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: aiam4494OpenMr. Troy C. Martin Specifications/Inspections Chief Texas State Purchasing & General Service Commission Lyndon Baines Johnson State Office Bldg. P.O. Box 13047 Capitol Station Austin, Texas 78711-3047; Mr. Troy C. Martin Specifications/Inspections Chief Texas State Purchasing & General Service Commission Lyndon Baines Johnson State Office Bldg. P.O. Box 13047 Capitol Station Austin Texas 78711-3047; "Dear Mr. Martin: This is a response to your letter of last year wher you stated your concern respecting the installation of 'latches' on the rear doors of a school bus of 10,000 lbs or less GVWR (small school bus), and asked a number of questions on release mechanisms for required rear emergency doors on these small school buses. I regret the delay in this response. You said that the State of Texas has a school bus specification that requires 'the first-closed (left-hand) door)' to have a latching mechanism at the top and bottom. Your supplier tells you that this specification conflicts with provisions of Federal safety standard 217, Bus Window Retention and Release (Standard 217). You go on to express your concern that a single mechanism would hold both doors closed, and that this feature increases the risk of injury from accidental or intentional opening. You believe that where a small school bus has two rear doors, if each door is secured independently, then there is a decreased risk of a student's falling through a door opened inadvertently. Let me begin my answer with some general information on the requirement for a rear emergency door in a small school bus. As your supplier suggests, there can be instances where independently securing the rear doors on a small school bus would violate Standard 217. Paragraph S5.2.3.1 requires a manufacturer of these buses to install either (1) one rear emergency door, or (2) one emergency door on the vehicle's left side and one push-out rear window. Where a manufacturer chooses to meet this requirement by installing one rear emergency door, the door may be hinged on either side of the vehicle. When a manufacturer installs more than one rear door exit, the question of whether both exits are 'emergency doors' under paragraph S5.2.3.1 of Standard 217 depends upon whether one or both doors must be opened for unobstructed passage of a specified parallelepiped under paragraph S5.4.2.2. The purpose of the school bus emergency exit requirements is to facilitate quick and safe rider exit from the vehicle in the event of an emergency. (44 FR 7961, 7962, February 8, 1979.) Question 1: Are both of the rear doors on small school buses (with GVWR of 10,000 lbs or less) considered 'emergency doors' in the context of Paragraph S5.2.3.1 of FMVSS 217? If a manufacturer installs more than one rear door on a small school bus, and intends one door to be a rear emergency door under S5.2.3.1 and one to be a regular door for loading and unloading passengers, then the designated rear emergency door is a sufficient rear emergency exit so long as it will permit unobstructed passage of the device specified in paragraph S5.4.2.2 of the Standard. In a case such as this one, the manufacturer must label the emergency door appropriately, and otherwise ensure that the designated rear emergency door meets the performance, accessibility, and release requirements for a rear emergency door on a small school bus. On the other hand, if the manufacturer installs two rear doors on a small school bus, and if both of those doors must be open to accommodate the parallelepiped, then both doors constitute a rear emergency exit under S5.2.3.1. In this case, the two doors together must meet the applicable provisions of Standard 217. There is yet another possibility that a manufacturer may install a second rear exit and designate it as an emergency exit. Assuming that at least one exit meets Standard 217's requirements for a rear emergency door exit, NHTSA would not prohibit installing this additional emergency exit. However, as the agency long has held, that 'extra' emergency exit must comply with Standard 217 provisions applicable to emergency exits in buses other than school buses. Question 2: Does Paragraph S5.3.3 require separate, independent operation, that is, must one be able to open the left-hand door without first opening the right-hand door from outside of the passenger compartment? Again, the answer to this question depends upon whether one door can meet the unobstructed test measurement for a required rear emergency door. Let me begin this answer by explaining the release requirements for a rear emergency door on a small school bus. Under paragraph S5.3.3, a required small school bus rear emergency door generally must have a release mechanism that allows (1) a single person (2) to operate the door manually (3) from in or outside the vehicle's passenger compartment without the use of remote controls or tools (4) irrespective of whether the vehicle's power system fails. (Paragraph S5.3.3 also sets the maximum permissible magnitude of force and the permissible direction in which a force must be applied to operate the release mechanism.) In an interpretation of March 17, 1982, this agency stated that the release mechanism is the mechanism that keeps the door from opening. In other words, the release mechanism is what you refer to in your letter as the door 'latch.' If the test device described in my answer to your first question passes through unobstructed only when both doors are open, then the door release mechanism must be operable for both doors from inside the vehicle passenger compartment irrespective of whether a person outside the vehicle operates the outside release mechanism. Further, this same release mechanism must be operable from outside the vehicle. In this circumstance, a separate release mechanism for each door would not comply with the Standard. If only one door needs to be open, and the manufacturer has designated the second door as an emergency exit, then this additional emergency door still must be operable from inside the passenger compartment. In this case, independent release mechanisms may be appropriate, but a release mechanism on an additional emergency exit need not be operable from outside the vehicle. (S5.3.2.) If only one door needs to be open to accommodate the parallelepiped, and the manufacturer neither intends the second door to be an emergency door, nor designates it as an emergency exit, then the second door is a regular door for loading and unloading passengers. Standard 217 would be inapplicable to this second door. Question 3: Does Paragraph S5.3.3 require a warning system to indicate an opened position of any latch or latches on the left-hand door even though this door cannot be opened until after the right-hand door is opened, provided both doors must be opened to insert the 45' high by 22' wide x 6' deep parallelepiped? If both doors must be opened for unobstructed passage of the specified parallelepiped, then there must be a single emergency release mechanism (or latch) for both doors. In a case such as this, there must be an audible alarm under S5.3.3 whenever the release mechanism is not closed and the vehicle ignition switch is 'on.' That alarm should sound if either door is unsecured. Question 4: Would a warning system be required to indicate opened latch or latches on the left-hand door as in 3 above, provided the parallelepiped could be inserted into the passenger compartment through the opened right-hand door with the left-hand door closed? In your question, the manufacturer may designate either door as the required S5.2.3.1 emergency exit if the door accommodates the test device. The warning system then must sound when the release mechanism on the designated rear emergency door is open and the vehicle ignition switch is 'on.' For example, if in your question, the manufacturer designated the right-hand door as the required rear door emergency exit, then the warning system must sound whenever the release mechanism for that door is open and the vehicle ignition position is 'on.' As I stated in Question 1, the second rear door could be an 'additional' emergency exit, or a regular means for loading and unloading passengers, then the additional door would have to meet such other requirements as may apply to these exits. Question 5: Would a latch or latches be required on the left-hand door if both doors had to be opened to insert this parallelepiped even though the left-hand door is close by the latches of the right-hand door? In this circumstance, Standard 217 would prohibit installing a separate release mechanism on each door. Recall that S5.2.3.1 requires on a small school bus, 'one rear emergency door,' or one side door and one push-out window. If the manufacturer chooses to install the rear emergency door, then under S5.4.2.2, the specified parallelepiped must pass through that rear emergency door without obstruction. If both doors must be open to accommodate the test device, then both doors constitute the single, rear emergency door which the Standard requires. Under paragraph S5.3.3, the required rear emergency door must have its own release mechanism. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam0984OpenMr. Don Riggs, Mechanical Engineer, Motorola, Inc., 1301 E. Algonquin Road, Schaumburg, IL 60172; Mr. Don Riggs Mechanical Engineer Motorola Inc. 1301 E. Algonquin Road Schaumburg IL 60172; Dear Mr. Riggs: This is in reply to your letter of January 8, 1973, in which you as whether Federal Motor Vehicle Safety Standards apply to after-market equipment, and if so, which standards so apply. There are some Federal Motor Vehicle Safety Standards that apply to after-market items, although most do not. The standards which apply are as follows: No. 106, 'Hydraulic Brake Hoses', No. 108, 'Lamps, Reflective Devices, and Associated Equipment', No. 109, 'New Pneumatic Tires', No. 116, 'Hydraulic Brake Fluids', No. 117, 'Retreaded Pneumatic Tires', No. 125, 'Warning Devices', No. 205, 'Glazing Materials', No. 209, 'Seat Belt Assemblies', No. 211, 'Wheel Nuts, Wheel Discs, and Hub Caps', and No. 213, 'Child Seating Systems'.; You ask further whether there are any States that have motor vehicl safety standards applicable to after-market items of motor vehicle equipment. Whenever a Federal safety standard is in effect, State or local regulations applying to the same aspect of performance must be identical to it (15 U.S.C. 1392(d)). It is possible that some State or local authorities have requirements for some areas not covered by the Federal standards, but you will have to collect such information from those authorities.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0792OpenMr. J. Mulvey, Bakelite Xylonite Limited, Industrial Products Division, Brantham, Manningtree, Essex COll lNJ (sic), England; Mr. J. Mulvey Bakelite Xylonite Limited Industrial Products Division Brantham Manningtree Essex COll lNJ (sic) England; Dear Mr. Mulvey: Thank you for your letter of June 28, 1972, inquiring about th applicability of Federal Motor Vehicle Safety Standard No. 302 to safety glazing.; Safety glazing is not included in the list of motor vehicle interio materials to which Standard No. 302 applies. However, if your plastic material is used as all or part of a component of vehicle occupant compartments included under S4.1 of the standard, then, it is required to meet the requirements of Standard No. 302. A copy of this standard is enclosed for your reference.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0268OpenCharles O. Verrill, Jr., Esq., Messrs. Patton, Blow, Verrill, Brand & Boggs, 1200 17th Street, N.W., Washington, DC 20036; Charles O. Verrill Jr. Esq. Messrs. Patton Blow Verrill Brand & Boggs 1200 17th Street N.W. Washington DC 20036; Dear Mr. Verrill: In your letter of November 16 you inquire whether the Bureau' interpretation of 'overall width' (49 CFR S 571.21, with reference to Federal Motor Vehicle Safety Standard No. 108) can 'embrace the situation where the entire lighting assembly, including the taillamps, stop lamps, and back-up lamps, as well as signal lamps, add to the dimension of the vehicle'.; Since 'overall width' means 'the nominal design dimension of the wides part of the vehicle exclusive of signal lamps [and] marker lamps . . . .', the Bureau concurs in your requested interpretation. Taillamps, stop lamps, and back-up lamps are 'signal' lamps, and their combined mounting in a fixture which may extend beyond the widest part of a boat trailer does not result in a corresponding increase in the 'overall width' of the trailer.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5590OpenMr. Jim Burgess Engineering Manager Independent Mobility Systems, Inc. 4100 West Piedras St. Farmington, NM 87401; Mr. Jim Burgess Engineering Manager Independent Mobility Systems Inc. 4100 West Piedras St. Farmington NM 87401; Dear Mr. Burgess: This responds to your letter of May 18, 1995 to thi office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system. You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no. FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states: S ide doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not conform to this standard. FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion. While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that 'lift' includes 'ramp.' In order to amend the standard to exclude wheelchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriate. I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures (2) 1985 final rule Part 552; |
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ID: aiam2255OpenMr. J.L. Chancey, President, Trail-O-Matic, Inc., P.O. Box 2367, Jacksonville, FL 32203; Mr. J.L. Chancey President Trail-O-Matic Inc. P.O. Box 2367 Jacksonville FL 32203; Dear Mr. Chancey: This responds to your March 8, 1976, request to know the status of 'lo trailers' under Standard No. 121, *Air Brake Systems*, whether the exclusion for 'heavy hauler' trailers terminates September 1, 1976, and what the penalties are for non-compliance with an applicable Federal motor vehicle safety standard. You indicate that you may know of some manufacturers that do not comply with Standard No. 121 and suggest that all persons concerned with the standard be advised of the status of the regulation.; Without description of the 'log trailers' in question, it is no possible to determine if Standard No. 121 applies to them. Most pole trailers and trailers equipped with any axle having a gross axle weight rating of 24,000 pounds or more are examples of vehicles that may be excluded from the standard. Mr. Herlihy of this office has already sent applicable documents to you under separate cover. The exclusion from the standard for 'heavy hauler' trailers was extended recently and now terminates September 1, 1977.; Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Ac (15 U.S.C. S1397(a)(1)) prohibits the sale and false or misleading certification of a non-complying vehicle to which a standard is applicable. Each violation of these provisions makes the manufacturer liable to a maximum civil penalty of $1,000 for each violation, up to a total of $800,000 for a related series of violations. (15 U.S.C. S1398). You may advise our Office of Standards Enforcement of any violations of which you are aware.; The NHTSA finds it impracticable to notify directly every intereste person of each of its regulatory actions. Each action is made public and is widely distributed by commercial services and trade associations. Enclosed is an information sheet that explains the various means to obtain copies of our regulations.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0507OpenMr. Albert D. Ekegren, Vice President and General Manager, Cats-Eye Lamp Division, Holophane Company, Inc., P.O. Box 567, Columbus, OH, 43216; Mr. Albert D. Ekegren Vice President and General Manager Cats-Eye Lamp Division Holophane Company Inc. P.O. Box 567 Columbus OH 43216; Dear Mr. Ekegren: This is in response to your letter of October 27, 1971, to David H Soule of the National Highway Traffic Safety Administration concerning the requirements of Motor Vehicle Safety Standard No. 108 for school bus lighting.; You are concerned with paragraph S4.1.4(b)(ii) which reads: >>>'The system shall be wired so that the amber signal lamps ar activated only by manual or foot operation, and if activated, are automatically deactivated and the red signal lamps automatically activated when the bus entrance door is opened.'<<<; You have commented that 'the use of the automatic system would make i mandatory that the red lights go on when the door is open and stop traffic where unnecessary--such as railroad crossings.' That is not correct. You will see from S4.1.4(b)(ii) that the red lamps are not automatically activated when the bus entrance door opens unless there has been prior manual or foot activation of the amber signal lamps.; You are also concerned with the fact 'that this automatic system i patented and only one manufacturer has the right to make it.' Since you have not enclosed the copy of the patent enclosed in attorney Smith's letter to you dated June 4, 1970, I am unable to comment on your statement. I would like to point out that Standard No. 108 does not mandate the use of an amber-red lamp system, a system of red lamps only is also permissible. If the amber-red lamp system is used, paragraph S4.1.4(b)(ii) does not specify system design but only that the system be wired so that the driver can activate the amber lamp system at his option, and if he does activate it, that it automatically be deactivated and the red system automatically activated when the bus entrance door is opened.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4817OpenMs. Carol C. Verenes District Transportation Supervisor Aiken County Public Schools 843 Edgefield Avenue, N.W. P.O. Box 1137 Aiken, South Carolina 29802-1137; Ms. Carol C. Verenes District Transportation Supervisor Aiken County Public Schools 843 Edgefield Avenue N.W. P.O. Box 1137 Aiken South Carolina 29802-1137; "Dear Ms. Verenes: This responds to your letter of September 7, 199 requesting 'written correspondence relative to the U.S. Department of Transportation, National Highway Traffic Safety Administration, adopted safety standards effective April 1, 1977, which applies to vans transporting school children.' Additionally, you requested 'information pertaining to Federal Motor Vehicle Safety Standards No. 220, 221, and 222' because your district is considering modifying vans to transport school children. By telephone conversation with Mary Versailles of my staff on September 28, 1990, you stated that your school district has stopped using its 12-15 passenger vans to transport school children, because you had been informed that such use violated federal law. You requested information on what needed to be done to modify your vans to comply with Federal school bus regulations. You also asked if a dealer who had sold your school district new vans which did not comply with school bus regulations would be required to modify the vans or replace them with complying vans. I am pleased to have this opportunity to clarify the operation of Federal law as it applies to school buses. Federal law regulates the manufacture and sale of new school buses. The National Highway Traffic Safety Administration (NHTSA) defines 'school bus' as a motor vehicle designed for carrying 11 or more persons, including a driver, and sold for transporting students to and from school or school-related events. Note that in determining whether a vehicle is a school bus, one must consider both the vehicle's seating capacity, and its intended use. Thus, under federal law, a 12-15 passenger van is considered a school bus if its intended use is to transport school children. 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 sell as a school bus any new 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 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 use of vehicles. Therefore, to determine whether your school district may use noncomplying vans to transport school children, you must look to state law. In addition, using noncomplying vans as a school bus could result in increased liability in the event of an accident. You might want to consult your attorney and insurance company to discuss this matter. Your first question asked what must be done to bring your vans into compliance as a school bus. Again, I must emphasize that there is no regulation under Federal law requiring your school district to retrofit your vans to comply with federal regulations. However, the following is a list of all Federal motor vehicle safety standards that include requirements for school buses: Standards No. 101 through 104, Standard No. 105 (school buses with hydraulic service brake systems), Standards No. 106 through 108, Standards No. 111 through 113, Standard No. 115, Standard No. 116 (school buses with hydraulic service brake systems), Standards No. 119 and 120, Standard No. 121 (school buses with air brake systems), Standard No. 124, Standards No. 201 through 204 (school buses with GVWR of 10,000 pounds or less), Standard No. 205, Standards No. 207 through 210, Standard No. 212 (school buses with GVWR of 10,000 pounds or less), Standard No. 217, Standard No. 219 (school buses with GVWR of 10,000 pounds or less), Standard No. 220, Standard No. 221 (school buses with GVWR greater than 10,000 pounds), Standard No. 222, Standards No. 301 and 302. Some of the standards which have unique requirements for school bus vehicles include, but are not necessarily limited to, Standards No. 105, 108, 111, 217, and 301, other standards (220, 221, and 222) are applicable only to school bus vehicles. Modification of the vehicles to comply with Standards No. 220 and 222 will be difficult and require recertification. The Federal motor vehicle safety standards are contained in Title 49 of the Code of Federal Regulations (CFR), Part 571. You may find a copy of 49 CFR Part 571 at a Federal Depository Library in your State. If you so choose, you may purchase a copy of the volume of Title 49 which includes Part 571 from the United States Printing Office (GPO), Washington, D.C., 20402, (202) 783-3238. Your second question asked whether the sale between the dealership and the school could be dissolved if you determined that any purchases of new vans did not comply with the regulations for school buses. While we have no regulations which void or 'dissolve' sales of noncomplying motor vehicles, the school might be able to contact the dealership that sold the noncomplying school buses and arrange to have the vehicles repurchased. In addition, if you believe that you had been sold noncomplying vehicles, and that the dealer knew of your intended use, the school should contact NHTSA's Office of Vehicle Safety Compliance, at the address given above, and inform them of the apparent violation of federal law. In the past, many dealers who have been notified by NHTSA of the illegality of selling noncomplying vans as school vehicles repurchased the vehicles that were sold in violation of the law. However, these instances involved essentially new vehicles. Section 154(a)(2)(A)(iii) of the Safety Act specifies the repurchase remedy as, 'the purchase price of such motor vehicle in full, less a reasonable allowance for depreciation' (emphasis added). Thus, it may be more cost efficient for the school district to use these vans for other purposes within the district or transfer them to other county functions. For future vehicle purchases, it may be advisable to inform dealers specifically that the vehicles will be used for transporting school children. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0157OpenMr. LaVern Goetz, State Chemist, Corporation Commission of Oklahoma, Jim Thorpe Building, Oklahoma City, Oklahoma 73105; Mr. LaVern Goetz State Chemist Corporation Commission of Oklahoma Jim Thorpe Building Oklahoma City Oklahoma 73105; Dear Mr. Goetz: This is in reply to your letter of April 15, 1969, in which you inquir about Federal regulation of brake fluid.; Brake fluid performance is regulated under the National Traffic an Motor Vehicle Safety Act by Federal Motor Vehicle Safety Standard No. 116. Copies of the Act and the current standards are enclosed.; Under the Vehicle Safety Act, manufacturers of motor vehicles an equipment (including brake fluid) that are covered by standards are fully responsible for ensuring that all of their products conform to the standards. The National Highway Safety Bureau conducts conformity tests of vehicles and equipment, either through its own personnel and facilities or under contract with other public or private testing organizations, but these are for enforcement purposes only.; The Bureau is conducting a continuing series of tests on brake fluid that has included samples from a majority of the major manufacturers, and will include the remainder in the near future. If you need more detailed information concerning this testing program, I suggest that you contact Mr. Francis Armstrong, Director, Office of Performance Analysis, National Highway Safety Bureau, Federal Highway Administration, Washington, D.C. 20591.; In answer to your final question, Standard No. 116 applies to all brak fluid manufactured or sold in the United States, and is not limited to that sold by automobile manufacturers or distributors.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam5355OpenHerr Tilman Spingler Robert Bosch GmbH Automotive Equipment Div. 2 Postfach 13 42 D-72703 Reutlingen Germany; Herr Tilman Spingler Robert Bosch GmbH Automotive Equipment Div. 2 Postfach 13 42 D-72703 Reutlingen Germany; Dear Mr. Spingler: This responds to your letter of March 25, 1994 asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems. You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are 'requirements for this cable concerning indivisibility and integration . . . .' There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design. Sincerely, John Womack Acting 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.