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: aiam5146OpenMr. A. L. Bragg Laboratory Manager Truck-Lite Co., Inc. 310 East Elmwood Ave. Falconer, NY 14733; Mr. A. L. Bragg Laboratory Manager Truck-Lite Co. Inc. 310 East Elmwood Ave. Falconer NY 14733; Dear Mr. Bragg: We have received your letter of February 22, 1993, t Paul Jackson Rice, the former Chief Counsel of this agency, with respect to his letter of December 30, 1992, to Stanley Electric Co. Ltd. In your opinion, the letter, which interpreted Safety Standard No. 108 as it applies to light- emitting diodes (LEDs), raises certain problems. You are correct that NHTSA equates individual LEDs with lighted sections. Currently, this is the only way in which NHTSA can relate LEDs to Standard No. 108, a standard based upon lamps with incandescent light sources. For this reason, NHTSA has begun to consider possible amendments to Standard No. 108 that would recognize, as the SAE has done with J1889, the advent of lamps with LED light sources. Should NHTSA then publish a notice of proposed rulemaking on this subject, we would welcome your further comments. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1806OpenMr. Tatsuo Kato,Staff, Safety,Nissan Motor Co., Ltd.,P.O. Box 1606,Englewood Cliffs, New Jersey 07632; Mr. Tatsuo Kato Staff Safety Nissan Motor Co. Ltd. P.O. Box 1606 Englewood Cliffs New Jersey 07632; Dear Mr. Kato:#This responds to your December 18, 1974, Questio whether the test procedure in S7.11.2.1 of Standard No. 105-75, *Hydraulic brake systems*, that specifies 'Accelerate immediately...After each stop' can be interpreted to permit a maximum rate of acceleration to the initial test speed of 60 mph. You also ask whether, in the case of a vehicle incapable of attaining 60 mph, the S5.1 requirement that it be tested 'at the highest speed attainable in the time or distance interval specified' can also be interpreted to permit a maximum rate of acceleration.#Both of these specifications permit acceleration at maximum speed. As in the case of any performance requirement, when a test procedure is not specified, a manufacturer must only 'exercise due care' to assure himself that each of his vehicles meets the requirement, by selecting a reasonable test procedure to demonstrate compliance. In fact the NHTSA has consistently started that, even when a test procedure is started, a manufacturer may use a different procedure, so long as it is calculated, in the exercise of due care, to demonstrate that the vehicle would comply if tested in accordance with the procedure.#Because the NHTSA has chosen not to specify an acceleration rate in S7.11.2.1 for fade tests, the manufacturer may reasonably choose the maximum or near maximum acceleration rate which ensures the greatest cooling effect in the brake assembly. This interpretation is also true for vehicles which are unable to attain 60 mph and must therefore reach their 'highest speed' under S5.1 prior to braking.#Therefore, in both cases cited, you may interpret the procedures to permit acceleration at 'maximum rate' as specified in S7.11.3.1.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2729OpenMaj. Gen. James A. Richardson III, 4551 LaSalle Avenue, Alexandria, VA 22304; Maj. Gen. James A. Richardson III 4551 LaSalle Avenue Alexandria VA 22304; Dear General Richardson: This is in response to your letter of December 12, 1977, concerning th preemption of State bumper standards by the Federal bumper standard (49 CFR Part 581, *Bumper Standard*).; Section 110 of the Motor Vehicle Information and Cost Savings Act (Pub L. 92-513) states that, until a Federal bumper standard takes effect, State bumper standards which were either in effect or promulgated prior to the effective date of the Act, shall be permitted to remain in force. Once the Federal bumper standard (Part 581) becomes effective, however, all State bumper standards applicable to the same aspect of performance as the Federal standard will be preempted.; Currently, the mandatory date for implementation of Part 581 i September 1, 1978. However, on June 20, 1977, the National Highway Traffic Safety Administration published a Federal Register notice (42 FR 31162) giving manufacturers the discretion to begin meeting the provisions of Part 581 prior to September 1, 1978. Once a manufacturer makes a decision to meet Part 581, it no longer has a responsibility to meet the currently effective bumper requirements of Standard No. 215, *Exterior Protection*. For such a manufacturer Part 581 would have taken effect and it would be obliged to meet the performance level the standard prescribes.; For purposes of preemption, once a manufacturer elects to meet th requirements of Part 581, that standard is in effect as to that manufacturer, and any State bumper standard applicable to the same aspect of performance as Part 581 is preempted as it applies to the vehicles he manufacturers.; Part 581 would not, however, be considered effective as to vehicle which continue to meet only the requirements of Standard 215. State bumper standards, thus, would not be preempted for purposes of application to those vehicles. Of course, all State bumper standards applicable to the same aspect of performance as Part 581 will be totally preempted after September 1, 1978, since at that time Part 581 becomes effective for all passenger cars.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0714OpenMr. Herman Kornahrens, Renick & Mahoney Div., Garsite Products, Inc., 10 E. Grand Blvd., Deer Park, L.I., NY 11729; Mr. Herman Kornahrens Renick & Mahoney Div. Garsite Products Inc. 10 E. Grand Blvd. Deer Park L.I. NY 11729; Dear Mr. Kornahrens: This is in reply to your letter of May 4, 1972, regarding th application of the Certification regulations (49 CFR Part 567) to tank truck manufacturers. Your questions are restated below, followed in each case by our response.; 1. If a vehicle ends up with a gross weight over the GVWR of the chasi (sic) are we (or anyone in our industry) liable to prosecution?; If the loaded weight of the vehicle, or the weight on an axle system exceeds the stated ratings, the vehicle may be found to contain a safety-related defect. While a vehicle manufacturer will not be liable to 'prosecution', as that term is generally understood, the failure of a vehicle to conform to applicable standards may result in the imposition of a civil penalty against its manufacturer of up to $1,000 for each violation, and up to $400,000 for each series of related violations (15 U.S.C. 1398). If a defect that relates to motor vehicle safety is discovered in the vehicle, the manufacturer will be required to notify first purchasers (15 U.S.C. 1402).; 2. Is it permissible to 'derate' the volumetric capacity of a tank (b setting the liquid markers low) in order to stay within the GVWR?; In assessing the safety aspects of a vehicle, the NHTSA considers al factors in the situation. These factors would include both the manufacturer's rating and the true capacity of the vehicle. I should emphasize that it is the actual situation, rather than any artificial statements or ratings, that we are primarily concerned with.; 3. If we so 'derate' a tank and the customer subsequently fills th tank, who would be responsible for the overweight?; The NHTSA does not regulate the user of a vehicle, although other Stat and Federal agencies do. The way in which a user loads his vehicle may, however, bring out a safety problem related to its load-carrying capacity. An important factor to be considered is the manufacturer's expectation as to how the vehicle is to be used at the time he sells it.; 4. Due to the manufacturing variations in chassis weights, tan dimensions, etc., are we allowed any tolerance on the actual weight versus the GVWR or GAWR?; While your question is somewhat unclear, the answer generally i negative. Any 'manufacturing variations' in components upon which these values are based must be taken into account by the manufacturer who assembles and labels the vehicle.; Finally, with reference to your complaint that certain of you competitors are not complying with the regulations, if you will furnish to us the names of the companies involved, we will be able to take whatever action is necessary to bring such companies into conformity with our requirements. We do not publish any booklets concerning the regulations, although various trade associations have undertaken to summarize them for their members.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5516OpenMr. Jeffrey D. Shetler Manager of Government Relations Kawasaki Motors Corp. U.S.A. P.O. Box 25252 Santa Ana, CA 92799-5252; Mr. Jeffrey D. Shetler Manager of Government Relations Kawasaki Motors Corp. U.S.A. P.O. Box 25252 Santa Ana CA 92799-5252; Dear Mr. Shetler: We are responding to your FAX of March 29, 1995, t Taylor Vinson of this Office. On May 6, 1994, we advised you that a motorcycle headlamp with an upper beam projector on one side of the vertical centerline and a lower beam projector on the other did not comply with Standard No. 108. You now ask whether the headlamp would comply if an exterior housing were installed on the headlamp which 'provides the appearance of two headlamps.' This modification in the design does not result in a complying headlamp. Regardless of its exterior appearance, the lamp remains a single headlamp incorporating both an upper and lower beam projector. Since both projectors are within a single headlamp, both projectors must be on the vertical centerline, as specified in Table IV of Standard No. 108. Even if the upper and lower beam projectors were in separate units, neither in itself would be a complying headlamp, and hence not a two-lamp system that could be mounted symmetrically about the vertical centerline. Standard No. 108 does not permit motorcycles to have a headlamp system with asymmetrical beam location. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, Philip R. Recht Acting Chief Counsel; |
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ID: aiam5003OpenThe Honorable Phil Gramm United States Senate 2323 Bryan Street, #1500 Dallas, Texas 75201; The Honorable Phil Gramm United States Senate 2323 Bryan Street #1500 Dallas Texas 75201; "Dear Senator Gramm: Thank you for your letter on behalf of you constituent, Mr. Frank Sonzala, Senior Vice President of International Transquip Industries (ITI), regarding Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems. ITI is a manufacturer of air brake systems and is apparently having difficulty selling its product to vehicle manufacturers because of a compliance issue related to Standard No. 121. The National Highway Traffic Safety Administration's Chief Counsel, Paul Jackson Rice, reviewed Mr. Sonzala's concerns, and I am pleased to provide you the following information. By way of background information, NHTSA issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, the Safety Act requires manufacturers to certify that their vehicles or equipment comply with applicable safety standards. Standard No. 121 specifies braking requirements for vehicles equipped with air brake systems. The purpose of the standard is to ensure safe braking performance under normal and emergency conditions. The standard applies only to motor vehicles and not to motor vehicle equipment. Therefore, vehicle manufacturers are responsible for ensuring compliance with the standard, and not brake equipment manufacturers such as ITI. The dispute between ITI and the vehicle manufacturers (ITI uses the term 'original equipment manufacturers') relates to the standard's parking brake requirements. The specific requirement at issue, set forth at S5.6 of Standard No. 121, requires a vehicle's parking brake to meet certain grade holding requirements (or other equivalent requirements) with 'any single leakage-type failure' of certain parts, including service brake chamber diaphragms. The purpose of this requirement is to ensure that a driver can safely park his or her vehicle in the event of a leakage-type failure in the service brake system. Leakage-type failures include such things as ruptured or severed brake hoses and torn diaphragms. Since these types of failures are relatively common in air brake systems, NHTSA believes that it is important that drivers be able to safely secure heavy trucks and other vehicles with such failures, until the vehicles can be repaired. For the purpose of determining whether a vehicle can meet Standard No. 121's grade holding requirements with one particular leakage-type failure, a failed diaphragm, ITI would like the standard to be interpreted to cover only a very limited and specific type of failure, i.e., a hole 1/8 inch in size located in a particular place. ITI states that the vehicle manufacturers generally have a broader view of what constitutes a failed diaphragm, i.e., they believe that failures include holes larger than 1/8 inch. ITI argues that Standard No. 121 is ambiguous in this area and requests NHTSA to issue an interpretation supporting its position. After consulting with NHTSA's Chief Counsel, we can state that the vehicle manufacturers are correct in their understanding that a failed diaphragm is not limited to a diaphragm with a 1/8 inch hole. Therefore, if a vehicle cannot pass Standard No. 121's grade holding test with a larger hole in a failed diaphragm, the vehicle manufacturer cannot certify that the vehicle complies with the standard. Further, we disagree with ITI's contention that Standard No. 121 is ambiguous as to what constitutes a failed diaphragm. As indicated above, Standard No. 121 specifies that the grade holding requirements must be met with any single leakage-type failure of certain parts, including a failed diaphragm. The usage of the term 'any,' when used in connection with a set of items, is specifically defined at 49 CFR 571.4 as meaning the totality of that set of items, any one of which may be selected by the Administration for testing. Thus, a vehicle must meet the grade holding requirements regardless of the extent of the failure selected by NHTSA for testing. We note that leakage-type failures of many types and sizes can occur in vehicle brake systems. NHTSA intentionally did not limit the size or location of such failures in developing this requirement to ensure that a vehicle has adequate grade holding performance regardless of the specific nature of such a failure. ITI also asked whether other broken components, such as heavy parking springs, brake shoes, linings, and drums should be part of Standard No. 121's test requirements, since diaphragms are tested when torn. Although NHTSA's brake standards do not have any express test requirements for broken parking springs, brake shoes, linings or drums, those standards include a number of requirements to ensure adequate braking performance in the event of various failures in a vehicle's brake system. We hope that this information is helpful. Sincerely, Frederick H. Grubbe Enclosure: Constituents Correspondence cc: Washington Office"; |
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ID: aiam0201OpenMr. R. O. Sornson, Manager, Highway and Vehicle Safety Relations, Chrysler Corporation, P. O. Box 1919, Detroit, MI 48231; Mr. R. O. Sornson Manager Highway and Vehicle Safety Relations Chrysler Corporation P. O. Box 1919 Detroit MI 48231; Dear Mr. Sornson: Thank you for your letter of January 20, 1970, with which you enclose copies of tables that you have developed for insertion into your consumer information booklets for prospective purchasers. These tables contain the required vehicle descriptions that were missing from your booklets, as I noted in my letter of December 11, 1969.; I am glad that you have decided to alter your existing booklets t conform as closely as possible, under the circumstances, to the regulations. With reference to your discussion of the advantages of various formats, I would simply say that at this time the matter is one of conformity to the regulations, and refer you to the advice in an earlier letter that the vehicle descriptions, in terms in which the vehicles are commonly described to the public, are required to be placed in proximity to the tables. The Bureau is willing to consider these and any other comments you might make as suggestions for further rulemaking to improve the required formats.; I assume that in subsequent printing runs of Chrysler booklets you wil print each vehicle description in close proximity to the pertinent table, so as to bring the booklets into full conformity. The Bureau and its legal staff are prepared to assist you at any time if you have further questions.; Sincerely, Robert Brenner |
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ID: aiam5453OpenMr. Harry L. Williams, Jr. President Willy Lights Inc. RR#1 Box 241 Bloomfield, Iowa 52537; Mr. Harry L. Williams Jr. President Willy Lights Inc. RR#1 Box 241 Bloomfield Iowa 52537; Dear Mr. Williams: We have received your letter mailed on September 27 1994, with respect to the permissibility under Federal law of your invention, Willy Lights. This product appears to consist of lights installed on wheel rims. You enclosed a copy of a memorandum to you on this subject dated October 24, 1988, from Greg Novak, an engineer with the Nevada Division of the Federal Highway Administration. After consulting with members of this agency, Mr. Novak wrote you that there were no regulations that prohibited the use of lighted wheel rims but that they could not 'interfere with any standard safety equipment on a vehicle.' You have asked whether this interpretation remains valid, and, if the lamps are not prohibited, the color permissible for the lamps. You have not provided a detailed description of your device, such as the amount of illumination provided by the lights. Mr. Novak's advice that there are 'no regulations prohibiting the use of lighted wheel rims' must be qualified. There are no Federal regulations that specifically prohibit the sale and installation of lighted wheel rims, but there may be regulations governing the use of lighted wheel rims issued by the individual States. We have no knowledge of State laws on this matter and suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment establishes the requirements for original lighting equipment for motor vehicles. Standard No. 108, in effect, prohibits the installation of supplementary lighting equipment such as Willy Lights before the initial sale of a vehicle if it impairs the effectiveness of the equipment required by Standard No. 108. Thus, if Willy Lights were sufficiently bright to mask in whole or in part the side marker lamps and reflectors and any lamps mounted on the front and rear that wrap around the sides, Standard No. 108 would prohibit their installation. The seller (dealer) of the new vehicle has the responsibility of ensuring that the vehicle remains in compliance with Standard No. 108 when it installs supplementary lighting equipment, that is to say, the responsibility of determining whether or not impairment exists. This agency does not question such determinations unless they appear clearly wrong. There is a similar prohibition for supplementary lighting equipment installed after the initial sale of a vehicle. When Willy Lights are installed by a manufacturer, dealer, distributor, or motor vehicle repair business, they must not make inoperative any of Standard No. 108's required equipment. With respect to Willy Lights, we would regard the question of making inoperative as equivalent to the question of impairing effectiveness. If it is concluded that Willy Lights do not impair new vehicle equipment, then one can conclude that its installation on a used vehicle will not have an operative effect on 108's equipment. However, the States retain the right to say whether or not Willy Lights may be used within their borders. The color of the lamps may also be important in any determination of impairment or inoperability. Under Standard No. 108, required side marking equipment at or near the front of a vehicle must be amber in color, and red at or near the rear. To lessen the chance of confusion in a driver approaching from the side who may never have seen lighted wheel rims, we believe that it would be preferable to follow Standard No. 108's color code. Use of different colors, such as white or green, could cause momentary confusion in the eyes of an approaching driver, leading to the conclusion that the required side lighting equipment has been impaired or made partially inoperative by Willy Lights. Sincerely, Philip R. Recht Chief Counsel; |
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ID: aiam2396OpenMr. Edgar E. Lungren, Jr., Pullman Trailmobile, 200 East Randolf Drive, Chicago, Il 60601; Mr. Edgar E. Lungren Jr. Pullman Trailmobile 200 East Randolf Drive Chicago Il 60601; Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identify and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers will be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking, and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1943OpenWarren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Warren M. Heath Commander Engineering Section Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Commander Heath: This is a further reply to your letter dated January 21, 1975, askin several questions regarding Standard No. 205, Glazing Materials.' We have attempted to incorporate the substance of your questions in our various answers.; 1. *Prime Glazing Material Manufacturer.* A company that buys and the bends or otherwise forms flat plastic glazing material into a motorcycle windshield is *not* a prime glazing material manufacturer, nor is a company which blows or stretches flat plastic glazing material that is purchased from another company. Prime glazing material manufacturers are only those who fabricate, laminate, or temper the glazing material. In neither of the examples you pose is the material fabricated, laminated, or tempered by the company in question.; 2. *Marking Requirements.* In the amendment to Standard No. 20 published November 11, 1972, (37 FR 24035), it was our intention to limit the use of the DOT symbol and manufacturer's code number to the prime glazing material manufacturer. Persons who cut glazing fabricated by others should not under Standard No. 205 utilize the prime manufacturer's code number or the DOT symbol. Our purpose in structuring the marking requirements this way was to enable us to determine, for purposes of attributing responsibility for conformity, which glazing in a motor vehicle had been manufactured by the prime manufacturer specifically for use in that vehicle, and which glazing had been cut, shaped, or otherwise altered before installation.; >>>(a) You are correct in your interpretation that the DOT symbol an the code number are applied by a prime glazing material manufacturer in addition to the manufacturer's trademark. It was our expectation that the prime manufacturer would furnish his customers with a heat stamp of the markings required by Section 6 of ANS Z26, without the DOT symbol and code number, by which the manufacturer cutting or otherwise shaping the material would mark those pieces he cut or shaped.; (b) Glazing produced by a prime glazing material manufacturer that i not designed for use in a specific vehicle should not contain the DOT symbol or the manufacturer's code number.; (c) The NHTSA has assigned numbers only to prime glazing materia manufacturers. We have not inquired, however, whether the company is in fact producing glazing materials for use in specific vehicle applications.; (d) As stated previously, a company which does not manufacture it glazing but which cuts glazing from larger pieces purchased from the producer of the material should not be using the prime manufacturer's code number or the DOT symbol.; (e) You are correct in your conclusion that the marking requirements o the standard do not apply to dealers. However any person (including a dealer) who sells glazing (separately or in a new vehicle) which is improperly marked may be violating Section 108 of the National Traffic and Motor Vehicle Safety Act.<<<; 3. *General Requirements.* >>>(a) Standard No. 205 does presently prohibit dealers from using th prime glazing material manufacturer's code number. If you are aware of instances where this requirement is not being followed, please forward to us the particulars of the cases in question and we will take appropriate action.; (b) Manufacturers who purchase glazing in large sheets and then cut i to fit window frames are not prime manufacturers and may not use the DOT symbol or manufacturer's code number. You are therefore not correct in your statement that a manufacturer of a window assembly may use the prime manufacturer's number even when the window manufactured is for a special application.; (c) The model number of glazing used in motorcycle windshields shoul be that which is assigned to it by the prime glazing material manufacturer in the glazing's original thickness. ANS Z26 calls for testing plastic glazing materials in substantially flat specimens, and not in molded specimens. However, the Federal standard does not require testing. Manufacturers are required only to use due care in the manufacture of their products. A person reforming' the plastic does not thereby become a prime glazing material manufacturer.; (d) The markings which should appear on plastic bubbles on minivan should be those of the prime manufacturer (not the DOT symbol or code number) of the glazing material and not those of the person who reshapes the glazing.; (e) A material marked AS4 that was used as a motorcycle windshiel would technically fail to conform to the standard as the standard does not provide for the use of AS4 materials in motorcycle windshields. However, if the material also conformed to the requirements of AS6 (which is permitted to be used in motorcycle windshields), the nonconformity would not be considered significant.; (f) Our basic approach has been that the standard applies to th vehicle locations specified in ANS Z26, and to any glazing (glass or plastics) used in those locations. However, opaque plastic materials which are clearly structural materials do not fall within the ambit of Standard No. 205.; (g) Standard No. 205 presently limits the use of plastic glazin materials in buses to readily removable windows, which include push-out windows. Plastic materials may not be used in buses in fixed quarter panels or sliding windows that are not readily removable.; We believe our reasons to be valid for limiting the use of the DO symbol and manufacturer's code number to glazing manufactured by prime manufacturers for use in a specific vehicle location. However, we would certainly be willing to consider steps you might suggest to facilitate State inspections that are consistent with the purposes of the labeling requirements presently in effect. Such a suggestion should be in the form of a petition to amend Standard No. 205 and should be specific.; Sincerely, James C. Schultz, 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.