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: aiam3278OpenMr. Samuel W. Halper, Bartmen, Braun & Halper, Attorneys at Law, 1880 Century Park East, Suite 1015, Los Angeles, CA 90067; Mr. Samuel W. Halper Bartmen Braun & Halper Attorneys at Law 1880 Century Park East Suite 1015 Los Angeles CA 90067; Dear Mr. Halper: This responds to your letter of March 13, 1980, asking severa questions about Standard No. 213, *Child Restraint Systems*, on behalf of California Strolee, Inc.; I would first like to correct an apparent misunderstanding you hav about remarks made by Mr. Hitchcock in a meeting with you and Mr. Richard Hyde of Strolee. Mr. Hitchcock's remarks were to the effect that the agency encouraged beneficial innovations in child restraints and would be receptive to amending the standard to remove any restrictions to beneficial innovations. Any amendments to the standard would be made in accordance with the requirements of the Administrative Procedures Act. The agency does not engage in 'ad hoc' rulemaking procedures.; The following are the responses to the fourteen questions you asked. 1. You asked how the minimum surface area requirements set in sectio 5.2.2 for the sides and back of child restraints are to be measured. You were specifically concerned about measuring 'curved surfaces, without some guidelines, the exact place where the side stops and the back begins cannot be ascertained.' The area's measurements can be determined by positioning the appropriate test dummy in the restraint. The area within the dummy's outline projected directly rearward and the areas within the dummy's torso outline projected directly sideward must comply with the minimum surface area for the back and sides of the restraint.; 2. You are correct that section S5.2.2.1(c) only requires a minimu radius of curvature and does not establish a minimum surface area for fixed or movable surfaces in front of the child. The agency encourages manufacturers to utilize designs with large surface areas at least equivalent to the shield designs incorporated in some current restraints.; 3. You asked whether shoulder belt grommets are prohibited by sectio 5.2.3.2. In response to Strolee's petition for rulemaking on section 5.2.3.2, the agency has amended the section to permit the use of grommets that comply with the protrusion limitation requirements of section 5.2.4.; 4. You raised a question about whether section 5.4.3.3 requires the us of a five-point belt system. The agency's intent was to allow the use of hybrid systems, which for example, might use upper torso restraints, a crotch strap and a shield instead of a lap belt. Thus, the agency provided in section 5.4.3.3(c) that a crotch strap must connect to the 'lap belt or other device used to restrain the lower torso.' The agency established the minimum radius of curvature requirements of section 5.2.2.1(c) to ensure that any surface used in place of a lap or other belt would not concentrate forces on a limited area of the child's body. The recent notice on the standard, appearing in the Federal Register of May 1, 1980, amends the standard to clarify section 5.4.3.3.; 5. You objected to the buckle force requirements set in section 5.4.3. as being too high. The goal of that section is to prevent young children from opening the buckles while ensuring that adults can do so. As explained in the December 1979 final rule, section 5.4.3.4 is based on research done by the National Swedish Road and Traffic Institute. The research showed that young children could not open a buckle requiring a release force of 12 or more pounds, but could open buckles requiring a lower release force. That same research found that buckles requiring a release force greater than 20 pounds would be difficult for adult women to open. The agency is not aware of any research contradicting the Swedish study and no commenter to the docket submitted any data showing that the Swedish study is inaccurate.; 6. You asked for an interpretation of the words 'integral' an 'position' as those words are used in section 6.1.2.3.1(c) and 6.1.2.3.2(c). Amended Standard 213 is intended to address, among other things, the problem of misuse of child restraints. The principal misuse involves the failure to attach buckles and latches. To ensure that children using child restraints are afforded protection notwithstanding such misuse, the standard specifies that the belts are to be attached to restraining shields during testing only if they are integral parts of the shields. Webster's New Collegiate Dictionary (1977) defines 'integral' as meaning 'formed as a unit with another part.' Attachment of belts that are integral parts is permitted since they are intended to remain attached whether or not the restraint is in use and thus are not subject to the type of misuse described above.; The word 'position' was also used in its common dictionary sense t mean put in place or arrange. Thus during the test, each movable surface will be put into place in accordance with the manufacturer's instruction. The positioning requirements only apply to the arrangement of the movable surface and does not permit the attachment of any belts that are not an integral part of the movable surface.; 7. You stated section 6.1.2.4 is inconsistent with S6.1.2.3.1 an 6.1.2.3.2 because 6.1.2.4. supposedly allows attachment of the restraint system's belts, while sections 6.1.2.3.1 and 6.1.2.3.2 do not allow belts to be attached that are not an integral part of a fixed or movable surface.; Your interpretation is not correct. Section 6.1.2.4 sets specification for tightening the restraint system's belts, prior to the sled test. However, both sections 6.1.2.3.1 and 6.1.2.3.2 provide that the belt adjustment requirements of section 6.1.2.4 are not to apply to belts that are not an integral part of the fixed or movable surface.; 8. You asked how the agency defined 'target point' as that term is use in section 5.1.3.2. Section 5.1.3.2 requires that 'no portion of the target point on either side of the dummy's head' shall pass through two specified planes during the sled test. The agency used the term 'target point' to refer to the center of the target on the side of the test dummy's head. THe location of the target is specified in the engineering drawing incorporated in part 572, *Anthropomorphic Test Dummies*, Subpart C.; 9. You asked whether the standard establishes strength specification for belts. Section 5.4 establishes performance requirements that the belt systems used in child restraint systems must meet. The section does not establish specific breaking strengths for the belts, other than the requirement in section 5.4.1(a) that after being subjected to 'the abrasion requirements of Standard No. 209, *Seat Belt Assemblies*, the belts must have a breaking strength of not less that 75 percent of the strength of the unabraided webbing....' Of course, belts which are to be attached during testing must not break during the test if the effect of the breakage is to cause a violation of section 5.1.2 and 5.1.3.; 10. You expressed concern about 'the difficulty in running qualit control tests where the buckle hardware is not subject to specifications, but only performance standards.' The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391) only authorizes the agency to issue requirements that are as performance oriented as possible. The Act places responsibility on a manufacturer to devise its own specifications which will ensure that its product performs as required.; 11. You asked our opinion whether the Waterbury buckle complies wit Standard No. 213. THe agency does not issue opinions as to whether a particular design does or does not comply with the requirements of a standard. Under section 114 of the Vehicle Safety Act, manufacturers must certify that they comply with all applicable federal standards.; 12. We have answered your questions concerning the use of soft foa armrests or trays in our earlier letter of April 17, 1980.; 13. You asked whether 'a buckle affixing the crotch strap to some othe portion of the car seat must comply with the tension (sic) requirements of section 5.4.3.5. That section provides that 'Any buckle in a child restraint system belt assembly designed to restrain a child using the system shall' meet specified buckle release requirements. Since a crotch strap is used in a child restraint system to restrain the child, a buckle used with the crotch strap must comply with the requirements of section 5.4.3.5.; 14. You raised a question about the safety of buckles that 'do not sna or latch, but rather require the turn of a knob to seal them together.' Your concern is that the knob may not be fully turned and thus the buckle may not be fully latched. Any buckle, regardless of its specific design must comply with the release requirements of section 5.4.3.5. In the preamble to the December 1979 final rule, the agency encouraged manufacturers to use push button buckles, similar to those used in automobile belts, so that people unfamiliar with child restraints can readily unbuckle them in emergencies. Use of push button buckles would also solve the potential problems of incomplete latching that may be associated with knob-type buckles.; If you have any additional questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4047OpenMr. Hisashi Tsujishita, Chief Co-ordinator, Technical Administration Deptartment, Daihatsu Motor Co., Ltd., 1.Daihatsu- Cho, Ikeda City, Osaka Prefecture, JAPAN; Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Deptartment Daihatsu Motor Co. Ltd. 1.Daihatsu- Cho Ikeda City Osaka Prefecture JAPAN; Dear Mr. Tsujishita: This is in further response to your letter of July 15, 1986, in whic you asked a number of questions concerning our standards and regulations. This responds to your question about Part 585, *Automatic Restraint Phase-In Reporting Requirements*. I hope the following discussion answers your question.; You asked about the requirement in Part 585.5(a)(4) of the regulation That section provides that a manufacturer's report 'contain a statement regarding the extent to which the manufacturer has complied with the requirements of S4.1.3 of Standard No. 208.' You explained that you did not understand what that sentence means and asked whether your sample report conformed to the requirement of the regulation.; S4.1.3 of Standard No. 208 provides for the phasing-in of the automati restraint requirement and sets certain percentage of passenger car production requirements that each manufacturer must meet.; The purpose of Part 585.5(a)(4) is to have each manufacturer state t what degree or extent it has met the applicable phase-in requirement. Thus, a statement, such as the one contained in your sample report, which sets out the percentage of your vehicles produced during an applicable reporting period that comply with the automatic restraint phase-in requirements of the standard would meet the requirement of Part 585.5(a)(4).; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3782OpenThe Honorable Tom Ridge, House of Representatives, Washington, D.C. 20515; The Honorable Tom Ridge House of Representatives Washington D.C. 20515; Dear Mr. Ridge: This responds to your letter of November 28, 1983, requestin information on behalf of your constituent, Mr. William H. Hull, Sr. Mr. Hull is concerned about the growing practice of persons installing darkly tinted film on passenger car windows. He believes that this is a dangerous practice because it prevents police officers from seeing inside the vehicles. You asked if we were considering the issuance of a regulation outlawing the use of such film and, if so, when such a regulation might be promulgated.; While our authority under the National Traffic and Motor Vehicle Safet Act (the Act) enables us to limit the practice of installing tinted film on vehicle windows, it does not permit us to issue a regulation prohibiting every individual from engaging in that practice. As explained below, while commercial establishments are prohibited from adding the film, we cannot prohibit a vehicle owner from doing so.; Pursuant to the the (sic) Act, we have promulgated Federal Moto Vehicle Safety Standard No. 205, *Glazing Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance. This specification for light transmittance precludes darkly-tinted windows in new automobiles.; Tinting films such as the type referred to in Mr. Hull's letter are no glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard.; A vehicle manufacturer or a dealer may place the film on glazing in new vehicle prior to sale of the vehicle only if that manufacturer or dealer is able to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Purchasers of a new vehicle may alter the vehicle as they please, so long as they adhere to all State requirements.; However, vehicle owners may not go to a commercial establishment t have the film installed for them. Section 108(a)(2)(A) of the Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. Thus, none of those persons may knowingly install a film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.; The individual States must govern the operational use of vehicles b their owners since the agency does not have authority in this area. Thus, it would be up to the States to preclude owners from applying films or one-way glass on their own vehicles. Mr. Hull may wish to contact the National Committee on Uniform Traffic Laws (555 Clark Street, Evanston, IL 6-2-4) to find out which States have laws that would preclude owners from placing tinting film on their automobile windows.; Sincerely, Diane K. Steed |
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ID: aiam2890OpenMr. Michael Pinto, Burke & Burke, 30 Rockefeller Plaza, New York, NY 10020; Mr. Michael Pinto Burke & Burke 30 Rockefeller Plaza New York NY 10020; Dear Mr. Pinto: This is in response to your letter of October 25, 1978, requestin approval of the tread labels Atlas Supply Company proposes to use in satisfaction of the labeling requirements of the Uniform Tire Quality Grading Standards (UTQGS) (49 CFR 575.104(d)(1)(i)(B)). You propose to include the applicable UTQGS grades for a particular tire on a tread label identifying the tire brand, type and size. All possible traction and temperature grades would be depicted with the grades applicable to the specific tire indelibly circled. A separate label would contain the general grading information from Figure 2 of the rule.; Part 575.104(d)(1)(i)(B) requires that each passenger car replacemen tire, other than a snow tire or temporary use spare tire, have affixed a tread label containing both the specific UTQGS grades for the tire and an explanation of the grades in the form illustrated in Figure 2. While the National Highway Traffic Safety Administration (NHTSA) has no objection to the inclusion of the required UTQGS information on the same label with other data such as tire size and brand name, failure to provide the required explanations on the same label with the applicable tire grades is not permitted by the regulation.; While Atlas' proposed tread labels do not meet the present requirement of Part 575.104(d)(1)(i)(B), NHTSA now has under consideration a petition for rulemaking requesting amendment of the UTQG regulation to permit greater flexibility in tread labeling.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3852OpenMr. H. Nakaya, Branch Manager, Mazda (North America), Inc., 23777 Greenfield Road, Suite 462, Southfield, MI 48075; Mr. H. Nakaya Branch Manager Mazda (North America) Inc. 23777 Greenfield Road Suite 462 Southfield MI 48075; Dear Mr. Nakaya: This responds to your letter dated January 20, 1984, concerning Federa Motor Vehicle Safety Standard (FMVSS) No. 101, *Controls and Displays*. You asked whether the standard would allow 'a secondary, redundant control placed in the rear seat area facilitating operation of the heating/ventilation and audio system functions by rear seat passengers.' As explained below, the answer to your question is yes.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not pass approval on the compliance of any vehicle or equipment with a safety standard before the actual events that underlie certification. Under the Vehicle Safety Act, it is your responsibility as a manufacturer to determine whether your vehicles and equipment comply with all applicable safety standards and regulations, and to certify your products in accordance with that determination. The following interpretation only represents the agency's opinion based on the information provided in your letter.; Your letter indicates that controls for the heating and ventilatio unit would be placed in the rear seating area. You stated that these controls would be 'redundant' and 'secondary.' NHTSA assumes that there will be additional controls for the various functions of the units that are operable by and visible to the driver of the vehicle which meet all applicable requirements of Standard No. 101.; Section 5.2.1 requires identifications of any hand-operated contro listed in column 1 of Table 1 of that section to be visible to the driver. Listed in column 1 are 'Heating and/or Air Conditioning Fan,' and 'Heating and Air Conditioning System.'; You asked about illumination requirements in section 5.3 of FMVSS No 101 that might apply. Again, this section is intended to regulate the controls and displays operable by and visible to the driver, not the controls located in the rear seating area.; In requiring properly located and effectively identified controls an displays under FMVSS No. 101, the agency sought to reduce the safety hazards caused by the diversion of the driver's attention from the road. Locating secondary controls for passengers in the rear seating area for the heating and ventilation system would not distract the driver from the operation of the motor vehicle. The identification and illumination requirements of sections 5.2 and 5.3 were intended to apply only to the controls operable by and visible to the driver.; You should be aware, however, that section 5.3.3 of FMVSS No. 10 provides that '(t)he intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable in a manner that complies with this paragraph.' This section applies to all illumination in the passenger compartment that is dependent on activation of the headlights regardless of whether it shines upon a control display, to enable drivers to reduce the glare in the passenger compartment. Items such as radios and clocks which are not regulated by the location and identification requirements of FMVSS No. 101 are subject to the variable intensity requirements of section 5.3.3 if illuminated when, and only when, the headlights are activated. If the controls located in the rear seating area that operate the heating and ventilation unit are illuminated in this way, the standard requires that the light intensity for such controls must be continuously variable as described in section 5.3.3. You should further note that where you provide a control for the illumination intensity, section 5.1 of FMVSS No. 101 requires that it be operable by the driver, and its identification visible to the driver. We interpret this section to require at least one such control to be operable by and its identification visible to the driver. If a manufacturer separately meets the requirement of S5.1 by a properly located and identified control, additional controls that are added voluntarily by the manufacturer are not prohibited.; You indicated in your letter that Mazda is considering placin secondary controls for the audio system in the rear seating area. Controls and displays for audio systems are not regulated by FMVSS No. 101. The location and identification of these controls and displays are left to the discretion of the manufacturer. Once again, however, if the controls are illuminated when, and only when, the headlights are activated, then the same analysis discussed above applies. At least one control for the illumination intensity must be operable by the driver, with its identification visible to the driver.; In conclusion, FMVSS No. 101 does not prohibit placing the secondar controls for the heating and ventilation unit and audio system in the rear seating area. We would like to point out that there are other safety standards which may apply to your proposal that you should consider when you design these features for your automobiles, such as FMVSS No. 201, *Occupant Protection in Interior Impact*.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2740OpenMr. K. A. Dirkzwager, Driver and Vehicle Services Director, Minnesota Department of Public Safety, Transportation Building, St. Paul, MN 55155; Mr. K. A. Dirkzwager Driver and Vehicle Services Director Minnesota Department of Public Safety Transportation Building St. Paul MN 55155; Dear Mr. Dirkzwager: This is in response to your letter of November 15, 1977, requesting a exemption from the Federal odometer disclosure regulations which will become effective as of January 1, 1978.; We appreciate the efforts of Minnesota to include odometer informatio on its certificates of title. However, we are not granting any exemptions for States which have not previously had odometer information on their titles. Since the citizens of your State have had to execute separate odometer disclosure statements in the past they will not be placed under any additional burden by this ruling. They will merely continue past practices until such time as Minnesota incorporates the revised odometer format on their titles.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam5085OpenMr. Ron Noirfalise Director of Pupil Transportation Missouri Department of Elementary and Secondary Education Post Office Box 480 Jefferson City, MO 65102-0480; Mr. Ron Noirfalise Director of Pupil Transportation Missouri Department of Elementary and Secondary Education Post Office Box 480 Jefferson City MO 65102-0480; "Dear Mr. Noirfalise: This follows up your telephone conversation o November 10, 1992, with Walter Myers of my staff regarding a newly-effective statute in Missouri which revises state requirements on transportation of school children. You also stated that you were told by your counterpart in the State of Washington that Federal law prohibits transportation of school children in vehicles with a passenger capacity of less than ten people. As discussed in your telephone conversation with Mr. Myers, I have enclosed four recent letters explaining Federal law and pertinent regulations applicable to school buses and transportation of school children. These four are a November 3, 1992 letter to Mr. G. Thomas Owens, a July 7, 1992 letter to Senator Jim Sasser, a May 27, 1992 letter to Mr. Gerald A. Guertain, and a January 15, 1991 letter to Ms. Carol C. Verenea. These letters cover a variety of issues that, I think, will clarify your understanding of the issues with which you are concerned. Also enclosed is a copy of a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations, revised June 1989, and an information sheet issued by this agency entitled Where to Obtain NHTSA's Safety Standards and Regulations. In addition, I am enclosing for your information a copy of Highway Safety Program Guideline No. 17, Pupil Transportation Safety. This publication was issued under the authority of the Highway Safety Act of 1966 which authorizes this agency to issue nonbinding guidelines that states may refer to in developing their highway safety programs. Guideline 17 was jointly issued by this agency and the Federal Highway Administration to provide recommendations to the states on various operational aspects of their school bus and pupil transportation safety programs. Among other things, Guideline 17 recommends that any vehicle designed to carry more than ten persons which is used as a school bus comply with all safety standards applicable to school buses at the time the vehicle was manufactured. I hope the enclosed information will be of assistance to you. If you have any further questions, feel free to contact Mr. Myers at this address or at (202) 366-1992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam0287OpenMr. P.H.G. Morgan, Managing Director, Morgan Motor Company, Ltd., Pickersleigh Road, Malvern Link, Worchestershire, England; Mr. P.H.G. Morgan Managing Director Morgan Motor Company Ltd. Pickersleigh Road Malvern Link Worchestershire England; Dear Mr. Morgan: By letter of November 19, 1970, you petitioned for reconsideration o Federal Motor Vehicle Safety Standard No. 214 - Side Door Strength (35 F.R. 16801, October 30, 1970). After consideration of the issues raised by Morgan's petition, the National Highway Traffic Safety Administration has found no sufficient justification for amending the standard and the petition is therefore denied.; Your company's petition states that the standard presents difficultie for cutaway doors, and that the structure of Morgan automobiles supplies a measure of protection through flared side fenders that extend beneath the doors. The Administration recognizes that there is considerable variety in door and side structure. However, the need to protect occupants of all vehicles from injury in side collisions dictates a uniform measure of such protection, and the Administration has determined that the requirements of Standard No. 214 are reasonable, practicable and appropriate for passenger cars.; The remaining points in your letter of November 19, 1970, are mor nearly questions for interpretation than requests for reconsideration. Your second question pertains to the height (or length) of the loading device. The standard states only that the device must not contact any structure above the bottom edge of the door window opening. There is no other restriction on the maximum height of the test device, and it is not clear, without further explanation, why Morgan would be limited to a cylinder only 4 inches high.; Your remaining question deals with the positioning of side windows Although the standard specifies that side windows shall be in the uppermost position, it does not require that side windows exist and should not be so interpreted.; Sincerely, Douglas W. Toms, Acting Administrator |
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ID: aiam2310OpenMr. T. Takeda, Manager, Automotive Lighting Engineering Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-Ku, Tokyo 153, Japan; Mr. T. Takeda Manager Automotive Lighting Engineering Dept. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-Ku Tokyo 153 Japan; Dear Mr. Takeda: This is in reply to your letter of April 20, 1976, asking for a amendment of S4.1.1.21 of Motor Vehicle Safety Standard No. 108 to allow a plus tolerance of 7.5 percent on maximum wattage requirements for Type 1A and 2A headlamps.; I enclose a copy of an interpretation furnished the General Electri Company which states that such a tolerance is allowed. However, to clarify our intent we plan to amend Standard No. 108 in the near future in the manner that you suggest.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam4694OpenMrs. Erika Z. Jones Mayer, Brown, & Platt 2000 Pennsylvania Avenue, N.W. Washington, D.C. 20006-1885; Mrs. Erika Z. Jones Mayer Brown & Platt 2000 Pennsylvania Avenue N.W. Washington D.C. 20006-1885; Dear Mrs. Jones: This responds to your letter requesting a confirmatio of your telephone conversation with Mr. Stephen Wood of my staff. In that conversation, he informally stated that the attached letter dated January 5, 1990 from Fidelity Tire Manufacturing Company contained the information necessary to comply with the notification requirements in S5.1 of Federal Motor Vehicle Safety Standard 119 (49 CFR 571.119) for tires and rims not listed in the publication of a specified tire and rim association. This letter confirms that Fidelity's letter would satisfy the requirements of section S5.1. Section S5.1 requires that a listing of the rims which may be used with each tire produced by a manufacturer be provided to the public. The purpose of this requirement is to ensure that the tire will be mounted only on appropriate rims and that the tire will be mounted on vehicles where its load-carrying capacity will be adequate. That section gives manufacturers the option of using the data provided for the tire size and corresponding rims published in certain standardization organization yearbooks or listing the appropriate information 'in a document furnished to dealers of the manufacturer's tires, to any person upon request, and in duplicate to NHTSA .' Fidelity's letter which includes the appropriate dimensional and load-carrying data for the tire and rim appears to satisfy this requirement. I hope this explanation is helpful. Please contact Mr. Marvin Shaw of my staff at (202) 366-2992 if you have any further questions. Sincerely, Paul Jackson Rice 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.