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: aiam2035OpenMr. Jerry W. McNeil, Director of Engineering, American Trailers, Inc., 1500 Exchange Avenue, Box 26568, Oklahoma City, Oklahoma 73126; Mr. Jerry W. McNeil Director of Engineering American Trailers Inc. 1500 Exchange Avenue Box 26568 Oklahoma City Oklahoma 73126; Dear Mr. McNeil: #This responds to your letter of August 12, 1975 concerning the application of Federal Motor Vehicle Safety Standard No 106-74, *Brake Hoses*, to an anchor coupling. #You enclosed a diagram depicting the installation of two of these couplings, and suggested that they are not subject to the labeling requirements of the standard. This interpretation is correct. 'Brake hose end fitting' is defined in Standard No. 106-74 as: #>>>a coupler, other than a clamp, designed for attachment to the end of a brake hose.<<< #The anchor couplings which you have described are attached to the ends of completed brake hose assemblies, rather than to the ends of brake hoses. Therefore, they are not 'brake hose end fittings' subject to the standard's requirements. #It appears from your letter that you might not consider the nylon tubing to be 'brake hose'. If the nylon tubing is flexible, However, such an interpretation would be incorrect. 'Brake hose' is defined in the standard as: #>>>a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.<<<# Thus flexible chassis plumbing and other flexible conduits, in addition to rubber brake hoses, are subject to the standard's requirements. #Sincerely Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam0767OpenMr. George J. Natinsky, Normark Corporation, 4839 Memphis Street, Dallas, Texas 75206; Mr. George J. Natinsky Normark Corporation 4839 Memphis Street Dallas Texas 75206; Dear Mr. Natinsky: This is in response to your letter of June 26, 1972, to the Office o the regional administrator, National Highway Traffic Safety Administration, concerning the Bond Bug.; For purposes of Federal motor vehicle safety standards, the Bond bug i classified as a 'motorcycle' since it is a 'motor vehicle...designed to travel on not more than three wheels in contact with the ground'. The only Federal standard currently applicable to it is Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*. Standard No. 123, *Motorcycle Brake Systems* will apply to motorcycles manufactured on or after January 1, 1974. I enclose a copy of each for your information. The new standard on motorcycle controls and displays, No. 123, does not apply to a motorcycle equipped with a steering wheel.; If you are interested in importing this vehicle on a commercial basis suggest that you write us directly for information on obligations of the manufacturer and importer concerning consumer information and safety-related defect notification.; Yours truly, Richard B. Dyson. Assistant Chief Counsel |
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ID: aiam3848OpenPaul Escobosa, Esq., Dinkelspiel, Donovan & Reder, One Embarcadero Center - 27th Floor, San Francisco, CA 94111; Paul Escobosa Esq. Dinkelspiel Donovan & Reder One Embarcadero Center - 27th Floor San Francisco CA 94111; Dear Mr. Escobosa: In reply to your letter of May 22, 1984, to Mr. Vinson of my office this is to advise you that you will find the truck air brake standard at 49 CFR 571.121, Motor Vehicle Safety Standard No. 121, *Air Brake Systems*.; As Mr. Vinson informed you, the 'Autostop' braking device about whic you inquired is not directly regulated by a Federal motor vehicle equipment or vehicle standard. However, its installation on a truck conforming to Standard No. 121 must not render the air brake system inoperative in whole or in part, pursuant to 15 U.S.C. 1397(a)(2)(A). If installation occurs before the truck is delivered to its first purchaser for purposes other than resale, the installer is required to attach a label to the truck in accordance with 49 CFR 567.7 that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards.; In any event, as an item of motor vehicle equipment, the 'Autostop' i subject to the notification and remedy provisions of 15 U.S.C. 1411 *et seq*. in the event that either its manufacturer or this agency determines that it contains or creates a safety-related defect.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1875OpenMr. Jeffrey A. Burt, Arnold and Porter, 1229 Nineteenth Street, NW., Washington, DC 20036; Mr. Jeffrey A. Burt Arnold and Porter 1229 Nineteenth Street NW. Washington DC 20036; Dear Mr. Burt: This is in response to your letter of April 22 regarding a propose defect notification letter by the Whittaker Corporation.; In our opinion, the proposed letter does not comply with the defec notification regulation (49 CFR, Part 577) and section 153 of the 1974 Amendments to the National Traffic and Motor Vehicle Safety Act. The specific areas of nonconformance are:; >>>1. The second sentence must be stated in the form and order a required by section 577.4(b), that is, you must add 'defect--which relates to motor vehicle safety--exists.'; 2. The first sentence in the fourth paragraph referring to the fac that no accidents have been reported could be construed as a disclaimer, and is therefore prohibited by section 577.6.; 3. Since owners may inspect these wheels themselves in lieu of having dealer perform the inspection, it is necessary to provide the owner with a return post card so the owner can certify that the wheels were inspected and do not contain a defect or were exchanged for new wheels.; 4. It is necessary to inform the owner that in the event th manufacturer, dealer or distributor is unable or fails to remedy the defect without charge, the owner may notify the Administrator, National Highway Traffic Safety Administration, Washington, D. C. 20590. This is required by section 153(a)(6) of the 1974 amendment.; If you have any questions regarding this matter, please contact Mr James Murray of my staff at 426-2840.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam5565OpenThe Honorable Ken Calvert Member, United States House of Representatives 3400 Central Avenue, Suite 200 Riverside, CA 92506; The Honorable Ken Calvert Member United States House of Representatives 3400 Central Avenue Suite 200 Riverside CA 92506; "Dear Mr. Calvert: Thank you for your letter on behalf of you constituent, Mr. Alexander H. Patnode of Lake Elsinore, concerning an engine stand your constituent purchased from Pep Boys. Mr. Patnode asked for assistance after the engine stand caused the engine to fall, injuring his ankle. As explained below, the National Highway Traffic Safety Administration (NHTSA) considers the engine stand to be 'motor vehicle equipment,' subject to our regulation. NHTSA has authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. 49 U.S.C. section 30102(a)(7) defines 'motor vehicle equipment' in relevant part as: (A) any system, part, or component of a motor vehicle as originally manufactured, (B) any similar part or component manufactured or sold for replacement or improvement of a system, part or component, or as an accessory, or addition to a motor vehicle... (emphasis added) Although an engine stand is not a system, part, or component of a motor vehicle, it would be considered an 'accessory' to a motor vehicle. NHTSA has typically used two criteria in determining whether a product is an 'accessory.' The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. Expected use is determined by considering product advertising, product labeling, the type of store that sells the equipment, and information about how the product is used. The second criterion is whether the product is intended to be purchased or otherwise acquired, and principally used by, ordinary users of motor vehicles. If a product satisfies both criteria, it is deemed an 'accessory.' We have determined the engine stand is an accessory, and thus an item of motor vehicle equipment. Applying the two criteria to the engine stand, (1) the engine stand is intended to be used in the maintenance of motor vehicle engines, and (2) assuming the stand was new when sold to Mr. Patnode, it was intended to be acquired and used by ordinary users of motor vehicles. We have searched our files by computer for reported complaints about engine stands, and for manufacturers' service bulletins and recalls. The search was conducted according to manufacturer (Rally) and equipment type (motor vehicle equipment: jacks, and other). A summary of the search results is enclosed. We found no reported instance of an injury caused by an engine stand, or of a manufacturer's issuing a service bulletin or recall because of an engine stand problem. We will keep a copy of Mr. Patnode's letter in our files on reported complaints. In the future, the letter may be helpful in establishing a pattern of safety-related concerns caused by the type of engine stand that resulted in Mr. Patnode's injury. I hope this information is helpful. If there are any questions, please let me know. Sincerely, John Womack Acting Chief Counsel Enclosure cc: Harleigh Ewell, Esq. Office of the General Counsel Regulatory Affairs Division U.S. Consumer Product Safety Commission Washington, D.C. 20207-0001"; |
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ID: aiam0337OpenMr. Herbert A. Strum, P.E., 830 Tostenabe Lane, North Muskegon, MI 49445; Mr. Herbert A. Strum P.E. 830 Tostenabe Lane North Muskegon MI 49445; Dear Mr. Strum: In your letter of April 20, 1971, to Robert L. Carter you ask fo copies of regulations governing 'the construction, equipping, and operation of private motor coaches.' It is our understanding that you wish to construct a vehicle for your own use upon a standard Dodge M-300 motor coach chassis.; A motor coach is categorized as a 'multipurpose passenger vehicle under the Federal motor vehicle safety standards. I enclose copies of the following safety standards which would apply to the motor coach body that you wish to construct, and with which you, as a 'manufacturer' of a motor vehicle, must ensure compliance.; >>>102 - Transmission Shift Lever, etc. (Note S3.2) 103 - Windshield Defrosting and Defogging Systems 104 - Windshield Wiping and Washing Systems 107 - Reflecting Surfaces 108 - Lamps, Reflective Devices, and Associate (sic) Equipment 111 - Rearview Mirrors 205 - Glazing Materials 206 - Door Locks and Door Retention Components 208 - Seat Belt Installation (effective July 1, 1971) 209 - Seat Belt Assemblies (effective September 1, 1971, th requirements in effect until then apply only to equipment manufacturers)<<<; This agency has no regulations governing the 'operation' of a privat motor home, however, Michigan may have special provisions as a prerequisite to the registration of a motor home.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5135OpenJames E. Schlesinger, Esquire Schlesinger, Arkwright & Garvey 3000 South Eads Street Arlington, VA 22202; James E. Schlesinger Esquire Schlesinger Arkwright & Garvey 3000 South Eads Street Arlington VA 22202; "Dear Mr. Schlesinger: This responds to your letter addressed to Walte Myers of this office, requesting an opinion concerning the Uniform Tire Quality Grading Standards (UTQGS). You stated in your letter that two tire manufacturers, A and B, both with production facilities in both Canada and the United States, produced tires for a brand name owner, Company C, in Canada. A, B, and C agreed that in the event of overproduction or if some of the tires were 'blems' (Company C refuses to accept blems, which are tires with minor cosmetic blemishes but structurally sound), A and B were free to market their tires elsewhere, including the United States. The tires manufactured for Company C contain the DOT number and the Canadian National Tire Safety Mark, but not the UTQGS information, which is not required in Canada. You stated that over a period of 1 1/2 years, A imported 10,622 tires into the United States while B imported 12,856 tires, including 4,644 blems, into the country. All were passenger tires and all sales occurred in 1990 and 1991. You then posed three questions based on those facts, which I will answer below in the order presented. First, by way of background information, under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381) et seq., as amended (hereinafter Act), the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards applicable to all new motor vehicles and items of new motor vehicle equipment, which includes tires. Section 203 of the Act (15 U.S.C. 1423) directs the Secretary to prescribe, through standards established under Title I of the Act, a uniform quality grading system for motor vehicle tires. NHTSA issued the UTQGS under the authority of 203 and 112(d) (15 U.S.C. 1401(d)), which authorizes the Secretary to require manufacturers to provide performance and technical data to the first purchasers of motor vehicle equipment for purposes other than resale. The UTQGS may be found at 49 CFR 575.104. The penalties for violation of the UTQGS are set forth in the Act. Section 108(a)(1)(E) of the Act (15 U.S.C. 1397(a)(1)(E)) prohibits any failure to comply with any rule, regulation, or order issued under 112. Sanctions for violation of 108 are set forth in 109 of the Act (15 U.S.C. 1398(a)), which provides civil penalties of up to $1,000 for each violation of 108, up to a total maximum civil penalty of $800,000 for 'any related series of violations.' In addition, 110(a) of the Act (15 U.S.C. 1399(a)) gives U.S. district courts the jurisdiction to restrain any violation of Title I of the Act, or any rule, regulation, or order issued thereunder, which include the UTQGS. With that background in mind, I turn now to your specific questions: 1. Is it unlawful to import, sell or distribute in the United States tires which do not have the UTQG information on the sidewall of the tire and/or on the paper tread label for the tire? ANSWER: Subject to the exceptions discussed in the answer to your question No. 3 below, 49 CFR 575.6(b) provides that: At the time a motor vehicle tire is delivered to the first purchaser for a purpose other than resale, the manufacturer of that tire or, . . . the brand name owner, shall provide to that purchaser the information specified in Subpart B of this part that is applicable to that tire. Subpart B includes 575.104 which, at (d)(1)(i)(A), requires that the UTQG information be molded onto or into the tire sidewall. Where a new tire line is introduced into the United States for the first time, however, the tire manufacturer or brand name owner may, for the first six months after the tire's introduction, provide the UTQG information by means of a paper label affixed to the tread surface of the tire. After that six-month grace period, the required information must be molded onto or into the tire sidewall. Although both the Act and the UTQGS are silent as to whether tires can be imported or distributed without the UTQGS information, there would be no point in doing so since the tires cannot legally be sold without that information. 2. If it is unlawful to import, distribute and sell tires in the United States without said UTQG information, what penalties are imposed on the manufacturer and/or brand name owner? ANSWER: As discussed above, civil penalties of up to $1,000 for each violation of 575.6(b) may be imposed, up to a maximum of $800,000. In addition, U.S. district courts have jurisdiction to restrain any such violations. 3. Would any of the exceptions of 49 CFR 575.104(c) apply in this case, and, if so, in what way? Is there any legislative history or interpretation of the meaning of 'limited production tires' as noted in this section, and what effects, if any, this limitation might have on the above fact situation? ANSWER: 49 CFR 575.104(c) provides that the UTQGS apply to new pneumatic passenger car tires. The standards do not apply, however, to deep tread, winter type snow tires, space-saver or temporary use spare tires, tires with nominal rim diameters of 10 to 12 inches, or 'limited production' tires. In order to qualify as a limited production tire, 575.104(c)(2) establishes four criteria, all of which the tires must meet: (i) The manufacturer's annual domestic production or importation into the U.S. of tires of the same size and design as the tire does not exceed 15,000 tires, (ii) The annual domestic purchase or importation by a brand name owner into the U.S. of tires of the same size and design as the tire does not exceed 15,000 tires, (iii) The tire's size was not listed as a vehicle manufacturer's recommended tire size designation for a new motor vehicle produced in or imported into the U.S. in quantities greater than 10,000 during the calendar year preceding the year of the tire's manufacture, and (iv) The total annual production or importation into the U.S. by the manufacturer or, if the tire is marketed under a brand name, the total annual domestic purchase or purchase for importation into the U.S. by the tire's brand name owner, of tires meeting the criteria of (i), (ii), and (iii) above, does not exceed 35,000 tires. Section 575.104(c) also states that 'tire design' is 'the combination of general structural characteristics, materials, and tread pattern, but does include cosmetic, identifying or other minor variations among tires.' The factual scenario you described in your letter would suggest that the tires in question might meet the numbers criteria of (c)(2)(i) and (ii), but there is not sufficient information on which to base an opinion as to whether they meet the other two criteria. There is likewise insufficient information to determine whether the exceptions relating to deep tread, winter-type snow tires, space-saver or temporary use spare tires, or tires with nominal rim diameters of 10 to 12 inches may apply to any or all the tires in question. The manufacturer(s) seeking to import those tires into the U.S. must make those determinations. For your additional information, I am enclosing a copy of 45 FR 23442, dated April 7, 1980, the final rule which initially exempted limited production tires from the UTQGS. That notice explains the rationale for exempting limited production tires and other background information you may find helpful. I hope the above information will be of assistance to you. Should you have any further questions or need additional information regarding this matter, please feel free to contact Walter Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam3337OpenMr. Ray W. Houseal, Osterlund, Inc., 7389 Paxton Street, P.O. Box 4376, Harrisburg, Pennsylvania 17111; Mr. Ray W. Houseal Osterlund Inc. 7389 Paxton Street P.O. Box 4376 Harrisburg Pennsylvania 17111; Dear Mr. Houseal: 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: aiam4558OpenVicky Johnson, Esq. Office of the Chief Counsel Kansas Department of Transportation 7th Floor, Docking State Office Bldg. Topeka, Kansas 66612-1568; Vicky Johnson Esq. Office of the Chief Counsel Kansas Department of Transportation 7th Floor Docking State Office Bldg. Topeka Kansas 66612-1568; "Dear Ms. Johnson: This is a response to your letter asking for m comments on a school transportation issue that has arisen in Kansas. I apologize for the delay in this response. You explained that, in the past, many school districts in your State used vans with more than ten seating positions to transport school children, even though these vehicles were not certified as meeting Federal school bus standards. According to your letter, you informed those school districts that there are 'civil liability risks' associated with transporting students in vehicles that do not meet Federal school bus standards. Further, you said you informed those districts that a manufacturer or dealer who sells a school district a bus that is not a certified school bus may be in violation of Federal law. According to your letter, most of those school districts now recognize the 'considerable risks' associated with this practice. You are concerned that some of these districts are now purchasing the same vehicles that were previously certified as buses, but the vehicles now have only ten seating positions. Accordingly, the vehicles are now certified by the manufacturer as multipurpose passenger vehicles (MPVs). You believe that this situation is not a violation of Federal law because dealers are no longer selling school districts 'buses' that are not certified as school buses. However, you believe there is still a considerable risk of civil liability for the school districts in the event of a crash. You asked for our comments on this practice. Generally speaking, there is no violation of Federal law when a dealer sells a properly certified MPV to a school district. On the other hand, NHTSA has maintained a long-standing position that if a dealer sells an MPV or bus capable of being converted and used as a school bus to a school or a school bus contract operator, that dealer is responsible for ensuring that the vehicle complies with all applicable school bus standards. (40 FR 60033, 60034, December 31, 1975.) For example, let us assume that a dealer sells a school district a vehicle that is certified as an MPV by its manufacturer. The vehicle has ten designated seating positions when it is delivered to the dealer, but is large enough to accommodate an additional bench seat, which would result in the vehicle having at least 13 designated seating positions. In this instance, a dealer who sells such a vehicle to a school district would have violated the prohibition in section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) against selling vehicles that do not comply with all applicable safety standards. In essence, NHTSA has concluded that a dealer may not legally sell a school district a vehicle that is capable of being converted into a school bus, unless: 1. that vehicle is certified as complying with applicable school bus standards, or 2. the dealer has reason to believe that the buyer has no intent of converting and using the vehicle as a school bus. If the dealer is uncertain of the buyer's intent, the agency has suggested that the dealer request a written statement of purpose from the buyer. (Id.) The agency has taken this position because the dealer frequently is the person in the distribution chain with the best knowledge of how a buyer intends to use a vehicle. Applying this reasoning to the situations described in your letter, the dealers selling MPVs to school districts might have done so in violation of Federal law. If the MPVs in question were capable of being converted into school buses, and the dealer had reason to believe that the purchasing school district intended to convert the vehicles to school buses, the dealer could only sell the MPV to the school district if the vehicles were certified as conforming to all applicable school bus standards. Your letter did not provide enough information for us to offer an opinion on any such potential liability. If you know of instances where a dealer may have sold vehicles to a school district under circumstances such as I describe here, please report this information to the Office of Enforcement, NHTSA, Room 6113, NEF-30 at the address on this letterhead. With respect to your question about the risk of civil liability in the event one of these vehicles is in a crash, that is a question of State, not Federal law. I am not qualified to offer an opinion on how the matter would be resolved under Kansas law. I suggest that you contact the Attorney General for the State of Kansas to get an opinion about how the laws of Kansas would apply in such a situation. I hope you find this information helpful. If you have further questions, please contact Joan Tilghman of my staff at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam3767OpenMr. Lee Jay Mandell, President, LJM Associates, Inc., 22030 Lanark Street, Canoga Park, CA 91034; Mr. Lee Jay Mandell President LJM Associates Inc. 22030 Lanark Street Canoga Park CA 91034; Dear Mr. Mandell: This is in response to your letter of October 19, 1983, discussing lighting product that you have developed and asking for 'the approval of the DOT or at least to insure that no active disapproval would be forthcoming.'; Your device utilizes the body panel between the left and right rea lights to emphasize braking, right and left turns, hazard flashing, and backing up. Roughly, your device operates by lights spreading from the center of the panel outward, in either or both directions.; We think that there is great potential for confusion that this devic could create since it is so unlike anything seen before on a motor vehicle. In the stopping mode the driver following will see the steady light of the stop lamp at the edge of the vehicle, but also the dynamic lights of your device spreading out from the center. The same dynamic light spread is seen but is meant to indicate something entirely different when both turn signal lamps are operating simultaneously in the hazard warning mode. Thus, the potential for impairment of the required lighting equipment exists.; Generally, we do not favor any lights on the rear of a vehicle that ar not required by the Federal lighting standard.; Sincerely, Frank Berndt, Chief Counsel |
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.