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: aiam4456OpenMr. J.V. McFadden President MTD Products Inc. P.O. Box 36900 Cleveland, Ohio 44136; Mr. J.V. McFadden President MTD Products Inc. P.O. Box 36900 Cleveland Ohio 44136; Dear Mr. McFadden: This responds to your letter concerning th applicability of Federal or State requirements to a hydraulic logsplitter mounted on a frame carriage equipped with highway high speed wheels and a trailer towing hitch. While we can not answer your question concerning applicable State requirements, we provide the following information on the applicability of Federal motor vehicle safety standards. By way of background information, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse commercial products. Instead, the Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer is required to certify that its products meet all applicable safety standards. The Vehicle Safety Act prohibits the manufacture or sale of a noncomplying product unless, despite the exercise of due care, the manufacturer doesn't have reason to know that the noncompliance exists. Any vehicle that falls within the statutory definition of the term 'motor vehicle' must comply with all applicable safety standards. Section 102(3) of the Vehicle Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. We have interpreted this language as follows. The definition does not include equipment which uses the highways only to move between job sites and which typically spends extended periods of time at a single job site. In this case, the on-highway use of the vehicle is merely incidental, and is not the primary purpose for which the vehicle was manufactured. On the other hand, when a vehicle frequently uses the highway going to and from job sites, and stays at the job site for only a limited time, it is the agency's position that the vehicle in question is a 'motor vehicle' in the statutory sense, since the on-highway use is more than 'incidental'. Notwithstanding the foregoing, a vehicle is not classified as a motor vehicle if it is of such an unusual configuration that it is easily distinguished from normal traffic and it has a top speed of not more than 20 miles per hour. A determination of whether or not a vehicle falls within the definition of motor vehicle is based upon a consideration of all of the above factors. Given the information that you have provided us, it appears that the hydraulic log-splitter is a motor vehicle. From the picture in the brochure, it is clear that the vehicle has an unusual configuration. This alone, however, is not adequate to prevent a determination that the vehicle is a motor vehicle within the meaning of the statute. More important is the fact that the vehicle may make frequent use of the highway, staying at one particular job site a limited amount of time. The provision of highway speed tires indicates the manufacturer's intention to produce a vehicle which is suitable for driving at highway speeds. Because the tow-behind logsplitter is equipped with a trailer tow hitch, we would consider the vehicle a trailer, defined in the agency's regulations as: a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle. (See 49 CFR 571.3.) The safety standards which apply to all trailers are Standard No. 108, Lamps, reflective devices, and associated equipment, Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars, and Standard No. 115, Vehicle Identification Number--Basic Requirements. The content requirements for the vehicle identification number are found at Part 565. In addition, if the trailer is equipped with brakes, it must meet Standard No. l06, Brake hoses, Standard No. 116, Motor vehicle brake fluids, and applicable requirements of Standard No. 121, Air brake systems. All of these standards are found in 49 CFR Part 571. We regret the delay in responding to your request. If you have further questions on this matter, please contact us. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam3239OpenMr. David T. Steadman, Senior Section Engineer, Project and Development Center, British Standards Institution, Maylands Avenue, Memel Hempstead, Herts HP2 4SQ England; Mr. David T. Steadman Senior Section Engineer Project and Development Center British Standards Institution Maylands Avenue Memel Hempstead Herts HP2 4SQ England; Dear Mr. Steadman: Please accept my apologies for our delay in responding to your lette of November 30, 1979. You asked whether five enumerated types of machinery capable of highway travel would be considered motor vehicles to which Federal Motor Vehicle Safety Standards and fuel economy standards would apply. The vehicles enumerated in your letter were:; >>>Wheel-mounted front-end loader, Crawler-mounted front-end loader Crawler- mounted hydraulic excavator, (Rough terrain) fork lift truck, Backhoe-loader<<<; As explained below, these vehicles are not subject to fuel econom standards. However, without more detailed information concerning these machines, we cannot give you a definitive answer as to their possible classification as motor vehicles to which Federal motor vehicle safety standards may be applicable. Nonetheless, we can provide you with guidelines for use in determining the status of these vehicles.; Pursuant to Title V of the Motor Vehicle Information and Cost Saving Act (15 U.S.C. 2001), this agency has promulgated regulations which establish the categories of motor vehicles that are subject to fuel economy standards. The regulations (49 CFR Part 523, copy enclosed) state that fuel economy standards are applicable only to automobiles, light trucks, and automobiles capable of off-highway travel. The definitions of these items which appear in Part 523 do not appear to encompass the types of vehicles that you enumerated in your letter.; Our safety standards apply to a vehicle and its manufacturer only i the vehicle qualifies as a 'motor vehicle' under the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. Section 102(3) of the Act (15 U.S.C. 1391(3)) defines 'motor vehicle' as:; >>>any vehicle driven or drawn by mechanical power manufacture primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; Thus, a motor vehicle is a vehicle which the manufacturer has reason t expect will use public highways at least part of the time.; Tracked (i.e., crawler mounted) and other vehicles incapable of highwa travel are not motor vehicles. In addition, vehicles intended and sold solely for off-road use (e.g., aircraft runway vehicles and underground mining vehicles) are not considered vehicles even if operationally capable of highway travel. They would, however, be considered motor vehicles if the manufacturer knew that a substantial proportion of his customers actually would use them on the highway.; There are some vehicles which are excepted from the motor vehicl classification despite their use of the highway. Highway maintenance and construction equipment lane strippers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles.; Historically, the agency has regarded vehicles which use the highway o a necessary and recurring basis to move between work sites as motor vehicles. The primary function of such vehicles is of a mobile, workperforming nature and as such their manufacturer contemplates a primary use of the highway. Mobile cranes, rigs, and towed equipment such as chippers and pull-type street sweepers are examples of vehicles which, in the agency's views, qualify as trucks or trailers and, as such are subject to several of the Motor Vehicle Safety Standards.; However, in a recent decision the United States Court of Appeals fo the Seventh Circuit held that mobile construction equipment does not fall within the definition of 'motor vehicles' found in section 102(3) of the Act. *Koehring Co.* v. *Adams*, 605 F.2d 280 (7th Cir. 1979). The agency has decided not to seek certiorari to the United States Supreme Court. Accordingly, the agency considers itself to be bound by the court's judgment in *Koehring* within the territorial limits of the Seventh Circuit (i.e. the states of Illinois, Indiana and Wisconsin) although it has not yet formulated its policy with respect to the nationwide applicability of the court's holdings. A manufacturer seeking to export vehicles from the United Kingdom to any of these states might wish to consult an attorney who practices in the Seventh Circuit.; A copy of the *Koehring* decision is enclosed. Also enclosed is a information sheet containing advice for obtaining an up-to-date copy of the regulations which apply to motor vehicles and their manufacturers, and a copy of 49 CFR Part 523, *Vehicle Classification*.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1204OpenMr. Arthur E. Allen, President, SCARTI, 2042 S. Sepulveda, Los Angeles, CA 90025; Mr. Arthur E. Allen President SCARTI 2042 S. Sepulveda Los Angeles CA 90025; Dear Mr. Allen: This is in reply to your letter of July 19, 1973, to the Administrator. The exemption provided vehicles with a curb weight of 1,000 pounds o less will cease to exist as of January 1, 1974, and lightweight vehicles manufactured on or after that date will be required to meet all Federal motor vehicle safety standards applicable to their vehicle category, *e.g.* passenger cars.; Under the circumstances you indicate, you would be the final-stag manufacturer of a vehicle manufactured in two or more stages, under 49 CFR Parts 567 and 568 of our regulations. We refer you specifically to sections 567.5 and 568.6 of those regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4006OpenWarren F. B. Lindsley, Esq., Camel Square Suite 200E, 4350 East Camelback Road, Phoenix, AZ 85018; Warren F. B. Lindsley Esq. Camel Square Suite 200E 4350 East Camelback Road Phoenix AZ 85018; Dear Mr. Lindsley: This is in reply to your letter of July 3, 1985, to Mr. Vinson of m staff, with reference to the center high-mounted stop lamp, in which you have asked 'whether a light which pulsates a few times and then assumes a steady state meets the requirements of the code.'; As Mr. Vinson explained to you, a center high-mounted stop lam installed as original equipment on a passenger car manufactured before September 1, 1986, must be steady-burning in use, but is permitted to flash automatically with the hazard warning system. As of September 1, 1986, original equipment lamps must only be activated upon application of the service brakes, and can only be steady-burning. A 'light that pulsates a few times then assumes a steady state' would not fulfill this requirement.; The standard does not cover aftermarket equipment for vehicles no originally manufactured with the center high-mounted stop lamp. For this application, the law of each State where a retrofitted car would be operated would determine the legality of a pulsating/steady state lamp. The agency, of course, would prefer that aftermarket equipment conform as closely as possible to original vehicle equipment specifications. We believe that standardization of rear signals minimizes the possibility of creating confusion to following drivers in situations where immediate action is essential to avoid a rear end collision.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2701OpenHonorable Glen English, House of Representatives, Washington, DC 20515; Honorable Glen English House of Representatives Washington DC 20515; Dear Mr. English: This confirms the conversation between Judy Dutterer of your staff an Roger Tilton of my staff concerning the applicability of the new Federal school bus regulations to activity buses.; The Motor Vehicle and School Bus Safety Amendments of 1974 (Pub. L 93-492) defined school bus to include buses used to transport children to and from school and related events. In the legislative history of those amendments, Congress clearly indicated that all buses used to transport school children to and from events related to school should be covered by the new school bus safety standards. Accordingly, the National Highway Traffic Safety Administration requires that all activity buses designed to transport school children to and from such events comply with the new standards.; You should note that we have initiated rulemaking, in response to petition, to examine the issue of whether activity buses should have different requirements applicable to them since they are frequently involved in long distance student transportation. Any action on that issue will be published in the Federal Register.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3813OpenJohn F. Ingman, Esq., 107 Oakway Mall, Suite A, Eugene, OR 97401; John F. Ingman Esq. 107 Oakway Mall Suite A Eugene OR 97401; Dear Mr Ingman: This responds to your letter asking for an interpretation of Safet Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). More specifically, you stated that you represent a client who has designed a 'child's seat belt,' which is attached to the seat belts installed in the vehicle to restrain children. Before proceeding further with development work on this product, you indicated that you needed answers to a number of questions.; Your first question was whether the definition of 'child restrain system' in section S4 of Standard No. 213 prohibits the use of a system like your client's 'child's seat belt.' Section S4 defines a child restraint system as 'any device, except Type I or Type II seat belts, designed for use in a motor vehicle to restrain, seat, or position children who weight not more than 50 pounds.' Apparently you were concerned that the language excluding Types I and II seat belts from the requirements of Standard No. 213 prohibits the use of child seat belts as child restraints. That is not the case. Seat belts which are designed solely to restrain children who weigh not more than 50 pounds would be considered child restraint systems and be subject to all the requirements of Standard No. 213.; You raised a number of ancillary questions, to which I will respond i the order you presented them.; (a) You asked if sections S5.4.3.3 and S5.4.3.4 of Standard No. 21 require that, where belts are used to restrain a child, there be belts passing over each shoulder, a lap belt, and a crotch restraint. Those sections do so require. A belt system similar to that used by adults with a lap belt and a single shoulder belt could not be certified as complying with Standard No. 213.; (b) You stated that section S5.3.2 of Standard No. 213 prohibits child restraint, other than a child harness, system from being attached to a Type II shoulder belt as a restraint against forward movement of the child restraint system, and inquired if this language means that your child's seat belt could not use a shoulder belt as one of its anchoring points. No child restraint system can be attached to Type II shoulder belts during the testing specified in Standard No. 213.; As a related question, you inquired whether a child harness would b permitted to use a Type II shoulder belt as an anchorage point. This question apparently arises from the language in section S5.3.2, which reads: 'When installed on a vehicle seat, each child restraint system, other than a child harness, shall be capable of being restrained against forward movement solely by means of a Type I seat belt assembly (defined in S571.209) that meets Standard No. 208, or by means of a Type I seat belt assembly plus one additional anchorage strap that is supplied with the system and conforms to S5.4.' A child harness is not prohibited by S5.3.2 or any other provision of the standard from using a Type II shoulder belt as an anchoring point. However, the child harnesses manufactured in the past, and those envisioned when Standard No. 213 was promulgated, were devices with two tether straps which attach to each other after passing around the seat back. Hence, the child harness does not need to be attached to Type II belts to provide restraint against forward movement.; (c) You asked what parts of the child's seat belt would be considere 'the child restraint system.' Only the seat belts and the attachment hardware would be considered part of the child restraint system. The seat belts in the vehicle, the car's seats, and the adult holding a child using the child's seat belt are not part of the child restraint system.; (d) You indicated that your client was interested in recommending 'la applications' of the child's seat belt, in which the restrained child would have his or her belt attached to a seat belt in use by an adult at that time, and the child would be seated in the adult's lap. You asked if Section S4.1(a) of Standard No. 209 would prohibit such lap applications, since it required that seat belts be designed for use by only one person at any given time. A lap application of your child's seat belt would not violate that requirement, because the seat belt in the vehicle, which is the only one subject to the requirements of Standard No. 209, would still be designed for use by only one person, even though you were actually using it to restrain two people.; However, I urge you not to recommend this lap application of you client's child seat belt. In a crash situation, a lap application would result in the restrained child being exposed not only to the impact forces of the crash, but also being subjected to forces generated by the restrained adult. Additionally, a lap application could overload the adult's belts and anchorages and cause a failure of the entire belt system, leaving both the adult and child unrestrained in the crash. Either of these occurrences could result in more serious injuries to the restrained child, or avoidable injuries to both the child and adult, and expose your client to product liability difficulties.; (e) The buckle release requirements of Standard No. 209 are no applicable to child restraint systems. Those systems are subject to the buckle release requirements specified in section S5.4.3.5 of Standard No. 213.; (f) The adjustment requirements of Standard No. 209 are not applicabl to child restraint systems.; (g) You asked what standard applies to a seat belt system designed t restrain the 51-100 pound child. Standard No. 209 applies to all seat belt systems, except those designed to restrain children who weigh not more than 50 pounds. Any seat belt system designed for use by larger children would have to be certified as meeting all requirements of Standard No. 209.; If you have any further questions on this subject, please contact Mr Stephen Kratzke of my staff at this address or by telephone at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5494OpenMr. Mark Warlick Four Winds International Corporation 791 C.R. 15 P.O. Box 1486 Elkhart, IN 46515-1486; Mr. Mark Warlick Four Winds International Corporation 791 C.R. 15 P.O. Box 1486 Elkhart IN 46515-1486; Dear Mr. Warlick: This responds to your letter asking how your compan would certify compliance with Federal Motor Vehicle Safety Standard (FMVSS) No. 302, Flammability of Interior Materials. You stated that your company manufactures motor homes and purchases interior materials from various vendors for these vehicles. These vendors provide you with letters stating that the materials comply with the FMVSS. You enclosed one such letter, which states that 'We have tested the panel ... that was made with COR63-AX-40. We used the MVSS 302 flame test, and obtained a flame rating of 0.64 inches per minute.' You ask whether this letter provides a sufficient basis for your company's certification of compliance with FMVSS No. 302. Some background information would be helpful. As you know, since Standard 302 applies to motor homes and other vehicles, Four Winds, as the vehicle manufacturer, is required to certify compliance with the standard. In the event NHTSA were to find an apparent noncompliance with Standard 302 when testing your vehicle to the requirements of the standard, Four Winds would be asked to show the basis for its certification that the vehicle complies with the standard. If in fact there is a noncompliance, Four Winds would be subject to civil penalties unless it can establish that it exercised 'reasonable care' in the design and manufacture of the product (through actual testing, computer simulation, engineering analysis, or other means) to ensure compliance, and did not have reason to know that the vehicle or item of equipment did not in fact comply with the safety standards (49 U.S.C. 30112(b)(2)(A)). With regard to your specific question, we cannot tell you at this time whether Four Winds' s reliance on a letter from its vendor would constitute 'reasonable care' on the part of your company in making its certification to Standard 302. NHTSA is unable to judge what efforts constitute 'reasonable care' outside of the course of a specific enforcement proceeding. What constitutes 'reasonable care' in a particular case depends on many factors, including such things as the limitations of current technology, the availability of test equipment, the size of the manufacturer, and above all, the diligence exercised by the manufacturer. In the situation you present, your vendor indicated that the burn rate of its material (0.64 inch per minute) is well within the limits of Standard 302 (not more than four inches per minute). The difference between the actual performance of a material and the required performance is a factor NHTSA would consider in making a determination of whether a manufacturer exercised reasonable care in making its certification. Another factor is whether the manufacturer should have determined whether the vendor's assurances were bona fide. Among other things, the expertise, reliability and experience of the vendor would be relevant for that issue. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel; |
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ID: aiam2351OpenMr. Edmund Downey, Suplicy Cacique Trading Co., Inc., 120 Wall St., New York, New York 10005; Mr. Edmund Downey Suplicy Cacique Trading Co. Inc. 120 Wall St. New York New York 10005; Dear Mr. Downey: #This is in response to your telephone conversation o June 3 and June 21, 1976, with Mark Schwimmer of this office concerning the application of the Federal motor vehicle safety standards to components of hydraulic brake systems for passenger cars. #The performance of hydraulic brake systems for passenger cars is the subject of Standard No. 105-75. The only standards that apply directly to components of a hydraulic drake system are Standard No. 106-74, *Brake Hoses*, and standard No. 116, *Motor Vehicle Brake Fluids*. Standard No. 106-74 applies to brake hoses, brake hose end fittings, and brake hose assemblies. These terms are defined in the standard as follows: #>>>'Brake hose means a flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes. #'Brake hose end fitting' means a coupler, other than a clamp, designed for attachment to the end of a brake hose. #'Brake hose assembly' means a brake hose, with or without armor, equipped with end fittings for use in a brake system, but does not include an air or vacuum assembly prepared by the owner or operator of a used vehicle, by his employee, or by a repair facility, for installation in that used vehicle. #'Vacuum tubing connector' means a flexible conduit of vacuum that (i) connects metal tubing to metal tubing in a brake system, (ii) is attached without end fittings, and (iii) when installed, has an unsupported length less than the total length of those portions that cover the metal tubing.<<< #Please note that vacuum tubing connectors are not presently subject to any safety standards. #Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, specifies that #>>>Every manufacturer or distributer of a motor vehicle or motor vehicle equipment shall furnish to the distributer or dealer at the time of delivery of such vehicle or equipment by such manufacturer or distributer the certification that each such vehicle or item of motor vehicle equipment conform to all applicable Federal motor vehicle safety standards. In the case of an item of motor vehicle equipment such certification may be in the form of a container in which such item is delivered... .<<< #With respect to an item of motor vehicle equipment for which there exists no applicable Federal motor vehicle safety standard, the National Highway Traffic Safety Administration interprets this section as not requiring any certification. Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam0696OpenMr. Frank D. Pepe, Manager, United States Testing Company, Inc, Main Laboratories 1415 Park Avenue, Hoboken, NJ 07030; Mr. Frank D. Pepe Manager United States Testing Company Inc Main Laboratories 1415 Park Avenue Hoboken NJ 07030; Dear Mr. Pepe: This is in reply to your letter of April 5, 1972, in which yo suggested that S4.3(d)(3) of Motor Vehicle Safety Standard No. 209 is not appropriate for buckles located between the front seats.; Although you are correct in saying that the requirement was originall developed to guard against the buckle's being opened by the pressure of the steering wheel, there is a chance that compressive forces will also affect buckles located between the seats. Even though the tests may be more difficult to administer, these buckles are not exempt under the present version of the standard, and it is not correct to say that the requirement is not applicable to them.; We do not suggest by this that the requirement could not be changed i response to an adequately supported petition. However, the requirement as it now stands applies to all buckles, wherever located.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1984OpenMr. Samuel W. Alderson, President, Humanoid Systems, Division of Alderson Biotechnology Corporation, 5250 El Segundo Boulevard, Hawthorne, CA 90250; Mr. Samuel W. Alderson President Humanoid Systems Division of Alderson Biotechnology Corporation 5250 El Segundo Boulevard Hawthorne CA 90250; Dear Mr. Alderson: This is in response to your letter of June 27, 1975, criticisin certain aspects of the Part 572 dummy specifications in light of difficulties you have encountered in making test dummies.; You may have misunderstood the June 26 conversation with Dick Dyson o our Chief Counsel's Office that you mentioned. In his conversation with you, as Dick said at the time, he was simply paraphrasing the letter from Bob Carter that on that day was on its way to you in response to your letter of May 30. His (and the letter's) point was that dummies are not items of motor vehicle equipment, that there is therefore no Federal requirement for their certification, that any deviation from the Part 572 specifications is purely a matter of private negotiation between dummy manufacturers and their customers, and that no government approvals are possible or appropriate. This remains our position with respect to the legal status of the Part 572 dummy specification.; We will be glad to answer any questions of interpretation of Part 57 or other National Highway Traffic Safety Administration regulations. We will also give full consideration and a timely response to any petitions for changes in these regulations, in accordance with the statutory requirements of the 1974 Amendments to the Act. I invite you to submit any such questions or petitions on matters of interest to you.; Sincerely, James B. Gregory, Administrator |
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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.