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: aiam4363OpenMr. Melvin H. Smith, Governor's Representative for Highway Safety, Illinois Department of Transportation, 2300 S. Dirksen Parkway, Springfield, IL 62764; Mr. Melvin H. Smith Governor's Representative for Highway Safety Illinois Department of Transportation 2300 S. Dirksen Parkway Springfield IL 62764; Dear Mr. Smith: This responds to your June 9, 1987, letter to me asking whether Sectio 103(d) of the National Traffic and Motor Vehicle Safety Act.; I have enclosed a copy of a March 23, 1976, letter to Mr. Marti Chauvin relating to the preemptive effect of Federal law over a New York State law for 28-inch high seat backs. Please note the discussion in the Chauvin letter relating to State requirements for additional safety features in *public school buses.* under Section 103(d), a State may require a seat back height higher than 20 inches for its public school buses, provided that the vehicles continue to comply with all applicable Federal safety standards.; I will send a copy of this letter to Mr. Larry Wort of your Department whose earlier letter to us asking about our requirements for seat back height and restraining barriers raised also the same preemption issues. Please feel free to contact my office if you have further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1161OpenMr. R. W. Harvey, Peterbilt Motor Truck Co., 300 Toland Street, San Francisco, CA 94124; Mr. R. W. Harvey Peterbilt Motor Truck Co. 300 Toland Street San Francisco CA 94124; Dear Mr. Harvey: This is in reply to your letter of May 22, 1973, in which you state yo are a distributor of Peterbilt trucks and ask whether certain operations you perform subject you to Federal requirements. These operations are modifications to air brake systems and the installation of used bodies on new truck chassis.; A company whose business includes the installation of used bodies o new truck chassis is a manufacturer under the National Traffic and Motor Vehicle Safety Act and, as such, has certain responsibilities under the Act and regulations issued by this agency. In response to your question regarding registration, you are required pursuant to NHTSA 'Manufacturers' Identification' regulations (49 CFR Part 566) to submit to the agency information regarding the manufacturing operations of your company and the types of vehicles that it manufacturers.; A manufacturer is also required, pursuant to NHTSA 'Certification regulations (49 CFR Part 567, 568) to ascertain and certify the conformity of each vehicle he manufacturers to applicable motor vehicle safety standards. Under these regulations the person who completes the vehicle (the 'final-stage manufacturer') is required to affix to the vehicle a label that contains the certification that the vehicle conforms to applicable standards, as well as other information. Our experience has been that most manufacturers who install truck bodies onto new chassis are final-stage manufacturers, who must affix this label. Persons whose manufacturing operations precede that of the final-stage manufacturer are required to provide documentation with the vehicle that indicates what steps will be necessary in order to bring the vehicle into conformity with applicable standards. You also ask if there are requirements for the making of periodic reports. NHTSA 'Defect Reports' regulations (49 CFR S 573.5(b)) do require manufacturers to furnish the NHTSA with quarterly production figures.; The other operation you describe is the modification of vehicle ai brake systems, including changes in valves, lines, spring brakes, air tanks, etc. If you merely modify an existing air brake system, there are presently no certification or reporting requirements applicable to you. The NHTSA has just issued certification requirements for persons who alter completed vehicles, and depending on the extent of the modification you perform, these requirements may apply to you. They are effective February 1, 1974. All trucks manufactured after September 1, 1974, that are manufactured with air brakes will be required to conform to requirements specified in Federal Motor Vehicle Safety Standard No. 121. The law would not allow you to modify the air brake system of any truck manufactured on or after that date, before the sale of the truck to a purchaser for a purpose other than resale (a user), if the modification you performed would cause the vehicle to no longer comply with the standard.; I have only summarized the requirements that, based on the facts yo have provided, would be applicable to you. Your responsibilities are stated specifically in the regulations we have referred to, and you may obtain copies of these requirements as indicated on the enclosed, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4699OpenMr. Jim Evans Quality Control Department The Bargman Company 129 Industrial Avenue Coldwater, MI 49036; Mr. Jim Evans Quality Control Department The Bargman Company 129 Industrial Avenue Coldwater MI 49036; Dear Mr. Evans: This is in reply to your letter of December 13, 1989 with respect to whether the installation of 'yellow' reflex reflectors on the rear of motor vehicles is permissible under Standard No. 108. Because the standard uses the term 'amber' instead of 'yellow', I shall refer to yellow as amber also. As you note, the standard requires two red reflex reflectors to be mounted on the rear, but is silent as to whether additional reflectors, amber in color, are permitted. One of your customers has asked you to manufacture an amber turn signal lens that would have an amber reflex reflector area around the outer edge. The turn signal lamp would be adjacent to a lamp of apparently identical size and shape with a red lens and reflex reflector area, providing stop and tail lamp functions. The State of Michigan apparently allows only red reflex reflectors on the rear. You have asked whether reflectors of other colors may be mounted on the rear as long as the required red ones are present, and if it is illegal, whether Standard No. 108 may be amended to eliminate the confusion. Because an amber reflector is not a required item of lighting equipment that Standard No. 108 specifies to be installed on the rear of a motor vehicle, its acceptability is subject to the general provisions of section S5.1.3. This states, in pertinent part, that no additional reflective device may be installed that impairs the effectiveness of lighting equipment required by Standard No. 108. It does not appear to us that an amber taillamp lens with an amber reflector would create an impairment. Under Standard No. 108, amber is a permissible color for rear turn signal lamps, and its presence on a reflector surrounding the lamp should not create confusion. Therefore, manufacture, sale, and installation of an amber taillamp lens with an amber reflector would not constitute a noncompliance with Standard No. 108. However, an interpretation by NHTSA that its lighting standard does not forbid the installation of an amber reflex reflector does not mean that a State could not adopt and enforce a law prohibiting such a reflector. Under section l03(d) of the National Traffic and Motor Vehicle Safety Act, a State may impose its own safety requirements covering any aspect of performance that is not covered by Standard No. 108. We construe this provision narrowly, as allowing a State to regulate all lighting equipment that is not specifically required by Standard No. 108. Noting that Section CI 257.691 of the Micigan vehicle lighting code that you enclosed specifies that reflectors 'mounted on the rear shall reflect a red color to the rear', the appropriate remedy would be to seek an amendment of the Michigan law. This agency presently has no plans to specify yellow as an alternate color for rear reflex reflectors. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam5122OpenMr. M.K. Chaudhari Director ARAI The Automotive Research Association of India Post Box No. 832 Survey No. 102, Vetal Hill Off Paud Road, Lothrud Pune-411 004 INDIA; Mr. M.K. Chaudhari Director ARAI The Automotive Research Association of India Post Box No. 832 Survey No. 102 Vetal Hill Off Paud Road Lothrud Pune-411 004 INDIA; "Dear Mr. Chaudhari: This responds to your follow-up letter of Novembe 16, 1992, subsequent to our response, dated August 12, 1992, to your earlier letter. I am pleased that the information given you in our previous letter is proving helpful in your work. In your current letter you request information regarding DOT certification of automotive components in general, and 'brake hose ends' in particular. I would like to clarify the relevant points made in our last letter to clear up any misunderstandings. Neither the Department of Transportation (DOT), nor the National Highway Traffic Safety Administration (NHTSA, a part of DOT) conduct any certification testing. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), a copy of which I have enclosed, the manufacturer is responsible for certifying that its components or vehicles are in compliance with NHTSA's safety standards. Manufacturers must have some basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. NHTSA tests vehicles and equipment sold to consumers for compliance with the FMVSS's and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of noncomplying or defective products is also subject to civil penalties. With respect to your specific question about 'brake hose ends,' Standard No. 106, 'Brake Hoses,' applies to new motor vehicles and to 'brake hoses' (which include plastic tubing), brake hose end fittings, and brake hose assemblies. A copy of the standard is enclosed. The standard specifies labeling and performance requirements for these products to reduce the likelihood of brake system failure from ruptures in the brake hose or brake hose assembly. New brake hoses, end fittings, and assemblies must meet these requirements to be sold in or imported into this country. If the items do not comply, the manufacturer is subject to the civil penalties and the recall responsibilities mentioned above. I have enclosed a copy of the test procedure manual used by the agency in its tests to verify compliance of the brake hoses. However, please see the Note on page 1 of the procedure manual regarding a manufacturer's certification testing. NHTSA does not authorize testing agencies to perform certification procedures. Therefore, we cannot provide a list of the agencies in India or elsewhere that are capable of certifying motor vehicles or motor vehicle equipment. I hope this information clarifies NHTSA's role in the certification process. If you have any further questions about NHTSA's safety standards, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366-2992. Our fax number is (202) 366-3820. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam0320OpenMr. J.B.H. Knight, Chief Development and Car Safety Engineer, Rolls-Royce Limited, Motor Car Division, Pym's Lane, Crewe, Cheshire, England; Mr. J.B.H. Knight Chief Development and Car Safety Engineer Rolls-Royce Limited Motor Car Division Pym's Lane Crewe Cheshire England; Dear Mr. Knight: This is in reply to your letter of April 14, 1971, in which you repea Rolls Royce's requests for interpretation of Standards No. 207 and 208.; The request for interpretation of the seat adjustment requirement o Standard No. 207 was initially made in your petition for reconsideration of that standard. Our response to the petitions on Standard No. 207 was published on April 20, 1971. Your petition was denied to the extent that it requested that the requirement be amended to permit 2 inches of travel. However, it is recognized that continuously adjustable seats may have a certain small amount of travel that would not be harmful, and the notice accordingly indicates that they are considered to remain in their adjusted position despite such motion.; We expect that you have by now received our reply to your questions o Standard No. 208. Your inquiry first reached us through your Washington counsel and we accordingly sent our reply by the same route. Please advise us if further clarification is needed.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam5572OpenMs. Denise Jones NiMi Manufacturing, Inc. 1044 Main St. Mosheim, TN 37818; Ms. Denise Jones NiMi Manufacturing Inc. 1044 Main St. Mosheim TN 37818; "Dear Ms. Jones: This responds to your letter to Ms. Deirdre Fujita o my staff asking about safety regulations, particularly for flammability resistance, for a device you call a 'Toddler Traveler pillow.' According to promotional literature you sent with your letter, the Toddler Traveler pillow is used with a child booster seat to provide 'padded comfort and support' to a child sleeping in the booster. The pillow provides a surface the child could lean on while sleeping. By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the information set forth in your letter and promotional literature. Currently there are no Federal motor vehicle safety standards (FMVSSs) that directly apply to the Toddler Traveler pillow. Our standard for 'child restraint systems,' FMVSS 213, applies to 'any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less.' The standard does not apply to accessory items, such as a pillow that is used with a child booster seat. Our standard for flammability resistance, FMVSS 302, applies to new motor vehicles and to new child restraint systems. It does not apply to child restraint accessory items. While no FMVSS applies to the Toddler Traveler pillow, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. 30118-30121 concerning the recall and remedy of products with safety related defects. I have enclosed a copy of those defect provisions, as well as an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. In addition, while it is unlikely that the Toddler Traveler pillow would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, 49 U.S.C. 30122 prohibits those businesses from installing the device if the installation 'makes inoperative' compliance with any safety standard. No commercial business listed in 30122 can install a Toddler Traveler pillow if the product undermines the vehicle's compliance with a safety standard, including Standard 302 for flammability resistance. The prohibition of 30122 does not apply to individual owners who install equipment in their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to degrade the safety of their vehicles. Before closing, we would like to comment on a further issue, one that you and Ms. Fujita discussed on the telephone. The advertising literature you enclosed with your letter described the Toddler Traveler pillow as being suitable for use with children ages '18 months to 4 years.' We believe this description is potentially confusing concerning the use of booster seats by young children. Booster seats are intended to be used as a transition to safety belts by older children who have outgrown convertible seats (ideally, over 40 pounds and 4 years). A booster seat is not designed to restrain young children, and under a requirement we recently adopted, cannot now be recommended for children under 30 pounds. Stating '18 months to 4 years' may be mistaken to imply that, with your pillow, a booster seat could be used to restrain a child as young as 18 months. To avoid any possible misunderstanding, we suggest that the phrase on recommended use of the pillow should refer to older children, such as those 'over 4 years.' One further note in closing. You said that a year ago, Ms. Fujita told you 'there are no codes to govern' your product. Ms. Fujita is concerned that you might believe you were given an oral interpretation of how our requirements apply to your product. Please note that we cannot give oral interpretations. Ms. Fujita provided you a copy of an interpretation we'd issued in the past on a child seat pillow accessory, while indicating that an interpretation of which requirements apply to your product must be from us in writing. (This letter comprises that interpretation.) We regret any confusion on this issue. I hope this information is helpful. If you have any other questions, please feel free to contact Ms. Fujita at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam1862OpenMr L. Steenbock, Engineering Department, FWD Corporation, Clintonville, WI 54929; Mr L. Steenbock Engineering Department FWD Corporation Clintonville WI 54929; Dear Mr. Steenbock: This responds to your March 11, 1975, question whether the exceptio category of 'no cargo-or passenger-carrying capacity' found in S3 of Standard No. 121, *Air brake systems*, includes a vehicle designed to carry a driver and a second person to operate the vehicle's specialized equipment.; The answer to your question is yes. We use the word 'passenger' in thi context to mean a person who does not help to operate the vehicle or its equipment, *i.e.*, who is not part of an operating crew. Positions for the crew necessary to operate a vehicle's specialized equipment would not disqualify a vehicle under the passenger-carrying criterion.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0770OpenMr. G. Doe, Vehicle Safety Manager, Lotus Cars Ltd., Norwich NOR 92W, Wymondham 3411, England; Mr. G. Doe Vehicle Safety Manager Lotus Cars Ltd. Norwich NOR 92W Wymondham 3411 England; Dear Mr. Doe: This is in reply to your letter of June 12, 1972, asking certai questions concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You ask if the standard applies to small components that have a maximu dimension of less than 4 inches, such as control knobs, and if so, how such components are to be tested. The standard applies to those components enumerated in S4.1. Control knobs and switches would not be subject to the standard unless they are 'designed to absorb energy on contact by occupants in the event of a crash.' Such components may be tested using the heat resistant wires that are inserted in the U-shaped frame, as described in paragraph S5.1.3 of the standard. The NHTSA is currently considering an amendment to the standard, however, which would modify the requirements as they apply to small components.; In response to your second question, electrical wiring is not subjec to the standard.; Your third question is, if a headliner is glued to the roof, would th test specimen be taken from a finished vehicle in such a way as to include the exterior paintwork. The answer to this question is no. The application of the standard to headlining (S4.1) does not include the roof to which it is attached, as the roof is not part of the component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5088OpenMr. Thomas Price ABAS Marketing, Inc. P.O. Box 5644 Norman, OK 73070; Mr. Thomas Price ABAS Marketing Inc. P.O. Box 5644 Norman OK 73070; "Dear Mr. Price: This responds to your letter asking about requirement for a device you call a 'noncomputerized antilock braking assist system,' for brakes installed on trucks and trailers. You stated that your device can be installed on vehicles equipped with air brake, electric brake, air over hydraulic brake, and vacuum/hydraulic brake systems. I am pleased to have this opportunity to explain our regulations to you. You asked what the agency's policy is regarding the approval, disapproval, or certification of any particular antilock brake system product. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act ('Safety Act'), it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards issued by this agency. A manufacturer then certifies that its vehicles or equipment comply with applicable standards. You also asked for a listing of the various standards and regulations with which you should be conversant, given your product, and an explanation of the responsibilities under the Safety Act of three types of parties: an original equipment manufacturer, an alterer of a previously certified new motor vehicle prior to its first sale, and an installer of an ABS device on a used motor vehicle. NHTSA has issued two standards about brake systems: Standard No. 105, Hydraulic Brake Systems and Standard No. 121, Air Brake Systems. Standard No. 105 specifies requirements for hydraulic service brake and associated parking brake systems, and applies to new passenger cars, multipurpose passenger vehicles, trucks, and buses equipped with hydraulic brake systems. Standard No. 121 establishes performance and equipment requirements for braking systems on vehicles equipped with air brake systems, and applies to almost all new trucks, buses, and trailers equipped with air brake systems. The agency does not have a regulation specifically covering a device such as a 'noncomputerized antilock braking assist system' which is added to a brake system. However, since your device would be tied into a vehicle's brake system, it could affect a vehicle's compliance with Standard No. 105 and Standard No. 121. If one of your devices is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that, with the device installed, the vehicle satisfies the requirements of all applicable safety standards, including Standard No. 105 and Standard No. 121. (See 15 U.S.C. 1397(a)(1) and 49 CFR Part 567.) If the device is added to a previously certified new motor vehicle prior to its first sale, the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. (See 49 CFR Part 567.7.) If the device is installed on a used vehicle by a business such as a garage, the installer would not be required to attach a certification label. However, it would have to make sure that it did not 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. (See 15 U.S.C. 1397(a)(2)(A).) You should also be aware of the requirements of Safety Standard No. 106, Brake Hoses, which specifies requirements for motor vehicle brake hose, brake hose assemblies, and brake hose end fittings. That standard applies to new motor vehicle equipment as well as to new motor vehicles. You should check to see if any parts of your devices are subject to the requirements of Standard No. 106. I also note that manufacturers of aftermarket equipment are subject to the Safety Act's defect provisions. Should a safety-related defect be discovered in your device, whether by the agency or yourself, you as the manufacturer would be required to notify purchasers and dealers and provide a cost-free remedy for the defect. Enclosed is a copy of an information sheet entitled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment,' which further explains a manufacturer's responsibilities under NHTSA's regulations. You may also wish to review the Federal Highway Administration's Federal Motor Carrier Safety Regulations, which set forth requirements for commercial motor vehicles. The address of the Office of Motor Carrier Standards is included in the enclosed information sheet. Finally, you asked how you could secure or have access to the complete Docket No. 92-29-01. This docket includes responses to an advance notice of proposed rulemaking (ANPRM) in which NHTSA announced that it is considering proposing additional requirements that might require medium and heavy duty vehicles to be equipped with antilock brake systems. The complete docket, including all the responses to the ANPRM, can be reviewed at the agency's Docket Section, room 5109, 400 Seventh Street, S.W., Washington D.C. 20590. Docket hours are 9:30 a.m. and 4:00 p.m., Monday through Friday. A complete copy of the docket is also available for a fee to cover search and copying costs by contacting the agency's technical reference division at (202) 366-4949. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0265OpenMr. B. Borisoff, Consulting Engineer, 5403 Blanco Avenue, Woodland Hills, CA 91364; Mr. B. Borisoff Consulting Engineer 5403 Blanco Avenue Woodland Hills CA 91364; Dear Mr. Borisoff: Reference is made to your letter of October 14, 1970 to Secretary Volp regarding our Consumer Information publication.; Concerning your comments on stopping distance, the wording used on pag 4 is the exact wording of this regulation. The category 'Stopping distance in feet with emergency brakes (partial service brake system)' is a generalization of the regulatory wording meant to convey the sense of this requirement to a consumer who may have no engineering background. The paragraph on page 193 paraphrases the regulatory wording. The title 'Partial Failure on One System' is, again, meant to convey the meaning to an otherwise uninformed consumer. I trust this clarifies the situation for you.; The reason many motorcycles are not listed is the fact that the dat was not received in time to be included in the book. I am enclosing copies of the data available for U.S. made motorcycles as you requested.; Volume 2, covering the 1971 makes and models will be availabl approximately November 15, 1970 and can be obtained from the Government Printing Office at a cost of $2.00. In addition two (2) new Consumer Aid publications entitled 'BRAKES - A Comparison of Braking Performance for 1971 Passenger Cars' and 'TIRES - A Comparison of Tire Reserve Load for 1971 Passenger Cars' will also be available at a cost of $.40 each.; Many thanks for your kind words and your interest in our motor vehicl safety program.; Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs; |
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.