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: aiam3705OpenMr. Chuck Howard, President, Safety Alert Co., Inc., 1667 9th Street, Santa Monica, CA 90404; Mr. Chuck Howard President Safety Alert Co. Inc. 1667 9th Street Santa Monica CA 90404; Dear Mr. Howard: We have received your petition for rulemaking of April 25, 1983, you letter of May 6 withdrawing it, and your letter of May 5 to Mr. Vinson of my staff asking for an interpretation. All this concerns the applicability of Standard No. 108 to your 'Vehicle Deceleration Warning System.'; As we understand it, this system was originally designed to provide flashing light through the back-up lamp system, in which yellow bulbs were used as substitutes for the white ones required by Standard No. 108. You were informally advised by agency staff that such a system would render the vehicle noncompliant with the requirement that a back-up lamp be white, and that it be steady burning in use.; You asked Mr. Vinson if there were another alternative for flashing re lights that would comply with Standard No. 108, and, in your letter of the 6th, whether use of the hazard warning system was acceptable. You also inquired about retrofitting vehicles manufactured before hazard warning signals were required, so that your system would work through the rear turn signals.; In the context of Federal regulations an optional system such as your is acceptable as original equipment, or equipment added before initial sale of the vehicle, if it does not impair the effectiveness of lighting equipment required by Standard No. 108. In our view, it is permissible to use any rear lighting system Standard No. 108 allows to flash for signalling purposes. Thus, your system could operate through the rear hazard warning system, or the rear turn signal system (red or amber) as long as the color of light or photometrics required by the standard was not changed.; As an aftermarket device intended for installation on vehicles in use it must not render inoperative in whole or in part Federally- mandated lighting equipment. Subject to the restrictions noted above, your system would not violate this prohibition were it installed to work through the hazard warning or turn signal systems. However, since your system involves an aspect of performance not covered by Standard No. 108, each State may regulate its use as it sees fit.; Passenger cars built since January 1, 1969, have been required to hav hazard warning signal systems. Use of the turn signal system of a vehicle built before that date is not prohibited under Federal regulations but is also a matter to be determined by local law.; I hope that this is responsive to your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2817OpenMr. R. O. Sornson, Manager, Environmental Relations, Office of Public Responsibility and Consumer Affiars (sic), Chrysler Corporation, P.O. Box 1919, Detroit, MI 48231; Mr. R. O. Sornson Manager Environmental Relations Office of Public Responsibility and Consumer Affiars (sic) Chrysler Corporation P.O. Box 1919 Detroit MI 48231; Dear Mr. Sornson: This is in reply to your letter of May 4, 1978, to Howard Dugof requesting confirmation of two interpretations of Motor Vehicle Safety Standard No. 108. You have cited our letter of December 29, 1976, to your Mr. Weil as support for your views.; With respect to your first concern, you have stated your understandin that in a multiple compartment taillamp the manufacturer has the option of using one or more compartments to meet the minimum photometric requirements specified for taillamps, but when the intensity ratio of the turn signal lamp to the taillamp is computed, the ratio must be determined with all taillamp compartments lighted.; As we interpret Standard No. 108's requirements for taillamps (SA Standard J585d, *Tail Lamps (Rear Position Light)*, August 1970), a single compartment lamp may be used as a taillamp, but if a multiple compartment lamp or multiple lamps are used to meet the photometric requirements, S3.1 of J585d requires that the combination of the compartments or lamps must be used to meet the photometric requirements for the corresponding numbers of lighted sections (Table 1, J585d) in those instances where the distances between filament centers do not exceed 22 inches for two- compartment or lamp arrangements, and 16 inches for three compartment or lamp arrangements. If these distances are exceeded, each compartment or lamp must comply with the photometric requirements for one lighted section. Therefore your interpretation is incorrect that a manufacturer may use only one compartment of a multi-compartment lamp when considering compliance with the photometric requirement for taillamps.; Your second concern is the requirement for multiple lamps in excess o three. You have noted that Table 1 of SAE J585 makes no provision for candlepower requirements where there are more than three lighted sections. Noting that the maximum candlepower permissible rises in increments of 5 per section (15 for one section, 20 for two sections, 25 for three sections) you have asked for confirmation of your opinion that 'it appears logical that the allowable candle-power for a four compartment system should be 30 candlepower.'; Standard No. 108 does not specify requirements for compartments o lamps in excess of three. If you wish to use a four compartment or lamp system you are legally free to distribute the candlepower as you deem appropriate. Accordingly we have no objection to your belief that 30 candlepower is allowable provided that the multiple compartment lamp or multiple lamp arrangement meets all other requirements of J585d.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3210OpenMr. Paul Stumbaugh, Esq., 115 South Oklahoma, Mangum, OK 73554; Mr. Paul Stumbaugh Esq. 115 South Oklahoma Mangum OK 73554; Dear Mr. Stumbaugh: Please accept my apologies for our delay in responding to your lette of September 17, 1979. You asked whether your client would be required to submit to this agency's inspection or gain its approval before installing a device which connects the gas cap of an automobile to the horn wires and switches so that the horn blows continuously when the gas cap is removed by a potential thief.; Your client would not be required to obtain an inspection of hi product by this agency or to obtain an approval of his product. However, he would be required to comply with other requirements should he begin to manufacture or install his device.; Part 566 of Title 49 of the Code of Federal Regulations (copy enclosed requires every person who begins the manufacture of motor vehicles or motor vehicle equipment to submit certain information about his business to this agency not later than thirty days after he begins to manufacture. The information consists primarily of the name and address of the manufacturer and a description of the types of motor vehicles or motor vehicle equipment to be produced.; The National Traffic and Motor Vehicle Safety Act, as amended 1974 (the Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue motor vehicle safety standards applicable either to entire vehicles or to equipment for installation in vehicles. Safety Standard No. 301-75, *Fuel System Integrity*, (copy enclosed) is a vehicle standard which applies to certain vehicles, including passenger cars, that use fuel with a boiling point above 32 degrees F. The standard applies to completed vehicles instead of fuel tanks or other fuel system components and thus is inapplicable to the manufacture of your client's device.; Despite the inapplicability of Safety Standard No. 301-75 to it manufacture, your client's device must be designed and manufactured for safety. Since use of your client's product involves attaching electrical wires to the gas cap, we are particularly concerned that it be built in a way which will prevent any electrical spark from coming into contact with gasoline in the fuel tank, filler pipe or in other fuel system components or with gasoline fumes. As a manufacturer of gas cap anti-theft devices, your client would be subject to the defects responsibility provisions of the Act (section 151 et seq., copy enclosed). Upon discovery of a safety-related defect by the NHTSA Administrator or your client himself, your client would be required to notify the vehicle owners, purchasers, and dealers and remedy the defect.; If your client installed one of his devices in a new vehicle, i.e., vehicle which has not yet been purchased in good faith for purposes other than resale, he would be a vehicle alterer under the NHTSA regulations. As an alterer, he would be required by 49 CFR 567.7 to affix an additional label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards--including Safety Standard No. 301-75. Should a noncompliance or safety-related defect be discovered in a (sic) such a vehicle, as a result of the modification, your client would be required to notify vehicle owners, purchasers, and dealers and to remedy the defect.; If your client installed one of his devices in a used passenge vehicle, he would not be required to attach an alterer's label. However, section 108(a)(2)(A) of the Act would apply. Section 108(a)(2)(A) provides in relevant part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item or motor vehicle equipment in compliance with a Federal motor vehicle safety standard. . .<<<; Thus, if your client added one of his devices to a used passenge vehicle manufactured in compliance with Safety Standard No. 301-75 and other standards, and in the process knowingly rendered inoperative the compliance of the fuel system or another system, he would be in violation of section 108(a)(2)(A).; I hope that you will find this information helpful. If you have furthe questions please feel free to contact Ms. Debra Weiner of my staff at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3640OpenConfidential; Confidential; Dear Confidential: This responds to your recent request for an interpretation of th requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. Specifically, you asked if that standard allows a manufacturer to equip a motorcycle with passenger car tires and rims.; Standard No. 120 permits a motorcycle to be equipped with passenger ca tires and rims, provided that those tires and rims meet all the requirements of the standard. Section S5.1.1 of Standard No. 120 requires all motorcycles equipped with pneumatic tires for highway service to be equipped with tires that meet either the requirements of Standard No. 109, which applies to new passenger car tires, or Standard No. 119, which applies to new tires for use on motor vehicles other than passenger cars. Thus, passenger car tires can be used on new motor cycles, as long as those passenger car tires are certified as complying with Standard No. 109.; Motorcycle rims are subject to two requirements. First, section S5.1. requires that the rims be listed by the manufacturer of the tires installed on the motorcycle as suitable for use with those tires. If you use rims which are the proper size for the passenger car tires to be used, this requirement is easily met by passenger car rims. Second, rims used on motorcycles must meet the rim marking requirements in section S5.2 of Standard No. 120. Passenger car rims generally do not meet these marking requirements, because the rim manufacturers do not mold the required information onto passenger car rims. However, if you can obtain passenger car rims marked with the information set forth in section S5.2 and listed by the passenger car tire manufacturer as appropriate for use with the passenger car tires, those rims could be used on new motorcycles.; A copy of this letter with your name and address deleted, along wit your request for an interpretation of Standard No. 120, has been placed in the public docket under interpretations of Standard No. 120. Should you have any further questions or need further information on this matter, please contact Mr. Stephen Kratzke of my staff at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4185OpenMr. Koji Tokunaga, Manager, Engineering, Isuzu Motors America, Inc., 21415 Civic Center Driver (sic), Southfield, MI 48076-3969; Mr. Koji Tokunaga Manager Engineering Isuzu Motors America Inc. 21415 Civic Center Driver (sic) Southfield MI 48076-3969; Dear Mr. Tokunaga: Thank you for your letter of December 19, 1985, to former Chief Counse Frank Berndt, asking several questions about how the requirements of Standards No. 207, *Seating Systems*, 209, *Seat Belt Assemblies*, and 210, *Seat Belt Assembly Anchorages*, apply to an air-suspension truck seat equipped with a safety belt and a tether belt. The diagrams you enclosed with your letter show that one end of the tether belt is connected to the floor behind the seat and the other end is connected to the frame of the air suspension seat. The safety belt is also connected to the frame of the seat. I regret the delay in our response and hope the following discussion answers your questions.; You first asked about which portion of the system is considered th safety belt anchorage for the purpose of Standard No. 210. S3 of the standard defines the term 'seat belt anchorage' as 'the provision for transferring seat belt assembly loads to the vehicle structure.' Since, according to the diagram enclosed with your letter, the safety belt is directly attached to the seat, we would consider the attachment point on the seat to be the anchorage. It is that attachment point that transfers the seat belt load to the vehicle structure. Although not specifically discussed in your letter, we believe that the primary purpose of the tether belt is to hold the seat in position during a crash rather than to transfer the safety belt loads to the vehicle structure.; You next asked whether S4.2(c) of Standard No. 207, *Seating Systems* would apply to the seat since the safety belt is secured to the seat. The answer is yes, S4.2(c) would apply. S4.2(c) sets requirements for any seat in which 'a seat belt assembly is attached to the seat.'; In your third question, you asked whether the seat would have to b tested to the requirements of Standard No. 210 if it meets the requirements of S4.2(c) of Standard No. 207. The seat must meet the requirement of S4.2(c) of Standard No. 207 and the seat belt anchorages must separately meet the requirements of Standard No. 210. As a manufacturer, your responsibility is to certify that the seat and safety belt anchorages will meet each of those requirements. You may not have to conduct two separate tests if you can demonstrate compliance to both sets of requirements when the seat and seat belt anchorage are tested in accordance with S4.2(c) of Standard No. 207.; In your fourth question, you asked whether the struts specified i S5.1.1 of Standard No. 207 can be used in testing the system. S5.1.1 provides that if 'the seat back and the seat bench are attached to the vehicle by the same attachments,' a strut can be secured on each side of the side for the purposes of securing a rigid crossmember used in loading the seat. In the case of your seat, the seat back and the seat bench are attached to the vehicle by the same attachments and thus use of the struts is permitted.; You then asked how the center of gravity of the seat is to b determined for the purpose of the test. You asked whether you are to determine the center of gravity of the entire system, including the seat stand with the air suspension and slide mechanism. In a July 14, 1983 letter to Mack Trucks, Inc., NHTSA addressed the issue of how to apply the loading required by Standard No. 207 to a heavy-duty truck seat which, as with yours, includes a suspension system and is mounted on a pedestal-like structure.; In its letter, Mack explained that it tests its seat in a two ste process. First, the seat supplier for Mack mounts the seat cushion and the seat back on a rigid structure and tests the seat to the performance requirements of Standard No. 207 by applying 20 times the weight of the seat cushion and seat frame to the seat. Then, Mack conducts a separate test of the seat cushion and seat back with those components mounted on the pedestal used in its trucks. In that test, Mack subjects those components to 20 times the weight of the seat back, seat cushion and pedestal applied at the center of gravity of the entire seat system (seat back, seat cushion, and pedestal).; In responding to Mack, NHTSA said that a manufacturer can separatel test the seat in the manner followed by Mack. Thus, a manufacturer can conduct one test of the upper section of the seat by applying 20 times the weight of those components to the upper section and then separately test the seat, as anchored to the vehicle floor, by applying 20 times the weight of the entire seat, including the pedestal, at the center of gravity of the entire seat.; In your sixth and final question, you asked whether the tether bel would have to meet the seat belt assembly requirements of Standard No. 209. S3 of Standard No. 209 defines, in part, a seat belt assembly as 'any strap, webbing, or similar device designed to secure a person in a motor vehicle to mitigate the results of any accident. . . .' Since your tether belt is not designed to restrain an occupant, it would not be required to meet the requirements of Standard No. 209.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2952OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your August 15, 1978, petition asking for changes i Standard No. 222, *School Bus Passenger Seating and Crash Protection*, as that standard applies to the measurement of contact area. In particular, you ask the National Highway Traffic Safety Administration (NHTSA) to amend the standard adopting a specific test medium for measuring contact area and deleting the existing list of acceptable contact area test mediums currently established in the agency's compliance test procedures.; On July 19, 1978, the NHTSA responded to an earlier petition (Decembe 20, 1977) submitted by you on this same issue. In that letter, the NHTSA denied your requested amendment of the standard. Your current petition presents no additional data or arguments supporting your suggested modification that were not presented and thoroughly considered in our determination of your first petition. Accordingly, for the reasons specified in our July 19, 1978, letter to you, the agency denies your suggested rulemaking.; In your August 15 petition, you suggested that Standard No. 222 shoul incorporate more detailed test procedures, because some of the agency's other safety standards specify test procedures in greater detail. Standard No. 222 currently specifies test procedures to be used by manufacturers in complying with the standard. However, like all of the agency's standards, Standard No. 222's compliance test procedures are even more detailed than the requirements specified in the standard.; The NHTSA writes safety standards as simply as possible while providin the necessary detail for manufacturers to comply with their requirements. A manufacturer is then permitted to develop its own test procedures as long as its procedures are compatible with the requirement of the standard. The NHTSA, itself, devises tests that it uses for testing a vehicle's compliance. Whenever possible, these tests are available to manufacturers, and manufacturers are free to adopt them or to proceed with their own test procedures. Your twice- submitted petition would have the NHTSA rewrite its standards in a manner that would specify test procedures in greater detail. Such an approach would increase the complexity of safety standards if done uniformly to all standards and would in fact be detrimental to small manufacturers. The purpose of allowing some variation in details of test procedures is to permit a manufacturer to develop test procedures that are tailored to that manufacturer's needs and constraints. For example, certain test procedures used by the NHTSA may be too costly for a small manufacturer. Under the current compliance system, any manufacturer can develop a less expensive alternative test methodology. Under the system that you propose, however, a manufacturer would be required to adopt the test procedures specified in the standard. Since your suggestion, if applied to all safety standards, could add costs to the agency's regulations without achieving any significant benefits, the NHTSA determines that your suggested amendment is not in the public interest.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1387OpenMrs. L. M. Thompson, 9624 4th St., N. E., Everett, WA 98205; Mrs. L. M. Thompson 9624 4th St. N. E. Everett WA 98205; Dear Mrs. Thompson: I would like to thank you for your interest in the safety benefits o the interlock system and for forwarding the Seattle newspaper advertisement which offers a method to bypass the seat belt interlock.; The interlock standard only requires that new vehicles be equipped wit required safety equipment. Therefore a purchaser may have the system modified to accommodate circumstances, such as physical incapacity, which makes use of the belts unwise or inconvenient.; The advertisement of a system to circumvent the standard, however, is different matter, and whether it is legally permitted is a conclusion which the courts will have to determine. This agency is reviewing the legal remedies available which might permit removal of such a product from the market. Having promulgated the interlock option as part of the occupant crash protection standard, whose validity was sustained in court, we are committed to taking all possible actions to insure its effectiveness.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2401OpenAlfred Teves GMBH, 6 Frankfurt/Main 2, Postfach 119155, West Germany; Alfred Teves GMBH 6 Frankfurt/Main 2 Postfach 119155 West Germany; Dear Sirs: #This responds to the Alfred Teves GMBH (Teves) petition o April 9, 1976, for amendment of S5.2.1 of Standard No. 106-74, *Brake Hoses*, to eliminate the striping requirement in the case of hose used in assemblies that have 'keyed' end fittings at both ends. We interpret 'keyed' fittings to mean those that can be installed in only one (or possibly several) orientation(s) to the vehicle. #This is to advise you that the National Highway Traffic Safety Administration has determined to grant Teves' petition with regard to hose that is assembled into an assembly whose fittings permit their installation into the vehicle with only one orientation. Detailed reasons for the limitations expressed in this letter will accompany any notice that proposed this change. #You should understand that our commencement of a rulemaking proceeding does not signify that the rule is made on the basis of all available information in accordance with statutory criteria. #Your letter incorrectly characterized the amendment of S5.2.2 that was proposed in Notice 19 of docket 1-5 (40 Fr 55365, November 28, 1975) and made final in Notice 21 (41 FR 28505, July 12, 1976). The amendment only stated that the labeling required on hose need not be present after the hose has become part of a brake hose assembly or after it has been installed in a motor vehicle. The conclusion in the second paragraph of your letter that '...brake hose does not require labelling according to S5.2.2...' is therefore incorrect. #With regard to your comments on Standard No. 116, *Brake Fluids*, I assume that you were referring to the agency's proposed definition of 'brake fluid' published on December 5, 1975 (40 FR 56928). I also assume that the phrase 'polychloroprene (CR) brake hose inner tube stock' in the proposed definition led you to conclude that only polychloroprene inner tube stock would be allowed for brake hose construction. This is incorrect. All of the materials specified in the definition, including SBR, EPR, CR, and NR, are considered suitable for use in brake hoses. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs; |
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ID: aiam2051OpenMr. Albert A. Dawes, Chief, Procurement Law Division, U.S. Army Tank-Automotive Command, Department of the Army, Warren, MI 48090; Mr. Albert A. Dawes Chief Procurement Law Division U.S. Army Tank-Automotive Command Department of the Army Warren MI 48090; Dear Mr. Dawes: This is in response to your letter of August 29, 1975, in which you as whether the exemption provided by 49 CFR S 571.7(c) applies to all commercial vehicles manufactured and sold directly to the Armed Forces of the United States.; All vehicles (including commercial vehicles) meeting the definition o 'motor vehicle' in section 102(3) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1392(3)) that are manufactured for, and sold directly to, the Armed Forces of the United States in conformity to contractual specifications are exempt from the Federal Motor Vehicle Safety Standards under 49 CFR S 571.7(c).; We hope this information is of assistance. Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4886OpenMr. Charles Stansell 5414 Robin Road Garland, TX 75043; Mr. Charles Stansell 5414 Robin Road Garland TX 75043; "Dear Mr. Stansell: This responds to your letter requesting informatio about the labeling requirements in Federal Motor Vehicle Safety Standard No. 218, Motorcycle Helmets (49 CFR 571.218). You posed two questions. First, you asked if it was true that 'the law does not prohibit anyone from removing a DOT sticker?' The DOT sticker to which you refer is the helmet manufacturer's certification that the helmet complies with Standard No. 218. Federal law prohibits any manufacturer, distributor, dealer, or repair business from removing the certification from the helmet. Federal law does not prohibit individual owners from removing the DOT certification from their own motorcycle helmets, but State law may do so. You will need to contact officials in the State of Texas to learn if there is such a prohibition in your State. Second, you asked if it was true that a 'large number' of motorcycle helmets manufactured before October 3, 1988 are not considered in violation of Standard No. 218 even though they do not have the DOT certification sticker. It is true that not all helmets manufactured before October 3, 1988 were subject to Standard No. 218. Those helmets that could not fit on the test headform (typically the small and extra small helmets) were not subject to the standard, and were not labeled with a DOT certification. However, the total population of helmets that were too small to fit on the headform was only approximately 10 percent of all helmets. The remaining 90 percent of helmets manufactured before October 3, 1988 were subject to Standard No. 218 and were required to be certified by means of a DOT sticker. All motorcycles helmets manufactured on or after October 3, 1988 are required to be certified as complying with Standard No. 218. For your information, I have enclosed two of our interpretation letters that provide detailed responses to the issues raised in your letter. These two letters are a December 8, 1988 letter to Mr. Wayne Ivie of the Oregon State Department of Transportation and a December 4, 1987 letter to Mr. Larry Hoppe. I have also enclosed a NHTSA information sheet on motorcycle helmets. I hope this information is helpful. If you have any further questions or need additional information, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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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.