NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: 1984-4.2OpenTYPE: INTERPRETATION-NHTSA DATE: 12/13/84 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Blue Bird Body Company -- Thomas D. Turner, Manager, Engineering Services TITLE: FMVSS INTERPRETATION TEXT: This responds to your letter dated December 5, 1983, to the National Highway Traffic Safety Administration (NHTSA) concerning the remanufacture of school buses. You requested NHTSA to confirm that when an old bus body is placed on a new chassis "the chassis is the incomplete vehicle and that the completed vehicle must conform to all applicable FMVSS and be properly certified based on a date no earlier than the date of manufacture of the chassis." You also requested an interpretation that the remanufacture of a school bus using a new body on an old chassis would be considered the manufacture of a new school bus which would be required to be certified based on the date of manufacture of the final stage, completed vehicle. You requested confirmation that NHTSA consider the school bus chassis to be the "incomplete vehicle" under 49 CFR Part 568, Vehicles Manufactured in Two or More Stages. "Incomplete vehicle" is defined in 49 CFR @ 568.2 as: an assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle. If the school bus chassis is completed to the extent that it has the above-listed components and merely needs the addition of a body by a final-stage manufacturer, it would be considered an incomplete vehicle. You are correct in your understanding of 49 CFR @ 567.5, Requirements for Manufacturers of Vehicles Manufactured in Two or More Stages. The completed vehicle must be properly certified by the final-stage manufacturer as conforming to all applicable Federal Motor Vehicle Safety Standards based on a date no earlier than the manufacturing date of the incomplete vehicle, and no later than the date of completion of the final-stage manufacture. The final-stage manufacturer must be consistent in its choice of completion date; it cannot choose one date to determine applicability of certain standards while choosing another date for other standards. You are also correct that the agency has previously said that the final-stage manufacturer's use of a new body on an old chassis does not amount to the manufacture of a new motor vehicle. The agency is aware of your concern regarding the remanufacture of school buses using a new bus body on an old chassis. NHTSA acknowledges your petition for rulemaking filed pursuant to 49 CFR Part 552, Petitions for Rulemaking, Defect, and Noncompliance Orders, and will conduct a technical review of your petition in accordance with this part.
SINCERELY, BLUE BIRD BODY COMPANY December 5, 1983 Administrator National Highway Traffic Safety Administration SUBJECT: PETITION FOR RULEMAKING AND/OR INTERPRETIVE ACTION Dear Ms. Stead: Blue Bird Body Company has received requests to mount new school bus bodies on used school bus chassis that are several years old. In the past these requests have been few and scattered and we have declined this business due to the obvious concerns dealing with safety, liability, compliance, certification, etc. We currently plan to continue with our practice of turning down these requests, however, with these requests becoming more numerous, we feel it is necessary to address the compliance and certification requirements involved in remanufacturing a school bus using a new body and a used chassis. It is our understanding, based on the December 29, 1977 NHTSA letter from Chief Counsel, Joseph J. Levin Jr. to the Honorable John Tower, reference NOA-30, and other NHTSA correspondence, that the manufacture of new motor vehicles includes the remanufacture of vehicles when such remanufacture is accomplished using a new chassis. Thus, remanufacture of a school bus using a new school bus chassis and a used school bus body constitutes the manufacture of a new school bus which would be subject to all applicable Federal Motor Vehicle Safety Standards in effect on the date of manufacture. The date of manufacture would be any date no earlier than the date of manufacture of the incomplete vehicle and no later than the date of completion of the final stage manufacture. It is our interpretation that the chassis is the incomplete vehicle and therefore, the date of manufacture of the chassis is the earliest limiting date for the purposes of compliance and certification. Thus, a 1975 bus body, for example, built without FMVSS 221 Joint construction or FMVSS 222 Seats and Barriers, would have to be upgraded to meet these and other applicable standards if it were to be mounted on a 1983 school bus chassis and completed as a final stage vehicle. We request your confirmation that the chassis is the incomplete vehicle and that the completed vehicle must conform to all applicable FMVSS and be properly certified based on a date no earlier than the date of manufacture of the chassis. Assuming that the above interpretation is correct and confirmed by NHTSA, it is the opinion of Blue Bird Body Company that the manufacture of school buses using new chassis is a safe and acceptable practice because both body and chassis will be required to conform to current FMVSS and the completed vehicle is required to be properly certified. The situation discussed in the first paragraph above, however, where school buses are remanufactured using a new body and an old chassis causes us concern. If the NHTSA does not consider this practice as manufacture of a new school bus, then apparently, no certification would be required and the vehicle would not have to conform to current FMVSS. If the agency does consider the remanufacture of school buses using new bodies and old chassis as the manufacture of a new vehicle, then questions of responsibility for compliance of the incomplete vehicle (the chassis), certification procedures, dates of effectivity, etc., are presented and must be addressed. For example, if a 1983 school bus body were to be mounted on a 1975 school bus chassis and completed as a school bus, what date would be used in determining the FMVSS that apply to the completed vehicle? If the 1975 date of manufacture of the incomplete vehicle (the chassis) is used, then the completed school bus would not be required to have FMVSS 221 Joint Construction or FMVSS 222 Seats and Barriers. We do not believe this would be an acceptable situation in terms of safety nor in the best interest of the school buses' owner, operator, passengers, the manufacturer of the incomplete and/or completed vehicle, the NHTSA or the pupil transportation industry in general. In the interest of safety and for the benefit of all parties concerned, Blue Bird Body Company requests that the NHTSA consider the situations discussed herein, initiate Rulemaking action and/or issue appropriate interpretations, to address the remanufacture of school buses. We feel appropriate action concerning remanufacture of school buses using new bodies on old chassis would be to (1) define this as the manufacture of a new vehicle to which FMVSS apply, (2) require that remanufactured school buses using new bodies on old chassis meet all applicable FMVSS and be certified based on the date of final manufacture of the final stage, completed vehicle. I trust that this letter provides sufficient information to NHTSA to enable proper action to be taken. If Blue Bird can be of any assistance or further information is needed, please feel free to contact me. Thomas D. Turner Manager Engineering Services C: WILBUR RUMPH -- V.P. ENGINEERING |
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ID: 1982-2.8OpenDATE: 04/21/82 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Cosco TITLE: FMVSS INTERPRETATION TEXT: This is to follow-up on your phone conversation with Mr. Stephen Oesch of my staff concerning the application of section 5.4.3.3 and 5.4.3.4 of Standard 213, Child Restraint Systems, to harnesses. If a harness is used as a portion of child restraint system, such as a booster seat, it must comply with the requirements of S5.4.3.3. If a harness is to be used alone, without any other structure, as a child restraint system, it must comply with section 5.4.3.4 of the standard. If you have any further questions, please let me know. |
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ID: nht90-4.53OpenTYPE: Interpretation-NHTSA DATE: November 6, 1990 FROM: J. P. Henries -- Captain, Safety Officer, Virginia State Police TO: Paul Jackson Rice -- Chief Counsel TITLE: None ATTACHMT: Attached to letter dated 12-26-90 from P.J. Rice to J.P. Henries (A37; Std. 208) TEXT: Attached you will find a copy of your letter of September 10, 1990, to Mr. Rembert Ryals, Esq., concerning an interpretation of Standards No. 208 and 209. At present the rules and regulations of Virginia's Official State Inspection Program require any 1963 and subsequent model vehicle designed and licensed primarily for passenger use, to be equipped with adult safety lap belts for at least two front seats or a combination of lap belts and shoulder straps or harnesses. In your letter to Mr. Ryals, you describe certain vehicles which were permitted to be manufactured without lap belts if they meet certain criteria. This being the case, how can our safety inspectors readily identify a vehicle which is not required to be equipped with a lap belt? Your assistance in this matter is appreciated. |
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ID: nht93-8.6OpenDATE: November 10, 1993 FROM: Cheryl Graham -- District Manager, Northeast Region, ARI TO: Chief Counsel's Office -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 2/7/94 from John Womack to Cheryl Graham (A42; VSA Sec. 108(a)) TEXT: I have spoken to several representatives of the Department of Transportation who were extremely helpful in providing me with information on brake light regulations, however, they suggested I write to you for a final determination on this subject. Background: I work for a fleet leasing company and a client of mine, with a substantial fleet of cars across the country, wishes to install additional brake lights with the hopes of reducing rear-end collisions. The intent is to install an additional light at each side of the rear window. These lights would be the same color as the other brake lights and would illuminate simultaneously. The vehicle manufacturers do not offer this as an option and the work would be performed by an after-market installer, not yet determined. When I initially investigated this request, I obtained copies of Federal Registers Volume 48, No. 202 and Volume 49, No. 97 as well as excerpts from the NHTSA Manual, Part 571.108. On page 236, S5.4(a) states that "No high-mounted stop lamp shall be combined with any other lamp or reflective device, other than with a cargo lamp." There were also several paragraphs referring to the positioning of high-mount stop lamps. My interpretation was that additional stop lights were not permitted. However, subsequent conversations with the Office of Rulemaking for NHTSA have led me to believe that they are permitted. Therefore, my letter to you. I would appreciate it if you could respond to me in writing as to whether my client can have the additional lights installed. Also, if the work is done improperly and results in an accident, where does the liability lie? As a leasing company, we are the registered owners of the vehicle but would have no direct control over the after-market installation. Insurance coverage is the responsibility of the lessee. Your assistance in this matter is greatly appreciated. If you need to contact me by phone, please feel free to do so at 609-778-1500. |
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ID: nht78-1.1OpenDATE: 12/12/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Thomas Built Buses, Inc. TITLE: FMVSS INTERPRETATION TEXT: Mr. James Tydings Thomas Built Buses, Inc. P.O. Box 2450 High Point, NC 27261 Dear Mr. Tydings: This responds to your November 7, 1978, question whether the National Highway Traffic Safety Administration's (NHTSA's) October 13, 1978, interpretation of the Ninth Circuit air brake ruling has revoked the exclusion of school buses from the "no lockup" requirements of Standard No. 121, Air Brake Systems. You also ask if a bus which is designed identically to a school bus qualifies for the exclusion from "no lockup" requirements if it is purchased and used for a purpose other than as a school bus. The answer to the first question is no. The exclusion of school buses from the stopping distance requirements of Standard No. 121 (S5.3.1) remains in effect and was not altered by the October 13, 1978, interpretation. The answer to the second question is also no. The exclusion from service brake stopping distance requirements (including the "no lockup" requirement) is limited to school buses, which are defined at 49 CFR S 571.3 as follows: "School bus" means a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation. The buses you describe would not qualify as "sold ... for purposes that include carrying students to and from school or related events." Therefore, they would not qualify for the school bus exclusion. Sincerely, Original Signed By Joseph J. Levin, Jr. Chief Counsel |
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ID: nht94-3.67OpenTYPE: INTERPRETATION-NHTSA DATE: July 14, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Donald W. Vierimaa -- Vice President-Engineering, Truck Trailer Manufacturers Associations TITLE: NONE ATTACHMT: Attached to a letter dated 6/1/94 from Donald W. Vierimaa to John Womack TEXT: This responds to your letter of June 1, 1994, requesting an interpretation of Motor Vehicle Safety Standard No. 108. You have asked whether the term "underride protection device" as used in S5.7.1.4.1 in Standard No. 108 "only include the device yet to be required by NHTSA or would it include the device described in TTMA RP No. 92?" At present, the term "rear underride protection device" as used in Standard No. 108 means the common "ICC bumper" described by the Federal Highway Administration in 49 CFR 393.86, or a similar device that the manufacturer of a trailer has provided regard less of whether it is required by 49 CFR 393.86. Thus, it presently includes the device described in TTMA RP No. 92. You have informed us that some manufacturers are installing guards with round cross sections, and some with square cross sections rotated 45 degrees which results in a "diamond" shape orientation. In addition, on some trash trailers, a curved hook grabs and holds the round cross section guard while trash is loaded into the trailers. You have asked whether a 38 mm wide retroreflective strip of sheeting applied to these guards will comply with Standard No. 108. S5.7.1.4.1(c) of Standard No. 108 specifies only that the strip shall be applied "across the full width of the horizontal member of the rear underride protection device." Although the reflective material is certified by its manufacturer for photometric c onformance in the vertical position, Standard No. 108 has not been interpreted to require structural changes in trailers for the sole purpose of enhancing the conspicuity installation. The agency's decision to avoid exceptions for trailers with unusual configurations was based on the expectation that manufacturers would use 2 their available structures for conspicuity material, rather than re-engineer them. Thus, we believe that the application of 38 mm wide sheeting to either of these guards would comply with S5.7.1.4.1(c). |
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ID: 0047Open Mr. Donald W. Vierimaa Dear Mr. Vierimaa: This responds to your letter of June 1, 1994, requesting an interpretation of Motor Vehicle Safety Standard No. 108. You have asked whether the term "underride protection device" as used in S5.7.1.4.1 in Standard No. 108 "only include the device yet to be required by NHTSA or would it include the device described in TTMA RP No. 92?" At present, the term "rear underride protection device" as used in Standard No. 108 means the common "ICC bumper" described by the Federal Highway Administration in 49 CFR 393.86, or a similar device that the manufacturer of a trailer has provided regardless of whether it is required by 49 CFR 393.86. Thus, it presently includes the device described in TTMA RP No. 92. You have informed us that some manufacturers are installing guards with round cross sections, and some with square cross sections rotated 45 degrees which results in a "diamond" shape orientation. In addition, on some trash trailers, a curved hook grabs and holds the round cross section guard while trash is loaded into the trailers. You have asked whether a 38 mm wide retroreflective strip of sheeting applied to these guards will comply with Standard No. 108. S5.7.1.4.1(c) of Standard No. 108 specifies only that the strip shall be applied "across the full width of the horizontal member of the rear underride protection device." Although the reflective material is certified by its manufacturer for photometric conformance in the vertical position, Standard No. 108 has not been interpreted to require structural changes in trailers for the sole purpose of enhancing the conspicuity installation. The agency's decision to avoid exceptions for trailers with unusual configurations was based on the expectation that manufacturers would use
their available structures for conspicuity material, rather than re-engineer them. Thus, we believe that the application of 38 mm wide sheeting to either of these guards would comply with S5.7.1.4.1(c). Sincerely,
John Womack Acting Chief Counsel ref:108 d:7/14/94
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1994 |
ID: nht87-3.40OpenTYPE: INTERPRETATION-NHTSA DATE: DECEMBER 9, 1987 FROM: ROBERT CUZZI -- BREDA TRANSPORTATION, INC. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA TITLE: 020-1287 ATTACHMT: MEMO DATED 6-17-88, FROM ERIKA Z. JONES, TO ROBERT CUZZI, STD 301 TEXT: My company, Breda Transportation, Inc., is currently working on a contract for the design, manufacture, and delivery of 236 articulated buses to the city of Seattle. the buses will be designed and manufactured in Italy, with final assembly in the United States. The buses' fuel tank will be built in Italy, and my question regards this. I need to know what federal standards and regulations, if any, refer to the fuel tank. Yesterday, 12/8/87, I spoke to Ms. Deidre Hom of your office, and she informed me that FMV SS 301 applies to fuel tanks, but for vehicles with a GVWR of 10,000 pounds or less. There are, it seems, no applicable FMVSS standards. Could you please confirm this, in writing, or advise me if there are any applicable federal standards which pertain to bus fuel tanks? Your assistance is greatly appreciated. |
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ID: 08_002292-dfOpen
Mr. Greg Broemeling Idaho Tote Dolly, Inc. 27980 North Juliaetta Grd. Juliaetta, ID 83535 Dear Mr. Broemeling: This responds to your email inquiry to the National Highway Traffic Safety Administration (NHTSA) concerning the classification of your product, The Idaho Tote, under NHTSA regulations. Your email, which you originally sent to Mr. David Coleman of NHTSAs Office of Vehicle Safety Compliance, was referred to my office for reply. We have also received a letter from U.S. Senator Michael D. Crapo on your behalf concerning The Idaho Tote, to which we are responding separately. By way of background, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, now codified as 49 U.S.C. Chapter 301, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable requirements. Title 49 U.S.C. Chapter 301 authorizes NHTSA to issue and enforce Federal motor vehicle safety standards (FMVSS) applicable to new motor vehicles and new items of motor vehicle equipment, which require minimum levels of safety performance. In your email communication to NHTSA, you indicated that you disagree with a recent Idaho Transportation Department classification of The Idaho Tote as a trailer and asked for our opinion on the matter. Keep in mind that State and Federal definitions of types of motor vehicles are relevant for different purposes. State law regulates, among other things, titling, licensing, and other aspects of motor vehicle use requirements. NHTSAs regulations apply to the manufacture and sale of new motor vehicles and specify, among other things, the requirements of this agency that new vehicles must meet according to the vehicle type. NHTSA does not interpret the laws of the individual States, such as Idahos definitions of motor vehicle type. Under NHTSAs regulations, based on the information supplied to this agency and for the reasons explained below, The Idaho Tote would be considered a trailer. The term motor vehicle is defined in the controlling statute (49 U.S.C. 30102) as a vehicle that is driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways. For purposes of applying the FMVSS, NHTSA defines vehicle types as set forth in 49 CFR 571.3. Trailer, which is one of those vehicle types, is defined in the agencys regulations at 49 CFR 571.3(b) as a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle. In your letter to Senator Crapo, you described The Idaho Tote as an external toy hauler with its own wheels and axle, which attaches to the towing vehicle by two main frame rails that are bolted to an attachment which is, in turn, welded to the frame of a truck or other towing vehicle. You stated that because The Idaho Tote is able to articulate up and down on the bolts, it eliminates any stress to the frame from road irregularities. You further stated that because it is attached to the towing vehicle by means of the two rails, the tote cannot swerve, sway, or jackknife, as can a trailer that is attached to a towing vehicle at a single pivot point. Under NHTSAs regulations (49 CFR 571.3(b)), a unit is a trailer if it is a motor vehicle (i.e., a vehicle that is driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways) and is designed for carrying persons or property and for being drawn by another motor vehicle. As is evident from our definition of trailer, the manner in which a unit is attached to a towing vehicle has no bearing on the units classification as a trailer for the purpose of NHTSAs regulations. You described The Idaho Tote as having been developed as an external toy hauler. You also furnished photographs of the tote, which has a flat bed and side rails, carrying what appears to be a small off-road vehicle. Since your product meets the statutory definition of a motor vehicle and is designed for carrying property and for being drawn by another motor vehicle, we would consider The Idaho Tote to be a trailer under NHTSAs regulations.[1] An informational brochure for new trailer manufacturers is posted on our website at www.nhtsa.gov/cars/rules/maninfo. This brochure identifies and describes the FMVSS that apply to trailers, and certain procedural requirements that a motor vehicle manufacturer must meet under NHTSAs regulations. Those requirements include the need to obtain from the Society of Automotive Engineers a world manufacturer identifier (WMI) to be incorporated into the vehicle identification numbers (VINs) that a manufacturer must assign to motor vehicles manufactured for sale in the United States. A manufacturer must also submit VIN deciphering information to NHTSA at least 60 days before offering for sale a motor vehicle with the manufacturers VIN, as required by NHTSAs regulations at 49 CFR Part 565, Vehicle Identification Number Requirements.[2] A manufacturer must also submit to NHTSA identifying information on itself and the vehicles that it manufactures, as required under NHTSAs regulations at 49 CFR Part 566, Manufacturer Identification. Finally, a manufacturer must permanently affix to each motor vehicle it manufactures for sale in the United States a label that, among other things, identifies the manufacturer and the vehicles date of manufacture, and states that the vehicle complies with all applicable FMVSS in effect on that date. This requirement is reflected in NHTSAs regulations at 49 CFR Part 567, Certification. Finally, you noted in the letter you sent to Senator Crapo that you believed that Mr. Coleman of NHTSA, with whom you also communicated by telephone about your product, supported your views and recommended that you plead your case to the Idaho State Senate. In a follow-up conversation with NHTSAs Office of Chief Counsel, Mr. Coleman recalled expressing a view that The Idaho Tote would be a trailer under NHTSAs regulations, and that he had only suggested that you discuss matters relating to licensing, titling, and registration requirements with state administrators. We regret any confusion or inconvenience the conversation may have caused. I hope this information is helpful. If you have any further questions, please do not hesitate to contact Ms. Sarah Alves of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel Enclosure ref:571 d.9/25/08 [1] You indicated in your letter to Senator Crapo that a July 25, 1995 letter from NHTSA to David Lowell supported a determination that your product was not a trailer. The letter does not support such a view. The letter addressed the issue of whether a vehicle was a truck or truck tractor under 49 CFR 571.3(b). Under 49 CFR 571.3(b), both trucks and truck tractors are defined as vehicles with motive power, among other characteristics. The Idaho Tote does not have its own engine and is not a truck or truck tractor under NHTSA regulations. [2] NHTSA published a final rule in the Federal Register of April 30, 2008, (73 FR 23367; NHTSA Docket 2008-0022), corrected 73 FR 28370, that made certain changes to the VIN regulation, effective October 27, 2008. A copy of these final rule documents is enclosed. |
2008 |
ID: nht88-2.22OpenTYPE: INTERPRETATION-NHTSA DATE: 05/08/88 FROM: MARTIN M. GINSBURG TO: ERIKA JONES -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 07/27/89 FROM STEPHEN P. WOOD -- NHTSA TO MARTIN M. GINSBURG -- PROLINE DESIGNS; REDBOOK A33; STANDARD 126; STANDARD 302 LETTER DATED 11/24/88 FROM MARTIN M. GINSBURG TO ERIKA Z. JONES -- NHTSA TEXT: After speaking to Mr. George Shifflett and Mr John Messera concerning Motor Vehicle Safety Standard No. 302, they recommended that I ask you for a legal interpretation indicating that I do not need to comply with this standard. My product consists of a window covering, also known as a curtain, which is made out of various fabric materials. This product is to be sold as an accessory for pick-up truck covers, also known as a shell or cap. This shell or cap is an after-market product. It is placed directly over the empty bed of the truck. There are no seats in the bed area or in the cover. Also this cover is segregated from the cab area. I would appreciate a legal interpretation concerning my need to comply with the 302 standard. Thank you |
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.