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: aiam4718OpenMr. Gary R. Balanza P.O. Box 88112 Honolulu, HI 96830; Mr. Gary R. Balanza P.O. Box 88112 Honolulu HI 96830; "Dear Mr. Balanza: This is in reply to your letter asking for a interpretation whether your invention 'will interfere with the standard equipment' required by Motor Vehicle Safety Standard No. l08. I regret the delay in responding. Your invention, 'Pinlights', is described as an auxiliary lighting system designed to fit an automobile's side contours. Its purpose is to light up the entire length of a vehicle, so that it will be more conspicuous at night. We note your uncertainty as to 'number of stripes allowed on a car', 'colors allowed on a car', and 'maximum brightness allowable.' There are two ways to approach your invention under the National Traffic and Motor Vehicle Safety Act, our authority for the issuance of the motor vehicle lighting standard, Standard No. l08. The first is as an item of original equipment, in place on the vehicle at the time it is bought by its first owner. You have asked the correct question: does the invention impair the effectiveness of the lighting equipment required by Standard No. l08? The equipment most likely to be impaired are the side marker lamps and reflectors. These items are located near the front and rear of the vehicle, to enhance vehicle conspicuity by affording an approximation of vehicle length, and an indication of the vehicle's front and rear. The lamps are amber to the front, and red to the rear. Your invention would be located along the side of the vehicle, from front to rear. This suggests that the color of your device should similarly be amber to the front and red to the rear, so as not to impair the effectiveness of the directional function of the side marker lamps. The second way to approach your invention is as an item available in the aftermarket. Standard No. l08 does not apply to a vehicle in use. However, as it applies to your question, the Vehicle Safety Act prohibits modifications by manufacturers, distributors, dealers, or motor vehicle repair businesses if they render inoperative, in whole or in part, any of the required lighting equipment. In most cases, we consider an impairment of new vehicle equipment to be equivalent to a partial inoperability. Further, if installation of aftermarket equipmentdirectly affects the performance of original equipment (such as a reduction of light output through an interference with the wiring), that would certainly be considered a partial inoperability. Lighting equipment that is not covered by Standard No. l08 remains subject to the requirements of each State in which a vehicle on which it is installed is registered and/or operated. We are unable to advise you on State laws, and suggest that, for an opinion, you write the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Stephen P. Wood Acting Chief Counsel /"; |
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ID: aiam3527OpenMr. Robert J. Carter, Director, Consumer and Technical Affairs, Woodhill Permatex, 18731 Cranwood Parkway, Cleveland, OH 44128; Mr. Robert J. Carter Director Consumer and Technical Affairs Woodhill Permatex 18731 Cranwood Parkway Cleveland OH 44128; Dear Mr. Carter: This responds to your recent letter concerning a product yo manufacture which is used to repair breaks in automobile windshields. You ask whether such a repair product would conflict with any present motor vehicle safety standards.; The National Highway Traffic Safety Administration has issued Federa Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair product such as you describe, however. There is no Federal regulation which would prohibit the use of such a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new windshield which may require repair as a result of damage sustained, for example, in shipment could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, which would be the responsibility of the person selling the windshield. Therefore, we do not recommend use of windshield repair kits prior to the first purchase of a new windshield by a consumer.; Please contact Hugh Oates of my staff if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5559OpenMr. Ron Hooker Missouri Department of Agriculture P.O. Box 630 Jefferson City, MO 65102-0630; Mr. Ron Hooker Missouri Department of Agriculture P.O. Box 630 Jefferson City MO 65102-0630; "Dear Mr. Hooker: This responds to your question about whether th State of Missouri has authority to promulgate regulations relating to the safety of motor vehicles powered by alternative fuels, particularly compressed natural gas (CNG). The short answer is that while Missouri is generally preempted in this area, it could issue its own more stringent safety standard for State-owned vehicles. Federal law will preempt a State law if (1) there is a Federal safety standard in effect, (2) the State law covers the same aspect of performance as that Federal standard, and (3) the State law is not identical to the Federal standard. Specifically, section 30103(b) of Title 49 of the United States Code states that (b) Preemption. - (1) When a motor vehicle safety standard is in effect under this chapter, a State or political subdivision of a State may prescribe or continue in effect a standard applicable to the same aspect of performance of a motor vehicle or motor vehicle equipment only if the standard is identical to the standard prescribed under this chapter. However, the United States Government, a State, or a political subdivision of a State may prescribe a standard for a motor vehicle or motor vehicle equipment obtained for its own use that imposes a higher performance requirement than that required by the otherwise applicable standard under this chapter. State safety standards applicable to CNG fuel system integrity are generally preempted by Federal law. The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standard (FMVSS) No. 303, Fuel system integrity of compressed natural gas vehicles. (59 FR 19659, April 25, 1994, copy enclosed). The Standard specifies frontal barrier and rear barrier crash tests conducted at 30 mph and a lateral moving barrier crash test conducted at 20 mph. The Standard applies to passenger cars, multipurpose passenger vehicles, trucks and buses that have a gross vehicle weight rating (GVWR) of 10,000 pounds or less and use CNG as a motor fuel. It also applies to school buses regardless of weight that use CNG as a motor fuel. The Standard takes effect September 1, 1995. Accordingly, after September 1, 1995, Missouri could only issue its own safety standard applicable to CNG vehicle fuel system integrity if the State safety standard is identical to FMVSS No. 303. The one exception to requiring such identical standards is that Missouri could prescribe a standard for motor vehicles obtained for its own use, provided the State law imposed a higher performance requirement than the level of performance prescribed by FMVSS No. 303. Thus, Missouri could issue its own more stringent safety standard for State-owned vehicles. NHTSA further notes that Missouri is free to issue safety standards applicable to the fuel system integrity of vehicles powered by other alternative fuels (e.g., liquid propane, hydrogen), since the agency has not issued any FMVSS applicable to other alternative fuels. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure "; |
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ID: aiam3874OpenMr. Gordon G. Berge, Mandan Public School District, Central Administration Building, 309 Collins Avenue, Mandan, ND 58554; Mr. Gordon G. Berge Mandan Public School District Central Administration Building 309 Collins Avenue Mandan ND 58554; Dear Mr. Berge: This responds to your December 3, 1984 letter to the National Highwa Traffic Safety Administration (NHTSA) concerning the use of Greyhound-type buses to transport school children to school-related activities. You stated that the Mandan Public School District is considering purchasing 1963 and 1965 model year Greyhound-type buses for the purposes of transporting elementary and secondary students to activity events. Your first question asked whether this would be allowed under our regulations on school buses.; To begin, I would like to explain that there are two sets o regulations, issued under different Acts of Congress, that could affect Mandan's choice of buses. The first of these, the motor vehicle safety standards issued by our agency under the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563, 15 U.S.C. 1381-1426) apply to the manufacture and sale of new motor vehicles. In a 1974 amendment to the Act, Congress expressly directed us to issue standards on specific aspects of school bus safety, including emergency exits, seating systems, window and windshields, and bus structure. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. If Mandan had planned to buy a *new* bus for use as an activity bus, the manufacturer and dealer must certify that the bus complies with the motor vehicle safety standards applicable to school buses.; Since Mandan plans to buy 1963 and 1965 model year buses, however, th Vehicle Safety Act standards do not apply. There is nothing under that Act to prevent Mandan from buying a bus that was manufactured before the effective date of the school bus safety standards for school use. There might, however, be an impediment under State law, if North Dakota has adopted the provisions of the standard on school transportation issued by our agency under the Highway Safety Act (Public Law 89- 564, 23 U.S.C. 401-408). This standard, Highway Safety Program Standard No. 17 (HSPS 17), specifies that a bus used to transport more than 16 pupils to and from school should be painted yellow, be equipped with special mirrors and warning lights, and be marked 'School Bus.' We have ruled that the States should apply these specifications to activity buses as well as to the buses used for daily transportation.; I want to stress that HSPS 17 has no direct effect on Mandan's purchas of 1963 and 1965 model year buses. HSPS 17 will affect Mandan only if North Dakota has adopted it and if North Dakota accepts our view that the specifications apply to activity buses. If North Dakota chooses to exempt activity buses from being painted, signed, and equipped as school buses, we might disagree with the wisdom of its decision but we would not insist on compliance with HSPS 17 to the extent of taking action against the State. Congress has given us discretion under the Highway Safety Act not to insist that a State comply with every requirement of the highway safety standards. While we have stressed the importance of a strong pupil transportation program, consistent with HSPS 17, we have not insisted that the States comply with every feature of the standard.; Having said this, however, I would like to restate the importance tha our agency attaches to the use of safe buses to transport children. It remains the agency's position that a yellow school bus meeting the motor vehicle safety standards is the safest means of transportation for school children. It may not be the most comfortable for long trips, since it lacks the reclining seats and restroom facilities of the Greyhound-type buses, but it has safety features that the Greyhound-type buses that you are considering lack, such as seat backs designed to cushion impacts, windows that prevent ejections, and exits that facilitate escape after crashes. In the years since buses began to be manufactured with these features, there has been a marked improvement in school bus safety. These are features that Mandan should consider before it decides to buy a Greyhound-type bus.; Your second question asked whether Mandan may charter Greyhound-typ buses from a common carrier to transport students to school-related events.; Again, Mandan would not be precluded from chartering Greyhound-typ buses if North Dakota has not adopted our view that the specifications of HSPS 17 apply to activity buses.; If you have any further questions, please do not hesitate to contac us.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1849OpenMr. Robert Marx, State Representative, District No. 34, Polk-Benton, House of Representatives, Salem OR 97310; Mr. Robert Marx State Representative District No. 34 Polk-Benton House of Representatives Salem OR 97310; Dear Mr. Marx: This is in response to your letter of March 10, 1975, requestin information concerning correspondence from one of your constituents, Mr. Jim Lee Martin, commenting on a proposed amendment to the Federal Bumper Standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1970 (sic) model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two ageny- sponsore (sic) studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Martin has directed his comments to what he believes to be proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face (plastic) systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2766OpenMr. William J. Wood, Nebraska Dept. of Motor Vehicles, Statehouse Station 94612, Lincoln, NE 68509; Mr. William J. Wood Nebraska Dept. of Motor Vehicles Statehouse Station 94612 Lincoln NE 68509; Dear Mr. Wood: This responds to your January 16, 1978, letter asking several question about the applicability of the school bus regulations to school buses manufactured after April 1, 1977, transporting 10 or more students to or from school or related events.; You first ask whether these buses must be painted yellow and hav school bus lighting and markings. The answer to your question is yes. Any vehicle that transports 10 or more students to or from school or related events is a school bus and must have the painting, marking, and lighting of a school bus.; Your second question is whether smaller school buses (vans) ar permitted to have van-type seats or must comply with the requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*. A vehicle that transports 10 or more students must comply with all of the Federal school bus regulations, including the seating standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5109OpenMr. Rodney T. Nash, P. E. Vice President Engineering Collins Industries, Inc. 421 East 30th Avenue Hutchinson, KS 67502-2493; Mr. Rodney T. Nash P. E. Vice President Engineering Collins Industries Inc. 421 East 30th Avenue Hutchinson KS 67502-2493; "Dear Mr. Nash: This responds to your letter to the Administrator National Highway Traffic Safety Administration (NHTSA), received in this office on November 18, 1992, and your telephone conversation of November 30, 1992 with Walter Myers of this office, regarding the proper classification of an ambulance. You indicated that Wheeled Coach Industries of Orlando, Florida, a subsidiary of Collins Industries, produces ambulances that are built on truck chassis. You stated that in the past those vehicles have been classified as trucks, but that Ford Motor Company auditors told you that they should be classified as multipurpose passenger vehicles (MPV). You said that you needed to know how to classify ambulances, observing that it appeared to you that the final stage manufacturer was free to choose between the two classifications, truck or MPV. NHTSA has long considered ambulances to be multipurpose passenger vehicles, which are defined in 49 Code of Federal Regulations (CFR) 571.3 as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' Your company's ambulances fit this definition very well: they are mounted on a truck chassis and are designed to carry ten persons or less. As you pointed out in your letter, it is true that an ambulance may carry more weight in special equipment than it carries in patients, and it may operate half its life with no patient on board. Nevertheless, NHTSA believes that whether or not a patient is on board or how much equipment is carried, the vehicle is primarily designed for the transportation and/or care of ill or injured persons, as well as the transportation of paramedic personnel to wherever they are needed. This is in contrast to a truck which is defined also in 49 CFR 571.3 as 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment'. Thus, although an ambulance carries special purpose equipment, NHTSA believes that the equipment is only ancillary to the primary function of an ambulance which is the transportation of persons. Accordingly, an ambulance falls within the definition of MPV rather than truck. I hope this will help clarify this issue for you. Should you have any further questions in this regard, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Assistant Chief Counsel for Rulemaking"; |
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ID: aiam2336OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your March 24, 1976, letter, concerning th label required by S 567.4(g) of 49 CFR Part 567, *Certification*.; The certification label is required by paragraph (g)(3) to includ ''GROSS VEHICLE WEIGHT RATING' or 'GVWR' followed by the appropriate value in pounds...' Paragraph (g)(4) specifies a similar requirement for Gross Axle Weight Rating.; You have pointed out that the Canadian motor vehicle safety regulation require a similar certification label with these weight ratings expressed in kilograms. You have asked whether a single label that expresses the weight ratings in both pounds and kilograms would be permitted by 49 CFR Part 567. The answer is yes, provided that each kilogram rating, which is optional, appear after the corresponding pound rating, which is required.; Please note that these two ratings differ in legal status. The ratin that is expressed in pounds is the official rating for the purposes of the United States Federal motor vehicle safety standards and regulations. The accompanying equivalent kilogram rating, however, will be considered as optional, supplementary information provided for the guidance of the reader. This distinction is necessary, because the measurement values, including weights, that appear in our safety standards and regulations are specified in exact terms, without tolerances. While a measurement in English units can be 'equal' to one in metric units to any preselected number of significant figures, the two can never be exactly equal.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam4431OpenMr. Hiroshi Kato MMC Services Inc. 3000 Town Center Suite 1960 Southfield, MI 48075; Mr. Hiroshi Kato MMC Services Inc. 3000 Town Center Suite 1960 Southfield MI 48075; "Dear Mr. Kato: This is in response to your letter of April 19, 1988 concerning whether a Mitsubishi Motors Corporation SH27 lightweight industrial truck that you intend to offer for sale in the United States should be classified as a motor vehicle under Section 102(3) of the National Traffic and Motor Vehicle Safety Act ('Safety Act'). You stated that this vehicle is intended for 'general or carrier work for off-road applications,' and that it is capable of a maximum speed of approximately 25 mph. You further explained that your company planned to advertise, promote, and market this vehicle as an off-road vehicle. Based on the information provided in your letter, it appears that the SH27 would not be a motor vehicle under the Safety Act. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. NHTSA has interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., airport runway vehicles and underground mining devices) are not considered motor vehicles, even though they may be operationally capable of highway travel. Vehicles that have an abnormal body configuration that readily distinguishes them from other highway vehicles and a maximum speed of 20 miles per hour (mph) are not considered motor vehicles, because their use of the public roads is intermittent and incidental to their primary intended off-road use. On the other hand, vehicles that use the public highways on a necessary and recurring basis are motor vehicles. For instance, a utility vehicle like the Jeep is plainly a motor vehicle, even though it is equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, then NHTSA has interpreted the vehicle to be a 'motor vehicle'. Further, the agency has determined that a vehicle such as a dune buggy is a motor vehicle if it is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, regardless of the manufacturer's stated intent regarding the terrain on which the vehicle is to be operated. Your vehicle is not easily classified under either of these groupings. On the one hand, your vehicle has a body configuration nearly identical to standard trucks, can be registered for use on the highways of several foreign countries, and can obtain a a maximum speed of approximately 25 mph. These factors suggest that the vehicle should be classified as a motor vehicle. On the other hand, you stated that this vehicle is intended to be used only for off-road applications and that this vehicle will be advertised and promoted for off-road purposes only and will contain four warning labels stating 'Warning: Off Road Use Only.' These factors suggest that the vehicle should not be classified as a motor vehicle. In instances where the agency is asked whether a vehicle is a motor vehicle when it has both off-road and on-road operating capabilities, and about which there is little or no evidence about the extent of the vehicle's on-road use, the agency has applied five factors in offering its advice. These factors are: 1. Whether States or foreign countries have permitted or are likely to permit the vehicle to be registered for on-road use. You noted that several foreign countries including Japan and Taiwan register for on-road use the general export configuration of this vehicle. This suggests that your vehicle should be considered a motor vehicle. You attempted to distinguish this fact by stating that the vehicle to be sold in the United States has different specifications than the general export vehicles. The differences are that the United States version has a maximum speed of 25 mph while the general export version can achieve speeds of greater than 55 mph, the engine displacement in the United States version has an engine of 548 cc rather than the 796 and 783 cc for the general export version, and the United States version has an hourmeter (similar to agricultural vehicles) rather than a speedometer. You stated that these differences mean that there is little basis for assuming that the experience in other countries would correlate to the likelihood of States permitting the vehicle to be registered for highway use in the United States. Since the vehicle closely resembles a small truck for highway use, we believe it is likely that States would permit it to be registered for highway use, just as other countries have. Therefore, this factor suggests that your vehicle should be considered a motor vehicle. 2. Whether the vehicle is or will be advertised for use on-road as well as off-road, or whether it is or will be advertised exclusively for off-road use. You stated that your advertising and promotional materials will state that your vehicle should be used only for off-road purposes and will not depict or suggest that the vehicle can be used on-road. This factor suggests that the vehicle should not be considered a motor vehicle. 3. Whether the vehicle's manufacturer or dealers will assist vehicle purchasers in obtaining certificates of origin or title documents to register the vehicle for on-road use. You stated that your dealers will be instructed that this vehicle is to be used solely for off-road purposes and that no assistance should be given to obtain a title for the vehicle or to register the vehicle in this country. Your company also will state on any ownership document that this vehicle is not intended for on-road use. Therefore, this factor would indicate that the vehicle should not be considered a motor vehicle. 4. Whether the vehicle is or will be sold by dealers also selling vehicles that are classified as motor vehicles. You stated that this vehicle will only be sold by dealerships that sell vehicles other than motor vehicles, such as material handling equipment like lifts and agricultural equipment. This factor suggests that the vehicle should not be considered a motor vehicle. 5. Whether the vehicle has or will have affixed to it a warning label stating that the vehicle is not intended for use on the public roads. You stated that four warning labels will be affixed to the interior and exterior of the vehicle body. Labels stating 'Off Road Use Only' will be applied to the exterior front panel of the cab, the rear gate, and the instrument panel. Additionally, a label stating 'Warning: Off Road Use Only' will be affixed to the exterior rear panel of the cab. This factor would indicate that the vehicle is not a motor vehicle. Based on the representations in your letter, the agency believes that the Mitsubishi SH27 lightweight truck does not appear to be a motor vehicle under the Safety Act. However, we will reexamine this conclusion if we learn that, for example, the vehicle is in fact used on the public roads by a substantial number of its owners. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel /"; |
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ID: aiam1633OpenMr. F.S. Vukan, B.F. Goodrich Tire Company, 500 South Main Street, Akron, Ohio 44318; Mr. F.S. Vukan B.F. Goodrich Tire Company 500 South Main Street Akron Ohio 44318; Dear Mr. Vukan: #This is in further reply to your letter of August 21 1974, asking whether tires manufactured by B.F. Goodrich that are filled with 'Tyrfil' will be subject to the requirements of Motor Vehicle Safety Standard No. 119. #On the basis of the information you have provided, we have determined that tires filled with Tyrfil are not 'pneumatic' tires, and are therefore subject neither to the requirements of Standards Nos. 109 nor 119. We find that Tyrfil, which is a solid polyurethane, differs significantly as a tire-filling medium from cellular foam, whose use has been determined to be within the scope of Standards Nos. 109 and 119 (37 FR 24908, November 23, 1972). #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs; |
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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.