NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam2573OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This responds to the Truck Body and Equipment Association's February 8 1977, petition for rulemaking to amend the definition of 'unloaded vehicle weight' and to add a new definition to 49 CFR Part 571.3 for 'special purpose vehicle.' The National Highway Traffic Safety Administration (NHTSA) denies your requested rulemaking.; Your petition requests an amendment of the term 'unloaded vehicl weight' similar to that proposed by Chrysler's December 20, 1976, petition. Both petitions recommend that, for purposes of barrier crash testing of certain vehicles, the unloaded vehicle weight be the lesser of the weight of a completed comparable model vehicle from which the particular vehicle is derived or 5,500 pounds. Further, you request an additional definition of 'special purpose vehicle' that would distinguish vehicles designed for a specific work function from other vehicles produced from the same chassis. We have determined that the effect of creating such a vehicle category as special purpose vehicle in conjunction with the establishment of arbitrary weights for vehicles when undergoing compliance testing would, in some situations, undermine the effectiveness of the motor vehicle safety standards. Vehicles falling into the category could, according to your suggested scheme, be tested at a weight which differs from their actual weight as equipped.; In the case of Standard No. 301, *Fuel System Integrity*, such a resul would possibly violate Congress' order in the 1974 Amendments to the National Traffic and Motor Vehicle Safety Act (Pub. L. 93-492) that the NHTSA not diminish the level of safety established at that time in the standard.; To allow certain vehicles to be tested at a weight which differs fro their actual weight, would permit the operation of vehicles which, as equipped, could fail the requirements of the standard.; You should note that the agency intends to proceed with the rulemakin to amend the definition of 'unloaded vehicle weight' as recommended in a petition from Chrysler dated November 29, 1976. This amendment will incorporate changes in the definition previously made by the NHTSA through interpretation.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2089OpenMr. Joe Steininger, Tiffin Metal Products, 450 Wall Street, Tiffin, OH 44883; Mr. Joe Steininger Tiffin Metal Products 450 Wall Street Tiffin OH 44883; Dear Mr. Steininger: This is in response to your request for an opinion on the applicabilit of Federal Motor Vehicle Safety Standard 205 to a road grader intended for use in highway construction.; The National Highway Traffic Safety Administration issues safet standards for 'motor vehicles.' Therefore, our regulations apply to a vehicle and its manufacturer only if the vehicle qualifies as a motor vehicle under the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. Section 102(3) of the Act defines motor vehicle as:; >>>any vehicle driven or drawn by mechanical power manufacture primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; Thus, a motor vehicle is a vehicle which the manufacturer expects wil use public highways as part of its intended function.; Tracked and other vehicles incapable of highway travel are not moto vehicles. In addition, vehicles intended and sold solely for off-road use (e.g. aircraft runway vehicles and underground mining vehicles) are not considered vehicles even if operationally capable of highway travel. They would, however, be considered motor vehicles if the manufacturer knew that a substantial proportion of his customers actually would use them on the highway.; Just as clearly, vehicles which use the highway on a necessary an recurring basis to move between work sites are motor vehicles. The primary function of some vehicles is of a mobile, work performing nature and as such their manufacturer contemplates a primary use of the highway. Mobile cranes, drill rigs, and towed equipment such as chippers and pull-type street sweepers are examples in this area. Even if the equipment uses highways infrequently, it is considered a motor vehicle. An exception to this is that occasional use of the highway in the immediate periphery of the work site, as is the case with some farm and construction equipment, would not by itself cause a finding that the vehicle is a motor vehicle. The motor vehicles described above generally qualify as trucks or trailers. As such they are subject to several of the motor vehicle safety standards, and the manufacturer must comply with other regulations in Chapter V of Title 49, code of Federal Regulations.; There are some vehicles which are excepted from the motor vehicl classification despite their use of the highway. Highway maintenance and construction equipment, lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles. This would appear to include road graders whose maximum speed does not exceed 20 miles per hour, if intended for use in highway construction.; From these guidelines you should be able to determine whether a piec of equipment qualifies as a motor vehicle.; Please write again if you are unable to make this determination. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1076OpenMr. R. J. Marini, State of New Jersey, Division of Motor Vehicles, 25 South Montgomery Street, Trenton, NJ 08666; Mr. R. J. Marini State of New Jersey Division of Motor Vehicles 25 South Montgomery Street Trenton NJ 08666; Dear Mr. Marini: This is in response to your letter of March 5, 1973, concerning th recently issued Federal odometer disclosure requirements.; Although we have not had the opportunity to review the revised Ne Jersey certificate of ownership, it appears that New Jersey is proceeding along lines that could make the certificate usable for purposes of compliance with our regulations. We are concerned, however, about the possibility of variance between State and Federal procedures.; The Federal regulation requires the transferor to state the mileage o the odometer at the time of transfer. In addition, if he knows the odometer reading to be wrong, he must so state by indicating that the actual mileage is unknown. Provision for a disclosure of odometer error is essential to the Federal regulation, and it is not clear to us that the New Jersey certificate provides for such a disclosure.; With respect to the older vehicles - those not subject to a revise certificate of ownership - the form attached to your letter will satisfy the Federal requirements. A disclosure statement of this type is required by our regulation to be made upon each transfer of a vehicle. I would hope that all dealers in New Jersey are receiving, and giving, such statements in each motor vehicle transaction.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4274OpenMr. Binichi Doi, NSK Representative Office, P. O. Box 1507, Ann Arbor, MI 48106; Mr. Binichi Doi NSK Representative Office P. O. Box 1507 Ann Arbor MI 48106; Dear Mr. Doi: Thank you for your letter of November 14, 1986, to Stephen Oesch of m staff concerning how our regulations would apply to a device intended to make it easier to reach the belt or latchplate of a safety belt system. I hope the following discussion answers your questions.; You enclosed a sketch with your letter that shows that the device woul be attached to the vehicle by the anchorage bolt for the upper torso portion of a lap/shoulder safety belt. You explained that the device called an 'arm' or 'belt reacher', is made of material which 'does not interfere with the general safety/comfort of passenger and is installed semi-rotationally around the shoulder-anchor point so that it can hold the tongue in a convenient position' for the occupant to reach the belt.; There are no safety standard that directly apply to the devic described in your letter. However, if the device is installed as an item of original equipment on a new vehicle, then the vehicle's safety belt system would have to continue to comply with all of the requirements of Standard No. 208. Thus, for example, if the device is installed on a vehicle that must comply with the comfort and convenience requirements, such as the retraction requirement of S7.4.5, with the device in place. Likewise, the safety belt anchorage would have to continue to comply with all of the performance requirements of Standard No. 210.; There is one further issue associated with the device shown in you letter that I want to address. The agency supports the use of equipment that will make safety belts easier and more comfortable to use. However, it is equally important that those devices not introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of that belt. You stated in your letter that the device is made of a material that makes it compliant so that it moves with the belt and does not interfere with the 'original protective function' of the safety belt. If you should implement the design depicted in your letter we encourage you to continue to make sure that the device will not introduce excessive slack in the belt.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1426OpenMr. Jim Lang, President, L and R Enterprises, P.O. Box 2201, Wichita Falls, TX 76307; Mr. Jim Lang President L and R Enterprises P.O. Box 2201 Wichita Falls TX 76307; Dear Mr. Lang: This responds to your February 15, 1974, letter asking whether you installation of spotlights through the left A-pillar of passenger cars is subject to Standards 201 and 216.; Standard 201 does not apply to the instrument panel area on th driver's side from the left door to a longitudinal plane 3- 1/4 inches to the right of the steering wheel. The left A pillar is within this excluded area.; Your drilling operation may affect roof strength and I have enclosed copy of Standard 216, our standard on roof crush resistance. Under the National traffic and Motor Vehicle Safety Act of 1966, it is the responsibility of the person who manufacturers or alters a vehicle to determine whether his vehicle meets the requirements.; Your business is subject to these requirements, however, only if yo qualify as an alterer of motor vehicles under 49 CFR 567.7, which is enclosed. The mounting of a spotlight by drilling the A-pillar is a 'non- readily attachable' alteration. Such an alteration would be subject to the S567.7 requirement only if you mount it 'before the first purchase of the vehicle in good faith for purposes other than resale.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4624OpenMr. Martin M. Ginsburg Proline Designs 25206 Loytan Street Torrance, CA 90505; Mr. Martin M. Ginsburg Proline Designs 25206 Loytan Street Torrance CA 90505; "Dear Mr. Ginsburg: This responds to your letters asking whethe Federal Motor Vehicle Safety Standard (FMVSS) No. 302, Flammability of Interior Materials (49 CFR /571.302), applies to the 'interior window coverings' that you manufacture for 'pick up truck shells.' In your letters, you briefly explain that the 'shell,' which is sold as an aftermarket product, 'is placed directly over the bed of a truck.' The answer to your question is no, Standard No. 302 does not apply to your product. I regret the delay in responding to your letter. By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not grant approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on our understanding of the facts provided in your letter. There are two factors which lead us to conclude that Standard No. 302 does not apply to your window coverings. First, you manufacture an aftermarket item of equipment--i.e., an accessory or addition to a motor vehicle sold to owners of used vehicles. Standard No. 302 regulates the flammability resistance of curtains and shades in new completed vehicles only. Second, even if the shell and its window coverings were installed on a new vehicle prior to the vehicle's first sale to a consumer, Standard No. 302 applies only to components in the 'occupant compartment air space' (S4), which the agency has indicated is the area in which persons are likely to use to ride. Assuming that we are correct in believing that people do not typically ride in the enclosed bed of the truck, we conclude that the area enclosed by the shell would not be an occupant compartment. This accords with the agency's February 15, 1983 letter to Mr. Nakaya in which NHTSA stated that, with regard to vans, the space to the rear of the rearmost seat was not part of the occupant compartment. Accordingly, since the window coverings in question are not located in the occupant compartment, we conclude that they are not subject to Standard No. 302. Nevertheless, there are two matters that you ought to consider when manufacturing your window coverings. First is the possibility of liability under State and common law if the coverings were to catch fire in a situation where a window covering meeting Standard No. 302's flammability resistance requirements would not have caught fire, or if the coverings burn much more rapidly than coverings meeting those requirements. Second is the possibility of a finding of a safety-related defect in your products. While Standard No. 302 does not directly apply to your product, you should be aware that the window coverings you manufacture are considered to be items of motor vehicle equipment. As the manufacturer of motor vehicle equipment, you are thereby subject to the provisions set forth in sections 151-159 of the Vehicle Safety Act concerning the recall and remedy of equipment with defects relating to motor vehicle safety. If you or this agency determined that your product had a defect relating to motor vehicle safety, you would have to notify all known purchasers of the defect and either repair your product so that the defect is removed, or replace the window coverings with an identical or reasonably equivalent product that does not contain a defect. Your letter did not indicate whether you also manufacture the truck shell to which you refer. If you are the shell manufacturer, and if your product contains glazing material, Standard No. 205 (49 CFR /571.205, Glazing Materials) directly applies to your product. Standard No. 205 is an equipment standard which sets performance requirements for glazing materials used in new and used motor vehicles and glazing materials sold as items of motor vehicle equipment, including glazing used in truck shells. The standard establishes both performance requirements, including those regulating the light transmittance and abrasion resistance of glazing, and labeling requirements applicable to the glazing used in your product. We note also that, since your description of the 'shell' was very brief, we were not certain whether the term 'shell' as you use it includes what our regulations refer to as a 'slide-in camper.' Under Standard No. 126, Truck-Camper Loading (49 CFR /571.126), a 'slide-in camper' is a structure having a roof, floor, and sides, designed for the purpose of providing shelter for persons and to be mounted on and removed from the cargo area of a truck by the user. (See, also, 49 CFR /575.103 for NHTSA's consumer information requirements for trucks that are capable of accommodating slide-in campers.) In light of the possibility that the structures to which you refer are slide-in campers, and that you might be the manufacturer of the campers, we would like to mention our regulations that apply to slide-in campers. Briefly, each slide-in camper must meet Standard No. 205 for any glazing materials used in the camper. In addition, Standard No. 126 requires each slide-in camper to be permanently labeled with information including its maximum loaded weight. This standard also requires each camper to be furnished with an owner's manual that includes information on total camper weight, proper matching of a truck and slide-in camper, appropriate methods of camper loading, and how to determine the camper's center of gravity (cg) and where the cg should be placed in the truck cargo area. All campers must also be certified in accordance with section 114 of the Vehicle Safety Act as conforming to all applicable Federal motor vehicle safety standards. Each camper manufacturer must submit certain information concerning its company pursuant to Part 566 of our regulations, Manufacturer Identification. However, Standard No. 302 does not apply to slide-in campers, even if the slide-in camper is installed on a new pickup truck. Finally, we must decline your request that we review 'California Health and Safety Code Standard No. 19' to inform you whether window coverings that meet the California standard can meet Standard No. 302. NHTSA determines whether a vehicle or item of motor vehicle equipment complies with an applicable safety standard by purchasing vehicles and equipment and testing them under strict conditions according to the procedures specified in the standards. Thus, we determine whether a product subject to our standards complies with those standards by assessing the actual performance of the product in our tests. Since your window coverings are not subject to Standard No. 302, they will not be part of our compliance testing. Further, even if the coverings were subject to Standard No. 302, we have already noted that it is the responsibility of the manufacturer of the motor vehicle or motor vehicle equipment--and not NHTSA--to ensure that its vehicles or equipment comply with applicable FMVSS's. I have enclosed copies of all of the safety standards and regulations mentioned above, and an information sheet explaining how you can obtain copies of NHTSA regulations for your future reference. I hope this information is helpful. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures"; |
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ID: aiam0667OpenMr. Harry O. Youngberg, Tiny's Tire Center, 10805 Pacific Avenue, Tacoma, WA 98444; Mr. Harry O. Youngberg Tiny's Tire Center 10805 Pacific Avenue Tacoma WA 98444; Dear Mr. Youngberg: Thank you for your recent letter regarding tire identification an recordkeeping, and your suggestions for promotion of safety on the highways.; As you know the Congress set forth the requirements for tir identification and recordkeeping as a part of the National Traffic and Motor Vehicle Safety Act of 1966, amended May 22, 1970. The Safety Act specifically places responsibility for tire identification and recordkeeping upon the manufacturer with the assistance of dealers and distributors. We believe Regulation Part 574 implements this mandate of the Congress in an effective and workable manner. Hopefully it will prove to be a protective measure to the great majority of conscientious industry members who are maintaining high safety standards in their products.; This Administration, by authority of the National Highway Safety Act o 1966, is also deeply involved in a program of traffic safety standards. Periodic Motor Vehicle Inspection is the first standard in the program. Details concerning the standard are contained in the Highway Safety Program Manual Volume I, copy enclosed.; Another standard in the program entitled 'Alcohol in Relation t Highway Safety' is described in the Highway Safety Program Manual Volume 8, copy enclosed. As you know, State and local enforcement plays a major role in the success of this type of program. We acknowledge, however, that much work at the Federal level is yet to be done in this area of safety.; Standardizing automotive switches and controls is related to acciden avoidance and is covered in the series-100 of Federal motor vehicle safety standards. Please note Standards No. 101 and No. 102 in the enclosed publication.; With regard to consumer information and protection, special attentio is being given to this subject by the White House's Office of Consumer Affairs. We are enclosing a pamphlet that contains an index of Federal publications on how to buy and use consumer products.; Your interest in consumer safety and protection is very muc appreciated.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1975OpenMs. Connie R. Gale, Chrysler Corporation, P.O. Box 1919, Detroit, MI 48231; Ms. Connie R. Gale Chrysler Corporation P.O. Box 1919 Detroit MI 48231; Dear Ms. Gale: This is in response to your letter of June 11, 1975, requesting a interpretation of Part 567 with respect to whether or not Chrysler should affix a certification label to an incomplete vehicle prior to shipping the vehicle to an outside vendor for body work.; It appears from your letter that there is some misunderstandin regarding the certification requirements applicable to manufacturers of incomplete vehicles. Section 567.4, to which you refer in your letter, is not applicable to vehicles manufactured in two or more stages. However, Section 567.5(c) provides that if an incomplete vehicle manufacturer assumes legal responsibility for all duties and liabilities imposed by the Act, as provided for in Section 568.7(a), then the incomplete vehicle manufacturer must ensure that a certification label is affixed to the final vehicle with the incomplete vehicle manufacturer's name after the words 'MANUFACTURED BY' or 'MFD BY'. The date to be included on this label must follow the words 'INCOMPLETE VEHICLE MANUFACTURED' or 'INC VEH MFD' and is the '[m]onth and year in which the original manufacturer of the incomplete vehicle performed his last manufacturing operation on the incomplete vehicle . . ..' (Section 567.5(a)(4)). The date as of which the manufacturer certifies that the vehicle conforms to applicable safety standards is any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture. (Section 567.5(a)(7)).; The regulations do not specify a date on which the certification labe must be affixed. However Section 114 of the Traffic Safety Act provides that the label must be on the vehicle at the time of its delivery by the manufacturer to the distributor or dealer.; We trust that the above explanation will provide you with the guidanc that you need. If you have any further questions, please let us know.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam3948OpenMr. M. Mizuguchi, Ashimori Industry Co., Ltd., 12, 4-chome Yokobori, Higashi-ku, Osaka, Japan; Mr. M. Mizuguchi Ashimori Industry Co. Ltd. 12 4-chome Yokobori Higashi-ku Osaka Japan; Dear Mr. Mizuguchi: Your letter of February 28, 1985, was forwarded to my office for reply You asked whether the webbing attached to a buckle you intend to use must meet the webbing width requirement of S4.2 of Standard No. 209, *Seat Belt Assemblies*. The webbing is enclosed in a plastic sheath. As explained below, the webbing must meet the width requirement of the standard.; S4.2 of Standard No. 209 provides that the 'width of the webbing in seat belt assembly shall be not less than 1.8 inches, except for portions that do not touch a 95th percentile adult male with the seat in any adjustment position and the seat back in the manufacturer's nominal design riding position when measured under the conditions prescribed in S5.1(a).' The purpose of S4.2 is to ensure that belt webbing which comes into contact with an occupant has a minimum width that spreads the load imposed by the belt in a crash. By requiring webbing to spread rather than concentrate the load, the belt width requirement helps minimize the possibility of webbing-caused injury.; In the case of your design, the webbing is enclosed in tightly-fitting plastic sheath. You state that the webbing/sheath combination can come into contact with an occupant. The sheath enclosed with your sample is made from an easily deformable plastic. Thus, when the crash loads are imposed by the belt, the sheath will deform and the crucial factor in concentrating the load on an occupant is the width of the belt. Since the webbing/sheath combination can contact and impose crash loads on an occupant, the agency concludes that the webbing must meet the minimum width requirement of S4.2.; If the webbing were encased in a reinforced sheath that did no appreciably deform under loading, the agency would consider both the width of the webbing and its encasing sheath in determining whether the requirement of S4.2 was met.; I have enclosed the sample of your product sent with your letter. I you have any further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam5465OpenSamson Helfgott, Esq. Helfgott & Karas, P.C. 60th Floor Empire State Building New York, NY 10118-6098 Re: Your Ref. No.: 12.065; Samson Helfgott Esq. Helfgott & Karas P.C. 60th Floor Empire State Building New York NY 10118-6098 Re: Your Ref. No.: 12.065; "Dear Mr. Helfgott: We have received your letter to John Womack, th former Acting Chief Counsel of this agency, responding to his letter to you of July 20, 1994. Thank you for enclosing a copy of his letter for ready reference. Our previous letter to you was without the benefit of the diagram of the Caine system which you have now enclosed. The system is intended to be placed 'along the side of trucks and other vehicles.' It consists of three red lamps mounted over three amber (yellow) ones, the array installed between the amber front side marker lamp and the red rear side marker lamp. In normal operation the amber lamps are used as 'running lights' but will be turned off when the red lamps are illuminated in a steady burning state upon application of the brake pedal. The three amber lamps will flash to indicate that the vehicle is turning. All six lamps will flash when the hazard indicator switch is on. If the turn signal is on and the driver's foot is on the brake pedal, the amber lamps will flash while the red ones illuminate in a steady burning state. At 32 candela, the turn signal lamps will be at a higher intensity than the running lamps which operate at 3 to 5 candela. These are within NHTSA specifications. You ask whether this system will be in violation of Standard No. 108. This office has corresponded with you on lighting matters on a number of occasions and you are well aware that supplementary lighting equipment is prohibited as original equipment only if it impairs the effectiveness of lighting equipment that is required by Standard No. 108. This determination is to be made by the manufacturer or dealer who installs the equipment and NHTSA will not question it unless it is clearly erroneous. Sincerely, Philip R. Recht Chief Counsel"; |
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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.