NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam5162OpenAIR MAIL Mr. T. Kouchi Director Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan; AIR MAIL Mr. T. Kouchi Director Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Kouchi: This responds to your letter of April 2, 1993, to Pau Jackson Rice, the former Chief Counsel of this agency. You refer to Mr. Rice's letter of December 30, 1992, which you interpret as saying that 'any device that contains more than three lighted sections, or LEDs, need only comply with the requirements prescribed for three lighted sections.' You consider 'that the lamps having three lighted sections described in the attached drawing No. 1 & No. 2 need only comply with the photometric requirements prescribed for three lighted sections.' You ask 'if our idea is appropriate.' We confirm your interpretation with respect to drawing No. 1, which appears essentially the same as covered by Mr. Rice's interpretation. With respect to drawing No. 2, this lamp appears to be composed of a panel of LEDs flanked by two incandescent bulbs. When the LED panel alone is operated, or when it is operated in conjunction with either one or both of the incandescent bulbs the requirements applicable to three lighted sections will apply. However, each bulb is regarded as being a single light source so that if the bulbs are operated individually, only the requirements for single lighted sections apply. If the bulbs are operated simultaneously to perform the same function, the requirements for two lighted sections apply. However, if the bulbs are operated simultaneously to perform different functions, the single lighted section requirements apply and all other requirements such as contrast ratios (e.g., the l:5 for tail and stop lamps) must be met. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3937OpenMr. Robert L. Hart, 19459 Manor, Detroit, MI 48221; Mr. Robert L. Hart 19459 Manor Detroit MI 48221; Dear Mr. Hart: This is in reply to your letter of February 11, 1985, to former Chie Counsel Frank Berndt asking for an interpretation that a combination stop lamp-rear view mirror you have invented would be permissible under paragraph S4.4.1 of Standard No. 108.; That paragraphs precludes combining a center high-mounted stop lam with any other lamp or reflective device. You have concluded that the prohibition applies only to passenger cars manufactured after September 1, 1985, 'and does not prohibit application of my device to vehicles manufactured prior to the effective date of the mandate.'; Actually, S4.4.1 does not apply to your device at all. The lam established by the standard is one that is mounted on the vertical centerline of the vehicle, at or near the rear window with no relationship to the forward left side of the vehicle where your combination lamp-mirror would be located. Standard No. 108 does contain in paragraph S4.1.3 a prohibition against additional lighting devices that impair the effectiveness of the lighting equipment required by the standard. But on the basis of the facts as you have presented them to us, we cannot say that impairment would exist. We therefore conclude that your device is not prohibited by Standard No. 108 as either original or replacement equipment on any motor vehicle.; However, Motor Vehicle Safety Standard No. 111, *Rearview Mirrors* does relate to your device. Passenger cars are required to be equipped with an outside rear view mirror on the driver's side, under paragraph S5.2.2 '...neither the mirror nor the mounting shall protrude farther than the widest part of the vehicle body except to the extent necessary to produce a field of view meeting or exceeding the requirements of S5.2.1.' Some of your designs show the lamp portion at the left end of the device's housing resulting in a wider unit than one incorporating a mirror alone. We recommend that you re-examine these designs with paragraph S5.2.2 in mind, relocating the lamp to the area either above or below that of the mirror surface if you conclude that the combination mounting would not comply with Standard No. 111.; There is no similar mounting requirement for driver's side mirrors o vehicles other than passenger cars, and your designs for mirrors on these vehicles would appear permissible under Standard No. 111.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2925OpenMr. Donald W. Vescio, Sr., Director of Engineering, R. E. Dietz Company, 225 Wilkinson Street, Box 1214, Syracuse, NY 13201; Mr. Donald W. Vescio Sr. Director of Engineering R. E. Dietz Company 225 Wilkinson Street Box 1214 Syracuse NY 13201; Dear Mr. Vescio:#This responds to your letter of September 21, 1978 requesting interpretation of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*.#In your first set of questions, you ask about the application of the display requirements to trucks with GVWR of 10,000 pounds or more. Those requirements do not apply to such trucks. Under S5 of the standard, the only trucks required by the standard to comply with the display requirements are those with a GVWR less than 10,000 pounds.#In your second set of questions, you pose various questions about the identification and illumination of controls. In the first question, you ask whether the turn signal control symbol must be placed on the control itself. The answer is 'no.' S5.2.1 provides that the symbol shall be placed on *or* adjacent to the control. You also ask if there is any size requirement. The answer is again 'no.' There are no size requirements for any of the control symbols.#In your second question, you ask about the size requirements for the hazard warning signal control. As indicated above, there are no size requirements. As to illumination, S5.3.1 provides that hand- operated controls mounted on the steering column are not required to be illuminated. Thus, neither the turn signal control symbol nor the hazard warning control symbol need be illuminated. With regard to the non-mandatory red lens between the turn signal control symbol, if that lens is intended to call attention to the location of the hazard warning control, we urge that it be triangular. If it is intended to call attention to the turn signal control, we urge that the shape be made less similar to the hazard warning symbol to avoid confusion.#In your third question, you asked about the relationship between the control and display requirements in FMVSS 101 and those in FMVSS 108. The agency will soon issue a notice dealing with this issue.#Sincerely, Joseph J. Levin, Jr., Chief Counsel; |
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ID: aiam2923OpenMr. Donald W. Vescio, Sr., Director of Engineering, R. E. Dietz Company, 225 Wilkinson Street, Box 1214, Syracuse, NY 13201; Mr. Donald W. Vescio Sr. Director of Engineering R. E. Dietz Company 225 Wilkinson Street Box 1214 Syracuse NY 13201; Dear Mr. Vescio:#This responds to your letter of September 21, 1978 requesting interpretation of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*.#In your first set of questions, you ask about the application of the display requirements to trucks with GVWR of 10,000 pounds or more. Those requirements do not apply to such trucks. Under S5 of the standard, the only trucks required by the standard to comply with the display requirements are those with a GVWR less than 10,000 pounds.#In your second set of questions, you pose various questions about the identification and illumination of controls. In the first question, you ask whether the turn signal control symbol must be placed on the control itself. The answer is 'no.' S5.2.1 provides that the symbol shall be placed on *or* adjacent to the control. You also ask if there is any size requirement. The answer is again 'no.' There are no size requirements for any of the control symbols.#In your second question, you ask about the size requirements for the hazard warning signal control. As indicated above, there are no size requirements. As to illumination, S5.3.1 provides that hand-operated controls mounted on the steering column are not required to be illuminated. Thus, neither the turn signal control symbol nor the hazard warning control symbol need be illuminated. With regard to the non-mandatory red lens between the turn signal control symbol, if that lens is intended to call attention to the location of the hazard warning control, we urge that it be triangular. If it is intended to call attention to the turn signal control, we urge that the shape be made less similar to the hazard warning symbol to avoid confusion.#In your third question, you asked about the relationship between the control and display requirements in FMVSS 101 and those in FMVSS 108. The agency will soon issue a notice dealing with this issue.#Sincerely, Joseph J. Levin, Jr., Chief Counsel; |
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ID: aiam5095OpenMr. Richard Horian President, Woodleaf Corp. 1458 West 240th Street Harbor City, CA 90710-1393; Mr. Richard Horian President Woodleaf Corp. 1458 West 240th Street Harbor City CA 90710-1393; "Dear Mr. Horian: This responds to your two letters of November 6 1992, with respect to the allowability under Federal regulations of the 'Sudden Brake Indicator Hazard Light.' As you describe it, 'when a driver engages in hard braking, a circuit activates a separate lighting system to warn other drivers to pay special attention to a potentially hazardous situation.' This system will not utilize any of the existing rear lights on a vehicle, and will consist of a single lamp or pair of lamps, either mounted separately, or in the same housing as the center high-mounted stop lamp. The system will be red or amber in color, and either steady burning or flashing. The system is activated only when a predetermined threshold of pressure is reached upon depression of the brake pedal. Supplementary lighting systems such as the one you have described are permissible as original motor vehicle equipment under Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment if they do not impair the effectiveness of the lighting systems required by the standard, or if there is no provision of the standard that affects them. Paragraph S5.4 of Standard No. 108 specifically prohibits the physical combination of the center highmounted stop lamp with any other lamp or reflective device, thus your system could not be used in a common housing with the center light (see copy of enclosed letter to Mr. S. Suzuki on this subject). However, if the system is mounted separately, under the circumstances you have presented, we do not believe that there would be any direct impairment of the required rear lights, or indirect impairment such as might be created when confusion may result upon simultaneous operation of the supplementary light and any required light. As the letter to Mr. Suzuki indicates, passenger cars manufactured before September 1, 1985, were not required to be equipped with the center lamp. This means that your light could be combined in the same housing as a center lamp intended for installation on vehicles manufactured before September 1, 1985, but it could not be part of a replacement center lamp intended for use on vehicles manufactured subsequently. In addition, with the exception just noted, installation of the system on a vehicle in use would not appear to affect the safety functioning of any safety system necessary for continued conformance of the vehicle, it would appear that your system is acceptable for sale and installation in the aftermarket as well. However, the individual States have the authority to regulate lamps for vehicles in use, and we suggest that you contact the American Association of Motor Vehicle Administrators (AAMVA) for an opinion as to whether the system is permissible under State laws. AAMVA's address is 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Paul Jackson Rice Chief Counsel Enclosusre "; |
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ID: aiam4516OpenMr. Scott A. Snyder 117 South Keesey Street York, PA 17402; Mr. Scott A. Snyder 117 South Keesey Street York PA 17402; "Dear Mr. Snyder: This is in reply to your letter of March l0, l988, t the Department's regional office in Philadelphia, asking for a response concerning 'ornamental lighting.' In your opinion 'a few extra lights on the side and rear of a vehicle would help other people see you better while driving at night.' The agency is interested in the role that vehicle conspicuity plays in accidents and accident avoidance. With reference to motorcycles, we have amended our motor vehicle lighting standard to prescribe performance characteristics for headlamp modulation. We were prepared to amend the standard to require the activation of motorcycle headlamps when the ignition was turned on (but did not do so when we learned that almost all motorcycles were being wired to operate in that fashion). Some time ago we asked the public to comment on ways of increasing the conspicuity of large vehicles as our research had indicated that reflective tape applied to the side and rear of wide trucks and trailers might lessen crashes and crash severity, and our research still continues in this area. Most importantly we adopted the center highmounted stop lamp for passenger cars because of the ability it demonstrated in test fleets to reduce the frequency of rear end impacts. The type of lights of which you speak are referred to as 'presence' lamps (as contrasted with 'signal' lamps), and the agency over the years has acted with respect to all motor vehicles by requiring them to be equipped with side marker lamps, and by increasing the lens area for stop lamps. As the Federal safety standards are by statutory definition 'minimum' safety standards, the requirement that there be two taillamps, for example, does not mean that a manufacturer may not add two more if it wishes, or any lighting device not covered by the standard. The sole restriction is that lighting devices added by the manufacturer or dealer that are in excess of the minimum must not impair the effectiveness of the equipment required by the standard. This could happen, for example, if a fog lamp (not covered by the standard) was of an intensity and located so that it masked an adjacent front turn signal. With respect to nighttime operation, the critical issue would appear to be thatadditional lighting devices not create glare to oncoming and following drivers. The owner of the vehicle is not under a similar Federal restriction, and may personally add such additional lighting devices as seems desirable, subject to the laws of the States where the vehicle is registered and/or driven. However, the owner may not have these devices installed by a motor vehicle dealer or repair business if the result is to render wholly or partially inoperative any of the vehicle's original lamps or reflectors. We appreciate your suggestion for improving motor vehicle safety. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam4069OpenMr. Hans W. Metzger, 6326 E. Turquoise Avenue, Scottsdale, AZ 85253; Mr. Hans W. Metzger 6326 E. Turquoise Avenue Scottsdale AZ 85253; Dear Mr. Metzger: Thank you for your letter of October 14, 1985, asking several question about Standard No. 208, *Occupant Crash Protection*. I hope that the following discussion answers your questions.; You first asked for a clarification of S4.1.3.1.2. That sectio provides that a manufacturer must equip a specific amount of its vehicles manufactured on or after September 1, 1986, and before September 1, 1987, with automatic restraints. The amount must not be less than 10 percent of the average annual production of passenger cars manufactured for sale in the United States during the period September 1, 1983, to August 31, 1986 (the base period).; You explained that your client did not produce any vehicles for th U.S. during one year of the base period (September 1, 1983 - September 1, 1984). For the other two years of the base period, your client produced a limited number of vehicles for sale in the U.S. You asked whether in calculating the average yearly production for the base period, it is correct for your client to use zero for the production between September 1, 1983 and August 31, 1984, and the actual production figures for two subsequent years.; The three year base period addresses a situation where a manufacture has produced vehicles for sale in the U.S. in each of those years. The purpose of averaging the production is to ensure that the calculation of the percentage of a manufacturer's passenger cars that must comply with the automatic restraint requirements is based on a production figure which is representative of the manufacturer's typical production. In the case of a manufacturer who has produced vehicles for two of those years, it would defeat the purpose of the rule to allow the manufacturer to lower artificially the number of vehicles which must comply with the automatic restraint requirement by counting its production as zero for one of the base years. Thus, in a situation where a manufacturer has only two years of production, the manufacturer should calculate its base period average based on the number of vehicles produced during those two years.; To provide manufacturer's with additional flexibility in calculatin the number of passenger cars which must be equipped with automatic restraints, NHTSA proposed, on April 12, 1985 (50 FR 14589), an amendment to Standard No. 208 which would give manufacturers the option of using either a three year average or the actual production for the model year in question. We expect to issue shortly a final rule on this subject.; You also asked for another clarification of S4.1.3.1.2. You asked i the required number of vehicles can be produced anytime (sic) between September 1, 1986 and August 31, 1987. S4.1.3.1.2 does not require that the automatic restraints be installed at any specific time during that period. Thus, you are correct that the installation of automatic restraints does not have to be evenly distributed throughout that 12 month interval.; I hope this information is of assistance to you. If you have an further questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2083OpenMr. Lowell E. Schellhase, Motor Vehicle Inspection, 523 E. 12th Street, Des Moines, Iowa 50319; Mr. Lowell E. Schellhase Motor Vehicle Inspection 523 E. 12th Street Des Moines Iowa 50319; Dear Mr. Schellhase: This responds to your May 29, 1975, letter to Mr. Vincent Esposito o the National Highway Traffic Safety Administration (NHTSA), in which you indicate your desire that a 'second independent means of stopping be made mandatory' on newly-manufactured motor vehicles.; Federal motor vehicle safety Standard No. 105-75 (49 CFR 571.105-75 becomes effective January 1, 1976, for passenger cars, and it establishes requirements for the service and parking brake systems of these vehicles (copy enclosed).The test procedures for parking brake testing specify that the service brake control be released in testing the parking brake system. This has the practical effect of requiring a separate parking brake similar to that specified by the Iowa law you cited in your letter.; Federal motor vehicle safety Standard No. 121, (49 CFR 571.121) becam effective January 1, 1975, for air-braked trailers and March 1, 1975 for air-braked trucks and buses (copy enclosed). It establishes requirements for the service and parking brake systems of these vehicles. Section S5.6.4 of the standard states that 'The parking brake control shall be separated from the service brake control.'; Section 103(d) of the National Traffic and Motor Vehicle Safety Act i 1966 (15 U.S.C. 1392(d)) provides that no State or political subdivision of a State may promulgate or continue in effect standards applicable to on aspect of motor vehicle or motor vehicle safety standard, unless the standards are identical.; As noted, STandard No. 105-75 and Standard No. 121 include requirement for the parking brake control aspect of braking performance. The Federal requirements must be regarded as conclusive with regard to this aspect of performance in order to maintain the uniformity necessary in a Federal regulation scheme. If States were permitted to impose additional requirements in an area regulated by a Federal safety standard manufacturers would be confronted with an impossible task of compliance. This reasoning formed the basis of a recent decision rendered in a case brought by the Motorcycle Industry Council, Inc. against the State of California in the United States District Court for the Eastern District of California concerning the preemption of a California State requirement that motorcycle headlamps be wired to operate when the engine is running. The Court held that the California requirement is preempted by the Federal Motor Vehicle Safety Standard No. 108 since the NHTSA intended to cover all aspects of performance directly involving motorcycle headlamps.; Therefore, requirements such as those described in your letter would b preempted by Standard No. 105-75 in the case of passenger cars, since the aspect of performance that would be affected is covers by the Federal standard. The same is true for motorcycles, covered by Standard No. 122, *Motorcycle Brake Systems*, and trucks, buses, and trailers equipped with air brake systems, covered by Standard No. 121.; With regard to trucks, buses, and multipurpose passenger vehicles tha are equipped with hydraulic brake systems, the NHTSA is in the process of developing a hydraulic brake standard. I have forwarded a copy of your letter to the NHTSA Office of Crash Avoidance for consideration in developing the standard in this area.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4730OpenMr. Earl W. Dahl Vice President The Goodyear Tire & Rubber Company Akron, Ohio 44316-0001; Mr. Earl W. Dahl Vice President The Goodyear Tire & Rubber Company Akron Ohio 44316-0001; "Dear Mr. Dahl: This responds to your letter seeking an interpretatio of 49 CFR 574, Tire Identification and Recordkeeping. Specifically, you asked whether an additional symbol, which is intended to identify more precisely the year of manufacturer, is permitted to be included in the tire identification number. As explained below, the answer is yes. The purpose of the tire identification requirements is to facilitate the effective recall of tires from the public if the tires are found not to comply with the applicable safety standards or if the tires contain a safety related defect. Section 574.5 requires that each tire be marked with the tire identification number. In particular, it requires that the fourth grouping contain three numerals of which the first two identify the week of the year and the third numeral identifies the year of manufacture. You believe that this requirement may lead to confusion because the third numeral, e.g. '9', could refer to more than one year, e.g., 1979 or 1989. Accordingly, you state that your company would like to be able to distinguish the year of manufacture in an interval longer than one decade. To do this, you would like to add a symbol immediately following the fourth grouping of the tire identification number to identify that this tire was produced in the decade 1990 through 1999. Standard No. 109, New pneumatic tires (49 CFR 571.109) and Standard No. 119, New pneumatic tires for vehicles other than passenger cars (49 CFR 571.119) together with Part 574 require that certain information be labeled on the sidewalls of each tire subject to the standards. In a May 31, 1988 letter to Mr. Garry Gallagher of Metzeler Motorcycle Tire (copy attached), the agency explained that The agency has frequently stated in past interpretations that the purpose of these labeling requirements is to provide the consumer, in a clear and straightforward manner, with technical information necessary for the safe use of the tires. These standards permit tire manufacturers to label additional information on the sidewall on the tires, provided that the additional information does not obscure or confuse the meaning of the required information, or otherwise defeat its purpose. Applying this standard to the question you have asked, we believe that the additional symbol, an isosceles right triangle, is not prohibited from appearing on the sidewall of your company's tires. As explained above, the labeling requirements are intended to provide information about the tire, including the year of manufacture, in a clear and straightforward manner. Because the suggested symbol does not appear to introduce additional information that might obscure or confuse the meaning of the required information or otherwise defeat its purpose, the agency has determined that marking a tire with an isosceles right triangle after the tire identification code is not prohibited. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam5113OpenMr. Terry Wagar Technical Services Bureau State of New York Department of Motor Vehicles Division of Vehicle Safety Services The Governor Nelson A. Rockefeller Empire State Plaza Albany, NY 12228; Mr. Terry Wagar Technical Services Bureau State of New York Department of Motor Vehicles Division of Vehicle Safety Services The Governor Nelson A. Rockefeller Empire State Plaza Albany NY 12228; "Dear Mr. Wagar: This responds to your letter asking about the repai of glazing in in-service motor vehicles that were originally designed to comply with Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205). You were specifically concerned about the safety of a repair process known as 'Ultra B-O-N-D' which you explained involves injecting a liquid through a crack in a windshield. The repaired area is then exposed to a lamp, scraped with a razor blade, and cleaned. You explained that after this process is completed, the crack is 'not as visible.' By way of background information, the National Traffic and Motor Vehicle Safety Act (Safety Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable to new motor vehicles and new motor vehicle equipment. Pursuant to this authority, the agency has issued Standard No. 205, which establishes performance requirements for all windows (called 'glazing' in the Standard) in new motor vehicles and for all new replacement windows for motor vehicles. The Federal motor vehicle safety standards do not apply to vehicles and motor vehicle equipment after their first sale to a consumer. The Safety Act does include a provision that prohibits manufacturers, distributors, dealers and motor vehicle repair businesses from 'rendering inoperative' any device or element of design installed on or in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard. However, that provision does not require those entities, in repairing a damaged vehicle, to restore it to its original level of performance. The States do have the authority to regulate motor vehicle repairs and the condition of in-service vehicles, and this agency encourages them to take steps to ensure the safe operating condition of vehicles-in-use. (The Federal Highway Administration has in-service requirements for commercial motor vehicles used in interstate commerce.) I regret that we are unable to provide any information concerning the safety of the 'Ultra B-O-N-D' process. We suggest that, in developing criteria for the condition of in-use glazing, including the permissibility of certain types of repairs, that you consider such factors as whether particular damage, even after repair, would adversely affect driver visibility, would likely become more serious during normal use (e.g., a small crack becoming a large crack), would reduce the ability of the windshield to retain unrestrained occupants in the vehicle, or would otherwise adversely affect vehicle safety. In addition, if the windshield is so extensively damaged that it cannot be repaired using the 'Ultra B-O-N-D' process, and must be replaced, the new windshield should be installed in accordance with the vehicle manufacturer's instructions. In the event of an accident, an improperly installed windshield may allow unrestrained occupants to be ejected from the vehicle with resulting personal injury. I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, John Womack 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.