NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam1955OpenMr. Mack Emmons, Emmons Brothers, P.O. Box 186, Meridian, MS, 39301; Mr. Mack Emmons Emmons Brothers P.O. Box 186 Meridian MS 39301; Dear Mr. Emmons: This is in response to your letter of May 1, 1975, concerning Federa Motor Vehicle Safety Standard No. 302, Flammability, and in amplification of your telephone conversation with Mr. Schwartz of my office.; As Mr. Schwartz advised you, Standard No. 302 applies to passenge cars, multipurpose passenger vehicles, trucks, and buses. Thus, the standard would apply to mattresses used in trucks. Further, it has been proposed to extend Standard No. 302 to campers and trailers other than those sold exclusively for the transportation of cargo (copy enclosed). Consequently, as you requested, I have enclosed a copy of Motor Vehicle Safety Standard No. 302, a recent amendment to that standard, and a proposed amendment which may also be of interest to you.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5445OpenMr. Gerald J. Gannon General Motors Corporation Legal Staff N Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit, MI 48232; Mr. Gerald J. Gannon General Motors Corporation Legal Staff N Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit MI 48232; Dear Mr. Gannon: This responds to your letter asking whether NHTS intended, in a recent final rule, 'to require that vehicles with an automatic transmission with a 'park' provision must prevent steering after removal of the key in order to have an ignition key-operated transmission shift override device?' You stated that the final rule might be interpreted to produce that result, but argued, based on the preamble, that a more limited result was intended. You suggested that a clarifying amendment would be appropriate. We apologize for the delay in our response. After reviewing your letter, we have concluded that the issue you raise should be addressed in rulemaking. We anticipate that a notice addressing this issue will be issued shortly. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2380OpenMr. Tokio Iinuma, Staff, Safety, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, New Jersey 07632; Mr. Tokio Iinuma Staff Safety Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs New Jersey 07632; Dear Mr. Iinuma: This is in response to your January 26, 1976, question whether Standar No. 124, *Accelerator Control Devices*, requires that the throttle return to the 'idle position' within specified time limits in the case where an 'automatic speed control device' is in operation and a failure occurs in it.; The requirements of S5.1 and S5.2 of the Standard require a return o the throttle to the idle position when either one source of throttle 'return energy' or a component of the accelerator control system fails or is disconnected. In the case you describe, failure does not occur as outlines in S5.1 and S5.2. Therefore, this failure is not regulated by the standard. This is the case, because the NHTSA does not consider throttle-setting devices to be a component that 'regulate[s] engine speed in direct response to movement of the driver-operated control and that return[s] the throttle to the idle position upon release of the actuating force' as defined in S4.1. As set out in the definition of 'idle position', the agency considers the effect of a throttle-setting device to be a separate condition that affects the setting of the accelerator control system.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0217OpenMr. Georges Siwac, Sofica, Division De La Societe Anonyme Francaise Du Ferodo, 24 Rue Des Pavillons, 92 - Puteaux (France); Mr. Georges Siwac Sofica Division De La Societe Anonyme Francaise Du Ferodo 24 Rue Des Pavillons 92 - Puteaux (France); Dear Mr. Siwac: I regret our delay in responding to your letter of December 2, 1969 which evidently became lost after it reached us.; In your letter you ask three questions. The questions, and our answer to them, are as follows:; >>>1. If a European concern manufactures seat belts for installation i vehicles imported into the United States, is the vehicle manufacturer or the seat belt manufacturer responsible for compliance with Motor Vehicle Safety Standard No. 209 with respect to those seat belts? It is our view that both manufacturers are responsible for compliance with the standard. Section 108(a) of the National Traffic and Motor Vehicle Safety Act prohibits the manufacture for sale in the United States of a nonconforming vehicle or item of motor vehicle equipment. A seat belt manufactured for installation on a motor vehicle to be sold in the United States is itself manufactured for sale in the United States. The manufacturer of the motor vehicle in which the nonconforming seat belt is installed would be in violation of section 108(a) because Motor Vehicle Safety Standard No. 208 requires certain motor vehicles to be equipped with seat belt assemblies that conform to Standard No. 209.; 2. Is a foreign manufacturer of seat belts which will be imported int the United States required to test the belts at approved facilities in the United States to demonstrate that they conform to Standard No. 209? The answer is no. There is no requirement in the law or the standard that seat belts must be subjected to approved tests before they can be imported and sold. The manufacturer must certify that the belts conform to the standard. In order to do so, a manufacturer would ordinarily make tests of his products. This is particularly the case because compliance with some of the standard's requirements can be ascertained only by actual tests of seat belts. However, there is no requirement that any particular test be made at any specific test facility.; 3. Must a European seat belt manufacturer designate an agent fo service of administrative process under section 110(e) of the National Traffic and Motor Vehicle Safety Act if he is merely supplying the belts for installation as original equipment in motor vehicles to be imported into the United States. It is our view that a foreign manufacturer of motor vehicle equipment who knows or has reason to know that his products will be imported into the United States, whether as original equipment on motor vehicles or otherwise, is obligated under section 110(e) to designate an agent for service of process in accordance with that section. Section 110(e) is not limited in its scope to manufacturers who actually import their products, it also applies to manufacturers who are 'offering a motor vehicle or item of motor vehicle equipment for importation into the United States'. The quoted language seems broad enough to cover suppliers of motor vehicle equipment who know or should know that the vehicles in which their products are installed will be imported for sale into the United States.<<<; Again, let me express my apologies for the delay in responding to you inquiry. If you have any further questions about your obligations under the National Traffic and Motor Vehicle Safety Act, please do not hesitate to contact me.; Very truly yours, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations; |
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ID: aiam5015OpenHerr Spingler Robert Bosch GmbH Geschaftsbereich K2 Entwicklung Lichttechnik Systeme Postfach 13 42 D-4710 Reutlingen Germany; Herr Spingler Robert Bosch GmbH Geschaftsbereich K2 Entwicklung Lichttechnik Systeme Postfach 13 42 D-4710 Reutlingen Germany; Dear Herr Spingler: This responds to your letter of April 3, 1992, t Mr. Van Iderstine of this agency asking for a 'quick answer' to your question regarding the acceptability of a new headlamp design. Please be advised that my Office is the one to which questions of interpretation of Motor Vehicle Safety Standard No. 108 should be addressed, and that correspondence addressed to the Chief Counsel allows us to respond more quickly to the concerns of the writer. We understand that you discussed the headlamp with Mr. Van Iderstine on his recent trip to Europe, and that it will be used in a replaceable bulb headlighting system that is governed by S7.5 of Standard No. 108. Your proposed headlamp incorporates a lower beam provided by an ellipsoid and an upper beam provided by a parabola. The drawing you enclosed shows the lower beam source above the upper beam source. When the upper beam is on, both bulbs will be activated simultaneously. Where, as in your design, each headlamp contains two light sources, S7.5(d)(2)(i)(A) and S7.5(e)(2)(i)(A) specify that the lower beam shall be provided by the outboard or uppermost light source. S7.5(d)(2)(ii)(A) and (B) and S7.5(e)(2)(ii)(A) and (B) specify that the upper beam shall be produced by the lowermost, or both, light sources. The beams in your headlamp are provided in this manner, and, therefore, are in accordance with the requirements of Standard No. 108. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam2800OpenMr. Philip P. Friedlander, Jr., National Tire Dealers & Retreaders Association, Inc., 1343 L. Street, N.W., Washington, DC 20005; Mr. Philip P. Friedlander Jr. National Tire Dealers & Retreaders Association Inc. 1343 L. Street N.W. Washington DC 20005; Dear Mr. Friedlander: This responds to your February 23, 1978, letter asking whether th National Highway Traffic Safety Administration's (NHTSA) interpretation concerning the registration of passenger car tires can be applied to the registration of truck tires. In that interpretation, the NHTSA stated that it was permissible for a tire dealer to allow the tire purchaser to fill out the tire registration form and hand it back to the dealer.; The NHTSA's interpretation is applicable to both truck and passenge car tires. A truck tire dealer may permit a purchaser to fill out the required information rather than completing the registration form himself. However, this all must occur at the point of sale of the tire. The registration forms for both passenger car tires and truck tires are not permitted to be taken home or shipped with the tires to be completed by the purchaser and subsequently returned or mailed to the dealer. This would impair the benefit of mandatory tire registration and make it a voluntary program. This is not the intent of the regulation, and the NHTSA would not consider such a registration program to be in compliance with the tire registration regulation.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3712OpenWilliam Shapiro, P.E., Manager, Regulatory Affairs, North American Car Operations, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; William Shapiro P.E. Manager Regulatory Affairs North American Car Operations Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro: This responds to your letter of May 24, 1983, requesting a interpretation concerning the retraction force requirements of Safety Standard No. 209, *Seat Belt Assemblies*. You are considering a Type 2 seat belt design which includes an emergency locking retractor for continuous loop webbing and an emergency locking retractor for additional webbing at the inboard buckle portion of the system. You state that this inboard webbing is extended only if the belt is used by an extremely large occupant. You ask whether the retraction force requirements of the standard allow testing with the webbing of the *entire system* extended 75%, i.e., even if this means that no webbing is extended from the inboard retractor, so that the retraction force is actually only measured from the retractor for the continuous loop portion of the belt.; Paragraph S4.3(j) of Safety Standard No. 209 specifies that a emergency locking retractor of a Type 1 or Type 2 seat belt assembly, when tested in accordance with the procedures specified in paragraph S5.2(j) shall:; >>>***** (4) exert a retractive force of at least 0.6 pound under zer acceleration when attached only to the pelvic restraint,; (5) exert a retractive force of not less than 0.2 pound and not mor than 1.1 pounds under zero acceleration when attached only to an upper torso restraint,; (6) exert a retractive force of not less than 0.2 pound and not mor than 1.5 pounds under zero acceleration when attached to a strap or webbing that restrains both the upper torso and pelvis.<<<; The test procedures of paragraph S5.2(j) specify that these retractio forces are to be measured with the belt webbing extended from the retractor to 75% of its length.; The requirements of S4.3(j) apply to *each* retractor on a Type 1 o Type 2 belt system. There is no exception in the standard for a system which includes two or more retractors which exert force on the same belt webbing. Thus, both retractors on your proposed system would have to comply with the requirements of the standard independently of one another. Under the test procedure you suggest, the retraction force of the inboard retractor would not be measured. This is contrary to the explicit language of the standard.; Both retractors on your proposed system would have to comply with th force requirements of paragraph S4.3(j)(6). This is true because both retractors are attached 'to a strap or webbing that restrains both the upper torso and the pelvis.' Therefore, the retraction force on your inboard retractor must be not less than 0.2 pound and not greater than 1.5 pounds when the webbing on that retractor is extended to 75% of its length. The same is true for the retractor on the continuous loop portion of the system.; I hope this has clarified any misunderstanding you might have ha concerning these requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3342OpenMr. Samuel W. Halper, Bartman, Braun & Halper, Suite 1015, 1880 Century Park East, Los Angeles, CA 90067; Mr. Samuel W. Halper Bartman Braun & Halper Suite 1015 1880 Century Park East Los Angeles CA 90067; Dear Mr. Halper: This responds to your letter of May 28, 1980, on behalf of Californi Strolee, Inc. (Strolee), to Stephen Oesch of my office and to the questions you asked during your meeting of August 7 with members of the agency's staff. Both your letter and your meeting concerned Standard No. 213, *Child Restraint Systems*. You asked whether Strolee's prototype child restraint, described in your letter and demonstrated at the meeting, must be tested in accordance with section 6.1.2.1.2 of the standard and, if so, whether the agency will attach the harness system of the child restraint during that testing. The answers are that the child restraint must be tested in accordance with section 6.1.2.1.2 and the agency will attach the harness during that testing.; Your May 29, 1980, letter, describing Strolee's future product plans requested confidentiality for Strolee's request for interpretation and the agency's response. At your August 7, 1980, meeting, you informed Mr. Oesch that Strolee had decided to withdraw its request for confidentiality.; The child restraint described in your letter and demonstrated to th agency has a movable shield. The shield is attached to each side of the restraint by a pivot mechanism, which has a spring that lifts the shield. Because the movable shield is spring-loaded, it must be mechanically held down or it will automatically raise the shield above the child's head. Attached to the lower part of the child restraint is a crotch strap with a buckle on one end. The crotch strap is intended to be manually passed through a loop mounted on the bottom of the movable shield and attached to the other portions of the five point harness system within the restraint.; The other portions of the harness system consist of two straps, eac strap serves as an upper and lower torso restraint. Each strap has a movable metal latchplate which is inserted into the buckle attached to the crotch strap.; Once the crotch strap is passed through the loop mounted on the shiel and attached to the harness system, the shield is held in place in front of the child. The five point harness system provides the primary restraint of the child, but the movable shield, which will be designed to comply with the shape and radius of curvature requirements of section 5.2.2.1(c) of the standard, also provides restraint in a crash.; Your first question was whether the child restraint must be tested i accordance with test configuration II specified in Section 6.1.2.1.2 of the standard. More specifically, the issue is whether the Strolee shield is the sort of restraining surface described in section 5.2.2.2. As explained below, the answer is yes. The Strolee child restraint will be tested in accordance with test configuration II. When tested in that configuration, it will not have its top tether attached.; Section 5.2.2.2 of the standard requires that: >>>Each forward facing child restraint system shall have no fixed o movable surface directly forward of the dummy and intersected by a horizontal line parallel to the SORL and passing through any portion of the dummy, except for surfaces which restrain the dummy when the system is tested in accordance with S6.1.2.1.2 so that the child restraint system shall conform to the requirements of S5.1.2 and S5.1.3.1.<<<; When the Strolee child restraint is used in accordance with th manufacturer's instructions, the crotch strap is passed through the loop on the movable shield and attached to the harness system. Once that action is taken, the movable shield is positioned in front of the test dummy. Although the five point harness system provides the primary restraint in the Strolee system, the shield also provides restraint. Therefore, the child restraint must be tested in accordance with section 6.1.2.1.2.; Your second question, raised during your meeting, was whether th agency would attach the crotch strap of the Strolee child restraint if the restraint must be tested in accordance with section 6.1.2.1.2. The answer is yes.; Section 6.1.2.3.1.(c) of the standard provides that in the 20 mph tes of forward facing child restraints with fixed or movable surfaces that restrain the child, the restraint system's belts are not to be attached 'unless they are an integral part of the fixed or movable surface.'; The crotch strap used in the Strolee child restraint is not an integra part of the movable shield. The movable shield is a complete unit by itself. The crotch strap is a separate device that must be manually passed through a loop mounted on the shield every time the unit is used.; The rationale for the integral belt requirement involves the principa misuse of child restraints, which is the failure to attach buckles. This failure is often associated with child restraints having movable surfaces that can be positioned in front of the child. Parents mistakenly assume that such surfaces by themselves would provide sufficient protection and thus do not buckle the harness system in the restraint. To reduce that misuse, the agency established the requirement that belts may be attached during the testing of restraints equipped with movable shields only if they are integral parts of the shield. Attachment of belts that are integral parts is permitted since they remain attached to the restraining shield whether or not the restraint is in use. In addition, the need to buckle those belts is more readily apparent than in the case of belts that are not integral parts of the shield. Thus, the integral belts are not subject to the type of misuse described above.; This rationale applies to belts on a child restraint having a movabl restraining shield that is not spring-loaded. It does not, however, apply to a nonintegral belt on a restraint having a spring-loaded movable shield, if that shield can be held in place only by attaching the nonintegral belt so as to fully and properly restrain the child. The Strolee spring-loaded movable shield will not stay in place in front of the child unless the crotch strap is attached. If the crotch strap is not fastened to the remaining portions of the Strolee child restraint, the movable shield automatically rises above the child's head to signal that the buckle is unfastened and the child is unrestrained. Requiring the crotch strap to be an integral part of the movable restraining shield is unnecessary if the movable shield can only be positioned in front of the child when the child is properly restrained.; The agency originally had several concerns about whether the movabl shield in the Strolee child restraint could be positioned in front of the child without fully and properly restraining the child. One concern was whether the crotch strap and buckle could be passed through the loop mounted on the shield without attaching it to the remaining portion of the harness and the weight of the buckle would hold the shield in place in front of the child. At the meeting, you explained that the large buckle used on the prototype was for demonstration purposes only. Strolee demonstrated a smaller, lighter push-button buckle which would be used on production models and which could not hold down the movable shield by its own weight.; Another concern was whether the crotch strap and buckle could be passe through the loop on the movable shield and attached to only one of the two remaining straps of the harness system. Thus, the shield could be in front of the child, but the child would not be fully and properly restrained because a portion of the five-point harness system would not be connected. An examination of current restraint systems should show that one child restraint is already using a similar type of five-point harness as used in the Strolee system. The agency has not received any reports that parents are connecting only one half of that harness system. In addition, the need to connect both straps is readily apparent, since the buckle on the crotch strap has a separate receptacle for the latchplate on each belt.; The agency is still concerned about the durability of a spring-loade system such as Strolee's. To properly perform its function, the spring must have sufficient force to slowly but repeatedly, raise the movable shield. Further, child restraints are traditionally handed down from child to child and family to family. We, therefore, urge Strolee to design the spring so that it will have sufficient durability to withstand at least several years of repeated use.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4487OpenMr. L. T. Mitchell Specification Engineer Thomas Built Buses, L.P. P.O. Box 2450 1408 Courtesy Road High Point, NC 27261; Mr. L. T. Mitchell Specification Engineer Thomas Built Buses L.P. P.O. Box 2450 1408 Courtesy Road High Point NC 27261; "Dear Mr. Mitchell: This is a response to your letter asking whether i is permissible to install only two seat belts on a 39-inch bench-seat in a school bus with a gross vehicle weight rating (GVWR) of 10,000 pounds or less (small school bus). I apologize for the delay in this response. The answer is no. You stated that Thomas Built Buses (Thomas) would like to accommodate certain customers who wish to have two designated seating positions on each 39-inch bench-seat installed in a small school bus 'for passenger comfort reasons.' Your letter sets forth a suggested rationale as to why Thomas believes such a configuration would be permissible in small school buses. First, you argued that a May 11, 1978 interpretation of Standard 217, Bus Window Retention and Release, states that Federal motor vehicle safety regulations do not prohibit having only two-passenger seating positions on a 39-inch bench-seat in a bus designed for adult transportation. In these circumstances, we said, a manufacturer has some discretion to decide the number of designated seating positions in its vehicles, but must make a good faith determination of the vehicle's passenger capacity to discourage vehicle overloading. You reason that because the term 'designated seating position' is in the Definitions section of the Federal safety standards (49 CFR 571.3), the definition applies to all safety standards. You apparently conclude that our earlier interpretation of Standard 217 and the definition of 'designated seating position' in 571.3 permit a manufacturer to make a good faith determination respecting the number of seating positions on a school bus. Based on this conclusion, you posited two situations in which this reasoning might be applied. Situation 1 was described as follows in your letter: Thomas Built Buses interprets (the May, 1978, interpretation) to be applicable for a school bus sold to carry only high school students. We consider the use of two seat belts on a 39 inch seat to be reasonable and justified due to passenger size making three passengers on one 39' seat impossible. We would honor a purchaser's request to equip these 39' seats with two belts each. Is this interpretation correct? This interpretation is incorrect for several reasons. First, the earlier interpretation did not apply to school buses, by its own terms, it is clearly limited to buses other than school buses. Second, there is not a separate set of standards that specify differing requirements for school buses designed to carry high school students. In determining whether school bus standards apply to a vehicle designed to carry 11 or more persons, the proper inquiry is whether the bus is sold to carry 'primary, preprimary, or secondary school students' to or from school or school-related events. Any vehicle that meets this definition of the term 'school bus' must comply with all applicable school bus standards, regardless of whether it is designed to carry small children to kindergarten or teenagers to high school. Third, the definition of 'designated seating position' and our interpretations of that term, are not relevant in determining whether a school bus bench-seat in a small school bus complies with the requirements of Standard 222. Paragraph S4.1 of Standard 222 sets out a specific procedure for calculating the number of seating positions in a bench seat. That paragraph explains that the number of seating positions on a bench seat in school buses is calculated by (1) measuring the width of the bench seat in inches, (2) dividing by 15, and (3) rounding to the nearest whole number. The value which results from this calculation (expressed by the term 'W') is the basis for determining whether the seat complies with the requirements of Standard 222. For a 39-inch bench-seat, the procedure in S4.1 shows that this seat has three seating positions. Paragraph S5(b) of Standard 222 therefore requires that this bench-seat have three seat belt assemblies installed. Therefore, if your company were to install only two seat belt assemblies on a 39-inch wide bench-seat in a small school bus, you could not certify that the vehicle complies with Standard 222. For these same reasons, your interpretation set forth in your 'Situation 2' is also incorrect. Even if a customer specifically asks that only two seat belt assemblies be installed on 39-inch bench seats, Standard 222 requires your company to equip these seats with three seat belt assemblies. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam0997OpenMr. Stan Haransky, Associate Director, Truck Body and Equipment Assoc., 5530 Wisconsin Avenue, Suite 1220, Washington, D.C. 20015; Mr. Stan Haransky Associate Director Truck Body and Equipment Assoc. 5530 Wisconsin Avenue Suite 1220 Washington D.C. 20015; Dear Stan: This is in reply to your letter of January 8, 1973, concerning th application of Standard No. 124, 'Accelerator Control Systems', to auxiliary throttles mounted inside or outside of the cab and used exclusively while the vehicle is in a stationary position to insure proper engine speed for the operation of pumps, elevating platforms, and similar equipment. Since the definition of 'idle position' was amended to provide for the use of throttle positioners in 37 F.R. 20035 (September 23, 1972), the auxiliary throttles described are not subject to the requirements of the standard.; Yours truly, Richard B. Dyson, Assistant 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.