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: aiam1102OpenMr. Thomas B. Mitchell, 707 East Queen Street, Hastings, New Zealand; Mr. Thomas B. Mitchell 707 East Queen Street Hastings New Zealand; Dear Mr. Mitchell: Thank you for your letter of March 27, 1973, requesting informatio concerning Federal Motor Vehicle Safety Standards with special emphasis on those standards pertaining to fuel systems.; Enclosure 1 is a brochure which gives a brief summary of all safet standards issued through June 1972, and a subscription Order Form, should you wish to purchase a complete edition of the standards from the Superintendent of Documents on a subscription basis.; Enclosure 2 is a copy of Federal Motor Vehicle Safety Standard No. 301 'Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections - Passenger Cars.' This standard is currently undergoing amendment that will include rollover and rear-end impact requirements in addition to the fixed barrier collision which is currently required.; The Bureau of Motor Carrier Safety regulates vehicular interstat commerce. Enclosure 3 is an Advanced Notice of Proposed Rule Making concerning plastic fuel tanks (*Federal Register,* Volume 36, No. 178, September 14, 1971) which was recently issued by this Bureau. Further information may be obtained by contacting this Bureau as follows:; >>>Director, Bureau of Motor Carrier Safety, Department o Transportation, 400 Seventh Street, S.W., Washington, D.C. 20590<<<; In response to your question: 'I particularly wish to know if th relevant Safety Standard in force in America requires the fuel tanks to be located outside the main body shell of the vehicles or if it is permissible under this Safety Standard for fuel tanks to be situated in the interior of the vehicles,' the standards as written do not specifically require that the fuel system be external to the passenger compartment. These standards, in accordance with Public Law 89-563 which authorized their development, emphasize performance rather than design considerations.; Another standard which may be of interest to you is Standard No. 302 'Flammability of Interior Materials in Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses,' which was effective September 1, 1972. Enclosure 4 is a copy of this standard along with two proposed amendments.; We trust your inquiry has been satisfactorily answered. If there ar any other questions or we can be of further service, please do not hesitate to contact this office. I am also returning the amount you enclosed for postage, etc.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3185OpenMr. Jeffrey Libman, President, Edison Rubber Company, P. O. Box 254, Edison, New Jersey 08817; Mr. Jeffrey Libman President Edison Rubber Company P. O. Box 254 Edison New Jersey 08817; Dear Mr. Libman: This responds to your letter of November 9, 1979, inquiring if it i permissible for your suppliers to cut off the DOT serial numbers on used tires before selling those tires to your company. You stated in your letter that your company buys used tires from several companies. These tires generally either have cuts in the tread or sidewalls or are out of round. Your company then resells the tires to another company, which resells the tires to the public.; The answer to your question is no. The presence of the DO identification number on tires is required by several of this agency's regulation. Our tire identification and record keeping regulation (49 CFR Part 574) requires that each manufacturer place the DOT number on at least one sidewall of each tire that it manufactures. The number serves several purposes. It is indispensable in aiding consumers to identify tires subject to a recall campaign for safety defects and noncompliance with the safety standards. It also aids this agency in enforcing its tire safety standards. Federal Motor Vehicle Safety Standards 109 (Passenger car tries, 49 CFR 571.119) and 119 (Tires for vehicles other than passenger cars, 49 CFR 571.119) require that each tire manufacturer certify that its tires conform to all applicable Federal safety standards by branding or molding the DOT number on the tire.; Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safet Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)), states that, 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on... an item of motor vehicle equipment in compliance with an applicable federal motor vehicle safety standard ....' By removing the DOT identification number from a tire, the person would be knowingly rendering inoperative an element of design on the tires which is included on the tire for compliance with the requirements of a Federal motor vehicle safety standard. Section 109 of the Act (15 U.S.C. 1398) specifies a penalty of up to $1,000 for each violation of section 108.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3184OpenMr. Jeffrey Libman, President, Edison Rubber Company, P.O. Box 254, Edison, New Jersey 08817; Mr. Jeffrey Libman President Edison Rubber Company P.O. Box 254 Edison New Jersey 08817; Dear Mr. Libman: This responds to your letter of November 9, 19799, inquiring if it i permissible for you suppliers to cut off the DOT serial numbers on used tires before selling those tires to your company. You stated in your letter that your company buys used tires from several companies. These tires generally either have cuts in the tread or sidewalls or are out of round. Your company then resells the tires to another company, which resells the tires to the public.; The answer to your question is no. The presence of the DO identification number on tires is required by several of this agency's regulations. Our tire identification and record keeping regulation (49 CFR Part 574) requires that each manufacturer place the DOT number on at least one sidewall of each tire that it manufactures. The number serves several purposes. It is indispensable in aiding consumers to identify tires subject to a recall campaign for safety defects and noncompliances with the safety standards. It also aids this agency in enforcing its tire safety standards. Federal Motor Vehicle Safety Standards 109 (Passenger car tires, 49 CFR 571.109) and 119 (Tires for vehicles other than passenger cars, 49 CFR 571.119) require that each tire manufacturer certify that its tires conform to all applicable Federal Safety standards by branding or molding the DOT number on the tire.; Section 108(a) (2) (A) of National Traffic and Motor Vehicle SAfety Ac of 1966, as amended (15 U.S.C. 1397(a) (2) (A)), states that, 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on...an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard...' By removing the DOT identification number from a tire, the person would be knowingly rendering inoperative an element of design on the tire which is included on the tire for compliance with the requirements of a Federal motor vehicle safety standard. Section 109 of the Act (15 U.S.C. 1398) specifies a penalty of up to $1,000 for each violation of section 108.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2513OpenMr. Dennis G. Moore, Dry Launch, 1113 Greenville, Livermore, CA 94550; Mr. Dennis G. Moore Dry Launch 1113 Greenville Livermore CA 94550; Dear Mr. Moore: This is in reply to your letter of December 27, 1976, asking severa questions about Federal Motor Vehicle Safety Standard No. 108. You referenced my letter of October 7, 1976 to Wesbar Corporation, and my views about the prohibition against the optical combination of lamps (S4.4.1).; It is evident from your letter and others that our previou interpretations of the term 'optical combination' have been found to be ambiguous and lacking in the objective criteria that a Federal motor vehicle safety standard must provide. We have reviewed the matter, and now wish to modify our previous interpretation. In our view a lamp is 'optically combined' when the same light source (i.e. bulb) and the same lens area fulfill two or more functions (*e.g.* taillamp and stop lamp, clearance lamp and turn signal lamp). A dual filament bulb would be regarded as the 'same light source'. In determining conformance, the photometric requirements for clearance and taillamp functions, where two bulbs are located in a single compartment, must be met with only the bulb energized that is designed to perform the specific function. But the 15 candlepower maximum under Standard No. 108, however, would be determined with both the taillamp and clearance lamp bulb energized. Further, the lamp must be located to meet requirements for both clearance and taillamps. our re- interpretation means that the issue of light spill-over from one area of the lamp to another is irrelevant to conformance.; You have also asked whether the November 1975 amendments (S4.3.1.1.1 'permit clearance lights that are designed *for OEM application only* be allowed to have lower or no photometrics in this area but still be considered a combination clearance and sidemarker lamp' as the lamp otherwise complies with Standard No. 108.; The amendment in question was intended to cover clearance lamps only If a lamp is intended as a combination clearance and side marker lamp and does not meet the requirements for a clearance lamp because of the exemption provided by S4.3.1.1.1, it must nevertheless meet the requirements for side marker lamps. If it doesn't, a separate conforming side marker lamp must be provided.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam3216OpenMr. David Martin, Director, Environmental Activities Staff, General Motors Corporation, General Motors Technical Center, Warren, MI 48090; Mr. David Martin Director Environmental Activities Staff General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Martin: This is in response to your recent request for an interpretation of th term 'capacity', as used in Safety Standard No. 301-75, *Fuel System Integrity*. Paragraph S7.1.1 of that standard provides that 'the fuel tank is filled to any level from 90 to 95 percent of capacity with Stoddard solvent....' You ask whether 'capacity' should include the vapor volume in the air dome plus the volume of the fuel filler pipe when filling a fuel tank for compliance purposes. (Total tank volume = usable capacity + unusable capacity + vapor volume + fluid in the filler pipe.); The vapor volume can be filled with solvent if the solvent is adde very slowly to force the air vapors out of the dome. This has been done in past compliance testing by the agency. Upon reconsideration, however, it is our opinion that the term, 'capacity', should not be interpreted to include the vapor volume in the air dome, since fuel tanks are never filled to this level by vehicle users. Fuel tanks are designed to include and area for fuel vapor and pressure build- up. Vehicle users never fill their tanks so slowly that this area is displaced with fuel. Therefore, it would be an unrealistic test to require manufacturers to fill tanks in this fashion. Apparently, fuel is actually squeezed out of the filler pipe during compliance testing if the tank is filled to this absolute level. This would not seem to be an accurate test of fuel tank integrity, since it is leaks or punctures in the tank itself that generally cause fuel loss in real-world crashes.; In consideration of these facts, the agency interprets 'capacity' t mean 'usable capacity', as used in the vehicle manufacturer's Part I submission to the EPA, plus 'unusable capacity' (i.e., the volume of fuel left in the tank when the engine fuel pump sucks air).; It should be emphasized that the 'usable capacity' should be determine only after the tank has been filled to its 'unusable capacity'. In other words, residual fuel level should be reached before the 'usable capacity' is added to the tank. If this is not done, the actual volume of fuel in the tank will be somewhat below the 'usable fuel capacity'.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3844OpenMr. Masakatsu Kano, Executive Vice President, MMC Services Inc., Suite 1960, 3000 Town Center, Southfield, MI 48075; Mr. Masakatsu Kano Executive Vice President MMC Services Inc. Suite 1960 3000 Town Center Southfield MI 48075; Dear Mr. Kano: This responds to your letter of April 13, 1984, addressed to Mr. Roma Brooks of NHTSA's Office of Enforcement. You stated that you were submitting the letter 'to assure that the Agency and Mitsubishi agree in writing as we did verbally' concerning the compliance of a proposed electronic odometer design with Standard No. 101, *Controls and Displays*. You also stated that lead time dictates an imminent decision on design plans, that the agency's 'early approval/response' to your selected solution is greatly appreciated, and that if you do not hear to the contrary within 30 days, you will assume the agency's concurrence. As discussed below, your letter indicates a serious misunderstanding of both Federal statutory requirements and NHTSA policies and procedures. Moreover, your apparent interpretation of Standard No. 101 is incorrect.; First, NHTSA does not grant approval of motor vehicles or motor vehicl equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements.; NHTSA is willing to provide interpretations and opinions in response t reasonable requests. However, such interpretations and opinions are only provided in writing and only by NHTSA's Chief Counsel. The agency does not consider itself bound by verbal statements made by agency employees or by interpretations made by persons other than the Chief Counsel.; Moreover, NHTSA does not offer interpretations by remaining silent i response to letters which assert that such silence is assumed to be concurrence. The agency considers the inclusion of such purported conditions to be inappropriate and does not consider itself bound by them.; The agency regrets if Mr. Brooks' conversation contributed to th misunderstandings apparent in your letter. In the future, questions of interpretation should be addressed in writing to the Chief Counsel.; Your question of interpretation concerns a proposed design for a electronic odometer which would display either miles or kilometers. The following represents our opinion based on the facts provided in your letter.; According to your letter, the vehicle's speedometer would display, a the option of the driver, in either miles per hour or kilometers per hour. The selected unit of measure would be identified by a lighted display reading either 'MPH' or 'Km/h'. The digits of the odometer would correspond to the units of measure selected for the speedometer, but the odometer itself would not identify its units of measure. As discussed below, such a design would not meet the requirements of Standard No. 101, since that standard requires an odometer that indicates kilometers to be identified by 'KILOMETERS' or 'km'.; Section S5 of Standard No. 101 requires that 'each passenger car multi-purpose passenger vehicle and truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.' Odometers are one of the displays listed in column 1 of Table 2.; Section S5.2.3 references the requirements of Table 2. Footnote 3 o Table 2 specifies the following requirement for odometers:; >>>If the odometer indicates kilometers, then 'KILOMETERS' (or) 'km shall appear, otherwise no identification is required.<<<; Section S5.2.3 further provides that '(t)he identification required o permitted by this section shall be placed on or adjacent to the display that it identifies.; Standard No. 101 thus requires odometers indicating kilometers to b identified by 'KILOMETERS' or 'km', and such identification must be placed on or adjacent to the odometer. Since your proposed design would indicate kilometers, it would be necessary to identify its units of measure according to these requirements.; I would note that these requirements cannot be met merely by placin the odometer adjacent to the speedometer. While the identification of the selected units of measure for the speedometer could be placed adjacent to both the speedometer and odometer, the identification requirements are different for the two displays. Table 2 requires that a speedometer graduated in miles per hour and kilometers per hour be identified by 'MPH and km/h' in any combination of upper or lower case letters. As discussed above, the requirement for odometers is 'KILOMETERS' or 'km'. A single identification of units of measure cannot meet these requirements simultaneously.; Please note that this opinion is limited to the specific issue raise by your letter and does not consider whether the proposed design would otherwise meet the requirements of Standard No. 101.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3846OpenMr. Masakatsu Kano, Executive Vice President, MMC Services Inc., Suite 1960, 3000 Town Center, Southfield Michigan 4805; Mr. Masakatsu Kano Executive Vice President MMC Services Inc. Suite 1960 3000 Town Center Southfield Michigan 4805; Dear Mr. Kano: This responds to your letter of April 13, 1984, addressed to Mr. Roma Brooks of NHTSA's Office of Enforcement. You stated that you were submitting the letter 'to assure that the Agency and Mitsubishi agree in writing as we did verbally' concerning the compliance of a proposed electronic odometer design with Standard No. 101, *Controls and Displays.* You also stated that lead time dictates an imminent decision on design plans, that the agency's early approval/response' to your selected solution is greatly appreciated, and that if you do not hear to the contrary within 30 days, you will assume the agency's concurrence. As discussed below, your letter indicates a serious misunderstanding of both Federal statutory requirements and NHTSA policies and procedures. Moreover, your apparent interpretation of Standard No. 101 is incorrect.; First, NHTSA does not grant approval of motor vehicle or motor vehicl equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements.; NHTSA is willing to provide interpretations and opinions in response t reasonable requests. However, such interpretations and opinions are only provided in writing and only by NHTSA's Chief Counsel. The agency does not consider itself bound by verbal statements made by agency employees or by interpretations made by persons other than the Chief Counsel.; Moreover, NHTSA does not offer interpretations by remaining silent i response to letters which assert that such silence is assumed to be concurrence. The agency considers the inclusion of such purported conditions to be inappropriate and does not consider itself bound by them.; The agency regrets if Mr. Brooks' conversation contributed to th misunderstandings apparent in your letter. In the future, questions of interpretations should be addressed in writing to the Chief Counsel.; Your question of interpretation concerns a proposed design for a electronic odometer which would display either miles or kilometers. The following represents our opinion based on the facts provided in your letter.; According to your letter, the vehicle's speedometer would display, a the option of the driver, in either miles per hour or kilometers per hour. The selected unit of measure would be identified by a lighted display reading either 'MPH' or 'Km/h'. The digits of the odometer would correspond to the units of measure selected for the speedometer, but the odometer itself would not identify its units of measure. As discussed below, such a design would not meet the requirements of Standard No. 101, since that standard requires an odometer that indicates kilometers to be identified by 'KILOMETERS' or 'km'.; Section S5 of Standard No. 101 requires that 'each passenger car multi-purpose passenger vehicle and truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.' Odometers are one of the display listed in column 1 of Table 2.; Section S5.2.3 references the requirements of Table 2. Footnote 3 o Table 2 specifies the following requirements for odometers:; >>>If the odometer indicates kilometers, then 'KILOMETERS' [or] 'km shall appear, otherwise no identifications is required.<<<; Section S5.2.3 further provides that '[t]he identification required o permitted by this section shall be placed on or adjacent to the display that it identifies.; Standard No. 101 thus requires odometers indicating kilometers to b identified by 'KILOMETERS' or 'km', and such identification must be placed on or adjacent to the odometer. Since your proposed design would indicate kilometers, it would be necessary to identify its units of measure according to these requirements.; I would note that these requirements cannot be met merely by placin the odometer adjacent to the speedometer. While the identification of the selected units of measure for the speedometer could be placed adjacent to both the speedometer and odometer, the identification requirements are different for the two displays. Table 2 requires that a speedometer graduated in miles per hour and kilometers per hour be identified by 'MPH and km/h' in any combination of upper or lower case letters. As discussed above, the requirement for odometers is 'KILOMETER' or 'km'. A single identification of units of measure cannot meet these requirements simultaneously.; Please note that this opinion is limited to the specific issue raise by your letter and does not consider whether the proposed design would otherwise meet the requirements of Standard No. 101.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0747OpenMr. Robert T. Sanders, Vice President, Manufacturing--Window Division, 4801 Springfield Street, Dayton, OH 45401; Mr. Robert T. Sanders Vice President Manufacturing--Window Division 4801 Springfield Street Dayton OH 45401; Dear Mr. Sanders: This is in reply to your letter of June 1, 1972, requesting a interpretation as to the application of Federal Motor Vehicle Safety Standard No. 205, 'Glazing Materials,' to certain recreational vehicles and equipment, pictures of which you enclosed. These components consist of slide-in and chassis-mount campers, trailers, and motor homes.; In a recently issued amendment to Standard No. 205, the NHTSA ha clarified the application of the standard to campers. As amended, the standard applies to campers, both slide-in and chassis-mount, that are designed to transport occupants while in motion. Accordingly, the pick-up cap which you illustrate appears to be exempt from the standard. In addition Standard No. 205 does not apply to trailers, and would not apply to the fifth-wheel unit illustrated in the drawing forwarded to us.; With reference to the chassis-mount and slide-in campers, any windo except forward facing windows, which include both front-facing windows and behind-the-cab windows, may be manufactured of any glazing material (AS 1 through AS 11) specified in ANS Z26.1-1966, and two additional materials (Items 12 and 13), the requirements for which are specified in the recent amendment. With reference to forward-facing camper windows, all of the above materials may be used, except for AS 6 and AS 7 glazing materials, as specified in ANS Z26.1-1966, and item 13 glazing specified in the new amendment.; With respect to motor homes that are not campers, these vehicles ar multipurpose passenger vehicles and must meet the glazing requirements for trucks. Accordingly, the windshield must be manufactured of either AS 1 or AS 10 glazing materials, side windows to the immediate right or left of the driver must be either AS 1, AS 2, AS 10, or AS 11 materials, and other side windows must be either AS 1, AS 2, AS 3, AS 4, AS 5, AS 8, AS 9, AS 10, or AS 11 glazing materials. We would consider the overhead window in the motor home you illustrate to be an 'opening in the roof,' and any of the materials allowed in side windows, or the materials allowed to be used by the recent amendment, may be used in this location.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1445OpenMr. Bruce J. Motyka, 2030 Laura Lane, Des Plaines, IL 60018; Mr. Bruce J. Motyka 2030 Laura Lane Des Plaines IL 60018; Dear Mr. Motyka: This is in reply to your letter of March 11, 1974, asking fo suggestions regarding problems you have experienced with your pickup truck-camper unit.; It appears from your letter that no violations of Federal requirement have occurred. Motor Vehicle Safety Standard No. 126 and its companion Consumer Information requirement (49 CFR S 575.103) about which we wrote to you through Senator Percy's office did not become effective until January 1, 1973, well after the time you bought your vehicle. Moreover, it is not correct to characterize the dealer who sold you the unit as a 'final-stage manufacturer.' Under NHTSA requirements a pickup truck is a completed vehicle, and a person who installs a slide-in camper into the cargo area of a truck does not become a manufacturer. While this is not the case with chassis-mount campers, it is with respect to slide-in campers.; I suggest that if you wish to proceed further you consult an attorney who would be able to best assess your chances of success in civil litigation. The dealer's employee who told you that the 'GVW plate meant nothing' was mistaken. The weight ratings provided on the plate represent the manufacturer's representation of the maximum safe weight of a fully loaded vehicle.; You might wish to examine the labels attached, pursuant to Standard No 126 and 49 CFR S 575.103, to later models of both the pickup truck and camper you purchased. It is possible that those models and the ones you purchased are not substantially different. If that is the case the information on the labels can provide an indication of the extent that the weight ratings were exceeded by installation of the camper unit in question.; While I regret we cannot be of further assistance I wish you success i your efforts to solve this problem.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1446OpenMr. Bruce J. Motyka, 2030 Laura Lane, Des Plaines, IL 60018; Mr. Bruce J. Motyka 2030 Laura Lane Des Plaines IL 60018; Dear Mr. Motyka: This is in reply to your letter of March 11, 1974, asking fo suggestions regarding problems you have experienced with your pickup truck-camper unit.; It appears from your letter that no violations of Federal requirement have occurred. Motor Vehicle Safety Standard No. 126 and its companion Consumer Information requirement (49 CFR S 575.103) about which we wrote to you through Senator Percy's office did not become effective until January 1, 1973, well after the time you bought your vehicle. Moreover, it is not correct to characterize the dealer who sold you the unit as a 'final-stage manufacturer.' Under NHTSA requirements a pickup truck is a completed vehicle, and a person who installs a slide-in camper into the cargo area of a truck does not become a manufacturer. While this is not the case with chassis-mount campers, it is with respect to slide-in campers.; I suggest that if you wish to proceed further you consult an attorney who would be able to best assess your chances of success in civil litigation. The dealer's employee who told you that the 'GVW plate meant nothing' was mistaken. The weight ratings provided on the plate represent the manufacturer's representation of the maximum safe weight of a fully loaded vehicle.; You might wish to examine the labels attached, pursuant to Standard No 126 and 49 CFR S 575.103, to later models of both the pickup truck and camper you purchased. It is possible that those models and the ones you purchased are not substantially different. If that is the case the information on the labels can provide an indication of the extent that the weight ratings were exceeded by installation of the camper unit in question.; While I regret we cannot be of further assistance I wish you success i your efforts to solve this problem.; Yours truly, Richard B. Dyson, Assistant 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.