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: aiam5513OpenThe Honorable Tillie K. Fowler Member, U.S. House of Representatives 4452 Hendricks Avenue Jacksonville, FL 32207; The Honorable Tillie K. Fowler Member U.S. House of Representatives 4452 Hendricks Avenue Jacksonville FL 32207; "Your Reference: 95-0167-J Dear Congresswoman Fowler: Thank you fo your letter on behalf of your constituent, Mr. Dail Taylor of St. Augustine, Florida. Mr. Taylor requested assistance, stating that his company would have to stop manufacturing passenger motor vehicles if the vehicles must meet the Federal Motor Vehicle Safety Standards (FMVSSs). I appreciate the concerns of Mr. Taylor as a small businessman and offer the following information. In order to protect motorists and their passengers, a Federal statute requires the National Highway Traffic Safety Administration to issue FMVSSs regulating motor vehicles and motor vehicle equipment. Mr. Taylor's company, Goodlife Motor Company, wrote to NHTSA asking whether their 'super golf cars' were motor vehicles and therefore subject to the FMVSSs. NHTSA's Chief Counsel responded by letter that the answer was 'yes'. We were informed that the 'super golf cars' are intended for use on public roads. NHTSA has two criteria for determining whether a vehicle that regularly uses the public roads is considered to be a 'motor vehicle.' A vehicle is not a motor vehicle if it meets both of the following criteria: the vehicle has an abnormal configuration distinguishing it from other vehicles, and the vehicle cannot attain speeds over 20 miles per hour (mph). The 'super golf cars' do not meet either criterion. We have determined that because the vehicles resemble passenger cars, they do not have an abnormal configuration. As to speed, we note that the top speed of the vehicles, 29 mph, is approximately the speed at which NHTSA conducts crash tests to see whether vehicles meet certain safety standards. It is also a speed at which vehicle occupants can readily suffer serious or even fatal injuries in a crash. We note further that older adults are more susceptible than younger adults to injury in motor vehicle crashes. This is particularly important since we understand that one of the primary expected uses of the 'super golf car' is in retirement communities. As motor vehicles, the 'super golf cars' must meet the FMVSS. As the president of a small business, Mr. Taylor has a number of compliance options. First, he can comply with the current safety standards. I appreciate that the costs of compliance would be significant. Second, Mr. Taylor may petition NHTSA to initiate rulemaking to amend the current safety standards to accommodate any special compliance problems that a small car might experience. NHTSA has authority to establish different levels of requirements for vehicles of different sizes. However, it lacks the authority to vary the stringency of requirements based on the size of a vehicle manufacturer. Third, NHTSA has authority to grant temporary exemptions to small manufacturers. Mr. Taylor may petition for a temporary exemption from one or more of the safety standards. However, as we explained to Mr. Taylor, temporary exemptions are primarily granted as an interim measure to give small manufacturers a chance to come into compliance. Further, the exemptions are typically given for only a select number of the standards applicable to an exempted vehicle. Across-the-board exemptions from all standards have not been granted. Mr. Taylor may himself prepare and submit any petition. We have enclosed copies of our regulations regarding petitions for rulemaking and petitions for exemption. If Mr. Taylor has any questions or needs further information on how to proceed under any of the three options discussed above, we will gladly provide assistance. Please ask him to contact Taylor Vinson at (202)366-2992. Sincerely, Carol Stroebel, Director Intergovernmental Affairs Enclosures"; |
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ID: aiam4566OpenMr. David W. Raney Environmental Activities Manager Saab-Scania of America, Inc. Saab Drive P. O. Box 697 Orange, CT 06477; Mr. David W. Raney Environmental Activities Manager Saab-Scania of America Inc. Saab Drive P. O. Box 697 Orange CT 06477; "Dear Mr. Raney: Thank you for your letter requesting ou interpretation of 49 CFR Parts 541, Federal Motor Vehicle Theft Prevention Standard, and 543, Exemption from Theft Prevention Standard. I apologize for the delay in this response. You asked two questions. Your first question concerned the scope of the exemptions granted under Part 543. You noted that the Saab 9000 car line has been determined to be a high theft car line. Accordingly, Part 541 requires that both the original equipment and the replacement major parts for the Saab 9000 be marked with certain information. Your letter states that your company marked both the original equipment and replacement major parts for the Saab 9000 in the 1987 and 1988 model years. For the 1989 model year, the Saab 9000 was granted an exemption from the parts marking requirements of Part 541, pursuant to the provisions of Part 543. Your company understands that this exemption means that the original equipment parts on the Saab 9000 are no longer required to be marked. However, the replacement parts for the Saab 9000 that are produced in 1989 and thereafter pose a more difficult problem. On the one hand, Saab could consider these parts as replacement parts for the 1989 models, which would mean these parts are exempted from the parts marking requirement. On the other hand, these parts could also be considered as replacement parts for the 1987 and 1988 Saab 9000 line, which would mean the parts have to be marked because no exemption applies for such parts. The answer to your question is that once a high theft line is granted a Part 543 exemption in whole from the parts marking requirements of Part 541, as the Saab 9000 was, the replacement parts for that line are also exempted from the parts marking requirements even if those parts can be used as replacement parts for the high theft line during model years for which no exemption applies. NHTSA addressed this issue in the preamble to the September 8, 1987 final rule establishing Part 543 (52 FR 33821), as follows: Section 602(d)(2)(A) of Title VI (of the Motor Vehicle Information and Cost Savings Act) states that the vehicle theft prevention standard can not require 'identification of any part which is not designed as a replacement for a major part required to be identified under such standard.' (Emphasis added.) As long as a manufacturer is producing a car line under an exemption granted in whole, there is no requirement to identify major parts otherwise subject to the theft standard, therefore, NHTSA can not require marking replacement parts. 52 FR 33828. Applying this reasoning to your company's situation, Saab was free to discontinue marking both the original equipment and replacement major parts for the Saab 9000 as soon as the Part 543 exemption took effect, provided that Saab actually installed the antitheft device described in its petition as original equipment on 1989 Saab 9000 vehicles. Your second question asked whether the manufacturer of a high theft car lines that has been granted an exemption from the parts marking requirements, pursuant to Part 543, may discontinue the installation of the antitheft device and resume parts marking in some future model year. We addressed this issue in detail in a May 4, 1988 letter to Ms. Deborah Bakker, a copy of which is enclosed for your information. A manufacturer of a high theft line that has received an exemption under Part 543 is required to either install the antitheft device as standard equipment on every vehicle in that line produced during a model year or to mark all original equipment and replacement major parts for that line produced during the model year. As long as Saab marked all of the original equipment and replacement parts produced in a model year for the Saab 9000, your company is free to stop installing the antitheft device on those cars. If you have any further questions or need additional information on this subject, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam5492OpenMr. Scott E. Peters Director, Regulations & Compliance U.S. Electricar 5355 Skylane Boulevard Santa Rosa, CA 95403; Mr. Scott E. Peters Director Regulations & Compliance U.S. Electricar 5355 Skylane Boulevard Santa Rosa CA 95403; "Dear Mr. Peters: This responds to your letter to me in which you aske whether Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire selection and rims (49 CFR 571.110), applies to your Electricar sedan. You explained that your Electricar sedan (Electricar), a converted Geo Prizm, is being built under NHTSA Exemption No. 92-3 for low-emission vehicles. You stated that the Electricar's speed and endurance limitations are substantially below those of internal combustion-powered vehicles. You further stated that it is your understanding that 'the purpose of Standard No. 110, S4.4.2 (I assume you meant paragraph S4.2.2, since there is no S4.4.2 in the standard) is to ensure against tire failure due to prolonged operation at speeds in the range of 75 mph or higher.' Thus, you interpret FMVSS No. 110 as not applying to the Electricar or other electric passenger cars 'in which it is physically impossible to operate at high speeds for an extended duration.' You asked this agency, therefore, to review paragraph S4.2.2 and provide you our opinion as to its applicability to your Electricar. As discussed below, the requirements of S4.2.2 are applicable to electric passenger cars. By way of background information, the National Highway Traffic Safety Administration issues safety standards for motor vehicles and motor vehicle equipment. The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable safety standards. Federal Motor Vehicle Safety Standard No. 110 specifies requirements for tire selection to prevent overloading. Section S2 of the standard provides that the standard applies to passenger cars. S4.2 of the standard specifies the following tire load limits: S4.2.1 The vehicle maximum load on the tire shall not be greater than the applicable maximum load rating as marked on the sidewall of the tire. S4.2.2 The vehicle normal load on the tire shall not be greater than the test load used in the high speed performance test specified in S5.5 of section 571.109 of that tire. The test load used in the high speed performance test specified in S5.5 of Standard No. 109 is 88 percent of the tire's maximum load rating as marked on the tire sidewall. With respect to your question whether S4.2.2 applies to electric passenger cars, the answer is yes. That section applies on its face to all passenger cars, and does not include an exception for electric passenger cars. Your understanding that the purpose of S4.2.2 is limited to ensuring against tire failure due to prolonged operation at speeds in the range of 75 mph or higher is incorrect. The reference in that requirement to Standard No. 109's high speed performance test is for the sole purpose of specifying a load and not to indicate that the requirement is limited to high speed operation. As indicated above, Standard No. 110 seeks to ensure that tires are not overloaded. One way Standard No. 110 does this is by requiring in S4.2.1 that the vehicle maximum load on the tire not exceed the maximum load rating of the tire. Another way Standard No. 110 does this is by limiting the vehicle normal load on the tire, so that the tire will have some reserve load carrying capacity available to handle safely cargo and other kinds of added loading the car may experience. S4.2.2 does this by limiting the normal load on a tire to 88 percent of the tire's maximum load rating, which ensures that 12 percent of the tire's load rating will be available to bear cargo and other added loads. I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam5488OpenMr. Scott E. Peters Director, Regulations & Compliance U.S. Electricar 5355 Skylane Boulevard Santa Rosa, CA 95403; Mr. Scott E. Peters Director Regulations & Compliance U.S. Electricar 5355 Skylane Boulevard Santa Rosa CA 95403; "Dear Mr. Peters: This responds to your letter to me in which you aske whether Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire selection and rims (49 CFR 571.110), applies to your Electricar sedan. You explained that your Electricar sedan (Electricar), a converted Geo Prizm, is being built under NHTSA Exemption No. 92-3 for low-emission vehicles. You stated that the Electricar's speed and endurance limitations are substantially below those of internal combustion-powered vehicles. You further stated that it is your understanding that 'the purpose of Standard No. 110, S4.4.2 (I assume you meant paragraph S4.2.2, since there is no S4.4.2 in the standard) is to ensure against tire failure due to prolonged operation at speeds in the range of 75 mph or higher.' Thus, you interpret FMVSS No. 110 as not applying to the Electricar or other electric passenger cars 'in which it is physically impossible to operate at high speeds for an extended duration.' You asked this agency, therefore, to review paragraph S4.2.2 and provide you our opinion as to its applicability to your Electricar. As discussed below, the requirements of S4.2.2 are applicable to electric passenger cars. By way of background information, the National Highway Traffic Safety Administration issues safety standards for motor vehicles and motor vehicle equipment. The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable safety standards. Federal Motor Vehicle Safety Standard No. 110 specifies requirements for tire selection to prevent overloading. Section S2 of the standard provides that the standard applies to passenger cars. S4.2 of the standard specifies the following tire load limits: S4.2.1 The vehicle maximum load on the tire shall not be greater than the applicable maximum load rating as marked on the sidewall of the tire. S4.2.2 The vehicle normal load on the tire shall not be greater than the test load used in the high speed performance test specified in S5.5 of section 571.109 of that tire. The test load used in the high speed performance test specified in S5.5 of Standard No. 109 is 88 percent of the tire's maximum load rating as marked on the tire sidewall. With respect to your question whether S4.2.2 applies to electric passenger cars, the answer is yes. That section applies on its face to all passenger cars, and does not include an exception for electric passenger cars. Your understanding that the purpose of S4.2.2 is limited to ensuring against tire failure due to prolonged operation at speeds in the range of 75 mph or higher is incorrect. The reference in that requirement to Standard No. 109's high speed performance test is for the sole purpose of specifying a load and not to indicate that the requirement is limited to high speed operation. As indicated above, Standard No. 110 seeks to ensure that tires are not overloaded. One way Standard No. 110 does this is by requiring in S4.2.1 that the vehicle maximum load on the tire not exceed the maximum load rating of the tire. Another way Standard No. 110 does this is by limiting the vehicle normal load on the tire, so that the tire will have some reserve load carrying capacity available to handle safely cargo and other kinds of added loading the car may experience. S4.2.2 does this by limiting the normal load on a tire to 88 percent of the tire's maximum load rating, which ensures that 12 percent of the tire's load rating will be available to bear cargo and other added loads. I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam2566OpenWilliam R. Scott, Esq., Messrs. Allen & Korkowski & Associates, P. O. Box 337, Rantoul, IL 61866; William R. Scott Esq. Messrs. Allen & Korkowski & Associates P. O. Box 337 Rantoul IL 61866; Dear Mr. Scott: This is in reply to your letter of March 3, 1977, to Mr. Oates of thi office asking whether your client, a manufacturer of motorcycle accessories, is subject to requirements imposed by 49 CFR Parts 573, 576, and 577 and 15 U.S.C. 1402.; For your reference I am enclosing a copy of a new Part 577 whic becomes effective June 28, 1977, that implements Part B of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1411 *et seq*.) effective December 27, 1974. These new sections have superseded Section 1402, to which you referred. Since you apparently are unaware of these changes I am also enclosing a copy of the amended Act.; Because your client manufactures motor vehicle equipment other tha original equipment (*i.e*. accessories) its products appear to be 'replacement equipment' as defined by 15 U.S.C. 1419(2)(B). Since Parts 573 and 576 apply only to motor vehicle manufacturers and not to equipment manufacturers you are correct in your conclusion that these regulations are inapplicable to your client. We have proposed, however, that Part 573 be amended to apply to manufacturers of replacement equipment although no action has yet been taken on the proposal. I include a copy of that proposal.; You also asked about the applicability of Section 577.4 which you foun to be 'silent about the duty of manufacturers of motor vehicle equipment'. The Part 577 that you referenced reflects the statutory scheme that was in effect until December 27, 1974, under which a manufacturer of motor vehicle equipment (as contrasted with a vehicle manufacturer who also produced equipment) was not required to notify purchasers of safety-related defects or noncompliances which it, the manufacturer, had discovered. The equipment manufacturer's obligation to notify arose only upon determination of the existence of a safety-related defect or noncompliance by the NHTSA Administrator and in that event Section 577.5 requires the equipment manufacturer to follow the provisions of Section 577.4. The new statutory scheme of 15 U.S.C. 1411 *et seq*., as reflected in revised Section 577.5, now extends the notification and remedy obligation to safety-related defects and noncompliances discovered by manufacturers of replacement equipment.; Finally, you have asked if there is no duty to retain records how ca an equipment manufacturer 'observe the requirements of Part 577.4.' I assume what you mean is how can it notify 'the first purchaser (where known). . .and any subsequent purchaser to whom a warranty on such. . . item of equipment has been transferred'. The actual obligation of a manufacturer of replacement equipment today, however, is that established by 15 U.S.C. 1413(c)(3)(A), in effect since December 27, 1974, and it is to notify 'the most recent purchaser known to the manufacturer' (See also new Section 577.7(a)(2)(ii)(A). Congress appears to have recognized that manufacturers of small and less expensive items of motor vehicle equipment generally may not keep records of ultimate purchasers when it authorized our agency to issue a public notice when the public interest requires it (15 U.S.C. 1413(c)(3)(B)). Since there is no obligation for a manufacturer to know the names of its purchasers, NHTSA will accept in good faith an equipment manufacturer's statement as to the extent of its knowledge of its most recent purchasers. Under proposed Section 573.7(c) your client, as a manufacturer of motor vehicle equipment, would be required to maintain certain records including a list of the names and addresses of the 'most recent purchasers known to the manufacturer'. Such a list would probably at a minimum comprise distributors of the product, might also include the dealers of the distributors, and possibly in some instances the ultimate purchaser. But it is not a requirement that steps be taken to know and list the names and addresses of all ultimate purchasers.; If you have further questions after reviewing this letter and it enclosures I will be happy to answer them for you.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam5407OpenMr. Walter Lavis 2467 Rt. 10 Bldg. 3 Apt. 7B Morris Plains, NJ 07950; Mr. Walter Lavis 2467 Rt. 10 Bldg. 3 Apt. 7B Morris Plains NJ 07950; "Dear Mr. Lavis: We have received your letter of June 6, 1994, wit respect to your 'Saf-T-Flec' reflectors. You say that you have been informed by a NHTSA representative that 'using the standard DOT approved reflector tape would allow the use of my reflector for the trucking industry.' Judging from the red, white, and amber samples you have enclosed, your 'reflectors' appear to be retroreflective tape which adheres to a semicircular aluminum base and is intended for vertical mounting on the side and back of vehicles. Several potential customers have asked whether your concept was 'DOT approved', and you have asked for a reply. The Department of Transportation has no authority to 'approve' items of motor vehicle equipment. We advise inquirers whether manufacture or use of any particular item of equipment is prohibited or permitted under the Federal motor vehicle safety standards and associated regulations. However, if an item is deemed permissible, this must not be represented as 'approval' by DOT. Your letter is somewhat unclear as to the intended use and market for Saf-T- Flec. The fact that you have enclosed a highlighted copy of S5.1.1.4 leads us to believe that one application you envision for Saf-T-Flec is as a substitute for original equipment side reflex reflectors. This substitution is permitted if the reflective material conforms to Federal Specification L-S- 300 (September 7, 1965) and, as used on the vehicle, meets the performance standards of SAE Standard J594f Reflex Reflectors, January 1977. Accordingly, if your red and amber samples meet these two requirements, they may be used as the side front, intermediate, and rear reflex reflectors that Tables I and III require on trucks and trailers. However, Standard No. 108 does not allow sheeting material to be used on the rear of vehicles in lieu of reflex reflectors. What if your reflectors do not meet the two specifications listed above? In this instance, they may be used as supplementary side reflectors to the reflectors that are required by Standard No. 108, and you may employ amber devices for this use as well as red and white. As supplementary equipment, they are subject to the Federal restriction only that they not impair the effectiveness of the required reflex reflectors. We do not believe that additional reflectors would have this effect. Supplementary lighting equipment such as additional reflectors is subject to the laws of the individual states. We are not able to advise you as to their acceptability under state laws. The American Association of Motor Vehicle Administrators (AAMVA) provides opinions on state law. AAMVA's address is 4600 Wilson Blvd., Arlington, Va. 22203. As you may know, S5.7 of Standard No. 108 requires red and white retroreflective material to be applied to the side and rear of large trailers that have been manufactured since November 30, 1993 (those whose overall width is 80 inches or more and whose GVWR is more than 10,000 pounds). This material may be retroreflective sheeting or reflectors. If sheeting is used, it must meet the photometric specifications of Figure 29. If reflectors are used, they must conform to SAE J594f, and provide specified minimum millicandela/lux at specified light entrance angles. Your initial question indicates that you may be interested in marketing Saf-T-Flec for use as a substitute for the conspicuity materials that conform to Standard No. 108. Manufacturers of conspicuity sheeting certify it with the material in a flat vertical plane (as evidenced by the DOT-C2 marking on your white sample). We have reservations whether the curved red and white Saf-T-Flec devices could meet the photometric specifications of Figure 29, for sheeting, or J594f and the millicandela/lux specifications of S5.7.2.1(b) or (c) for reflectors. Amber is not one of the specified colors for conspicuity treatment, and could not be used as a substitute. I hope that this answers your questions. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3233OpenMr. Dick Pilch, P.O. Box 1311, Puyallup, Washington 98371; Mr. Dick Pilch P.O. Box 1311 Puyallup Washington 98371; Dear Mr. Pilch: This responds to your February 7, 1980 letter to the Department o Transportation, in which you complained about the failure of a tire on your truck. Specifically, you stated that the tires on the front axle of your truck were overloaded by 570 pounds each, and that no non-radial tire is currently manufactured which would not have been overloaded if used on this front axle.; If the tires which were overloaded came as original equipment on th truck, the manufacturer of the truck violated Federal Motor Vehicle Safety Standard No. 120 (49 CFR 571.120). Paragraph S5.1.2 of Standard No. 120 requires the sum of the maximum load ratings of the tires fitted to any axle to be at least equal to the gross axle weight rating of that particular axle. This requirement is applicable to all trucks manufactured on or after September 1, 1976. If your truck was manufactured after that date, please send ne the name of the manufacturer as well as the information provided by the manufacturer specifying the appropriate tire sizes to be used on the truck. The information concerning appropriate tire sizes will appear on a label on the door latch post on the driver's side of the truck. If the manufacturer has violated Standard No. 120, appropriate steps will be taken by the agency.; You also stated that certain radial tires would have met th load-carrying requirements for your truck, but that you would not use radial tires because of erratic wear patterns. For your Information, I have enclosed a booklet published by the Rubber Manufacturers Association setting forth information on the care and service of radial and non-radial truck tires. On page 11 of this booklet there is a description of the irregular wear to which you refer, as well as instructions on how to prevent irregular wear from lessening the overall mileage the tire will give you. Hence, if you wish to use radial tires on your truck, there is no reason to expect them to perform unsatisfactory.; More significant, however, is the misunderstanding you have i suggesting that no bias ply tire is manufactured which would not have been overloaded on your truck. Such a tire is now manufactured and has been manufactured for at least the past 20 years. On page 30 of the enclosed booklet, you will find a table showing the load-carrying capacity of bias ply tire sizes mounted on 15 degrees drop center rims. The tire size mounted on your truck, the 11-22.5, does indeed have a maximum load of 5,430 pounds if it is a load range F tire. However, a load range G tire of the same size has a maximum load of 6,040 pounds, and would not overload if used on your truck. This is the tire you should probably use on the front axle.; I am sorry to hear of your accident and hope that you have recovere from your injuries. Your complaint about the failure of the Uniroyal Delta tire has been recorded, and the agency will be alert to other indications of problems with this tire. To date, however, we do not have sufficient data indicating a safety problem to open a formal investigation.; I want to thank you for taking the time to express your concern abou motor vehicle safety. It is only through the efforts of concerned citizens such as yourself that we can ensure maximum safety for all users of the highway. If you have any further questions or concerns about this matter or any other aspect of highway safety, please do not hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2141OpenInterps. file, Parts 575.104(d)(1)(ii) and 575.6; Interps. file Parts 575.104(d)(1)(ii) and 575.6; Office visit by Pat Raher, Hogan and Hartson I received an office visit on December 8, 1975, from Mr. Raher of Hoga and Hartson (representing Mercedes-Benz). He showed me a sample information sheet of the type that Mercedes proposes to use to indicate the quality grades of tires with which its vehicles are equipped. We discussed the vehicle manufacturer's information requirement of the Uniform Tire Quality Grading Standards, and I indicated that a formal interpretation would follow our receipt of his letter, which is en route.; Mark I. Schwimmer, Attorney- Advisor |
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ID: aiam2142OpenInterps. file, Parts 575.104(d)(1)(ii) and 575.6; Interps. file Parts 575.104(d)(1)(ii) and 575.6; Office visit by Pat Raher, Hogan and Hartson I received an office visit on December 8, 1975, from Mr. Raher of Hoga and Hartson (representing Mercedes-Benz). He showed me a sample information sheet of the type that Mercedes proposes to use to indicate the quality grades of tires with which its vehicles are equipped. We discussed the vehicle manufacturer's information requirement of the Uniform Tire Quality Grading Standards, and I indicated that a formal interpretation would follow our receipt of his letter, which is en route.; Mark I. Schwimmer, Attorney- Advisor |
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ID: aiam1705OpenMr. Murray Balmages, RSM Co., 602 Main Street, Gwynne Bldg., P.O. Box 1997, Cincinnati, Ohio 45201; Mr. Murray Balmages RSM Co. 602 Main Street Gwynne Bldg. P.O. Box 1997 Cincinnati Ohio 45201; Dear Mr. Balmages: #In reply to your letter of October 31, 1974, we d not have specifications for polyester tire cord. Our requirements for tires are directed only to the performance of manufactured tires, and do not deal with specifications for tire cord. #Yours truly, Richard B. Dyson, Acting Chief Counsel; |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.