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: aiam3238OpenMr. William N. Whitley, Vice President, Whitley & Whitley, Inc., 20600 Chagrin Boulevard, Tower East, Shaker Heights, Ohio 44122; Mr. William N. Whitley Vice President Whitley & Whitley Inc. 20600 Chagrin Boulevard Tower East Shaker Heights Ohio 44122; Dear Mr. Whitley: This responds to your February 8, 1980, letter asking whether th CarVan that you manufacture would be required to comply with Federal safety standards. The CarVan is designed to be mounted over the trunk of a car and weight approximately 80 pounds.; The CarVan is considered a piece of motor vehicle equipment fo purposes of compliance with the motor vehicle safety standards. Since it does not slide into the cargo area of a truck, however, it would not be considered a slide-in camper subject to Standard No. 126, Truck-Camper Loading. However, as a piece of equipment, it would be required to comply with Standard No. 205, *Glazing Materials*. I am enclosing an information sheet detailing where you can obtain a complete copy of all motor vehicle safety standards.; The agency notes that the CarVan would be installed in such a locatio that it would obscure the rear lights of the vehicle upon which it is mounted. The agency considers this to be very dangerous and concludes that you should adopt a tail light system for the CarVan. The Federal safety standard for lighting is Standard No. 108. Without a tail light system, the agency concludes that the installation and use of your CarVan would constitute a safety related defect, and we would exercise our authority to require any such defect to be remedied. We also note also that many States prohibit any device that covers the licence plates.; The agency would like to take this opportunity to correct som misinformation that was supplied to you an May 4, 1978, when we responded to your previous request for information on a camper that was designed to be loaded in a car's trunk.; In that letter, the agency stated that the camper would be required t comply with Standard No. 126. That statement is incorrect. Since your camper is designed for a passenger car and not a truck, it would not be required to comply with Standard No. 126. It would be subject to the other standard mentioned above for the CarVan. We regret any inconvenience our error may have caused you.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0399OpenMr. Fred W. Cords, O.E.M. Marketing Manager, Minnesota Automotive, Inc., 502 Patterson Avenue, Mankato Minnesota 56001; Mr. Fred W. Cords O.E.M. Marketing Manager Minnesota Automotive Inc. 502 Patterson Avenue Mankato Minnesota 56001; Dear Mr. Cords: This is in reply to your letter of June 29 asking whether th installation of MICO brake locks, as a supplemental parking brake system, is acceptable to the National Highway Traffic Safety Administration.; We understand that the MICO brake lock is used only in hydraulic brak systems of trucks. There is no Federal motor vehicle safety standard currently in effect covering truck hydraulic brake systems, and installation of MICO brake locks by a dealer, prior to first sale of a vehicle, is permissible as long as the lock does not impair conformance of brake hoses and brake hose assemblies with Federal Motor Vehicle Safety Standard No. 106. That the installation might impair conformance is inferred in the Chevrolet Dealer letter, DD-1412, May 10, 1971, which you enclosed.; A proposal has been issued (Docket No. 70-27) that would require truck equipped with hydraulic brake systems to meet certain performance requirements, effective with trucks manufactured on or after October 1, 1972. If this proposal is adopted as a Federal standard, installations of the MICO supplemental brake system on a truck, by a dealer, prior to first sale of a vehicle would be allowable as long as the installation does not affect conformance of the required mechanical parking brake system with Federal requirements, or with Standard No. 106.; Sincerely (signature illegible) |
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ID: aiam4652OpenMr. John E. Hammer John E. Hammer & Associates 235 W. Hamilton Lane Battle Creek, MI 49015; Mr. John E. Hammer John E. Hammer & Associates 235 W. Hamilton Lane Battle Creek MI 49015; "Dear Mr. Hammer: This responds to your inquiry about the attachment o a rigid hood ornament onto a motor vehicle. You explained that you were developing an aftermarket kit to help prevent the theft of such hood ornaments. You asked about the legalities of an individual owner using such a kit to attach a hood ornament. As explained below, while the agency does not regulate the actions of an individual vehicle owner, you as the manufacturer will have responsibilities under the National Traffic and Motor Vehicle Safety Act ('Vehicle Safety Act'). A replacement hood ornament kit would be considered 'motor vehicle equipment' under section 102(4) of the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act). That section defines, in relevant part, the term 'motor vehicle equipment' as: any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle.... The Safety Act gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Although NHTSA has issued motor vehicle safety standards for certain types of motor vehicle equipment, there is no standard directly applicable to hood ornaments. Thus, the manufacture and sale of the aftermarket product to a vehicle owner for use with his or her vehicle would not be affected by the requirements of any Federal motor vehicle safety standard. Although no standard directly applies to a hood ornament, there are several statutory provisions of which you should be aware. First, /108(a)(2)(A) of the Vehicle Safety Act states 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... If using the hood ornament would adversely affect compliance with a safety standard, then a manufacturer, distributor, dealer, or repair business installing this product would 'render inoperative' a design element in compliance with a Federal motor vehicle safety standard. The person who committed such an act would have violated /108(a)(2)(A), and would be subject to a civil penalty of up to $1000 for each /108 violation where a design element was 'rendered inoperative.' However, the provisions of 108(a)(2)(A) do not apply to the actions of a vehicle owner in adding or otherwise modifying his or her vehicle. Thus, a vehicle owner would not violate the Act by using the hood ornament kit even if doing so would adversely affect some safety feature in his or her vehicle or equipment. Second, you will be a motor vehicle equipment manufacturer if you offer this product for sale. As a manufacturer, you will be subject to the requirements of //151-159 of the Safety Act (15 U.S.C. 1411-1419), concerning the recall and remedy of products with defects related to motor vehicle safety. Section 102(11) of the Vehicle Safety Act defines 'defect' as 'any defect in performance, construction, components, or materials in motor vehicles or motor vehicle equipment.' (emphasis added). Section 102(1) defines 'motor vehicle safety' as 'the performance of motor vehicles or motor vehicle equipment in such a manner that the public is protected against unreasonable risk of accidents occurring as a result of design, construction or performance of motor vehicles...' (emphasis added). If you or the agency determined that the product had a defect related to motor vehicle safety, you would have to notify all product purchasers of the defect, and either: 1. repair the product so that the defect is removed, or 2. replace the product with an identical or reasonably equivalent product that does not have the defect. The manufacturer would have to bear the full expense of the notice-and-recall campaign, irrespective of the option chosen, for any owner who purchased the product less than eight years before the notice-and-recall campaign. The agency does not determine the existence of safety-related defects, except in the context of a defect proceeding. I note that hood ornaments typically are constructed to yield to pressure so as to reduce the risk of injuries to pedestrians. Therefore, it is possible that a rigid, non-yielding ornament might be considered a safety related defect if the rigid design were determined to pose an unreasonable safety risk. I hope you find this information helpful. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam3344OpenMr. R. H. Madison, Engineering Consultant, 12814 Ashbury Drive, Tantallon, MD 20022; Mr. R. H. Madison Engineering Consultant 12814 Ashbury Drive Tantallon MD 20022; Dear Mr. Madison: This responds to your June 25, 1980, letter asking whether a propose air brake system that you submitted would comply with the requirements of Standard No. 121, *Air Brake Systems*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of systems constructed in compliance with safety standards. It is the responsibility of manufacturers to assure that their vehicles or equipment comply with the requirements of the safety standards. It is frequently impossible for the agency to tell from diagrams and descriptions of devices whether they will comply with the standards. Compliance is based upon testing and observation of the entire vehicle or piece of equipment as it is installed on the vehicle. Without the benefits of such tests, NHTSA cannot state whether your system would comply with Standard No. 121.; Our engineering staff has reviewed your letter and offers the followin information. First, the standard contains no requirements for tractor protection valve control pressures. However, control pressures are usually set so that the trailer brakes apply before the tractor brakes.; Second, you asked whether it is appropriate to require the release o parking brakes by pushing in both the tractor protection control valve and the park valve. The standard states that the parking brake control shall control the parking brakes of the vehicle and any vehicle it is designed to tow. The standard is silent regarding the release of those brakes.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5632OpenMr. Larry W. Strawhorn Vice President of Engineering American Trucking Associations 2200 Mill Road Alexandria, VA 22314-4677; Mr. Larry W. Strawhorn Vice President of Engineering American Trucking Associations 2200 Mill Road Alexandria VA 22314-4677; "Dear Mr. Strawhorn: This letter responds to your request for a interpretation of the antilock malfunction indicator requirements set forth at S5.2.3.3 of Standard No. 121, Air Brake Systems. This provision explains the situations in which the trailer lamp malfunction indicator must remain activated. Section S5.2.3.3 reads as follows: S5.2.3.3 Antilock Malfunction Indicator. Each trailer (including a trailer converter dolly) manufactured on or after March 1, 1998 and before March 1, 2006 shall be equipped with a lamp indicating a malfunction of a trailer's antilock brake system. Such a lamp shall remain activated as long as the malfunction exists whenever the power is supplied to the antilock brake system. The display shall be visible within the driver's forward field of view through the rearview mirror(s), and shall be visible once the malfunction is present and power is provided to the system. (Emphasis added.). In particular, you request that the agency confirm your belief that the lamp activation pattern for trailers may be such that the bulb be ON when the antilock system is working properly and OFF when a malfunction exists, the antilock system is not getting electrical power, or the lamp bulb is burnt out. You contended that such an activation pattern provides a fail safe pattern i.e., it will signal an inoperative antilock system even when the system is not receiving electrical power or the lamp bulb is burnt out. NHTSA disagrees with your suggested reading of the malfunction indicator requirements. Such a reading would be inconsistent with S5.2.3.3's language stating that the lamp must 'remain activated as long as the malfunction exists whenever the power is supplied to the antilock brake system.' As with other malfunction indicators, the agency intends the malfunction indicator to activate when a malfunction exists and not activate when the system is functioning properly. To require otherwise would be inconsistent with our requirements for other indicators and thus would create confusion. Please note that NHTSA provided a lengthy discussion about the issue of a malfunction indicator's activation protocol in the March 10, 1995 final rule. (60 FR 13216, 13246) The agency stated that in response to an ABS malfunction, a trailer or tractor indicator must activate and provide a continuous yellow signal. The agency explained that such a common indicator pattern standardizes the activation format, thus reducing ambiguity and confusion and expediting Federal and State inspections. I hope this information has been helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3207OpenMr. Joe Cain, Ross Frame & Axle, Inc., P.O. Box 343, Ross, OH 45061; Mr. Joe Cain Ross Frame & Axle Inc. P.O. Box 343 Ross OH 45061; Dear Mr. Cain: This responds to your January 8, 1980, letter asking whether th computers connected to the air brake systems of trucks can be disconnected.; The computerized braking systems were used by some manufacturers t comply with the requirements of Standard No. 121, *Air Brake Systems*. Part of that safety standard was invalidated by the court in *PACCAR v. NHTSA*, 532 F2d. 632 (9th Cir. 1978). In that decision, the Court invalidated portions of the standard involving some of the road test requirements for trucks and trailers. The computer systems that you question were usually added for purposes of complying with the invalidated antilock sections of the standard.; The agency has previously addressed the question of whether th antilock system can be disconnected in light of the court decision. Section 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 systems 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.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2250OpenMr. Ron Stacy, School District No. 12, Adams County, 10280 North Huron Street, Denver, CO 80221; Mr. Ron Stacy School District No. 12 Adams County 10280 North Huron Street Denver CO 80221; Dear Mr. Stacy: This responds to your March 5, 1976, request for written permission t deactivate the '121 brake system' of a school bus manufactured from a Ford chassis with a Kelsey-Hayes antilock system.; From the description of the problems you have encounted (sic) with thi vehicle, I assume that you do not intend to disconnect the entire '121 brake system', but only one or more antilock systems installed in satisfaction of the 'no lockup' requirements of S5.3.1 of Standard No. 121, *Air Brake Systems*. The National Highway Traffic Safety Administration (NHTSA) has made a finding that early models of the antilock system supplied on transit and intercity buses is characterized by malfunction that warrants its deactivation until a correction is fully developed. This finding was not made with regard to the Kelsey-Hayes system that equips your vehicle.; Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safet Act (15 U.S.C. S 1397(a)(2)(a)) prohibits, with one exception, knowing disconnection of the antilock system by manufacturers, distributors, dealers, or repair businesses. A person that does not fall into these categories is not prohibited from disconnection of the system. Other State or Federal requirements, such as those of the Bureau of Motor Carrier Safety, may prohibit disconnection. In any case, the NHTSA urges that you not disconnect safety devices without consulting the vehicle manufacturer with regard to the safest configuration of the vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4559OpenLance E. Tunick, Esq. Vice President and General Counsel Maserati Automobiles, Inc. 1501 Caton Avenue Baltimore, MD 21227; Lance E. Tunick Esq. Vice President and General Counsel Maserati Automobiles Inc. 1501 Caton Avenue Baltimore MD 21227; "Dear Mr. Tunick: This responds to your October 20, 1988 letter, i which you asked for an interpretation of Standard No. 208, Occupant Crash Protection (49 CFR 571.208). More specifically, you noted that section S4.1.3 requires a specified percentage of a manufacturer's annual production to be equipped with automatic occupant protection. You stated that some vehicles imported into the United States may subsequently be exported to Canada. Since section 108(b)(5) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(b)(5), the Safety Act) specifies that none of the safety standards apply to vehicles intended solely for export, your company assumes that it should not include vehicles subsequently exported to Canada in its annual production totals when determining compliance with S4.1.3 of Standard No. 208. This assumption is incorrect, as explained below. In a September 4, 1985 letter to Messrs. Stephen Waimey and Dean Hansell (copy enclosed), we answered the question of how manufacturers that produce cars outside the United States should calculate their annual production to determine compliance with the phase-in requirements of Standard No. 208. That letter explains that foreign-based manufacturers should count the number of vehicles that were produced and certified for sale in the United States, in accordance with 49 CFR Part 567, Certification, during the relevant time period to determine their annual production for the purposes of Standard No. 208. Your letter referred to section 108(b)(5) of the Safety Act, and suggested that this statutory provision means that any vehicles that are imported into the United States and subsequently exported to a different country should not be counted as part of the manufacturer's annual production. I am happy to explain our view of what is permitted under that statutory provision. Section 108(b)(5) provides that the requirements in the safety standards 'shall not apply in the case of a motor vehicle or item of motor vehicle equipment intended solely for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.' This statutory language establishes three separate conditions that would have to be satisfied to exclude a vehicle from the requirements of the safety standards, including the calculation of a manufacturer's annual production for purposes of Standard No. 208. These three conditions are: 1. The vehicle must be intended solely for export, 2. The vehicle must have a label or tag on it at the time it is imported which shows that the vehicle is intended solely for export, and 3. The vehicle must actually be exported. We agree with your contention that a vehicle satisfying all three of these conditions would not be subject to the requirements of any of the safety standards, and could properly be excluded from the calculation of a manufacturer's annual production for the purposes of Standard No. 208. For a similar interpretation regarding imported tires that are intended solely for export and so labeled, see the enclosed November 10, 1975 letter to Mr. John B. White. Of course, it would not be sufficient if only one of these conditions, such as the third one regarding actual exportation, were satisfied. We are uncertain regarding the facts surrounding the vehicles that have already been imported into the United States and then exported to Canada and thus are unable to give an opinion concerning their satisfaction of the section 108(b)(5) conditions. It should be relatively simple for you to determine whether these vehicles satisfied the first two conditions. Did those vehicles truly just pass through the US on their way to Canada? To what country's standards were those vehicles certified and when? When the vehicles were imported into the United States, your company was required to complete a Form HS-7. That form allows the importer to declare that a vehicle is intended solely for export and that the vehicle bears a label or tag to that effect. What type of declaration was made with respect to the vehicles in question? As to vehicles which Maserati Automobiles, Inc., wishes in the future to import into this country and pass directly through to Canada for sale there, satisfaction of each of the three section 108(b)(5) conditions will assure that the vehicles are not included in the Standard No. 208 calculations. If you have any further questions or need additional information on this subject, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosures"; |
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ID: aiam2366OpenMr. W.M. Page, Senior Engineer, Clayton Dewandre Company Limited, P.O. Box 9, Titanic Works, Lincoln LN5 7JL, England; Mr. W.M. Page Senior Engineer Clayton Dewandre Company Limited P.O. Box 9 Titanic Works Lincoln LN5 7JL England; Dear Mr. Page: This responds to Clayton Dewandre Company's May 20, 1976, request fo confirmation that its 'Dual Brake Booster' system is designed to conform to the definition of 'split service brake system' and the requirements of S5.1.2 and S5.1.3 specified in Standard N0. 105-75, *Hydraulic Brake Systems*. in unimpaired braking circuits, the primary circuit which is initially powered by the driver's application of pedal force and subsequently supplemented by pressurized fluid from the pump accumulator system, and the secondary circuit which is powered by pressurized fluid from the pump accumulator system. In the event of a primary circuit failure, a mechanical connection unimpaired by a loss of reservoir fluid continues to modulate the secondary circuit. In event of a secondary circuit failure, the driver's pedal application continues to actuate the primary circuit by muscular effort alone. A single master cylinder reservoir is provided to supply the primary circuit. A single pump reservoir supplies the pump, accumulator, and secondary circuit.; As you are no doubt aware, the National Traffic and Motor Vehicl Safety Act does not authorize a 'type approval' of vehicle design as the basis for certification (15 U.S.C. S 1397(a) (1) (A)). Our comments on the description of your system do not relive the vehicle manufacturer of its responsibility to design a system for each of its products that actually complies with the standard's requirements.; From your description of the system, it would appear to qualify as 'split service brake system' as that term is defined in S4 of the standard. You state that, in the event either of indefinite operation. This conforms to the NHTSA's September 14, 1973, letter to Citroen on the meaning of 'unimpaired operation' of a subsystem.; With regard to partial failure performance, your state that the vehicl can meet the requirements of S5.11.2 (inadvertently designated as S5.1.1 in your letter) using either of two subsystems.; With regard to the requirements of S5.1.3 (for inoperative brake powe assist unit or brake power unit), you indicate that the vehicle is capable of stopping within the specified distances of column IV of Table II 'purely by muscular effort of the driver'. By this we assume you mean that the vehicle conforms to the condition required for testing under S5.1.3.1, *i.e.*, with one power unit inoperative and deleted of all reserve capability. Please note that the NHTSA regards the 'pump and accumulator' energy source to constitute a 'brake power unit' and not a 'brake power assist unit', because the described unit 'provides the energy required to actuate the brakes, either directly or indirectly through the auxiliary device, with the operator action consisting only of modulating the energy applica- tion level.' (S4 definition of 'brake power').; We are assuming that Clayton Dewandre does not object to making publi the designs described in your May 20 letter.The NHTSA will place the materials in the public docket three weeks after the date of this letter unless we hear otherwise from you.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam1578OpenMr. R. L. Limbaugh, General Manager, Rite-Way Inc. of Indiana, 4301 Bluffton Road, Fort Wayne, IN 46809; Mr. R. L. Limbaugh General Manager Rite-Way Inc. of Indiana 4301 Bluffton Road Fort Wayne IN 46809; Dear Mr. Limbaugh: This responds to your July 29, 1974, request for a copy of ou temporary exemption regulations, and for information on the effective date of Standard No. 121, *Air brake systems*, as it applies to vehicles with a driven front axle. I have enclosed a copy of NHTSA's 'Temporary Exemption' regulations, Part 555 of Title 49, the Code of Federal Regulations.; Standard No. 121 applies to trucks manufactured on or after March 1 1975, with only limited exceptions. Fire trucks are excluded from regulation until September 1, 1975, and vehicles with an overall width of 108 inches or more or a gross axle weight rating for any axle of 24,000 pounds or more, are excluded until September 1, 1976.; In addition, a truck manufactured before September 1, 1975, that has front steerable axle with a gross axle weight rating of 16,000 pounds or more, or a front steerable drive axle, is exempt from some of the stopping distance requirements if its brakes conform to a certain retardation force and values. Aside from these exemptions, any truck with a front steerable drive axle must meet all other requirements of the standard.; Yours truly, Richard B. Dyson, Acting 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.