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: aiam3952OpenMr. Victor Felice, President, Eurospec, Inc., 109 Treetops Circle, Nanuet, NY 10954; Mr. Victor Felice President Eurospec Inc. 109 Treetops Circle Nanuet NY 10954; Dear Mr. Felice: This responds to your letter of March 29, 1985, concerning tw aftermarket products you intend to import. The products, which you call the 'Super Klip' and the 'Klunk Klip' safety belt comfort devices, consist of plastic devices which attach to the upper torso belt anchorage. The belt webbing then goes through a wedge attached to your device. A belt user can then pull the webbing through the open wedge and close the wedge to introduce slack into the shoulder portion of the belt. You asked for the agency to review the devices and inform you of any comments or objections.; As background information, let me explain that the agency does not hav the authority to approve items of motor vehicle equipment, such as your devices. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards.; Your particular aftermarket products are not covered by any of ou safety belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your products. Those responsibilities are set out in sections 151-160 of the National Traffic and Motor Vehicle Safety Act, a copy of which is enclosed.; The agency is concerned that a belted occupant could use your produc to reduce the effectiveness of the upper torso belt by moving the belt so close to the edge of the shoulder that the occupant could rotate out of the upper torso belt in a crash. Likewise, your product could be used to introduce excessive slack in the upper torso belt, which would also reduce its effectiveness. The instructions you provide with the 'Klunk Klip' do include information about how much slack to introduce into the belt and warns users not to introduce excessive slack. The instructions for the Super Klip contain no information or warnings on belt slack. We urge you to include a warning in both your instructions to advise belt users about the consequences of introducing too much slack in the belt.; I am returning the samples of your products that you enclosed with you letter. If you have any further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam3289OpenMr. Robert Slagle, Parts Manager, Brown Motors Volkswagen, 5 West 18th Street at National City Boulevard, National City, CA 92050; Mr. Robert Slagle Parts Manager Brown Motors Volkswagen 5 West 18th Street at National City Boulevard National City CA 92050; Dear Mr. Slagle: This responds to your recent letter requesting information concernin the Federal requirements that would be applicable to the manufacture and installation of auxiliary diesel fuel tanks in passenger cars. I am enclosing a copy of a letter of interpretation the agency issued last August which discusses the general implications of such installations under Federal law.; Your letter asked whether it will be necessary for you to crash tes vehicles that have the auxiliary tanks installed. As indicated in the enclosed interpretation, if the tank is added to a new vehicle prior to its first purchase for purposes other than resale, the person making the alteration will have to certify that the vehicle continues to be in compliance with all Federal motor vehicle safety standards, including Standard No. 301-75. The National Traffic and Motor Vehicle Safety Act requires a manufacturer (including an alterer) to exercise due care to assure that a vehicle it certifies is in fact in compliance with all safety standards (15 U.S.C. 1397). It is up to the manufacturer to determine how he will establish due care and, in this case, whether he will crash test a vehicle or use some other method to ensure compliance of the vehicle. The test procedures in Safety Standard No. 301-75 are not obligatory, only the performance requirements. The test procedures do, however, state how the agency will test a vehicle to determine compliance.; In answer to your question number 4, I can state that it will not b necessary for you to crash test each vehicle which has a tank installed in order to establish due care. If by your question you meant one car of each car 'model,' once again, it is up to the manufacturer how he establishes due care.; In answer to your question number 3, the information contained in th enclosed interpretation includes discussions of all the Federal safety requirements that would be applicable to your company's activities. There may, of course, be other general Federal laws regarding the conducting of a business which would be pertinent. For example, Federal Trade Commission regulations regarding advertising could affect your activities. You are probably aware of these general regulations, however, since you are already an established business enterprise.; Regarding your final question, all vehicle manufacturers, both domesti and foreign, have performed crash tests to determine compliance with Safety Standard No. 301-75. Since your company is a Volkswagen dealership, I suggest you contact Volkswagen regarding its compliance testing program for Safety Standard No. 301-75.; If you have any further questions after reviewing this information please contact Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4651OpenMr. Douglas Shoner S.E.M. Co. 12244 Truro Avenue Hawthorne, CA 90250; Mr. Douglas Shoner S.E.M. Co. 12244 Truro Avenue Hawthorne CA 90250; "Dear Mr. Shoner: This responds to your letter asking about NHTSA' regulation of foam-filled tires. Specifically, you asked what criteria must be satisfied in order for a foam-filled tire to be approved by this Department, and whether any foam-filled tires have satisfied these criteria. As explained below, NHTSA does not 'approve' any motor vehicle or item of motor vehicle equipment. Instead, the manufacturer itself must certify that the vehicle or item of equipment complies with any and all applicable safety standards. By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. When the agency has issued an applicable safety standard, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) provides that no person shall 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any new motor vehicle or new item of equipment unless the vehicles or equipment comply with the applicable standard. A manufacturer is not required to get 'approval' or 'recognition' from this agency before selling its motor vehicles or items of motor vehicle equipment. In fact, NHTSA has no authority under the Safety Act to approve, certify, or otherwise endorse any commercial product. Instead, section 114 of the Safety Act (15 U.S.C. 1403) establishes a self-certification process under which every manufacturer is required to certify that each of its products meet all applicable Federal safety standards. I note that, following a telephone conversation with you, Marvin Shaw of my staff sent you a copy of our September 2, 1986 letter to Mr. Andrew Kroll explaining how NHTSA's regulations apply to foam-filled tires. That letter remains an accurate expression of this agency's regulation of foam-filled tires. If you have any further questions or need additional information on this subject, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam4156OpenMr. Rudy Valdez, Product Manager, Mr. Gasket Company, 19914 South Via Baron St., Compton, CA 90220; Mr. Rudy Valdez Product Manager Mr. Gasket Company 19914 South Via Baron St. Compton CA 90220; Dear Mr. Valdez: This is in reply to your letter of May 1, 1986, with reference t Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*.; Your first question concerns the liability of an aftermarket splas guard installed behind the rear wheels which would incorporate a decorative light, the illustration you enclose shows the word 'Ford' illuminated. Although the lighting equipment that is required by Standard No. 108 must be located on a rigid part of the vehicle, there is no such requirement for aftermarket equipment such as the device that you propose. If an item of aftermarket equipment is installed before the sale of a new vehicle to its first owner, such an item is permissible under Standard No. 108 provided that it does not impair the effectiveness of the required lighting equipment, but no matter when it is installed, it would be subject to regulation by any State in which a vehicle so equipped is registered or operated. We are not familiar with State laws on this subject, and recommend that you contact the Department of Motor Vehicles in States where you intend to sell your device.; Your second question asks for information on the new center hig mounted stop lamp, saying that you have seen some that do not appear to meet Federal requirements. You ask whether we will require retrofitting of vehicles. The new lamp was optional for passenger cars manufactured on or after August 1, 1984, and mandatory for those manufactured on or after September 1, 1985. The coverage of Standard No. 108 also extends to aftermarket items that are manufactured to replace original equipment center high mounted stop lamps, but there are no Federal requirements for lamps intended for use on cars that were not originally manufactured with them. We encourage manufacturers to meet the Federal specifications as closely as possible, however, and I enclose a copy of the regulation for your information. We have no authority to require retrofitting of vehicles.; I hope that this answers your questions. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam5129OpenMr. Nilton Mello Vitrotec - Vidros De Seguranca Ltda Rua Jacofer, 350 CEP 02712 Sao Paulo, Brazil; Mr. Nilton Mello Vitrotec - Vidros De Seguranca Ltda Rua Jacofer 350 CEP 02712 Sao Paulo Brazil; "Dear Mr. Mello: This responds to your inquiry about the exportation o your laminated motor vehicle windshields into the United States. According to your letter, you have already designated an agent in this country and have received your DOT number. You asked whether you are required to perform tests at an American laboratory before you can export your product into the United States. I am pleased to have this opportunity to respond to your inquiry. I am also enclosing a copy of a fact sheet entitled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' By way of background information, section 103 of the National Traffic and Motor Vehicle Safety Act ('Safety Act,' 15 U.S.C. 1392) authorizes NHTSA to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not however approve or certify any vehicles or items of 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. NHTSA tests vehicles and equipment sold to consumers for compliance with safety standards and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of noncomplying or defective products is also subject to civil penalties. In response to your question about whether you are required to perform tests at an American laboratory, the answer is no. As indicated above, manufacturers of motor vehicles and motor vehicle equipment are required to certify that their products comply with all applicable safety standards. Manufacturers must have some basis for their certification. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. You are not required to use the services of an American laboratory in conducting tests associated with certification. I hope that you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam5456OpenMr. Thomas L. Wright Coordinator, Technical Support New Jersey Division of Motor Vehicles CN 179 Trenton, NJ 08666; Mr. Thomas L. Wright Coordinator Technical Support New Jersey Division of Motor Vehicles CN 179 Trenton NJ 08666; Dear Mr. Wright: This responds to your letter of July 15, 1994, t Robert Hellmuth of this agency requesting an opinion whether brush guards offered as accessories for Range Rovers and installed in front of headlamp units are in violation of Standard No. 108. Our letter is based upon the configurations of 'brush bars' depicted as accessory equipment in a 1994 Range Rover brochure. The brochure notes that brush bars 'may be illegal for on-road use in some states. Please check local regulations before purchase, installation, or use.' We note that this advisory applies to the rear lamp guards as well. The purpose of the brush bar is to offer protection to the grille, radiator, and front and rear lamps, and it does so by incorporating three slender horizontal bars in front of the lenses of the front and rear lamps. Paragraph S7.8.5 of Standard No. 108 states that headlamps when activated 'shall not have any styling ornament or other feature, such as a translucent cover or grille, in front of the lens.' The lamp guard portion of the brush bar is the type of 'other feature . . . in front of the lens' that is prohibited by Standard No. 108. Thus, under Federal law, a Range Rover could not be displayed for sale and sold with a brush bar installed unless the lamp guards had been removed. This should present no problem as, according to the brochure, the 'lamp protectors are easily removable for cleaning and maintenance.' In our view, the proper time for installation of the lamp protectors is when the vehicle begins to be used off-road. Although there is no similar direct prohibition in Standard No. 108 applicable to other vehicle lamps, the parking lamps, turn signal lamps, and rear lamps are required to conform with the photometric requirements of Standard No. 108 when the lamp guards are in place. This is based upon two paragraphs of the standard. S5.3.1.1 prohibits any part of a vehicle from preventing parking lamps, turn signal lamps, and rear lamps from meeting the required photometric output. S5.1.3 prohibits the installation of supplementary motor vehicle equipment that impairs the effectiveness of lighting equipment that Standard No. 108 requires as original equipment. The guards are designed for maintenance by the owner, and their installation by the owner after purchase of the Range Rover would not be in violation of Federal law, even if installed for on-road use. Operation of the Range Rover is subject only to State law, and a State may forbid on-road use of a Range Rover with the lamp guards installed if it so chooses. Sincerely, Philip R. Recht Chief Counsel; |
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ID: aiam5086OpenLawrence A. Beyer, Esq. 674 Lake Road Webster, N.Y. 14580; Lawrence A. Beyer Esq. 674 Lake Road Webster N.Y. 14580; "Dear Mr. Beyer: This responds to your FAX of September 22, 1992, t Taylor Vinson of this Office with reference to your request to become a Registered Importer ('RI'). We interpret your letter as seeking an opinion on your eligibility to submit an application to become an RI under 49 CFR 592. Because of your representation of RIs, you are familiar with the record keeping mechanisms and other regulatory requirements of this agency. Your intent is to perform modifications on those Canadian vehicles which require only minor modifications, and you have a 3-car garage, tools including pneumatics, and storage space. You would have in your employ several people qualified to perform the modifications required. You are aware that, in promulgating Part 592, NHTSA specificaly rejected a proposal to allow RIs to designate agents to perform conformance work, thus you would not accept vehicles requiring major modifications, but would refer those to the other RIs. Section 592.5 sets forth the requirements for registration as an RI. According to paragraph 592.5(a), 'any person' may file an application. An application must contain the information specified by the subparagraphs of paragraph (a). We note no restrictions upon who is eligible to apply for RI status. We therefore see no legal impediment to your submitting an application under section 592.5. The Office of Vehicle Safety Compliance (OVSC) has the authority to grant or deny applications for RI status. Your application must, therefore, contain arguments sufficient to convince OVSC of your ability to perform the limited modifications that you contemplate. We advise you, therefore, to set out with specificity in your application the Federal motor vehicle safety standards for which you have the capability to conform vehicles, and the standards for which you have not. We would like to make clear that, in the event a vehicle requires major modifications, our regulations would not allow you to bring the vehicle into partial conformance before transfering the vehicle to another RI for to complete the conformance process. An RI must certify the conformance work to NHTSA, and paragraph 592.6(e) requires the RI's certification to state that 'it is the person legally responsible for bringing the vehicle into conformity.' We interpret that as meaning that the certifier itself performed all the conformance work and did not resort to an agent. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5181OpenMr. Steve Flint Century Products Co. 9600 Valley View Road Macedonia, OH 44056-2096; Mr. Steve Flint Century Products Co. 9600 Valley View Road Macedonia OH 44056-2096; "Dear Mr. Flint: This responds to your question about the registratio form required by S5.8 of Standard 213, 'Child Restraint Systems.' In telephone conversations with Deirdre Fujita of my staff, you indicated that your registration form would have certain characteristics. The form would be identical to the ones shown in figures 9a and 9b of Standard 213 and required by S5.8 of the standard, except that cards bearing additional information would be attached to it. The additional information consists of French and Spanish translations of the instructions shown in Figure 9a for filling out the registration form, and a French version of the registration form shown in Figure 9b. You stated that the Spanish instructions are for the Spanish speaking population in the U.S. You also said that the French form is required by Canada for restraints sold there, and that attaching it to the U.S. (English) form facilitates your compliance with both U.S. and Canadian standards. We conclude that as long as the English form complies with S5.8 and does not bear any information or writing beyond that required to be on the form, cards bearing the French and Spanish information may be attached to the English form if the information on those cards is presented in a manner that is not likely to confuse consumers in this country about the meaning of the English form or the importance of owner registration. As to whether the additional information is likely to cause confusion, we note the additional information consists solely of French and Spanish translations of the information on the English form. We note further that you indicated to Ms. Fujita that significant numbers of your consumers have been filling in and mailing the tri-lingual registration cards. This return rate indicates that the additional information has not confused the consumers. We appreciate your recognition of the differing language needs of your customers. NHTSA has suggested to manufacturers that they should consider providing consumer instructions on the use of child restraints not only in English, but also in other languages, to address a possible need for such information. (See, denial of petition for rulemaking from Mr. Mattox, 55 FR 48262, November 20, 1990.) Please note, however, that NHTSA wishes to maximize the return rates for the registration forms. If information arises that indicates the French and Spanish information is confusing consumers or otherwise negatively affecting return rates, the agency will reconsider whether such information should be permitted. I hope this information is helpful. Please call Ms. Fujita at (202) 366-2992 if you have further questions. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3959OpenMr. M. Ojima, Manager, Asahi Glass Company, Ltd., 1-2, Marunouchi 2-Chome., Chiyoda-Ku, Tokyo, Japan; Mr. M. Ojima Manager Asahi Glass Company Ltd. 1-2 Marunouchi 2-Chome. Chiyoda-Ku Tokyo Japan; Dear Mr. Ojima: Thank you for your letter of May 8, 1985, to Administrator Stee concerning the requirements of Standard No. 205, *Glazing Materials*, that apply to glass-plastic glazing. The answers to your questions are discussed below.; Your first question concerns the requirements of the boil and humidit tests that apply to glass-plastic glazing. You explained that after the boil test and the humidity test, your plastic material develops a haze. You stated that the maximum haze resulting from the boil test is approximately 45 percent and the maximum haze resulting from the humidity test is approximately 10 percent. However, after the sample had been left at room temperature for 24 hours, the plastic haze disappeared and the plastic 'completely recovered to the original condition.'; As you correctly noted, Standard No. 205 requires glass-plastic glazin to pass Test No. 3, Humidity, and Test 4, Boil Test, of the American National Standard Institute's 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways' Z26.1-1977, January 26, 1977 as supplemented by Z26.1a, July 3, 1980, which is incorporated by reference in our standard. As explained in the preamble to the November 16, 1983, final rule setting performance requirements for glass-plastic glazing, the purpose of the humidity and boil tests is to ensure that the plastic layer of glass-plastic glazing does not delaminate when exposed to high temperatures and humidity. Since the temporary haze does not result in a permanent change in the structure of the glazing, which would occur if the glazing delaminated, we do not consider the temporary haze to be a failure of the boil or humidity tests. The glazing must, of course, comply with Test No. 17, Abrasion Resistance, as modified by Standard No. 205, which is directly meant to limit haze.; Your second question concerned whether you should mark glass-plasti glazing as 'AS1' or 'AS14'. You noted that ANSI Z26.1-1983 specifies that glass- plastic glazing should be marked 'AS1', while our standard specifies the use of 'AS14'. Standard No. 205 incorporates by reference the 1977 version of Z26.1, as supplemented by Z26.1a, July 3, 1980, and does not incorporate Z26.1-1983. Therefore, in accordance with S6.1 of Standard No. 205, you must mark glass- plastic glazing manufactured for sale in the United States with 'AS14'.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2551OpenMr. David E. Martin, Director, Automotive Safety Engineering, General Motors Technical Center, General Motors Corporation, Warren, Michigan 48090; Mr. David E. Martin Director Automotive Safety Engineering General Motors Technical Center General Motors Corporation Warren Michigan 48090; Dear Mr. Martin: This responds to your February 16, 1977, question whether Safet Standard No. 105-75, *Hydraulic Brake Systems*, preempts the parking brake requirements specified in New York's school bus brake system regulations.; Safety Standard No. 105-75 (49 CFR 571.105-75) becomes effective Apri 1, 1977, for school buses and establishes requirements for the service and parking brake systems on these vehicles. The standard includes a static test requirement for parking brake systems (grade-holding capability) and a dynamic test requirement for service brake systems (emergency stopping capability). The New York brake system regulations include a static test requirement and also a dynamic test requirement for parking brake systems. You ask whether Standard No. 105-75 is preemptive of New York's dynamic test requirement for parking brakes.; Section 103(d) of the National Traffic and Motor Vehicle Safety Act (1 U.SC. S 1392 (d)) provides that no State or political subdivision of a State may promulgate or continue in effect standards applicable to an aspect of motor vehicle or motor vehicle equipment performance which is covered by a Federal motor vehicle safety standard, unless the standards are identical.; As noted, Standard No. 105-75 includes requirements for the parkin brake control aspect of braking performance. The Federal requirements must be regarded as conclusive with regard to this aspect of performance in order to maintain the uniformity necessary in a Federal regulatory scheme. It is the agency's opinion, therefore, that Standard No. 105-75 is preemptive of the nonidentical aspects of New York's school bus parking brake requirements.; However the second sentence of S 103(d) clarifies that the limitatio on State safety regulations of general applicability does not preempt governmental entities from specifying additional safety features in vehicles purchased for their own use if such requirements impose a higher standard of performance. Thus, the State of New York may specify these additional parking brake requirements for public school buses. The second sentence of S 103(d) does not permit governmental entities to specify safety features that prevent the vehicle or equipment from complying with applicable safety standards.A school bus manufacturer must continue to comply with all aspects of Standard No. 105-75. A school bus manufacturer, therefore, would have to meet the force requirements specified in Standard No. 105-75 for engagement of the parking brake, even for school buses intended for new York's own use.; Sincerely, Frank A. Berndt, 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.