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: aiam1581OpenMr. George Semark, Safety Engineer-Vehicles, Sheller-Globe Corporation, 2885 St. Johns Avenue, Lima, OH 45804; Mr. George Semark Safety Engineer-Vehicles Sheller-Globe Corporation 2885 St. Johns Avenue Lima OH 45804; Dear Mr. Semark: This is in response to your letter of July 15, 1974, inquiring as t the applicability of Part 581, the proposed bumper standard (39 FR 25237), to buses, specifically school buses.; The standard, as proposed, applies to passenger motor vehicles othe than multipurpose passenger vehicles. These vehicle categories are used in the standard as they are defined in Section 2 of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Act defines passenger motor vehicles as those vehicles with motive power designed to carry 12 persons or less, except motorcycles and trucks not designed primarily as passenger carriers. Multipurpose passenger vehicles are defined as passenger motor vehicles constructed either on a truck chassis or with features for occasional off-road use. Buses, which are defined at 49 CFR Part 571.3 but not in the Cost Savings Act, are motor vehicles designed to carry more than 10 persons.; The application section of the proposed bumper standard excludes fro coverage passenger carrying vehicles designed to seat 12 persons or less when they are either constructed on a truck chassis or possess features for off-road operation. Any vehicle defined under 49 CFR Part 571.3 that is designed to carry 11 or 12 passengers would, for the purposes of Part 581, be classified as either a multipurpose passenger vehicle or a passenger vehicle. If such a bus meets the multipurpose passenger vehicle definition it would be excepted from the standard's coverage. However, if the bus has neither features for occasional off-road use nor a truck chassis it would be subject to the Part 581 bumper standard.; A school bus is a subcategory of bus, and it would be subject to any o the requirements of the proposed bumper standard applicable to buses in general.; Thank you for your inquiry. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4279OpenThe Honorable Floyd D. Spence, U.S. House of Representatives, Washington, DC 20515; The Honorable Floyd D. Spence U.S. House of Representatives Washington DC 20515; Dear Mr. Spence: Thank you for your letter enclosing correspondence from you constituent, Mr. George Seaborn of the South Carolina Association of School Superintendents, concerning Federal regulations for school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration is responsible for administering Federal programs relating to school bus safety.; In his letter to you, Mr. Seaborn expresses his concern about a Federa regulation that 'excludes the use of vans capable of transporting more than 10 persons from use by schools.' Mr. Seaborn explains that it would be difficult for school districts to comply with a restriction on van use since large vans are extensively used for pupil transportation. He believes that schools should be permitted to use vans since those vehicles are safe for transporting passengers other than school children.; I appreciate this opportunity to clarify our school bus regulations. A explained below, there is no Federal prohibition directed against schools or school districts which prevents them from using vans carrying 11 or more persons. Federal law does, however, affect the sale of buses to schools. NHTSA has the authority, under the National Traffic and Motor Vehicle Safety Act, to regulate the manufacture and sale of new motor vehicles. In 1974, Congress enacted the Schoolbus and Motor Vehicle Safety Amendments to direct NHTSA to issue motor vehicle safety standards on specific aspects of school bus safety and apply those standards to all 'school buses.' The school bus standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date.; The parties subject to the Vehicle Safety Act are the manufacturers an sellers of new school buses. The Vehicle Safety Act requires each person selling a new 'school bus' to ensure that the bus complies with our school bus safety standards. Under Federal law, a van designed for 11 or more persons (driver included) is a 'bus,' and is a 'school bus' if intended for transporting students to and from school or related events.; A person may sell a new bus (including a van designed to carry 10 o more persons) to a school or school district provided that the vehicle meets our motor vehicle safety standards for school buses.; Because our regulations apply only to the manufacture and sale of ne motor vehicles, we do not prohibit school districts from using their large vans to transport school children even when the vehicles do not meet Federal school bus safety standards. Matters relating to motor vehicle use are determined by state law. However, in the event a South Carolina school district decides to buy a new school bus, we would like the district to keep in mind that the seller would be obligated under the Vehicle Safety Act to sell complying school buses. The seller should know that he or she risks substantial penalties if a noncomplying bus is sold as a school bus.; Since Mr. Seaborn is interested in transporting students in vans, would like to clarify a few additional matters concerning our school bus regulations. In his letter to you, your constituent expresses a belief that large vans (i.e., buses) should be safe for school children since they are safe for other passengers. The legislative history of the Schoolbus Amendments of 1974 indicate that Congress believed that special measures should be taken to protect school children who use school bus transportation. Fifteen-passenger vans (i.e., buses) meeting our school bus safety standards provide more safety features than other buses. School buses must meet stringent performance requirements, including those for interior protection, fuel systems, emergency exits, windows and windshields and seating systems.; New 15-passenger vans, conforming to our school bus standards, may b sold to school districts to transport their pupils to school related events. School districts may also purchase 9-passenger vans for school transportation, because such vans are considered 'multipurpose passenger vehicles' (MPV's) and not 'buses' or 'school buses' under Federal law. We do not prohibit the sale of MPV's to carry school children nor do we require them to comply with Federal school bus safety standards. Instead, they must meet the performance requirements set by the safety standards for MPV's which also provide high levels of passenger safety.; I hope this information is helpful. We have provided similar letters t Representatives Robin Tallon and Butler Derrick who contacted us on behalf of Mr. Seaborn. Please let us know if we can be of further assistance to you and your constituents.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4783OpenMr. William Shapiro Volvo Cars of North America Rockleigh, NJ 07647; Mr. William Shapiro Volvo Cars of North America Rockleigh NJ 07647; "Dear Mr. Shapiro: This responds to your letter about the built-i child seat Volvo has designed for the center rear seating position. The built-in seat uses the vehicle's lap-shoulder safety belt to restrain the child. I regret the delay in responding. You indicated in a telephone conversation that Volvo is considering designing the seat solely for children who weigh more than 50 pounds. Such a seat is not subject to the requirements of Standard 213 because the seat is not a 'child restraint' as that term is defined in the standard. Paragraph S4 of Standard 213 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 weigh not more than 50 pounds.' The agency would determine whether your built-in seat is designed solely for children weighing more than 50 pounds by considering available indications of the manufacturer's design intent, e.g., the physical suitability of the seat for use by children who weigh less than 50 pounds, and the manner in which the seat is labeled and marketed. The agency would look to see whether the seat is clearly and permanently labeled to show the size and age of children intended to be restrained by the system. We would also consider any indications in Volvo's marketing efforts and point of sale materials regarding the size and age of child that the seat is designed to restrain. Finally, we would consider any size and age information included in the vehicle's owner manual. You also indicated Volvo may consider designating the seat as suitable for children weighing more than 40 pounds. If the seat were so designated, it would no longer be a seat designed solely for children weighing more than 50 pounds, and therefore be a child restraint system subject to Standard 213. You ask whether, if Standard 213 applies to your seat, the standard permits such a seat. You state that the seat would meet the labeling and performance requirements of the standard. You believe that Standard 213 permits the seat because the final rule that amended 213 to set requirements directly applicable to built-in seats (53 FR 1783, January 22, 1988) said that paragraph S5.4.3.3 of the standard allows child restraint systems other than a 5-point harness system. You are correct that the standard does not require the use of a harness in a child restraint system. Paragraph S5.4.3.3 provides, in part, that 'each child restraint system . . . that has belts designed to restrain the child' must comply with the specific requirements of S5.4.3.3 (i.e., provide upper and lower torso restraint, and a crotch restraint (for seats for children weighing over 20 pounds), of a specific form). The definition of a 'child restraint system' specifically excludes the vehicle's lap/shoulder belts from the coverage of the standard. Thus, under that definition and the language of S5.4.3.3, the specific requirements of S5.4.3.3 on harness systems applies only to seats that have belts, and not to a seat such as yours that uses the vehicle's belt system. Please note that Standard 213 sets limits on knee excursion for built-in seats (S5.1.3.1(b)). Thus, although your seat is not required to have a crotch strap, the seat must be designed to prevent a child from sliding excessively forward and down, legs first ('submarining'). The agency would like to emphasize its concern that when a vehicle lap belt is used with a child restraint system to restrain a child, the lap belt should be positioned so that it does not apply impact loads to the abdomen of the child, the area most vulnerable to the forces imposed by the belt. Instead, the vehicle lap belt should be held in place by the child restraint so that it passes over the pelvis of a child, the area of the body best able to withstand the forces imposed by the vehicle belt. We cannot determine from your drawing whether the vehicle lap belt would be properly positioned and securely held by the restraint. The instructions for the proper use of the built-in seat that are required by S5.6.2 of the standard should inform users how to properly adjust the belt system, so to avoid submarining and imposing impact loads to the child's abdomen. The agency is also concerned that the sitting height of some children who may occupy the seat might not be high enough for the shoulder belt to be properly positioned when attached. Instead, the belt might pass in front of the child's neck or face. For those cases, if no other option is available, NHTSA believes that the shoulder belt should be placed behind the child's back. We recommend that you include information in the printed instructions about such adjusting of the shoulder belt for small children. As a reminder, NHTSA will use these adjustment instructions per S6.1.2.3.1 to position the three year old dummy in the seat if the agency tests the seat in its compliance program. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam3046OpenMr. Paul Schuil, 27 Seneca Avenue, Emerson, NJ 07630; Mr. Paul Schuil 27 Seneca Avenue Emerson NJ 07630; Dear Mr. Schuil: This responds to your recent letter asking whether smoked, tinted an mirrored windows may legally be used on vehicles operating on U.S. highways.; The Federal requirements for glazing materials on motor vehicles ar set forth in the Federal Motor Vehicle Safety Standard No. 205 (49 CFR 571.205). This standard specifies performance requirements for the various types of glazing and also the locations in vehicles in which each glazing type may be used. Smoked, tinted and mirrored glazing may be used in certain vehicles in certain locations. For example, smoked glass may be used in side windows of trucks and buses. However, glazing material for use in any vehicle at levels requisite for driving visibility (e.g., windshields) must have a luminous transmittance of at least 70 percent. Most smoked glass would not pass this requirement. I am enclosing a copy of Safety Standard No. 205 for your information. If you have any questions after reviewing the standard, contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3553OpenJerry Manzagol, Director, New Mexico Transportation Department, Motor Vehicle Division, Manuel Lujan Senior Building, Santa Fe, NM 87503; Jerry Manzagol Director New Mexico Transportation Department Motor Vehicle Division Manuel Lujan Senior Building Santa Fe NM 87503; Dear Mr. Manzagol: This is in response to your letter of March 10, 1982, requesting th approval of the revised New Mexico odometer disclosure for use in lieu of the Federal odometer disclosure statement. In October 1981 you submitted New Mexico's proposed odometer disclosure statement to the agency for approval for use in lieu of the separate Federal odometer form. The agency reviewed the form and determined that it could not be substituted for the Federal form unless the third alternate certification was rephrased to comport with the requirements of the Federal odometer law and the transferee's signature was added.; The agency has reviewed New Mexico's revised odometer disclosur statement and has now determined that it can be substituted for use in lieu of the Federal odometer disclosure statement.; If you have any further questions, please do not hesitate to write. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4296OpenCharles Schamblin, Flag-It Fluorescent Signaling Device Co., Post Office Box 1709, Bakersfield, CA 93302; Charles Schamblin Flag-It Fluorescent Signaling Device Co. Post Office Box 1709 Bakersfield CA 93302; Dear Mr. Schamblin: Your letter of December 29, 1986, to Michael M. Finkelstein has bee referred to my Office for reply. You also addressed a letter of January 9, 1987, to my Office. Because these letter concern the same matter, this response addresses them both. In the December 29 letter, you asked about the appropriate color for your product, the Flag-It Fluorescent Signaling Device. The device, which you enclosed with your correspondence, is a rectangular green fluorescent strip, designed to be permanently attached to and hang vertically from the license plate frame on the front of a motor vehicle.; You state that you designed this device 'especially to meet th requirements for fluorescent material in the front of motor vehicles.' You ask for a 'letter of certification' that your device can be used and sold in the Unites States.; The National Highway Traffic Safety Administration (NHTSA) ha authority to issue safety standards applicable to new motor vehicle and certain items of motor vehicle equipment. However, NHTSA does not approve nor certify motor vehicles or motor vehicle equipment, or endorse any commercial product. Instead, the National Traffic and Motor Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer must certify that its product meets agency safety standards, or other applicable standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; Your product is an item of motor vehicle equipment under S102(4) of th National Traffic and Motor Vehicle Safety Act, and as such, falls under NHTSA's jurisdiction. However, none of our Federal motor vehicle safety standards applies to your product.; Standard 125, *Warning Devices*, sets uniform design specifications o reflective warning devices used to warn approaching traffic of the presence of a stopped vehicle. As is apparent from the provisions regarding the scope and applications of the standard, Standard 125 applies to devices designed to be carried in motor vehicles and erected when needed to warn approaching traffic. It does not apply to warning devices designed to be permanently attached to a motor vehicle. Nevertheless, you may wish to use the colors specified in paragraph S5.3. They are the ones which the agency believes most appropriate for warning devices subject to the standard.; Standard 108, *Lamps, Reflective Devices, and Associated Equipment* applies to reflective devices. While the agency notes that your product includes reflective material, Standard 108 covers aftermarket reflective devices only to the extent that the aftermarket device replaces required original reflective equipment. Because the kind of device you described is not subject to any Standard 108 requirement as original reflective equipment, it is likewise not subject to any such requirement as aftermarket equipment.; Finally, please be aware that if you or the agency finds your produc to contain a safety-related defect after you market the product, you are responsible for conducting a notice and recall campaign under S154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1414).; Further, you should be aware that State law may apply to equipment suc as your signaling device. You may wish to consult the state and local transportation authorities in the areas where you intend to market your product.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1094OpenMr. Lowell Liebenstein, President, Gil-Mar Welding Corp., 2142 Maple Road, Grafton, WI 53024; Mr. Lowell Liebenstein President Gil-Mar Welding Corp. 2142 Maple Road Grafton WI 53024; Dear Mr. Liebenstein: This is in reply to your letter of March 14, 1973, asking how to compl with NHTSA Certification regulations in cases where you supply a trailer chassis or frame only, and another manufacturer installs the body. In another example, you supply the vehicle without an axle assembly, which is, we assume, also installed by another party.; Based on your letter, the procedures to be foloowed in certifyin vehicles such as these are those contained in NHTSA regulations for 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568, copy enclosed). Briefly, these regulations require the incomplete vehicle manufacturer, who would be you in these cases, to furnish with the incomplete vehicle a document indicating the extent that the incomplete vehicle a document indicating the extent that the incomplete vehicle conforms to Federal standards, and what the final stage manufacturer must do in order that the completed vehicle will conform to all applicable standards.; If upon your review of these regualtions you have further questions, w will be pleased to respond to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3103OpenMr. Mark K. McDonald, PACCAR, Inc., Business Center Building, P.O. Box 1518, Bellevue, Washington 98009; Mr. Mark K. McDonald PACCAR Inc. Business Center Building P.O. Box 1518 Bellevue Washington 98009; Dear Mr. McDonald: This is in response to your letter of May 22, 1979, concerning Federa Motor Vehicle Safety Standard No. 115, and in confirmation of your telephone conversation with Mr. Schwartz of my office.; You have asked whether a manufacturer must designate a vehicle a 'incomplete vehicle' if, although it is shipped in an incomplete form, its completed type is known. The 'incomplete vehicle' type was established to deal with situations where the manufacturer did not know what the vehicle's final type would be when it assigned the VIN. If the final form the vehicle will take is known to the manufacturer, it may identify that type in the VIN, or it may designate it as an incomplete vehicle. The agency would prefer, however, that the final type be indicated.; There is no requirement that use of a particular vehicle typ designation for VIN purposes be consistent with any other documentation regarding shipment or sale of vehicles manufactured in more than one stage, except that the actual VIN must be used where it appears on the documentation. For example, a vehicle may be designated an incomplete vehicle for the purposes of the NHTSA certification requirements and a truck for the purposes of the VIN requirements.; You have also asked the agency to confirm that engine horsepower nee not be directly or indirectly decipherable from the VIN. This is essentially correct. 'Engine type' is defined in S3 of the standard to mean a power source with defined characteristics such as fuel utilized, number of cylinders, displacement and net brake horsepower. Thus, encoding an engine manufacturer's basic model number would be sufficient. There remains, however, a question as to the point at which two engines with the same characteristics except for horsepower become two different engines. The agency intends to resolve this question in a notice in the Federal Register.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5487Open"Mr. Gary Blous V.P. Engineering Fitting Image 2075 Adams Avenue San Leandro, CA 94577"; "Mr. Gary Blous V.P. Engineering Fitting Image 2075 Adams Avenue San Leandro CA 94577"; "Dear Mr. Blous: This responds to your letter asking about how thi agency's regulations might apply to your product. I apologize for the delay in sending this letter. In your letter, you described your product as a bag holder for the interior of vehicles, designed to attach to the head restraint and hang on the back side of the front seats. Based on the illustration you provided, the bag holder appears to be a 12 inch flexible strap that attaches to the head restraint, with a 'rigid plastic' hook at the end from which plastic grocery bags are suspended. The short answer to your question is that, while there are no regulations that apply directly to your product, there are Federal requirements that may affect the sale of this product. I am enclosing a copy of a fact sheet titled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' By way of background information, NHTSA is authorized to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles and new items of motor vehicle equipment. NHTSA's authority to issue these regulations is based on title 49, section 30102(7) of the U.S. Code (formerly the National Traffic and Motor Vehicle Safety Act), the relevant part of which defines the term 'motor vehicle equipment' as: (A) any system, part, or component of a motor vehicle as originally manufactured, (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component or as any accessory, or addition to a motor vehicle . . . (emphasis added). Although you appear to recognize the applicability of our regulations, based on your characterization of your product as 'after market equipment,' allow me to explain how NHTSA determines whether an item of equipment is considered an accessory under the U.S. Code. The agency applies two criteria. The first criterion is whether a substantial portion of its expected uses are related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. If the product satisfies both criteria, then the product is considered to be an 'accessory' and thus subject to the provisions of the U.S. Code. Your bag holder appears to be an accessory and thus an item of motor vehicle equipment under our regulations. It appears to be designed specifically to fit in motor vehicles using the head restraints, meaning that a substantial portion of its expected use relates to motor vehicle operation. The bag holder would typically be purchased and used by ordinary users of motor vehicles (i.e., anyone using the vehicle). While your bag holder is an item of motor vehicle equipment, NHTSA has not issued any standards for such an item. However, you as a manufacturer of motor vehicle equipment are subject to the requirements in sections 30118-30122 of Title 49 of the U.S. Code concerning the recall and remedy of products with defects related to motor vehicle safety. 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. Although no standards apply directly to the bag holder, there are other provisions of law that may affect the manufacture and sale of your product. NHTSA has issued a safety standard (Standard No. 201, Occupant protection in interior impact) that requires, among other things, that seat backs have a certain amount of cushioning to provide protection when struck by the head of rear seat passengers during a crash. Installation of your product on the back of front seats could have an impact on compliance with that standard. If your bag holder were installed so that a hard object (e.g., the rigid plastic hook) were to be struck by the occupant's head, the requisite amount of cushioning might not be achieved. We do not know how big or how 'rigid' the hook is, but it is something of which you should be aware. Other legal requirements could apply depending on how your product is marketed. If your product were installed by a vehicle manufacturer as original equipment, the vehicle manufacturer would have to certify that the vehicle with the bag holder installed complies with all FMVSS's, including Standard No. 201. In addition, although we recognize it would be unlikely that your product would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, section 30122(b) of title 49 prohibits those commercial businesses from 'knowingly mak ing inoperative any part of a device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard . . .' For instance, compliance with Standard No. 201 might be degraded if the bag holder were mounted in front of rear seat passengers. Any violation of this 'make inoperative' prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation. The 'make inoperative' prohibition does not apply to modifications that vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where individual vehicle owners install your bag holder in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, NHTSA encourages vehicle owners not to degrade any safety device or system installed in their vehicles. In addition, individual States have the authority to regulate modifications that individual vehicle owners may make to their vehicles, so you might wish to consult State regulations to see whether your device would be permitted. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Mr. Atelsek of my staff at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam2342OpenHonorable Guy Vander Jagt, House of Representatives, Washington, DC 20515; Honorable Guy Vander Jagt House of Representatives Washington DC 20515; Dear Mr. Vander Jagt: This is in response to your letter of June 14, 1976, forwarding petition from Gulf + Western Manufacturing Company for reconsideration of the bumper standard recently issued as Part 581 of Title 49 Code of Federal Regulations.; A number of requests for our view on the Gulf + Western petition hav been forwarded by members of Congress who have received copies of the Gulf + Western petition accompanied by a letter from Mr. James A. Graham.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Gulf + Western.; I assure you that Gulf + Western's comments and the informatio contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.