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: aiam3292OpenMr. William G. Milby, Manager, Engineering Services Department, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. William G. Milby Manager Engineering Services Department Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby:#This responds to your letter of January 16, 1980, i which you asked a number of questions pertaining to Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The answers to your questions are presented below and are numbered to correspond with the numbering of the questions in your letter.#1. Section 5.2.1 provides that where Table 1 of Standard 101-80 shows both a symbol and identifying words or abbreviations for a particular control, use of the symbol is mandatory and use of the words or abbreviations is optional.#2. When a manufacturer identifies a control with both the symbol shown in Table 1, Column 3, and the identifying words or abbreviations shown in Table 1, Column 2, only the symbol is subject to the illumination requirements of Section S5.3. That section states that with certain exceptions (i.e., foot operated controls or hand operated controls mounted upon the floor, floor console or steering column or in the windshield header area) 'the identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are actuated.' Since this section refers only to the identification required by Safety Standard 101-80, it does not apply to identification which is optional under the standard.#3., 4., 5., 6., 7., 8. In questions designated by these numbers, you asked whether the following controls are subject to the identification and illumination requirements of Standard 101-80:#>>>(a) a driver comfort fan which is not a part of the windshield or rear window defrosting and defogging system or the heating and air conditioning system,#(b) hot water flow valves for heaters which are opened in winter and then closed again in summer,#(c) heater fresh air control valves used to control the ratio of fresh to recirculated air entering the heater,#(d) driver's side window defroster control,#(e) driver's fresh air vent control,#(f) fan control for an optional driver's heater which directs air at the driver's feet.<<<#Section 5 of Standard 101-80 states that each vehicle that is subject to the standard and is manufactured with any control listed in Section 5.1 or in column 1 of Table 1 must comply with the requirements of Standard 101-80 regarding the location, identification and illumination of such control. Of the controls listed above, those lettered (a), (d) and (e) are not listed in either of these locations and thus are not subject to these requirements. Items (b), (c) and (f) are part of a heating or air conditioning system indicated in column 1 of Table 1 and is therefore subject to the location and identification requirements of Standard 101-80. However, the fan control, which directs air at the driver's feet, is not subject to the illumination requirements, since section 5.3.1 states, 'control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield.' Likewise, if the hot water flow valves and fresh air control valves are 'mounted upon the floor, floor console or steering column, or in the windshield header area,' then section 5.3.1 does not require them to be illuminated.#9. In your question 9, you asked whether the penultimate line in Table 2 concerning malfunctions in antilocks applies only to vehicles equipped with air brakes and whether the last line concerning brake system malfunctions applies only to vehicles equipped with hydraulic brakes.#The penultimate line of Table 2 applies to all vehicles less than 10,000 pounds GVWR which are equipped with an antilock system, regardless of whether they are air or hydraulic brake equipped vehicles. The agency included the reference to Standard 105, *Hydraulic Brake Systems*, to indicate that section 5.3 of that standard permits a manufacturer to use either a yellow or red warning light depending on whether there is a separate indicator that only warns of antilock failure or there is an indicator which warns of antilock and other brake system failures.#The last line of Table 2 concerning the telltale for brake system malfunction applies to all vehicles equipped with this type of telltale regardless of the type of brake system. The agency included the reference to Standard 105 since section 5.3 of that standard specifies other requirements that brake system malfunction indicators used in hydraulic brake systems must meet.#10. This agency has never established specific size requirements for the identification symbols specified in Tables 1 and 2 of Standard 101-80. Sections 5.2.1 and 6 only require that such symbols be visible to a driver restrained by crash protection equipment.#11. None of the display requirements of Table II of Standard 101-80 apply to vehicles with a GVWR exceeding 10,000 pounds. Displays included in such vehicles in accordance with other standards are subject only to the provisions of those standards.#12. Section 5.3.1 provides that the illumination requirements of Standard 101-80 do not apply to hand operated controls mounted on the steering column. Accordingly, they are not applicable to a hazard control mounted on the steering column.#13. If the clearance lamps are controlled with the headlamp switch, Table 1, footnote 2, of the standard provides that the only identification required is the headlamp switch symbol.#14. Standard 101-80, section 5.2.1, states that controls must be identified with the symbol indicated in Table 1 and that such identification shall be placed on or adjacent to the control. The agency has previously indicated that manufacturers could use a symbol that is a minor deviation from the required symbol, as long as the symbol used substantially resembles that specified in the standard (43 FR 27541, June 26, 1978). Thus, if the wiper symbol you want to use is only a minor deviation and substantially resembles the required wiper symbol, you may use it.#15. You enclosed in your letter a blueprint showing a bank of switches which control multispeed fans and asked whether the identification shown in the print would comply with the requirements of Standard 101-80. Since the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391) requires manufacturers to certify their compliance with all applicable Federal motor vehicle safety standards, this agency does not approve products. However, from our understanding of the information you have provided, it appears that the identification you propose to use for fan controls would comply with Standard 101-80. This opinion is based on the fact that your blueprint shows use of the fan symbol in accord with section 5.2.1 and identification of each function of the fan switch in accord with section 5.2.2.#16. With respect to air conditioning systems:#>>>(1) Section 5.3.1 does not require illumination of the control identification if the system does not direct air directly upon the windshield.#(2) Table 1 and section 5.2.1 require the fan symbol to be used to identify the fan for an air conditioning system,#(3) If the air conditioning system control regulates temperature over a quantitative range, the extreme positions must be identified in accord with 5.2.2.<<<#17. With respect to vehicles over 10,000 pounds GVWR, the requirements of Standard 101-80 concerning telltales used to indicate high engine coolant temperature or low engine oil pressure are inapplicable. With respect to vehicles less than 10,000 pounds GVWR, these requirements are applicable. In a letter to Ford Motor Company (copy enclosed), this agency stated that use of the engine symbol which Ford proposed for identification of such telltales would comply with the requirements of Standard 101-80.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam4557OpenMr. 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 concerning the testin of hydraulic brake hose assemblies to the whip resistance requirement (S5.3.3) of Standard No. 106, Brake Hoses. I regret the delay in responding. Your question relates to Table II of Standard No. 106, which specifies the amount of slack that should be introduced when mounting brake hose assemblies on the whip test apparatus. (The amount of the hose indicated as 'slack' in Table II is the difference between the projected length of the hose assembly (when mounted in the whip test machine) and the free length of the hose while maintained in a straight position.) Slack must be present in the hose when mounted on the whip test machine to enable the proper 'whipping' movement of a brake hose assembly. Without slack, an assembly would probably be incapable of withstanding any rotation of the movable header of the whip test apparatus described in Standard No. 106 without rupturing. Table II specifies the amount of slack for some sizes of assemblies, and not for others. You ask whether a hydraulic brake hose assembly of a size falling in the latter category--viz., an assembly comprised of a brake hose that is 19 to 24 inches in free length, and which is more than one-eighth inch or three millimeters (mm.) in diameter--'need not be tested to meet or exceed the whip resistance requirement' of the standard. With regard to NHTSA's Standard No. 106 compliance testing, your understanding is correct that Table II does not specify the amount of slack for testing assemblies of the size you describe. Due to the absence of the slack specification, NHTSA does not require testing of such assemblies to the whip resistance requirements of the standard. With regard to your certification that the brake hose assemblies you manufacture comply with all applicable requirements of Standard No. 106, you are correct that hydraulic brake hose assemblies of the size you describe are not subject to the whip resistance requirements. However, the agency urges manufacturers to ensure that these assemblies perform in a safe manner while subject to environmental conditions of vehicle operations which may result in flexing of the brake hose or brake hose assembly. Please contact my office if you have further questions. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam3338OpenMr. Emerson D. Gilbert, Yellowstone, Inc., 28163 C.R. 20 W., P.O. Box 1128, Elkhart, Indiana 46515; Mr. Emerson D. Gilbert Yellowstone Inc. 28163 C.R. 20 W. P.O. Box 1128 Elkhart Indiana 46515; Dear Mr. Gilbert: This is in response to your letter forwarding your firm's vehicl identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115, *Vehicle Identification Number*.; The National Highway Traffic Safety Administration does not giv advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1305OpenMr. Kurt Meier, Porsche, Research and Development, 8124 Billow Vista Drive, Playa Del Rey, CA 90291; Mr. Kurt Meier Porsche Research and Development 8124 Billow Vista Drive Playa Del Rey CA 90291; Dear Mr. Meier: Thank you for your letter of September 2, 1973, to Mr. Jame Hofferberth of my staff, inquiring if a particular safety belt system which is illustrated in your enclosures meets the criteria for a passive restraint system.; The interpretation of a passive restraint system published in th Federal Register on May 4, 1971 (36 F.R. 8296) was:; >>>'The concept of an occupant protection system that requires 'n action by vehicle occupants' as used in Standard No. 208 is intended to designate a system that requires no action other than would be required if the protective system were not present in the vehicle.'<<<; With respect to your belt system, a requirement for placing the belt i the storage holder when leaving the car would be considered 'action' and not permitted under the above interpretation of a passive system. However, if the belt system could be entered and exited with essentially no action, in the event the storage holder was not used, automatically releasing 'convenience' holder would not compromise the belt's qualification as a passive system.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam4107OpenMr. Wayne Ivie, Manager, Support Section, Oregon Department of Transportation, Motor Vehicles Division, 1905 Lana Avenue N.E., Salem, OR 97314; Mr. Wayne Ivie Manager Support Section Oregon Department of Transportation Motor Vehicles Division 1905 Lana Avenue N.E. Salem OR 97314; Dear Mr. Ivie: Thank you for your letter concerning Oregon's new vehicle code. Yo asked us to review the code and comment on possible Federal preemption of Oregon's laws for motor vehicle equipment. We apologize for the delay in responding to your inquiry.; On March 19, Ms. Hom of my staff explained in a telephone conversatio that this office is unable to undertake a general review of your state vehicle code as you requested. It would be more appropriate if your legal department reviewed your requirements.; Your letter also requested a clarification of our regulatory definitio of a 'bus.' You asked whether we have a definition of a 'bus' separate from definitions for 'school buses' or 'commercial motor buses.' You appeared to question whether privately-owned passenger vans would be classified as buses since Oregon currently considers 15-passenger vans as either 'passenger vehicles' or 'trucks.'; NHTSA's regulatory definitions for motor vehicles, issued for purpose of the Federal motor vehicle safety standards, are set forth at 49 CFR Part 571.3. We define a 'bus' as a motor vehicle, except a trailer, designed for carrying more than 10 persons. This definition would include 15-passenger vans, and would thus apply to both commercial motor coaches and privately-owned 15-passenger vans.; Our definition of a 'bus' is separate from our 'school bus' definition While the latter term incorporates our 'bus' definition, it includes further criteria based on the intended use of the vehicle. Under Part 571.3, a 'school bus' is a bus that is sold for purposes that include carrying students to and from school or related events (excluding common carriers in urban transportation). If a new 15-passenger van were sold for school transportation purposes, it would be considered a 'school bus' and would have to comply with NHTSA's school bus safety standards.; For purposes of understanding the interaction between Federal and stat vehicle definitions, it is important to distinguish NHTSA's motor vehicle safety standards from state safety standards. State motor vehicle safety regulations apply to the sale and use of motor vehicles. Oregon's vehicle definitions are relevant for determining state requirements applicable to the sale and use of particular classes of motor vehicles. On the other hand, our regulations apply to the manufacture and sale of new motor vehicles, and our definitions specify categories of vehicles subject to appropriate Federal motor vehicle safety standards. New vehicles included within particular categories must be certified as complying with the safety standards applying to that vehicle type. The applicability of our safety standards to a vehicle is not altered by the fact that a vehicle type is classified differently under state law. Thus, although Oregon classifies 15-passenger vans as passenger vehicles or trucks, manufacturers of new 15-passenger vans must manufacture those vehicles to Federal safety standards for buses, or school buses if intended for school use.; I hope this information is helpful. Please contact my office if yo have further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0144OpenMr. E. Woodbridge, Chief Engineer, The Society of Motor Manufacturers and Traders Limited, Forbes House, Halkin Street, London SWI; Mr. E. Woodbridge Chief Engineer The Society of Motor Manufacturers and Traders Limited Forbes House Halkin Street London SWI; Dear Mr. Woodbridge: Thank you for your letter of January 9, 1969, to the Federal Highwa Administrator concerning your 1968 Edition of the S.M.M.T. Tyre and Wheel Engineering Manual.; Federal Motor Vehicle Safety Standard No. 109, within Section S3, list the 'Tyre and Wheel Engineering Data Book dated 1965/1966 of the Society of Motor Manufacturers and Traders Limited (S.M.M.T.)' as one of the references containing acceptable test rims.When Standards No. 109 and No. 110 were developed, the National Highway Safety Bureau accepted the S.M.M.T. 1965/1966 Data Book tire and rims combinations based on established usage. We did not, nor do we at present intend to accept general updating of these referenced publications, either foreign or domestic, as valid reasons for amending Standard No. 109 and No. 110. Consequently, any new tire size designations or alternative rim sizes that you wish to list within Standards No. 109 or No. 110 will have to comply, on an individual basis, with the abbreviated guidelines as outlined in the October 5, 1968 *Federal Register*.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam2179OpenMr. Walter C. Robbins, Jr., Walt Robbins, Inc., 6121 Lincolnia Rd., Alexandria, Va. 22312; Mr. Walter C. Robbins Jr. Walt Robbins Inc. 6121 Lincolnia Rd. Alexandria Va. 22312; Dear Mr. Robbins: This is in response to your November 7, 1975, request for a interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires--Passenger Cars*, as applied to the tire that you have described as a 'Radial, Bias Ply Tire'.; On that date, a meeting was held with you, Mr. Al Duduk, and th following NHTSA personnel in attendance: Dr. E.H. Wallace, A.Y. Casanova, and Mark Schwimmer. At the meeting, out letter to you, dated November 3, 1975, was discussed and alternative forms of labeling for this tire were explored. you presented, in substance, the following four examples of sidewall labeling and inquired about their compliance with Standard No. 109:; >>>1. 'POLYANGLE' accompanied by '3 PLIES 2 POLYESTER 1 ARAMID' 2. 'POLYANGLE' accompanied by 'NOT A CONVENTIONAL RADIAL PLY TIRE' an '3 PLIES 2 POLYESTER BIAS PLIES 1 ARAMID RADIAL PLY'; 3. 'RADIAL/BIAS' accompanied by 'NOT A CONVENTIONAL RADIAL PLY TIRE and '3 PLIES 2 POLYESTER BIAS PLIES 1 ARAMID RADIAL PLY'; 4. 'RADIAL/BIAS' accompanied by 'NOT TO BE USED WITH CONVENTIONA RADIAL BELTED TIRES' and '3 PLIES 2 POLYESTER BIAS PLIES 1 ARAMID RADIAL PLY'<<<; Tires labeled according to your firs example would be in complianc with the requirements of S4.3(g) of Standard no. 109. A strict interpretation of S4.3(g) would rule out the remaining examples because the word 'radial' appears in all of them. However, the NHTSA recognizes that, with the development of new tire construction types, this section of the standard may not be adequate to serve its original purpose, to reduce the hazards associated with the mismatching of tires on a single vehicle. Accordingly, we are preparing to issue a notice of proposed rulemaking to amend the standard. For this reason and because the second, third, and fourth examples are in conformity with the spirit of S4.3(g), the NHTSA will, on an interim basis, consider tires so labeled to be in compliance. You may wish the consult with the Federal Trade Commission concerning the advertising of these tires.; I would like to point out that S4.3(d) requires Kevlar, if used as cord material in a tire, to be identified by its generic name on the tire's sidewall. The generic name of kevlar, as established by the FTC pursuant to the Textile Fiber Product Identification Act (15 USC 70), is Aramid.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5346OpenKen Simons, Esq. P.O. Box 883 Fairmont, WV 26555; Ken Simons Esq. P.O. Box 883 Fairmont WV 26555; "Dear Mr. Simons: This responds to your letter asking about brak requirements for trailers used in tractor trailer combinations. I apologize for the delay in our response. You asked whether all such trailers are required to be equipped with 'maxi' brakes on one or both axles. You state that a 'maxi' brake is found on all road tractors and 'sets the brakes automatically when the air pressure gets down to a minimum level.' Please note that the term 'maxi' brakes ordinarily refers to spring brakes used in parking and emergency brake applications. I further note that most, but not all, trailers are equipped with spring brakes. I am pleased to have this opportunity to explain our requirements. By way of background information, under the National Traffic and Motor Vehicle Safety Act ('Safety Act,' 15 U.S.C. 1392), the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA does not approve vehicles or equipment. Instead, manufacturers are required to certify that their vehicles or equipment meet all applicable standards. Standard No. 121, Air Brake Systems (49 CFR 571.121, copy enclosed), specifies performance requirements for trucks, buses and trailers equipped with air brake systems. The purpose of the standard is to insure safe braking performance of vehicles under normal and emergency conditions. While Standard No. 121 does not require manufacturers to use spring brakes or any other particular type of brake system, many manufacturers use spring brakes to comply with the standard's requirements concerning parking brake performance (trucks, buses and trailers, see S5.6), emergency brake performance (trucks and buses only, see S5.7), and trailer pneumatic system failure performance (see S5.8). I note that while the requirements of S5.6 and S5.8 apply to most air-braked trailers, S3 of Standard No. 121 excludes some trailers from all of the standard's requirements. In addition, S5.6 and S5.8 specify alternative requirements for some trailers. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam2483OpenMr. David J. Humphreys, 5272 River Road, Suite 400, Washington, D.C. 20016; Mr. David J. Humphreys 5272 River Road Suite 400 Washington D.C. 20016; Dear Mr. Humphreys: This responds to your November 24, 1976, letter in which you as whether a draft certification label and owner's manual (submitted along with your letter) that are designed to accompany a camper would comply with Standard No. 126, *Truck-Camper Loading*.; The camper you describe uses a third axle which can support varyin amounts of the 'total cargo weight' of the caper, as this term is used in the standard. Although this camper falls within the definition of a slide-in camper, the NHTSA concludes that the requirements of Standard No. 126 are not appropriate and were not intended for this type of camper. Campers employing third axles as part of their support pose loading problems which Standard No. 126 does not adequately address. The required statements and figures in S5.1.2(c) and (e) of the standard address the concept of 'center of gravity' not 'effective center of gravity' to which you refer in your letter.; Although we have interpreted the requirements of Standard No. 126 to b inappropriate and inapplicable to the camper you describe, we recognize a need to provide the purchaser with sufficient information to ensure that the load capabilities of trucks will not be exceeded and that the 'effective center of gravity' of the camper will correspond to the center of gravity of the truck. The information detailed in your letter should aid the purchaser in the safe installation of the camper. Without this information improper installation could more easily occur, which would affect the overall safety of the vehicle.; At this time, we are not able to make ny comments regarding potentia handling problems that may arise because of the additional axle. The NHTSA will, therefore, continue to study the use of campers with third axles. If the agency identifies problems in this configuration or discovers accidents resulting from improper installation of the camper, we would consider amending Standard No. 126 to include appropriate requirements for campers with third axles.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0514OpenMr. Armand F Macmanus, Esq., Phillips Petroleum Company, Bartlesville, Oklahoma 74004; Mr. Armand F Macmanus Esq. Phillips Petroleum Company Bartlesville Oklahoma 74004; Dear Mr. Macmanus: This is in reply to a request made on behalf of Phillips Petroleu Company by Veigh J. Nielson for an assigned identification mark for two of Phillips' plants which manufacture tires for research purposes.; As I informed you in my letter of September 20, 1971, if Phillip purchases a new tire, removed the tread material an then applies its own experimental tread containing various rubber compounds, Phillips is considered to be a new tire manufacturer. If Phillips applies its experimental tread to a used tire, it is considered a retreader of tires.; As a new tire manufacturer you are required to certify the tire a conforming to the new passenger car tire standard (No. 109) and comply with Part 574 - Tire Identification and Record Keeping (49 CFR 574). Accordingly, you are assigned the identification mark of 'J1' for tires made in your Bartlesville, Oklahoma plant and 'K1' for tires manufactured in you Stow, Ohio plant.; If you act as a retreader then Part 574 would not be applicable for th tires you retread because they are retreaded for your own use. (Enclosed is a copy of Docket No. 70-12, Notice No. 8 which makes the regulation inapplicable to retreaders who retread for their own use). As explained in my letter of September 20, you are, of course, required to certify that your new tires and your retreaded tires comply with the respective standards for new and retreaded tires if they are to be used on public highways, by placing the symbol DOT on the tires in the prescribed location.; Sincerely, Lawrence R. Schneider |
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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.