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: aiam3529OpenMr. Malcolm J. McCalmon, International Sales Manager, CENTRA Leichtmetall-Rader GmbH, Daimlerstrasse 6, D-6733 Hassloch/Pfalz, West Germany; Mr. Malcolm J. McCalmon International Sales Manager CENTRA Leichtmetall-Rader GmbH Daimlerstrasse 6 D-6733 Hassloch/Pfalz West Germany; Dear Mr. McCalmon: This responds to your letter to Mr. Kratzke of my staff concerning th Federal requirements for vehicle wheels that are to be imported into the United States. You noted in your letter that the wheels would be for 'original equipment on passenger vehicles and non-passenger vehicles (recreation vehicles).' There are two Federal Motor Vehicle Safety Standards which apply to wheel rims. There are no standards applicable to the rest of the wheel assembly, however.; The two applicable standards are No. 110, *Tire selection and rims passenger cars,* and No. 120, *Tire selection and rims for motor vehicle other than passenger cars*. I have enclosed copies of both standards, along with Standard Nos. 109 and No. 119, which are applicable to tires. For those passenger car rims you manufacture there are two requirements, specified in section S4.4 of Standard No. 110. First, the rim must be constructed to the dimension of one of the rims that is listed under definition of a test rim in Standard No. 109. This means that the rim must comply with the dimensional specifications shown for that rim size in the current publications of specified standardization organizations, such as the Tire & Rim Association, the European Tyre and Rim Technical Organization, or the Deutsches Institut fur Normung. Second, in the event of a rapid loss of inflation pressure with the vehicle travelling in a straight line at 60 miles per hour, the rim must retain the deflated tire until the vehicle can be stopped with a controlled braking applications.; For those rims you manufacture for use on vehicles other than passenge cars, Standard No. 120 also specifies two requirements: The first requirement, set forth in section S5.1.1, is that the rims on a vehicle must correspond with the size tire on the vehicle, i.e., be listed as suitable by the tire manufacturer, pursuant to either Standard No. 109 or No. 119. This would be done in the publications of the standardization organizations, as explainted (sic) above. This requirement is the responsibility of the vehicle manufacturer, since only it knows what size tires will actually be on the vehicle. The second requirement, set forth in section S5.2, is that the second requirement,, set forth in section S5.2, is that the rim must be marked with certain specified information.; When a rim manufacturer determines that its rims comply with th requirements outlined above, it may certify the rims and sell them in the United States. In your letter, you inaccurately stated that there is no a(sic) specific DOT certification for rims. While there is no specific DOT certification number, as required by some other standards for item of equipment other than rims, a manufacturer must always certify that each item of motor vehicle equipment complies with all applicable Federal motor vehicle safety standards, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1403)(copy enclosed). That section specifies that the certification for items of motor vehicle safety equipment, including rims, may be in the form of a label or tag on the item, or on the outside of a container in which the item is delivered. All of your rims to be sold in this country must contain such a certification.; The United States does not use a certification process similar to th EEC, in which the manufacturer delivers the item to be certified to the governmental entity, and that entity tests the item to determine if it can be certified. Instead, in the United States, the individual manfuactuer(sic) must certify that the product complies with all applicable standards. Further, this agency does not require that a certification be based on actual tests of the equipment, we only require that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer to determine in the first instance exactly what data or information it needs to allow it to certify that the equipment meets all applicable Federal standards. Obviously, with respect to the requirements for rims, a manufacturer is not expected to test if the rims have the necessary markings or if the rim size is listed in one of the publications of a standardization organization.; Should you have any further questions about these standards, feel fre to contract me. If you need further information about the actual process of importing the rims into the United States or the form for the certification, you can contact the U.S. Customs Service Duty Assessment Division at 1301 Constitution Avenue, N.W., Washington, D.C. 20229.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1514OpenMr. Sergio Campanini, Vice President, Marketing, The Berg Manufacturing Company, 333 East Touhy Ave., Des Plaines, IL 60018; Mr. Sergio Campanini Vice President Marketing The Berg Manufacturing Company 333 East Touhy Ave. Des Plaines IL 60018; Dear Mr. Campanini: This responds to your December 21, 1973, letter and subsequen communication with Mr. Sidney Williams of the NHTSA Handling and Stability Division asking if a check valve located at the isolated reservoir (as pictured in your schematic drawing) to protect the trailer service reservoir(s) would comply with S5.2.1.5 of Standard No. 121, *Air brake systems*.; The check valve may be placed at the isolated tank to protect th trailer service reservoir as specified in S5.2.1.5.; It appears from your schematic that a single failure in the servic brake system could cause loss of service brakes on both trailer axles. It should be noted that if this arrangement is used and a significant safety problem results, it would be subject to NHTSA safety defect authority.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4716OpenMr. R.W. Schreyer Senior Sales Engineer Transportation Manufacturing Corp. Box 5670 (R.I.A.C.) Roswell, NM 88202-5070; Mr. R.W. Schreyer Senior Sales Engineer Transportation Manufacturing Corp. Box 5670 (R.I.A.C.) Roswell NM 88202-5070; "Dear Mr. Schreyer: This responds to your letter to Mr. Harry Thompso of this agency's Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210). You posed two questions, which I will answer in the order presented. First, you noted that the State of Nevada will be procuring some prison buses, equipped with lap-only safety belts at the passenger seating positions. You correctly noted that no safety standard requires safety belts to be installed for passenger seating positions on buses, but asked if this agency could 'provide direction on what course of action TMC should take.' You asked particularly whether you should design the anchorages for the lap-only safety belts to conform with the requirements of Standard No. 210. NHTSA answered this question in a March 22, 1989 letter to Mr. Keith McDowell, a copy of which is enclosed for your information. As we said in that letter, NHTSA must decline to issue any 'guidelines' beyond or in addition to the requirements set forth in the safety standards. Therefore, since Standard No. 210 expressly exempts passenger seats in buses from the standard's anchorage requirements, Federal law leaves the question of how any such anchorages should be designed entirely up to the judgment of the bus manufacturer. Please note, however, that the State of Nevada is free to specify certain design and performance criteria with which these anchorages must comply in its contract for these buses. Second, you asked for a clarification of the testing conducted to determine compliance with Standard No. 210. Section S4.2 of Standard No. 210 sets forth the strength test with which anchorages must comply. Section S4.2.4 of Standard No. 210 reads as follows: 'Except for common seat belt anchorages for forward-facing and rearward-facing seats, floor-mounted seat belt anchorages for adjacent designated seating positions shall be tested by simultaneously loading the seat belt assemblies attached to those anchorages.' You asked whether all seats in the coach must be tested simultaneously or whether a single seat would be tested, and then the next seat tested, and so forth. Please note that the only anchorages subject to a simultaneous testing requirement are 'floor-mounted' anchorages for 'adjacent designated seating positions.' Assuming that there is an aisle or some other separation between the seat assemblies in your buses, the only 'adjacent' designated seating positions would be those common to one occupant seat. Therefore, no more than one occupant seat's anchorages would be tested simultaneously under Standard No. 210. Even those anchorages common to one occupant seat would be tested simultaneously only if the anchorages were floor-mounted. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam3179OpenMr. Glen Brinks, 2110 Magnolia Avenue, Santa Ana, CA 92707; Mr. Glen Brinks 2110 Magnolia Avenue Santa Ana CA 92707; Dear Mr. Brinks: This responds to your recent letter requesting information concernin the Federal safety regulations applicable to motorcycle fuel tanks and motorcycle trailers.; The Federal Motor Vehicle Safety Standard regarding fuel syste integrity, Standard No. 301-75, currently does not apply to motorcycles. Two safety standards would be applicable to the manufacture of motorcycle trailers: Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* and Safety Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars*.; The manufacturer of a trailer, including a motorcycle trailer, woul have to certify the compliance of the trailer to these two safety standards. Part 566 of our regulations, *Manufacturer Identification* (49 CFR 566), specifies information which must be submitted to the NHTSA by manufacturers of motor vehicles, including trailers. Part 567, *Certification* (49 CFR 567), specifies the content and location of the certification label or tag that must be attached to motor vehicles regulated by our standards. I am enclosing an information sheet that explains where you can obtain copies of these safety standards and regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1144OpenMs. Anna Ruth Baldwin, 4315 Aegean Drive, Apartment 230, Tampa, FL 33611; Ms. Anna Ruth Baldwin 4315 Aegean Drive Apartment 230 Tampa FL 33611; Dear Ms. Baldwin: This is in response to your letter request of May 8, 1973, fo information on possible dealer liability for a nonfunctional odometer and for failure to make an odometer disclosure statement in connection with your purchase of a 1970 Pontiac Lemans on March 29, 1973.; Title IV of the Motor Vehicle Information and Cost Savings Act of 197 became effective January 18, 1973, and made it unlawful to reset or alter the odometer of any motor vehicle with the intent to change the numers (sic) indicated thereon. It would not be a violation of the Act if either dealer sold the vehicle without repairing the odometer, or repaired the odometer without resetting the mileage prior to sale. If, however, it can be proved that the odometer was reset by either dealer after January 18, 1973, you may have cause of action under 409(a) of the Act for $1,500 or three times the amount of damages you actually sustained.; On March 1, 1973, regulations implementing the Act became effective an made it unlawful for a transferor of a motor vehicle to fail to make an odometer disclosure to his transferee, or to give a false statement in making a disclosure. A signed statement from the transferor to the transferee must be executed prior to the transfer of the vehicle, disclosing the cumulative mileage on the odometer, and indicating that the reading is inaccurate if the transferor knows such to be the case.; Ralph King's may be liable for its failure to make a statement if i could be proved that it knew of the disclosure obligation and purposely failed to make the statement with intent to defraud Crown. The bookkeeper's belief that March 15, 1973, was the effective date would appear to make proof of fraudulent intent difficult.; Crown's mileage statement is deficient in several respects. It was no made prior to the transfer and it was not completed and dated. If Crown bought the car with the odometer still inoperative or with notice of the inaccurate mileage reading, Crown was also required to check the box indicating that the odometer reading was inaccurate.; To obtain a recovery against either dealer under the provisions of th Act for failure to make the required statement or for a false statement, you must prove that the dealer knew of its disclosure obligation and ignored it in an attempt to defraud its transferee.; I am enclosing a copy of the Act and regulations. You may find i advisable to consult an attorney concerning your rights in this matter.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3483OpenMr. T. Fumima, President, Taiyo Trading USA Inc., 1543 West Olympic Boulevard, Los Angeles, CA 90015; Mr. T. Fumima President Taiyo Trading USA Inc. 1543 West Olympic Boulevard Los Angeles CA 90015; Dear Mr. Fumima: This responds to your letter of June 17, 1981, asking about th applicability of Federal motor vehicle safety standards to a manually operated door opener that you are considering importing. The door opener is designed for passenger cars and taxis and allows the driver to open the rear door by shifting a lever located by the driver's side.; By way of background information, the agency does not give approvals o vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. We note that the term 'manufacturer' is defined by section 102(5) of the Act to mean 'any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, *including any person importing motor vehicles or motor vehicle equipment for resale*.' Emphasis added. ; The agency does not have any regulations covering manually operate door openers. However, installation of such a device may affect a vehicle's compliance with other safety standards. If any standard would be affected, it would probably be Safety Standard No. 206, *Door Locks and Door Retention Components*. For your convenience, we have enclosed a copy of that standard, which includes performance requirements for a vehicle's latch and striker assembly, door hinges, and door locks. However, based on the limited drawings included with your letter, it is not possible for us to determine whether a vehicle's compliance with that standard would be affected. We suggest that you carefully examine the requirements of Standard No. 206 to make that determination.; If your device is added to a new motor vehicle prior to its first sale the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. You will find the specific certification requirements for alterers at 49 CFR Part 567.7, *Certification*. On the other hand, you as the manufacturer of the device would have no certification requirements, because we have no safety standards applicable to your equipment. However, an alterer would probably require information from you in order to make the necessary certification.; If your device is installed on a used vehicle by a business such as garage, the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, which states in relevant part:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard.<<<; Please feel free to contact us if you have any further questions. Yo may also wish to check with state and local authorities to determine whether the use of your device is affected by their regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4346OpenMs. Deborah Rutan, Director of Marketing/Research, The Rutabaga Co., Inc., P. O. Box 413, 605 Robson Street, Winona Lake, IN 46590; Ms. Deborah Rutan Director of Marketing/Research The Rutabaga Co. Inc. P. O. Box 413 605 Robson Street Winona Lake IN 46590; Dear Ms. Rutan: This responds to your letter seeking an interpretation of Federal Moto Vehicle Safety Standard No. 213, *Child Restraint Systems* (49 CFR S571.213, copy enclosed). Specifically, you sought our 'comments and recommendations' on a child harness/vest that your company has developed. I am pleased to have this opportunity to explain our statute and regulations to you.; As you noted in your letter, your product is a 'child restraint system within the meaning of section S4 of Standard No. 213. this means that it is subject to all applicable requirements of the standard. From the pictures and descriptions of your harness/vest included with your letter, it appears that the harness/vest would have to be modified to comply with four particular requirements in Standard No. 213.; The first requirements with which you harness/vest does not appear t comply is set forth in section S5.4.3.4(b) of Standard No. 213. That section provides that each child harness shall 'provide lower torso restraint by means of lap and crotch belt.' The pictures of your harness/vest show that it does *not* include a crotch belt to restrain the child's lower torso. You will have to modify the design of the harness/vest to include a crotch belt in order for your harness/vest to comply with the requirements of Standard No. 213.; The second requirement with which your harness/vest may not comply i the flammability resistance requirement incorporated in section S5.7 of Standard No. 213. That section provides, 'Each material used in a child restraint system shall conform to the requirements of S4 of FMVSS No. 302.' I have enclosed a copy of Standard No. 302 for your information. As you will see, that standard requires that subject materials be resistant to flammability. You stated in your letter that the 'vest fabric is a strong, yet lightweight, polyester jersey knit.' It is not clear from this description if you knew your company has to certify that this vest fabric complies with the flammability resistance requirements specified in Standard No. 213.; The third and fourth requirements with which your harness/vest does no appear to comply are the labeling requirements in S5.5 of Standard No. 213 and the installation instructions in S5.6 of Standard No. 213. Both these requirements specify that certain information must be provided with each child restraint system. In the case of the labeling information, you are required to permanently label your harness/vest with the information specified in S5.5.2(a) through (1). Further, S5.5.3 requires that the information specified in S5.5.2(g) through (k) shall be located on the child restraint system so that it is visible when the system is properly installed in a vehicle. In the case of the installations instructions, S5.6.6 requires that the harness/vest have a location on it for storing your installation instructions. This could be satisfied by adding a pouch to the vest for storing these instructions.; In addition to these requirements, you would have to determine that th harness/vest complies with all the performance requirements set forth in S5 of Standard No. 213. Once you have made such a determination, you are required to certify that each harness/vest you manufacture satisfies all applicable requirements of Standard No. 213. This agency does not require that a manufacturer's certification be based on a specified number of tests of the child restraint, or any tests at all. Pursuant to the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et Seq.*), we only require that a manufacturer's certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer in the first instance to determine what data, test results, or other information it needs to enable it to certify that its child restraint system complies with Standard No. 213. We would certainly recommend, however, that a manufacturer selling a new child restraint system test the system in accordance with the test procedures specified in Standard No. 213. Once you determine that your harness/vest complies with all requirements of Standard No. 213, you would certify that compliance by placing a certification label on the harness/vest, as specified in section S5.5 of the standard.; You should also be aware of the fact that you will be a manufacturer o motor vehicle equipment if you manufacture your harness/vest for sale. As such, you will be subject to the requirements or sections 151- 159 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1411-1419), concerning the recall and remedy of products that either do not comply with an applicable safety standard or have defects related to motor vehicle safety. If it were determined that your harness/vest did not comply with a requirements of Standard No. 213 or that it had a defect related to motor vehicle safety, your company as the manufacturer would have to notify all purchasers of the noncompliance or defects and either:; >>>1. repair the harness/vest so that the noncompliance or defect wa removed, or<<<; >>>2. replace the harness/vest with an identical or reasonabl equivalent product that does not have the noncompliance or defect.<<<; Whichever of these options were chosen, your company as th manufacturer would have to bear the full expense of the notification and remedy. This means you could not charge the owners of the harness/vests anything for the remedy if those harness/vest were purchased less than eight years before the notification campaign.; If your decide to manufacture these harness/vests for sale, you shoul also be aware of 49 CFR Part 566, *Manufacturer Identification* (copy enclosed). This regulation requires a manufacturer of child restraint systems to submit its name, address, and a brief description of the child restraints it manufactures to this agency within 30 days of the date the child restraints are first manufactured.; Finally, I would like to make clear that this discussion of ou requirements is not an agency 'recommendation'. NHTSA does not offer its opinion as to the value or practicality of any motor vehicles or motor vehicle equipment. When we are presented with questions from potential manufacturers of new vehicles or items of equipment, such as your harness/vests, we only explain how our statute and regulations would apply to the new product. It is up to the individual manufacturer to assess the value and practicality of its product.; If you have any further questions or need more information on thi subject, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202)366-2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0305OpenMr. Thomas S. Pieratt, Executive Secretary, Distributors Association, P.O. Box 11088, Cincinnati, OH 45211; Mr. Thomas S. Pieratt Executive Secretary Distributors Association P.O. Box 11088 Cincinnati OH 45211; Dear Mr. Pieratt: This is in response to your letter of March 1, 1971, in which yo inquired whether a 'crew-cab' truck is classified as a multipurpose passenger vehicle or a truck.; You said in your letter, 'It was our reasoning that the prime purpos of an MPV was to carry passengers, rather than to haul something, and that the addition of a crew cab which would accommodate an additional three persons, onto a chassis-cab which contains a dump body or utility body would not necessarily change the classification.'; The above statement is essentially correct. A crew-cab truck combine the purposes of both a multipurpose passenger vehicle and a truck. Where a vehicle has a significant capability for carrying either persons or cargo, its manufacturer may exercise his own discretion in classifying the vehicle.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2338OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your March 24, 1976, letter concerning the labe required by S 567.4(g) of 49 CFR Part 567, *Certification*.; The certification label is required by paragraph (g)(3) to includ ''GROSS VEHICLE WEIGHT RATING' or 'GVWR' followed by the appropriate value in pounds...' Paragraph (g)(4) specifies a similar requirement for Gross Axle Weight Ratings.; You have pointed out that the Canadian motor vehicle safety regulation require a similar certification label with these weight ratings expressed in kilograms. You have asked whether a single label that expresses the weight ratings in both pounds and kilograms would be permitted by 49 CFR Part 567. The answer is yes, provided that each kilogram rating, which is optional, appear after the corresponding pound rating, which is required.; Please note that these two ratings differ in legal status. The ratin that is expressed in pounds is the official rating for the purposes of the United States Federal motor vehicle safety standards and regulations. The accompanying equivalent kilogram rating, however, will be considered as optional, supplementary information provided for the guidance of the reader. This distinction is necessary, because the measurement values, including weights, that appear in our safety standards and regulations are specified in exact terms, without tolerances. While a measurement in English units can be 'equal' to one in metric units to any preselected number of significant figures, the two can never be exactly equal.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam5107OpenMr. Curtis J. Crist Product Development US Marine P.O. Box 9029 Everett, WA 98206; Mr. Curtis J. Crist Product Development US Marine P.O. Box 9029 Everett WA 98206; Dear Mr. Crist: This responds to your letter of December 10, 1992, i which you ask for confirmation that the provisions of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108 relating to front side marker lamps for boat trailers remain unchanged from interpretations provided by this Office in 1976 and 1977. I am pleased to confirm that these requirements remain the same. Paragraph S4.3.1.3, however, was renumbered S5.3.1.3 several years ago. You have also asked as to what action you must take for elimination of the requirement for rear identification lamps on boat trailers 80 or more inches in overall width. You may file a petition for rulemaking requesting this change. I enclose a copy of 49 CFR Part 552, the regulation governing these petitions, which will advise you as to these procedures. Section 552.4 sets forth the information that the petition should contain, and the address to which it must be sent. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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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.