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: aiam5334OpenMr. J. Hulshof Nedap N.V. P.O. Box 6 7140 AA Groenlo The Netherlands; Mr. J. Hulshof Nedap N.V. P.O. Box 6 7140 AA Groenlo The Netherlands; "Dear Mr. Hulshof: This responds to your letter to Mr. Patrick Boy requesting a written interpretation concerning whether your sunroof would meet the requirements of Federal Motor Vehicle Safety Standard No. 118, 'Power-Operated Window, Partition, and Roof Panel Systems.' I apologize for the delay in responding. By way of background, the National Traffic and Motor Vehicle Safety Act establishes a self-certification system under which manufacturers are responsible for ensuring that their products comply with all applicable FMVSSs. We do not approve, endorse, or gives assurances of compliance of any product. In response to manufacturers' requests for interpretations of the FMVSS's, we try, to the extent possible, to provide information that will help them make their determinations of compliance. However, these responses are based on information provided by the manufacturer, and are subject to the findings of actual compliance testing by the agency. Should the agency, in the future, examine your product and detect an apparent noncompliance or defect, those results will control. You explain in your letter that your power-operated sunroof (which is a power operated 'roof panel system' under Standard 118) can be closed only in four circumstances. In three of these, the ignition key must be activated. In the fourth, the sunroof can be closed when there is 'Continuous operation of Central close mechanism, not capable sic closing the roof panel from a distance of more than 6 meters from the vehicle.' Standard 118 requires sunroofs other than those that have an automatic reversing feature to close only in certain circumstances. One of those (S4(a)) is when the key controlling the vehicle's engine is in the activated (i.e. 'on', 'start' or 'accessory') position. The three circumstances you described where the ignition key must be activated to operate the sunroof appear to satisfy S4(a). With regard to the fourth circumstance, Standard 118 also permits sunroofs to close 'Upon continuous activation of a remote actuation device, provided that the...device shall be incapable of closing the sunroof from a distance of more than 6 meters from the vehicle' (S4(d)). The circumstance you described appears to satisfy S4(d). Your sunroof will close only upon continuous operation of a 'Central close mechanism,' and the mechanism is incapable of closing the sunroof from a distance of more than 6 meters from the vehicle. I hope this information has been helpful. If you have any further questions, please contact Mr. David Elias of my office at the above address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1377OpenMr. Richard Wright West, West & Wilkinson, P.O. Box 257, 2815 Huntington Avenue, Newport News, VA 23607; Mr. Richard Wright West West & Wilkinson P.O. Box 257 2815 Huntington Avenue Newport News VA 23607; Dear Mr. West: This is in response to your letter of January 2, 1974 requestin information concerning the legal permissibility of an automobile dealership furnishing private passenger motor vehicles with add-on gasoline tanks of modifying existing gasoline tanks.; Motor Vehicle Safety Standard No. 301, *Fuel System Integrity* establishes minimum performance requirements for motor vehicle fuel systems. Compliance with the level of performance mandated by the standard is enforced by Section 108 (a)(1) of the National Traffic Safety Act which prohibits the manufacture, sale, delivery, or importation of vehicles or motor vehicle equipment that do not meet the requirements of applicable safety standards. Therefore, if your client modified a motor vehicle fuel tank in such a manner that it no longer complied with Standard No. 301 and then offered it for initial sale for purposes other than resale he would be in violation of the Motor Vehicle Safety Act and would be subject to civil penalties of not more than $1,000 for each such violation. If, however, your client performed a fuel tank modification on a vehicle that was already owned by and in the possession of a buyer who purchased the vehicle for purposes other than resale, no violation of the Act could result. The installation of an add-on fuel tank would be considered a modification. Therefore, the fuel system would have to comply with Standard No. 301 with the add-on fuel tank considered as part of the system.; There are no Motor Vehicle Safety Standards applicable to add-o gasoline tanks since these are items of motor vehicle equipment and Standard No. 301 restricts its application to motor vehicles. Section 113(e)(2) of the Motor Vehicle Safety Act, however, authorizes the Secretary of Transportation to determine whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If the Secretary finds that a safety-related defect exists, your client may be compelled to notify all purchasers of vehicles with the add-on fuel tanks of the attendant hazard.; The action of installing add-on gasoline tanks in motor vehicle exposes your client to the requirements of yet another safety regulation (49 CFR 567.7). If the vehicle in which he installs the fuel tank is a certified and complete vehicle that has not yet been purchased in good faith for purposes other than resale, your client will be considered an alterer of the vehicle, and he must provide a certification that the vehicle as altered still conforms to the standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4175OpenMr. J. L. Hendricks, Manager, Product Environmental Management, Cummins Engine Company, Inc., Box 3005, Columbus, IN 47202-3005; Mr. J. L. Hendricks Manager Product Environmental Management Cummins Engine Company Inc. Box 3005 Columbus IN 47202-3005; Dear Mr. Hendricks: This responds to your letter regarding the difficulty, during a ongoing safety defect campaign (NHTSA 85E-016), of locating current owners of heavy-duty diesel engines and replacement engine products which are installed in trucks selected by the original equipment manufacturer. I regret the delay in responding to your letter.; The information contained in your letter and in telephone conversation with agency staff indicates your concern with the delay in your efforts to locate the current owners in Connecticut of Cummins engines and replacement equipment involved in this voluntary recall. This problem arose when a large number of original recall notices mailed to the most recent known purchasers of this equipment were returned to you. You then contacted each State and requested a search of their motor vehicle files using the truck vehicle identification numbers (VIN's) in order to locate the current owners. We understand that special procedures followed by Connecticut to protect individual privacy have led to delays in your obtaining the names and addresses of current owners.; In your letter, you mention Connecticut's practice of requiring formal declaration of VIN's and a justification for conducting a search of their vehicle registration files. While we agree with the statement in your letter that each State has the right to safeguard individual privacy and place restrictions on access to lists of motor vehicle owners, we also regret the delay, which is apparently caused by Connecticut's procedure in notifying the current owners of the equipment involved in this campaign.; You indicate that this delay is increased by Connecticut's practice o requiring the services of a third party agency who, by contractual agreement, obtains the registration information and sells it to the party conducting the safety recall campaign.; These difficulties do not, of course, diminish the responsibility o manufacturers to conduct notification campaigns. We appreciate the difficulty of locating current owners of trucks with original and replacement Cummins equipment, and commend your efforts to locate them. However, this agency cannot interfere in the efforts of a State to protect the privacy of Connecticut motor vehicle owners. Further, this agency cannot interfere in a contractual agreement between a State and a third party.; You indicate that the task of locating current owners is additionall complicated by at least two factors. First, we understand that Cummins receives a list of VIN's from the original vehicle manufacturer with the names and addresses of the first purchasers of trucks on which your equipment is installed. These purchasers may or may not be the actual users of the trucks. Second, the owners/operators of the trucks on which these engines and replacement equipment are installed tend to be very mobile in their operations and registration practices. The result has been a large number of safety-related defect notices returned to your company, because the current owners cannot be located.; In your letter, you also request that this agency write to th Connecticut Bureau of Motor Vehicles and solicit their assistance in negotiating with Cummins a program to enable your company to maintain an on-going system to obtain vehicle registration on a timely basis. We think that such a program could be appropriate during a specific safety recall campaign. While not wishing to interfere with a State's decision to set reasonable procedures to safeguard lists of vehicle owner names and addresses, the agency believes that a request to Connecticut to assist you could be helpful in locating the current owners of Cummins equipment involved in this recall campaign. For these reasons, NHTSA, by separate letter, is requesting the Connecticut Department of Motor Vehicles to provide assistance to Cummins, as expeditiously as possible, in supplying the names and addresses of the equipment owners requested by your company.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1727OpenMr. J. R. Ayers, ICI United States Inc., Marshall Plant, Box 790, Marshall, TX 75670; Mr. J. R. Ayers ICI United States Inc. Marshall Plant Box 790 Marshall TX 75670; Dear Mr. Ayers: This responds to your August 27, 1975, question whether Standard No 121, *Air Brake Systems*, applies to trucks that operate within one state in a short-haul operation from a mine site to a processing plant.; Standard No. 121 applies to air-braked trucks, buses, and trailers with only a few exceptions that do not appear to include the truck you describe. The National Highway Traffic Safety Administration considers vehicles that operate on the highway, even for short distances, to be motor vehicles operating in the stream of interstate commerce that are subject to our requirements. Therefore, the vehicle you describe would be a motor vehicle under our definition, and it is classified as a truck that must comply with Standard No. 121.; I would like to point out that the standard applies to th newly-manufactured vehicle, and that after its sale to your company, you are entitled to modify the system as necessary to ensure the safety of the vehicle in your specialized operations. I have enclosed a copy of a letter on this subject pointing out, however, that a manufacturer, distributor, dealer, or repair business is prohibited from disconnecting the antilock device for you.; I would emphasize that this discussion does not address separat responsibilities you may have under State, Occupational Safety and Health Administration, or Bureau of Motor Carrier Safety regulations for the operation of your vehicles.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0835OpenMr. Jack Bronte, President, Paradise Manufacturing Company, 2840 East 26th Street, Los Angeles, CA, 90023; Mr. Jack Bronte President Paradise Manufacturing Company 2840 East 26th Street Los Angeles CA 90023; Dear Mr. Bronte: This is in reply to your letter of August 31, 1972, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether the Standard applies to the shower and matching window curtains you manufacture and sell to manufacturers of mobile homes, trailers, and campers, and whether mobile homes must comply with the requirements of the Standard.; Because Standard No. 302 applies to motor vehicles, the components o vehicle occupant compartments listed in S.4.1 of the Standard are subject to the Standard only when they are installed in a vehicle included under a vehicle class to which the Standard is applicable. Standard No. 302 applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. It does not apply to trailers, the vehicle category which includes mobile homes and other towed recreational vehicles, but it does apply to those campers that are constructed on new chassis. Since the only vehicles you list that must meet the requirements of the Standard and that use your curtains are campers constructed on new chassis, the Standard applies only to the curtains used in such campers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2808OpenMr. Bruce Baldwin Mohs, President, Mohs Seaplane Corporation, 2355 University Avenue, Madison, WI 53705; Mr. Bruce Baldwin Mohs President Mohs Seaplane Corporation 2355 University Avenue Madison WI 53705; Dear Mr. Mohs: This is in reply to your letter of May 5, 1978, asking 'what i necessary for the rewriting of [Motor Vehicle Safety Standard No.] 108 to include my . . . system for vehicle identification.' As you have described this reflective device, it is a polyvinyl extrusion in which is placed polyester tape which 'becomes a continuous reflector down the side of a vehicle - amber toward the front, red on the rear half of the vehicle and red across the back.' You state that in your experimental installation you are 'retaining the 3' spot reflectors as required in Standard 108.'; If your material conforms to Federal Specification L-S-300 and, as use on the vehicle, meets the performance standards in Table 1 of SAE Standard J495d, 'Reflex Reflectors,' March 1967, it could be used as the front and rear reflex reflectors required by Standard No. 108. However, if it does not meet this specification, Standard No. 108 would not prohibit the sale and installation of your system as original equipment, or as an aftermarket accessory, provided it is supplementary to the side and rear reflectors required by Standard No. 108. Thus, no Federal 'approval' of your system is required. A change in Standard No. 108 is required only if you believe your system should be mandatory on all motor vehicles. In the event you wish to petition for such an amendment of Standard No. 108, I enclose a copy of our rulemaking procedures.; Yours truly, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4525OpenMr. Koji Tokunaga Manager, Engineering Isuzu Motors America, Inc. 21415 Civic Center Drive Southfield, MI 48076-3969; Mr. Koji Tokunaga Manager Engineering Isuzu Motors America Inc. 21415 Civic Center Drive Southfield MI 48076-3969; "Dear Mr. Tokunaga: This letter responds to your inquiry in which yo ask a number of questions concerning Federal motor vehicle safety standard (FMVSS) 124, Accelerator Control Systems. I apologize for the delay in this response. In your letter, you describe a new accelerator control system that operates through electrical rather than mechanical signals. You state that the moving components of this system are the accelerator pedal, stepping motor arm, linkage, and the throttle lever. When a driver depresses the accelerator pedal, a pedal sensor converts the displacement into a proportional electric signal. The signal goes through a control unit to a position switch, and then to a stepping motor. This stepping motor works to move the motor's arm and linkage, and they in turn work the throttle lever. Therefore, you say, the engine speed is controlled in proportion to the amount of accelerator pedal displacement. You further inform us that Isuzu already has distributed vehicles equipped with this system in Japan, and that the company would like to market this kind of vehicle in the United States. You present three questions and a diagram of the system components, and request an agency response. First, please be aware that in issuing this interpretation, NHTSA is neither approving, certifying, nor endorsing your new accelerator control system. Under the National Traffic and Motor Vehicle Safety Act, each manufacturer must certify that its product meets agency safety standards, or other applicable standards. However, based on the information you supplied in your letter, I have the following responses. Question I: In this vehicle, Isuzu considers the battery that drives the stepping motor to be one of the energy sources under S5.1, and the return springs (accelerator pedal and throttle lever return springs) the other sources. Is this interpretation correct? We do not have enough information to state whether the battery that drives the stepping motor, or the return springs would be considered energy sources under S5.1. Section S5.1 of Standard 124 requires, among other things, that there be a minimum of two energy sources capable of returning the throttle to idle whenever the driver removes the opposing actuating force, or if there is a single severance or disconnection in the accelerator control system. With respect to the battery, if all system elements are operating properly, then it would appear that removing the actuating force will cause the electrical circuit from accelerator pedal sensor to stepping motor to return the throttle to idle. On the other hand, if there is a failure caused by a severance or disconnection in the accelerator control system between the pedal and the stepping motor, it is not clear to me whether the stepping motor will return to zero, and bring the throttle springs back to idle, or lock the arm and linkage in an 'open-throttle' position. Similarly, it is not clear to me that the accelerator pedal and throttle return springs are capable of returning the throttle to idle in the event of a failure caused by an ACS severance or disconnection. (While you include the throttle lever in your description of the accelerator control system, the agency considers it as part of the fuel metering device. However, as NHTSA explained in the preamble to 124, an energy source under the Standard may be attached to the fuel metering device. 37 FR 20033, September 23, 1972. ) Ordinarily, the agency would have no difficulty in finding that either of the throttle return springs is an energy source capable of returning the throttle to idle. But I cannot tell from your description and diagram whether a severance or disconnection in the electrical system would cause the throttle to lock in a position other than idle. I would make the same observation with respect to the accelerator pedal. I can not tell from the information you supplied what impact a severance or disconnection failure would have on the pedal. For example, it is not apparent whether some element in the electrical system senses a severance or disconnection in the accelerator control system, so that a sensor transmits a signal to the appropriate energy sources that the throttle should return to idle. If the pedal and return springs can operate mechanically and in concert to return the throttle to idle in the event of a failure in the accelerator control system caused by a severance or disconnection, then together they may be an energy source under the Standard. Question 2a: Is a severance in electric wires in this system a severance or disconnection within the meaning of S5.2? Isuzu considers negative because electric wires are not a moving part. A severance or disconnection of the electric wires in this system would be a severance or disconnection within the meaning of S5.2 of Standard 124. Section S4.1 of Standard 124 defines a 'driver-operated accelerator control system' as 'all vehicle components, except the fuel metering device, that regulate engine speed in direct response to movement of the driver-operated control and that return the throttle to the idle position upon release of the actuating force.' You stated in your letter that, in this new system, when the driver depresses the accelerator pedal, the mechanical displacement is converted into electrical signals. These electrical signals are transmitted by wires to a control unit that regulates engine speed in direct response to pressure on the accelerator pedal, again by means of wires that connect the control unit's electrical signal to the appropriate components. Thus, the control unit, all of the components to which it is connected, and the wires that make those connections are 'vehicle components ... that regulate engine speed in direct response to movement of the driver-operated control and that return the throttle to the idle position upon release of the actuating force.' Under S4.1, then, the control unit, the components to which it is connected, and the wires that make the connection are components of the driver-operated accelerator control system. Section S5.2 of Standard 124 requires that the throttle return to idle 'from any accelerator position or any speed...whenever any one component of the accelerator control system is disconnected or severed at a single point.' Please note that this language does not limit the requirement to disconnections or severances of components that are moving parts. Thus, all severances or disconnections of any component of the accelerator control system are within the ambit of the standard. In this case, since the wires are a component of the accelerator control system, the throttle must return to idle whenever a wire is disconnected or severed. Question 2b: If a severance in electric wires were a severance or disconnection under S5.2, what about a short-circuiting that may result from such a severance? Does the Standard require that the throttle returns to the idle position even in such a condition? Yes. Section S5.2 of Standard 124 requires the throttle to return to the idle position whenever any component of the accelerator control system is disconnected or severed at a single point, regardless of the other consequences of the disconnection or severance. In the case of this system, this language requires the throttle to return to idle when any wire is severed, even if the severance results in a short circuit. Question 2c: Our understanding is that a failure (other than severance or disconnection) of a system component itself (i.e. a failure in the accelerator pedal sensor with pedal position switches, control unit, throttle valve position switch, or stepping motor) is not subject to the throttle return requirement under the Standard. Is this correct? Your understanding is partially correct. Standard 124 addresses those circumstances where (1) the driver removes the opposing actuating force, and (2) a severance or disconnection in the ACS causes a failure. Therefore, you are correct that Standard 124 addresses only those failures resulting from a severance or disconnection within the system. However, for electrical systems, shorted or open circuits are the consequence of a change in one or more of the electrical components in the system. The agency would consider such a change a disconnection or severance in the context of this Standard. Question 3: It is our interpretation that the battery and the electric wires from the battery to the control unit are not a part of the accelerator control system under this definition. (That is, the definition of 'driver-operated accelerator control system.') Is this interpretation correct? No, your interpretation is incorrect. We have set out the definition of 'driver-operated accelerator control system' in section S4.1 above, in response to your Question 2a. With respect to your electrical accelerator control system, the electrical impulse that travels between the vehicle battery and the control unit is a direct consequence of the driver's applying an actuating force to the accelerator pedal. Given this aspect of your system's design, both the vehicle battery and the electric wires from the battery to the control unit fall within the definition of 'driver-operated accelerator control system.' I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam1009OpenTom Caine, Esq., Legal Counsel, Goodyear Tire & Rubber Company, Akron, OH, 44316; Tom Caine Esq. Legal Counsel Goodyear Tire & Rubber Company Akron OH 44316; Dear Mr. Caine: This is to confirm your conversation with Dave Schmeltzer of thi office in which he informed you that a spare tire that is installed in a new vehicle within the occupant compartment would not have to meet the requirements of Standard No. 302 if it is not designed to absorb energy on contact by occupants in the event of a crash. However, this ruling is limited to the actual tire and would not apply to the wheel housing cover of a spare tire since that would be a component specified in S4.1 of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3034OpenMr. Howard J. Bogner, Federal Government Relations Manager, Minnesota Mining & Manufacturing Company, 1101 Fifteenth Street, S.W., Washington, D.C. 20005; Mr. Howard J. Bogner Federal Government Relations Manager Minnesota Mining & Manufacturing Company 1101 Fifteenth Street S.W. Washington D.C. 20005; Dear Mr. Bogner: This is in reply to your letter of June 18, 1979, asking about 'th history of the implementation of FMVSS 108 and the dates as to these proceedings.'; I assume that you are interested in the initial standards and not th many amendments that have occurred at frequent intervals since the first effective dates. An advance notice of proposed rulemaking was published in the *Federal Register* on October 8, 1966, inviting suggestions for all the initial Federal motor vehicle safety standards. The initial motor vehicle lighting requirement were proposed on November 30, 1966 (31 FR 15212, corrected at 31 FR 15600). Standard No. 108 published on February 3, 1967, however, (32 FR 2408, establishing 23 CFR 255.21, effective January 1, 1968) applied only to vehicles whose overall width was 80 inches or more. On the same day the agency (then known as the National Traffic Safety Agency, Department of Commerce) proposed 'MVSS No. 112' to become effective January 1, 1968, to cover all vehicles whose width was less than 80 inches (32 FR 2418). The same notice also proposed amendments to the just-issued Standard No. 108 which were adopted on December 16, 1967 (32 FR 18032) with varying effective dates. Instead of adopting 'Standard No. 112', the agency also amended Standard No. 108 on December 16, 1967 (32 FR 18033) to incorporate the proposed '112' requirements, for vehicles under 80 inches in overall width, but with an effective date of January 1, 1969. At least one amendment occurred before January 1, 1969 (See 33 FR 2994, February 15, 1968), and one interpretation (See 32 FR 8808, June 21, 1967), defining 'overall width'. A petition for review of boat trailer lighting requirements was filed in 1968, and the requirements upheld (See *Boating Industry Association* v. *Boyd*, 409 F.2d 408 (7th Cir., 1969, rehearing denied).; This is the history of the early days of Standard No. 108. The onl 'documentation' that might still exist would be microfiche copies of docket comments (Docket No. 9) which are warehoused in Virginia. The head of our technical reference service, Ms. Winifred Desmond (426-2728) may be able to assist you with these.; If you have any further questions you may call me at 426-9511. Sincerely, Z. Taylor Vinson, Senior Staff Attorney |
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ID: aiam1459OpenMr. Robert L. Carleton, President, Timpte, Inc., 5990 Washington Street, Denver, CO 80216; Mr. Robert L. Carleton President Timpte Inc. 5990 Washington Street Denver CO 80216; Dear Mr. Carleton: This responds to your April 2, 1974, request for a procedure to permi the manufacture of semi- trailers which do not comply with Standard No. 121, *Air brake systems*, after the standard's effective date.; Our authority to enforce standards under S108(a)(1) of the Nationa Traffic and Motor Vehicle Safety Act of 1966 prohibits the sale of a vehicle which does not comply with applicable standards. We are unable to permit by regulation what is prohibited by this section of the law.; We do have under consideration petitions to delay the effective date o Standard 121 as it applies to trailers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.