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: aiam1616OpenMr. Ira Hamilton, Hamilton & Bell, Box 3486 Terminal Annex, Spokane, WA 99220; Mr. Ira Hamilton Hamilton & Bell Box 3486 Terminal Annex Spokane WA 99220; Dear Mr. Hamilton: NHTSA Regional Administrator Hall has forwarded your letter of Augus 27, 1974 for our comments.; I enclose a copy of an information sheet: 'Where to Obtain Moto Vehicle Safety Standards and Regulations.' The standards that apply to 'motorcycles' are those that apply to mopeds. Some of these standards contain lesser requirements for 'motor-driven cycles'--motorcycles with 5 H.P. or less. I also enclose a copy of recent amendments to the standards, specifically directed towards motor-driven cycles including mopeds. We have no standard for snowmobiles as they are not 'motor vehicles' under our jurisdiction.; Our current fuel system integrity standard (No. 301) does not cove buses. The new standard effective September 1, 1975 (No. 301-75) will include a wider range of motor vehicles including buses of 10,000 lbs. or less gross weight, but only those that use fuel with a boiling point above 32 degrees F.; Four-wheel drive 'jeep'-type vehicles such as the Haflinger hav generally been classified by their manufacturer as 'multipurpose passenger vehicles.' This category of vehicle, is defined as a vehicle 'designated to carry 10 persons or less which is constructed either as a truck chassis or with special features for occasional off-road operation.' A Haflinger model 'designed primarily for the transportation of property or special purpose equipment,' however, would be a 'truck.'; I hope this answers your questions. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4414OpenMr. M. Iwase, Manager, Technical Administration Dept., Koito Mfg., Co., Ltd., Shizuoka Works, 500, Kitawaki, Shimuzu-shi, Shizuoka-ken, JAPAN; Mr. M. Iwase Manager Technical Administration Dept. Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimuzu-shi Shizuoka-ken JAPAN; Dear Mr. Iwase: This is in reply to your letter of September 15, 1987, with furthe reference to features of a 60 degree slant replaceable bulb headlamp presently being developed by Koito. You have explained that the aiming pads for the new system will be installed on the aiming adapter, rather than the headlamp lens, and have asked for confirmation that this is 'not illegal' under Motor Vehicle Safety Standard No. 108.; As you noted in your letter, paragraph S4.1.1.36(a)(2) specificall requires the exterior face of each replaceable bulb headlamp lens to have three aiming pads. The agency has no specifications for the design of aiming adapters, and a headlamp without aiming pads would be one that is not designed to conform to the standard.; The agency is examining concepts for aiming methods for other tha mechanical aim, but no amendments to Standard No. 108 are contemplated that would permit or require aiming pads to be on aiming adapters.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1246OpenMr. Pundalik K. Kamath, P.O. Box 560, Oshkosh, WI 45901; Mr. Pundalik K. Kamath P.O. Box 560 Oshkosh WI 45901; Dear Mr. Kamath: This is in reply to your letters of August 7 and August 23, 1973 concerning the conformity to Standard No. 121 of certain features in air brake systems submitted to you by suppliers.; Your first question is whether the volume of a supply reservoir tha lacks a check valve is to be included in arriving at the required reservoir volume of 12 times the full-travel service brake chamber volume. Our reply is that S5.1.2.1 includes the volume of all service and supply reservoirs, regardless of valving, and that the volume of the supply reservoir in question would therefore be included in the combined reservoir volume.; You next ask whether a system that has no isolated emergency reservoi can rely on its service reservoirs to provide air for the two emergency stops proposed as S5.7.3 by Docket No. 73-13, Notice 1 (38 F.R. 14963). Under this proposal, the stops would have to be accomplished with a single failure of a part (other than a common valve, manifold, brake fluid housing or brake chamber housing) designed to contain compressed air or brake fluid. If the system is designed so that no single failure, other than a valve, manifold, or housing failure, will cause a loss of air in both tanks, it would seem to be capable of meeting the proposed requirement even though it does not have an isolated emergency reservoir. However, if a single failure in a brake line would deplete the air in both service reservoirs, the system would be unable to meet S5.7.3 unless an emergency isolated reservoir were provided.; In answer to your last question, the emergency stops proposed in S5.7. would be conducted from an initial pressure in excess of the compressor cut-in pressure. The reservoirs would not be depleted by prior stops.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2893OpenMr. Edgar E. Lungren, Jr., Pullman Trailmobile, 200 East Randolph Drive, Chicago, IL 60601; Mr. Edgar E. Lungren Jr. Pullman Trailmobile 200 East Randolph Drive Chicago IL 60601; Dear Mr. Lungren: This responds to your October 19, 1978, questions about the effect o the *PACCAR v. NHTSA* decision (532 F2d. 632 (9th Cir. 1978)) on certain aspects of Standard No. 121, *Air Brake Systems*. This reply addresses several issues related to the questions you asked.; Standard No. 121 as a whole was not invalidated by the Court decision Only the 'road testing' requirements of S5.3.1, S5.3.2, and S5.7.1 for trucks and trailers were addressed by the Court, and only some of the performance requirements and test procedures associated with them were held invalid. Thus, requirements such as timing, dynamometer, and equipment specifications remain valid and enforceable.; One question raised is whether the court invalidated these 'roa testing' requirements and associated procedures only as of the October 11th entry of mandate, or whether the court found the requirements invalid back to their January and March 1975 implementation dates. While there are conflicting statements in the court's opinion about the holding on 'no lockup' and 60-mph stopping distances, we believe that these requirements are invalid from the effective date of the standard for affected vehicle types. This conclusion relies on the court's conclusion about the adequacy of promulgation 'at the time [the standard] was put into effect' (573 F2d. at 640).; Thus the NHTSA does not believe that a vehicle which lacks 'no lockup performance or the specified 60-mph stopping distance capability would be in noncompliance with Standard No. 121. Noncompliance enforcement of these performance aspects will, therefore, not be pursued.; A second question is whether a commercial facility (manufacturer distributor, dealer, or repair business) can disconnect or remove antilock systems that were installed prior to October 11, 1978, the date on which the court made its decision effective. With regard both to new vehicles in inventory and used vehicles in service that have been antilock equipped, S 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (the Act) states that --; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ....<<<; The issue is whether the antilock was 'installed .... in complianc with an applicable .... standard.' Because the NHTSA concluded that the 'no lockup' and 60-mph stopping distances have been invalidated from the effective date of the standard, we also conclude that a manufacturer could not have actually been installing antilock or the brake performance levels in satisfaction of such a requirement, however much intended. Therefore, the NHTSA would not consider it to be a violation of S 108(a)(2)(A) for a commercial facility to disconnect an antilock system or to provide instructions on how it can safely be disconnected. The NHTSA recommends that any modification be undertaken only after consulting with the manufacturer about the safest configuration of the particular vehicle.; I would emphasize that disconnection of systems prior to the firs retail sale may not have the effect of causing the vehicle to fail to comply with other applicable requirements.; The issue of disconnecting systems in service is totally different i the case of a manufacturer or agency determination that an antilock system contains a defect that relates to motor vehicle safety. Under S 154 of the Act, the vehicle manufacturer must provide an adequate repair of safety- related defects, unless replacement of the vehicle or refund of the purchase price is undertaken.'Adequate repair' is defined in S 159(4) not to include 'any repair which results in substantially impaired operation of a motor vehicle or item of replacement equipment.' The agency does not agree with the court's view that antilock systems have the potential to reduce highway safety, and therefore, anything other than repair of an antilock system containing a safety-related defect would be considered by the NHTSA to constitute substantial impairment of the motor vehicle.; A third question is whether Canadian-built (or U.S.-built for export trucks and trailers which comply with the Canadian air brake standard can now be imported since certain 'road testing' portions of the U.S. standard have been invalidated. The Canadian standard came into effect later than the U.S. standard and it differs in having no stopping distance, 'no lockup', timing, or dynamometer requirements. Thus, there may be differences between vehicles built for the U.S. and those built for Canadian service.; Operation of uncertified vehicles in the United States constitutes a importation in violation of S 108(a)(1)(A) of the Act if built after the applicable effective date of Standard No. 121. Enclosed is a letter to the Canadian Trucking Association on this subject. The invalidation of some of the differences between the U.S. and Canadian standards does not completely eliminate the disparity of required performance between the two groups of vehicles. This would apply both to vehicles in service and to newly manufactured vehicles that do not comply with Standard No. 121.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4044OpenThe Honorable Harold Rogers, U.S. House of Representatives, Washington, DC 20515; The Honorable Harold Rogers U.S. House of Representatives Washington DC 20515; Dear Mr. Rogers: Thank you for your letter on your constituent's behalf to former Chie Counsel Frank Berndt asking several specific questions about our motor vehicle safety standards for school buses. I hope this information is helpful to you in responding to your constituent. If you or your constituent need further clarification about how our requirements apply in a specific situation, please let me know.; Your questions were as follows: >>>1. Can a vehicle designed, manufactured, and sold as a truck, eve be considered a 'school bus' unless remanufactured, modified, or converted by a manufacturer or a manufacturer's dealer or distributor and certified as a school bus?<<<; The answer to your question depends on whether you are asking about vehicle being considered a 'school bus' under State or Federal law. Under Federal law, which applies to the manufacture and sale of new motor vehicles, the answer is no. A vehicle is certified only once, when manufactured as a new vehicle. With the one exception discussed below, there is no provision in our statutes or regulations for recertification of a used vehicle which has been modified so that it falls into a different category of vehicles. The National Traffic and Motor Vehicle Safety Act and regulations issued thereunder require manufacturers to classify their new motor vehicles and certify that their vehicles meet all Federal motor vehicle safety standards applicable to the vehicle type. Those determinations are only made by the manufacturer at the time the vehicle is originally manufactured. Since both the physical attributes underlying the vehicle types and the applicable safety requirements differ from type to type, a vehicle can be classified only as a single type. Therefore, a new vehicle manufactured and sold as a 'truck' is certified as meeting our safety standards for trucks and cannot be certified also as a vehicle meeting safety standards for school buses.; Our regulations do not prohibit used trucks from being modified fo pupil transportation purposes. Since our certification requirements apply only to the manufacture or alteration of new motor vehicles, the person performing the modification does not recertify the vehicle as a 'school bus' unless the modification of the vehicle is so extensive as to constitute a manufacture of a new vehicle. For example, a used truck chassis lacking requisite systems required by our regulations might be combined with a new school bus body. The completed school bus would be considered newly manufactured, and would have to be certified as a 'school bus.'; Used trucks which have been modified to carry school children might b considered 'school buses' under State law. State definitions of school buses determine the applicability of school bus operational requirements to vehicles. If the modifications to a truck bring it within a State's definition of 'school bus,' then the vehicle would be considered a school bus under State law and would have to comply with State requirements for school buses in order to be properly used as a school bus in that State.; >>>2. Do Federal Motor Vehicle Safety Standards apply only t manufacturers, their dealers and distributors?<<<; The answer to your question is no, because our motor vehicle safet standards apply to anyone who manufactures, distributes or sells new motor vehicles. Federal law requires manufacturers of new school buses to certify that their vehicles comply with all applicable school bus safety standards. In addition, distributors and sellers of new school buses must ensure that only complying school buses are sold. While new school buses are typically sold by their manufacturers or manufacturers' distributors and dealers, the responsibility to sell complying school buses rests with any person selling new school buses.; The Vehicle Safety Act applies also to persons who perfor manufacturing operations on previously certified *new* vehicles prior to the vehicles' first purchase in good faith for purposes other than resale. Such persons are considered 'alterers' under our regulations and are subject to requirements that they certify compliance with Federal Motor Vehicle Safety Standards. Alterers who significantly affect the configuration of a new motor vehicle previously certified to applicable safety standards must certify that the new vehicle, as altered, conforms to all applicable safety standards affected by the alteration in effect on the date of manufacture of the original vehicle or on the date the alterations were completed. In addition, the Vehicle Safety Act applies to commercial businesses performing operations on *new and used* motor vehicles. Section 108(a)(2)(A) of the Vehicle Safety Act (copy enclosed) states, in part:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .<<<; Thus, the requirements of our motor vehicle safety standards affec those aforementioned parties modifying or repairing new or used motor vehicles, by setting limits on the operations performed on those vehicles. Those persons are prohibited from either removing, disconnecting or degrading the performance of safety equipment installed in compliance with an applicable safety standard. There is no prohibition against an individual owner modifying his or her own vehicle.; >>>3. What is the difference between a tamperer and a modifier as the relate to Federal Motor Vehicle Safety Standards?<<<; Our regulations do not define the terms 'modifier' and 'tamperer. However, the terms are commonly used to describe persons who make changes to vehicles. The term 'modifier' is often used to describe persons making changes to new or used vehicles. As explained above, persons modifying a new motor vehicle prior to its first purchase are considered 'alterers' under our regulations and are subject to requirements that they recertify the vehicle. Commercial parties involved with modifying new or used vehicles are subject also to the 'render inoperative' prohibitions of Section 108(a)(2)(A).; 'Tamperers' often refer to persons modifying or removing safety system or equipment on used vehicles. Commercial parties involved in tampering are subject to the 'render inoperative' prohibitions of Section 108(a)(2)(A). Violations of Section 108(a)(2)(A) are punishable by civil penalties up to $1,000 per violation. Again, our regulations do not apply to individual owners modifying their own vehicles. Such modifications, however, would have to comply with State law.; >>>4. Who can make the certification that a vehicle meets applicabl Federal Motor Vehicle Safety Standards?<<<; Under the Vehicle Safety Act, manufacturers of new motor vehicle certify that their vehicles comply with all applicable motor vehicle safety standards. As suggested above, 'alterers' are considered to be vehicle manufacturers and therefore are also subject to certification requirements. Alterers certify that the vehicle, as altered, conforms to applicable safety standards affected by the alteration.; >>>5. Does the date of manufacture of a vehicle determine the specifi Federal Motor Vehicle Safety Standards that the vehicle has to meet?<<<; In general, the answer to this question is yes. The date of manufactur is one factor determining applicability of our motor vehicle safety standards. Each motor vehicle manufactured on or after the effective date of a safety standard is subject to requirements of that standard if, of course, the standard applies to that vehicle type. However, as explained above, 'alterers' affecting compliance with Federal safety standards by their alteration may choose the completion date of the alterations as the date by which to certify.; >>>6. Are passenger restraint systems required on school buses with manufacture date prior to April 1, 1977?<<<; In 1974, Congress directed NHTSA to issue motor vehicle safet standards for various aspects of school bus safety. Pursuant to that mandate, we issued Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which requires school buses to provide a passenger restraint system through a concept called 'compartmentalization'. The standard became effective on April 1, 1977, and applies to each school bus manufactured on or after that date. School buses manufactured prior to April 1, 1977, are not subject to compartmentalization requirements.; >>>7. Are there any Federal Motor Vehicle Safety Standards applicabl only to school buses prior to April 1, 1977?<<<; The answer is no. There are three safety standards that we issue exclusively for school buses, i.e., Standards No. 220, *School Bus Rollover Protection*, No. 221, *School Bus Body Joint Strength, and No. 222, *School Bus Passenger Seating and Crash Protection*. Those standards became effective April 1, 1977.; >>>8. Do school buses manufactured prior to April 1, 1977, have to mee FMVSS No. 217 and FMVSS No. 222?<<<; Standard No. 217 became effective September 1, 1973. School buse manufactured on or after that date and prior to April 1, 1977, had to meet Standard No. 217 *if* push- out windows or other emergency exits were provided. Pursuant to the 1974 Congressional mandate, NHTSA amended Standard No. 217 to require school buses manufactured on or after April 1, 1977, to contain additional emergency exits and set special requirements for those exits.; Standard No. 222 became effective on April 1, 1977. School buse manufactured prior to that date do not have to meet that standard.; Again, please contact my office if you or your constituent have an further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3781OpenMr. Jeff S. Brantner, 316 Whitebirch, Wenatches, WA 98801; Mr. Jeff S. Brantner 316 Whitebirch Wenatches WA 98801; Dear Mr. Brantner: This responds to your letter of November 9, 1983, to the Urban Mas Transit Administration, which was forwarded to this agency for reply, concerning legal requirements regulating window stickers. The following discussion addresses the Federal requirements applicable to sticker or other films applied to glazing materials in motor vehicles.; The National Highway Traffic Safety Administration has the authority t govern the manufacture of new motor vehicles and motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, we have promulgated Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance.; The agency has stated in past interpretations that films such as th type referred to in your letter are not glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, that manufacturer or dealer has to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Section 108(a)(1) prohibits any person from offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards.; After a new vehicle has been sold to the consumer, he may alter hi vehicle as he pleases, so long as he adheres to all State requirements. Under Federal law, the owner could install the film on glazing in his vehicle whether or not such installation adversely affected the light transmittance and abrasion resistance of his vehicle's glazing. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. 'Render inoperative' means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the Federal safety standards. Thus, none of those persons may knowingly install a film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.; Please contact Stephen Oesch of my staff if you have any furthe questions (202- 426-1834).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0007OpenMr. Louis F. Wilson Instant Traffic Lights 2580 W. Venice Boulevard Los Angeles, CA 90019; Mr. Louis F. Wilson Instant Traffic Lights 2580 W. Venice Boulevard Los Angeles CA 90019; Dear Mr. Wilson: This is in reply to your letter of February 20, 1991 with respect to the acceptability under Federal law of your product, the 'Instant Traffic Light. I regret that we do not appear to have a record of your earlier letters to the agency on this subject. The 'Instant Traffic Light' is a four-section unit intended to perform three functions, each indicated by a different color. A green light appears when the accelerator is applied, an amber light when the accelerator is released, and a red light when the brakes are applied. The lamp's shipping carton shows the unit mounted on the rear parcel shelf behind the rear window. The text on the carton says that the lamp is easy to assemble. You have asked whether the product meets Standard No. 108, whether it would be 'legal' in the U.S. 'and her territories', and whether the product could replace, or be an option to, the requirements of Standard No. 108 for the center high-mounted stop lamp. Finally, of the l6 States that have responded to your inquiry, an equal number (six) have indicated that the lamp is and is not acceptable to them, while the remaining four 'said they will follow the Federal requirement.' Standard No. 108 does not permit the center high-mounted stop lamp to be combined with any other lamp. This means that your product could not be used as original equipment on a passenger car, whether as standard equipment or as an option, or marketed and sold as replacement equipment for a center lamp on a passenger car that was originally equipped with it. However, Standard No. 108 does not apply to the 'Instant Traffic Light' if it is marketed or sold exclusively for use on passenger cars that were not originally required to be manufactured with the center stop lamp, i.e., those cars that were manufactured before September 1, l985. Under this circumstance, the question of the legality of use of the device is to be determined by the laws of the individual States. The 'territories' are 'States' for purposes of this discussion. Since there is no legal prohibition under Federal law for installation of your lamp only on older passenger cars, we presume that the four States that reserved their decision would permit it on pre - l985 vehicles registered and/or operating within their borders. We are aware that, nevertheless, there may be some owner interest in replacing original equipment center stop lamps with your product. We would like to advise that such replacement would be a violation of the National Traffic and Motor Vehicle Safety Act, if performed by a manufacturer, distributor, dealer, or motor vehicle repair business. There is no such restriction upon a vehicle owner who performs the replacement of the lamp himself. I hope that this responds to your questions. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam5205OpenMr. Dave Beidleman Arizona Department of Transportation Equipment Services; Mr. Dave Beidleman Arizona Department of Transportation Equipment Services; FAX 602-258-5193 Dear Mr. Beidleman: We have received your FAX of Jul 2, 1993, to the attention of Taylor Vinson of this Office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of rear identification lamps. The rear configuration of l0 dump trucks that are being constructed for the Arizona DOT is such that you would like to raise the center lamp of the three- lamp identification lamp cluster approximately 1 1/2 inches, the two outer lamps of the array cannot be raised due to the positioning of the underbody tailgate release mechanism. Table II of Standard No. 108 requires that the identification lamps be mounted 'as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline.' In our opinion, the lamps in an identification lamp cluster must be equally spaced laterally and mounted at the same height in order for the identification lamp system to perform its intended purpose. Therefore, I am afraid the agency cannot accept a lamp display that differs. Although the lamps could be mounted on the rear of the cab, we understand that in that position they could be obscured by the top lip of the dump body. We realize that the contractor has pre-punched holes for the lamps, which would be flush-mounted in the rear cross sill of the truck body. If a way were found to cover the holes, there are surface-mounted lamps available which could be mounted at the same height (your desired height for the center lamp) in a manner than should not affect the positioning of the underbody tailgate release mechanism. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0457OpenMr. J. G. Abbott, Transportation Chemicals, Development & Service, Dow Chemical Europe, S.A., Todi-Strasse 68, 8810 Horgen 2, Switzerland; Mr. J. G. Abbott Transportation Chemicals Development & Service Dow Chemical Europe S.A. Todi-Strasse 68 8810 Horgen 2 Switzerland; Dear Mr. Abbott: This is in reply to your letter of September 24 to Francis Armstron regarding the effective date of the new Federal motor vehicle brake fluid standard, No. 116.; The effective date of March 1, 1972, means that any vehicl *manufactured* on or after that date for sale in the United States must be equipped with brake fluid meeting Motor Vehicle Safety Standard No. 116.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4947OpenGordon W. Didier, Esquire Butzel Long Suite 200 32270 Telegraph Birmingham, Michigan 48010-4996; Gordon W. Didier Esquire Butzel Long Suite 200 32270 Telegraph Birmingham Michigan 48010-4996; "Dear Mr. Didier: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 118 Power Windows (49 CFR 571.118), on behalf of your client, a manufacturer of automobile sunroofs. As you noted in your letter, the agency has published a final rule amending Standard No. 118 in the April 16, 1991 edition of the Federal Register (56 FR 15290). You requested clarification of certain requirements in that final rule. The agency has received several petitions for reconsideration of the final rule amending Standard No. 118. The agency is currently reviewing the merits of each petition. The agency will issue a notice in the Federal Register granting and/or denying the petitions. In that notice, the agency will also address the concerns raised in your request for an interpretation on Standard No. 118. Please let us know if you have any questions about the issues raised in your letter after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. If you need more information on this subject, please feel free to contact Dorothy Nakama of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice 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.