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: aiam5462OpenMr. Bryan J Williams Director, International Operations Red Spot Paint & Varnish Co Inc. 1111 East Louisiana Street Evansville, IN 47711; Mr. Bryan J Williams Director International Operations Red Spot Paint & Varnish Co Inc. 1111 East Louisiana Street Evansville IN 47711; "FAX 812-467-2388 Dear Mr. Williams: This is in reply to your FAX o October 24, 1994, to Taylor Vinson of this Office requesting an interpretation regarding the relationship of Motor Vehicle Safety Standard No. 108 to an AAMVA list. Your company manufactures UV coatings for polycarbonate headlamp lenses. These 'provide abrasion resistance properties as well as protecting the plastic lens from the deleterious effects of outdoor exposure.' One of these coatings, UVT200, is used by Ford, General Motors, and Chrysler on headlamp lenses. However, 'UVT200 does not appear on the American Association of Motor Vehicle Administrators (AAMVA) 'Listing of Acceptable Plastics for Optical Lenses and Reflectors Used on Motor Vehicles.'' You inform us that some overseas headlamp manufacturers believe that appearance on the list is required by Federal law and is a prerequisite to certification. The question you ask is: Must a coating for plastic (polycarbonate) headlamp lenses appear on the AAMVA 'Listing . . .' in order to meet the requirements of FMVSS 108? The answer is no. Paragraph S5.1.2 of Standard No. 108 requires that plastic materials used in lenses (which include headlamp lenses) conform to SAE Recommended Practice J576c, Plastic Materials for Use in Optical Parts, Such as Lenses and Reflectors of Motor Vehicle Lighting Devices, May 1970. Under SAE J576c's outdoor exposure test, the luminous transmittance of the material must not change by more than 25% from its performance before the test. In appearance, the headlamp lens material must not show surface deterioration, crazing, dimensional changes, or delamination. Also, under paragraph S5.1.2(b), after the outdoor exposure test, the haze and surface luster of the material must not be greater than 30 percent haze, as measured by ASTM D-1003-61. Manufacturers have found that a coating is required for the plastics used in headlamp lenses to meet Standard No. 108's outdoor exposure requirements. However, neither SAE J576c or Standard No. 108 require the coating, let alone specify what coating is acceptable. The decision to coat, and the choice of coating, is that of the manufacturer in determining compliance with and certification to Standard No. 108. Therefore, the AAMVA list has no legal relationship to Standard No. 108 and it is immaterial to NHTSA whether the coating used is or is not on the AAMVA list. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam1702OpenHonorable Thomas F. Eagleton, United States Senate, Washington, DC 20510; Honorable Thomas F. Eagleton United States Senate Washington DC 20510; Dear Senator Eagleton: I am pleased to respond to your November 18, 1974, letter asking for clarification of the National Highway Traffic Safety Administration regulations that might affect disconnection of the ignition interlock and continuous buzzer in 1974- and 1975-model passenger cars. Chrysler Corporation has suggested that our regulations make disconnection more complicated than contemplated by the 'Motor Vehicle and Schoolbus Safety Amendments of 1974.'; The NHTSA has issued no regulations which govern the disconnection o any safety devices, including the ignition interlock and continuous buzzer. The only interlock or belt warning system requirements issued by the NHTSA specified installation of these safety features at the factory, and they are unrelated to disconnection of these devices by the dealer or any other person. The regulation in question (Standard No. 208, *Occupant crash protection*) specified installation of ignition interlocks until October 29, 1974, when that requirement was deleted in response to legislation enacted October 27, 1974. The regulation also specified installation of a 'continuous buzzer' until December 3, 1974, when that requirement was modified in response to the same legislation, after the new system had been proposed and had been commented on by interested persons. The new system conforms to the legislative prohibition on continuous buzzers, and it is optional until February 24, 1975, when it becomes mandatory.; The only restrictions on disconnection of safety devices are statutor and, as such, are not subject to modification by the NHTSA. Specifically, the Safety Act of 1966 prohibits sale of a vehicle which does not comply with applicable standards at the time of sale, and this effectively prohibits disconnection prior to sale (S108(a)(1)). Until the Safety Amendments of 1974 become effective on December 26, 1974, (sic); The new system consists of a continuous or flashing reminder light tha operates only during the 4- to 8-second period after the ignition is operated, and a continuous or intermittent audible warning signal which operates only during the 4- to 8-second period after the ignition is operated if the driver's lap belt is not in use. Either the old system or new system can be provided in passenger cars until February 24, 1975, when the law requires that the old system be discontinued.; Since the permissibility of disconnection is the subject of a la passed by Congress, our regulation does not address the issue. We have prepared a short discussion of the disconnection law and I enclose a copy that explains its effect. The NHTSA is, of course, not authorized to modify this law.; Thank you for your interest in motor vehicle safety. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1646OpenMr. Reno Laforest, After Sales Service Manager, Alouette Recreational Products, Ltd., 3700 St. Patrick Street, Montreal 205, Quebec, Canada; Mr. Reno Laforest After Sales Service Manager Alouette Recreational Products Ltd. 3700 St. Patrick Street Montreal 205 Quebec Canada; Dear Mr. Laforest: This is in reference to your defect notification campaign involvin 1973 and 1974 Alouette AX-125 motorcycles.; Since four different defects are involved, it has been found necessar to assign four different National Highway Traffic Safety Administration (NHTSA) identification numbers. Please refer to these numbers in all future correspondence concerning these campaigns.; Campaign numbers have been assigned as follows: >>>74-0178 - Rear brake pedal lever problem 74-0179 - Kick stand problem 74-0180 - Fuel leakage problem 74-0181 - Rear brake back plate holder lock nut problem<<< Although NHTSA will consider this matter as four campaigns, you ma still combine them in one owner notification letter and in communications with dealers.; The letter which you have sent to the owners of the vehicles which wer sold in the United States of America does not entirely meet the requirements of Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter does not contain the precise wording that is required by Part 577.4(b). Use of the words 'potential' and 'may' also imply that possibly a defect does not exist and should therefore be deleted from this sentence.; Your letter also fails to adequately evaluate the risk to traffi safety as required by Part 577.4(d). If vehicle crash can occur, the letter must state this. Your letter also does not make clear if the repairs will be performed free of charge and also does not give an estimate of the time needed to perform the labor necessary to correct the defect, as required by Part 577.4(e).; It is therefore necessary that you revise the owner notificatio letters and send a copy of the revised letter to this office and all known owners of the affected vehicles. Since you have stated that owners will receive a second notice at the time that parts have become available, the revised notification letter can be sent to owners at that time.; It is also necessary that you submit a Defect Report in accordance wit Part 573 of the regulations. The first Quarterly Reports, as required by Part 573.5, should be submitted before February 5, 1975, for the period ending December 31, 1974.; Copies of Part 573 and Part 577 are enclosed. If you desire furthe information, please contact Messrs. W. Reinhart or James Murray at this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam1463OpenMr. Ronald N. Granning, Vice President, Granning Suspensions, Inc., 3040 Wyoming, Dearborn, MI 48120; Mr. Ronald N. Granning Vice President Granning Suspensions Inc. 3040 Wyoming Dearborn MI 48120; Dear Mr. Granning: This responds to your March 21, 1974, request for an explanation o your certification responsibilities under the National Traffic and Motor Vehicle Safety Act of 1966 as a manufacturer of liftable and 'additional' axles which are installed on completed vehicles by an independent truck equipment dealer or, in some cases, by the vehicle manufacturer at the factory.; Your responsibilities under Standard 121, *Air brake systems*, ar largely the same as your responsibility for certification of the GAWR of an axle under 49 CFR Part 567, although somewhat more complicated. It is the responsibility of the vehicle manufacturer to certify compliance with Standard 121 (49 CFR Part 567.4), and if the completed vehicle is altered, it is the responsibility of the vehicle alterer (49 CFR Part 567.7). The addition of an axle will change the GAWR-GVWR and the brake performance of the altered vehicle and will require recertification by the dealer who undertakes alteration.; A dealer is normally not equipped to recertify an altered vehicle except on the basis of certification information supplied to him by the manufacturer of the component that is being added. A component manufacturer like yourself might issue a performance guaranty which relies on the information that is supplied to him by the manufacturer of the basic parts (e.g. brakes, axles in your case) and which is conditioned on the observance of certain limits on installation. For instance, the reservoir volume requirement (S5.1.2.1) might be exceeded if the liftable axle manufacturer did not qualify his information by stating that a certain tank volume must be provided to serve the air chambers on his axle system. Another qualification could refer to brake actuation and release time as complying only if it did not reduce the brake actuation and release timing of the vehicle as a whole. The effect of your axle on each of the requirements would have to be determined.; We do not require certification of the axle by you as its manufacturer. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2413OpenMr. Jim S. Green, Hux and Green, 204 W. North Street, Sikeston, MO 63801; Mr. Jim S. Green Hux and Green 204 W. North Street Sikeston MO 63801; Dear Mr. Green: This responds to your August 18, 1976, request to know th responsibilities of a manufacture of motor vehicles under the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. S 1381, *et seq*.). The information you request appears in Title 49 of the Code of Federal Regulations, and I enclose an information sheet which explains how this material may be obtained. I have also enclosed copies of several of the pertinent regulations.; Part 566, *Manufacturer Identification (49 CFR Part 566), specifie identification information which must be submitted to the NHTSA by manufacturers of vehicles and equipment regulated by our standards.; Part 567, *Certification* (49 CFR Part 567), specifies the content an location of the certification label or tag that must be attached to motor vehicles regulated by our standards. After a manufacturer has certified a motor vehicle, persons who alter it, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies (or minor finishing operations such as painting), and persons who change the vehicle's weight ratings, must be able to state that, as altered, the vehicle continues to comply. The requirements for such alterers appear at S 567.7 and S 568.8 of NHTSA regulations. An example of a significant alteration is mounting of a snowplow to a certified vehicle.; It is common practice in the truck industry to manufacture vehicles i two or more stages, often by the manufacture of a cab-chassis by a large volume manufacturer, followed by the installation of a body or piece of work-performing equipment by a smaller manufacturer in the locality where the truck is being purchased. To assign responsibilities for the certification of such 'multi-stage' vehicles, the NHTSA has issued Part 568, *Vehicles Manufactured in Two or More Stages* (49 CFR Part 568). The manufacturer of an 'incomplete vehicle' (such as a cab-chassis) must provide documentation to the intermediate and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. It is the responsibility of the final- stage manufacturer to affix the certification label discussed earlier, unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.; In some cases, the two- stage process involves mounting a used body o a new chassis or mounting a new body on an old chassis. It is only when a new chassis is involved that the NHTSA considers the operation to be the manufacture of a new vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2412OpenMr. J. H. Stitt, Frink Sno-Plows, 205 Webb Street, Clayton, NY 13624; Mr. J. H. Stitt Frink Sno-Plows 205 Webb Street Clayton NY 13624; Dear Mr. Stitt: This responds to your September 29, 1976, request to know th responsibilities of a manufacturer of motor vehicles under the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. S 1381, *et seq*.). The information you request appears in Title 49 of the Code of Federal Regulations, and I enclose an information sheet which explains how this material may be obtained. I have also enclosed copies of several of the pertinent regulations.; Part 566, *Manufacturer Identification (49 CFR Part 566), specifie identification information which must be submitted to the NHTSA by manufacturers of vehicles and equipment regulated by our standards.; Part 567, *Certification* (49 CFR Part 567), specifies the content an location of the certification label or tag that must be attached to motor vehicles regulated by our standards. After a manufacturer has certified a motor vehicle, persons who alter it, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies (or minor finishing operations such as painting), and persons who change the vehicle's weight ratings, must be able to state that, as altered, the vehicle continues to comply. The requirements for such alterers appear at S 567.7 and S 568.8 of NHTSA regulations. An example of a significant alteration is mounting of a snowplow to a certified vehicle.; It is common practice in the truck industry to manufacture vehicles i two or more stages, often by the manufacture of a cab-chassis by a large volume manufacturer, followed by the installation of a body or piece of work-performing equipment by a smaller manufacturer in the locality where the truck is being purchased. To assign responsibilities for the certification of such 'multi-stage' vehicles, the NHTSA has issued Part 568, *Vehicles Manufactured in Two or More Stages* (49 CFR Part 568). The manufacturer of an 'incomplete vehicle' (such as a cab-chassis) must provide documentation to the intermediate and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. It is the responsibility of the final- stage manufacturer to affix the certification label discussed earlier, unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.; In some cases, the two- stage process involves mounting a used body o a new chassis or mounting a new body on an old chassis. It is only when a new chassis is involved that the NHTSA considers the operation to be the manufacture of a new vehicle.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0556OpenMr. David J. Humphreys, RVI Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, N.W., Washington, DC 20006; Mr. David J. Humphreys RVI Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue N.W. Washington DC 20006; Dear Mr. Humphreys: This is in response to your letter of December 21, 1971, relating t the upcoming requirements for GVWR and GAWR on the vehicle label, under Part 567 of our regulations.; You discussed the difficulties some of your members have had i arriving at the proper values for gross axle weight ratings. To the extent that your discussion highlights the uncertainty that may in the past have existed with respect to the basic load-carrying capacity of vehicle components, it emphasizes the need for the regulation not only as a matter of information but also to ensure the proper design and selection of safety- related components. You asked specifically 'what NHTSA would consider to be the requisite test factors which should be utilized for determining wheel ratings.' Pending development of performance standards for wheels (or other components), we can only say that the ratings should reflect the manufacturer's own judgement as to the loads that the component can safely carry under the conditions expected to be encountered in use.; The diagrams that you enclosed setting forth basic weighing procedure for determining vehicle and axle loads appear to interpret the regulations correctly.; You mentioned the problem of a possible misunderstanding concerning th measurement of GAWR of a trailer and asked whether the tongue weight may be 'deducted from GVWR in arriving at what GAWR should be.' The answer is yes, since weight that is carried by the towing vehicle will not be carried by the trailer axle. We should add, however, that GAWR is a *rating* and therefore may be greater than the actual weight on the axle system when the vehicle is loaded to capacity.; Finally, you requested an 'extension of the effective date of the GAW and GVWR certification requirements to allow time to be sure the industry is advised of the procedure to follow.' This request is denied. On the basis of the information available to this agency, it has been determined that our procedures, and the lead time between issue and effective date of the regulations, have been fully adequate to allow affected manufacturers to prepare for compliance. Also, by a recent notice published in the Federal Register, we have allowed final-stage manufacturers using incomplete vehicles manufactured before January 1, 1972, for which the weight rating information has not been made available, to omit the GVWR and GAWR values from their labels.; Sincerely, Elwood T. Driver, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam0232OpenDavid Sugarman, Esq., 119 West 57th Street, New York, NY 10019; David Sugarman Esq. 119 West 57th Street New York NY 10019; Dear Mr. Sugarman: In response to your letter of April 16 I enclose copies of Federa Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, 'SAE Technical Reports Referenced in Federal Motor Vehicle Safety Standards'.; The answer to your first question is that Standard No. 108 require passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle 'as far forward as practicable', and one marker and one reflector, red in color, on each side of the vehicle, 'as far to the rear as practicable'(sic) Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two, was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverdi displayed at the recent New York show were amber and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standards applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.; In answer to your second question, Table III of Standard No. 10 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.; You have asked in your third question whether headlamps may be place in the grille. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.; Standard No. 107 does not specify a particular color for the horn rin and hub of the steering assembly but it does specify a maximum permissible value for specular glass.; Finally, other than Standard Nos. 205 (Glazing Materials) and 21 (Windshield Mounting) which all passenger cars must meet, there is no 'specific safety requirement as to the windshield' for convertibles, and there is no 'requirement as to a roll bar'.; Sincerely, Lawrence R. Schneider, Chief, Regulations Division |
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ID: aiam0230OpenDavid Sugarman, Esq., 119 West 57th Street, New York, New York 10019; David Sugarman Esq. 119 West 57th Street New York New York 10019; Dear Mr. Sugarman: In response to your letter of April 16 I enclose copies of Federa Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, 'SAE Technical Reports Referenced in Federal Motor Vehicle Safety Standards'.; The answer to your first question is that Standard No. 108 require passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle 'as far forward as practicable', and one marker and one reflector, red in color, on each side of the vehicle, 'as far to the rear as practicable'. Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverdi displayed at the recent New York show were amber and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standard applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.; In answer to your second question, Table III of Standard No. 10 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.; You have asked in your third question whether headlamps may be place in the grille. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.; Standard No. 107 does not specify a particular color for the horn rin and hub of the steering assembly but it does specify a maximum permissible value for specular glass.; Finally, other than Standard Nos. 205 (Glazing Materials) and 21 (windshield Mounting which all passenger cars must meet, there is no 'specific safety requirement as to the windshield' for convertibles, and there is no 'requirement as to a roll bar'.; Sincerely, Lawrence R. Schneider, Chief, Regulations Division |
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ID: aiam1746OpenMr. L. W. Steenbock, Designer, FWD Corporation, Clintonville, WI 54929; Mr. L. W. Steenbock Designer FWD Corporation Clintonville WI 54929; Dear Mr. Steenbock: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 316 - 1965 through 1973 FWD an Seagrave firetrucks. Possibility that the upper steering arm may crack and in some cases break in the mid-section of the steering arm resulting from excessive stresses due to power steering assist. This information was furnished in your letter of December 18, 1974.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74-0245*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject vehicle does not meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter does not conform to Part 577.4(b) due to inclusion of the word 'may' and because the defect is described as existing in the steering arm rather than the vehicle itself. In cases where a vehicle manufacturer is notifying owners of vehicles, the letter should state that the defect exists in the vehicle itself, even though it may be caused by only one specific part. If the defect is not present in every vehicle, this may be stated in an additional statement.; Your letter also does not evaluate the risk to traffic safety a required by Part 577.4(d). Furthermore, since it appears that the labor cost for performing the corrective action must be born by the owners, Part 577.4(e)(3) should have been followed. It is therefore necessary that an estimate of the labor time necessary for replacing the arm and recommendations as to where the necessary work can be done be given. Your instructions for replacement of the arm are also inadequate since they seem to be limited primarily to the visual inspection and do not outline the actual replacement procedure. It is therefore necessary that you send a revised notification letter to those owners who have not yet had their vehicles corrected. A copy of the revised letter should also be sent to this office.; We also wish to inform you that it is not necessary to submit a copy o every single notification letter that is mailed. When letters are identical, except for the address, only one sample copy need be submitted. The names and addresses of vehicle owners need only be submitted when specifically requested. A copy of Part 577 is enclosed. If you desire further information, please contact Messrs. W. Reinhart or James Murray of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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.