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 |
|---|---|
| search results table | |
ID: aiam4230OpenMr. Douglas MacGregor, Terralab Engineers, 3585 Via Terra, Salt Lake City, UT 84115; Mr. Douglas MacGregor Terralab Engineers 3585 Via Terra Salt Lake City UT 84115; Dear Mr. MacGregor: Thank you for your letter of August 28, 1986, to Stephen Oesch of m staff concerning Standard No. 301, *Fuel System Integrity*. You asked whether the performance requirements of the standard would apply to a propane-fired engine block heater. You explained that the heater has its own fuel system that is independent of the vehicle's fuel system. As explained below, a propane-fired heater would not be covered by Standard No. 301.; Standard No. 301 sets performance requirements for the fuel system use in certain motor vehicles. The heater you have described apparently does not have any connections to the fuel tank or fuel lines of the vehicle. Instead, the heater has its own propane fuel system. Since the heater is not connected to the vehicle's fuel system, it would not be covered by the standard. Even if the heater were connected to the vehicle fuel system, it would not have to meet the performance requirements of the standard, since it is a propane-fired heater. S3 of Standard No. 301 limits the application of the standard to vehicles that use a fuel with a boiling point above 32 degrees Fahrenheit. Propane has a boiling point below 32 degrees Fahrenheit.; Even though the heater is not covered by the requirements of Standar No. 301, it would be considered an item of motor vehicle equipment. I have enclosed a copy of an information sheet that describes how our regulations, including those on defect notification and remedy campaigns, apply to equipment manufacturers.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam1032OpenMr. Robert W. Herr, Assistant Attorney General, Office of the Attorney General, State of Minnesota, St. Paul, MN 55155; Mr. Robert W. Herr Assistant Attorney General Office of the Attorney General State of Minnesota St. Paul MN 55155; Dear Mr. Herr: This is in reply to your letter of January 19, 1973, concerning th Federal requirements governing safety belt length.; Federal Motor Vehicle Safety Standard No. 208, Occupant Cras Protection, regulates the length of safety belts installed in cars made after January 1, 1972. There are two safety belt length requirements of this Standard that may enter into the case enclosed with your letter. The first requires that the manufacturers provide, as a minimum, sufficient safety belt length to fit at least a 95th percentile adult male with the seat in any (i.e., all) adjusted positions. A 95th percentile adult male weighs 215 pounds and has a 42.5 inch waist with 47.2 inch hips (sitting dimensions).; The second requirement concerns the length of the inboard end of th safety belt. In this case, the Standard requires that the intersection of the shoulder belt with the lap belt shall be at least 6 inches from the front vertical centerline of the average-size occupant, with the seat in the rearmost adjusted position. While this may result in an inboard belt length that may be somewhat more difficult to fasten than in some previous model cars, it significantly reduces the possibility that the shoulder belt could pull the lap belt up off the pelvis into the abdomen in a crash, possibly causing abdominal injuries.; With regard to the particular case at hand, our experience has bee that the vehicle manufacturers are usually willing to provide longer belts to fit very large new car buyers. With respect to inboard belt length, our experience has been that belts which approach the permissible 6 inch dimension mentioned above are usually satisfactory in terms of convenience. However, shorter inboard belt lengths, exceeding the minimum safety requirements of the standard, are permissible. In these cases, the customers may want to seek adjustment by the dealer or vehicle manufacturer.; In regard to the allegation made in the case that the belts cannot b changed, there is no Federal law or regulation that would prevent the dealer from modifying the safety belts. The National Traffic and Motor Vehicle Safety Act grants us the authority to regulate the safety of new motor vehicles. Although a dealer may not sell a new vehicle that does not conform to the standards, once the vehicle is sold and delivered the customer may have it modified by the dealer. In such a case, the dealer would not violate Federal law.; The dealer in question may well have had reasons for declining t modify the safety belts. He may be unsure of his ability to do a proper job and may fear incurring civil liability to the customer if someone should be injured as a result of his work. We would not encourage modification of a vehicle's mandatory safety features unless it is done with expert advice, or according to the manufacturer's recommendations.; Please contact this office if you desire any further discussion of thi matter.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam4660OpenMr. S. Watanabe, Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-l3, Nakameguro, Meguro-Ku Tokyo l53, Japan; Mr. S. Watanabe Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-l3 Nakameguro Meguro-Ku Tokyo l53 Japan; "Dear Mr. Watanabe: This is in reply to your FAX of September 14, l989 asking for an interpretation of Motor Vehicle Safety Standard No. l08, with respect to a vehicle headlamp aiming device (VHAD), as shown in the drawing attached to your letter. You have two questions: '1) Does a VHAD without a function which compensates the deviation of floor slope satisfy FMVSS No. l08 S7.7.5.2(a)(l(v)?' Paragraph S7.7.5.2(a)(v) states that 'Means shall be provided in the VHAD for compensating for deviations in floor slope not less than 1.2 degrees from the horizontal that would affect the correct positioning of the headlamp for vertical aim.' If a VHAD is 'without a function which compensates the deviation of floor slope' it would not satisfy Standard No. l08. '2) This Head Lamp is designed to be aimed vertically by means of observing only one spirit level placed on the movable reflector, as shown in the drawing. Does this structure of VHAD satisfy FMVSS No. l08 S7.7.5.2(a)(l)(v)?' The answer is yes, if observation of the simple spirit level is coordinated with an off-vehicle measurement of floor slope. As located, the spirit level with the range of +/- 1.2 degree range will allow aim of the headlamp, even though the vehicle may not be level, and willcompensate for floor slopes of up to 1.2 degrees, thus fulfilling the requirement that there be compensatory means when the vehicle upon which the headlamp is mounted is not resting upon level ground. I hope that this answers your questions. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
|
ID: aiam1198OpenMr. Stan Haransky, Associate Director, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Associate Director Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This is in reply to your letter of July 6, 1973, forwarding to us letter from Mr. Jim Finley of the Hughes Tool Company. Mr. Finley describes two situations, requesting an opinion on the applicability of NHTSA requirements to each of them.; The first question is whether an earth auger body that is mounted on crane carrier will conform to the Certification regulations (49 CFR Part 567) if the vehicle exceeds its stated weight ratings when a derrick is mounted on the vehicle but a permanent metal plate is also affixed to the vehicle which states: 'The GVWR and GAWR require that the derrick be removed before operating this vehicle upon a public highway.'; We do not believe such a label may be used to bring a vehicle int conformity with the Certification regulations. Both 'gross vehicle weight rating' and 'gross axle weight rating' call for a rating set by the manufacturer, but each is intended to reflect a fully-loaded vehicle or axle condition as a vehicle is likely to be used. Although your letter is not explicit in this regard, if it is a reasonable expectation that the vehicle will be operated on the public highways with the derrick mounted on it (but for the label), even though the derrick is 'removable', we would not consider the weight ratings to be consistent with the regulations if they do not take into account the weight of the derrick.; Similarly, the components used in the manufacture of the vehicle shoul be of sufficient strength to carry the derrick when the vehicle is in motion. On the other hand, if it is unreasonable to expect the derrick to be attached to the crane carrier when the carrier is operated on the highway, the weight ratings need not take into account the weight of the derrick. In neither case, however, would the label you illustrate affect the conformity of the vehicle to the regulations, in the former case the label does not correct the incorrect weight ratings, and in the latter case, the label is unnecessary.; Your second question is whether Federal regulations regarding lightin may be met if the rear lights of a truck-mounted earth auger utilize hinged covers that are intended to protect the lights during boring operations. You state that when the vehicle is operated, the cover is secured to expose the lights. You ask if we recommend the use of a warning sticker in the cab to remind the driver to open the covers.; The use of these covers is not prohibited by the Federal lightin standard, Federal Motor Vehicle Safety Standard No. 108, 'Lights, Reflective Devices, and Associated Equipment' (49 CFR 571.108). We think the idea of a warning sticker in the cab is nonetheless a good one.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1462OpenMr. Ronald P. Moeller, Product Development Engineer, Conco, Incorporated, Mendota, IL 61342; Mr. Ronald P. Moeller Product Development Engineer Conco Incorporated Mendota IL 61342; Dear Mr. Moeller: This is in response to your letter to Mr. W. J. Reinhart, dated Marc 26. In this letter you requested that the Office of Defects Investigation (ODI) reconsider the necessity of your revising the notification letters which were mailed by you in conjunction with your defect notification campaign (NHTSA No. 74-0038).; We have determined that your notification letter must be revised an that you must provide this office, and those owners who did not correct their vehicles, with a copy, sent certified mail, of the revised letter. It is not sufficient under Part 577 for you to state that a 'safety hazard' exists 'due to a decrease in visibility of the vehicle.' This statement fails to conform to section 577.4(d) of the Defect Notification regulations (49 CFR Part 577). That section provides that the risk to traffic safety presented by the defect be evaluated in terms of whether or not vehicle crash is the *potential* occurrence.We believe it obvious within the context of Part 577 that the potential result of the failure of any vehicle to conform to the lighting requirements of Standard No. 108 is vehicle crash. The factors you cite, that the vehicles have limited use, go only to whether it is likely they may be involved in crashes, not whether crash is the potential or possible result. In this regard, we note that your own description of the likelihood of crash does not preclude the possibility that crash can occur.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
|
ID: aiam5421OpenJohn E. Gillick, Esq. Winthrop, Stimson, Putnam & Roberts 1133 Connecticut Ave., N.W. Washington, DC 20036; John E. Gillick Esq. Winthrop Stimson Putnam & Roberts 1133 Connecticut Ave. N.W. Washington DC 20036; Dear Mr. Gillick: This responds to your request for an interpretatio of the phase-in requirements of Standard No. 214, Side impact protection. In the alternative, you also petition NHTSA to grant your client, Automobili Lamborghini S.p.A. (Lamborghini), a temporary exemption from Standard No. 214 until September 1, 1996, pursuant to 49 CFR part 555, Temporary exemption from motor vehicle safety standards. By way of background, on October 30, 1990 (55 FR 45722), NHTSA published a final rule establishing new dynamic performance requirements for Standard No. 214, and two alternative phase-in schedules for manufacturers to comply with the new requirements. You write that Lamborghini was owned by Chrysler Corporation at the final rule's publication, and Lamborghini planned to comply with Standard No. 214's phase-in schedule by being counted as part of Chrysler's fleet. You write that on January 31, 1994, Chrysler sold Lamborghini. You state that Lamborghini, on its own, is not able to meet either of the two phase-in schedules established in Standard No. 214. Thus, despite Lamborghini's sale, you are asking NHTSA to permit Chrysler to include Lamborghini's vehicles as part of Chrysler's fleet for purposes of compliance with Standard No. 214's phase-in schedule. We are unable to interpret the phase-in requirements of Standard No. 214 as you suggest. This is because these requirements apply to vehicles 'produced by more than one manufacturer,' and the vehicles in question will not be. Alternatively, we have further determined that your request would be most appropriately resolved by treating it as a petition pursuant to part 555. We are presently reviewing your submission pursuant to part 555, and anticipate issuing a proposed decision shortly. If you have any questions, please contact Mr. Z. Taylor Vinson of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
|
ID: aiam0623OpenMr. William C. McCamant, Washington Representative, Automotive Service Industry Association, 1725 K Street, N.W., Washington, DC 20006; Mr. William C. McCamant Washington Representative Automotive Service Industry Association 1725 K Street N.W. Washington DC 20006; Dear Mr. McCamant: This is in reply to your letter of February 23, 1972, concerning th requirements of section 573.6 (Owner lists) of the Defect Reports regulations (49 CFR Part 573).; In your letter you describe a situation where manufacturers perfor modifications to heavy duty vehicles for dealers and may have difficulty, for competitive reasons, in obtaining the name of the ultimate purchaser. You ask that in this situation, these manufacturers be permitted, in meeting the requirements of section 573.6, to list the dealer as the 'first purchaser,' '. . . so that if a defect arises, the owners of record will be notified -- and, where applicable, the owners of record could notify the ultimate owners (usually warranty holders) of the defective vehicles.'; The requirement that an owner list be maintained under section 573. does not arise until a defect notification campaign is undertaken. The compilation of such a list at that time, however, would of necessity be based on some existing source of all owner names. One such source could be, and probably will be in most situations, a list compiled at the time of sale for warranty purposes. This is apparently the situation you have in mind.; If a manufacturer has only the name of his dealer as the firs purchaser, then we would consider using that name in his compilation as meeting the owner list requirement. The manufacturer would still be responsible for maintaining and updating the list as specified in section 573.6, and for obtaining the updated information from the dealer if it is the latter who is correcting the vehicles in question. If the manufacturer is making the corrections, of course, the updated information will be readily available to him.; With regard to your assumption, '. . . so that if a defect arises, th owners of record will be notified -- and, where applicable, the owners of record could notify the ultimate owners (usually warranty holders) of the defective vehicles,' the requirement for notification of owners (Section 113 of the National Traffic and Motor Vehicle Safety Act) is separate from the requirement for compiling owners lists, and specifically excludes notification of dealers. While manufacturers may make arrangements with dealers and distributors for conducting notification campaigns, the ultimate responsibility for conducting the campaign lies with the manufacturer, and he does not meet this responsibility by merely notifying dealers.; At the same time, we would expect to be notified at once should dealer both insist on keeping his customer list confidential from the manufacturer and refuse otherwise to cooperate with the manufacturer, so that notification letters cannot be sent.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam1931OpenMr. Kenneth B. Kramer, Floyd, Kramer & Lambrecht, 220 Western Federal Savings Building, Colorado Springs, CO 80902; Mr. Kenneth B. Kramer Floyd Kramer & Lambrecht 220 Western Federal Savings Building Colorado Springs CO 80902; Dear Mr. Kramer: This responds to your letter of April 25, 1975, concerning th applicability of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to the Wabco Westinghouse Duo-Matic Coupler.; You have described the Coupler as a device which replaces the glad han coupler now used by most manufacturers to connect truck tractor and trailer brake lines. Because the brake hose which attaches to the Coupler is equipped with its own end fittings, the Coupler itself is not an end fitting. Therefore, Standard No. 106-74 is inapplicable.; The Coupler is, however, subject to the requirements of 49 CFR Par 393.45 and 393.46, of which I have enclosed a copy. Please direct any questions you may have concerning interpretation of these requirements to the Office of the Chief Counsel, Federal Highway Administration, at 400 Seventh St., S.W., Washington, D.C. 20590.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam5071OpenMr. Christopher Leone NewBold Designs 765 Allens Avenue Providence, R.I. 02905; Mr. Christopher Leone NewBold Designs 765 Allens Avenue Providence R.I. 02905; "Dear Mr. Leone: This responds to your FAX of August 6, 1992, to Taylo Vinson of this Office, asking for rules and regulations of the Department on electric vehicles. I understand that you talked with Mr. Vinson later in the day, and received an overview of the matter. I further understand that you intend only the construction of a single experimental vehicle, and have no plans for its production. Under the National Traffic and Motor Vehicle Safety Act, the introduction into interstate commerce, by any person, of a motor vehicle that does not conform to all applicable Federal motor vehicle safety standards is a violation, for which a civil penalty of up to $1,000 may be imposed. The Federal motor vehicle safety standards are set out in Title 49 Code of Federal Regulations Part 571. There are no standards that apply specifically to electric vehicles, and the standards that apply to your project car are those that apply to 'passenger cars' in general. However, the manufacturer of an electric vehicle may petition us for a temporary exemption (up to 2 years) from one or more of the safety standards on the basis that the exemption would facilitate the development and field evaluation of a low-emission motor vehicle. The temporary exemption regulations are found at 49 CFR Part 555. An exemption covers up to 2,500 vehicles per year for any 12-month period that the exemption is in effect. Regulations governing the licensing of motor vehicles are the prerogative of the individual States. Thus, you should inquire as to what Rhode Island requires for your contemplated vehicle. There is a regulatory gap which your situation highlights, and that is the legal status of a person who intends to build only a single motor vehicle. Such a person is not a 'manufacturer' under the Act, since the operative portion of the definition of 'manufacturer' is one who manufactures or assembles 'motor vehicles'. The temporary exemption authority appears directed towards commercial enterprises and not single motor vehicles. Nevertheless, we believe we have the authority to exempt a single motor vehicle under these provisions. If you wish to consult us further in this matter, Taylor Vinson will be pleased to help you. Sincerely, Paul Jackson Rice Chief Counsel"; |
|
ID: aiam0789OpenMr. K. Kreuger, Manager, Emissions, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ, 07632; Mr. K. Kreuger Manager Emissions Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kreuger: This is in response to your letter of March 21, 1972, petitioning t amend Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' Your petition both requests that amendments be made to the standard, and comments on the notice of proposed rulemaking published May 26, 1971 (36 F.R. 9565). For the reasons indicated below, your petition is hereby denied.; You petition that the 4- inch-per-minute burn rate specified in th standard be changed to 12- inches-per-minute. Your argument is that a 4-inch-per-minute rate is unreasonable because variations in the burn rates of materials make it impossible, without averaging test results, to guarantee a 4-inch-per- minute rate for the majority of materials used in vehicle interiors. You suggest that a 12-inch-per-minute rate is reasonable because only 1.2 inches of material would burn in 6 seconds, the time you specify as necessary for a vehicle to be stopped from 70 mph, and maintain that a 12- inch-per-minute rate should at least be specified until the NHTSA compiles a list of approved fire retardant additives.; Your request to change the 4- inch-per-minute burn rate to one of 1 inches is denied. The 4-inch-per- minute rate was incorporated into the standard as a result of the agency's determination that it provides a flammability rate sufficiently low to provide adequate escape time from a vehicle, in the event fire should occur. In addition, the combustion by-products of some vehicle interior materials are such that the materials must burn at a rate that is low enough that vehicle occupants will not be overcome or panicked by harmful gases before they can escape from the vehicle. We believe that a 4-inch- per-minute burn rate is necessary to respond to this need. With respect to the justification you provide for a 12-inch-per-minute burn rate, the NHTSA does not agree that this test reflects adequate escape time. Testing at the University of Oklahoma has indicated, rather, that escape times that are needed exceed considerably the time needed to merely stop a moving vehicle. It must also be remembered that materials burn most slowly in the horizontal position, and therefore the laboratory horizontal burn rate cannot be used as a direct indication of how much material might be burned in an on-the-road event.; The NHTSA does not agree that the 4- inch-per-minute rate should b modified because the burn rates of identical materials may vary. While we understand that such variations do occur, this fact will be taken into account, along with the frequency and extent of test failures, in assessing whether a manufacturer has exercised due care in meeting the standard. It would not be appropriate, however, to respond to the problem of variability by relaxing the burn rate. Such an action would probably result simply in manufacturers choosing cheaper and less safe materials. With reference to your request that the standard provide for the averaging of burn rate results, the structure of the motor vehicle safety standards does not allow for the averaging of test results. This is because the NHTSA must be able to establish firmly that a material does not conform to the requirements, on the basis of a limited-sample test. This requires that each material meet the requirements when subjected to the test procedures of the standard. Again, minor and occasional deviations will be considered similarly to problems involving variability, in assessing whether a manufacturer has used due care.; Your request that the NHTSA approve flame-retardant treatments if th 4-inch- per-minute rate is maintained is denied. The NHTSA does not specify materials which manufacturers are to use to conform to standards. The responsibility for conformity rests with manufacturers and it is for them to determine which materials and treatments they should use to meet the standard's requirements.; You have requested a one-year delay in the effective date of th standard. This request is denied. The NHTSA believes the effective date of September 1, 1972, has provided sufficient time for manufacturers to conform to the standard's requirements.; With reference to the test procedures of the standard, you petitio that a test cabinet recommended by Daimler-Benz be substituted for the test cabinet specified in the standard, arguing that the Daimler-Benz cabinet provides better ventilation, faster dissipation of smoke, a lower heat buildup, and more uniform test results. The NHTSA will evaluate, as part of its compliance program, the test procedures of the standard. If the NHTSA determines that the test procedures should be modified to improve the reliability of results, the characteristics of the Daimler-Benz cabinet as well as other available information will be utilized in evaluating possible changes in these procedures. If manufacturers do use other test procedures, they should correlate, to support a showing of 'due care,' the results they obtain with results obtained using the procedures specified in the standard.; You also request that the standard be amended to provide for th conditioning of samples within a range of 73.5 degrees F. *+* 3.5 degrees, and a relative humidity of 50 *+* 5%. The standard presently specifies a conditioning temperature of 70 degrees F. at a relative humidity of 50%. This request is denied. Test conditions are specified as exact values in the motor vehicle safety standards because they represent a legal standard, not manufacturers' procedures. Manufacturers should design their tests, choosing their own procedures as necessary, to ensure that the materials will perform satisfactorily at the specified conditions.; You have also requested a more precise definition of the gas used i the test procedure, and that the standard specify a ventilated hood. These requests are denied. The NHTSA has judged the description of the gas to be used in the test cabinet to be sufficiently specific. With respect to ventilation of the test cabinet, manufacturers are free, subject to the limitations described above, to modify this aspect of the procedure as well.; You also request that the standard be amended to exclude smal components, and comment on the notice of proposed rulemaking of May 26, 1972, to the effect that neither testing both sides of materials nor testing separate padding materials should be required. Each of these points is being considered as part of our preparation of an amendment to the standard, based on the notice of May 26, 1971. Your comments on these matters have been considered in the preparation of this amendment, which we plan to publish in the near future.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
|
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.