions for reconsideration of the center sea interlock requirements, we followed the techniques of cost/benefit analysis adopted in our earlier studies of passive restraints (see General Reference items 42, 43, and 99). The anticipated incremental benefit from an interlock at the center position was $9.70 per vehicle, which, when divided by the incremental cost of $7.00 supplied by Ford Motor Company (N16-69- 7-3), produced a favorable ratio of 1.4. Although the analysis was completed, it was used as a rough working paper and was not submitted to the docket. A typed draft of the analysis is being prepared for submission to the docket.; Although we decided to grant interim relief for belt systems from th 60g, 3-millisecond chest injury criterion, several manufacturers submitted data which indicated to us that their present systems were capable of meeting the criterion or that they were close enough that minor modifications would enable them to meet it. The data from your own organization (N13-69-7-16) showed that a number of cars were passing the criterion by comfortable margins. The Chrysler data, for example, revealed that in 9 tests no dummy recorded chest accelerations in excess of 50g's. Although General Motors, in its comment, submitted data on subcompacts which indicated a problem with chest accelerations, the data from their larger vehicles ranged between 38 and 52g's. (N13-69-7-20). Toyota also submitted test results with most accelerations in the range of 45-50g's, with only one test of a Corrolla appearing to show a marginal condition (N13-69-7-23).; From our research contracts, a number of sled tests have been conducte at Cornell Aeronautical Laboratory (General Reference No. 135), and most of these produced accelerations of between 30 and 50g's. From other sources have come data indicating that such improvements in belt design as the use of tear seams can produce significantly lower accelerations (see, e.g., General Reference items 161, 166, and 167).; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam3738 Open Mr. Gary Richards, VIRACON, Inc., 800 Park Drive, Owatonna, MN 55060; Mr. Gary Richards VIRACON Inc. 800 Park Drive Owatonna MN 55060; Dear Mr. Richards: This is to follow-up on your phone conversation with Stephen Oesch o my staff concerning the agency's regulations and standards which would be applicable to a sunroof kit that you plan to manufacture as an item of aftermarket motor vehicle equipment. As I understand it, you only plan to manufacture the sun roof kit and have no plans to install the sun roof in vehicles. You were, however, interested in any regulations or standards affecting the installation of such a sun roof kit.; Safety Standard No. 205, Glazing Materials, specifies performance an location requirements for all glazing materials used on motor vehicles, whether as original equipment or as replacement (aftermarket) equipment. As a manufacturer or fabricator of glazing you would have to certify that the glazing used in your sun roof complies with all applicable requirements of the standard, a copy of which is enclosed.; Manufacturers of motor vehicle equipment also have specifi responsibilities under the National Traffic and Motor Vehicle Safety Act regarding safety-related defects in their products. Sections 151 et seq. of the Act requires manufacturers to notify purchasers about safety-related defects in their product and to remedy such defects without charge. A copy of the Act and the applicable defect regulations are enclosed. In addition, Part 556, Manufacturer Identification, requires vehicle and equipment manufacturers to provide the agency with certain information concerning themselves and the products they manufacture. A copy of Part 556 is enclosed.; If a sun roof is added to a vehicle before sale of the vehicle to it first purchaser, the vehicle alterer is required by Part 567 of our regulations to certify that the vehicle, as altered, complies with all applicable safety standards. A copy of Part 567 is enclosed. If the sun roof is added by a manufacturer, dealer, distributor, or repair shop after the sale of the vehicle to its first purchaser, the vehicle does not have to be recertified. Such businesses are, however, prohibited from knowingly rendering inoperative any device or element of design installed in a vehicle in compliance with any safety standard. Thus, for example, they would have to ensure that they do not install the sun roof in such a way that the vehicle no longer complies with Standard No. 216, Roof Crush Resistance, a copy of which is enclosed.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel

NHTSA Interpretation File Search

Overview

Understanding NHTSA’s Online Interpretation Files

Reasons interpretation letters in this database may not be applicable to your situation

Searching NHTSA’s Online Interpretation Files

More search options

Search Tool

NHTSA's Interpretation Files Search

ID: aiam3387

ID: aiam0952

ID: aiam1640

ID: aiam3368

ID: aiam1355

ID: aiam2980

ID: aiam3692

ID: aiam4157

ID: aiam0817

ID: aiam3738

Request an Interpretation

How do I submit a request for interpretation?