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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



Displaying 8091 - 8100 of 16490
Interpretations Date

ID: aiam1726

Open
Mr. Robert L. Donnelly, Secretary, Armstrong Rubber Company, New Haven, Connecticut 06507; Mr. Robert L. Donnelly
Secretary
Armstrong Rubber Company
New Haven
Connecticut 06507;

Dear Mr. Donnelly: This responds to your letter of May 30, 1975, concerning the standard applicable to a tire which you manufacture and sell with the designation L78-15LT, Load Range C.; You are mistaken in your assumption that a station wagon is classifie as a multi-purpose passenger vehicle. Because it is constructed neither on a truck chassis nor with special features for occasional off-road operation, a station wagon is a passenger car rather than a multi-purpose passenger vehicle.; If, despite this misunderstanding, the L78-15LT tire in question i designated by you as primarily intend for use on lightweight trucks or multi-purpose passenger vehicles, then it is a light truck tire subject to Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*.; Because a station wagon is a passenger car, Standard No. 110 require that its original equipment tires comply with Standard No. 109. Standard No. 110 is not applicable to used cars, so there is no prohibition on the use of the L78-15LT tire as replacement equipment on a station wagon. However, because the informational placard on a station wagon would suggest to its owner the use of inflation pressures which are dangerously inadequate for light truck tires, we do not wish to encourage the sale of such tires as replacement equipment for use on station wagons.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam4021

Open
Mr. William E. Sandham, Sales Manager, OEM Division, Velvac, Inc., 2900 South 160th Street, New Berlin, WI 53151; Mr. William E. Sandham
Sales Manager
OEM Division
Velvac
Inc.
2900 South 160th Street
New Berlin
WI 53151;

Dear Mr. Sandham: Thank you for your letter of May 21, 1985, concerning the vertica adjustment of rearview mirrors for trucks. You asked us to clarify whether the standard requires a mirror both to tilt, as shown in your sketch 'A,' and to move up and down its mounting bracket, as shown in your sketch 'B.' As discussed below, a truck mirror can meet the adjustment requirement by either tilting or by moving up and down its mounting bracket.; The agency has not specified the means used to provide a vertica adjustment. We would consider a mirror which tilts, as shown in your sketch 'B,' as meeting the adjustment requirement. You should know that the agency has interpreted this vertical adjustment requirement for trucks to mean that adjustment with tools is allowed. The use of tools is justified because trucks and buses are generally driven for longer periods of time by the same driver and thus the mirror does not have to be continually adjusted.; Please note that S6.1(a) of Standard No. 111 also permits trucks with GVWR of 10,000 pounds or less to be equipped with rearview mirrors which meet the performance requirements for passenger cars in section S5, instead of the requirements for trucks in S6.1(b), S7, or S8. If the passenger car specifications are chosen, the driver must be able to adjust the inside and outside rearview mirrors in both vertical and horizontal directions by tilting them. The agency has not permitted the use of tools for adjusting passenger car mirrors, since passenger cars are often driven by different drivers who will need to quickly and easily adjust their mirrors. A mirror mounted on a universal ball socket joint, for example, meets this requirement. In this situation, the vertical tilting adjustment shown in your sketch 'A' would appear to comply as long as that mirror could also be adjusted horizontally by tilting. The vertical sliding adjustment shown in sketch 'B' apparently would not meet this requirement because it appears to require the use of tools to make the adjustment.; A copy of the current version of Standard No. 111 is enclosed. I hop this information is helpful to you.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam0402

Open
Mr. William H. Maas, Coordinator, Product Safety Regulations, Harley- Davidson Motor Co., Inc., 3700 West Juneau Avenue, Milwaukee, WI 53201; Mr. William H. Maas
Coordinator
Product Safety Regulations
Harley- Davidson Motor Co.
Inc.
3700 West Juneau Avenue
Milwaukee
WI 53201;

Dear Mr. Maas: This is in reply to your letter of June 21, 1971, concerning a disput you are having with your supplier of glazing materials concerning who is the 'prime glazing material manufacturer' as specified in S3.4 of Standard No. 205, and who would consequently be required to obtain a manufacturers' code number under S5.2 of the proposed amendment to Standard No. 205, published January 9, 1971 (Docket 71-1, Notice 1) (36 F.R. 326). You indicate that you purchase the glazing material from your supplier, and cut it to size for motorcycle windshields. You state that your supplier claims that although he manufactures the material to specification, he considers it to be purely a raw material, and that he is not a motor vehicle window or windshield manufacturer.; Federal Motor Vehicle Safety Standard No. 205 applies to 'glazin materials for use in . . .' specified types of motor vehicles, one of which is motorcycles. It applies to glazing material that is manufactured for use in these vehicles before as well as after it has been cut to size or installed in the motor vehicle.; If a manufacturer is producing glazing materials that he knows are fo use in motor vehicles he is, under the National Traffic and Motor Vehicle Safety Act, manufacturing glazing (1) which must comply with Standard No. 205 and (2) which he must certify, as specified in section 114 of the Act, and the Certification regulations (49 CFR Part 567, copy enclosed) as complying with the standard. A prime glazing material manufacturer may certify the material by the alternative method specified in S3.4 of Standard No. 205.; The standard clearly distinguishes between the prime manufacturer an those who merely cut the material, and places responsibility for compliance and certification on the former as well as the latter.; A producer of the basic glazing material, to be used in motor vehicles is a 'prime glazing material manufacturer' under the standard, and would be required to obtain the manufacturers' code mark under S5.2 of the proposed standard.; That proposal is currently under consideration, however, and it i recommended that no action be taken until a final regulation is published.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam4878

Open
Mr. Masaharu Morino Manager, Far East Department Guy B. Barham Company 500 North Nash Street El Segundo, California 90245; Mr. Masaharu Morino Manager
Far East Department Guy B. Barham Company 500 North Nash Street El Segundo
California 90245;

"Dear Mr. Morino: This responds to your request for an interpretatio of Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps (49 CFR 571.211). In your letter, you enclosed two samples of 'spinner' hubcaps, a product sheet describing several different designs of spinner hubcaps, and a letter from the New York Area Director of the U.S. Customs Service regarding spinner hubcaps. You asked whether these 'spinner' hubcaps may legally be imported into this country from Taiwan. The answer is no. Spinner hubcaps may not legally be manufactured or sold in the United States, nor may they legally be imported into the United States. I have enclosed copies of this agency's March 16, 1988 letter to Representative Terry L. Bruce, a May 13, 1987 letter to Representative William E. Dannemeyer, and a November 13, 1987, letter to Mr. William J. Maloney. These letters reaffirmed past interpretations stating that spinner hubcaps do not comply with the requirements of Standard No. 211, and have not complied with that Standard since it became effective on January 1, 1968. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) makes it illegal to 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any hubcaps that do not comply with Standard No. 211 (Emphasis added.). We would consider each sale or offer for sale of spinner hubcaps to be a separate violation of this statutory provision. Section 109 of the Safety Act (15 U.S.C. 1398) specifies a civil penalty of up to $1000 for each violation of Section 108(a), up to a maximum of $800,000. In your letter, you stated that some spinner hubcaps are currently being manufactured in the U. S. Thank you for alerting us to this situation. We have referred this information to our enforcement staff for appropriate action. I have also sent a copy of this letter to the Area Director of Customs for the New York Seaport. Sincerely, Paul Jackson Rice Chief Counsel Enclosures cc: Area Director of Customs New York Seaport New York, New York 10048 re: CLA-2-87:S:N:N1:101 835326";

ID: aiam0016

Open
Mr. Masaharu Morino Manager, Far East Department Guy B. Barham Company 500 North Nash Street El Segundo, California 90245; Mr. Masaharu Morino Manager
Far East Department Guy B. Barham Company 500 North Nash Street El Segundo
California 90245;

"Dear Mr. Morino: This responds to your request for an interpretatio of Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps (49 CFR 571.211). In your letter, you enclosed two samples of 'spinner' hubcaps, a product sheet describing several different designs of spinner hubcaps, and a letter from the New York Area Director of the U.S. Customs Service regarding spinner hubcaps. You asked whether these 'spinner' hubcaps may legally be imported into this country from Taiwan. The answer is no. Spinner hubcaps may not legally be manufactured or sold in the United States, nor may they legally be imported into the United States. I have enclosed copies of this agency's March 16, 1988 letter to Representative Terry L. Bruce, a May 13, 1987 letter to Representative William E. Dannemeyer, and a November 13, 1987, letter to Mr. William J. Maloney. These letters reaffirmed past interpretations stating that spinner hubcaps do not comply with the requirements of Standard No. 211, and have not complied with that Standard since it became effective on January 1, 1968. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) makes it illegal to 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any hubcaps that do not comply with Standard No. 211 (Emphasis added.). We would consider each sale or offer for sale of spinner hubcaps to be a separate violation of this statutory provision. Section 109 of the Safety Act (15 U.S.C. 1398) specifies a civil penalty of up to $1000 for each violation of Section 108(a), up to a maximum of $800,000. In your letter, you stated that some spinner hubcaps are currently being manufactured in the U. S. Thank you for alerting us to this situation. We have referred this information to our enforcement staff for appropriate action. I have also sent a copy of this letter to the Area Director of Customs for the New York Seaport. Sincerely, Paul Jackson Rice Chief Counsel Enclosures cc: Area Director of Customs New York Seaport New York, New York 10048 re: CLA-2-87:S:N:N1:101 835326";

ID: aiam1510

Open
Mr. J.C. Vecchio,Assistant Counsel,Amerace Corporation,245 Park Avenue,New York, New York 10017; Mr. J.C. Vecchio
Assistant Counsel
Amerace Corporation
245 Park Avenue
New York
New York 10017;

Dear Mr. Vecchio:#This is in reply to your letter of May 17, 1974, wit questions as to the applicability of the National Traffic and Motor Vehicle Safety Act to your operations, and its relationship to a contract provision requested by General Motors (GM) requiring that you certify compliance of the hoses you deliver to it.#Your primary responsibility under the Act is to manufacture brake hoses that conform to 49 CFR S571.106, Motor Vehicle Safety Standard No. 106. On and after September 1, 1974, pursuant to S5.2, *Labeling*, of that standard, each hydraulic brake hose, end fitting, and assembly shall be marked with 'The symbol DOT, constituting a certification' by the hose manufacturer, fitting manufacturer, and hose assembler that each item 'conforms to all applicable Federal motor vehicle safety standards.' Since the symbol is a permanent mark on the product, certification will be furnished to anyone through whose hands it passes, whether or not it is required by S114 of the Act. In our view, the symbol DOT is also a 'certificate' within the meaning of S108(b) (2) since it is the manufacturer's representation of compliance upon which other persons may rely. The contract language suggested by GM is therefore not something required by the Act.#I note however, that the amendment requested by GM is to take effect July 1, 1974, two months before you are legally required to use the DOT mark. With respect to your obligations in the interim: Under S114 and the certification notice published November 4, 1967, (32 F.R. 15444) an equipment manufacturer must certify conformity to 'dealers' and 'distributors' by a label or tag on the item itself or on the container in which it is shipped. Obviously this includes dealers and distributors to whom you sell directly.#We also consider that the manufacturer of a vehicle, such as GM, into which a hose is incorporated is a distributer of brake hoses to whom S114 certification must be provided. Any further requirements specified by GM in your contract would be, of course, purely a matter of contract law.#Because you are required to manufacture hoses to conform to Standard No. 106 you are legally responsible for any violation directly attributable to the manufacturing process, irrespective of any certification provided GM. The question whether that certification relieves GM of liability cannot be answered in the abstract. As of January 1, 1975, Standard No. 106 will also apply to motor vehicles, and we do not interpret S108(b) (2) in this context as relieving a vehicle manufacturer of his obligation to exercise due care. Certainly, at a minimum, GM would be liable for violations attributable to installation.#You have also asked for guidance on the recall provisions of S111 and the notification provisions of S113. The repurchase provisions of S111 come into effect upon a determination by either NHTSA or a manufacturer that there exists either a safety-related defect or a nonconformance. This section is not enforced directly by NHTSA, but affords redress to distributors and dealers in the event a manufacturer refuses to repurchase substandard vehicles or equipment items. Since a S108(b) (2)certificate covers only compliance and is not a guarantee of freedom from safety-related defects, it cannot have been intended 'to pass the expense of recall from GM' to you when S111 is invoked. The S108(b) (2) certificate was intended only to provide protection to certificate holders from civil penalty liabilities. Liability for expenses under S111 or S113 is a contract matter between GM and you.#As for S113, your understanding of Mr. Vinson's remarks is essentially correct. There is a direct notification obligation under S113(a) only upon manufacturers of vehicles and tires. But a S113(e) proceeding can involve any motor vehicle equipment manufacturer as a party, who could be ordered to proceed with a S113(a) notification campaign upon a finding that a safety-related defect or a noncompliance exists. A brake hose manufacturer upon such a finding would be required to provide notification to aftermarket purchasers. If the component is used as original vehicle equipment the vehicle manufacturer would normally also be a party to a S113(e) proceeding and required to furnish notification to vehicle purchasers.#Sincerely,Lawrence R. Schneider,Chief Counsel;

ID: aiam1631

Open
Mr. Orville A. Feikema, 18225 Burnham Avenue, Lansing, IL 60438; Mr. Orville A. Feikema
18225 Burnham Avenue
Lansing
IL 60438;

Dear Mr. Feikema: This is in reply to your letter of September 30, 1974, requestin copies of Federal laws and regulations dealing with the manufacture and sale of automobiles, and asking specifically for information regarding the responsibility of persons who modify for resale vehicles which, prior to modification, conform fully to Federal requirements.; I am enclosing a copy of the National Traffic and Motor Vehicle Safet Act of 1966 (15 U.S.C. 1381 *et seq*.) and the Motor Vehicle Information and Cost Savings Act (15 U.S.C. S 1901 *et seq*.). These two laws contain this agency's authority to regulate the manufacture of motor vehicles. The former statute has very recently been amended but we do not as yet have copies of the amended language for distribution. I have also enclosed information on where you may obtain copies of the Federal motor vehicle safety standards and regulations. The Environmental Protection Agency administers laws and regulations which deal with vehicle pollution. Questions regarding these requirements should be directed to Mr. Eric Stork, Environmental Protection Agency, Room 1219, East Tower, 401 'M' Street, SW, Washington, DC 20460. In addition, there is legislation of which you are no doubt aware which require manufacturers to affix the retail price and other information to new vehicles. This legislation can be found at 15 U.S.C. S 1231 *et seq*.; With respect to your question regarding persons who modify vehicles the NHTSA has issued requirements which apply specifically to this situation. Under Section 114 of the Vehicle Safety Act (15 U.S.C. S1403) and regulations issued thereunder (49 CFR Parts 567, 568), manufacturers of motor vehicles must certify each vehicle's conformity to all applicable safety standards by affixing to the vehicle a label containing certain specified information. Persons who modify vehicles in the manner you describe before their sale to the user are considered to be vehicle alterers in these regulations, and are required to conform to requirements set forth in 49 CFR S567.7 and S568.8.; If you have further questions of a specific nature after you hav reviewed the applicable requirements we will be happy to answer them for you.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: aiam2602

Open
Mrs. J. A. Selsemeyer, 5911 Cape Cod Court, Indianapolis, IN 46250; Mrs. J. A. Selsemeyer
5911 Cape Cod Court
Indianapolis
IN 46250;

Dear Mrs. Selsemeyer: This responds to your April 1, 1977, letter asking several question concerning a manufacturer's responsibility for tires installed as original equipment on a passenger car.; You asked the following questions in your letter: >>>1. Are there any laws now in effect which pinpoint responsibilit for the quality of tires received as original equipment on a new car?<<<; Section 159 of the National Traffic and Motor Vehicle Safety Act o 1966 (the Act) (15 U.S.C. 1381 *et seq*.) places responsibility upon the vehicle manufacturer for compliance of original equipment with motor vehicle safety standards. However, Section 159 gives the National Highway Traffic Safety Administration the authority to shift to the tire manufacturer the responsibility for compliance of tires with Federal safety standards. You should note that the Act establishes responsibility for compliance with Federal regulations and does not establish remedies for litigants in private law suits.; >>>2. Is it true that there is a federal law which makes it mandator for United States auto manufacturers to buy original equipment tires in equal amounts from each domestic manufacturer of tires? If so, may I have a copy of this law?<<<; There are no Federal laws of which we are aware that require vehicl manufacturers to purchase equal numbers of tires from each tire manufacturer.; >>>3. What is the current status of safety testing as provided by la in 1966, but never implemented? This law was to be effective January 1, 1976 for radial tires, July 1, 1976 for bias-belted tires, and January, 1977 for bias- ply tires. Was it? If not, what are the prospects?<<<; The regulation to which you refer is known as Uniform Tire Qualit Grading and is found in the Code of Federal Regulations, Title 49, Part 575. The effective dates for implementation of tire quality grading standards for the three tire types you mention have been delayed by litigation. The agency intends to establish new effective dates shortly.; >>>4. Can a customer of General Motors ask for and receive a servic agreement for the tires at the time of sale of a car?<<<; This is a contractual matter between the purchaser of a motor vehicl and General Motors. Federal regulations neither encourage nor discourage such arrangements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2601

Open
Mrs. J. A. Selsemeyer, 5911 Cape Cod Court, Indianapolis, IN 46250; Mrs. J. A. Selsemeyer
5911 Cape Cod Court
Indianapolis
IN 46250;

Dear Mrs. Selsemeyer: This responds to your April 1, 1977, letter asking several question concerning a manufacturer's responsibility for tires installed as original equipment on a passenger car.; You asked the following questions in your letter: >>>1. Are there any laws now in effect which pinpoint responsibilit for the quality of tires received as original equipment on a new car?<<<; Section 159 of the National Traffic and Motor Vehicle Safety Act o 1966 (the Act) (15 U.S.C. 1381 *et seq*.) places responsibility upon the vehicle manufacturer for compliance of original equipment with motor vehicle safety standards. However, Section 159 gives the National Highway Traffic Safety Administration the authority to shift to the tire manufacturer the responsibility for compliance of tires with Federal safety standards. You should note that the Act establishes responsibility for compliance with Federal regulations and does not establish remedies for litigants in private law suits.; >>>2. Is it true that there is a federal law which makes it mandator for United States auto manufacturers to buy original equipment tires in equal amounts from each domestic manufacturer of tires? If so, may I have a copy of this law?<<<; There are no Federal laws of which we are aware that require vehicl manufacturers to purchase equal numbers of tires from each tire manufacturer.; >>>3. What is the current status of safety testing as provided by la in 1966, but never implemented? This law was to be effective January 1, 1976 for radial tires, July 1, 1976 for bias-belted tires, and January, 1977 for bias- ply tires. Was it? If not, what are the prospects?<<<; The regulation to which you refer is known as Uniform Tire Qualit Grading and is found in the Code of Federal Regulations, Title 49, Part 575. The effective dates for implementation of tire quality grading standards for the three tire types you mention have been delayed by litigation. The agency intends to establish new effective dates shortly.; >>>4. Can a customer of General Motors ask for and receive a servic agreement for the tires at the time of sale of a car?<<<; This is a contractual matter between the purchaser of a motor vehicl and General Motors. Federal regulations neither encourage nor discourage such arrangements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam0860

Open
Mr. Satoshi Nishibori, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ, 07632; Mr. Satoshi Nishibori
Engineering Representative
Nissan Motor Co.
Ltd.
560 Sylvan Avenue
Englewood Cliffs
NJ
07632;

Dear Mr. Nishibori: This is in reply to your letters of August 8, and August 28, 1972 requesting interpretation of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'.; In your August 8th letter, as we understand your first question, yo ask whether the adhesive, sound-proofing material used on the floor panels of your cars should be tested together with the few insulating fibers which become embedded in this material when the insulation which covers the sound- proofing material is removed. The Standard provides a list of the interior components which must meet its requirements and the manner in which those components are to be tested. Since the sound-proofing material you have described would not be considered a floor covering and it is not otherwise included in S4.1 of the Standard, it is not subject to the requirements.; You ask further whether the 'seal screen' you glue peripherally on th inner, door panels to prevent water from penetrating the interior of the door must meet the requirements of the Standard. The 'seal screen', as you describe it, does not appear to be part of the panel and, accordingly, it would not be subject to the Standard.; In your August 28th letter, you ask whether the procedure you have fo testing the 'jute' insulating material used under the floor carpet of your cars conforms to the requirements of Standard No. 302. You state that this procedure includes removing the insulation and testing its top surface, which you designate as 'surface B', rather than testing its bottom surface, which you designate as 'surface A'. We are not sure what you mean by testing a 'surface', the Standard refers to a test for the entire specimen. You may be concerned with whether the specimen is oriented upward or downward. Under the Standard, the test specimen for each component is to be tested 'so as to provide the most adverse results'. Accordingly, the relevant test result is the most adverse one achieved in any horizontal orientation, either upward- or downward-facing. The fact that you remove the insulating material so as not to raise the nap on its bottom surface is consistent with existing test procedures.; 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.

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