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: aiam1361OpenMr. George R. Semark, Planning and Development Center, Sheller-Globe Corporation, Transportation Group, 1200 East Kibby Street, Lima, Ohio 45802; Mr. George R. Semark Planning and Development Center Sheller-Globe Corporation Transportation Group 1200 East Kibby Street Lima Ohio 45802; Dear Mr. Semark: This is in response to your letter of November 21, 1973. Federal Moto Vehicle Safety Standard No. 125 applies only to the manufacturers of warning devices, not manufacturers of vehicles who supply warning devices with their vehicles. Therefore, there are no requirements that you furnish an approved device with your vehicles. What the standard prohibits is the manufacture or sale (separately or on a vehicle) of a *warning device produced on or after January 1, 1974*, that does not conform to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam4499OpenMs. Deborah M. Bakker Assistant Manager, Regulatory Affairs MMC Services, Inc. 3000 Town Center Suite 1960 Southfield, MI 48075; Ms. Deborah M. Bakker Assistant Manager Regulatory Affairs MMC Services Inc. 3000 Town Center Suite 1960 Southfield MI 48075; "Dear Ms. Bakker: This letter is in response to your request for a interpretation of 49 CFR Part 541, Federal Motor Vehicle Theft Prevention Standard. Specifically, you asked about a situation in which a car line (the Mitsubishi Galant) was designated as a high theft line beginning in the 1987 model year, pursuant to the procedures set forth in Part 542. Mitsubishi applied for and received an exemption from the marking requirements of the theft prevention standard because of a standard equipment antitheft device to be installed in the Galant. This exemption, issued pursuant to Part 543, applied beginning in the 1987 model year. For the 1988 model year, the body style of the Galant was redesigned and a new nameplate was assigned to the line. It is now called the Galant Sigma. Additionally, Mitsubishi plans to introduce a new car line in the 1989 model year called the Galant. This line is, according to your letter, completely redesigned from the 1987 line that was called the Galant, bears no resemblance to the Galant Sigma, and will cost less than either the Galant Sigma or the 1987 line called Galant. You posed the following questions: 1. Should a new theft determination be made for both the Galant Sigma and the redesigned Galant? ANSWER: No. Based on the information enclosed with your letter, we conclude that the redesigned Galant is a continuation of the 1987 Galant line and the Galant Sigma is a new model within the Galant line. As a general matter, section 601(2) of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2021(2)) defines the term 'line' as 'a name which a manufacturer applies to a group of motor vehicle models of the same make which have the same body or chassis, or otherwise are similar in construction or design.' As noted in your letter, the agency uses the same language to define the term 'line' in 541.4. This language treats groups of motor vehicles as a continuation of an existing line if the groups have the same name and are similar in construction or design. We have applied this language in the following manner. With respect to the redesigned Galant, I addressed such a question in my March 6, 1987 letter to Mr. Jeffrey Link (copy enclosed) as follows: The agency has in several instances determined that groups of vehicles using the same name as previous groups of vehicles were continuations of the previous line, even though the new vehicles used all new sheet metal and drivetrains as compared with the previous group of vehicles. This determination was based on the fact that the vehicles were still similar in construction or design to the older vehicles they replaced. On the other hand, NHTSA has also determined that groups of vehicles using the same name as previous groups of vehicles were nevertheless new lines, because of significant changes in the construction or design of the vehicle. For instance, when a vehicle is redesigned to be front wheel drive, it is not treated as the same line as the predecessor rear wheel drive line, even if the newly designed vehicle has the same name as the older vehicles. The redesigned Galant obviously has the same name as the 1987 model year Galant. Additionally, the redesigned Galant is similar in construction and design to the 1987 Galant, notwithstanding the new sheet metal and different drivetrains. Accordingly, we believe that the redesigned Galant is a continuation of the 1987 Galant line. This means that the redesigned Galant is subject to the previous high theft determination for the Galant line. With respect to the Galant Sigma, we conclude that this is a new model within the Galant line, not a new line. In our preamble to the insurer reporting requirements in 49 CFR Part 544, we discussed the application of the terms 'model, make, and line' as follows: 'Make' refers to the general name used by the vehicle manufacturer. For example, Dodge, Ford, and Pontiac are makes of vehicles. 'Line' refers to the nameplate assigned by the manufacturer to a group of vehicle models of the same make. For example, Dodge Charger, Ford Thunderbird, and Pontiac 6000 are lines of vehicles. 'Model' refers to a specific grouping of similar vehicles within a line. For example, the Dodge Charger 2.2 2-door, Ford Thunderbird Turbo Coupe, and Pontiac 6000 LE 4-door are models. 52 FR 59, at 65, January 2, 1987. In general, if a manufacturer calls a group of vehicles by the same general name as it applies to another group, but adds a further description to that name (e.g., Honda Civic CRX, Volkswagen Golf GTI, and Porsche 911 Carrera), we presume that the further description indicates a unique model within that line. This presumption can be overcome only if the vehicle with the further description in its name is not 'similar in construction or design.' Thus, we have determined, for example, that the Honda Civic CRX is simply a model within the Civic line, notwithstanding the fact that its driveline and body styling are different from all other Honda Civic models. It is similar in construction or design (all are front-wheel drive passenger cars) and bears the same name as other Civics. On the other hand, the Colt/Mirage Station Wagon is not considered a model within your Colt/Mirage line. The Station Wagon bears the same name as other Colt/Mirage models. However, the Colt/Mirage Station Wagon is classified as a multipurpose passenger vehicle, while the other Colt/Mirage models are passenger cars. This difference is substantial enough that the vehicles are not 'similar' in construction or design. In the case of the Galant Sigma, we agree that it is not identical in construction or design to the other redesigned Galant models. However, it is similar in construction and design to the other Galant models, since all are front-wheel drive passenger cars. Hence, the Galant Sigma is simply a model within the Galant line. 2. If a new high theft determination should not be made for the redesigned Galant and the Galant Sigma, which of the vehicles is designated as high theft and for which car line could the exemption granted for the old Galant be used? ANSWER: As explained above, the Galant Sigma is not a separate car line, but is simply a model within the Galant line. The redesigned Galant line is a continuation of the older Galant line. Thus, the previous high theft determination applies to all models in the redesigned Galant line, including the Galant Sigma. The exemption that was granted to the older Galant line can be used for the redesigned Galant line if the antitheft device that was the subject of the previous petition is installed as standard equipment in all cars in the redesigned Galant line, including the Galant Sigma. If the antitheft device that was the subject of the previous petition is not installed as standard equipment in all cars in the redesigned Galant line, you would be required to mark all cars in the redesigned Galant line to conform to Part 541. 3. If one or both the redesigned Galant and the Galant Sigma are newly designated as high theft lines, can the exemption granted for the Galant in the 1987 model year be used for either or both car lines, or would the exemption be invalidated because of the change in body style? ANSWER: Because the redesigned Galant is a continuation of the 1987 Galant line and the Galant Sigma is just a model within the redesigned Galant line, as explained above, the exemption granted under Part 543 to the 1987 Galant line continues in full effect for the redesigned Galant line. Your company has the option of installing anti-theft devices as standard equipment in all vehicles in the redesigned Galant line, including the Galant Sigma, in accordance with the 1987 exemption, or marking all major parts in all vehicles in the redesigned Galant line, in accordance with Part 541. 4. If an exemption is granted but a manufacturer continues to mark parts in accordance with Part 541, can installation of the anti-theft device be discontinued at any time? ANSWER: Yes. Exemptions are granted only, among other things, after a determination has been made that the line in question is a high theft line that should be listed in Appendix A of Part 541. Section 541.3 states that the parts marking requirements of Part 541 apply to all lines listed in Appendix A. Section 541.5 requires each major part that is original equipment on a line designated as high theft to be marked with certain information. Section 541.6 requires each replacement major part for high theft lines to be marked with certain information. Thus, each line listed in Appendix A must comply with the requirements of sections 541.5 and 541.6. There is a single exception to this requirement. Part 543 sets forth procedures by which a line that has been determined to be a high theft line can be exempted from the marking requirements of Part 541. To be eligible for an exemption under Part 543, an antitheft device must be installed as standard equipment in all cars in the line. The lines that have been granted exemptions under Part 543 are listed in a special subset of Appendix A, Appendix A-I. When a manufacturer gets an exemption for a line under Part 543, it is given two options to comply with the requirements of Part 541. First, the manufacturer can install the antitheft device that was the subject of the exemption proceeding under Part 543 as standard equipment on all cars in that line, in accordance with the terms of the exemption. However, the manufacturer is not required by Part 543 or any other provision to install standard equipment antitheft devices in that line. If the manufacturer chooses not to use the antitheft device exemption for that line, the manufacturer must choose the second option -- that is, marking the major parts of every car in the line, in accordance with 541.5, and marking the replacement major parts for that line, in accordance with 541.6. If a manufacturer has complied with both of these options in a particular model year, by marking every vehicle and every covered major replacement part for a line and by installing an antitheft device that was the subject of a Part 543 exemption proceeding in every marked vehicle, as posited in your example, the manufacturer is free to discontinue either, but not both, of the courses of action at any point during the model year. When the manufacturer chooses to discontinue either course of action for even a single vehicle in the high theft line, it is then required to follow the other course of action until the end of the model year in question. Please note that this choice exists only if the manufacturer has complied fully with the requirements of Part 541.5 and Part 541.6 and with the terms of the exemption granted under Part 543. If some vehicles in a line or some of the replacement major parts were not marked in accordance with Part 541, the manufacturer must install the antitheft device that was the subject of the Part 543 proceeding in all vehicles in that line for the rest of the model year. When the next model year for the subject line begins, the manufacturer is permitted to discontinue the installation of the antitheft device and to comply with the requirements of Part 541 for that line in the new model year. However, for any particular model year, each of a manufacturer's lines must fully comply with either the requirements of Part 541 or the exemption granted under Part 543. Please feel free to contact Steve Kratzke of my staff if you have any further questions or need more information on this subject. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
|
ID: aiam5322OpenMr. Mark Archer Orbital Engine Company Pty. Ltd. 1 Whipple Street, Balcatta 6021 Western Australia Australia; Mr. Mark Archer Orbital Engine Company Pty. Ltd. 1 Whipple Street Balcatta 6021 Western Australia Australia; "Dear Mr. Archer: This responds to your letter in which you asked i the National Highway Traffic Safety Administration (NHTSA) has any regulations affecting a vehicle that has an automatic engine shut-off device that operates when the vehicle remains idle for extended periods. I regret the delay in responding. By way of background information, NHTSA administers Federal requirements for the manufacture and sale of new motor vehicles and certain items of motor vehicle equipment. The National Traffic and Motor Vehicle Safety Act ('Safety Act,' copy enclosed) establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable Federal motor vehicle safety standards (FMVSS's). This process requires each manufacturer to determine in the exercise of due care that its products meet all applicable requirements. NHTSA tests vehicles and equipment sold to consumers for compliance with the FMVSS's and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of a noncomplying product is also subject to a civil penalty of up to $1,000 for each noncomplying item it produces. I have enclosed an information sheet that highlights these responsibilities. We cannot tell from your letter whether you seek to produce a vehicle that has a shut-off device installed as original equipment ('O.E.'), i.e., prior to a first sale to a consumer, or produce the device as an 'aftermarket' item of equipment, sold for installation in used vehicles. We will discuss both situations in this letter. A shut-off device may not be installed on a new vehicle if the device causes the vehicle not to comply with all applicable FMVSS's. Standard No. 102, 'Transmission shift lever sequence, starter interlock, and transmission braking effect,' states that 'the engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive position.' (S3.1.3). NHTSA does not know of any shut-off device that would enable a vehicle to meet S3.1.3 of Standard 102. In 1984, NHTSA terminated rulemaking on an action that would have amended S3.1.3 to permit a shut-off device that restarted the vehicle's engine when the accelerator is depressed. A copy of the termination notice is enclosed. The agency terminated rulemaking citing a number of safety concerns with the particular features of the shut-off device that was the subject of the rulemaking. NHTSA stated in the notice that, if in the future a more effective and safe fuel saving device is developed, NHTSA would again consider amending Standard 102. However, given that S3.1.3 of Standard 102 was not amended, that section precludes the O.E. installation on a shut-off device such as the one described in the termination notice. With respect to the aftermarket installation of a shut-off device, there is currently no FMVSS that directly applies to the product. Standard 102 applies only to new motor vehicles and not to aftermarket components of a vehicle's transmission, such as a shut-off device. However, there are other Federal requirements that indirectly affect the manufacture and sale of a shut-off device. Under the Safety Act, the product is considered to be an item of motor vehicle equipment. As explained above, each manufacturer of motor vehicle equipment is subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. In the event that the manufacturer or NHTSA determines that the product contains a safety-related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 108(a)(2)(A) of the Safety Act, which states: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ....' This means that if a shut-off device were sold in the 'aftermarket,' no manufacturer, distributor, dealer, or motor vehicle repair business could install it if doing so would render inoperative any previously certified item of equipment in the vehicle. As explained above, each motor vehicle is certified as meeting Standard 102. A shut-off device that causes the vehicle to no longer comply with Standard 102 could not be installed by any person listed in section 108(a)(2)(A) without subjecting that person to civil penalties (section 109 of the Safety Act specifies a civil penalty of up to $1,000 for each violation of 108). The 'render inoperative' prohibition of 108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles. However, NHTSA urges all owners not to perform modifications that would degrade the safety of their vehicles, such as installing a fuel shut-off device that raises significant safety concerns. I hope this responds to your concerns. If you have any further questions, please contact David Elias of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
|
ID: aiam0120OpenMr. Berkley C. Sweet, Executive Vice President, Truck Body and Equipment Association, Inc., 1012 Fourteenth Street, N.W., Washington, DC 20005; Mr. Berkley C. Sweet Executive Vice President Truck Body and Equipment Association Inc. 1012 Fourteenth Street N.W. Washington DC 20005; Dear Mr. Sweet: Thank you for your letter of September 12, 1968, to Mr. J. E. Leysat of this Bureau, requesting a clarification of the aiming requirements for school bus signal lamps as specified in Federal Motor Vehicle Safety Standard No. 108.; Paragraph S3.1.3.1 of Standard No. 108 specifies that red school bu signal lamps shall conform to SAE Standard J887, 'School Bus Red Signal Lamps,' July 1964, and that amber signal lamps shall conform to the same SAE Standard except for color and candlepower requirements. In the last paragraph of SAE Standard J887, aiming requirements are specified as follows: 'Lamps should be mounted on the school bus with their aiming plane vertical and normal to the vehicle axis. A suggested tolerance for this aim is 5 inches at 25 feet in vertical aim and 10 inches at 25 feet in horizontal aim. If lamps are aimed or inspected with a mechanical headlamp aimer (see SAE J602) the graduation settings for aim should be 2 down and 0 sideways. The limits for inspection should be from 3 up to 7 down and from 10 right to 10 left.'; In accordance with the above quoted paragraph, either visual o mechanical aiming of the signal lamps is permitted. Therefore, the graduation settings and inspection limits, as specified in the last two sentences of the paragraph, are applicable only when a mechanical headlamp aimer is used to aim the signal lamps.; Thank you for writing. Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
|
ID: aiam4860OpenMr. Mark A. Pacheco Vice President Innovative Industries of Tampa, Inc. 5126 Le Tourneau Circle Tampa, FL 33610; Mr. Mark A. Pacheco Vice President Innovative Industries of Tampa Inc. 5126 Le Tourneau Circle Tampa FL 33610; "Dear Mr. Pacheco: This responds to your letter in which you aske about the application of Federal regulations to your client's product. This product, called a 'Walk Machine,' looks like a two-wheeled scooter, with a small 37cc engine attached to it. You stated that this product is designed for off-road use. NHTSA has the authority under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A), Safety Act) to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 102(3) of the Safety Act defines 'motor vehicle' as: A ny 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. NHTSA has interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., airport runway vehicles and underground mining devices) are not considered motor vehicles, even though they may be operationally capable of highway travel. On the other hand, vehicles that use the public highways on a necessary and recurring basis are motor vehicles. For instance, utility vehicles like the Jeep are plainly motor vehicles, even though they are equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, NHTSA has found the vehicle to be a 'motor vehicle.' Further, if a vehicle is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, NHTSA has found the vehicle to be a motor vehicle. This finding was made with respect to dune buggies and regardless of the manufacturer's stated intent regarding the terrain on which the vehicles were to be operated. Your letter did not indicate whether the 'Walk Machine' would be designed and sold solely for off-road use, or whether it would be used on-road for a substantial amount of time. However, based on your letter, this vehicle would not be a 'motor vehicle' even if it is regularly used on the public roads. This is because NHTSA has stated in many previous interpretations that vehicles that regularly use the public roads will not be considered 'motor vehicles' if such vehicles have a maximum attainable speed of 20 miles per hour (mph) and have an abnormal configuration which readily distinguishes them from other vehicles. The information provided for the 'Walk Machine' indicates that it has a top speed of 16 mph and a configuration that would readily distinguish it from motorcycles and other two-wheeled vehicles. Because this vehicle is not a 'motor vehicle,' none of this agency's standards apply to it. You may wish to contact the Consumer Product Safety Commission to learn if they have any Federal safety regulations that would apply to this vehicle. Their address is: Office of the General Counsel, U.S. Consumer Product Safety Commission, 5401 Westbard Avenue, Bethesda, Maryland 20207. You may also wish to consider the possible application of State laws to your client's product. For additional information on State laws, you may contact the American Association of Motor Vehicle Administrators at: 4200 Wilson Blvd., Suite 600, Arlington, Virginia 22203. Sincerely, Paul Jackson Rice Chief Counsel"; |
|
ID: aiam0570OpenMr. Vincent G. Grey, Engineering Manager, Truck Trailer Manufacturers Association, 1413 K Street, N.W., Washington, DC 20005; Mr. Vincent G. Grey Engineering Manager Truck Trailer Manufacturers Association 1413 K Street N.W. Washington DC 20005; Dear Mr. Grey: This is in reply to your letter of December 20, 1971, asking whethe the Certification regulations (Docket Nos. 70-6, 70-8, 70-15) apply to pole trailers. The Docket numbers you refer to also include the regulations concerning 'Vehicles Manufactured in Two or More Stages.'; As there are no motor vehicle safety standards presently applicable t pole trailers, neither the Certification regulations (49 CFR Part 567) nor the regulations governing 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568) apply to them. As you were informally informed, however, pole trailers manufactured on or after January 1, 1973, that are equipped with air brake systems would be required to comply with Motor Vehicle Safety Standard No. 121, and their manufacturers would be required to comply with the Certification regulations and, where applicable, the regulations governing Vehicles Manufactured in Two or More Stages.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam5288OpenMr. Lloyd Boshaw M&L Auto Trim P.O. Box 822 Poway, CA 92074; Mr. Lloyd Boshaw M&L Auto Trim P.O. Box 822 Poway CA 92074; Dear Mr. Boshaw: We have received your letter of January 28, 1993 asking whether you must disconnect an original equipment center highmounted stop lamp when you add an aftermarket spoiler to the deck lid that incorporates such a lamp. I enclose a copy of an interpretive letter we sent David Holscher on August 31, 1990, which remains our position today. In brief, a spoiler lamp will supersede the original equipment center lamp. When the spoiler is installed, Federal law does not dictate whether the original lamp must be disconnected or remain usable. That question is answerable under State law, and we suggest that you consult the Department of California Highway Patrol for its views. If California has no regulation bearing on this problem, we assume that you may either disconnect the original lamp or leave it connected, as your customers desire. Sincerely, John Womack Acting Chief Counsel Enclosure; |
|
ID: aiam2222OpenMr. Phil Schneider, PTV Project Supervisor, Steam Power Systems, 7617 Convoy Court, San Diego, CA 92111; Mr. Phil Schneider PTV Project Supervisor Steam Power Systems 7617 Convoy Court San Diego CA 92111; Dear Mr. Schneider: This is in response to your letter of January 22, 1976, requestin confirmation that your company's Paratransit Vehicle would be classified as a 'multipurpose passenger vehicle' for purposes of the Federal motor vehicle safety standards and regulations.; Your letter states that the Paratransit Vehicle is designed primaril to carry wheel-chair- confined passengers in a Dial-a-Ride or jitney type of service, and that the vehicle is of the forward control configuration, constructed with a custom chassis-body structure.; Based upon the facts presented in your letter, the description an specifications contained in the attached SAE design paper, and the National Highway Traffic Safety Administration's previous interpretation of the classification, we would conclude that the Paratransit Vehicle does qualify as a 'multipurpose passenger vehicle.'; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3960OpenMr. H. Moriyoshi, Executive Vice President and General Manager, Mazda (North America), Inc., 24402 Sinacola Court, Farmington Hills, MI 48018; Mr. H. Moriyoshi Executive Vice President and General Manager Mazda (North America) Inc. 24402 Sinacola Court Farmington Hills MI 48018; Dear Mr. Moriyoshi: This is in reply to your letter of June 3, 1985, asking for a interpretation of Motor Vehicle Safety Standard No. 108 regarding requirements for the center high- mounted stop lamp.; You reference an agency letter of July 30, 1980, to Volkswagen o America in which the Chief Counsel concluded that placement of the stop lamps and taillamps on the deck lid could be viewed as a defect in performance requiring notification and remedy. You have asked, in essence, how this relates to Standard No. 108's present allowance of a center high- mounted stop lamp mounted on a vehicle's decklid, hatch, or tailgate.; The assumption underlying the agency's 1980 letter was that a defec could exist if all a vehicle's stop lamps and taillamps were mounted on the decklid, where their signals could be unobserved or obscured if the lid were in any position other than closed. The center high-mount stop lamp, on the other hand, while an item of required equipment, is nevertheless a supplementary stop lamp. Even if the deck, hatch, or tailgate upon which it is mounted should be open, following drivers may still observe the signals of the primary stop lamps remaining on the body.; You have asked that we also discuss the implications of a stop lamp an taillamp constructed so that a portion is fixed to the body of the vehicle adjacent to the decklid opening and the remaining portion is mounted on the outboard area of the decklid.; Compliance of a vehicle is determined with respect to its norma driving position, that is to say, with the tailgate, hatch, or decklid closed. However, in order to obviate any possibility of the existence of a safety-related defect, we recommend that the portion of the lamp that is mounted on the body itself comply with the minimum requirements of Standard No. 108 for a single compartment stop lamp or taillamp.; I hope that this answers your questions. Sincerely, Jeffrey R. Miller, Chief Counsel |
|
ID: aiam2672OpenMr. J. Shillinger, Project Engineer, AM General Corporation, 32500 Van Born Road, Wayne, MI 48184; Mr. J. Shillinger Project Engineer AM General Corporation 32500 Van Born Road Wayne MI 48184; Dear Mr. Shillinger: This responds to AM General Corporation's July 18, 1977, request fo confirmation that certain aspects of the M.A.N. articulated transit bus conform to the requirements of Standard No. 121, *Air Brake Systems*, and Standard No. 124, *Accelerator Control Systems*. In an October 3, 1977, telephone call with Mr. Herlihy of this office, it was determined that the request for interpretation is now limited to confirmation that the four-way pressure protection valve described in M.A.N.'s June 22, 1977, letter would meet the location and functional requirements of S5.1.2.3 of Standard No. 121. Section S5.1.2.3 specifies--; >>>S5.1.2.3 Each service reservoir shall be protected against loss o air pressure due to failure or leakage in the system between the service reservoir and its source of air pressure by check valves or equivalent devices.<<<; I am enclosing prior interpretations of the location requirement o S5.1.2.3. While the agency cannot 'approve' systems based on schematic drawings, it appears that the location of the four-way protection valve in the M.A.N. drawings does not violate the provisions contained in S5.1.2.3.; As we understand the description and capabilities of the four-wa valve, it appears to be a pressure protection device that is 'equivalent' to the check valve otherwise required by S5.1.2.3.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
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.