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: aiam0049OpenMr. John F. Floberg, Vice President, Secretary and General Counsel, The Firestone Tire & Rubber Company, Akron, Ohio 44317; Mr. John F. Floberg Vice President Secretary and General Counsel The Firestone Tire & Rubber Company Akron Ohio 44317; Dear Mr. Floberg: Your petition of March 7,1968, requesting a reduction in the high spee performance test (Section S5.5) of Federal Motor Vehicle Safety Standard No. 109 (23 CFR, Part 255) for special heavy gauge tread taxi tires is denied.; While we agree that some taxis are used for low speed intercit operation, many taxis now use high speed freeways for sustained periods of time. With the continuous expansion of freeways in metropolitan areas, the average service speed for taxi tires is certain to increase. In view of this, and because it is impossible to limit the use of taxi type tires to speeds lower than those presently permitted for other passenger vehicles, an amendment to Standard No. 109 exempting the heavy gauge tread tires from the high speed performance requirements, would not be in the interest of safety.; For your future reference enclosed is a copy of *Rule Makin Procedures: Motor vehicle Safety Standards* as published in the *Federal Register (32 F.R. 15818 - 15820). Your attention is directed to S216.31 which sets forth the procedural regulations for petitions for rule making.; Sincerely, John R. Jamieson, Deputy Federal Highway Administrator |
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ID: aiam2003OpenMr. William D. Keettel, Carlton, Fields, Ward, Emmanuel, Smith & Cutler, P.A., The Exchange National Bank Building, P.O. Box 3239, Tampa, FL 33601; Mr. William D. Keettel Carlton Fields Ward Emmanuel Smith & Cutler P.A. The Exchange National Bank Building P.O. Box 3239 Tampa FL 33601; Dear Mr. Keettel: This is in response to your letter of July 15, 1975, commenting o several aspects of the odometer disclosure regulation (49 CFR Part 580, *Odometer Disclosure Requirements*).; You suggested that the term 'transferor,' defined in S 580.3 of th odometer regulation, poses a potential problem for a person who transfers ownership of a motor vehicle by gift to a member of his family and fails to execute an odometer disclosure statement. In your opinion, the attractive civil penalty available for noncompliance with the disclosure requirements might expose such a transferor to suit by his transferee despite the need to demonstrate intent to defraud as a prerequisite to recovery.; The National Highway Traffic Safety Administration (NHTSA) does no agree with your comment. Section 402(3) of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513) defines the term 'transfer' as a change of ownership by purchase, *gift*, or any other means (emphasis added). Section 408 of the Act orders the Department of Transportation to prescribe rules requiring any transferor to give an odometer disclosure statement to the transferee in connection with the transfer of ownership of a motor vehicle. Thus, the law mandates the execution of an odometer disclosure statement even when the transfer of ownership is by gift.; Since intent to defraud must be shown in order to obtain recovery unde the Act, it is doubtful that someone who innocently fails to provide a disclosure form would suffer the consequences imposed by the Act. It is important that disclosure statements be executed at each point a vehicle changes hands as a means of protecting individuals in the chain of ownership. Once it is discovered that an odometer has been altered, the owner of the vehicle may name all prior owners as defendants in his suit and the disclosure form may be the only absolute evidence of one's innocence. Thus, the Act's requirement that a disclosure statement be provided, even in the case of an intra-family gift, has a definite basis. The 'intent to defraud' aspect of the penalty section serves as a safeguard against abuse.; You commented in your letter that a loophole exists in section 580.5(b making it possible for new car dealers to transfer vehicles without executing a disclosure statement. Your understanding of the section is incorrect. A new car dealer is required to complete an odometer disclosure statement whenever he transfers ownership of a vehicle to a person for purposes other than resale. This means that the only time a disclosure form is unnecessary (under S 580.5(b)) is when the vehicle is transferred between parties for the purpose of resale. An example of this type of transfer is between a distributor and a dealer.; In your letter you cite possible problems involving the point at whic the disclosure statement must be executed, the conspicuousness of the statement, and the effect of the statement that the mileage indicated on the odometer differs from the true number of miles the vehicle has traveled. S 580.4 requires that the disclosure statement be furnished to the transferee of a vehicle before any transfer of ownership document is executed. In the preamble to the regulation, the agency explained this to mean that the disclosure must be made as part of the transfer, and not at some later time. This assures that the transferee will be made aware of the odometer mileage and its accuracy before he obtains ownership of the vehicle.; Although there is no requirement that the odometer statement b provided as a separate document, it is necessary that all of the required information be contained on some form which is provided to the transferee. There is, of course, no way of assuring that a transferee will examine all of the papers handed to him when he takes ownership of a vehicle. However, since the disclosure document must include a considerable amount of current information on the vehicle, it is likely that transferee (sic) will be aware of the filling out of the form.; The statement included on the form relating to the accuracy of th odometer mileage is phrased in positive terms and states that the mileage indicated on the odometer *is* incorrect, not that it *may* be incorrect. The odometer disclosure requirements are intended to assure that a transferee is aware of the accuracy of his vehicle's odometer mileage. If the transferor indicates that the mileage is incorrect, he has put the purchaser on notice and the purchaser from that point assumes the risk of owning a vehicle whose mileage is uncertain. It seems unlikely that a certification that the mileage is incorrect would be overlooked as might happen with 'fine print' since the transferor must make a mark by the statement showing its applicability. This, it would seem, would draw one's attention to the warning.; Thank you for your comments. Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2453OpenMr. Fred J. Greiner, Executive Vice President, NAFDEM, 5530 Wisconsin Avenue, Washington, DC 20015; Mr. Fred J. Greiner Executive Vice President NAFDEM 5530 Wisconsin Avenue Washington DC 20015; Dear Mr. Greiner: This responds to your July 23, 1976, request for clarification o certification responsibilities in the case of trucks that are manufactured in two or more stages. By virtue of our earlier correspondence, you are aware of the National Highway Traffic Safety Administration's (NHTSA) regulations for the assignment of these responsibilities (Part 567, *Certification*, and Part 568, *Vehicles Manufactured in Two or More Stages*).; With regard to the first two questions in your letter, the NHTS considers the mounting of a used body on a new cab-chassis to be the manufacture of a motor vehicle that requires certification. In these cases, the incomplete vehicle document is provided along with the new cab-chassis. The replacement of a used body with a new one is not considered to be a manufacturing operation that requires certification of the vehicle as completed.; Your second and third questions ask whether the final-stag manufacturer of a tank truck may assume what commodity will constitute the cargo (*e.g*., bulk milk) as the basis for assigning the vehicle's gross vehicle weight rating (GVWR). Section 567.4(g)(3) specifies that the GVWR determination be based on the 'rated cargo load' which is determined by the final-stage manufacturer. It would appear reasonable for the final-stage manufacturer to use the weight of bulk milk as the basis for its calculation of rated cargo load, particularly where the tank was used for milk previously, and when the vehicle is completed by a member of a trade association specializing in food and dairy equipment manufacture.; Your fourth question raises the difficulty of certifying a complete vehicle in the case where the incomplete vehicle document is missing from the cab-chasis (sic). You object that the final-stage manufacturer bears 'the ultimate burden' of certification, when he does not have control over the entire manufacturing operation.; Section 114 of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S 1403) mandates that the manufacturer of a vehicle certify compliance, and this constitutes a statutory requirement which is not subject to the control of the NHTSA. Part 568 requires provision of the incomplete vehicle document and represents the agency's judgement of the means by which the final-stage manufacturer can best be assisted in meeting the statutory obligation to certify compliance. The agency believes that the incomplete vehicle manufacturer would be in a position to supply a substitute document in the event the original document is lost.; In answer to your last question S 568.5 of our regulations provide that an intermediate-stage manufacturer (such as a person that adds or moves an axle) shall, if such changes affect the validity of statements in the incomplete vehicle document, furnish an addendum to the document that indicates appropriate changes that should be made in the document. Thus the intermediate-stage manufacturer that affects the weight rating set forth in the incomplete vehicle document must provide an addendum explaining the effect of the modifications. The responsibility for certification continues to remain with the manufacturer, who is the person exercising ultimate control over the components used in the axle system.; If, after having digested these comments, you still feel a meeting i necessary, please get in touch with our Engineering Systems Staff ((202) 426-2817) and one will be arranged.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5396OpenMs. Eileen Jones 17 Ballinger Court Burtonsville, MD 20866; Ms. Eileen Jones 17 Ballinger Court Burtonsville MD 20866; "Dear Ms. Jones: This responds to your faxed letter of May 19, 1994. A you explained in your letter: My three month old son has a physical condition whereby the formula that he drinks refluxes back into his throat causing him to choke and become unable to breathe. Due to this condition, I cannot keep his infant seat in the back of the car where I will be unable to reach him and thus prevent him from choking. My problem lies in that I have a passenger as well as a driver's side air bag in our 1993 Ford Taurus Wagon. Due to the danger of having an infant's seat in the front of a car with a passenger air bag, I have contacted local Ford dealers as well as the overall Ford customer service people and have been told each time that they will not disable my car air bags for me as it is against federal law. You requested 'a waiver of a portion of the federal guidelines regarding air bags in automobiles.' Standard No. 208, Occupant Crash Protection, requires that cars be equipped with automatic crash protection at the front outboard seating positions. The air bags in your car were installed as one means of complying with that requirement. The removal or deactivation of one of those air bags by a vehicle dealer is prohibited by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, the act under Standard No. 208 was issued. That section provides that-- (n)o manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard. However, in limited situations in which a vehicle must be modified to accommodate the needs of a person with a particular disability or a person's special medical needs, NHTSA has in the past stated that it would consider violations of the 'render inoperative' prohibition as purely technical ones justified by public need, and that it would not institute enforcement proceedings. This is to advise you that we would regard a temporary deactivation of the passenger-side air bag in your car in the same way. Based on the results of recent agency research, NHTSA has concluded that rear-facing infant restraints should not be placed in the front seat of a vehicle with a passenger-side air bag. NHTSA would consider the special medical needs of your child as sufficient justification for not taking enforcement action against a dealer that temporarily deactivates the air bag to accommodate your child. I want to add a caution. The purpose of the 'render inoperative' prohibition is to ensure, to the degree possible, current and subsequent owners and users of your vehicle are not deprived of the maximum protection afforded by the vehicle as newly manufactured. Accordingly, our willingness to permit this deactivation is conditioned on the reactivation of the air bag by the dealer as soon as your son can use a forward-facing child restraint. In addition, I strongly encourage you to ensure that other passengers in this seating position use their safety belts while the air bag is disconnected. I hope that this letter resolves your problem. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0194OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Mr. Heath: In response to your letter of July 9 to Mr. Toms I would like to mak clear that the creation of the subcategory 'mobile structure trailer' does not remove mobile homes towed on their own wheels from their original categorization under the Federal motor vehicle safety standards as trailers. This means that rule making actions applicable to 'trailers' are also applicable to mobile homes unless there is specific language indicating that a Federal standard or portion thereof does not apply to a mobile structure trailer.; Therefore, in answer to your specific questions: >>>(a) Proposed Standards Nos. 119 and 120 would apply to trailers an therefore to mobile structure trailers.; (b) No proposal has been issued which would extend the Federa hydraulic brake standard, No. 105, to cover trailers. Therefore a State may adopt hydraulic brake requirements for mobile homes. However, we have issued a proposal (Docket No. 70-16, 35 F.R. 10456, June 26, 1970) which would establish requirements for 'trailers equipped with air brake systems'. If adopted, this new standards would preclude a state from adopting other than identical air brake requirements for mobile homes and other trailers. The point may be academic as it is my understanding that mobile homes, as a rule, are equipped with electric brakes.<<<; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel, Regulation |
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ID: aiam2900OpenMr. Robert J. Shirock, Safety Director, U.S. Army Tank- Automotive Materiel Readiness Command, Department of the Army, Warren, MI 48090; Mr. Robert J. Shirock Safety Director U.S. Army Tank- Automotive Materiel Readiness Command Department of the Army Warren MI 48090; Dear Mr. Shirock: This is in reply to your letter of November 13, 1978, to th Administrator questioning whether certain trucks procured by your Command comply with paragraph S4.5.4 of Federal Motor Vehicle Safety Standard No. 108.; That paragraph states 'The stop lamps on each vehicle shall b activated upon application of the service brakes.' You wrote that 'when the hazard warning lights are activated the stop lamp cannot be activated upon application of the service brakes.' The system you describe would be in compliance with Standard No. 108, if the stop lamps and signal lamps are optically combined, for the following reason. Paragraph S4.4.1 allows combination of a stop lamp with a turn signal lamp (which provides the hazard warning signal). Paragraph 4.2 of SAE Standard J586c *Stop Lamps*, August 1970 (incorporated by reference in Standard No. 108 as the operative standard for stop lamps) requires that 'When a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on in the turn signal which is flashing.; This, of course, means that in a combination lamp the stop signa cannot be given while the hazard warning signal is being operated. If the Army deems it desirable it could require a different circuitry in combination lamps by which the stop lamps and hazard warning signal lamps could operate simultaneously, as military vehicles need not conform to Federal safety standards (49 CFR 571.7(c)).; Because several jurisdictions require slow-moving vehicles to use th hazard lamps while in motion, I am asking our Office of Rulemaking to review this prohibition. Thank you for bringing this matter to our attention.; Sincerely, Joseph J. Levin, Jr. Chief Counsel |
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ID: aiam3612OpenMr. M. G. Goode, Engineer-Director, State Department of Highways and Public Transportation, Motor Vehicle Division, Austin, TX 78779; Mr. M. G. Goode Engineer-Director State Department of Highways and Public Transportation Motor Vehicle Division Austin TX 78779; Dear Mr. Goode: This is in response to your letter of September 20, 1983, requestin approval for use of the Texas Certificate of Title and disclosure documents in lieu of the Federal odometer disclosure form which is required by 49 CFR Part 580.; The proposed Texas documents do not conform with the regulation' requirements. To conform, the odometer disclosure statements must include the name and address of both the transferee and the transferor, Section 24(a) of the Texas Certificate of Title Act does require their inclusion. It appears, however, that the disclosure statements do not provide a space for the transferor's (seller's) address. Additionally, a space must be provided on the statements for the transferee's (purchaser's) signature. The Agency considers this signature to be essential because it is an acknowledgment that the purchaser was aware of the mileage. The purchaser, when he signs the document, is prevented from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. If these items are added, the Texas forms will satisfy the Federal odometer disclosure statement requirements, and may be used in lieu of a separate Federal form.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4587OpenMr. Melvin Krewall Director, Transportation Section Financial Services Division Oklahoma State Department of Education 2500 North Lincoln Blvd Oklahoma City, OK 73105-4599; Mr. Melvin Krewall Director Transportation Section Financial Services Division Oklahoma State Department of Education 2500 North Lincoln Blvd Oklahoma City OK 73105-4599; "Dear Mr. Krewall: Thank you for your letter asking two questions abou how this agency's regulations apply to vehicles used as school buses. Before I answer your specific questions, it may be helpful to discuss some background information. Federal law regulates the manufacture and sale of new school buses. A 'school bus' is defined at 49 CFR /571.3 as 'a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.' The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standards applicable to all new school buses. It is a violation of Federal law for any person to manufacture for sale a new school bus that does not comply with these safety standards. It is also a violation of Federal law for any person to sell as a school bus any vehicle that does not comply with all school bus safety standards. On the other hand, without violating any provision of Federal law, a school district may purchase or use a vehicle to transport school children even if the vehicle does not comply with Federal school bus regulations. This is so because the individual States have authority over the activities of a retail purchaser or user of a school bus. (Note, however, that a dealer who sold a vehicle other than a school bus to a school district with knowledge that it is intended to be used to transport school children would violate the Federal law.) With this background, I will now address the specific questions raised in your letter. First, you asked whether a 'transit coach-type vehicle' that was manufactured prior to April 1, 1977 could be used to transport students to and from school. In a subsequent telephone conversation with Joan Tilghman of my staff, you explained that you used the term 'transit coach-type vehicle' to mean a bus with a gross vehicle weight rating (GVWR) of over 10,000 pounds. As explained above, Federal law does not regulate the use of vehicles as school buses. If there are any limitations on the use of vehicles as school buses in your State, those limitations arise from the laws or regulations of the State of Oklahoma. NHTSA has repeatedly advised the States of our position that the safest way to transport students is in a vehicle that is certified as complying with Federal school bus regulations. We have encouraged States and school districts to consider this fact carefully when deciding what vehicles should be used to transport students to and from school and school-related events. Your second question asked what must be done to bring a bus with a GVWR of more than 10,000 pounds 'into compliance as a standard Type 'D' school bus.' In your telephone conversation with Ms. Tilghman, you explained that Oklahoma refers to school buses with a GVWR of more than 10,000 pounds as 'Type D' school buses. Please note that Federal school bus standards apply only to new school buses. Accordingly, there is no Federal requirement under NHTSA regulations that any person retrofit a used bus to make it comply with our standards for new school buses. You may wish to know that the Federal Highway Administration (FHWA), a separate agency within the U.S. Department of Transportation, has proposed regulations to enhance highway safety by regulating operations of 'private motor carriers of passengers.' (54 Federal Register 7362, February 17, 1989, Private Carriage of Passengers.) FHWA is exploring whether it is appropriate to require retrofit of some buses owned by that category of operators to meet NHTSA vehicle safety standards. While the proposed rule does not address the operations of governmental entities, you may wish to consider the FHWA proposal or comment on it. I enclose a copy for your information, and direct your attention to the comment closing date of June 19, 1989. I hope you find this information helpful. If you have further questions, please contact Joan Tilghman of my staff at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam3242OpenMr. J.W. Martin, Trainee, Department of Trading Standards, Royal County of Berkshire, The Old Fire Station, 12 Cookham Road, Maidenhead, Berkshire, SL6 8AJ, England; Mr. J.W. Martin Trainee Department of Trading Standards Royal County of Berkshire The Old Fire Station 12 Cookham Road Maidenhead Berkshire SL6 8AJ England; Dear Mr. Martin: This responds to your letter of February 20, 1980, in which yo requested information concerning this agency's requirements that motor vehicles be equipped with tamper-resistant odometers and the method used to enforce this requirement. As described below, I have enclosed copies of the National Highway Traffic Safety Administration's (NHTSA) pertinent regulations and enabling legislation as well as some background material.; Among the enclosures to this letter are a series of Federal Registe notices which trace the development of Federal Motor Vehicle Safety Standard (FMVSS) No. 127, *Speedometers and Odometers*. As you will see, (43 FR 10919, March 16, 1978, Notice 4) the initial requirement that odometers 'be moveable in the forward direction only' has been modified several times largely in response to comments from the public and from the automobile manufactures (examples enclosed). The rule in effect at present requires either that (1) odometers be irreversible 'whether installed in or removed from a vehicle' unless one or more of five specified operations is necessary to achieve reversal or (2) that odometers be equipped with a marking system which permanently marks the wheel registering ten thousands of miles as the numeral disappears from the driver's view (see 44 FR 17500, March 22, 1979). changes to standard have been proposed (see 44 FR 17532, March 22, 1979) and this agency expects to publish a final rule incorporating some of these changes in the near future. Upon its publication I will be happy to send you a copy. In anticipation. of publication of this rule, the agency has not yet conducted an evaluation in the field of the effectiveness of the odometer provisions of Safety Standard No. 127. However, The agency is now preparing to begin such an evaluation. At this point I am unable to provide you with any details on the form which the evaluation will take.; I have also enclosed an economic impact analysis prepared in 1978 whic discusses, among other things, an early version of Safety Standard 127's odometer tampering provision. Please note that this analysis was not updated as the odometer requirements of Safety Standard No. 127 were modified because this agency concluded that these changes would not significantly alter the standard's economic impact.; You may also be interested to know that SAfety Standard 127 is not thi agency's only tool against odometer tampering. Title IV, Odometer Requirements, of the Motor Vehicle Information and Cost Savings Act (copy enclosed) which is enforced in part, by this agency states that no person shall (1) disconnect reset or alter or cause to be disconnected reset or altered the odometer of a motor vehicle with intent to change the number of miles indicated thereon, (2) with intent to defraud, operate a motor vehicle on any street or highway knowing that the odometer of such vehicle is disconnected or nonfunctional of (3) advertise for sale, sell, use or install or cause to be installed any device which causes an odometer to register any milage other that the true milage driver.; In addition, the act authorizes this agency to develop regulation requiring any transferor of ownership of a motor vehicle to provide to the transferee written disclosure of the cumulative milage registered on the odometer or, in cases where the transferor knows that the odometer reading is different from the number of miles the vehicle has actually traveled, disclosure of that fact. The agency's regulations concerning these disclosures are enclosed for your information.; In your letter, you also requested information indicative of the exten to which odometer tampering presents a problem in the United States.; Unfortunately, I am unable to provide you with any reliable studie conducted in this area. The legislation and regulations aimed at reducing the incidence of odometer tampering have all rested upon a common but un-quantified consensus that odometer tampering is a significant problem in the United States. Safety engineers in this agency have estimated, simply on the basis of their experience, that between 50% and 75% of the used cars sold in the United States contain odometers whose readings have been reduced.; I hope that you will find this information helpful in preparing you project on tamper-proof odometers.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0897OpenMr. Jerry Alexander, Purchasing - Window Division, Philips Industries Inc., 4801 Springfield Street, Dayton, OH 45401; Mr. Jerry Alexander Purchasing - Window Division Philips Industries Inc. 4801 Springfield Street Dayton OH 45401; Dear Mr. Alexander: This is in reply to your letter of October 5, 1972, concerning th manufacture of storm windows for use in recreational vehicles. You refer to our letter to Mr. Bob Sanders of your company (our records show the date of the letter to be July 5) in which we outlined the requirements for glazing materials used in various locations in recreational vehicles, and ask whether storm windows used in these locations must meet the same requirements.; The answer is yes. Storm windows for use in motor vehicles must mee the same requirements as other glazing materials, according to their location in the vehicle.; I have enclosed a copy of our Response to Petitions for Reconsideratio concerning the latest amendment to Standard No. 205.; Sincerely, 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.