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 7231 - 7240 of 16490

Interpretations	Date

ID: aiam5251 Open Mr. John P. Gach Marketing Coordinator North American Lighting, Inc. P.O. Box 499 Flora, IL 62839; Mr. John P. Gach Marketing Coordinator North American Lighting Inc. P.O. Box 499 Flora IL 62839; "Dear Mr. Gach: We are replying to your letter of September 1, 1993, t Richard Van Iderstine of this agency with respect to the 'Blu-Lite.' You would like our views on this product 'in both OEM and aftermarket applications.' The advertising circular which you enclosed shows Blu-Lite to be a three- compartment stop lamp that is mounted in the center of the parcel shelf adjacent to the rear window. The center compartment contains a blue light 'that comes on immediately with heavy brake pressure and flashes quickly and independently from your regular brake lights.' The center blue light compartment is flanked by compartments that contain a 'red stop light.' It is clear that Blu-Light is intended as a substitute for the center highmounted stop lamp that Federal Motor Vehicle Safety Standard No. 108 has required to be installed as original equipment on passenger cars manufactured on and after September 1, 1985, (and light trucks and vans since September 1, 1993). Blu-Light does not meet the original equipment specifications of Standard No. 108 because, among other things, it is not a single red lamp mounted on the vertical centerline of the vehicle. Therefore, Blu-Light is impermissible under Federal law as original motor vehicle lighting equipment. With respect to aftermarket applications, the National Traffic and Motor Vehicle Safety Act prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from 'knowingly rendering inoperative in whole or in part' any equipment installed in accordance with a Federal motor vehicle safety standard. Removal of the original equipment center lamp and replacement with Blu-Light would be a 'rendering inoperative' as we interpret that term, and, hence, a prohibited act. However, the prohibition does not extend to persons outside the four named categories, such as the vehicle owner, and installation of Blu-Light by persons not named in the prohibition would not violate any Federal requirement. But the legality of the use of Blu- Light is determinable under the laws of each State in which the device is operated. As you note, many States reserve the color blue for lamps used to indicate emergencies. If you are interested in pursuing this question further, the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, can advise you whether any State allows the use of blue lamps for other than emergency use. Further, there is no violation of Federal law involved in installing Blu-Lite on vehicles that were not required by Standard No. 108 to be originally equipped with one, i.e., cars manufactured before September 1, 1985, and other vehicles manufactured before September 1 of this year. In this instance, too, legality of use is determinable under State law. I hope that this answers your questions. Sincerely, John Womack Acting Chief Counsel ";
ID: aiam4266 Open MR. M. R. Dunn, Engineering Director, Rolls-Royce Motor Cars Limited, Crew Cheshire CW1 3PL, ENGLAND; MR. M. R. Dunn Engineering Director Rolls-Royce Motor Cars Limited Crew Cheshire CW1 3PL ENGLAND; Dear Mr. Dunn: Thank you for your telefax of December 18, 1986, concernin Rolls-Royce's ability to meet the automatic restraint phase-in requirements of Standard No. 208, Occupant Crash Protection. You reported that Rolls-Royce has experienced setbacks in both its automatic belt and airbag programs and faces 'a real possibility of being unable to comply during the 1987 model year to 31 August 1987.' You asked 'whether there would be any restriction imposed on our sales of non-complying 1987 model year cars and the extent of any financial penalty per car if any.'; The National Traffic and Motor Vehicle Safety Act sets out manufacturer's obligation to produce vehicles that comply with all applicable Federal motor vehicle safety standards. The Vehicle Safety Act provides for a number of remedies the agency would pursue if a manufacturer has failed to comply with the requirements of the Act. Those remedies are discussed below.; Section 108(a)(1)(A) of the Vehicle Safety Act obligates a manufacture to produce vehicles that conform to the Federal motor vehicle safety standards. That section prohibits a manufacturer from manufacturing, introducing into interstate commerce, selling, or importing a vehicle that does not conform with all applicable Federal motor vehicle safety standards. Section 114 of the Vehicle Safety Act also obligates a manufacturer to furnish, at the time of delivery of a vehicle to a distributor or dealer, a certificate that the vehicle conforms to all applicable Federal motor vehicle safety standards. It is a violation of section 108(a)(1)(C) of the Vehicle Safety Act for a manufacturers to issue such a certification if it 'in the exercise of due care has reason to know that such certificate is false or misleading in a material respect.'; The Vehicle Safety Act provides NHTSA with a wide range of remedies th agency can pursue if there is a violation of the Act. Section 109(a) provides for a civil penalty of $1,000 for each violation of a provision of section 108 of any regulation issued under the authority of that section. Section 109(a) further provides that each non-complying motor vehicle constitutes a separate violation and entitles the agency to collect a civil penalty of up to $8000,000 for a series of violations.; Under section 110 of the Vehicle Safety Act, the agency has authorit to seek injunctive relief to restrain 'violations of this title (or rules, regulations or orders thereunder), or to restrain the sale, offer for sale, or the introduction or delivery for introduction in interstate commerce, or the importation into the United States' of non-complying motor vehicles.; Section 111 of the Vehicle Safety Act imposes additional duties o manufacturer of a non- complying vehicle that has been delivered to a distributor or dealer but not yet sold to a retail customer. That section requires the manufacturer to repurchase the non-complying vehicle from the distributor or dealer, and to reimburse the dealer or distributor for a portion of its expenses. As an alternative, the manufacturer can furnish the purchasing distributor or dealer with the necessary conforming parts and reimburse the distributor or dealer for a portion of its expenses. If a non-complying vehicle has been sold to a retail purchaser, sections 151-159 of the Vehicle Safety Act require the vehicle's manufacturer to conduct a non-compliance notification and remedy campaign.; Under the phase-in requirements of Standard No. 208, Rolls-Royce ha the obligation to install automatic restraints in ten percent of its vehicles manufactured during the period September 1, 1986 - August 31, 1987 for sale in the United States. If the agency were to determine that passenger car manufactured by Rolls-Royce for sale in the United States do not conform to the automatic restraint requirements of Standard No. 208, the agency could pursue any or all to the following remedies under the Vehicle Safety Act. To determine the extend of Rolls-Royce's compliance, the agency could require Rolls-Royce to provide information on the number of vehicles produced and the number equipped with automatic restraints. The agency could seek to restrain the sale of the non-complying Rolls-Royce cars that have been imported into the Untied States. In addition, the agency could seek to restrain the further importation of non-complying Rolls-Royce passenger cars into the United States. Further, the agency could seek a civil penalty against Rolls-Royce for each violation of section 108(a)(1)(A) and (C). In addition to seeking those remedies, the agency has authority under section 152 of the Vehicle safety act to determine whether Rolls-Royce should be ordered to conduct a notification and remedy campaign for the non-complying vehicles. While your question and the above discussion are hypothetical, we strongly urge Rolls-Royce to take all necessary steps to assure compliance with the phase-in requirements of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam3905 Open Mr. Andrew P. Kallman, Kallman Marketing, 205 W. Saginaw, Lansing, MI 48933; Mr. Andrew P. Kallman Kallman Marketing 205 W. Saginaw Lansing MI 48933; Dear Mr. Kallman: This responds to your letter of January 14, 1985, concerning wha regulations affect a process you intend to market for new and used cars. The process consists of grinding two parallel grooves into the lower portion of the windshield. The grooves are 2mm wide, 0.1-0.3mm deep, and are 2mm from each other. You stated that the purpose of the grooves is to improve the efficiency of the wipers and increase their life expectancy. The following discussions address the effect of our regulations on the process you described.; First, let me explain how our regulations apply to a new vehicle or t a new windshield sold as an item of replacement equipment. Our agency has issued Standard No. 205, Glazing Materials, which sets performance requirements for glazing materials used in new vehicles or sold as items of replacement equipment. I have enclosed a copy of the standard. If, before they are sold, the safety grooves are ground into either the windshield of a new vehicle or into a new windshield sold as an item of replacement of equipment, the person making the grooves would have to certify that the glazing continues to be in compliance with all of the requirements of Standard No. 205 for windshields. I note that the test results enclosed with your letter do not address whether the glazing would continue to comply with the requirements after it has had the safety grooves ground into it. In particular, we would urge you to determine whether the glazing would continue to comply with the requirements regarding impact and penetration resistance, optical deviation and visual distortion after the grooves have been ground into the windshield. Purchasers of a new vehicle may alter the vehicle as they please, so long as they adhere to all State requirements.; If the safety grooves are ground into the windshield of a used vehicle then Section 108 (a)(2)(A) of the National Traffic and Motor Safety Act may apply. That section 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. Thus, none of those persons may knowingly grind the grooves into a vehicle's windshield if by so doing they would render inoperative the compliance of the vehicle's glazing with Standard No. 205. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel
ID: aiam3208 Open Mr. Jay Blanchard, Administrative Assistant, Diesel Fuel Saver, P.O. Box 516, Russell, IA 50238; Mr. Jay Blanchard Administrative Assistant Diesel Fuel Saver P.O. Box 516 Russell IA 50238; Dear Mr. Blanchard: This responds to your February 8, 1980, letter requesting confirmatio of statements made to you by an NHTSA engineer, Robert Williams. Apparently, Mr. Williams stated that your product, the 'Diesel Fuel Saver,' would comply with Safety Standard No. 301-75, Fuel System Integrity (49 CFR 571.301-75).; As you describe the product, the 'Diesel Fuel Saver' is a piece o aftermarket equipment that can be readily attached to diesel fuel systems to heat the fuel and ostensibly increase fuel economy. However, Safety Standard No. 301-75 is only applicable to new vehicles and, therefore, would not apply to motor vehicle equipment such as yours unless it is installed on new vehicles. Further, Safety Standard No. 301-75 does not specify design requirements for individual components of fuel systems. Rather, the standard specifies performance requirements that must be achieved by vehicle fuel systems during barrier crash tests.; There are no other safety standards that would be applicable to you product. However, you would be responsible under the National Traffic and Motor Vehicle Safety Act, amended 1974 (15 U.S.C. 1381, et seq.), our enabling authority, for any defects in the 'Diesel Fuel Saver' relating to motor vehicle safety. This means that you would have to notify purchasers of your product of any such defects that might exist and remedy those defects at your own expense.; Although Safety Standard No. 301-75 is not directly applicable to th 'Diesel Fuel Saver,' the standard does create responsibilities for certain persons who may install the product.; Section 108(a)(2)(A) of the Vehicle Safety Act specifies that n manufacturer, dealer, distributor or motor vehicle repair business may knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle in compliance with a Federal motor vehicle safety standard. This means that none of the mentioned persons, which could include your own company, would be permitted to install the 'Diesel Fuel Saver' on a motor vehicle if the equipment would destroy the vehicle's compliance with Safety Standard No. 301-75 (or any other applicable safety standard). Therefore, as a responsible manufacturer, you should determine whether vehicles can meet the performance requirements specified in Safety Standard No. 301-75 with your product installed. The prohibition in section 108(a)(2)(A) only applies to those persons mentioned above. Therefore, a private individual (the vehicles owner, for example) could install the 'Diesel Fuel Saver' with impunity, regardless of whether the vehicle thereafter complies with Safety Standard No. 301-75. This, of course, would not remove your liability in private litigation.; I hope this have been responsive to your inquiry. If you have an further questions, please contact Hugh Oates of my office at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1379 Open Mr. Richard Wright West, West & Wilkinson, P.O. Box 257, 2815 Huntington Avenue, Newport News, VA 23607; Mr. Richard Wright West West & Wilkinson P.O. Box 257 2815 Huntington Avenue Newport News VA 23607; Dear Mr. West: This is in response to your letter of January 2, 1974 requestin information concerning the legal permissibility of an automobile dealership furnishing private passenger motor vehicles with add-on gasoline tanks or modifying existing gasoline tanks.; Motor Vehicle Safety Standard No. 301, Fuel System Integrity establishes minimum performance requirements for motor vehicle fuel systems. Compliance with the level of performance mandated by the standard is enforced by Section 108(a)(1) of the National traffic and Motor Vehicle Safety Act which prohibits the manufacture, sale, delivery, or importation of vehicles or mtor vehicle equipment that do not meet the requirements of applicable safety standards. Therefore, if your client modified a motor vehicle fuel tank in such a manner that it no longer complied with Standard No. 301 and then offered it for initial sale for purposes other than resale he would be in violation of the Motor Vehicle Safety Act and would be subject to civil penalties of not more than $1,000 for each such violation. If, however, your client performed a fuel tank modification on a vehicle that was already owned by and in the possession of a buyer who purchased the vehicle for purposes other than resale, no violation of the Act could result. the installation of an add-on fuel tank would be considered a modification. Therefore, the fuel system would have to comply with Standard No. 301 with the add-on fuel tank considered as part of the system.; There are no Motor Vehicle Safety Standards applicable to add-o gasoline tanks since these are items of motor vehicle equipment and standard No. 301 restricts its application to motor vehicles. Section 113(e)(2) of the Motor Vehicle Safety Act, however, authorizes the Secretary of Transportation to determine whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If the Secretary finds that a safety-related defect exists, your client may be compelled to notify all purchasers of vehicles with the add-on fuel tanks of the attendant hazard.; The action of installing add-on gasoline tanks in motor vehicle exposes your client to the requirements of yet another safety regulation (49 CFR 567.7). If the vehicle in which he installs the fuel thank is a certified and complete vehicle that has not yet been purchased ingood faith for purposes other than resale, your client will be considered an alterer of the vehicle, and he must provide a certification that the vehicle as altered still conforms to the standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam4751 Open The Honorable Lawrence J. Smith U. S. House of Representatives Washington, D.C. 20515; The Honorable Lawrence J. Smith U. S. House of Representatives Washington D.C. 20515; "Dear Mr. Smith: I am writing in response to your letter forwardin correspondence from your constituent, Mr. Joel Leitson, with respect to litigation recently brought by the United States against several firms that install plastic film, or 'tint,' on automobile windows. You have asked about the statutory authority under which these suits were brought. Pursuant to section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 ('Safety Act'), 15 U.S.C. 1392, the National Highway Traffic Safety Administration ('NHTSA') has issued safety standards applicable to new motor vehicles and items of motor vehicle equipment. One of the standards that we have issued under this authority is Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), which applies to all new vehicles and all new glazing materials for use in motor vehicles. Among the requirements set forth in Standard No. 205 are specifications for minimum levels of light transmittance (70 percent light transmittance in areas requisite for driving visibility, which includes all windows in passenger cars). Section 108(a)(i)(A) of the Safety Act, 15 U.S.C. 1397(a)(1)(A), provides that no person may manufacture or sell any vehicle unless it is in conformity with all applicable safety standards. Pursuant to section 108(b)(1) of the Safety Act, 15 U.S.C. 1397(b)(1), this paragraph does not apply after a vehicle is first sold to a consumer. However, both before and after the first sale, section 108(a)(2) of the Safety Act, 15 U.S.C. 1397(a)(2), provides that 'No manufacturer, distributor, dealer, or motor vehicle repair 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, by installing tint film on automobiles that reduces the light transmittance of their glass below 70 percent, the firms in question have been rendering those vehicles 'inoperative,' in violation of the Safety Act. The same principle would apply to a service station that removed an airbag or a safety belt from a vehicle, since such an action would create a noncompliance with the occupant protection requirements of NHTSA's standards. You also asked for our comments on whether Florida's statutes are preempted by these suits. We assume that you are referring to the provision of Florida law that prohibits the operation of any vehicle in the State of Florida that has glazing with less than 35 percent light transmittance. This statute, and similar statutes adopted by other states, do not purport to legitimize conduct -- the rendering inoperative of glazing by tint installation firms -- that is illegal under the Safety Act. Thus, there is no conflict with Federal law, and Florida may continue to enforce its operating rules. I hope that this responds to your questions. If we can be of further assistance, please let me know. Sincerely, Paul Jackson Rice Chief Counsel";
ID: aiam3142 Open Mr. Alan L. Sinder, Manager, Vehicle Products Group, Veeder-Root Company, Hartford, Connecticut 06102; Mr. Alan L. Sinder Manager Vehicle Products Group Veeder-Root Company Hartford Connecticut 06102; Dear Mr. Sinder: This is in response to your letter of August 21, 1979, asking whethe Federal Motor Vehicle Safety Standard No. 127, Speedometers and Odometers, applies to your product, the Veeder-Root 7-Day Tachograph, and whether the odometer provisions of the standard would apply if your product were installed in vehicles with gross vehicle weight ratings (GVWR) of less than 16,000 pounds. You also asked whether a tachograph installed in a school bus as a replacement for the speedometer and marked with speeds from 0 to 50 mph on both the dial and on the inside chart would comply with Safety Standard 127.; Section 4.1.1 of Safety Standard 127 requires that 'each motor vehicl shall have a speedometer that meets the requirements ...' of the standard. Section 4.2.1 requires that 'each motor vehicle with a gross vehicle weight rating of 16,000 pounds or less shall have an odometer that meets the requirements ...' of the standard. Therefore a tachograph installed in lieu of the speedometer and odometer in a new vehicle with a gross vehicle weight rating of 16,000 pounds or less must meet both the speedometer and the odometer requirements of Safety Standard 127. If the new vehicle in which the tachograph were installed had a gross vehicle weight rating greater than 16,000 pounds the speedometer requirement of Safety Standard 127 would apply but the odometer requirements would not.; If the tachograph were installed in a new vehicle as a supplement to existing speedometer and odometer which meet the requirements of Safety Standard 127, the provisions of Safety Standard No. 127 would not apply to the tachograph.; Section 4.1.4 of Safety Standard 127 provides that: >>>No speedometer shall have graduation or numerical values for speed greater than 140 km/h and 85 mph and shall not otherwise indicate such speeds.<<<; Although this section specifies the maximum speed indication which ma appear on the dial of a speedometer, it does not prohibit the use of a lower maximum speed indication. Section 4.1.5 of the standard provides that 'each speedometer shall include the numeral '55' in the mph scale.' However, this provision assumes that the speedometer dial will have calibrations for speeds in excess of 55 mph. If the speedometer dial will not include calibrations for speeds of 55 mph and above, then there is no requirement that the numeral 55 be included in the mph scale. This follows from the rationale on which Safety Standard 127 is based, which is to reduce the temptation for drivers to test the top speeds of their vehicles and to induce greater compliance with the national maximum speed limit of 55 mph.; I hope that you will find this response helpful and have not bee greatly inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam3914 Open Mr. Carl R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, Windshield Retention, as well as Standard No. 216, Roof Crush Resistance. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, Windshield Zone Intrusion.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel
ID: aiam3915 Open Mr. Carl. R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl. R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, Windshield Retention, as well as Standard No. 216, Roof Crush Resistance. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, Windshield Zone Intrusion.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel
ID: aiam3913 Open Mr. Carl R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, Windshield Retention, as well as Standard No. 216, Roof Crush Resistance. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, Windshield Zone Intrusion.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, 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: aiam5251 Open Mr. John P. Gach Marketing Coordinator North American Lighting, Inc. P.O. Box 499 Flora, IL 62839; Mr. John P. Gach Marketing Coordinator North American Lighting Inc. P.O. Box 499 Flora IL 62839; "Dear Mr. Gach: We are replying to your letter of September 1, 1993, t Richard Van Iderstine of this agency with respect to the 'Blu-Lite.' You would like our views on this product 'in both OEM and aftermarket applications.' The advertising circular which you enclosed shows Blu-Lite to be a three- compartment stop lamp that is mounted in the center of the parcel shelf adjacent to the rear window. The center compartment contains a blue light 'that comes on immediately with heavy brake pressure and flashes quickly and independently from your regular brake lights.' The center blue light compartment is flanked by compartments that contain a 'red stop light.' It is clear that Blu-Light is intended as a substitute for the center highmounted stop lamp that Federal Motor Vehicle Safety Standard No. 108 has required to be installed as original equipment on passenger cars manufactured on and after September 1, 1985, (and light trucks and vans since September 1, 1993). Blu-Light does not meet the original equipment specifications of Standard No. 108 because, among other things, it is not a single red lamp mounted on the vertical centerline of the vehicle. Therefore, Blu-Light is impermissible under Federal law as original motor vehicle lighting equipment. With respect to aftermarket applications, the National Traffic and Motor Vehicle Safety Act prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from 'knowingly rendering inoperative in whole or in part' any equipment installed in accordance with a Federal motor vehicle safety standard. Removal of the original equipment center lamp and replacement with Blu-Light would be a 'rendering inoperative' as we interpret that term, and, hence, a prohibited act. However, the prohibition does not extend to persons outside the four named categories, such as the vehicle owner, and installation of Blu-Light by persons not named in the prohibition would not violate any Federal requirement. But the legality of the use of Blu- Light is determinable under the laws of each State in which the device is operated. As you note, many States reserve the color blue for lamps used to indicate emergencies. If you are interested in pursuing this question further, the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, can advise you whether any State allows the use of blue lamps for other than emergency use. Further, there is no violation of Federal law involved in installing Blu-Lite on vehicles that were not required by Standard No. 108 to be originally equipped with one, i.e., cars manufactured before September 1, 1985, and other vehicles manufactured before September 1 of this year. In this instance, too, legality of use is determinable under State law. I hope that this answers your questions. Sincerely, John Womack Acting Chief Counsel ";
ID: aiam4266 Open MR. M. R. Dunn, Engineering Director, Rolls-Royce Motor Cars Limited, Crew Cheshire CW1 3PL, ENGLAND; MR. M. R. Dunn Engineering Director Rolls-Royce Motor Cars Limited Crew Cheshire CW1 3PL ENGLAND; Dear Mr. Dunn: Thank you for your telefax of December 18, 1986, concernin Rolls-Royce's ability to meet the automatic restraint phase-in requirements of Standard No. 208, Occupant Crash Protection. You reported that Rolls-Royce has experienced setbacks in both its automatic belt and airbag programs and faces 'a real possibility of being unable to comply during the 1987 model year to 31 August 1987.' You asked 'whether there would be any restriction imposed on our sales of non-complying 1987 model year cars and the extent of any financial penalty per car if any.'; The National Traffic and Motor Vehicle Safety Act sets out manufacturer's obligation to produce vehicles that comply with all applicable Federal motor vehicle safety standards. The Vehicle Safety Act provides for a number of remedies the agency would pursue if a manufacturer has failed to comply with the requirements of the Act. Those remedies are discussed below.; Section 108(a)(1)(A) of the Vehicle Safety Act obligates a manufacture to produce vehicles that conform to the Federal motor vehicle safety standards. That section prohibits a manufacturer from manufacturing, introducing into interstate commerce, selling, or importing a vehicle that does not conform with all applicable Federal motor vehicle safety standards. Section 114 of the Vehicle Safety Act also obligates a manufacturer to furnish, at the time of delivery of a vehicle to a distributor or dealer, a certificate that the vehicle conforms to all applicable Federal motor vehicle safety standards. It is a violation of section 108(a)(1)(C) of the Vehicle Safety Act for a manufacturers to issue such a certification if it 'in the exercise of due care has reason to know that such certificate is false or misleading in a material respect.'; The Vehicle Safety Act provides NHTSA with a wide range of remedies th agency can pursue if there is a violation of the Act. Section 109(a) provides for a civil penalty of $1,000 for each violation of a provision of section 108 of any regulation issued under the authority of that section. Section 109(a) further provides that each non-complying motor vehicle constitutes a separate violation and entitles the agency to collect a civil penalty of up to $8000,000 for a series of violations.; Under section 110 of the Vehicle Safety Act, the agency has authorit to seek injunctive relief to restrain 'violations of this title (or rules, regulations or orders thereunder), or to restrain the sale, offer for sale, or the introduction or delivery for introduction in interstate commerce, or the importation into the United States' of non-complying motor vehicles.; Section 111 of the Vehicle Safety Act imposes additional duties o manufacturer of a non- complying vehicle that has been delivered to a distributor or dealer but not yet sold to a retail customer. That section requires the manufacturer to repurchase the non-complying vehicle from the distributor or dealer, and to reimburse the dealer or distributor for a portion of its expenses. As an alternative, the manufacturer can furnish the purchasing distributor or dealer with the necessary conforming parts and reimburse the distributor or dealer for a portion of its expenses. If a non-complying vehicle has been sold to a retail purchaser, sections 151-159 of the Vehicle Safety Act require the vehicle's manufacturer to conduct a non-compliance notification and remedy campaign.; Under the phase-in requirements of Standard No. 208, Rolls-Royce ha the obligation to install automatic restraints in ten percent of its vehicles manufactured during the period September 1, 1986 - August 31, 1987 for sale in the United States. If the agency were to determine that passenger car manufactured by Rolls-Royce for sale in the United States do not conform to the automatic restraint requirements of Standard No. 208, the agency could pursue any or all to the following remedies under the Vehicle Safety Act. To determine the extend of Rolls-Royce's compliance, the agency could require Rolls-Royce to provide information on the number of vehicles produced and the number equipped with automatic restraints. The agency could seek to restrain the sale of the non-complying Rolls-Royce cars that have been imported into the Untied States. In addition, the agency could seek to restrain the further importation of non-complying Rolls-Royce passenger cars into the United States. Further, the agency could seek a civil penalty against Rolls-Royce for each violation of section 108(a)(1)(A) and (C). In addition to seeking those remedies, the agency has authority under section 152 of the Vehicle safety act to determine whether Rolls-Royce should be ordered to conduct a notification and remedy campaign for the non-complying vehicles. While your question and the above discussion are hypothetical, we strongly urge Rolls-Royce to take all necessary steps to assure compliance with the phase-in requirements of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam3905 Open Mr. Andrew P. Kallman, Kallman Marketing, 205 W. Saginaw, Lansing, MI 48933; Mr. Andrew P. Kallman Kallman Marketing 205 W. Saginaw Lansing MI 48933; Dear Mr. Kallman: This responds to your letter of January 14, 1985, concerning wha regulations affect a process you intend to market for new and used cars. The process consists of grinding two parallel grooves into the lower portion of the windshield. The grooves are 2mm wide, 0.1-0.3mm deep, and are 2mm from each other. You stated that the purpose of the grooves is to improve the efficiency of the wipers and increase their life expectancy. The following discussions address the effect of our regulations on the process you described.; First, let me explain how our regulations apply to a new vehicle or t a new windshield sold as an item of replacement equipment. Our agency has issued Standard No. 205, Glazing Materials, which sets performance requirements for glazing materials used in new vehicles or sold as items of replacement equipment. I have enclosed a copy of the standard. If, before they are sold, the safety grooves are ground into either the windshield of a new vehicle or into a new windshield sold as an item of replacement of equipment, the person making the grooves would have to certify that the glazing continues to be in compliance with all of the requirements of Standard No. 205 for windshields. I note that the test results enclosed with your letter do not address whether the glazing would continue to comply with the requirements after it has had the safety grooves ground into it. In particular, we would urge you to determine whether the glazing would continue to comply with the requirements regarding impact and penetration resistance, optical deviation and visual distortion after the grooves have been ground into the windshield. Purchasers of a new vehicle may alter the vehicle as they please, so long as they adhere to all State requirements.; If the safety grooves are ground into the windshield of a used vehicle then Section 108 (a)(2)(A) of the National Traffic and Motor Safety Act may apply. That section 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. Thus, none of those persons may knowingly grind the grooves into a vehicle's windshield if by so doing they would render inoperative the compliance of the vehicle's glazing with Standard No. 205. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel
ID: aiam3208 Open Mr. Jay Blanchard, Administrative Assistant, Diesel Fuel Saver, P.O. Box 516, Russell, IA 50238; Mr. Jay Blanchard Administrative Assistant Diesel Fuel Saver P.O. Box 516 Russell IA 50238; Dear Mr. Blanchard: This responds to your February 8, 1980, letter requesting confirmatio of statements made to you by an NHTSA engineer, Robert Williams. Apparently, Mr. Williams stated that your product, the 'Diesel Fuel Saver,' would comply with Safety Standard No. 301-75, Fuel System Integrity (49 CFR 571.301-75).; As you describe the product, the 'Diesel Fuel Saver' is a piece o aftermarket equipment that can be readily attached to diesel fuel systems to heat the fuel and ostensibly increase fuel economy. However, Safety Standard No. 301-75 is only applicable to new vehicles and, therefore, would not apply to motor vehicle equipment such as yours unless it is installed on new vehicles. Further, Safety Standard No. 301-75 does not specify design requirements for individual components of fuel systems. Rather, the standard specifies performance requirements that must be achieved by vehicle fuel systems during barrier crash tests.; There are no other safety standards that would be applicable to you product. However, you would be responsible under the National Traffic and Motor Vehicle Safety Act, amended 1974 (15 U.S.C. 1381, et seq.), our enabling authority, for any defects in the 'Diesel Fuel Saver' relating to motor vehicle safety. This means that you would have to notify purchasers of your product of any such defects that might exist and remedy those defects at your own expense.; Although Safety Standard No. 301-75 is not directly applicable to th 'Diesel Fuel Saver,' the standard does create responsibilities for certain persons who may install the product.; Section 108(a)(2)(A) of the Vehicle Safety Act specifies that n manufacturer, dealer, distributor or motor vehicle repair business may knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle in compliance with a Federal motor vehicle safety standard. This means that none of the mentioned persons, which could include your own company, would be permitted to install the 'Diesel Fuel Saver' on a motor vehicle if the equipment would destroy the vehicle's compliance with Safety Standard No. 301-75 (or any other applicable safety standard). Therefore, as a responsible manufacturer, you should determine whether vehicles can meet the performance requirements specified in Safety Standard No. 301-75 with your product installed. The prohibition in section 108(a)(2)(A) only applies to those persons mentioned above. Therefore, a private individual (the vehicles owner, for example) could install the 'Diesel Fuel Saver' with impunity, regardless of whether the vehicle thereafter complies with Safety Standard No. 301-75. This, of course, would not remove your liability in private litigation.; I hope this have been responsive to your inquiry. If you have an further questions, please contact Hugh Oates of my office at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1379 Open Mr. Richard Wright West, West & Wilkinson, P.O. Box 257, 2815 Huntington Avenue, Newport News, VA 23607; Mr. Richard Wright West West & Wilkinson P.O. Box 257 2815 Huntington Avenue Newport News VA 23607; Dear Mr. West: This is in response to your letter of January 2, 1974 requestin information concerning the legal permissibility of an automobile dealership furnishing private passenger motor vehicles with add-on gasoline tanks or modifying existing gasoline tanks.; Motor Vehicle Safety Standard No. 301, Fuel System Integrity establishes minimum performance requirements for motor vehicle fuel systems. Compliance with the level of performance mandated by the standard is enforced by Section 108(a)(1) of the National traffic and Motor Vehicle Safety Act which prohibits the manufacture, sale, delivery, or importation of vehicles or mtor vehicle equipment that do not meet the requirements of applicable safety standards. Therefore, if your client modified a motor vehicle fuel tank in such a manner that it no longer complied with Standard No. 301 and then offered it for initial sale for purposes other than resale he would be in violation of the Motor Vehicle Safety Act and would be subject to civil penalties of not more than $1,000 for each such violation. If, however, your client performed a fuel tank modification on a vehicle that was already owned by and in the possession of a buyer who purchased the vehicle for purposes other than resale, no violation of the Act could result. the installation of an add-on fuel tank would be considered a modification. Therefore, the fuel system would have to comply with Standard No. 301 with the add-on fuel tank considered as part of the system.; There are no Motor Vehicle Safety Standards applicable to add-o gasoline tanks since these are items of motor vehicle equipment and standard No. 301 restricts its application to motor vehicles. Section 113(e)(2) of the Motor Vehicle Safety Act, however, authorizes the Secretary of Transportation to determine whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If the Secretary finds that a safety-related defect exists, your client may be compelled to notify all purchasers of vehicles with the add-on fuel tanks of the attendant hazard.; The action of installing add-on gasoline tanks in motor vehicle exposes your client to the requirements of yet another safety regulation (49 CFR 567.7). If the vehicle in which he installs the fuel thank is a certified and complete vehicle that has not yet been purchased ingood faith for purposes other than resale, your client will be considered an alterer of the vehicle, and he must provide a certification that the vehicle as altered still conforms to the standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam4751 Open The Honorable Lawrence J. Smith U. S. House of Representatives Washington, D.C. 20515; The Honorable Lawrence J. Smith U. S. House of Representatives Washington D.C. 20515; "Dear Mr. Smith: I am writing in response to your letter forwardin correspondence from your constituent, Mr. Joel Leitson, with respect to litigation recently brought by the United States against several firms that install plastic film, or 'tint,' on automobile windows. You have asked about the statutory authority under which these suits were brought. Pursuant to section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 ('Safety Act'), 15 U.S.C. 1392, the National Highway Traffic Safety Administration ('NHTSA') has issued safety standards applicable to new motor vehicles and items of motor vehicle equipment. One of the standards that we have issued under this authority is Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205), which applies to all new vehicles and all new glazing materials for use in motor vehicles. Among the requirements set forth in Standard No. 205 are specifications for minimum levels of light transmittance (70 percent light transmittance in areas requisite for driving visibility, which includes all windows in passenger cars). Section 108(a)(i)(A) of the Safety Act, 15 U.S.C. 1397(a)(1)(A), provides that no person may manufacture or sell any vehicle unless it is in conformity with all applicable safety standards. Pursuant to section 108(b)(1) of the Safety Act, 15 U.S.C. 1397(b)(1), this paragraph does not apply after a vehicle is first sold to a consumer. However, both before and after the first sale, section 108(a)(2) of the Safety Act, 15 U.S.C. 1397(a)(2), provides that 'No manufacturer, distributor, dealer, or motor vehicle repair 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, by installing tint film on automobiles that reduces the light transmittance of their glass below 70 percent, the firms in question have been rendering those vehicles 'inoperative,' in violation of the Safety Act. The same principle would apply to a service station that removed an airbag or a safety belt from a vehicle, since such an action would create a noncompliance with the occupant protection requirements of NHTSA's standards. You also asked for our comments on whether Florida's statutes are preempted by these suits. We assume that you are referring to the provision of Florida law that prohibits the operation of any vehicle in the State of Florida that has glazing with less than 35 percent light transmittance. This statute, and similar statutes adopted by other states, do not purport to legitimize conduct -- the rendering inoperative of glazing by tint installation firms -- that is illegal under the Safety Act. Thus, there is no conflict with Federal law, and Florida may continue to enforce its operating rules. I hope that this responds to your questions. If we can be of further assistance, please let me know. Sincerely, Paul Jackson Rice Chief Counsel";
ID: aiam3142 Open Mr. Alan L. Sinder, Manager, Vehicle Products Group, Veeder-Root Company, Hartford, Connecticut 06102; Mr. Alan L. Sinder Manager Vehicle Products Group Veeder-Root Company Hartford Connecticut 06102; Dear Mr. Sinder: This is in response to your letter of August 21, 1979, asking whethe Federal Motor Vehicle Safety Standard No. 127, Speedometers and Odometers, applies to your product, the Veeder-Root 7-Day Tachograph, and whether the odometer provisions of the standard would apply if your product were installed in vehicles with gross vehicle weight ratings (GVWR) of less than 16,000 pounds. You also asked whether a tachograph installed in a school bus as a replacement for the speedometer and marked with speeds from 0 to 50 mph on both the dial and on the inside chart would comply with Safety Standard 127.; Section 4.1.1 of Safety Standard 127 requires that 'each motor vehicl shall have a speedometer that meets the requirements ...' of the standard. Section 4.2.1 requires that 'each motor vehicle with a gross vehicle weight rating of 16,000 pounds or less shall have an odometer that meets the requirements ...' of the standard. Therefore a tachograph installed in lieu of the speedometer and odometer in a new vehicle with a gross vehicle weight rating of 16,000 pounds or less must meet both the speedometer and the odometer requirements of Safety Standard 127. If the new vehicle in which the tachograph were installed had a gross vehicle weight rating greater than 16,000 pounds the speedometer requirement of Safety Standard 127 would apply but the odometer requirements would not.; If the tachograph were installed in a new vehicle as a supplement to existing speedometer and odometer which meet the requirements of Safety Standard 127, the provisions of Safety Standard No. 127 would not apply to the tachograph.; Section 4.1.4 of Safety Standard 127 provides that: >>>No speedometer shall have graduation or numerical values for speed greater than 140 km/h and 85 mph and shall not otherwise indicate such speeds.<<<; Although this section specifies the maximum speed indication which ma appear on the dial of a speedometer, it does not prohibit the use of a lower maximum speed indication. Section 4.1.5 of the standard provides that 'each speedometer shall include the numeral '55' in the mph scale.' However, this provision assumes that the speedometer dial will have calibrations for speeds in excess of 55 mph. If the speedometer dial will not include calibrations for speeds of 55 mph and above, then there is no requirement that the numeral 55 be included in the mph scale. This follows from the rationale on which Safety Standard 127 is based, which is to reduce the temptation for drivers to test the top speeds of their vehicles and to induce greater compliance with the national maximum speed limit of 55 mph.; I hope that you will find this response helpful and have not bee greatly inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam3914 Open Mr. Carl R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, Windshield Retention, as well as Standard No. 216, Roof Crush Resistance. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, Windshield Zone Intrusion.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel
ID: aiam3915 Open Mr. Carl. R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl. R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, Windshield Retention, as well as Standard No. 216, Roof Crush Resistance. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, Windshield Zone Intrusion.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel
ID: aiam3913 Open Mr. Carl R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, Windshield Retention, as well as Standard No. 216, Roof Crush Resistance. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, Windshield Zone Intrusion.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel

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