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: aiam4003OpenMr. Thomas J. Burke, Vice President - Domestic Sales, Hess & Eisenhardt Armoring Company, 8959 Blue Ash Road, Cincinnati, OH 45242; Mr. Thomas J. Burke Vice President - Domestic Sales Hess & Eisenhardt Armoring Company 8959 Blue Ash Road Cincinnati OH 45242; Dear Mr. Burke: Thank you for your letter of July 3, 1985, to Mr. Burdette and Mr Brownlee concerning a new automobile safety package your company is developing. Your letter was referred to my office for reply. You described your product as a number of modifications to a vehicle to improve its security. The modifications include changes to the windows, tires, doors, and fuel tank. I hope the following discussion explains how our regulations would affect your product.; The National Traffic and Motor Vehicle Safety Act authorizes th National Highway Traffic Safety Administration (NHTSA) to issue Federal Motor Vehicle Safety Standards for new motor vehicles and items of motor vehicle equipment. Under that authority, NHTSA has issued vehicle safety standards on a wide variety of subjects, including on tires, windows, doors and fuel tanks. I am enclosing an information sheet explaining how you can obtain copies of our standards. A manufacturer of new vehicles must certify that its vehicles conform to the requirements of all applicable safety standards. Under our certification regulation, Part 567, *Certification* (49 CFR Part 567), a person who modifies a vehicle prior to its first sale to the consumer is considered an 'alterer.' Part 567.7 requires vehicle alterers to certify that the vehicle, as altered, conforms to all of our safety standards. Thus, if your company is modifying vehicles with your security package prior to their first sale to the consumer, it must certify that the vehicles, as altered, conform with all applicable standards. Any person who fails to comply with our certification regulations is subject to civil penalties under the Vehicle Safety Act.; If your company is modifying used vehicles, then its actions would b affected by section 108(a)(2)(A) of the Vehicle Safety Act (15 U.S.C. S1397(a)(2)(A)), which was added to the Act in 1974 to address the problem of persons tampering with safety equipment installed on a motor vehicle. Section 108(a)(2)(A) provides, in part, that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard.....<<<; Thus, a manufacturer, distributor, dealer, or motor vehicle repai business making the modifications you describe must ensure that those modifications do not 'render inoperative' the compliance of the vehicle with any safety standard. The Vehicle Safety Act provides for civil penalties for persons that 'render inoperative' an element of a safety standard.; I hope this information is of assistance to you. If you have furthe questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam1201OpenMr. Charles J. Calvin, Managing Director, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin Managing Director Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: This is in reply to your letter of July 5, 1973, requesting a unifor location for trailer certifications labels required by both the Hazardous Materials regulations (49 CFR S 178.340-10) and NHTSA Certification regulations (49 CFR Part 567). You request that location be specified as the 'forward half of the left side of the trailer.'; NHTSA Certification regulations, as you note, presently provide tha the certification label for trailers must be placed on the 'forward half of the left side of the vehicle' (49 CFR S 567.4(d)). This requirement does not distinguish between the frame and the tank shell, and the reference to 'vehicle' in the language of the provision is considered inclusion of both. The Certification regulations therefore appear to permit the location of the label that you request.; I note, however, the drawings in your letter, those titled 'Acceptabl Locations of Certification Labels' and 'Suggested Locations for Certification Labels', picture as an appropriate label location the front of the vehicle.; This location is not permitted by the NHTSA Certification regulations which clearly call for the label to be affixed to the vehicle 'left side'. While it is not clear whether you intended to request that the label be permitted to be affixed to the vehicle front, we do not find sufficient justification in your letter to depart from the existing requirements in this regard.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs; |
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ID: aiam1714OpenMr. David D. Anderson, Chairman, ASTM Subcommittee E17.24, Tire and Slider characteristics, General Motors Proving Ground, Milford, Michigan 48042; Mr. David D. Anderson Chairman ASTM Subcommittee E17.24 Tire and Slider characteristics General Motors Proving Ground Milford Michigan 48042; Dear Mr. Anderson: This is in reply to your letters of October 25, and November 5, 1974 requesting our opinion on whether a tire recently approved by ASTM for special purpose highway and airport runway skid resistance tests must conform to Motor Vehicle Safety Standard No. 109 (49 CFR S 571.109), and whether it may be used for skid resistance testing on highways and airport runways. You describe the tire as a G778-15 of bias-belted construction (2-ply polyester sidewall and 2 fiberglass belts), having a tread with no grooves or sipes. You indicate that due to the tread configuration the tire will not meet the high speed performance requirements (S4.2.2.6) of Standard No. 109.; Standard No. 109 applies according to its terms to '...tires for use o passenger cars...' We believe it reasonable to distinguish these ASTM test tires from tires subject to Standard No. 109. While physically similar to passenger car tires, these tires are manufactured purely as test devices, and for test purpose. We conclude, therefore, that they are not 'for use on passenger cars' within the meaning of Standard No. 109. These tires should be distinguished from experimental program for passenger car tires, which we have found to be subject to Standard no. 109.; Because of this conclusion, there are no NHTSA prohibitions on th tires' use as test tires. They may be used for testing purposes on public highways and airport runways if that testing can be conducted in a safe manner. You should, however, check State and local laws in any area in which you which to conduct testing to see that those laws permit testing if this type. Because the tires are not subject to Standard No. 109 we believe it would be preferable if they did not contain the nomenclature required by Standard No. 109 except insofar as that nomenclature relates to their safe use in testing. This would reduce the chance that they may be used on passenger cars for other than test purposes. We also believe a stronger warning against general use would be proper. We have in mind Something like 'CAUTION: NOT FOR GENERAL HIGHWAY USE - DO NOT USE EXCEPT FOR SPECIAL TEST PURPOSES.'; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam3729OpenMr. C. B. Bright, Jr., C. B. Bright Motor Co., Route 1, Ashland, MS 38603; Mr. C. B. Bright Jr. C. B. Bright Motor Co. Route 1 Ashland MS 38603; Dear Mr. Bright: This is in reply to your letter of July 19, 1983, to Mr. Vinson of thi office. You have asked whether you are violating any Federal standards or regulations by adding 'right side steering, accelerator, brakes & turn signal controls to rural mail carriers delivery vehicles (cars, pickup, jeeps, etc.).' You have told us that you do not modify in any way the left hand side controls with which the vehicle was originally equipped.; Assuming that your modifications do not affect the performance of an of the systems with which the vehicle was equipped by its original manufacturer, your conversion operations would not be prohibited by the National Traffic and Motor Vehicle Safety Act. However, with respect to any new vehicle that you modify which has not yet reached its first purchaser for purposes other than resale, you are required to affix a label identifying you as the alterer and certifying that the vehicle as altered meets all applicable Federal motor vehicle safety standards. This is required by Title 49 Code of Federal Regulations, Section 567.7. I enclose a copy of Part 567 for your information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0806OpenMr. Sam Huff, Specifications Consultant, Associated General Contractors, Texas Highway-Heavy Branch, P. O. Box 2185, Austin, TX 78767; Mr. Sam Huff Specifications Consultant Associated General Contractors Texas Highway-Heavy Branch P. O. Box 2185 Austin TX 78767; Dear Mr. Huff: This is in reply to your letter of July 31, 1972, concerning work to b performed on new trucks. Your three questions are answered below.; You ask, 'What are the legal aspects of a road contractor doing th fifth-wheel work on a new truck?' The installation of a fifth wheel on a new vehicle would most likely make the installer a 'final-stage manufacturer' under NHTSA Certification regulations (49 CFR Part 567) and regulations governing 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). Final-stage manufacturers bear the responsibility for certifying that the completed vehicle conforms to all applicable motor vehicle safety standards. The procedure for certifying is specified in the Certification regulations, copies of which are enclosed.; Your second question is, 'At what stage after purchase may a new truc be legally termed a used truck?' For our purposes, a used vehicle is any vehicle that has been purchased in good faith for a purpose other than resale (15 U.S.C. 1397(b)(1)).; Your last question is, 'Would the installation of extra lights o safety items be construed as final manufacturing?' The installation of readily attachable components, such as mirrors or tires, is not considered to be an activity which makes the installer a final-stage manufacturer. We are of the opinion that the same would be true regarding the installation of 'extra' lights (those not required pursuant to Motor vehicle Safety Standard No. 108, (49 CFR 571.108)). We cannot provide you with an opinion as to 'safety items' as this term is too general. However, assuming that you are referring to items not required by a motor vehicle safety standard, our answer would most likely be the same. The manufacturer should determine whether the component he installs affects to a significant extent either the configuration or purpose of the vehicle. If it does not, (we will accept a manufacturer's reasonable determination in this regard) then the installer would not be considered a final- stage manufacturer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4516OpenMr. Scott A. Snyder 117 South Keesey Street York, PA 17402; Mr. Scott A. Snyder 117 South Keesey Street York PA 17402; "Dear Mr. Snyder: This is in reply to your letter of March l0, l988, t the Department's regional office in Philadelphia, asking for a response concerning 'ornamental lighting.' In your opinion 'a few extra lights on the side and rear of a vehicle would help other people see you better while driving at night.' The agency is interested in the role that vehicle conspicuity plays in accidents and accident avoidance. With reference to motorcycles, we have amended our motor vehicle lighting standard to prescribe performance characteristics for headlamp modulation. We were prepared to amend the standard to require the activation of motorcycle headlamps when the ignition was turned on (but did not do so when we learned that almost all motorcycles were being wired to operate in that fashion). Some time ago we asked the public to comment on ways of increasing the conspicuity of large vehicles as our research had indicated that reflective tape applied to the side and rear of wide trucks and trailers might lessen crashes and crash severity, and our research still continues in this area. Most importantly we adopted the center highmounted stop lamp for passenger cars because of the ability it demonstrated in test fleets to reduce the frequency of rear end impacts. The type of lights of which you speak are referred to as 'presence' lamps (as contrasted with 'signal' lamps), and the agency over the years has acted with respect to all motor vehicles by requiring them to be equipped with side marker lamps, and by increasing the lens area for stop lamps. As the Federal safety standards are by statutory definition 'minimum' safety standards, the requirement that there be two taillamps, for example, does not mean that a manufacturer may not add two more if it wishes, or any lighting device not covered by the standard. The sole restriction is that lighting devices added by the manufacturer or dealer that are in excess of the minimum must not impair the effectiveness of the equipment required by the standard. This could happen, for example, if a fog lamp (not covered by the standard) was of an intensity and located so that it masked an adjacent front turn signal. With respect to nighttime operation, the critical issue would appear to be thatadditional lighting devices not create glare to oncoming and following drivers. The owner of the vehicle is not under a similar Federal restriction, and may personally add such additional lighting devices as seems desirable, subject to the laws of the States where the vehicle is registered and/or driven. However, the owner may not have these devices installed by a motor vehicle dealer or repair business if the result is to render wholly or partially inoperative any of the vehicle's original lamps or reflectors. We appreciate your suggestion for improving motor vehicle safety. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam1344OpenMr. Thomas S. Pieratt, Truck Equipment & Body, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Truck Equipment & Body 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of November 6, 1973, requestin information on whether vehicle certification labels must be affixed by persons who for their own use install fifth wheels on chassis cabs.; The NHTSA takes the position that vehicles completed by persons fo their own use must conform to all applicable motor vehicle safety standards and be certified (by affixing the appropriate label) as conforming. The NHTSA considers the use of these vehicles to be an introduction or delivery for introduction in interstate commerce and subject to the prohibitions of section 108 of the Safety Act. Persons who complete incomplete vehicles are final-stage manufacturers and all other regulations applicable to manufacturers (Parts 566, 573, and 577) apply to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3379OpenMr. B. G. Ridgway, Chief Car Safety and Regulation Engineer, Rolls-Royce Motors Ltd., Car Division, Crew, Cheshire CW1 3PL, England; Mr. B. G. Ridgway Chief Car Safety and Regulation Engineer Rolls-Royce Motors Ltd. Car Division Crew Cheshire CW1 3PL England; Dear Mr. Ridgway: This responds to your letter concerning the labeling requirements o Standard No. 105 applicable to a separate indicator lamp concerning reservoir level. Your letter asked whether it is permissible to use words other than 'Brake Fluid' for vehicles which use hydraulic system mineral oil rather than conventional brake fluid. As explained below, the answer is yes.; Section S5.3.5 of Standard No. 105 states in relevant part: >>>...If separate indicator lamps are used for one or more of th various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word 'Brake' and appropriate additional labeling (use 'Brake Pressure,' 'Brake Fluid' for S5.3.1(a) and S5.3.1(b) except that if a separate parking indicator lamp is provided, the single word 'Park' may be used....<<<; As your letter pointed out, conventional brake fluid and hydrauli system mineral oil are not compatible. Safety Standard No. 116, *Motor Vehicle Brake Fluids*, differentiates between 'brake fluid' and hydraulic system mineral oil.'; We interpret section S5.3.5 to require the use of the words 'Brak Fluid' only for vehicles which use conventional brake fluid. The section's use of the word 'appropriate, ' prior to its statement that 'Brake Fluid' be used for S5.3.1(b), indicates that the labeling set forth in the parentheses need only be used where it adequately describes the fluid being used. For vehicles which use hydraulic system mineral oil, or other types of non-conventional brake fluid which might be developed in the future, the general requirement for the word 'Brake' and appropriate additional labeling is applicable.; We are concerned, however, about your proposed use of the words BRAK HSMO/LHM, since we doubt that many persons would understand that HSMO/LHM is an abbreviation for hydraulic system mineral oil/liquide hydraulique minerale. We suggest that you consider using the words 'BRAKE MINERAL OIL' or similar language that more persons would understand.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4146OpenThe Honorable Harold Rogers, U.S. House of Representatives, Washington, DC 20515; The Honorable Harold Rogers U.S. House of Representatives Washington DC 20515; Dear Mr. Rogers: Thank you for your letter on your constituent's behalf to former Chie Counsel Frank Berndt asking several specific questions about our motor vehicle safety standards for school buses. I hope this information is helpful to you in responding to your constituent. If you or your constituent need further clarification about how our requirements apply in a specific situation, please let me know.; Your questions were as follows: >>>1. Can a vehicle designed, manufactured, and sold as a truck, eve be considered a 'school bus' unless remanufactured, modified, or converted by a manufacturer or a manufacturer's dealer or distributor and certified as a school bus?<<<; The answer to your question depends on whether you are asking about vehicle being considered a 'school bus' under State or Federal law. Under Federal law, which applies to the manufacture and sale of new motor vehicles, the answer is no. A vehicle is certified only once, when manufactured as a new vehicle. With the one exception discussed below, there is no provision in our statutes or regulations for recertification of a used vehicle which has been modified so that it falls into a different category of vehicles. The National Traffic and Motor Vehicle Safety Act and regulations issued thereunder require manufacturers to classify their new motor vehicles and certify that their vehicles meet all Federal motor vehicle safety standards applicable to the vehicle type. Those determinations are only made by the manufacturer at the time the vehicle is originally manufactured. Since both the physical attributes underlying the vehicle types and the applicable safety requirements differ from type to type, a vehicle can be classified only as a single type. Therefore, a new vehicle manufactured and sold as a 'truck' is certified as meeting our safety standards for trucks and cannot be certified also as a vehicle meeting safety standards for school buses.; Our regulations do not prohibit used trucks from being modified fo pupil transportation purposes. Since our certification requirements apply only to the manufacture or alteration of new motor vehicles, the person performing the modification does not recertify the vehicle as a 'school bus' unless the modification of the vehicle is so extensive as to constitute a manufacture of a new vehicle. For example, a used truck chassis lacking requisite systems required by our regulations might be combined with a new school bus body. The completed school bus would be considered newly manufactured, and would have to be certified as a 'school bus.'; Used trucks which have been modified to carry school children might b considered 'school buses' under State law. State definitions of school buses determine the applicability of school bus operational requirements to vehicles. If the modifications to a truck bring it within a State's definition of 'school bus,' then the vehicle would be considered a school bus under State law and would have to comply with State requirements for school buses in order to be properly used as a school bus in that State.; >>>2. Do Federal Motor Vehicle Safety Standards apply only t manufacturers, their dealers and distributors?<<<; The answer to your question is no, because our motor vehicle safet standards apply to anyone who manufactures, distributes or sells new motor vehicles. Federal law requires manufacturers of new school buses to certify that their vehicles comply with all applicable school bus safety standards. In addition, distributors and sellers of new school buses must ensure that only complying school buses are sold. While new school buses are typically sold by their manufacturers or manufacturers' distributors and dealers, the responsibility to sell complying school buses rests with any person selling new school buses.; The Vehicle Safety Act applies also to persons who perfor manufacturing operations on previously certified *new* vehicles prior to the vehicles' first purchase in good faith for purposes other than resale.; Such persons are considered 'alterers' under our regulations and ar subject to requirements that they certify compliance with Federal Motor Vehicle Safety Standards. Alterers who significantly affect the configuration of a new motor vehicle previously certified to applicable safety standards must certify that the new vehicle, as altered, conforms to all applicable safety standards affected by the alteration in effect on the date of manufacture of the original vehicle or on the date the alterations were completed.; In addition, the Vehicle Safety Act applies to commercial businesse performing operations on *new and used* motor vehicles. Section 108(a)(2)(A) of the Vehicle Safety Act (copy enclosed) states, in part:>>>No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .<<<; Thus, the requirements of our motor vehicle safety standards affec those aforementioned parties modifying or repairing new or used motor vehicles, by setting limits on the operations performed on those vehicles. Those persons are prohibited from either removing, disconnecting or degrading the performance of safety equipment installed in compliance with an applicable safety standard. There is no prohibition against an individual owner modifying his or her own vehicle.; >>>3. What is the difference between a tamperer and a modifier as the relate to Federal Motor Vehicle Safety Standards?<<<; Our regulations do not define the terms 'modifier' and 'tamperer. However, the terms are commonly used to describe persons who make changes to vehicles. The term 'modifier' is often used to describe persons making changes to new or used vehicles. As explained above, persons modifying a new motor vehicle prior to its first purchase are considered 'alterers' under our regulations and are subject to requirements that they recertify the vehicle. Commercial parties involved with modifying new or used vehicles are subject also to the 'render inoperative' prohibitions of Section 108(a)(2)(A).; 'Tamperers' often refer to persons modifying or removing safety system or equipment on used vehicles. Commercial parties involved in tampering are subject to the 'render inoperative' prohibitions of Section 108(a)(2)(A). Violations of section 108(a)(2)(A) are punishable by civil penalties up to $1,000 per violation. Again, our regulations do not apply to individual owners modifying their own vehicles. Such modifications, however, would have to comply with State law.; >>>4. Who can make the certification that a vehicle meets applicabl Federal Motor Vehicle Safety Standards?<<<; Under the Vehicle Safety Act, manufacturers of new motor vehicle certify that their vehicles comply with all applicable motor vehicle safety standards. As suggested above, 'alterers' are considered to be motor vehicle manufacturers and therefore are also subject to certification requirements. Alterers certify that the vehicle, as altered, conforms to applicable safety standards affected by the alteration.; >>>5. Does the date of manufacture of a vehicle determine the specifi Federal Motor Vehicle Safety Standards that the vehicle has to meet?<<<; In general, the answer to this question is yes. The date of manufactur is one factor determining applicability of our motor vehicle safety standards. Each motor vehicle manufactured on or after the effective date of a safety standard is subject to requirements of that standard if, of course, the standard applies to that vehicle type. However, as explained above, 'alterers' affecting compliance with Federal safety standards by their alteration may choose the completion date of the alterations as the date by which to certify.; >>>6. Are passenger restraint systems required on school buses with manufacture date prior to April 1, 1977?<<<; In 1974, Congress directed NHTSA to issue motor vehicle safet standards for various aspects of school bus safety. Pursuant to that mandate, we issued Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which requires school buses to provide a passenger restraint system through a concept called 'compartmentalization.' The standard became effective on April 1, 1977, and applies to each school bus manufactured on or after that date. School buses manufactured prior to April 1, 1977, are not subject to compartmentalization requirements.; >>>7. Are there any Federal Motor Vehicle Safety Standards applicabl only to school buses prior to April 1, 1977?<<<; The answer is no. There are three safety standards that we issue exclusively for school buses, i.e., Standards No. 220, *School Bus Rollover Protection*, No. 221, *School Bus Body Joint Strength*, and No. 222, *School Bus Passenger Seating and Crash Protection*. Those standards became effective April 1, 1977.; >>>8. Do school buses manufactured prior to April 1, 1977, have to mee FMVSS No. 217 and FMVSS No. 222?<<<; Standard No. 217 became effective September 1, 1973. School buse manufactured on or after that date and prior to April 1, 1977, had to meet Standard No. 217 *if* push- out windows or other emergency exits were provided. Pursuant to the 1974 Congressional mandate, NHTSA amended Standard No. 217 to require school buses manufactured on or after April 1, 1977, to contain additional emergency exits and set special requirements for those exits.; Standard No. 222 became effective on April 1, 1977. School buse manufactured prior to that date do not have to meet that standard.; Again, please contact my office if you or your constituent have an further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3683OpenMr. Richard H. Attenhofer, Technical Manager, O.E., Dunlop Tire Company, Box 1109, Buffalo, NY 14240; Mr. Richard H. Attenhofer Technical Manager O.E. Dunlop Tire Company Box 1109 Buffalo NY 14240; Dear Attenhofer: This responds to your recent letter to Mr. Kratzke of my staff requesting an interpretation of 49 CFR Part 574, *Tire Identification and Recordkeeping*. Specifically, you asked if Dunlop could use a print type called OCR-A for the DOT symbol and the tire identification number.; Note 1 to Figure 1 of Part 574 specifies only four different prin types which may be used for the DOT symbol and identification number, none of which are OCR-A. However, Note 4 to Figure 1 states that other print type will be permitted if approved by this agency. We have examined the print type shown in the diagram attached to your letter and have no objections to your company printing the required information in OCR-A type.; In the final rule establishing Part 574 (35 FR 17257, November 10 1970), the agency explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The OCR-A print type shown in the diagram attached to your letter is easily readable and thus satisfies our concerns in that regard. Accordingly, that print type is hereby approved.; Sincerely, Frank Berndt, 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.