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: aiam3450OpenMr. Marshall Zaun, President, Sigma Six Inc., P.O. Box 4272, Westlake Village, CA 91359; Mr. Marshall Zaun President Sigma Six Inc. P.O. Box 4272 Westlake Village CA 91359; Dear Mr. Zaun: This responds to your July 29, 1981 letter asking whether three-wheeled vehicle would be classified as a motorcycle for purposes of complying with the motor vehicle safety standards.; The term 'motorcycle' is defined in our regulations as 'a motor vehicl with motive power...designed to travel on not more than three wheels in contact with the ground' (Volume 49, Code of Federal Regulations, Part 571.3). Since your vehicle is designed to travel on three wheels, it would be classified as a motorcycle for purposes of complying with the safety standards. The agency plans no major rulemaking at this time that would change the definition of motorcycle or the standards with which these vehicles comply.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0020OpenMr. Earl W. Kinter, Arent, Fox Kinter, Plotkin & Kahan, 1100 Federal Bar Building,1815 'H' Street, NW,Washington D.C. 20006; Mr. Earl W. Kinter Arent Fox Kinter Plotkin & Kahan 1100 Federal Bar Building 1815 'H' Street NW Washington D.C. 20006; Dear Mr. Kinter:#This is in response to your letter of April 7, 1967 in behalf of the Motor Equipment Manufacturers Association (MEMA) regarding the application of the Initial Motor Vehicle Safety Standard to original equipment and replacement parts.#I am pleased to have this opportunity to answer the questions which have been raised by the MEMA members and outlines in your letter. Before doing so, however, I would like to briefly discuss and clarify the effect of the actions taken March 29, 1967, by the National Traffic Safety Bureau, regarding Standard Nos. 111 and 206.#In your letter you have quoted certain language from the preamble to the amendments of Standards Nos. 111 to 206, and interpreted such language to mean that original equipment manufactured on or after January 1, 1968, and replacement parts for vehicles manufactured on or after that date, fall within the regulations of these two Standards. I must advise that this interpretation in not correct. These standards as now amended no longer apply to equipment, but only to the vehicles specified in the standard when such vehicles are completed by the vehicle manufacturer on or after January 1, 1968.#It should be noted that where, as in the case of amended Standard Nos. 111 and 206, the paragraph designated 'S.2' and entitled, 'Application,' refers only to vehicles and not to vehicle equipment, the person responsible for compliance is the vehicle manufacturer. This is true notwithstanding the fact that identifiable equipment may be referred to and made the subject of control in some other paragraph of the standard. For example, Standard No. 107, in paragraph S4, refers to the 'horn ring and hub of steering wheel assembly, 'and prohibits a specular gloss of the surface of such equipment from exceeding a specified brightness. The vehicle manufacturer is solely responsible for compliance with this requirement.#There are now sixteen of the twenty initial standards which require compliance only by the vehicle manufacturer. However, Standard Nos. 106,205,209 and 211 each refer to *equipment* for use in specified motor vehicles in the application paragraph. Compliance and certification is required by both equipment manufacturer and vehicle manufacturer with regard to these four standards.#I will now direct myself to your specific questions which I will quote and follow with a brief answer.#(1) Do all the Initial Standards require *compliance and certification* by parts manufactured as to *replacement parts* for vehicles manufactured *after* January 1, 1968?#Answer: No, only Standard Nos. 106,205,209 and 211. #(2) Which of the Initial Standards, if any, apply to *replacement parts* produced on or after January 1, 1968, for vehicles manufactured *prior* to that date?#Answer: Standard Nos. 106,205,209 and 211. #(3) With respect to question 2, is a certification required of the affected equipment manufacturers in such cases?#Answer: Yes. #(4) With respect to question 1-3, are the compliance and certification requirements any different where the replacement parts involved are *identical* to the original equipment for vehicles produced on or after January 1, 1968?#Answer: No. #(5)Do the Initial Standards require manufacturers of *original equipment* produced on or after January 1, 1968, to certify their products?#Answer: The requirement for certification of motor vehicle equipment found in section 114 of the National Traffic and Motor Vehicle Safety Act, provides in the pertinent part that:#>>>'Every manufacturer or distributor of ... motor vehicle equipment shall furnish to the *distributer or dealer* at the time of delivery of such ... equipment ... the certification that each such ... item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards ...'(emphasis supplied).<< |
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ID: aiam2619OpenMr. Jack Gromer, Vice President - Technical Operations, Timpte, Inc., 5990 N. Washington Street, Denver, Colorado 80216; Mr. Jack Gromer Vice President - Technical Operations Timpte Inc. 5990 N. Washington Street Denver Colorado 80216; Dear Mr. Gromer: This responds to your May 6, 1977 letter asking whether your tir information label complies with the requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, and Part 567, *Certification*. Further, you request that the National Highway Traffic Safety Administration (NHTSA) expedite treatment of Docket No. 73-31, Notice 1, which, if implemented would simplify the certification and information labels.; Concerning Docket 73-31, the NHTSA published on June 20, 1977, a notic (42 FR 31161) implementing Notice 1 which proposed the use of the designation 'all axles' rather than listing each axle individually on the certification label. The implementation of this regulation should resolve many of your problems.; Regarding the sample information label you submitted with your letter the NHTSA does not give advance approvals of compliance with Federal safety regulations or standards. We will, however, giver an informal opinion of whether your label appears to comply with the requirements. The label you submitted does not appear to comply with the requirements of Part 567 or Standard No. 120. I have enclosed copies of both these regulations for your information.; Your certification label should use the designation 'all axles' no 'each axle.' The tire and rim information should follow that designation stated in the form presented in the examples in Standard No. 120 and Part 567.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4629OpenMr. William L. Dunlap Engineering Manager Philips Industries, Inc. Dexter Axle Division 500 Collins Road Elkhart, IN 46515; Mr. William L. Dunlap Engineering Manager Philips Industries Inc. Dexter Axle Division 500 Collins Road Elkhart IN 46515; "Dear Mr. Dunlap: This responds to your request for an interpretatio of Standard No. 120, Tire Selection and Rims for Motor Vehicles other than Passenger Cars (49 CFR /571.120, copy enclosed). I apologize for the delay in this response. You stated that your company manufactures rims that you sell to other wheel manufacturers. These wheel manufacturers combine your company's rims with center disc sections of their own design to produce finished wheels for use on light trucks and trailers. Section S5.2(c) of Standard No. 120 specifies that each rim shall be marked with certain information. You asked whether your company, as the rim manufacturer, or any subsequent manufacturer that uses your company's rims to produce complete wheels is required to mark the rims in compliance with section S5.2(c). The answer is that the rim manufacturer is responsible for those markings, as explained below. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A), the Safety Act) specifies that 'No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any ... item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ...' In this case, section S5.2 of Standard No. 120 requires certain markings to appear on all newly manufactured rims for use on motor vehicles other than passenger cars. These requirements became effective August 1, 1977. Thus, section 108 of the Safety Act makes it illegal for any person to 'manufacturer for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any rim manufactured on or after August 1, 1977 designed for use on motor vehicles other than passenger cars unless that rim is marked in accordance with section S5.2 of Standard No. 120. Your company would violate this provision of the law if you were to sell light truck rims without the required markings, even if the party to whom you sold such rims was going to use the rims to produce completed wheel assemblies. You suggested in your letter that your company's markings on its rims used by other manufacturers to produce completed wheel assemblies may be misleading or unfair, because your company has no control over the integrity of the completed wheel assemblies. This may represent a misunderstanding of the meaning and purpose of the required rim markings. The markings and certification required on rims for motor vehicles other than passenger cars by section S5.2 of Standard No. 120 provide information about only the rims, not the entire wheel assembly. In your letter, you indicated that other wheel manufacturers simply add center discs to your company's rims to produce completed wheel assemblies. In these circumstances, the accuracy of the markings and certification put on a rim by your company as the rim manufacturer would not be affected by another manufacturer simply adding a center disc to that rim to produce a completed wheel assembly. If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam2127OpenMr. Kenneth J. Bena, Safety Advisor, The Cleveland Electric Illuminating Co., Illuminating Bldg., Public Square, Cleveland, OH 44101; Mr. Kenneth J. Bena Safety Advisor The Cleveland Electric Illuminating Co. Illuminating Bldg. Public Square Cleveland OH 44101; Dear Mr. Bena: This is in further response to your letter of June 11, 1975, to Mr Kenneth Bowman, Area Director, Cleveland, Ohio, concerning the legal responsibilities of a person who modifies a motor vehicle.; >>>IMPACT OF FEDERAL LAW<<< A person who performs work on a vehicle prior to the first purchase o a the vehicle in good faith for purposes other than resale may be subject to the regulations of the National Highway Traffic Safety Administration (NHTSA) either as an alterer of a completed vehicle or as a final-stage manufacturer of an incomplete vehicle. A vehicle is 'complete' only if it bears a certification label stating conformity to all applicable Federal regulations.; In addition, the National Traffic and Motor Vehicle Safety Act provide 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.' (Sec. 108(a)(2)(A), Pub. L. 93-492, 88 Stat. 1470, 15 U.S.C. S 1397(a)(2)(A))<<<; This prohibition applies both before and after the first purchase of motor vehicle, but does not apply to work performed on a vehicle by the individual owner of the vehicle. In addition, exceptions are provide to permit the rendering inoperative of safety belt interlocks and continuous buzzers after the first purchase of the vehicle, and in certain circumstances just before first purchase.; >>>VEHICLE ALTERATION<<< The regulations of the NHTSA cover two types of vehicle alterations The first is an alteration of a completed vehicle by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting which do not alter the vehicle's stated weight rating (49 CFR S 567.6). This type of alteration does not involve any additional responsibilities by the alterer.; The second type of alteration is an alteration of a certified vehicl by means other than the addition, substitution, or removal of readily attachable components or minor finishing operations, or alteration in such a manner that the vehicle's stated weight ratings are no longer valid (49 CFR S 567.7). This type of alteration, if done prior to the first purchase of the vehicle for purposes other than resale, must include, in addition to the certification label, a label stating that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards and containing the firm or individual name of the alterer (49 CFR S 567.7).; >>>COMPLETION OF VEHICLE MANUFACTURE<<< If a vehicle (such as a chassis-cab) requires further manufacturin operations in order to become a completed vehicle, the completion of the vehicle constitutes final manufacture and necessitates compliance with the certification requirements of 49 CFR SS 567.5 and 568.6. The name of the final-stage manufacturer must appear on the certification label as the manufacturer, unless the incomplete vehicle manufacturer assumes legal responsibility for the vehicle as finally manufactured (49 CFR SS 567.5, 568.6 and 568.7).; To aid the final-stage manufacturer, the incomplete vehicl manufacturer is required to furnish with the incomplete vehicle a statement including the weight ratings of the vehicle if completed as intended, descriptions of the Federal motor vehicle safety standards applicable to the vehicle, and the conditions under which final completion of the vehicle will comply with such standards (49 CFR S 568.4). If the final-stage manufacturer follows these instructions and conditions, the liability for non- compliance with a safety standard will be on the incomplete vehicle manufacturer. Although the certification requirements may be modified as a result of litigation, the NHTSA will consider compliance with the published requirements to meet any manufacturer's responsibilities under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1403 *et seq*.).; Final- stage manufacturers are also subject to the manufacture identification rules of 49 CFR S 566, which require manufacturers to submit to the NHTSA identifying information and descriptions of the items they produce. A final-stage manufacturer may also be subject to the defect reporting requirements of 49 CFR S 573, which concern a manufacturer's responsibilities to report safety- related defects. Enclosed are copies of section 108 of the National Traffic and Motor Vehicle Safety Act, and Parts 566, 567, 568 and 573 of the NHTSA's regulations. In addition, we are enclosing a copy of 'Standards', a summary description of the Federal motor vehicle safety standards.; If you have any questions concerning the foregoing regulations or an Federal motor vehicle safety standard, we suggest you write; >>>Chief Counsel, National Highway Traffic Safety Administration, 40 Seventh Street, S.W., Washington, D.C. 20590<<<; We hope that this information has been of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2125OpenMr. Charles F. Butler, President, Butler Associates, Inc., Post Office Box K, Washington, DC 20014; Mr. Charles F. Butler President Butler Associates Inc. Post Office Box K Washington DC 20014; Dear Mr. Butler: I am writing in response to your September 22, 1975, letter concernin safety standards applicable to your 1975 Ford Custom Wagon. Your letter was referred to this agency by Senator Magnuson.; I am enclosing a brochure entitled *Standards* which briefly lists th Federal motor vehicle safety standards and the vehicles to which they apply.; Most of the standards were initially applied to passenger cars becaus they accounted for the vast majority of traffic deaths and injuries. Your Custom Wagon is classified for the purposes of our standards as a multi-purpose passenger vehicle (MPV). Each particular type of vehicle, such as a car, small or large truck, van, bus, or motorcycle, has its own design characteristics and configuration, with widely different causes of crash injury and fatality. Since the original Federal standards were established in 1967, effective January 1, 1968, we have been in the process of extending the applicability of our current standards and of preparing new standards where appropriate to other vehicle types, including MPV's. For example, effective January 1, 1976, all trucks and MPV's with a Gross Vehicle Weight Rating of 10,000 pounds or less will be required to be equipped with combination lap and shoulder belts with inertial retractors, just as has been required of passenger cars since September 1973. With the constantly improving accident investigation information on how and why particular injuries occur in particular types of vehicles, we expect to be able to determine which safety items are necessary and will do the most good on all vehicles. We will then issue appropriate standards as rapidly as possible.; I appreciate your concern over the safety of our motor vehicles. Sincerely, James B. Gregory, Administrator |
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ID: aiam5146OpenMr. A. L. Bragg Laboratory Manager Truck-Lite Co., Inc. 310 East Elmwood Ave. Falconer, NY 14733; Mr. A. L. Bragg Laboratory Manager Truck-Lite Co. Inc. 310 East Elmwood Ave. Falconer NY 14733; Dear Mr. Bragg: We have received your letter of February 22, 1993, t Paul Jackson Rice, the former Chief Counsel of this agency, with respect to his letter of December 30, 1992, to Stanley Electric Co. Ltd. In your opinion, the letter, which interpreted Safety Standard No. 108 as it applies to light- emitting diodes (LEDs), raises certain problems. You are correct that NHTSA equates individual LEDs with lighted sections. Currently, this is the only way in which NHTSA can relate LEDs to Standard No. 108, a standard based upon lamps with incandescent light sources. For this reason, NHTSA has begun to consider possible amendments to Standard No. 108 that would recognize, as the SAE has done with J1889, the advent of lamps with LED light sources. Should NHTSA then publish a notice of proposed rulemaking on this subject, we would welcome your further comments. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3808OpenMr. Don Gerken, Senior Product Engineer, Research and Development, COSCO, 2525 State Street, Columbus, IN 47201; Mr. Don Gerken Senior Product Engineer Research and Development COSCO 2525 State Street Columbus IN 47201; Dear Mr. Gerken: This responds to your letter asking for an interpretation of Safet Standard No. 213, *Child Restraint Systems* (49 CFR S 571.213). Specifically, you noted that your company would like to begin producing a child restraint system with a new shield design. The new shield would be substantially smaller than the shield your company currently uses. You noted that this type of shield is already being sold by other companies, and that in your restraint, the harness system, but not the shelf-like shield, would restrain the child's forward movement. A system with that characteristic would not comply with Standard No. 213.; Section S5.2.2.2 of Standard No. 213 specifies that no fixed or movabl surface shall be in front of the child, except surfaces which restrain the child. Since your proposed new shield does not restrain the child, it is expressly prohibited from being mounted on the child restraint.; Even assuming that the proposed new shield did act to restrain th child, there is still a question of whether the shield would comply with section S5.2.2.1(c), since your drawing does not indicate which portions of the shield would restrain a child's torso and thus would need to comply with the 2-inch radius of curvature requirement.; At this time, the Enforcement Division of this agency has severa investigations pending concerning potential violations of the standard by firms using shields along the lines of the shield you propose. These investigations focus primarily on whether such shields satisfy the 2-inch radius of curvature requirement of section S5.2.2.1(c) of Standard No. 213.; Please do not hesitate to contact me if you need further information o have further questions on this matter.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0522OpenMr. T. E. Needham, Engineering Department, Mechanisms Division, Amington Road, Birmingham B25 8EW, England; Mr. T. E. Needham Engineering Department Mechanisms Division Amington Road Birmingham B25 8EW England; Dear Mr. Needham: Your letter of November 4, 1971, concerning the compliance of two dua rear door locking systems with Standard 206, has been forwarded to this office for reply.; Both systems consist of >>>'. . . a primary locking system which when engaged renders th outside rear door handle and the inside rear door handle inoperative and a special locking device accessible from the door shut face, which when engaged renders the inside door handle inoperative but does not affect the outside door handle.'<<<; The systems differ in that engagement of the special locking device i the first system prevents the engagement of the primary locking system, while engagement of the special device in the second system does not have this effect.; As stated in the preamble to the April 27, 1968 amendment (33 F.R 6465) to the standard, S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be engageable or disengageable regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism, it will not constitute a failure to comply with the standard.; Under these criteria, the first dual system would not comply with th standard since engagement of the special locking mechanism would interfere with the operation of the primary locking mechanism.; The second dual system would comply if engagement of the specia locking mechanism would prevent neither the engagement nor the disengagement of the primary locking mechanism.; Please write if I can be of any further assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4945OpenMr. S. Suzuki Managing Director Suzusho Trading Co. Center Building No. 601 Fuchucho 1-12-7, Fuchu-shi Tokyo, Japan; Mr. S. Suzuki Managing Director Suzusho Trading Co. Center Building No. 601 Fuchucho 1-12-7 Fuchu-shi Tokyo Japan; Your ref: ST-9015/91 Dear Mr. Suzuki: This responds to your letter o October 16, l991, to the Director, Office of Public and Consumer Affairs, with reference to the 'Safety Shot' lighting device that you have developed. You have enclosed photographs illustrating three types of this device in operation. In brief, the device consists of a center red highmounted stop lamp, immediately flanked by amber lamps that serve as supplementary turn signal/hazard warning signal lamps. Although the photos are not entirely clear, the device appears to consist of segmented compartments in a common housing, with thicker dividers separating the signal and stop functions. Type I incorporates an L.E.D. and is mounted at the top of the rear window. Type II also incorporates an L.E.D. and is mounted at the bottom of the window. Type III is located at the top of the rear window and uses conventional bulbs for its light source. You have been referred to us by Chrysler Corporation. We assume that you approached Chrysler with a view towards having your device accepted as original motor vehicle equipment. You have asked for our views on whether it is possible to use this device in the U.S. market. In the United States, the applicable Federal motor vehicle safety standard for rear lighting is Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Section S5.4 of Standard No. 108 does not allow a center high-mounted stop lamp to be physically combined with any other lamp or reflective device. Because Safety Shot appears to have a common housing for signalling and stopping functions, the lamps are 'combined' within the meaning of the prohibition. This means that the Safety Shot may not be used as original equipment on motor vehicles, and it may not be offered as a replacement for original equipment center highmounted stop lamps (required on each passenger car manufactured on or after September 1, l985). If you wish to sell the Safety Shot as an accessory in the aftermarket, for passenger cars manufactured before September 1, l985, different considerations apply. Installation of the Safety Shot by a manufacturer, distributor, dealer, or motor vehicle repair business is not permitted if it renders inoperative, in whole or in part, the function of any other rear lighting device. The question, therefore, is whether the effectiveness of the function of any other rear lighting device is compromised by the Safety Shot to the extent that the other device's function is rendered, at the minimum, partially inoperative. We note that original equipment amber signal lamps are not prohibited from flashing when the stop lamps are operating. It would not appear that the addition of the Safety Shot to a passenger car manufactured before September 1, l985, would compromise the signals from the original turn signal and stop lamps in a manner to render them, at least, partially inoperative. However, the Safety Shot is subject to regulation by the individual States of the United States in which it is sold or used. We are unable to advise you on State laws, and suggest that you write for an opinion to American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Motor vehicles are also required to be manufactured to conform to Standard No. 111, Rearview Mirrors. Under this standard, if installation of the Safety Shot prevents the vehicle from meeting the rearview mirror field of view requirements specified, the manufacturer, distributor, dealer, or motor vehicle repair business installing the Safety Shot must install a rear view mirror on the passenger side of the vehicle (as a practical matter, most vehicles in the U.S. are manufactured with this additional mirror). Sincerely, Paul Jackson Rice 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.