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
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ID: aiam5623OpenMr. John C. Golden Product Manager, Lighting & Electrical Federal Mogul Corporation P.O. Box 1966 Detroit, MI 48235; Mr. John C. Golden Product Manager Lighting & Electrical Federal Mogul Corporation P.O. Box 1966 Detroit MI 48235; "Dear Mr. Golden: This responds to your request for an interpretatio asking if, under NHTSA's requirements, your company may market a lighting device, called a 'Lightman,' for use on warning triangles. I apologize for the delay in responding. As explained below, the answer to your question is yes. However, since the Federal Highway Administration (FHWA) regulates use of warning triangles carried in commercial vehicles, that agency's regulations could also affect your product. You explain that the Lightman is a battery operated safety strobe device, which is in the shape of an equilateral triangle measuring 3 1/2 inches on each side. You would like to market the Lightman specifically for use on warning triangles, but are concerned about the minimum area requirements of Safety Standard No. 125, Warning Devices. You ask, 'Does the mounting of one of these devices...take away minimum reflective area such that it would render the warning triangles illegal or ineffective?' As you note, Standard No. 125 specifies requirements for the configuration of warning devices. Warning devices that are subject to Standard No. 125 must be certified as meeting those configuration requirements. As we understand the Lightman, it will be sold to motorists separately from the Standard No. 125 warning devices. However, we understand that you will market the Lightman as appropriate for use with previously-certified warning devices. There is a provision in our statute that regulates the modifications that motor vehicle manufacturers, dealers, distributors and repair businesses may make to certified vehicles and equipment. (See section 30122 of Title 49 U.S.C. 30101 et seq., copy enclosed.) However, this provision does not regulate the modifications that individuals make to their vehicles or items of equipment, such as warning triangles. Thus, under NHTSA's statute, an individual would not be precluded from placing the light on his or her equilateral triangle. As you note in your letter, the FHWA regulates use of warning devices with regard to commercial trucks, and should be contacted about your question. Responding to your request for a contact in FHWA, we suggest Mr. James Scapellato, Director, FHWA Office of Motor Carrier Research and Standards, at the following address and telephone number: 400 Seventh Street, S.W. Rm. 3107 Washington, DC 20590. Telephone: (202) 366-1790 We will be happy to forward your letter to Mr. Scapellato, if you would like us to do so. I hope this information is helpful. If you have any further questions about our regulations, please feel free to call Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure bcc: Mr. Larry Minor Office of Motor Carrier Research & Standards FHWA, Rm. 3107"; |
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ID: aiam4071OpenMr. D. Black, Director, U.S. Engineering, Alfa Romeo, Inc., 250 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. D. Black Director U.S. Engineering Alfa Romeo Inc. 250 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Black: This responds to your letter to Mr. Barry Felrice, our Associat Administrator for Rulemaking, requesting an interpretation of Part 541, *Federal Motor Vehicle Theft Prevention Standard*. You stated that you plan to begin production of a 1987 carline in March 1986. This particular carline has been selected as one that will be subject to the requirements of Part 541. However, Part 541 does not become effective until April 24, 1986. You stated your belief that the introduction of the 1987 vehicles in that carline before the effective date of Part 541 means that none of the 1987 vehicles in that carline will be required to comply with Part 541, but that the 1988 vehicles would be required to comply. Your belief is essentially correct.; As you noted, the effective date for Part 541 is April 24, 1986. Thi effective date means that Part 541 applies to all selected carlines beginning with the 1987 model year. However, the legislative history for Title VI of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2021 *et seq*.), which Title requires that Part 541 be promulgated, expressly states: 'The theft prevention standard cannot apply to a car in the middle of the model year.' H.R. Rep. No. 1087, 98th Cong., 2d Sess. at 11 (1984).; For the purposes of Title VI of the Cost Savings Act, NHTSA believe that the model year for a carline begins on the day on which a vehicle in that carline is introduced into commerce in the United States. In your case, since these cares are manufactured outside of the United States, the start of production does *not* constitute an introduction into commerce in the United States. The cars would be considered to be introduced into commerce in the United States when the first vehicle is *imported* into the customs territory of the United States.; Assuming that one of the 1987 vehicles in this carline is imported, an thus introduced into commerce, before April 24, 1986 (the effective date for Part 541), the 1987 model year for that carline would have begun prior to the effective date of the theft prevention standard. Obviously, the requirements of any standard do not apply before the effective date. Given the clear expression of Congressional intent that this theft prevention standard cannot apply to a carline in the middle of its model year, NHTSA concludes that a 1987 model year version of a carline introduced into commerce before the effective date of the theft prevention standard is not subject to the requirements of the theft prevention standard for the 1987 model year. It would, of course, be subject to the requirements for the 1988 model year.; If you have any further questions or need more information on thi subject, please do not hesitate to contact me.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4403OpenMr. Frederic M. Petler, Head, Administration, Government Relations Department, American Suzuki Motor Corporation, P.O. Box 1100, 3251 East Imperial Highway, Brea, CA 92622-1100; Mr. Frederic M. Petler Head Administration Government Relations Department American Suzuki Motor Corporation P.O. Box 1100 3251 East Imperial Highway Brea CA 92622-1100; Dear Mr. Petler: This letter responds to your letter of June 12, 1987, stating that you company wishes to add the following additional language to the Part 567 certification label:; >>>'This vehicle equipped for 800 lb./360 kg payload. See owner' manual for additional information.'<<<; You further state your understanding that NHTSA has permitte manufacturers to put information on the certification label beyond what Part 567 requires. You include two samples ('A' and 'B') representing certification labels, showing alternative locations on the label for your statement. The sample you designate as 'A' shows your statement just above the required vehicle identification number, and just below the statement that your vehicle complies with all applicable Federal motor vehicle safety standards. The sample you designate as 'B' shows your statement just below all of the information S567.4 requires a manufacturer to put on the certification label. You ask which sample the agency would find acceptable.; You are correct that the agency has permitted manufacturers to includ information on the certification label beyond that which Part 567 requires. Where NHTSA has acquiesced in this practice, the additional information appeared after that required under S567.4(g). Sample B shows the placement of your additional statement after the required Part 567 information. NHTSA finds that Sample B is acceptable so long as your label otherwise complies with Part 567.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2361OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co. Inc., P.O. Box 50, 100 W. Alondra Blvd. #Gardena, Calif. 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 100 W. Alondra Blvd. #Gardena Calif. 90247; Dear Mr. Gill: This is in reply to your letter of July 16,1976, asking for interpretation of S6.1 of Motor Vehicle standards No. 122, *Motorcycle Brake Systems*.; S6 requires the performance requirements of S5 to be met under certai specified conditions. One of these, S6.1, states that the test weight is unloaded vehicle weight plus 200 pounds. You have stated that some Honda motor cycles with limited engine displacement are equipped to carry the driver only and that the recommended vehicles load limit is less than 200 pounds. You have requested an interpretation that will allow Honda to perform tests for Standard No. 122 at unloaded vehicle weight plus 1500 pounds.; There is no requirements that tests be conducted at any specifie weight, only that the performance requirements of Standard No. 122 will be met when the test weight is unloaded vehicle weight plus 150 pounds. Thus Honda may test at unloaded vehicle weight plus 150 pounds and certify compliance with Standard No. 122 as long as it is reasonably certain, (through extrapolation of test results for example) that the vehicle will comply if tested by NHTSA under the condition imposed by S6.1.; I do not know if this interpretation is responsive to your concern. I Honda believes that the 200 pound test condition is impracticable for small motorcycles it may wish to submit a petition for rulemaking to amend S6.1.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam3734OpenMr. M. Iwase, Manager, Technical Administration Department, Koito Manufacturing Co., Ltd., Shizuoka Works, 500, Kitawaki, Shimuzu-shi, Shizuoka-ken, 424, Japan; Mr. M. Iwase Manager Technical Administration Department Koito Manufacturing Co. Ltd. Shizuoka Works 500 Kitawaki Shimuzu-shi Shizuoka-ken 424 Japan; Dear Mr. Iwase: This is in reply to your letter of June 22, 1983, to Mr. Medlin of thi agency asking for an interpretation of the recent amendment to Motor Vehicle Safety Standard No. 108 allowing use of replaceable bulb headlamp systems.; Regarding plastic lens materials, you have asked the limits o luminance transmittance loss and presence of haze after outdoor exposure test. These values are those specified by the referenced SAE standard, J576c.; You have also asked whether an accelerated weathering test i acceptable, such as ASTM E 838. Our reply is that you are free to conduct any accelerated weathering test you deem appropriate to support certification of compliance to Standard No. 108. We have not adopted any such test and will perform our compliance tests according to the 3-year test in SAE J576c.; Regarding the structural configuration of headlamps, you have aske about methods that may be acceptable to joining the lens and reflector, such as glue or welding. Standard No. 108 specifies no method for joining components, and any method is acceptable which results in an indivisible lens-reflector unit. Use of clips to supplement glue is permissible but use of clips alone would not result in an indivisible lens-reflector assembly. There is no objection to use of an additional rubber boot behind the reflector and bulb in the manner depicted in your letter. Drain holes, etc. may be provided as long as the headlamp complies with all the requirements of Standard No. 108. We shall publish in the near future a clearer indication of the headlamp terminal arrangement, as well as the dimensional specifications of the connector to the terminals of the bulb socket. We do not understand your request about the specific dimension and shape of each terminal 'blade' as the length, thickness, and width are already specified in the amendment (Figure 3-3). You have asked also whether the wattage values of 65 for the upper beam and 45 for the lower beam are maximum or nominal values. These values are maximum values.; Finally, concerning patent matters, you have asked whether certai aspects of the bulb and socket assembly are the subjects of patent claims. Ford has indicated in a letter of March 2, 1983, that, 'To facilitate compliance with the standard by all who wish to make or use replaceable bulb headlamps or their components, Ford Motor Company offers to grant royalty-free non-exclusive licenses to all manufacturers of motor vehicles, headlamps, or headlamp components that request such licenses, under U.S. patents and U.S. patent applications which claim these inventions to the extent that their use is needed to employ the proposed optional headlamp system.' If you have further questions on this issue you should write to Ford Motor Company.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5343OpenMr. Chris Barr Chris Barr Construction Co. 16409 S. E. Division Suite 216 Portland, Oregon 97236; Mr. Chris Barr Chris Barr Construction Co. 16409 S. E. Division Suite 216 Portland Oregon 97236; "Dear Mr. Barr: This responds to your letter of December 29, 1993 asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to your lighting device. You have requested confidential treatment of the matter but, in a telephone conversation of March 16, 1994, with Taylor Vinson of this office, you agreed to our practice in these matters to delete from the publicly available copy of this letter all information that would identify you, while disclosing the information necessary to render you an opinion. You plan to create 'signs, logos, emblems, accents, etc.' which will be constructed of 'sheet metal cut-outs of logos/company names,' which 'would be applied to large trucks and trailers'. The color of the LEDs would 'correspond to the safety color assigned to the panel of attachment (rear/red, side/amber- yellow)'. You note that LEDs provide a low level of illumination, for example, '100 LEDs would produce only 15 candelas of light.' You believe the ideal height is 2 feet to 3 feet. You have asked for an interpretation that this would not be prohibited under S5.1.3 of Standard No. 108. Paragraph S5.1.3 allows the installation on a new motor vehicle (i.e., one that has not been delivered to its first purchaser for purposes other than resale) of motor vehicle equipment provided that it does not impair the effectiveness of the lighting equipment required by Standard No. 108. For trailers or trucks whose overall width is 80 inches or more, the required side lighting equipment consists of amber and red side marker lamps, trailers of this width are also required to have conspicuity striping of red/white segments (which is not required for narrower trailers) applied near the lower horizontal edge. We interpret impairment as something that interferes with the function of the required equipment. The function of marker lamps and conspicuity taping is to alert drivers of other vehicles to the presence of a large vehicle in the roadway. We believe your device would not detract from this function since it also serves to call attention to the presence of a large vehicle. When equipment of this nature is not prohibited under Federal law, its permissibility must be determined under the laws of the States where the vehicle is operated. We are unable to advise you on State laws, and suggest that you consult for an opinion the American Association of Motor Vehicle Administrators, 4600 Wilson Blvd., Arlington, Va. 22203. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2089OpenMr. Joe Steininger, Tiffin Metal Products, 450 Wall Street, Tiffin, OH 44883; Mr. Joe Steininger Tiffin Metal Products 450 Wall Street Tiffin OH 44883; Dear Mr. Steininger: This is in response to your request for an opinion on the applicabilit of Federal Motor Vehicle Safety Standard 205 to a road grader intended for use in highway construction.; The National Highway Traffic Safety Administration issues safet standards for 'motor vehicles.' Therefore, our regulations apply to a vehicle and its manufacturer only if the vehicle qualifies as a motor vehicle under the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. Section 102(3) of the Act defines motor vehicle as:; >>>any vehicle driven or drawn by mechanical power manufacture primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; Thus, a motor vehicle is a vehicle which the manufacturer expects wil use public highways as part of its intended function.; Tracked and other vehicles incapable of highway travel are not moto vehicles. In addition, vehicles intended and sold solely for off-road use (e.g. aircraft runway vehicles and underground mining vehicles) are not considered vehicles even if operationally capable of highway travel. They would, however, be considered motor vehicles if the manufacturer knew that a substantial proportion of his customers actually would use them on the highway.; Just as clearly, vehicles which use the highway on a necessary an recurring basis to move between work sites are motor vehicles. The primary function of some vehicles is of a mobile, work performing nature and as such their manufacturer contemplates a primary use of the highway. Mobile cranes, drill rigs, and towed equipment such as chippers and pull-type street sweepers are examples in this area. Even if the equipment uses highways infrequently, it is considered a motor vehicle. An exception to this is that occasional use of the highway in the immediate periphery of the work site, as is the case with some farm and construction equipment, would not by itself cause a finding that the vehicle is a motor vehicle. The motor vehicles described above generally qualify as trucks or trailers. As such they are subject to several of the motor vehicle safety standards, and the manufacturer must comply with other regulations in Chapter V of Title 49, code of Federal Regulations.; There are some vehicles which are excepted from the motor vehicl classification despite their use of the highway. Highway maintenance and construction equipment, lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles. This would appear to include road graders whose maximum speed does not exceed 20 miles per hour, if intended for use in highway construction.; From these guidelines you should be able to determine whether a piec of equipment qualifies as a motor vehicle.; Please write again if you are unable to make this determination. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1981OpenHonorable Robert Taft, Jr., United States Senate, Washington, DC 20510; Honorable Robert Taft Jr. United States Senate Washington DC 20510; Dear Senator Taft: This is in further response to your letter of July 1, 1975, forwardin correspondence from Mr. R. H. Lawrence concerning the National Highway Traffic Safety Administration's (NHTSA) Tire Identification and Record Keeping regulation.; By Act of Congress (Public Law 91-265), the National Traffic and Moto Vehicle Safety Act was amended in 1970 to require manufacturers and retreaders of tires to maintain the names and addresses of first purchasers so that owners of defective tires may be notified of any defect. The legislative history of this amendment makes it clear that the Congress recognized the need for regulations in the area. Earlier joint attempts by manufacturers and the National Highway Traffic Safety Administration to notify purchasers of defective tires produced inadequate results even in cases where the manufacturer offered to replace the defective tires free of charge. The poor results were attributable to the fact that owners could not be directly notified of the defect.; The magnitude of the problem which the regulation seeks to alleviate i clear. Since the inception of the program in 1966 through 1973, there have been 1,427,670 tires recalled in 88 separate defect recall campaigns. In 1973 alone, there were 116,743 tires recalled in 11 defect recall campaigns.; With regard to the effectiveness of the recordkeeping regulation, ou records indicate the percentage of tires being recorded is increasing, and should continue to increase when additional enforcement action is taken against manufacturers and dealers who do not comply with the regulation. Of course, what is most needed to make the regulation effective is the voluntary cooperation of retreaders and dealers in recording, reporting and maintaining the required information.; While this regulation indisputably places an added responsibility o retailers, we also believe that the burden is neither onerous nor unjustified in view of the danger to the consumer. NHTSA has continually attempted to improve and simplify the procedures for the registration of tires, the most recent example being the Universal Tire Registration Format issued on June 3, 1974. I have enclosed a copy for your information.; For these reasons, we are convinced that the requirement that dealer record the name and address of tire purchasers at the time of sale is reasonable and appropriate.; Mr. Lawrence also suggested that it is inappropriate to require tire to be graded on the basis of mileage, because different drivers may obtain different total mileages from identical tires. He appears to have misunderstood the meaning of the treadwear grades established by the Uniform Tire Quality Grading Standards. That regulation, issued pursuant to Section 203 of the National Traffic and Motor Vehicle Safety Act of 1966, requires new tires to be graded in each of the following performance areas: treadwear, traction, and temperature resistance. The treadwear grade is based on the mileage which a tire can be expected to attain when tested on a specified course under controlled conditions and driving procedures. This grade is not designed to predict the actual mileage a consumer will obtain from a tire, because that mileage depends on many environmental factors, including the difference in driving styles to which Mr. Lawrence has referred. It is designed to permit a prospective tire purchaser to compare the performance of competing tires. For this reason, the treadwear grade is expressed as a percentage (of a nominal 30,000 miles), rather than as a mileage. For your convenience, I have enclosed a copy of the regulation.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam2409OpenMr. Jack B. Schiff, 230 South Bemiston Avenue, Clayton, St. Louis, MO 63105; Mr. Jack B. Schiff 230 South Bemiston Avenue Clayton St. Louis MO 63105; Dear Mr. Schiff: This is to acknowledge receipt of your letter of October 8, 1976 concerning odometer statements issued by auction companies.; As we have indicated in previous letters to you, the statement 'n mileage guarantee' does not conform to section 580.6 of title 49, Code of Federal Regulations, the disclosure form. Therefore, any transferor of a motor vehicle who gives such a statement to his buyer is in violation of the Motor Vehicle Information and Cost Savings Act. This applies equally to all transferors of ownership in motor vehicles, including individuals, dealers, distributors, and auction companies.; At first glance, the odometer disclosure statement issued by Floy Hauhe Auto Auction appears to be in violation of the Federal law because it clearly states that mileage is not guaranteed. However, upon closer inspection, such is not necessarily the case. You will note that their statement says 'warranty and mileage are not guaranteed to be good or correct on any car purchased *thru* this auction.' (Emphasis added) Additionally, it says that 'this sale is solely a transaction between the buying and selling dealer.' This language changes the facts significantly. The vehicle appears not to be as you state in your letter, purchased 'from' the auction company. It was instead purchased *through* the auction, and Floyd Hauhe was not, apparently, a tranferor (sic) of ownership in a motor vehicle as defined in Part 580.3 of title 49.; The responsibilities of an auctioneer with regard to the Federa odometer law vary depending upon the capacity in which he is operating. If the auctioneer is conducting business with both the buyer and seller present, the seller is required to disclose the mileage to the buyer at the time of sale and the auctioneer is essentially a by-stander as far as the Federal requirements are concerned. If the auctioneer buys a vehicle, then auctions it, he becomes the transferor and must disclose the mileage. In this case, the auctioneer would not be permitted to state that mileage was not guaranteed. If the auctioneer is acting as consignee for a seller who is not present and who may have delivered the vehicle from hundreds of miles away, he will have to obtain some assurance from the seller concerning the mileage on the vehicle at the time it left the owner's premises before a disclosure is made. As owner, the seller is ultimately responsible for the disclosure statement, but he may have to rely on his driver or the auctioneer to make out the statement at the auction.; It is unclear from the Floyd Hauhe Auto Auction statement as to th capacity in which they are operating. The language on the fact of the statement appears to indicate that they are not tranferors (sic) and thus are not responsible for issuing odometer statements. If however, they are requested to do so by absent sellers, their form is in violation of the Act because it does not provide the transferor's name, address or signature, and because it states that mileage is not guaranteed.; I hope that this information clarifies your questions. If you have an further questions, please do not hesitate to write.; Sincerely, John Womack Assistant Chief Counsel |
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ID: aiam5011OpenThe Honorable Phil Gramm United States Senator 2323 Bryan Street, #1500 Dallas, TX 75201; The Honorable Phil Gramm United States Senator 2323 Bryan Street #1500 Dallas TX 75201; Dear Senator Gramm: This responds to your Memorandum attachin correspondence from your constituent Stephen Newmark of Tarrant County. Mr. Newmark, Vice-President of Lonestar Classics, Inc., states that his company 'has requested an exemption' from this agency 'for the purposes of manufacturing kit cars,' and asks your help 'in determining whether our exemption will be granted or whether the National Highway Traffic Safety Administration (NHTSA) requires further information.' He also states that 'the timing of NHTSA's response is critical to our moving ahead.' Mr. Newmark FAXED the Administrator on May 5, 1992, about the possibility of obtaining an exemption, and followed up with a telephone call to the Office of Chief Counsel on May 15. As we understand it from that conversation, the business plan intended by Lonestar is to sell and deliver a certain number of unassembled components to purchasers who will complete the assembly of the vehicle by providing the engine, drive train, and suspension. We informed Mr. Newmark orally that, given these facts, Lonestar is not considered to be a 'manufacturer' of motor vehicles under the National Traffic and Motor Vehicle Safety Act. Because of this, Lonestar is not required to ensure the compliance of the completed vehicle with the Federal motor vehicle safety standards, and, hence, no exemption is required for it to implement its business plan. We informed Mr. Newmark of your interest in his behalf, and that our response to you would also serve as a reply to his FAX of the 5th to the Administrator. For this reason we are providing him a copy of this letter. Sincerely, Frederick H. Grubbe Enclosure: Constituent's Correspondence cc: Washington Office; |
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.