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: aiam1640OpenMr. Jack M. Dubard, Dubard & Vail, P.O. Box 38, Bonneville, MS 38829; Mr. Jack M. Dubard Dubard & Vail P.O. Box 38 Bonneville MS 38829; Dear Mr. Dubard: This responds to your October 11, 1974, letter (JAH:nh) asking whethe a truck body manufactured in part before and in part after the effective date of Standard No. 121, *Air brake systems*, must conform to the requirements of that standard. Standard No. 121 becomes effective for trailers on January 1, 1975, and for trucks and buses on March 1, 1975.; Standard No. 121 applies to air brake-equipped trucks, buses, an trailers, but not to truck bodies, which we consider to be items of motor vehicle equipment. Therefore, if your client only makes and sells truck bodies, his products are not subject to Standard No. 121.; If your client combines a chassis-cab with a truck body, he may in man cases be manufacturing a new motor vehicle, and as such, be responsible for compliance with Federal motor vehicle safety standards. I have enclosed 49 CFR Parts 567, *Certification*, and 568, *Vehicles manufactured in two or more stages*, which set out the certification responsibilities of persons who manufacture vehicles in stages.; Section 568.8 states that a 'final-stage manufacturer' (frequently thi will be one who installs a truck body on a chassis cab) must certify the vehicle as conforming with all standards effective as of the date of manufacture of the 'incomplete vehicle,' the date of final completion, or any date between those two dates. The manufacturer makes this certification based both on documentation furnished by the incomplete vehicle manufacturer under S 568.4, and on the changes he has made to complete the vehicle.; Therefore, if your client completes a truck by adding a truck body t it, he must certify that the vehicle meets all applicable standards as of a date chosen by him within the specified period. For example, a vehicle completed by the addition of a body on March 15, 1975, which used a chassis-cab manufactured on February 1, 1975, could be certified as complying with all standards as of February 1, 1975. In this case, the vehicle would not be subject to Standard No. 121.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4714OpenMr. George B. Maday President Network USA Inc. 136 Walker St., SW Atlanta, GA . 30313-1326; Mr. George B. Maday President Network USA Inc. 136 Walker St. SW Atlanta GA . 30313-1326; Dear Mr. Maday: This is in reply to your letter with respect to th automatic light switching device whose potential for the U.S. market you are assessing. The device automatically activates the headlamps at a pre-determined (but adjustable) level of darkness. There is a manual override for the operator. I regret the delay in responding. You have asked two questions: 'l. What legislation is in force or pending regarding the mandatory utilization of such daytime running lights for vehicles?' None. The agency once proposed that motor vehicles be equipped with daytime running lamps as an option, but it terminated rulemaking on this subject without taking action. '2. What regulations, standards, forms, etc. have to be submitted to you or the appropriate agency to ensure that the product meets any U.S. specifications or standards prior to importation. None. There are no Federal motor vehicle safety standards that apply to this item of motor vehicle equipment. However, if you intend it to be installed as an item of original equipment, it must not create a noncompliance with Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, or result in an impairment of the effectiveness of the lighting equipment that the standard requires. For example, the standard requires the taillamps to be activated when the headlamps are activated. Therefore, when your device activates the headlamps, the taillamps must also be activated. Though expressed in somewhat different terms, the acceptability of your device in the aftermarket is governed by a similar consideration: it may not be installed by a motor vehicle manufacturer, distributor, dealer or repair business if the installation would render inoperative any element of design or device installed in accordance with Standard No. 108. The device would remain subject to the laws of any State in which it is sold or operated. We are unable to advise you as to its acceptability under State laws, and recommend that you consult the American Association of Motor Vehicle Administrators (AAMVA), 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam3718OpenMr. Charles Jayne, Tire Manager, J-B Purchasing Corporation, P.O. Box 692, Auburn, NY 13021; Mr. Charles Jayne Tire Manager J-B Purchasing Corporation P.O. Box 692 Auburn NY 13021; Dear Mr. Jayne: This responds to your recent letter asking about the requirements of 4 CFR Part 574, *Tire Identification and Recordkeeping*. You noted that your company currently retreads tires for its own use, and that you soon plan to retread tires for sale to others. You asked if the tires you retread for your own use need to be identified with a tire identification number. The answer is no.; Section 574.5 of the Tire Identification and Recordkeeping regulatio provides, in part, that, 'Each tire retreader, *except tire retreaders who retread tires for their own use*, shall conspicuously label one sidewall of each tire he retreads by permanently molding or branding into or onto the sidewall, ...a tire identification number....' Your question concerns a situation in which a tire retreader retreads some tires for his own use and some tires for sale or lease to others. To answer your question, it is helpful to examine the purpose of the identification requirement.; The purpose of having the tire identification number labeled on th sidewall of retreaded tires is twofold. First, it enables this agency and the user of the retreaded tire to identify the retreader of the tire in the event of some safety problem with the tire. Second, it enables the tire retreader to accurately identify the retreaded tires it may have to recall. In the case of tires offered for sale or use outside your company, it is plain that both these purposes would be served by having the tire identification number on the sidewall. Therefore, Part 574 requires that each such tire have a tire identification number on one sidewall.; However, with respect to tires retreaded for the retreader's own use it is obvious who retreaded the tire, whether or not a tire identification number appears on the sidewall. Hence, the first purpose listed above would not be served by having the tire identification number on the sidewall of these tires. Further, the retreader can inspect all of the retreaded tires it uses to determine if any are subject to its recall, and assure adequate remedy for those which are within the recall, without publicizing the identification numbers of those tires. Thus, the second purpose set forth above also would not be furthered by having the tire identification number on the sidewall of these tires. Please note, however, that any tire not marked with a tire identification number can never legally be sold or otherwise offered for use outside of your company.; Should you have any further questions or need additional informatio about this topic, please contact Steve Kratzke of my staff at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3719OpenMr. Charles Jayne, Tire Manager, J-B Purchasing Corporation, P.O. Box 692, Auburn, NY 13021; Mr. Charles Jayne Tire Manager J-B Purchasing Corporation P.O. Box 692 Auburn NY 13021; Dear Mr. Jayne: This responds to your recent letter asking about the requirements of 4 CFR Part 574, *Tire Identification and Recordkeeping*. You noted that your company currently retreads tires for its own use, and that you soon plan to retread tires for sale to others. You asked if the tires you retread for your own use need to be identified with a tire identification number. The answer is no.; Section 574.5 of the Tire Identification and Recordkeeping regulatio provides, in part, that, 'Each tire retreader, *except tire retreaders who retread tires for their own use*, shall conspicuously label one sidewall of each tire he retreads by permanently molding or branding into or onto the sidewall, ...a tire identification number....' Your question concerns a situation in which a tire retreader retreads some tires for his own use and some tires for sale or lease to others. To answer your question, it is helpful to examine the purpose of the identification requirement.; The purpose of having the tire identification number labeled on th sidewall of retreaded tires is twofold. First, it enables this agency and the user of the retreaded tire to identify the retreader of the tire in the event of some safety problem with the tire. Second, it enables the tire retreader to accurately identify the retreaded tires it may have to recall. In the case of tires offered for sale or use outside your company, it is plain that both these purposes would be served by having the tire identification number on the sidewall. Therefore, Part 574 requires that each such tire have a tire identification number on one sidewall.; However, with respect to tires retreaded for the retreader's own use it is obvious who retreaded the tire, whether or not a tire identification number appears on the sidewall. Hence, the first purpose listed above would not be served by having the tire identification number on the sidewall of these tires. Further, the retreader can inspect all of the retreaded tires it uses to determine if any are subject to its recall, and assure adequate remedy for those which are within the recall, without publicizing the identification numbers of those tires. Thus, the second purpose set forth above also would not be furthered by having the tire identification number on the sidewall of these tires. Please note, however, that any tire not marked with a tire identification number can never legally be sold or otherwise offered for use outside of your company.; Should you have any further questions or need additional informatio about this topic, please contact Steve Kratzke of my staff at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4462OpenMr. Allan J. Lameier Quality Assurance Specialist, Defense Logistics Agency Defense Contract Administration Services Management Area, Dayton C/O Defense Electronics Supply Center Dayton OH 45444; Mr. Allan J. Lameier Quality Assurance Specialist Defense Logistics Agency Defense Contract Administration Services Management Area Dayton C/O Defense Electronics Supply Center Dayton OH 45444; "RE: A. Lameier 513-684-3915 Dear Mr. Lameier: This is in response t your letter requesting clarification concerning the classification of a Davey mobile compressor. You state that the manufacturer of the compressor indicates that the wheeled compressor need not comply with Standard No. 108, Lamps, reflective devices and related equipment, because the compressor is not a trailer. Based on the information provided with your letter, we believe that the compressor is not a motor vehicle and is therefore not subject to the requirements of Standard No. 108 or any other Federal motor vehicle safety standards. By way of background, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act, 15 U.S.C. 1381 et seq.) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. The National Highway Traffic Safety Administration (NHTSA) does not approve motor vehicles or motor vehicle equipment. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. A 'trailer' is defined at 49 CFR /571.3 as 'a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle.' The mobile compressor shown in the brochure enclosed with your letter appears to be designed for carrying property (the compressor) and for being drawn by a motor vehicle. The answer to your question of whether this compressor is a trailer, then depends on whether the compressor is a 'motor vehicle' within the meaning of the Safety Act. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. We have interpreted this language as follows. Vehicles such as forklifts and mobile construction equipment which are sold primarily for off-road use, but which incidentally use the public roads to travel from one job site to another, are not considered motor vehicles. On the other hand, vehicles which regularly use the public roads and stay off-road for only limited periods of time are motor vehicles and are subject to our safety standards. The agency has previously concluded in a July 1, 1980 letter to Mr. E.C. Elliott (copy enclosed) that his company's portable air compressors were not motor vehicles, based on statements that these devices spend the bulk of their useful lives on construction sites and are seldom drawn over public roads by mechanical power. If the Davey portable compressors are used in the same fashion as the compressors discussed in the July 1, 1980 letter, we believe that the Davey compressors were properly classified by the manufacturer as something other than a 'motor vehicle'. This means that the Davey compressors are not subject to any of the Federal motor vehicle safety standards. I hope this information has been useful. My apologies for the delay in responding to your letter. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam4719OpenMr. Mehid Rowghani Dallas European Parts Distributors 1505 Wallace Drive Carrollton, TX 75006; Mr. Mehid Rowghani Dallas European Parts Distributors 1505 Wallace Drive Carrollton TX 75006; Dear Mr. Rowghani: This is in reply to your letter of January 9, 1990 to Taylor Vinson of this Office. You have asked whether 'importation and sale of European doors (without reinforcement bars) is in accordance with the rules and regulations of the Department of Transportation.' Your question appears premised upon the fact that many European passenger cars achieve compliance with Federal Motor Vehicle Safety Standard No. 214 Side Door Strength by being equipped with doors incorporating reinforcement bars. However, this standard applies only to new vehicles, and does not extend to replacement parts for such vehicles. Thus, if damage to a vehicle is such that its original door must be replaced, and that door incorporated a reinforcing bar, there is no requirement that the replacement door restore the vehicle to a condition in which it continues to meet Standard No. 214. In short, the importation and sale of a replacement door that does not incorporate a reinforcing bar does not violate any of the statutes, standards, or other regulations administered by this agency. If the replacement door is intended for use on a passenger car line that is subject to the Federal Motor Vehicle Theft Prevention Standard that this agency administers, however, you should be aware that it must nevertheless be marked with the registered trademark of the manufacturer of the door, or unique identifier if there is no registered trademark, and the letter 'R'. I enclose a copy of the standard for your information, as this requirement is a relatively new one, and may not be clearly understood. This marking must be on the door before the door is imported into the United States. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure (Part 541); |
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ID: aiam4662OpenMr. William E. Alkire CEO, Brakelight Enhancer, Inc. 1010 Rancheros Drive San Marcos, CA 92069; Mr. William E. Alkire CEO Brakelight Enhancer Inc. 1010 Rancheros Drive San Marcos CA 92069; Dear Mr. Alkire: This is in response to your letter of August 24, l989 in care of Taylor Vinson of this Office, asking for our comments on your 'Brake Light Enhancer'. This device flashes the stop lamps of a vehicle three times within the first two seconds after actuation of the stop lamp system, the lamps remaining illuminated thereafter. Our comments on your device are restricted to its acceptability under the Federal regulatory scheme as either original or aftermarket equipment. The Federal motor vehicle safety standard applicable to lighting equipment on new vehicles is Standard No. 108. This standard must be met when the vehicle is manufactured, and when it is sold to its first purchaser (i.e., dealer-installed equipment must not affect compliance of the vehicle with the safety standards). Section S5.5.10(e) of Standard No. 108 requires stop lamps to be wired to be steady burning in use, and your device's initial cycle of three flashes in two seconds would create a noncompliance with this requirement. Accordingly, your device is not permissible as an item of original equipment. There is no aftermarket Federal standard applicable to your device. Equipment intended for vehicles in use are subject to the restriction of the National Traffic and Motor Vehicle Safety Act that they may not render inoperative, in whole or in part, equipment installed in accordance with a Federal motor vehicle safety standard, if they are installed by a person other than the vehicle owner. In our view, if a modification creates a noncompliance with a standard that applies to a new motor vehicle, it is the equivalent of creating a partial inoperability of orignial safety equipment when that modification is performed on a motor vehicle in use. Installation of the Brake Light Enhancer by a person other than the vehicle owner would have this effect, and thus would be subject to the prohibition of the Act. Use of the device is also subject to the laws of the various States in which the device will be sold and operated. Although California may permit its use, per Calif. Senate Bill 1317 that you enclosed, other States may not. We are unable to advise on State laws, and recommend that you write the American Association of Motor Vehicle Administrators for an opinion. Its address is 4600 Wilson Boulevard, Arlington, VA 22203. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam5093OpenMr. Jordan J. Pokrinchak President, Jordan Research Corp. 415 Howe Avenue Shelton, CT 06484; Mr. Jordan J. Pokrinchak President Jordan Research Corp. 415 Howe Avenue Shelton CT 06484; "Dear Mr. Pokrinchak: This responds to your letter of November 7, 1992 with respect to the Tekonsha electronic brake control. You apparently wrote in reference to my letter of April 3, 1992, to Echlin, Inc., the manufacturer of the Tekonsha brake control, in which I discussed that section of the National Traffic and Motor Vehicle Safety Act (the Safety Act) that prohibits certain named commercial entities from 'rendering inoperative' safety equipment on motor vehicles. (15 U.S.C. 1397(a)(2)(A)). You believe that this agency has 'approved' this brake control. Based on your belief that the Tekonsha brake control poses a safety hazard on the public roads, you asked us to reconsider our decision to 'approve' this brake control. Let me begin by emphasizing that this agency has no authority to 'approve,' endorse or offer assurances of compliance to any items of motor vehicle equipment. All that our letters of interpretation purport to do is to answer questions from manufacturers and other members of the public as to whether the manufacture, sale, and/or installation of equipment is permissible under applicable Federal laws and regulations. Our letter of April 3, 1992, to Echlin, was a letter of interpretation, which concluded that 'it now appears that the sale of the Tekonsha Control is not in violation of the National Traffic and Motor Vehicle Safety Act.' This letter and conclusion can in no way be read as 'approving,' endorsing, or recommending the use of the Tekonsha system. You believe that 49 CFR 393.25(f) 'is quite specific when dealing with the actuation of the trailer stop lamps, either manually or automatically,' and has nothing to do with the 'render inoperative' prohibition of section 1397(a)(2)(A) of the Safety Act. The regulation you have identified (49 CFR 393.25(f)) is administered by another Federal agency, the Federal Highway Administration, acting under statutory authority other than the Safety Act. Obviously, only that agency can give an official interpretation of its regulations. However, based on my understanding of the Tekonsha system, it does not appear that the use of the Tekonsha system would be affected by the regulations in Part 393. Part 393, including 393.25, applies only to commercial motor vehicles. I understand that the Tekonsha control is used on smaller, personal vehicles, like pickups and vans, to tow trailers such as campers, travel trailers, and so forth. If my understanding is correct, the Federal Highway Administration's regulations would not apply. If you wish to receive an official interpretation of this matter, you may contact: Mr. James E. Scapellato, Director, Office of Motor Carrier Standards, Federal Highway Administration, Washington, D.C. 20590. With respect to your request that we reconsider our previous conclusion that the sale of the Tekonsha control would not violate the 'render inoperative' prohibition of the Safety Act, we do not now have, nor are we aware of, any data indicating that there is a real-world safety problem created by use of the Tekonsha brake control. Hence, we have no reason to change the conclusion announced in the April 3 letter to Echlin about the legality of the Tekonsha control. We would be willing to review this matter again if data become available indicating a potential problem. Thus, if you learn of any specific safety problems that have arisen for vehicles equipped with the Tekonsha control, please let us know. Thank you for taking the time to express your concerns. I hope that this further explanation of our April 3 letter is helpful. Sincerely, Stephen P. Wood Assistant Chief Counsel for Rulemaking"; |
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ID: aiam4699OpenMr. Jim Evans Quality Control Department The Bargman Company 129 Industrial Avenue Coldwater, MI 49036; Mr. Jim Evans Quality Control Department The Bargman Company 129 Industrial Avenue Coldwater MI 49036; Dear Mr. Evans: This is in reply to your letter of December 13, 1989 with respect to whether the installation of 'yellow' reflex reflectors on the rear of motor vehicles is permissible under Standard No. 108. Because the standard uses the term 'amber' instead of 'yellow', I shall refer to yellow as amber also. As you note, the standard requires two red reflex reflectors to be mounted on the rear, but is silent as to whether additional reflectors, amber in color, are permitted. One of your customers has asked you to manufacture an amber turn signal lens that would have an amber reflex reflector area around the outer edge. The turn signal lamp would be adjacent to a lamp of apparently identical size and shape with a red lens and reflex reflector area, providing stop and tail lamp functions. The State of Michigan apparently allows only red reflex reflectors on the rear. You have asked whether reflectors of other colors may be mounted on the rear as long as the required red ones are present, and if it is illegal, whether Standard No. 108 may be amended to eliminate the confusion. Because an amber reflector is not a required item of lighting equipment that Standard No. 108 specifies to be installed on the rear of a motor vehicle, its acceptability is subject to the general provisions of section S5.1.3. This states, in pertinent part, that no additional reflective device may be installed that impairs the effectiveness of lighting equipment required by Standard No. 108. It does not appear to us that an amber taillamp lens with an amber reflector would create an impairment. Under Standard No. 108, amber is a permissible color for rear turn signal lamps, and its presence on a reflector surrounding the lamp should not create confusion. Therefore, manufacture, sale, and installation of an amber taillamp lens with an amber reflector would not constitute a noncompliance with Standard No. 108. However, an interpretation by NHTSA that its lighting standard does not forbid the installation of an amber reflex reflector does not mean that a State could not adopt and enforce a law prohibiting such a reflector. Under section l03(d) of the National Traffic and Motor Vehicle Safety Act, a State may impose its own safety requirements covering any aspect of performance that is not covered by Standard No. 108. We construe this provision narrowly, as allowing a State to regulate all lighting equipment that is not specifically required by Standard No. 108. Noting that Section CI 257.691 of the Micigan vehicle lighting code that you enclosed specifies that reflectors 'mounted on the rear shall reflect a red color to the rear', the appropriate remedy would be to seek an amendment of the Michigan law. This agency presently has no plans to specify yellow as an alternate color for rear reflex reflectors. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam1643OpenMr. Jack M. Dubard, Dubard & Vail, P.O. Box 38, Booneville, MS 38829; Mr. Jack M. Dubard Dubard & Vail P.O. Box 38 Booneville MS 38829; Dear Mr. Dubard:This responds to your October 11, 1974, letter (JAH:nh asking whether a truck body manufactured in part before and in part after the effective date of Standard No. 121, *Air brake systems*, must conform to the requirements of that standard. Standard No. 121 becomes effective for trailers on January 1, 1975, and for trucks and buses on March 1, 1975.; Standard No. 121 applies to air brake-equipped trucks, buses, an trailers, but not to truck bodies, which we consider to be items of motor vehicle equipment. Therefore, if your client only makes and sells truck bodies, his products are not subject to Standard No. 121.; If your client combines a chassis- cab with a truck body, he may i many cases be manufacturing a new motor vehicle, and as such, be responsible for compliance with Federal motor vehicle safety standards. I have enclosed 49 CFR Parts 567, *Certification*, and 568, *Vehicles manufactured in two or more stages*, which set out the certification responsibilities of persons who manufacture vehicles in stages.; Section 568.8 states that a 'final-stage manufacturer' (frequently thi will be one who installs a truck body on a chassis cab) must certify the vehicle as conforming with all standards effective as of the date of manufacture of the 'incomplete vehicle,' the date of final completion, or any date between those two dates. The manufacturer makes this certification based both on documentation furnished by the incomplete vehicle manufacturer under S 568.4, and on the changes he has made to complete the vehicle.; Therefore, if your client completes a truck by adding a truck body t it, he must certify that the vehicle meets all applicable standards as of a date chosen by him within the specified period. For example, a vehicle completed by the addition of a body on March 15, 1975, which used a chassis-cab manufactured on February 1, 1975, could be certified as complying with all standards as of February 1, 1975. In this case, the vehicle would not be subject to Standard No. 121.; 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.