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: aiam4016OpenThe Honorable Malcolm Wallop, United States Senate, Washington, DC 20510; The Honorable Malcolm Wallop United States Senate Washington DC 20510; Dear Senator Wallop: Thank you for your letter to Secretary Dole requesting clarification o the regulations pertaining to school bus identification. Your letter has been referred to our agency for reply, since we administer the school bus regulations.; You explained that several of your constituents are concerned that ou regulations prohibit identifying nine-passenger vehicles that carry children to and from school as school buses. You suggested that school bus identification should be allowed as an added safety measure to alert other drivers to the nature of the vehicle.; I appreciate this opportunity to respond to your concerns. In brief our regulations do not prohibit States from identifying smaller school vehicles as 'school buses.' States have the discretion to choose to identify nine-passenger school vehicles as school buses if the States wish to include such a requirement in their highway safety programs.; We have two sets of regulations, issued under separate Acts o Congress, that apply to school buses. The first of these, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966, includes the motor vehicle safety standards applying to the manufacture and sale of new school buses. The second set of regulations, issued under the Highway Safety Act of 1966, provides guidelines to the States for their highway safety programs. One of these program standards provides recommended procedures for the identification of school vehicles.; Under the requirements of the Vehicle Safety Act, motor vehicl manufacturers must certify that their vehicles comply with all applicable motor vehicle safety standards. The applicability of our motor vehicle safety standards to a particular vehicle depends, in part, on the classification of that vehicle. Under Federal law, school vehicles carrying 10 or more passengers are 'school buses' which must meet our school bus safety standards. The demarcation between school vehicles carrying 10 or more passengers and those carrying fewer than 10 is thus pertinent for the purpose of determining the classification of a vehicle, and the applicability of our school bus safety standards. Nine- passenger van-type school vehicles are not considered 'school buses' under our regulations, but are classified as 'multipurpose passenger vehicles' (MPV's). While MPV's must be certified as meeting the safety standards for MPV's, they may also be voluntarily manufactured to meet the requirements for school buses as long as the vehicle continues to comply with our standards for MPV's.; I wish to emphasize that our safety standards for school buses ar performance standards which apply only to the manufacture and sale of new school buses. They do not govern the manner in which a school bus is identified or marked. Under the Highway Safety Act, we issued Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed), which contains recommendations for the identification, operation, and maintenance of school vehicles. However, the implementation of Program Standard No. 17 is a matter for the States to decide, and State law would determine the operational requirements, such as those for school bus identification, that school vehicles must meet.; I hope this information is helpful. Please feel free to contact thi agency if you have any further questions.; Sincerely, Diane K. Steed |
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ID: aiam4481OpenMr. Max J. Mizejewski Foreign Marketing Specialists, Inc. 14451 Chambers Rd., Suite 155 Tustin, CA 92680; Mr. Max J. Mizejewski Foreign Marketing Specialists Inc. 14451 Chambers Rd. Suite 155 Tustin CA 92680; "Dear Mr. Mizejewski: This is in response to your letter in which yo asked whether a product your company plans to import would be subject to any Federal motor vehicle safety standard (FMVSS). According to your letter, this product, which you refer to as a 'Roadreader,' attaches to the front of a motor vehicle and has two sensors which give a visual and audible alarm when the vehicle drifts off a road. You indicated that this product would be connected to the wiring related to the turn signals. You noted that this device does not affect vehicle functions such as acceleration, braking, lighting, or visibility. You further stated that if required, you would provide the device to NHTSA or another government agency for inspection. Section 103 of the National Traffic and Motor Vehicle Safety Act ('Safety Act') directs the National Highway Traffic Safety Administration (NHTSA) to establish safety standards for motor vehicles and motor vehicle equipment. Title 49 CFR Part 571 contains the safety standards promulgated by the agency. Although you stated that this device does not affect the electrical wiring related to the turn lights, I suggest you closely review Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (Copy enclosed). This safety standard applies to both motor vehicle equipment installed in new motor vehicles and replacement equipment sold in the aftermarket. While I cannot conclusively say that this standard is or is not applicable to your product based on the limited facts in your letter, this standard may apply to your product because the wiring for your device is connected to components (i.e., turn lights) subject to the standard. For instance, S4.5.11 requires that components including the turn signal lamps must be wired to flash. More generally, S4.1.3 forbids the installation of an additional piece of motor vehicle equipment that impairs the lighting equipment required by Standard No. 108. Therefore, a device such as yours is permissible as original vehicle equipment provided that it does not impair the effectiveness of the lighting equipment required by the standard. As for the sale of your product in the aftermarket for vehicles in use, Section 108 of the Safety Act prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a FMVSS. Since an importer is defined by the Safety Act as a manufacturer, you should assure that installation of your device does not render inoperative, in whole or in part, the turn signal lamp or any other item of motor vehicle equipment subject to Standard No. 108. As for your second question concerning inspection and approval of your product, you should be aware that NHTSA does not provide approvals of motor vehicles and motor vehicle equipment. Under Section 114 of the Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable safety standards. Further, as you noted, you would be responsible for recalling any safety-related defects which you or this agency finds in your product. You also should be aware that laws from particular States may apply to your device. Therefore, you may wish to contact the State and local transportation authorities in the areas where you intend to market your product. The American Association of Motor Vehicle Administrators (4600 Wilson Boulevard, Arlington, Va. 22203) may also be able to provide information about State laws concerning devices similar to your product. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam2583OpenMs. Lea Jenny, Administrator, Senate Transportation Committee, 431 Capitol Building, Salem, OR 97310; Ms. Lea Jenny Administrator Senate Transportation Committee 431 Capitol Building Salem OR 97310; Dear Ms. Jenny: Permit me to comment upon Oregon House Bill 2998 which I understand i to be considered by the Transportation Committee of the Oregon Senate on June 3, 1977.; The Bill would amend ORS 483.404 to require that headlamps on moto vehicles registered in Oregon meet the standards established for such under the National Traffic and Motor Vehicle Safety Act of 1966 or; >>>'...the United Nations Agreement concerning the Adoption of Approva and Reciprocal Recognition of Approval for Motor Vehicle Equipment and Parts, done at Geneva on 20 March 1958, as amended and adopted by the Canadian Standards Association (CSA Standard 106.2) or both.'<<<; Pursuant to 15 U.S.C. 1392 (a) [Section 103(a) of the National Traffi and Motor Vehicle Safety Act of 1966] Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* (49 CFR 571.108), has been established, effective January 1, 1972, as the Federal standard for headlamps both as original and replacement equipment on motor vehicles. Under 15 U.S.C. 1392(d); >>>'Whenever a Federal motor vehicle safety standard established unde this title is in effect, *no State* or political subdivision of a State *shall have any authority* either *to establish*, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment *any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard*.' [Emphasis added.]<<<; The United Nations Agreement, and this Agreement as amended by th Canadian Standards Association, permit the use of motor vehicle headlamps that are not of sealed beam construction and whose candlepower output may exceed 75,000, and do not require that they be mechanically aimable. Standard 108, on the other hand, requires that headlamps on passenger vehicles be of sealed beam construction, imposes a limit of 75,000 candlepower on all but one type of headlamp, and requires that all headlamps be mechanically aimable. Thus, the United Nations Agreement, and this Agreement as amended by the Canadian Standards Association, do not specify requirements for headlamps that are identical to those of Standard No. 108. This means that if House Bill 2998 is enacted in its present form the language that I quoted from it would, in our opinion, be preempted by 15 U.S.C. 1392(d), and of no legal effect. This means also that any person in Oregon manufacturing for sale, selling, offering for sale, introducing or delivering for introduction in interstate commerce, or importing into the United States a headlamp that did not conform to Standard No. 108, in reliance upon House Bill 2998 were it to be enacted, would be subject to civil penalties for apparent violations of 15 U.S.C. 1397(a) (1) (A) in an amount up to $800,000 (15 U.S.C. 1393 (a)), and to a restraining order (15 U.S.C. 1399(a)).; Section 1392(d) and the Act's preemptive effect have been invariabl upheld. (See *e.g. Chrysler Corp v. Malloy*, 294 F. Supp 524 (U.S.D.C. Vt. 1968), *Chrysler Corp v. Tofany*, 419 F.2d 499 (C.C.A. 2 1969)) We would also observe that the interpretation of the preemption language by this agency, as the administering agency, has been viewed by courts as 'of controlling weight.' (*Thorpe v. Housing Authority of Durham*, 393 U.S. 268 (1969) quoted with approval in *Chrysler Corp. v. Tofany, supra*, at 512.); If you have any questions, Taylor Vinson of this office will be glad t assist you (202-426-9511).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3950OpenMr. Charles E. Gillipsie, President, Salem Quality Equipment, Inc., 501 East 8th Street, Salem, VA 24153-6385; Mr. Charles E. Gillipsie President Salem Quality Equipment Inc. 501 East 8th Street Salem VA 24153-6385; Dear Mr. Gillipsie: This responds to your April 30, 1985 letter asking if your leasin company is allowed to occasionally rent 10- and 15-passenger vans to schools for special school activity trips. As Ms. Hom of my staff informed you in a telephone conversation on April 26, 1985, you are not prohibited by Federal statute or regulations from renting vans to schools on a one-time or very occasional basis.; The National Highway Traffic Safety Administration (NHTSA) has th authority under the National Traffic and Motor Vehicle Safety Act to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles. The parties directly affected by the Vehicle Safety Act are manufacturers of new school buses and persons selling new school buses. The Vehicle Safety Act prohibits those parties from selling new buses for use as school buses if those vehicles do not comply with the Federal school bus safety standards.; When Congress passed the 1974 amendments to the Vehicle Safety Act Congress adopted the following definition of a 'school bus': 'Schoolbus means a passenger motor vehicle which is designed to carry more than 10 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...' (Emphasis added.); Two basic considerations are relevant, therefore, to the Vehicle Safet Act's definition of a 'school bus' and the applicability of the Act's requirements to school bus sellers. The first is the vehicle's passenger capacity, and second, its intended use. If you buy a new 12- or 15-passenger van to rent to schools on a regular basis, that van would be a 'school bus,' since it would have the passenger capacity of a 'bus' and is 'likely to be significantly used' to carry school children. A dealer or distributor who sells you the new van would have to ensure that the van meets our school bus safety standards. Conversely, the less frequently a bus is used for school service, the less likely it is that its use is 'significant.' If you use your van to carry students on a very infrequent basis, as the case appears to be, then it would not be considered a 'school bus,' and the van would not have to meet the school bus safety standards.; In your letter, you referred to a Federal Register notice (40 FR 60033 December 31, 1975) that amended NHTSA's regulatory definition of a 'school bus' and discussed leasing arrangements. NHTSA's definition of a school bus covers buses 'sold or introduced in interstate commerce for purposes that include carrying students to and from school or related events.' The notice explained that NHTSA's definition includes buses 'introduced in interstate commerce' in order to account for those situations where buses are leased to schools for transporting students. You asked for clarification of this discussion.; The term 'introduction in interstate commerce' and the reference in th Federal Register notice to leasing arrangements addressed those situations where a new bus is leased by a manufacturer, distributor or dealer directly to a school or school district. In those situations, there is no sales transaction involved. When a new bus is leased to a school or school district directly from its manufacturer, distributor or dealer, the Vehicle Safety Act requires that the bus must comply with the school bus safety standards.; If you have further questions, do not hesitate to contact my office. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0583OpenMr. Robert M. Martin, Director of Central Services, City of Lynchburg, Box 60, Lynchburg, VA 24505; Mr. Robert M. Martin Director of Central Services City of Lynchburg Box 60 Lynchburg VA 24505; Dear Mr. Martin: This is in reply to your letters of December 20, 1971, and January 4 1972, concerning dump trucks recently purchased by the city of Lynchburg. You state that the trucks have a 24,000 GVW rating (rear axle 17,500 pounds, front axle 7,000 pounds), and were delivered with 8.25-20 tires, and ask whether there is a Federal requirement that restricts GVW rating according to tire size.; Beginning January 1, 1972, Federal regulations (49 CFR Parts 567, 568 have required all motor vehicle manufacturers to affix a label to their vehicles that contains both a gross vehicle weight rating (GVWR) and a gross axle weight rating for each axle (GAWR). These ratings are to be established by the manufacturer based upon all vehicle systems including tires. The requirements apply to the manufacturer, however, and not to the purchaser, if the vehicle is completed when he receives it. Nor is the regulation designed to regulate vehicles-in-use, which are subject to State regulation, but it is possible that some States may use these figures as a basis of determining whether vehicles are overloaded.; With reference to your particular trucks, it appears that they wer manufactured before January 1, 1972, and the regulations are therefore not applicable to them. However, according to the 1971 Tire and Rim Association Yearbook, which sets recommended load and inflation pressures for all vehicle tires, the 8.25-20 10-ply tire has a recommended maximum load, for dual usage, of 3,550 pounds at 75 psi. Assuming 4 tires on the rear axle, this would be equal to a load rating of 14,200 pounds, lower than the 17,500 pounds at which the axle is rated. For single usage, the tire is rated at 4,050 pounds at 85 psi. Assuming 2 tires on the front axle, the maximum load for the axle would be 8,100 pounds, which, unlike the rear axle, is greater than the load rated for the axles.; A copy of our Certification regulations, which contain the requirement for GVWR and GAWR is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4191OpenMr. J. Leon Conner, Manager, Long & Associates, Inc., P.O. Box 691, San Angelo, TX 76902; Mr. J. Leon Conner Manager Long & Associates Inc. P.O. Box 691 San Angelo TX 76902; Dear Mr. Conner: This responds to your letter seeking an interpretation of th requirements of 49 CFR S575.104, *Uniform Tire Quality Grading Standards* (UTQGS). Specifically, you asked whether this regulation requires the treadwear testing for a tire size to be conducted only with vehicles that specify the subject tire size either as the original equipment size or as one of the recommended optional tire sizes. The UTQGS does not contain any such provision.; The conditions and procedures to be followed in grading tires fo treadwear under the UTQGS are set forth in S575.104(e). That section specifies tire loading conditions and rim dimensional requirements for the vehicles used in the treadwear testing. However, it does *not* specify that the vehicles used in the treadwear testing can only be used to test tire sizes recommended as either original equipment or optional tires on the vehicle when new. Accordingly, persons testing tires to determine the treadwear grade may mount the tires on any vehicle, provided that the tire and vehicle satisfy all the requirements of S575.104(e), relating to tire construction, inflation pressure, size designation, vehicle loading, and wheel alignment.; You stated in your letter that the UTQGS compliance test procedures used by this agency for conducting its enforcement testing for treadwear grades, currently specify that tire sizes must be tested on vehicles that specify that size as either original equipment or recommended optional size. This specification may have been adopted after the following language appeared in a 1975 preamble to a final rule establishing the UTQGS:; >>>Several commenters suggested that the rule specify all vehicles in given convoy be identical, to reduce variations in projected treadlife. ... Variations in vehicle type, however, do not appear to produce significant variations in treadwear projections. Nevertheless, to minimize such variations, tires will be tested for compliance only on vehicles for which they are available as original equipment or recommended replacement options. 40 FR 23073, at 23076, May 28, 1975.<<<; As explained above, the UTQGS regulation does not specify that th vehicles used in treadwear testing can only be used to test tire sizes recommended as either original equipment or optional tires on the vehicle. The agency's compliance test procedures are only the methods the agency itself uses to determine the appropriate treadwear grade for a tire. Persons outside the agency are not bound by any testing conditions and methods not set forth in the UTQGS itself. Such persons may, therefore, conduct their own testing in a manner different from that specified in NHTSA's compliance test procedures, provided that their testing satisfies all requirements of S575.104(e).; You also stated that the use of different vehicles for treadwea testing of tires will produce measurably different treadwear grades for the tire, even when all the vehicle factors are closely and properly controlled. As quoted above, NHTSA concluded that vehicle-to-vehicle variations 'do not appear to produce significant variations in treadwear projections', when it examined this issue in 1975. However, the agency is currently re-examining the effects of vehicle-to- vehicle variations on treadwear projections, particularly with respect to front-wheel vs. rear-wheel drive vehicles and passenger cars vs. light trucks and vans. If you wish to provide some additional data on this subject, please forward the data to Mr. Barry Felrice, Associate Administrator for Rulemaking, at this address. We would be interested in analyzing whatever data form the basis for your belief that our 1975 conclusion was incorrect.; Please feel free to contact Steve Kratzke of my staff, at this addres or by telephone at (202) 366-2992, if you have any further questions about our UTQGS.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1523OpenMr. Charles R. Taylor, Taylor Farm Service, 'The Farm Center', Tremonton, UT 84337; Mr. Charles R. Taylor Taylor Farm Service 'The Farm Center' Tremonton UT 84337; Dear Mr. Taylor: This responds to your May 15, 1974, question whether Standard No. 121 *Air brake systems*, mandates the use of air brakes on 1-ton and larger trucks.; Standard No. 121 only applies to vehicles equipped with air brak systems. This means that the manufacturer is free to equip his products with whatever brake system he choses, (sic) but that if he choses (sic) an air brake system, it must comply with the Federal safety standard.; Yours truly, Richard B. dyson, Assistant Chief Counsel |
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ID: aiam5648OpenMs. Alison Vredenburgh Vice President Research and Development Error Analysis, Inc. Suite 205 5811 Amaya Drive La Mesa, CA 91942-4156; Ms. Alison Vredenburgh Vice President Research and Development Error Analysis Inc. Suite 205 5811 Amaya Drive La Mesa CA 91942-4156; "Dear Ms. Vredenburgh: This is in reply to your letter of September 18 1995, to Kenneth Hardie of this agency, with respect to the Motorcycle Conspicuity Enhancement System (the 'System') described in your letter. You understand 'that this system may only be used during daylight hours and may not affect the headlight', and you ask if there are any other regulations of which you should be aware. We understand that the System is still under development, and that the intent is to offer it both as original and aftermarket equipment. Two Systems will be tested, at a flash rate of 60 to 80 per minute, one at an intensity of 35,000 candlepower, and the other at 50,000 candlepower. One System will have three bulbs, and another, four. Each System will be activated when the headlamp is on. We note that motorcycle headlamps are wired to be activated when the ignition is on because many States require that headlamps be operating at all times. As you know, each motorcycle must be manufactured and certified to conform to all applicable Federal motor vehicle safety standards, including Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Standard No. 108 prescribes no requirements for supplemental equipment such as the System. However, additional lighting equipment may not be installed by the manufacturer or dealer before sale if the supplemental equipment impairs the effectiveness of lighting equipment required by Standard No. 108 (paragraph S5.1.3). You are therefore correct when you say that the System 'may not affect the headlamp.' One way in which the System could impair the effectiveness of the headlamp is if it continued to operate at a time when the headlamp is required to provide sufficient illumination of the roadway (as you recognize in your comment that 'the system may only be used during daylight hours'). You have not described the method by which the System will be deactivated. We believe that this should not be a manual operation, left to the discretion of the motorcycle operator. In establishing the specifications that allow optional installation of modulating headlamp systems for improving the conspicuity of motorcycles, this agency requires that they be equipped with a sensor that will deactivate the modulation when a certain low ambient light level is reached. Also, the modulation rate is regulated to prevent seizures in susceptible individuals. I enclose a copy of paragraph S5.6 of Standard No. 108 which discusses these light levels. The System must also not impair the effectiveness of the motorcycle's front turn signals. That is to say, it must not mask the signal or detract from its detectability by oncoming drivers. Whether this might occur will depend upon the color and brightness of the System and its proximity to the turn signal lamp. If a motorcycle manufacturer is satisfied that the installation of the System on its product would be permissible under S5.1.3, then it may certify that the motorcycle conforms to all applicable Federal motor vehicle safety standards. NHTSA will not question a determination of non-impairment unless it appears to be clearly erroneous. Satisfaction of Federal new vehicle requirements means that the System is acceptable for sale in the aftermarket under Federal regulations. However, supplementary lighting equipment, whether original or aftermarket, that is not specifically covered by Standard No. 108 remains subject to regulation by the States. We note that many States have vehicle equipment and use regulations regarding auxiliary amber flashing lamps, Many States also prohibit blue as a color for lamps, reserving it for police, fire, and emergency vehicles. We are unable to advise you on the specifics of State laws, and urge you to consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, Samuel J. Dubbin Chief Counsel"; |
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ID: aiam1157OpenMr. Donald McGuigan, Ford Motor Company, The American Road, Dearborn, Michigan 48121; Mr. Donald McGuigan Ford Motor Company The American Road Dearborn Michigan 48121; Dear Mr. McGuigan: This is to confirm your phone conversation of June 20, 1973, with Mik Peskoe of this office as to whether Motor Vehicle Safety Standard No. 110 requires passenger cars manufactured on or after July 1, 1973, to be equipped with tires that conform to Standard No. 109 as of July 1, 1973. the answer to this question is no. We will consider passenger cars to conform to Standard No. 110 if they are equipped with tires that conform to Standard No. 109 as of the date the tires are manufactured.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0869OpenMr. L. E. Maison, President, Monroe Standard, Inc., 118 Harding Way West, Galion, OH 44833; Mr. L. E. Maison President Monroe Standard Inc. 118 Harding Way West Galion OH 44833; Dear Mr. Maison: This is in reply to your letter of September 25, 1972, regarding th warning signal required under S5.1.5 of Motor Vehicle Safety Standard No. 121, Air Brake Systems.; Your reading of the second sentence of S5.1.5 is partially in error. I the visible low pressure warning signal is provided with a companion audible signal, the visible signal does not have to be within the driver's forward field of view. Under S5.1.5 a manufacturer may choose to install a visible signal within the driver's forward field of view, in which case he may omit the audible signal, or to install the signal outside the driver's forward field of view, in which case he must provide an audible signal. If a manufacturer provides a signal within the forward field of view, he may choose to provide an audible signal as well, but the section does not require him to do so.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.