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 |
|---|---|
ID: 07-007541asOpenMr. Darby Crow CEO Crow Cycle Co. 863 Opal Street San Diego, CA 92109 Dear Mr. Crow: This responds to your letter concerning whether the Crow Cycle Companys motorized bicycle design (the Crow beach cruiser) is considered a motorcycle, subject to the jurisdiction of the National Highway Traffic Safety Administration (NHTSA). As discussed below, it is our opinion that the Crow beach cruiser is a motor vehicle. Moreover, based on the specifications of the vehicle that you provided, it is our opinion that the Crow beach cruiser should be considered a motorcycle, or more specifically a motor-driven cycle, and therefore is subject to Federal laws governing those vehicles. By way of background, NHTSA regulates the manufacture, importation, and sale of motor vehicles and motor vehicle equipment. The definition of motor vehicle is given is 49 USC 30102, and reads: [M]otor vehicle means a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways, but does not include a vehicle operated only on a rail line. Furthermore, the NHTSA has included definitions of various vehicle types in its regulations. In 49 CFR 571.3, we defined a motorcycle as a motor vehicle with motive power having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground. A motor-driven cycle is defined as a motorcycle with a motor that produces 5-brake horsepower or less. You have provided detailed specifications regarding the Crow beach cruiser. Most relevantly, you stated that it comes equipped with a 36cc, 1.6 HP engine. The Crow beach cruiser has a bicycle frame, seat, transmission, and mountain bike wheels. The speed control is a twist throttle, similar to motorcycle designs, and most other components are standard bicycle components. Furthermore, you stated that the Crow beach cruiser can be operated in three different modes. The first is Human Power, in which the vehicle is operated like a non-powered bicycle. The second is Human Power plus gasoline engine, in which the vehicle operates like a power-assisted bicycle. The third is Gasoline engine only, in which the engine provides the sole power for the vehicle. In this mode, the vehicle has a top speed of 28 mph when placed in the smallest gear. Additionally, we note that the beach cruiser style of bicycles, whether motorized or not, are marketed in part for and commonly used on public roads. You provided several arguments as to why you believe NHTSA should not consider your product a motor vehicle. You state that the engine output and top speed of the vehicle, 1.6 HP and 28 mph, respectively, are similar to what a world-class cyclist can sustain through human power alone, and what an average cyclist can produce in brief bursts. Therefore, you state, the performance of the vehicle is similar to that of an ordinary bicycle powered by a cyclist. You also state that the Crow beach cruiser cannot keep up with normal road traffic, is not capable of quick acceleration, and cannot climb hills at a speed comparable to a motorized vehicle. You made several additional arguments. First, you argued that the Crow beach cruiser is very similar to a mountain or road bicycle. You state that the controls are similar and the components are largely bicycle components. Furthermore, you presented information on various State laws regarding the classification of motorized bicycles and motorcycles. You stated that a majority of States classify a vehicle a top speed of 30 mph or less and an engine capable of producing 2 HP or less as a motorized bicycle. Based on the description of the vehicle you provided, we believe that the Crow vehicle is a motor vehicle, subject to the Federal Motor Vehicle Safety Standards (FMVSSs). We believe that it should be classified as a motor-driven cycle. Below, we will state our rationale, as well as address the arguments you put forth in your letter. NHTSAs position on whether motorized bicycles should be classified as motor vehicles under the definition in 49 U.S.C. 30102 has been discussed in several previous interpretations. In a 1999 interpretation, we stated that attaching a motor to a bicycle rendered the bicycle a motor vehicle, because the motor was capable of propelling the vehicle on its own.[1] Similarly, a 1997 interpretation to an electric bicycle manufacturer stated that NHTSA considered self-propelled bicycles to be motor vehicles, subject to the Federal requirements.[2] We are enclosing copies of both previous interpretations. Because the Crow beach cycle is capable of operating solely under mechanized power, we would consider it to be a motor vehicle, and thus subject to Federal requirements. We note that we do not consider power-assisted bicycles to be motor vehicles. In a recent letter of interpretation, we stated that a bicycle with an engine that was not powerful enough to power the bicycle alone would not be considered a motor vehicle.[3] The Crow beach cruiser, on the other hand, is capable of performing purely on engine power. You argued that the Crow beach cruiser is no more capable of keeping up with traffic than human-powered cyclists, and therefore should not be considered a motor vehicle. We disagree with this argument. The Crow beach cruiser, using only the motor, is capable of sustained speeds of up to 28 mph. We believe that vehicles with speeds of over 20 mph are capable of on-road operation. We note that one class of four-wheeled motor vehicles, low speed vehicles (LSVs), have a top speed of more than 20 mph but not more than 25 mph. You also argued that because the Crow beach cruiser uses similar controls to a road or mountain bicycle, it should be considered a motorized bicycle, and that many States do not consider low-powered motorized bicycles to be motorcycles. While we are not familiar with the various State laws you mentioned, we note that Congress has enacted laws regarding motorized bicycles. Specifically, in the Consumer Product Safety Act, Congress distinguished certain types of motorized bicycles, namely, low-speed electric bicycles, which have a top speed of less than 20 mph. In that Act, Congress stated that because low-speed electric bicycles are designed not to exceed the maximum speed of a human-powered bicycle, and they are typically used in the same manner as human-powered bicycles, electric bicycles should be regulated in the same manner and under the same agency (the [Consumer Product Safety Commission] CPSC) as human-powered bicycles. While we note that this law applies only to electric bicycles, and not gasoline-powered bicycles like the Crow beach cruiser, we take note that Congress used a cutoff speed of 20 mph. We also note that the 20 mph cutoff point was the speed that NHTSA used to determine the minimum top speed for LSVs. Therefore, we are not persuaded by your argument that the speed and design of the Crow beach cruiser should cause NHTSA to not consider it a motor vehicle. Based on the above analysis, we have concluded that the Crow beach cruiser is a motorcycle, or more specifically, a motor-driven cycle. As such, it is subject to the FMVSSs applicable to motorcycles. If you have any further questions relating to NHTSA, please contact Ari Scott of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel Enclosures ref:108 d.4/17/08 |
2008 |
ID: 07-007542--29 Feb 08--sa--2OpenDr. Klaus Bs Lear Corporation Technology Center Allershausen Am Ziegelwerk 1 D-85391 Allershausen-Leonhardsbuch Germany Dear Dr. Bs: This is in response to your December 12, 2007 facsimile, in which you asked about the head restraint position specification for the dynamic compliance option in Federal Motor Vehicle Safety Standard (FMVSS) No. 202a, Head Restraints. Specifically, you refer to a 2007 final rules elimination of the backset adjustment specification (while maintaining the up/down adjustment specification) in the dynamic compliance option for head restraints (72 FR 25484, May 4, 2007). You ask for clarification of how head restraints with adjustable backsets should be positioned for the dynamic compliance tests. As discussed below, the omission in the regulatory text of the language you referenced was an inadvertent error, and we plan to correct this error as a technical correction. This correction will clarify that head restraints with adjustable backsets can be tested in any position of adjustment during compliance tests for the dynamic option, i.e., the vehicle must comply in all such positions of adjustment. FMVSS No. 202a seeks to reduce whiplash injuries in rear collisions, and in 2004 the National Highway Traffic Safety Administration (NHTSA) upgraded this standard to provide better whiplash protection for a wider range of occupants (2004 Final Rule). On May 4, 2007, NHTSA published a new final rule (2007 Final Rule) amending FMVSS No. 202a, which responded to petitions for reconsideration of the 2004 Final Rule (69 FR 74848, Dec. 14, 2004). In your letter, you refer to the 2007 Final Rules elimination of the specification of backset adjustment in the dynamic compliance option for head restraints. Your letter asks for clarification of your assumption that the absence of specific instructions for backset adjustment must mean that head restraints with adjustable backsets should be adjusted midway between the most forward and rearward position of adjustment, analogous to the condition specified for the up/down adjustment of the head restraint (midway between the lowest and the highest position of adjustment). As explained below, your assumption is incorrect. The 2004 Final Rule altered the head restraint position specification for the dynamic compliance option from any position of adjustment to a mid-height position and any position of backset adjustment. This was indicated in both S4.3 and S5.3: S4.3 Dynamic performance and width. At each forward-facing outboard designated seating position equipped with a head restraint, the head restraint adjusted midway between the lowest and the highest position of adjustment, and at any position of backset adjustment, must conform to the following: * * * * * S5.3 Procedures for dynamic performance. Demonstrate compliance with S4.3 of this section in accordance with S5.3.1 through S5.3.9 of this section with a 50th percentile male Hybrid III test dummy specified in 49 CFR part 572 subpart E, with the head restraint midway between the lowest and the highest position of adjustment, and at any position of backset adjustment. The 2007 Final Rule preamble did not discuss, and we did not intend to make any changes to the provisions of head restraint adjustment for this test. The omission of this test condition was an inadvertent error, and the agency plans on correcting this mistake in a forthcoming technical correction to the 2007 Final Rule. This will clarify that head restraints with adjustable backset can be tested in any position of adjustment during the dynamic compliance option. If you have any further questions, please do not hesitate to contact Sarah Alves of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel ref:202 d.4/29/08 |
2008 |
ID: 07-26-01_Rubel_ltr_spwOpen Eric A. Rubel, Esq. Dear Mr. Rubel: This is in reply to your letter, written on behalf of DEKA Research and Development Corporation (DEKA), asking whether certain products would be considered "motor vehicles" subject to regulation by this agency. You generally described the products. You stated that the products in question, which to date have not been marketed or sold, would have either two or four drive wheels, would operate on battery power, and would be intended primarily for use on sidewalks. You also stated that the products could be described as low-speed electric personal assistive mobility devices, which are self-balancing, can operate on two non-tandem wheels, have an electric propulsion system, and have a maximum speed on a paved level surface of less than 20 mph, when powered solely by such a propulsion system and ridden by an operator who weighs 170 pounds. As you know, the National Highway Traffic Safety Administration regulates "motor vehicles." A "motor vehicle" is defined, in part, as one "manufactured primarily for use on the public streets, roads, and highways." 49 U.S.C. ' 30102(a)(6). Accordingly, only vehicles which are operated on the public streets, roads, and highways, as one of their primary uses, are considered to be motor vehicles. In determining whether a particular product is operated on the public streets, roads, and highways, as one of its primary uses, we consider a number of factors, including whether the vehicle can be licensed for use on public streets, roads and highways. If a vehicle cannot be so licensed, we consider whether the vehicle is, in fact, used on public streets, roads, and highways by a substantial number of people. Considering that the vehicles you describe are still in the planning stage (i.e., are not presently available for sale to the general public), no data are available concerning their actual use. In situations like this, where such data are unavailable, this agency has looked to the use patterns of vehicles similar to the ones in development. Given the general nature of the description, identifying like-vehicles is difficult. This problem is compounded by the fact that the vehicles DEKA is planning to manufacture appear to be unique. Nevertheless, we note that they have characteristics that, at least in some respects, are similar to those of motorized wheelchairs. This agency does not consider motorized wheelchairs to be "motor vehicles." They are not licensable and are not used on public streets, roads, and highways by a substantial number of people. Thus, they are not subject to this agency's safety regulations. Based on our understanding of the characteristics of the vehicles in question and on the assumptions that they would not be licensable and would be used in a fashion similar to motorized wheelchairs, we would not consider the vehicles to be "motor vehicles." If our assumptions about licensability and actual usage proved incorrect, we would reconsider this position. If you have any questions, you may contact Robert Knop of this Office at (202) 366-2992. Sincerely, John Womack ref:571 |
2001 |
ID: aiam0502OpenMr. G. E. Fouche', Jr., Project Leader, Kendall Company, P. O. Box 1828, 6300 Carmel Road, Charlotte, NC, 28201; Mr. G. E. Fouche' Jr. Project Leader Kendall Company P. O. Box 1828 6300 Carmel Road Charlotte NC 28201; Dear Mr. Fouche': This is in reply to your letter of November 2, 1971, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to synthetic fabrics. You state that certain of these fabrics do not ignite when tested with a stationary flame as they melt and shrink away from the flame, but burn faster than the 4-inch-per-minute rate if the flame is moved to keep it in contact with the fabric. You ask whether materials that behave in this manner comply with the standard.; The standard requires that the vehicle components specified in S4.1 o the standard meet the burn rate requirements when tested as provided in S5.3 of the standard. This procedure specifies a stationary flame. Consequently, we would consider materials which melt and shrink away from the flame, but do not ignite, as long as the other aspects of the test procedure were followed, to comply with the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam5350OpenMr. Michael E. Klima Managing Engineer Failure Analysis Associates, Inc. 2100 East Maple Road, Suite 200 Birmingham, MI 48009; Mr. Michael E. Klima Managing Engineer Failure Analysis Associates Inc. 2100 East Maple Road Suite 200 Birmingham MI 48009; Dear Mr. Klima: This responds to your letter of March 29, 1994, to Mr Edward Jettner of this agency concerning the dynamic testing requirements of Standard No. 208, Occupant Crash Protection. Your questions concern the application of this standard to a pickup truck manufactured in April 1988 with a gross vehicle weight rating (GVWR) of 4,400 pounds. You asked whether the injury criteria in S6 apply to this truck, whether a 35 mph fixed barrier crash test is required, and which sections of Standard No. 208 apply to this truck. The safety belt installation requirements for all vehicle types are set forth in Standard No. 208. Section S4.2.1 of Standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in trucks and multipurpose passenger vehicles with a GVWR of 10,000 pounds or less, manufactured on or after January 1, 1976 and before September 1, 1991. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seating positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protection requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic protection for the front outboard seats, and have a warning system for the safety belts provided. Option 3, set forth in S4.1.2.3, requires the manufacturer to install lap or lap/shoulder safety belts at every seating position and to have a warning system for those belts. According to your letter, the manufacturer installed Type 2 seat belt assemblies at the front outboard seating positions. This suggests that the manufacturer chose to comply with Option 3. Under this option, the only requirements in Standard No. 208 that those belts were required to comply with were S7.1, S7.2, and S7.3. The belts were also required to comply with the requirements of Standard No. 209, Seat Belt Assemblies. The manufacturer was not required to certify that the vehicle complied with the dynamic testing requirements of Standard No. 208. The injury criteria in S6 of the standard are applicable only to vehicles which must comply with the dynamic testing requirements. Standard No. 208 does not include a 35 mph fixed barrier crash test requirement. The dynamic crash test in Standard No. 208 is barrier crash test at any speed up to 30 mph. NHTSA does perform some 35 mph barrier crash tests as part of the New Car Assessment Program (NCAP). NCAP is a consumer information program, not a safety compliance test. NHTSA does not test every vehicle under this program. In the 1993 model year program, NHTSA tested 37 new vehicles and released results on 68 additional vehicles which had been tested previously and had not changed significantly in model year 1993. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
|
ID: aiam2495OpenMr. David Munafo, Commercial Plastics, 98-34 Jamaica Avenue, Richmond Hill, NY 11418; Mr. David Munafo Commercial Plastics 98-34 Jamaica Avenue Richmond Hill NY 11418; Dear Mr. Munafo: This responds to your letter of December 7, 1976, regarding the use o plastic glazing materials for side windows of school buses. You asked what materials are permitted by Federal regulations for school bus side windows and whether Federal laws concerning the materials that may be used preempt State laws on the same subject.; Section 103(d) of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S1381 *et*. *seq*.) provides in part:; >>>Whenever a Federal motor vehicle safety standard established unde this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.<<<; Safety Standard No. 205, *Glazing Materials* (49 CFR 571.205) currentl does not permit the use of plastic glazing in bus side windows. Therefore, State laws that permit plastic glazing are in direct conflict with Standard No. 205, and it is the agency's opinion that they would be preempted.; I would point out that the agency recently issued a proposal to amen Standard No. 205 that would permit the use of rigid plastic glazing in bus side windows (41 FR 56837, Dec. 30, 1976). I am enclosing a copy of this proposal for your information. I am also enclosing a copy of Standard No. 205 and the ANS Z26 standard that is incorporated by reference in Standard No. 205. From these standards you can determine the various types of glazing materials that are permitted for side windows and the requirements that the glazing must meet.; Regarding your question about replacement glazing, Standard No. 205 i not a vehicle standard and is applicable to all glazing for use in motor vehicles, whether the glazing is to be installed in new vehicles or as replacement in used vehicles. Therefore, glazing manufacturers and fabricators cannot produce glazing to be used in a given location in a vehicle unless the standard permits that type of glazing to be used in that location, regardless of whether it is original or replacement glazing.; Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam0152OpenMr. Yoshiyuki Mizuno, Factory Engineer, Nissan Motor Corporation, 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Factory Engineer Nissan Motor Corporation 400 County Avenue Secaucus NJ 07094; Dear Mr. Mizuno:#Thank you for your letter of March 7, 1969, to Dr William Haddon, Jr., concerning the location and the identification of the windshield washer switch on the steering column.#The system as you describe it appears to conform to Federal Motor Vehicle Safety Standard No. 101, however, the Bureau does not issue approvals of any specific system, and the development of equipment to comply with the standard is the responsibility of the individual manufacturer.#In reference to your second question about the identification of the windshield washer switch, Paragraph S3.2 reads, in part, '.... The following controls, when mounted on the instrument panel, shall be identified to permit recognition -- >>>... (c) Windshield Washing System, ....'<<<#This section of the regulation does not apply to the identification of controls in any position other than on the instrument panel.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service; |
|
ID: aiam4111OpenMr. Marshall D. Carter, Whisper Electric Car AS, 87 Hadsundve, Als, DK-9560 Hadsund, Denmark; Mr. Marshall D. Carter Whisper Electric Car AS 87 Hadsundve Als DK-9560 Hadsund Denmark; Dear Mr. Carter: This is in reply to your letter of February 18, 1986, asking tw questions with respect to the Federal motor vehicle safety standards.; With respect to electric vehicles, you have asked 'is there a standar regulating the minimum length of time that the hazard light must be able to function at a minimum intensity, on the service battery alone?' There is no such standard. The vehicle must be equipped with a hazard warning signal operating unit designed to conform to SAE J910, January 1966, and a hazard warning signal flasher designed to conform to SAE J945, February 1966, but there is no requirement in the Federal motor vehicle safety standard on vehicle lighting, Standard No. 108, that the hazard warning signal flashers perform for a minimum specified period of time in service.; You have also asked 'Is there a requirement that the vehicle b equipped with an illuminated display, indicating gear selection?' We are unable to confirm your conclusion that there is no such requirement under Standard No. 101. Paragraph S3.2 of Standard No. 102 requires that identification of shift lever positions or patterns be permanently displayed in front of the driver. Paragraph S5.3.1 of Standard No. 101 requires illumination of the 'gauges' listed in Column 1 of Table 2 that are accompanied by the word 'Yes' in Column 5. The last 'gauge' listed is 'Automatic gear position', and the word 'Yes' appears in Column 5. The automatic gear position is a 'gauge' as defined by paragraph S4 of Standard No. 101, 'a display that is listed in ...Table 2 and is not a telltale'. Thus the Federal standards do require illumination of the gear positions of automatic transmissions, but not of manual ones.; I hope that this responds to your questions. Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam1313OpenMr. Gordon M. Bradford, Vice President, Corporate Development, American Safety Equipment Corporation, 16055 Ventura Boulevard, Encino, CA 91316; Mr. Gordon M. Bradford Vice President Corporate Development American Safety Equipment Corporation 16055 Ventura Boulevard Encino CA 91316; Dear Mr. Bradford: This is in reply to your letter of October 5, 1973, concerning you proposed use of a tension reliever device in a seat belt retractor. As we understand the concept of the tension reliever, it allows a small amount of slack to be introduced into the webbing by a mechanism roughly similar to that of a window shade. If the webbing is pulled smoothly back and forth, the retractor exerts a normal retractive force. If, however, the retraction is halted at a certain point, as when the belt comes to rest against an occupant's shoulder, the reliever engages and the occupant is relieved of the active pull of the retractor until he moves forward by an inch or two and disengages the reliever.; Your initial question is whether a reliever-equipped retractor will b considered to meet the retraction force requirements of S4.3(j)(6) of Motor Vehicle Safety Standard No. 209. You state that it will meet the test so long as the procedures of S5.2(j) are strictly observed and no oscillations are introduced by the test apparatus. If the facts are as you state, it is our opinion that the retractor would meet S4.3(j)(6).; Your other question, as clarified by telephone on November 1, 1973, i whether we have reservations about the concept of a tension reliever that would lead us to bar its use through amendment of Standard No. 209. Based on the information presently available, we have no such reservations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3284OpenCharles M. Kneip, Vehicle Services Division, Department of Motor Vehicles, Lincoln, NE 68509; Charles M. Kneip Vehicle Services Division Department of Motor Vehicles Lincoln NE 68509; Dear Mr. Kneip: This is in response to your letter of May 7, 1980, in which you aske whether the proposed Nebraska certificate of title may be used as a substitute for the Federal odometer disclosure form required by 49 CFR Part 580.; The Nebraska title differs from the minimum Federal requirements i that there is no certification that the odometer reading reflects the actual mileage or the mileage over 99,999 miles, or is not the actual mileage. The buyer is not required to sign the Nebraska title as he is the Federal form (sic). In addition, your title does not refer to the legal consequences of a false disclosure. If you can make these additions, the Nebraska title will satisfy the Federal requirements.; For your information, I have enclosed a copy of the *Federal Register notice which discusses the short form odometer disclosure that States may use on their titles to satisfy Federal requirements, a letter to Maryland in which we indicate that formal approval by NHTSA is not necessary if the title contains the specified information, and sample titles that the NHTSA has approved.; If you need any further inforamtion, please do not hesitate to contac us.; Sincerely, John Womack, Assistant Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.