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: aiam0332OpenHugh A. Blackwell, Fleming, Robinson & Bradshaw, Attorneys at Law, 1212 American Building, Charlotte, NC 28202; Hugh A. Blackwell Fleming Robinson & Bradshaw Attorneys at Law 1212 American Building Charlotte NC 28202; Dear Mr. Blackwell: This is in response to your letter of April 14, 1971, concerning th Tire Identification and Record Keeping Regulation. The answers given you by Mr. David Schmeltzer in your telephone conversation are, for the most part, correct. This letter is to confirm those answers where appropriate and reply to the unanswered questions you raised.; The numbered paragraphs correspond to the numbered questions in you letter.; 1. The regulation speaks of a three year retention period for th information required by section 574.7(a) and the same three year period would be considered an appropriate length of time to retain the records required by section 574.7(c).; 2. The regulation specifies that each manufacturer or brand name owne shall record and maintain the records required by the regulation. Therefore, the regulation allows anyone to maintain those records but the legal responsibility may not be shifted. Thus, a brand name owner may have the manufacturer maintain the required records, but he remains legally responsible for their maintenance.; 3. Under the regulation, the distributors and dealers are required t submit the required information to the brand name owner, or the tire manufacturer, whoever has the legal responsibility of maintaining the records or to the manufacturer's designee. In other words, the person responsible for maintaining the records is the person who should receive the records unless he designates someone else to receive them.; 4. The tire manufacturer is required to furnish a means of recordin the required information to distributors and dealers, but not to brand name owners. However, this does not preclude the possibility of an arrangement whereby the tire manufacturer supplies the brand name owner the means for recording the required information.; 5. The records required by Part 574 need not be kept for reclassifie tires. However, Standard No. 109, the passenger car tire standard, sets forth requirements for maintaining records for reclassified tires.; 6. Under the regulation, the brand name owner has no obligation t supply information to the tire manufacturer.; 7. Your understanding that brand name owners are not responsible fo keeping records of reclassified tires under Standard No. 109 is correct.; 8. Tires which are manufactured for off public road use are no considered to be items of motor vehicle equipment under either the Act or the regulation.; 9. The repurchasing obligations for the manufacturer or brand nam owner for tires in the hands of dealers and distributors in the event of a defect notification, are contained in Section 111 of the Act. There are no repurchasing obligations under the Act which relate to the first purchaser for purposes other than resale of the tire involved in the defect notification.; 10. Because the legal responsibility for defect notifications rest with the brand name owner, as well as the tire manufacturer (Section 113(f) of the Act) the requirements of Section 113(d) also apply to the brand name owner. We consider copies of notices received from either the manufacturer or the brand name owner as fulfilling the requirements of Section 113(d). It has been our practice to notify both the manufacturer and brand name owner in the event of a defect described as a result of our investigation.; 11. The brand name owner will be required to give a defect notificatio when he receives information that a defect has been determined whether that information comes from the manufacturer or from the Administrator or from his own knowledge.; 12. The certification regulations are satisfied, in the case of tires by the symbol 'DOT' embossed on the sidewall of the tire. This is the manufacturer's certification that the tire complies with the tire standard.; 13. At this point in time, there are no regulations requirin performance of technical data to be furnished with new or retreaded tires. However, at any time, the National Highway Traffic Safety Administration has the authority to require such information pursuant to Section 112(d) of the Act.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam1489OpenMr. Andy K. Holen, Purchasing Manager, Weyerhaeuser Company, Tacoma, WA 98401; Mr. Andy K. Holen Purchasing Manager Weyerhaeuser Company Tacoma WA 98401; Dear Mr. Holen: This responds to your April 29, 1974, request to be apprised of th Standard No. 121 requirements concerning air brakes on trucks and trailers.; Standard No. 121, like all Federal motor vehicle safety standards, is manufacturer requirement, not a user requirement. While it places obligations on the vehicle manufacturers to construct their vehicles so that they conform to the standard, it does not place any responsibilities on you as a user of air brake-equipped vehicles.; If you would nevertheless like to examine the current requirements they may be obtained from the Government Printing Office as explained in the enclosed brochure, or from commercial or library sources as part of Chapter V of Title 49 of the Code of Federal Regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4371OpenMr. Hisashi Tsujishita, Chief Co-ordinator, Technical Administration Department, Daihatsu Motor Co., Ltd., 1.Daihatsu- cho, Ikeda City, Osaka Prefecture, JAPAN; Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Department Daihatsu Motor Co. Ltd. 1.Daihatsu- cho Ikeda City Osaka Prefecture JAPAN; Dear Ms. Tsujishita: Thank you for your letter requesting an interpretation of th requirements of three of our safety standards. This letter responds to your questions concerning Standard No. 201, *Occupant Protection in Interior Impact*. I have previously responded to your requests for interpretations of the other two standards. I regret the delay in this response.; Your questions concern the requirements of S3.5.1(b) of the standard which provides that 'Along not less than 2 continuous inches of its length, the armrest shall, when measured vertically in side elevation, provide at least 2 inches of coverage within the pelvic impact area.' You expressed concern about determining whether several different armrest designs comply with that requirement. Specifically, you provided three examples and asked how the requirement would apply to each example. Your example I11.1 is an armrest that, when viewed in side elevation (i.e., a view in which a person is looking from in front or behind an armrest to determine how the armrest projects from the door surface) has a flat surface. Example I11.2 is an armrest that has a slightly curved surface. Example I11.3 is an armrest with a surface that is steeply angled inward toward the door. Because of the angling of the armrest, it has a sharp projection at its top.; You believe that examples I11.1 and I11.2 comply with the requiremen of S3.5.1(c). You also believe that example I11.3 would not comply because of its sharp projection. However, you expressed concern about what criteria should be used to distinguish example I11.2 from example I11.3.; S3.5.1(c) of Standard No. 201 does not set any radius of curvatur requirements for armrest surfaces. Thus, a manufacturer is not required to provide an armrest with a flat surface. The only requirement is that the armrest provides at least two inches of coverage within the pelvic impact area. The purpose of the requirement is to reduce potential injuries to an occupant by ensuring that the armrest has a minimum surface area that will spread the force resulting from an occupant impacting the armrest in a crash. Thus, for this requirement to have a meaningful effect, an armrest should be designed to ensure that there is at least two inches of contact between the surface of the armrest and the pelvic impact area of an occupant. If your examples I11.1 and I11.2 provide two inches of coverage within the pelvic impact area, they would appear to comply, since they present an essentially flat surface. Based on your drawing, it appears that the steep inwardly sloping angle of the armrest shown in example I11.3 may not contact a minimum of two inches of the pelvic impact area. One method of determining the degree of occupant contact would be to measure the amount of contact between a test dummy and the armrest in a static push test or in a dynamic side impact test. We share your concern that an armrest not have sharp projections which could concentrate potentially harmful forces on an occupant striking the armrest.; Finally, you provide a drawing of an additional armrest. Briefl described, the armrest has a slightly curved surface with a decreasing radius within the pelvic impact area. At the top of the portion of the armrest within the pelvic impact area there is a small indentation. The agency has previously said, in an interpretation letter of July 1, 1893 to MMC Services, Inc., that bezels and other indentations are not precluded by the standard. However, the area of the indentation will not be measured in determining whether the armrest provides two inches of coverage if the indentation is so deep that it cannot be contacted. Based on your drawing, the indentations shown in your proposed armrest is shallow and would be contactable by an occupant. Thus, the surface area of the indentation would be counted in determining whether the vehicle complied.; Finally, I would point out that S3.5.1(c) is one of three optiona means of compliance that manufacturers may choose. A manufacturer may also meet the requirements of Standard No. 201 by complying with either S3.5.1(a) or S3.5.1(b), in which case it is not necessary to provide two inches of coverage with the pelvic impact area.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1173OpenMr. Dennis E. David, Legislative Coordinator, Kawasaki Motors Corporation, 1062 McGaw Avenue, Post Office Box 11447, Santa Ana, California 92711; Mr. Dennis E. David Legislative Coordinator Kawasaki Motors Corporation 1062 McGaw Avenue Post Office Box 11447 Santa Ana California 92711; Dear Mr. David: In your letter of June 21, 1973, to Mr. Schneider, you ask whethe Standard No. 123 precludes use of a device that, when activated, does not allow and automatic return of the throttle to idle.; "As you have observed, Standard No. 123 specifies that if a twist-gri throttle is provided, its manner j of operation shall be 'self-closing to idle ... after release of hand.' This requirements is without qualification and means that at any time the operator's hand is removed from the throttle, the throttle shall automatically return to idle. Therefore, a motorcycle equipped with the device you describe would not comply with Standard No. 123."; Yours truly, Assistant Chief Counsel |
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ID: aiam4721OpenHis Excellency D. H. Burney Ambassador of Canada 501 Pennsylvania Ave., N.W. Washington, D.C. 20001; His Excellency D. H. Burney Ambassador of Canada 501 Pennsylvania Ave. N.W. Washington D.C. 20001; "Dear Mr. Ambassador: Thank you for your letter of March 16, 1990 expressing the concern of your country about this agency's new regulations on importation of motor vehicles and equipment. Canada is concerned that, under P.L. l00-562, the Imported Vehicle Safety Compliance Act of l988, Canadian vehicle brokers, dealers, and private citizens will not, for all practical purposes, be able to export new or used Canadian market vehicles to the United States. It is concerned further that Canadian individuals and firms will be precluded from providing conformance goods and services for vehicles exported to the United States. Canada therefore requests that this agency modify its regulations with respect to Canadian market vehicles, recognizing their near-compliance with the Federal Motor Vehicle Safety Standards, and accommodating their entry in the least costly and burdensome manner. You have five specific requests, and I shall address each. Preliminarily, I want to note several things. First, my assurance that this agency gave very careful consideration to the concerns of Transport Canada in adopting final regulations under the 1988 Act, as well as those expressed by Canadian companies that commented on the proposed regulations. As we noted in the notices proposing and adopting those regulations, our discretion to make changes in the regulations was narrowly circumscribed in many instances by the detailed language of that Act. On a more technical level, I want to note that your understanding of our new regulations expressed in paragraphs (a) through (g) on page 2 of your letter is essentially correct. However, with respect to your paragraph (d), please note that determinations of vehicle eligibility for importation may also be made by me as Administrator on my own initiative, and need not be pursuant to a petition. Also, as to paragraph (e), I would like to point out that the bond processing fee, proposed to be $125, is only $4.35 (however, under paragraph (f) the bond is not less than l50% of the dutiable value of the vehicle). Your first request is that the agency 'recognize Canadian market vehicles as a special class of non-complying vehicles requiring only minor changes to meet the FMVSS.' The l988 Act was enacted on October 31, l988, and became effective January 31, l990. I regret to say that none of its provisions authorize the agency to directly distinguish between non-complying vehicles of Canadian manufacture and those originating in other countries. However, the eligibility provisions that you reference in paragraph (d) do permit a basis for minimizing some of the burden that the l988 Act imposes. We begin with the premise that if a Canadian vehicle has not been certified by its manufacturer as in conformance with U.S. standards, then it cannot be presumed to conform in all respects to the U.S. standards. Canadian and U.S. safety standards do differ in some ways (e.g., mandatory automatic crash protection for U.S. market passenger cars manufactured on and after September 1, l989). Nevertheless, we believe that enough similarity may exist to support a finding that a Canadian passenger car is 'substantially similar' to a U.S. passenger car, justifying a determination that it is eligible for importation into the United States, and capable of conversion to meet U.S. safety standards. Further, such a finding may be made on our own initiative. I am pleased to inform you that NHTSA is publishing a notice of tentative determination that would cover all passenger cars certified as meeting the Canadian Motor Vehicle Safety Standards, and that were manufactured up to September 1, l989. A copy of the notice is enclosed for your reference. After receiving and considering public comment, we will make a final decision on this matter. If we decide to adopt our tentative determination as a final determination, your first request would, in effect, be granted. Your second request is that we 'exempt such vehicles from the fees.' These fees are the ones mentioned in paragraphs (c), (d), and (e) of your letter, the registered importer annual registration fee, the vehicle eligibility petition fee, and the bond processing fee. Each fee is specifically required by the l988 Act, and must be established in advance of the fiscal year in which it is effective. The registered importer fee is required to cover agency costs for administration of the registration program. The vehicle eligibility fee is required to cover the agency's costs in making and publishing eligibility determinations. The bond processing fee is required to reimburse the U.S. Customs Service for its costs in processing the agency's conformance bond that accompanies each nonconforming vehicle. Congress provided no authority to waive these fees, or to modify them during the fiscal year that they are in effect. Thus, the fees that have been established must remain in effect until October 1, l990. When we begin the review that will lead to next year's fees, we shall be happy to consider whether some provision may be made for Canadian market vehicles. In the meantime, I would like to point out that under our notice of tentative determination on eligibility of Canadian vehicles, the fee of $l,560 would cover the blanket determination of all passenger cars, and would not be applied to each individual model and model year of passenger car. This action would effectively moot Canada's second request that Canadian market passenger cars be exempted from the determination fee. Canada's third request is to 'exempt them from the bonding requirement.' The l988 Act requires the importer of a non-conforming vehicle to furnish an appropriate bond to ensure that the vehicle will be brought into compliance, or will be exported or abandoned to the United States. This is not a new requirement, ever since January 1, l968, each nonconforming vehicle, Canadian or otherwise, has been required to be accompanied by a conformance bond upon its entry into the United States. The l988 Act provides us with no authority to exempt Canadian vehicles, and does not distinguish degrees of nonconformity. Therefore, we believe that we are unable to grant Canada's request, absent specific authorization by the U.S. Congress. The fourth request is to 'exempt them from the requirement that they be imported by registered importers, who must be U.S. citizens.' This request raises two issues: whether Canadian market cars may be imported by persons other than registered importers, and whether registered importers must be U.S. citizens. As to the first issue, the l988 Act does allow one alternative to direct importation by a registered importer. That is, a person other than a registered importer may import a nonconforming vehicle if he has a contract with a registered importer to perform conformance work. This would allow a Canadian citizen to import a Canadian market car, without himself becoming a registered importer. The second issue is whether a Canadian company is permitted to be a registered importer. We believe that a registered importer is a person who is physically present in the territory in which importation occurs, as opposed to an exporter, who is outside that territory. While we are not conversant with the laws of the individual States, we believe that a Canadian company could qualify to do business within an individual State, and become a registered importer. Thus, it is not necessary to be a U.S. 'citizen', but it is necessary to be subject to U.S. jurisdiction. The l988 Act requires the registered importer regulation to contain requirements for recordkeeping, and inspection of records and facilities. Since the jurisdiction of the National Traffic and Motor Vehicle Safety Act does not extend beyond the boundaries of the United States, we believe that it would be difficult to enforce our provisions on inspection of premises, documents, etc. in the territory of another country. This brings us to your fifth and final request, that we 'allow modifications to be done in either the United States or Canada.' Under current regulations, conformance work is permitted to be performed outside the United States. However, vehicles modified in this fashion must be admitted under the same procedures as if they had not been modified. This allows the agency to review the documents on pre-importation conversion work, to ensure that it has been satisfactorily accomplished, before the conformance bond is released. Accordingly, we believe that the concern underlying this request has already been accommodated. If, after reviewing this letter, you have further suggestions for reducing the burdens that the new law may have imposed on importations of Canadian-manufactured vehicles, I would be happy to consider them. Sincerely, Jerry Ralph Curry Enclosure"; |
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ID: aiam1523OpenMr. Charles R. Taylor, Taylor Farm Service, 'The Farm Center', Tremonton, UT 84337; Mr. Charles R. Taylor Taylor Farm Service 'The Farm Center' Tremonton UT 84337; Dear Mr. Taylor: This responds to your May 15, 1974, question whether Standard No. 121 *Air brake systems*, mandates the use of air brakes on 1-ton and larger trucks.; Standard No. 121 only applies to vehicles equipped with air brak systems. This means that the manufacturer is free to equip his products with whatever brake system he choses, (sic) but that if he choses (sic) an air brake system, it must comply with the Federal safety standard.; Yours truly, Richard B. dyson, Assistant Chief Counsel |
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ID: aiam5219OpenRon D. Belk, President Kustom Fit 8990 Atlantic Box 3004 South Gate, CA 90280; Ron D. Belk President Kustom Fit 8990 Atlantic Box 3004 South Gate CA 90280; "Dear Mr. Belk: This responds to your letter of May 17, 1993, which i a follow-up to our May 6, 1993, letter in which we explained the self-certification process, 'render inoperative,' and 'due care.' You include information from tests you have done to determine whether seats you manufacture can be installed in vehicles that must comply with requirements for dynamically tested manual belts in Standard No. 208, Occupant Crash Protection (49 CFR 571.208), which specifies performance requirements for the protection of vehicle occupants in crashes. You have experienced difficulties because of variability in belt pay-out ranging from 2.25 inches to 4.9 inches and asked whether Standard No. 209, Seat Belt Assemblies (49 CFR 571.209) allows this much variability. It is unclear from the information you provided what is causing the belt pay-out you are experiencing. I note that S4.3(i) of Standard No. 209 limits the amount of webbing which can extend from an automatic-locking retractor prior to the retractor locking. A similar requirement for webbing-sensitive emergency- locking retractors is included in S4.3(j). Section 4.6 of Standard No. 209 excepts dynamically tested manual belts from the requirements of S4.2(a)-(f) and S4.4 of Standard No. 209, however, these belts must still comply with S4.3. The test for compliance with sections S4.3(i) and S4.3(j) are different from the tests you have been performing. Therefore, your tests would not indicate whether the seat belt assembly complies with these requirements of Standard No. 209. You also asked for further advice on how to reassure your customers that vehicles will comply with Standard No. 208 with your seat installed. It is possible that you may not be able to do this. As explained in our previous letter, Standard No. 208 is applicable to vehicles and not to individual items of equipment (except for pressure devices and explosive devices used in air bags). Therefore, you, as the seat manufacturer, would have no certification responsibilities under Standard No. 208. The vehicle manufacturer is required to certify compliance with Standard No. 208. This is because compliance with Standard No. 208 is dependent on a variety of factors, including the seat, the seat belts, and the vehicle interior. Because you manufacture only the seat, you cannot control the other factors, and, therefore, probably cannot provide your clients with all the information they need in order to certify their vehicles compliance with Standard No. 208. However, you should be able to provide them with information on your seats that they can use to help determine if their vehicles comply with Standard No. 208. Finally, you asked whether NHTSA would impose liability on you or the seat belt manufacturer if we discovered an apparent non-compliance with Standard No. 208. Because Standard No. 208 applies to the vehicle, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) imposes liability for non- compliance on the vehicle manufacturer, not the seat or seat belt manufacturer. However, state law may allow the vehicle manufacturer to recover damages from the manufacturer of either the seat or the seat belt. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2026OpenMr. Russ Jura, Legislative Analyst, Engineering Division, Yamaha International Corporation, P. O. Box 6600, Buena Park, CA 90622; Mr. Russ Jura Legislative Analyst Engineering Division Yamaha International Corporation P. O. Box 6600 Buena Park CA 90622; Dear Mr. Jura: This is in reply to your letter of August 5, 1975, asking whether prototype 'stiff rubber supported turn signal' would comply with S4.3.1 of Motor Vehicle Safety Standard No. 108.; S4.3.1 requires lighting equipment to 'be securely mounted on a rigi part of the vehicle.' Your proposed turn signal lamp is mounted at the end of a stiff rubber bracket which is attached to the vehicle. The bracket must be considered part of the vehicle. Obviously, even with a metal mounting there will be some vibration transmitted from the motorcycle to the lamp when the engine is running. We would consider the prototype mounting to be sufficiently 'rigid' to conform to the standard if the rubber mount is stiff enough so that there is little or no amplification of vibration when the engine is running.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5649OpenMr. Patrick Holmes 22235 Frontier Road Clovis, CA 93611; Mr. Patrick Holmes 22235 Frontier Road Clovis CA 93611; "Dear Mr. Holmes: This responds to your request for an interpretatio whether, if you manufacture a motorcycle helmet for personal use, and ensure that your helmet meets Federal Motor Vehicle Safety Standard (FMVSS) No. 218 Motorcycle helmets, you may certify the helmet. Subject to qualifications explained below, the answer is yes. NHTSA is authorized under 49 U.S.C. Chapter 301 Motor Vehicle Safety to issue FMVSSs for new motor vehicles and new items of motor vehicle equipment. Among the FMVSSs is Standard No. 218. In 49 U.S.C. section 30115, a self- certification system is established whereby the vehicle or equipment manufacturer is responsible for exercising 'reasonable care' in certifying the product will, if tested as specified in the applicable FMVSSs, meet the safety requirements in the standards applicable to the product. Section 30115 states: 'A person may not issue the certificate if, in exercising reasonable care, the person has reason to know the certificate is false or misleading in a material respect.' I have enclosed an information sheet that briefly describes the responsibilities for manufacturers of new vehicles and new items of motor vehicle equipment. Please note the discussion on page two concerning manufacturers' responsibilities to ensure that their products are free of safety-related defects. In addition, as noted on page two, Part 566 of our regulations requires each manufacturer of motor vehicle equipment to which an FMVSS applies (e.g., motorcycle helmets) to submit identifying information to NHTSA, with a description of the items they produce. I have enclosed a copy of Part 566 and of Standard No. 218 for your information. I hope this information is helpful. Please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, Samuel J. Dubbin Chief Counsel Enclosures"; |
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ID: aiam2476OpenMr. W. Bailey Watson, P. O. Box 4307, North Charleston, SC 29405; Mr. W. Bailey Watson P. O. Box 4307 North Charleston SC 29405; Dear Mr. Watson: Your letter of August 16, 1976, asking whether the 1972 Pontia Bonneville was equipped with a safety bumper has been forwarded to this office by the Federal Trade Commission for reply.; The National Highway Traffic Safety Administration (NHTSA), which i responsible for developing motor vehicle safety standards, promulgated Standard No. 215, *Exterior Protection*, to protect certain safety components when a vehicle is involved in low-speed front and rear collisions. The standard, in its initial form, became effective on September 1, 1972, and provided that passenger cars be capable of sustaining 5 mph front and 2 1/2 mph rear barrier impacts with no damage resulting to lighting, cooling, fuel, or exhaust systems, or to doors and other closures. In order to comply with the required performance level, manufacturers had to strengthen their vehicle bumper systems.; The standard only affects cars manufactured after September 1, 1972 and the start of the 1973 model year. It is therefore unlikely that any 1972 model vehicles would have been produced under its authority. Before September 1, 1972, the Federal government imposed no safety requirements affecting motor vehicle bumpers. Thus, vehicle manufacturers were free to equip their automobiles with any type of bumpers they chose. The NHTSA cannot comment on the safety qualities of the 1972 Pontiac Bonneville bumper since it was not at that time involved in regulating that aspect of vehicle performance.; 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.