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: aiam4891OpenMessrs. Steven M. and Morris G. Healy P.O. Box 73 Worthington, MA 01098-0073; Messrs. Steven M. and Morris G. Healy P.O. Box 73 Worthington MA 01098-0073; Dear Messrs. Healy: This responds to your letter of June 5, l99l, t Richard Van Iderstine of this agency, asking for an opinion as to the legality of your device that attaches monitoring lights to bug deflectors 'and/or to other appropriate mounting areas on vehicles.' As you state it, the primary purpose of the device is to 'bring indicator lights up and into the line of vision of the vehicle operator.' You specifically mention the turn signal and upper beam indicators ('or other appropriate applications desired by the operator).' You mention that the existing indicator lights on the dashboard are left undisturbed. As bug deflectors or shields are accessory equipment sold in the aftermarket, it is clear that you do not intend your device to be original equipment offered by the vehicle manufacturer. The Federal statute governing the manufacture of motor vehicles and motor vehicle equipment is the National Traffic and Motor Vehicle Safety Act. There is no regulation or standard under this Act that relates to the manufacture and sale of your device. We must, however, add a cautionary note relating to the use of your device by its purchaser. The Act prohibits any 'manufacturer, distributor, dealer, or motor vehicle repair business' from rendering 'inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in accordance with an applicable Federal motor vehicle safety standard.' You have assured us that the existing indicator lamps are not affected. However, one of the requirements of the lighting standard (Standard No. 108) that applies to motor vehicles is that accessory equipment not 'impair the effectiveness' of the lighting equipment required by the standard. We regard the potential to create confusion as the potential to impair the effectiveness of lighting equipment. It does not appear that the turn signal indicator portion of your device, operating in tandem with the turn signals, would create confusion. Likewise, the upper beam indicator would be too small to be perceived by an oncoming car at any great distance. However, you have added qualifications to your letter ('other appropriate mounting areas on vehicles' and 'other appropriate applications desired by the operator') that require us to advise you of the statutory prohibition. The prohibition does not affect vehicle owners, and if you intend the device to be installed by them, you may disregard the foregoing. However, in any event, the use of the device is also subject to the laws of any State in which it will be used. We are unable to advise you on these laws, and suggest that you write for an opinion the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam3946OpenMr. Dick Kruse, Secondary Schools Principals Association, 1904 Association Drive, Reston, VA 22091; Mr. Dick Kruse Secondary Schools Principals Association 1904 Association Drive Reston VA 22091; Dear Mr. Kruse: This responds to your May 1, 1985 telephone call to the Nationa Highway Traffic Safety Administration (NHTSA) regarding the Federal motor vehicle safety standards applying to buses for school extracurricular activities. You were especially interested in the agency's regulatory definition of 'school bus' which was adopted pursuant to enactment of the Motor Vehicle and Schoolbus Safety Amendments of 1974 (Public Law 93-492, hereinafter 'the Schoolbus Safety Amendments').; In the Schoolbus Safety Amendments, Congress defined 'school bus' as: >>>a passenger motor vehicle which is designed to carry more than 1 passengers in addition to the driver, and which the Secretary determines is likely to be significantly used for the purpose of transporting primary, preprimary, or secondary school students to or from such schools or events related to such schools.<<<; The legislative history of the Schoolbus Safety Amendments shows tha Congress chose to specify a broad definition of a school bus, so as to require vehicles used solely for extracurricular activities to meet the same safety standards as buses used to transport the children to and from school. Congress intended NHTSA to set forth a regulatory definition of a school bus that encompassed any bus likely to be significantly used for student transportation.; The agency's definition of a school bus in accordance with th Congressional definition of that term. The agency definition is found in the definitions section of our motor vehicle safety standards (Volume 49 of the Code of Federal Regulations, Part 571.3). A school bus is defined as:; >>>a bus that is sold, or introduced in interstate commerce, fo purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operations as a common carrier in urban transportation. <<<; Our regulations further define 'bus' as 'a motor vehicle with motiv power, except a trailer, designed for carrying more than 10 persons.'; The enclosed materials include a Federal Register notice (40 FR 60033 December 31, 1975) amending the agency's definition of school bus to conform to the mandate of the Schoolbus Safety Amendments, and materials on the legislative history of Title II of the Amendments, *Schoolbus Safety*. Pursuant to your request, I have also enclosed a copy of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, and information describing our motor vehicle safety standards and how you can obtain copies of those standards.; You expressed an interest in Secretary Dole's response t Representative Cheney's recent letter regarding NHTSA's regulations for activity buses used by school districts. A copy of that letter is enclosed.; Please let me know if we can be of further assistance. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam1804OpenMr. Charles J. Calvin, President, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin President Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: It has come to the attention of the National Highway Traffic Safet Administration that a 'Recommended Practice' issued by the Truck Trailer Manufacturers Association, titled 'Method for Determining GAWR and GVWR for Truck Trailer Certification' may be misleading some trailer manufacturers in their responsibilities to certify their products to Standard No. 121, *Air Brake systems*. The recommended practice was reviewed by the NHTSA in draft form to determine its consistency with Parts 567, *Certification*, and 568, *Multi-stage vehicle manufacture*, of Title 49 of the Code of Federal Regulations.; The NHTSA in a March 30, 1972, letter to Mr. Vincent Grey found th draft consistent with Parts 567 and 568. The draft discusses, among other things, the method for determining the gross axle weight rating (GAWR) of an axle at a speed lower than full highway speed. It appears, however, that some manufacturers have understood the draft's discussion to set out the entirety of their responsibilities under the safety standards, and in particular, Standard No. 121. Although the March 30, 1972, review of the TTMA procedures did approve the use of speed qualifications in establishing GAWR and GVWR on Certification labels, our review only recognized the possibility that in some cases GAWR and GVWR might be properly established on the basis of a speed limitation. (An example of such a possibility would be for a vehicle which was physically incapable of reaching highway speeds.); We do not consider it reasonable to extend that interpretation t permit a manufacturer to establish a reduced- speed rating to avoid a safety standard such as Standard No. 121. A vehicle capable of highway speeds and reasonably expected to be operated at such speeds is subject to Standard No. 121 at weight ratings specified for highway speeds.; In view of the misunderstanding that has arisen, we believe i necessary to clarify our approval letter of March 30, 1972, insofar as it relates to the establishment of GAWR and GVWR. These values, to meet the requirements of SS 567.4(g)(3) and (4), must henceforth be unqualified ratings, and may not be based on reduced speeds. If reduced-speed ratings are to be established, they must be *in addition to* the unqualified ratings, and must appear at the end of the certification label, or on a separate label, and in either case be accompanied by an adequate explanation as to the scope of their use.; We realize that this clarification may force revision of the practice of some of your members. Manufacturers who have utilized this practice should be advised immediately that it is inappropriate under the requirements.; Yours truly, James C. Schultz, Chief Counsel |
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ID: aiam1805OpenMr. Charles J. Calvin, President, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin President Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: It has come to the attention of the National Highway Traffic Safet Administration that a 'recommended Practice' issued by the Truck Trailer Manufacturers Association, titled 'Method for Determining GAWR and GVWR for Truck Trailer Certification' may be misleading some trailer manufacturers in their responsibilities to certify their products to Standard No. 121, *Air brake systems*. The recommended practice was reviewed by the NHTSA in draft form to determine its consistency with Parts 567, *Certification*, and 568, *Multi-stage vehicle manufacture*, of Title 49 of the Code of Federal Regulations.; The NHTSA in a March 30, 1972, letter to Mr. Vincent Grey found th draft consistent with Parts 567 and 568. The draft discusses, among other things, the method for determining the gross axle weight rating (GAWR) of an axle at a speed lower than full highway speed. It appears, however, that some manufacturers have understood the draft's discussion to set out the entirety of their responsibilities under the safety standards, and in particular, Standard No. 121. Although the March 30, 1972, review of the TTMA procedures did approve the use of speed qualifications in establishing GAWR and GVWR on Certification labels, our review only recognized the possibility that in some cases GAWR and GVWR might be properly established on the basis of a speed limitation. (An example of such a possibility would be for a vehicle which was physically incapable of reaching highway speeds.); We do not consider it reasonable to extend that interpretation t permit a manufacturer to establish a reduced- speed rating to avoid a safety standard such as Standard No. 121. A vehicle capable of highway speeds and reasonably expected to be operated at such speeds is subject to Standard No. 121 at weight ratings specified for highway speeds.; In view of the misunderstanding that has arisen, we believe i necessary to clarify our approval letter of March 30, 1973, insofar as it relates to the establishment of GAWR and GVWR. These values, to meet the requirements of SS567.4(g)(3) and (4), must henceforth be unqualified ratings, and may not be based on reduced speeds. If reduced-speed ratings are to be established, they must be *in addition to* the unqualified ratings, and must appear at the end of the certification label, or on a separate label, and in either case be accompanied by an adequate explanation as to the scope of their use.; We realize that this clarification may force revision of the practice of some of your members. Manufacturers who have utilized this practice should be advised immediately that it is inappropriate under the requirements.; Yours truly, James C. Schultz, Chief Counsel |
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ID: aiam3411OpenMr. Thomas W. Elkins, Secretary, North American Classics Corporation, 1851 Austin, Troy, MI 48084; Mr. Thomas W. Elkins Secretary North American Classics Corporation 1851 Austin Troy MI 48084; Dear Mr. Elkins: This is in reply to your letter of April 15, 1981, asking two question with respect to the temporary exemption provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410) and implementing regulations (49 CFR Part 555).; Your first question is: >>>(1) Assuming North American Classics designs the total engineerin of the Thunderbird reproduction, selects all components to be incorporated therein, retains primary control over quality control, testing, FMVSS compliance in design, and manufacturing assembly sequence, and markets the produced vehicles on its behalf to its customers, does North American Classics remain eligible to apply for exemption from meeting certain FMVSS requirements for this vehicle in the event that the actual responsibility for the assembly of the vehicles is contracted by North American Classics to a manufacturer which produces more than 10,000 motor vehicles per year?<<<; Although you have not said so I understand from Taylor Vinson that th manufacturer with whom you would contract is a foreign corporation which has never produced motor vehicles for the American market. We also understand that it may be less expensive to have your car built abroad than at home.; Under the circumstances you describe, the foreign corporation appear to be nothing more than your agent in fabricating the vehicles and returning them for sale. This would not affect your eligibility for exemption. You would retain the responsibility for certification, as we understand it, even though the name of the foreign manufacturer would also appear on the certification label, as required by 49 CFR 567.4(g)(1).; Your second question is: >>>(2) In the event that North American Classics enters into a agreement to have such vehicles produced or assembled by a major automotive manufacturer, who would not be so eligible, and if such agreement provides for the sharing of profits derived from the sales of the finished product between North American Classics and such manufacturer, as a means of providing North American Classics assurance that projected costs of such manufacturer do not increase beyond North American Classics' ability to survive financially, in such event would North American Classics retain its eligibility status, assuming North American Classics retains control of the functions outlined in paragraph?<<<; We do not believe that a profit-sharing agreement *per se* would affec your eligibility for exemption. Were the foreign company to receive a majority share of the profits or to purchase sufficient stock in your company to give it effective control, however, we would have substantial questions about which party actually exercises primary control.; I hope this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4774OpenMr. Jack Rademacher Chief Engineer Polar Tank Trailer, Inc. 12810 County Road 17 Holdingford, MN 56340; Mr. Jack Rademacher Chief Engineer Polar Tank Trailer Inc. 12810 County Road 17 Holdingford MN 56340; Dear Mr. Rademacher: This is in reply to your letter of May 8, l990, t Stephen P. Wood of this Office, asking for reconsideration of a recent interpretation of Standard No. 108. We assume you mean our letter of January 9, 1990, to Howard Kossover of Oklahoma City. That interpretation stated that if rear lamps on a semi-trailer were mounted 27 inches forward of the rear edge of the vehicle, they were not mounted 'on the rear', the location specified by Standard No. 108. We also observed that compliance with the 45-degree visibility requirements in that location appeared questionable. You say that it has long been the practice of the Truck Trailer Manufacturers Association (TTMA) and its members that 'if the 45 degree visibility requirement of these lights were met 'on the rear' of the trailer both inboard and outboard, the manufacturer met the intent of the standard.' You inform us that the liquid bulk transport industry is especially affected by this interpretation because of reasons of practicality unique to tank transports. On these vehicles, you state that the rear lamps have been 'mounted as far as 36 inches forward from the rear of the bumper', but that, in this location, they 'still maintain the 45 degree visibility requirements.' You therefore ask for reconsideration of the interpretation if the 45 degree visibility requirements are met. The lamps in your letter (and Mr. Kossover's) are stop, turn signal, and taillamps. Only the taillamps are presence lamps. The stop lamps and turn signal lamps operate independently of the headlamps. That is to say, they are intended for use at all times and not just at night or under other conditions of reduced visibility. They indicate actions taken by the vehicle operator to signal his operational intentions to other drivers and pedestrians. Problems with depth perception of following drivers could result if the lamps are not mounted 'on the rear' as the standard requires. We are willing to interpret 'on the rear' as meaning the trailing edge of the rear fender, which may not extend as far rearward as the bulk tank container, provided the visibility requirements are met, but we conclude that a mounting location for stop and turn signal lamps that is 36 inches forward from the rear of the bumper is not 'on the rear' as the standard requires. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam5297OpenMaurice Hannigan, Commissioner Department of California Highway Patrol P.O. Box 942898 Sacramento, CA 94298-001; Maurice Hannigan Commissioner Department of California Highway Patrol P.O. Box 942898 Sacramento CA 94298-001; "Dear Mr. Hannigan: It has come to our attention that misunderstanding has arisen about a letter we issued on March 31, 1993 to W.C. Burke of your Department. That letter explained the marking responsibilities of a person who installs replacement glass (referred to as glazing in the Federal standard) under section S6.4 of Federal motor vehicle safety standard No. 205, Glazing Materials (49 CFR 571.205, copy enclosed.) On January 12, 1994, Mr. Clarke Harper of this agency's Office of Vehicle Safety Standards and Mr. Marvin Shaw of my staff contacted Mr. Walter Burke and Mr. Kyle Larson of CHP to discuss this matter. This letter is a follow up to that discussion. Based on its understanding of the March 1993 letter, CHP is requiring installers to mark replacement glazing with a number (which the agency refers to as a manufacturer's code mark) and has directed school districts to tell installers of glass to contact NHTSA ' t o obtain a number as required by Standard No. 205 .' Standard No. 205 does not require the typical aftermarket installer to obtain such a number from the agency. We explained in the March 1993 letter that a person who cuts glazing (i.e., a typical installer of aftermarket glazing) must mark the piece with the following information required by section 6 of American National Standard (ANS) Z26: (1) the words 'American National Standard' or the characters 'AS,' (2) a number identifying the item of glazing, (3) a model number assigned by the manufacturer that identifies the type of construction of the glazing material, and (4) the manufacturer's distinctive designation or trademark. Mr. Larson stated that he was under the impression that '(3) a model number assigned by the manufacturer' was a number assigned by NHTSA. As we explained to him, this is not the case. The installer devises his own model number. The only number assigned by NHTSA under Standard No. 205 is the code mark assigned to a manufacturer who 'fabricates, laminates, or tempers the glazing material' (known as a 'prime glazing material manufacturer'). We hope that this clarifies our earlier letter on this subject. If you have any other questions, please contact Mr. Shaw at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2498OpenMr. Allan Cheshire, Market Research Analyst, Robert Bosch Corporation, 2800 South 25th Avenue, Broadview, IL 60153; Mr. Allan Cheshire Market Research Analyst Robert Bosch Corporation 2800 South 25th Avenue Broadview IL 60153; Dear Mr. Cheshire: This is in response to your letter of January 26, 1977, asking fo confirmation of several interpretations of Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*.; You are correct that, as an equipment standard, Standard No. 10 applies only to replacement of equipment that was originally mounted on the vehicle to enable it to comply with the requirements of the standard. It does not apply to items not covered by the standard, but which are frequently provided as new vehicle options, such as fog lamps and cornerning (sic) lamps. Any item of lighting equipment not required is permissable (sic) to be installed, as you also noted, if it does not impair the effectiveness of the required lighting equipment (paragraph S4.1.3). Additional lighting equipment is otherwise subject to State regulation.; You also asked 'what would be the NHTSA's stand on products where SA standards do not exist, for example halogen headlights?' A halogen headlamp that does not comply with Standard No. 108 and is intended as a replacement headlamp may not be imported and sold for this use. On the other hand, halogen fog lamps may be imported and sold, subject to State regulations.; I hope this answers your questions. Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam5498OpenMr. John E. Getz Director, Mobile Products Engineering Ellis & Watts 4400 Glen Willow Lake Lane Batavia, Ohio 45103; Mr. John E. Getz Director Mobile Products Engineering Ellis & Watts 4400 Glen Willow Lake Lane Batavia Ohio 45103; "Dear Mr. Getz: This responds to your letter asking whether certai operations that your company performs on used trailers result in the trailers being considered 'newly manufactured' for purposes of the Federal motor vehicle safety standards. You stated that you sometimes change the finishing and equipment of a used trailer for a new application. As an example, you stated that you recently took a 10- year old trailer, stripped the inside, and refinished it as a mobile marketing facility. You also stated that in some cases you may cut a hole in the side and install a door for a specific application. In a telephone conversation with Dorothy Nakama of my staff, you indicated that you have also changed trailers by adding heating or air conditioning units, or making the trailer usable as an auditorium. In your letter, you asked whether the trailers would be considered 'newly manufactured' if the running gear, VIN and the basic trailer structure do not change, but the ownership does change. You asked this question in light of the fact that change of ownership is relevant under 49 CFR part 571.7(f) in determining whether a trailer manufactured from new and used components is considered newly manufactured. As discussed below, it is our opinion that the operations you describe do not result in the trailers being considered newly manufactured. By way of background information, the National Highway Traffic Safety Administration issues safety standards for new motor vehicles and new motor vehicle equipment. The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles or equipment meet all applicable standards. The following represents our opinion based on the facts provided in your letter. Section 49 CFR part 571.7(f) reads as follows: Combining new and used components in trailer manufacture. When new materials are used in the assembly of a trailer, the trailer will be considered newly manufactured for purposes of the safety standards , unless, at a minimum, the running gear assembly (axle(s), wheels, braking and suspension) is not new, and was taken from an existing trailer-- (1) Whose identity is continued in the reassembled vehicle with respect to the Vehicle Identification Number, and (2) That is owned or leased by the user of the reassembled vehicle. This section only applies when new and used materials are used in the 'assembly' of a trailer. It is our opinion that the operations that you describe, i.e., where the running gear, VIN and the basic trailer structure do not change, do not constitute trailer assembly. Therefore, this section, including its provision concerning transfer of ownership, does not apply. We consider your operations to be in the nature of repair or refurbishment of a used trailer, which does not result in the trailer being considered newly manufactured. I hope this information is helpful. If there are any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam2576OpenHonorable Warren G. Magnuson, Chairman, Committee on Commerce, Science, and Transportation, United States Senate, Washington, DC 20510; Honorable Warren G. Magnuson Chairman Committee on Commerce Science and Transportation United States Senate Washington DC 20510; Dear Mr. Chairman: This is in response to your letter of April 11, 1977, expressing you concern over a perceived pattern of delay in the implementation of the Federal motor vehicle safety and damageability standards. You expressed particular concern about the National Highway Traffic Safety Administration's (NHTSA) recent proposal to delay for one year the effective date for the second phase of requirements in the Part 581 bumper standard.; I am aware that there have been instances in the past when th effective dates of final rules have been delayed or when the final rules have been modified or rescinded. I do not intend to pass judgment on whether the actions of my predecessors in those particular instances should have been taken. However, I agree with your view that changes in the substantive requirements and effective dates of final rules can have undesirable effects and should be avoided if possible.; I believe that the most effective means of reducing the necessity fo changes in final rules is to ensure that each proposed rule is thoroughly examined prior to issuance in final form. Every significant issue should be explored and comments and data from all interested persons should be carefully analyzed. Where gaps in our knowledge appear, the information-gathering authority given the NHTSA should be utilized. For example, extensive use of that authority has been recently made in connection with rulemaking under Title V of the Motor Vehicle Information and Cost Savings Act, as amended, to establish average fuel economy standards for model year 1981-1984 passenger automobiles. By making more careful analyses and obtaining needed information, we can minimize the possibility that belatedly discovered information or circumstances will necessitate a change in our requirements or implementation schedules.; Our taking these steps does not, of course, mean that there will no continue to be some instances in which effective dates and substantive requirements are changed. We must be responsive to new information and changed circumstances to ensure that our requirements continue to meet all statutory criteria. There will still be problems not completely foreseen by the agency or the manufacturers. New concerns such as those relating to fuel economy and noise will arise. Finally, there may be a need to adjust our standards to accommodate changes in other types of motor vehicle standards.; As to the second phase of the bumper requirements, I am currentl reviewing the reasons for the proposal to delay, and the comments on the notice are being analyzed. The statute, under which Part 581 was promulgated, requires that interested persons be given an opportunity for oral presentation of comments prior to the issuance of any amendment to the bumper standard. Thus, my decision on the proposed amendment will be made following a public hearing which will be scheduled in the near future.; Sincerely, Joan B. Claybrook |
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.