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: aiam1259OpenMr. Arthur G. Vara, Sr., Octopus Road Safety Devices, Inc., 53 Clark Street, Hamburg, New York 14075; Mr. Arthur G. Vara Sr. Octopus Road Safety Devices Inc. 53 Clark Street Hamburg New York 14075; Dear Mr. Vara: This is in response to your September 4, 1973, petition for rule makin to amend Standard 125, *Warning devices*, to permit the triangular portion of the device to tilt to a position of 30 degrees from the vertical when subjected to winds of 40 mph from any direction for 3 minutes.; The present standard permits 10 degrees tilt under these condition Rowland Development Corporation of Kensington, Connecticut, and Safety Triangles Company of Phoenix, Arizona, have also requested modification of the tilt rule to permit 30 degrees movement. The NHTSA determined that such tilting distorted the distinctive shape of the equilateral triangle and reduced its reflective characteristics. There factors outweighed the claimed benefits of the proposed change. The NHTSA published its decision in the Federal Register on January 30, 1973 (Docket No. 4-2, Notice 6, 38 F.R. 2760).; We have considered your phone calls and your letters of July 25, 1973 August 4, 1973, and September 4, 1973, to the Office of Operating Systems. One letter enclosed a report dated July 13, 1973, which indicates that your device may tilt as much as 80 degrees, which distorts its appearance and reduces its reflective ability. The NHTSA has concluded that the rapid 'flickering' movement which you consider a desirable feature of your device does not outweigh these disadvantages. Therefore, in conformity with our response to earlier petitions for a 30 degrees tilt, your petition is denies. A copy of the previous denial is enclosed for your information.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0018OpenMr. Roddy Williams Container Enterprise 3900 Paris Road P.O. Box 1098 Chalmette, LA 70044-1098; Mr. Roddy Williams Container Enterprise 3900 Paris Road P.O. Box 1098 Chalmette LA 70044-1098; "Dear Mr. Williams: This responds to your letter that asked whethe your company is permitted to assign its own Vehicle Identification Numbers (VINs) pursuant to Federal Motor Vehicle Safety Standard No. 115, Vehicle Identification Number--Basic Requirements (49 CFR 571.115) to trailers that it 'remanufactures' from previously used trailers. The answer is that a company that performs the remanufacturing operations described in your letter may assign a new VIN to its remanufactured trailers. By doing so, however, the trailers would be treated as newly manufactured trailers for the purposes of this agency's safety standards and regulations. Among other things, this would mean that your company would be required to certify that the trailers comply with all applicable safety standards in effect as of the date of the remanufacturing operations, including the lighting, tire, and brake standards applicable to new trailers. In a telephone conversation with Dorothy Nakama of my staff, you stated that your company, Container Enterprise, works on trailers that were used to carry cargo containers. You stated that approximately 90% of the trailers that Container Enterprise works on were originally built between 1974 and 1979. Container Enterprise takes used container chassis that are 23 feet long and removes the axles and half of the crossmembers on the original frame. Container Enterprise then manufactures a 12 foot subframe and reinstalls the used axles on this subframe. The subframe is then attached to the container chassis, extending its chassis length to 27 feet. The conversion allows the chassis to slide open or closed. You stated that upon completion of this process, Container Enterprise will issue 'a new manufacturer plate with a new VIN number' and date of remanufacture. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) authorizes this agency to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 115, which applies to all new vehicles. S4.1 of Standard No. 115 specifies that vehicles manufactured in one stage shall have a VIN assigned by the vehicle manufacturer and S4.5 specifies that the assigned VIN shall appear clearly and indelibly on the vehicle. Thus, the only person that can assign a VIN to a vehicle is the vehicle's manufacturer. The question then is whether your company's 'remanufacturing' operations are substantial enough that the remanufactured trailers should be considered to be new vehicles and the manufacturer of those vehicles would be your company, instead of the original manufacturer of the trailer. NHTSA's regulations specifically address the question of when trailers produced by combining new components (the subframe fabricated by your company) and used components (the parts of the used container chassis) are considered to be new trailers. 49 CFR 571.7(f) states that when new and used components are used in trailer manufacture, the trailer will be considered 'newly manufactured' unless the following three conditions are met. First, the trailer running gear assembly, which includes the axle(s), wheels, braking and suspension, is not new, and was taken from an existing trailer. Second, the existing trailer's identity is continued in the reassembled vehicle with respect to the Vehicle Identification Number. Third, the existing trailer is owned or leased by the user of the reassembled vehicle. You have stated that your company would assign new VINs to the trailers it remanufactures. Upon doing so, the second condition in 571.7(f), continuing use of the original VIN, would not be met. Therefore, the trailers 'remanufactured' by your company would be considered to be newly manufactured. Your company, as the manufacturer, must certify that these trailers comply with all applicable Federal motor vehicle safety standards in effect at the time of the remanufacture. This means that, in addition to complying with the 1991 requirements of Standard No. 115, your company would be required to certify that the trailers comply with the 1991 versions of the lighting standard (Standard No. 108), the tire and rim standard (Standard No. 120), and the air brake standard (Standard No. 121), to name a few examples of applicable standards. To assist you in making any such certifications, I am enclosing a brochure that briefly describes each of the safety standards and an information sheet for new manufacturers of motor vehicles that explains how to get copies of our standards and regulations. Your letter also referred to U. S. Department of the Treasury Publication 510 on Excise Taxes. We can only tell you that your remanufactured trailers with new VINs would be considered new vehicles for the purposes of the Safety Act and the Federal motor vehicle safety standards. If you have any questions about the trailers for purposes of excise taxes, you should contact the Internal Revenue Service. Their District Office for Louisiana is located at 500 Camp Street, New Orleans, LA 70130. I hope this information is helpful. If you have any additional questions, please feel free to contact Ms. Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam2025OpenMr. H. Ray Cozad, Chief Engineer, Crane & Excavator Division, 1201 Sixth Street Southwest, Cedar Rapids, IA 52406; Mr. H. Ray Cozad Chief Engineer Crane & Excavator Division 1201 Sixth Street Southwest Cedar Rapids IA 52406; Dear Mr. Cozad: This responds to your July 28, 1975, letter asking whether the unloade vehicle weight of a mobile crane carrier would include components that are essential to its specialized function but are not removed for transit purposes. You also suggest alternative wording for a particular exclusion criterion proposed for mobile crane carriers and similar vehicles under Standard No. 121, *Air Brake Systems*.; I have enclosed a copy of a recent notice that amends Standard No. 121 The preamble to the notice deals with the issues you have raised and should make clear to you that vehicle components are not generally considered part of the rated cargo capacity and therefore would not be subtracted from a vehicle's gross vehicle weight rating to determine the unloaded vehicle weight.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4958OpenMr. Phil Gray Inventor Westech U.S.A. Inc. Airport Road (P.O. Box 629) Franklin County Airport Swanton, VT 05488; Mr. Phil Gray Inventor Westech U.S.A. Inc. Airport Road (P.O. Box 629) Franklin County Airport Swanton VT 05488; "Dear Mr. Gray: This responds to your letter asking how the laws an regulations administered by this agency would apply to a product you have invented. The device is a flexible plastic stalk that reroutes the shoulder belt to improve the shoulder belt fit for children that have outgrown child safety seats. I am pleased to have this chance to explain our laws and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) authorizes this agency to issue motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 208, Occupant Crash Protection (49 CFR 571.208). This standard requires new motor vehicles to be equipped with safety belts and requires that those belts meet specified fit and comfort requirements, as set forth in S7 of the standard. However, Standard No. 208 does not apply to aftermarket items that seek to alter belt fit and/or comfort. Hence, your company is not required to certify that this product complies with Standard No. 208 before offering the product for sale. In addition, you are not required to get some sort of 'approval' from this agency before offering this product for sale. NHTSA has no authority to 'approve' motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. As stated above, this product is not subject to any safety standard, so your company does not have to make any certification. Although none of our safety standards directly apply to this product, there are several provisions in the Safety Act that are relevant. Manufacturers of motor vehicle equipment such as your belt positioning device are subject to the requirements in sections 151-159 of the Safety Act (15 U.S.C. 1411-1419) concerning the recall and remedy of products with defects related to motor vehicle safety. Your letter indicated that you were aware of this responsibility and your company would carry out any necessary recalls if problems should become apparent with this device when it is used by the public. In addition, use of your product could be affected by section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits manufacturer, distributors, dealers, and repair shops from knowingly 'rendering inoperative,' in whole or in part, any device or element of design installed on or in a vehicle in compliance with an applicable safety standard. There are two elements of design in a vehicle that might be 'rendered inoperative' by the use of your company's belt positioning device. One is the occupant protection afforded by belts that meet the specified fit and comfort requirements. The other element of design that could be rendered inoperative by the use of your belt positioning device is the burn resistance required by Standard No. 302, Flammability of Interior Materials (49 CFR 571.302). The materials used in the interior of vehicles, including the seat belts, seat backs and cushions, trim panels, and headliner must comply with the burn resistance requirements of Standard No. 302 to reduce deaths and injuries in the event of a fire in the vehicle's interior. If your belt positioning device renders inoperative the belt fit and comfort requirements specified in Standard No. 208 or does not comply with burn resistance requirements, it could not be installed in a vehicle by any manufacturer, distributor, dealer, or repair shop. I have enclosed a general information sheet for new manufacturers that gives a thumbnail sketch of NHTSA's regulations and provides information on how to obtain copies of those regulations. I hope that this information is helpful. If you have any further questions or need some additional information, please feel free to contact Steve Kratzke 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: aiam0448OpenMr. Joseph M. Mazzafro, Manager, Production Engineering, Strick Corporation, U. S. Highway No. 1, Fairless Hills, PA, 19030; Mr. Joseph M. Mazzafro Manager Production Engineering Strick Corporation U. S. Highway No. 1 Fairless Hills PA 19030; Dear Mr. Mazzafro: This is in reply to your letter of September 21, 1971, to Mr. Dougla Toms, Administrator, National Highway Traffic Safety Administration, requesting an interpretation on the mounting of identification lamps on your trailers.; We hesitate to agree with you that it is not practicable to mount th identification lamps at the extreme height of the trailer. It would appear to be practicable to mount these lamps at the extreme height, even if a shield were necessary to prevent damage to the lamps during use.; If the identification lamps are mounted at the extreme height of th trailer, the clearance lamp mounting height is optional, therefore, clearance lamps could be mounted on the rear crossmember, as shown on your drawing SK-24139.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam2475OpenMr. R. E. Weil, Exterior Lighting Development, Chrysler Corporation, P.O. Box 1118, Detroit, MI, 48231; Mr. R. E. Weil Exterior Lighting Development Chrysler Corporation P.O. Box 1118 Detroit MI 48231; Dear Mr. Weil: This is in reply to your letter of September 16, 1976, to Mr. Brooks o this agency on photometric test requirements of multiple compartment and multiple lamp configurations. You have asked for our concurrence on two interpretations of Standard No. 108, as discussed below.; In your 'example 1', on vehicles designed with a two lamp system parking and (or taillamp) and turn signal functions are combined in each lamp of the two lamp system. You have asked whether the second lamp in this system would be treated as supplemental and need not meet the photometric requirements for required lamps.; The answer is no. As you are aware the photometric requirements o multiple lamps or multiple compartment lamps, where a tail or parking lamp is combined with the turn signal lamp, are partially determined by Note 4 to SAE Standard J588e *Turn Signal Lamps*. Note 4 establishes permissible ratios of intensity between functions *i*. *e*. that the intensity of the tail or parking lamps shall not be so great as to diminish the effectiveness of the turn signal function. Where two lamps are used and the distance between filament centers does not exceed 22 inches (as appears to be the case here) the combination of the lamps must be used to meet the photometric requirements for the corresponding number of lighted sections. (Paragraphs 3.1 of J585d, J588e). Further, the ratio of the turn signal to the tail or parking lamps must be computed with all the lamps lighted (Note 4). With reference to those vehicles designed with a two-lamp system (your example 1), your first answer is the correct one, the lamps would be photometered together to meet the two compartment requirements for the two lamp functions performed, as specified in Table 1 of Standard No. 108.; With respect to your example 2, a multiple compartment lamp with on compartment performing turn signal and parking or tail lamp functions, and the other portion the function of parking or tail lamp only, photometric requirements for the tail lamp function are determined on the basis of the output of the two compartments. The single compartment parking lamp may, however, be treated as a 'supplemental' lamp, except that the candlepower ratios (with turn signal lamp) must be met with both parking lamp compartments illuminated.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0366OpenMrs. Annemarie Shelness, Physicians for Automotive Safety, 50 Union Avenue, Irvington, NJ 07111; Mrs. Annemarie Shelness Physicians for Automotive Safety 50 Union Avenue Irvington NJ 07111; Dear Mrs. Shelness: Thank you for your letter of May 24, 1971, informing us of Mr. Hurley' Safe-Trip-Seat and inquiring about enforcement of Standard No. 209 concerning a non-complying Hankscraft child harness.; Mr. Hurley sent us a letter on April 10, 1971, informing us of hi device. Our letter to him was sent out on May 10, 1971, so he had not received it when he wrote to you. I believe we have adequately informed him of his lack of compliance with Standard No. 213 and the penalties involved if he does not. A copy of our letter to him is enclosed for your information. Our compliance personnel were also alerted on the Safe-Trip-Seat.; Hankscraft was notified in a letter dated March 23, 1971, of ou position on any child harness (copy enclosed). Please note that we will enforce Standard No. 209 on harnesses advertised in any way to provide any measure of protection in a vehicle accident. We will not enforce the requirements of Standard No. 209 of harnesses which carefully state that they are not intended to protect a child from the effects of an accident.'; A copy of this letter is being forwarded to our compliance personne for appropriate action by them.; Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs; |
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ID: aiam5164OpenMr. Brett J. Higgins 10257 Slater Ave. #103 Fountain Valley, CA 92708; Mr. Brett J. Higgins 10257 Slater Ave. #103 Fountain Valley CA 92708; "Dear Mr. Higgins: This responds to your letter of March 25, 1993 t former Chief Counsel Paul Jackson Rice seeking information on how the laws and regulations administered by this agency would apply to an item of equipment you wish to sell. According to your letter, the item is a special clamp that is applied to the shoulder strap of a seatbelt as an after-market item. The purpose of this clamp is to allow for slack in the shoulder harness section of a seatbelt thus allowing it to be worn more comfortably. I am pleased to have this opportunity to explain our laws and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) authorizes this agency to issue motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 208, Occupant Crash Protection (49 CFR 571.208). This standard requires new motor vehicles to be equipped with safety belts and requires that those belts meet specified fit and comfort requirements, as set forth in S7 of the standard. However, Standard No. 208 does not apply to aftermarket items that seek to alter belt fit and/or comfort. Hence, you are not required to certify that this device complies with Standard No. 208 before offering the device for sale. In addition, you are not required to get some sort of 'approval' from this agency before offering this device for sale. NHTSA has no authority to 'approve' motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self- certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. As stated above, this device is not subject to any safety standard, so you do not have to make any certification. Although none of our safety standards directly apply to this device, there are several provisions in the Safety Act that are relevant. Manufacturers of motor vehicle equipment such as your belt positioning device are subject to the requirements in sections 151-159 of the Safety Act (15 U.S.C. 1411-1419) concerning the recall and remedy of products with defects related to motor vehicle safety. In addition, use of your product could be affected by section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits manufacturer, distributors, dealers, and repair shops from knowingly 'rendering inoperative,' in whole or in part, any device or element of design installed on or in a vehicle in compliance with an applicable safety standard. There are two elements of design in a vehicle that might be 'rendered inoperative' by the use of your belt positioning device. One is the occupant protection afforded by belts that meet the specified fit and comfort requirements. The other element of design that could be rendered inoperative by the use of your device is the burn resistance required by Standard No. 302, Flammability of Interior Materials (49 CFR 571.302). The materials used in the interior of vehicles, including the seat belts, seat backs and cushions, trim panels, and headliner must comply with the burn resistance requirements of Standard No. 302 to reduce deaths and injuries in the event of a fire in the vehicle's interior. If your device renders inoperative the belt fit and comfort requirements specified in Standard No. 208 or does not comply with burn resistance requirements, it could not be installed in a vehicle by any manufacturer, distributor, dealer, or repair shop. I note that NHTSA has received a number of inquiries about devices similar to the one you plan to sell. As we have advised others, this agency is concerned that a belted occupant could inadvertently use such products to introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of that belt. We encourage you to provide instructions with the product that warn users not to introduce excessive slack and provide detailed guidance for users on what is an excessive amount of slack. I have enclosed a general information sheet for new manufacturers that gives a thumbnail sketch of NHTSA's regulations and provides information on how to obtain copies of those regulations. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam0736OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment and Body Distributors Assn., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment and Body Distributors Assn. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of June 9 asking whether pole trailer must be certified.; The answer is no. According to 49 CFR S 567.2(a), only motor vehicle to which one or more Federal motor vehicle safety standards are applicable must be certified. The only Federal standard currently in effect that applies to 'trailers', Standard No. 108, specifically exempts 'pole trailers' from its applicability and therefore pole trailers need not be certified.; Your letter of February 23 regarding clearance lamps and identificatio lamps is still under consideration and we hope to provide a response in the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1824OpenHonorable Harley O. Staggers, Chairman, Committee on interstate and Foreign Commerce, House of Representatives, Washington, DC 20515; Honorable Harley O. Staggers Chairman Committee on interstate and Foreign Commerce House of Representatives Washington DC 20515; Dear Mr. Chairman: Thank you for your February 19, 1975, request for our evaluation o Representative B. F. Sisk's concern that the National Highway Traffic Safety Administration (NHTSA) has incorrectly interpreted the definition of 'Motor vehicle' as it appears in S 102 of the National Traffic and Motor Vehicle Safety Act of 1966:; >>>Sec. 102. As used in this title -- (3) 'Motor vehicle' means any vehicle driven or drawn by mechanica power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; Mr. Sisk questions whether air-braked trailers which transport far commodities from the field to processing plants or warehouses qualify as motor vehicles under this definition. You also ask for the status of a request for exemption from Standard No. 121, *Air brake systems*, which concerns these vehicles.; The NHTSA has developed criteria for the interpretation of th definition of motor vehicle in the area of heavy vehicles with an off-road function. We conclude that the definition includes vehicles which use the highway on a necessary and recurring basis to move between work sites. We have cited mobile cranes, drill rigs, and towed equipments such as brush chippers and pull-type street sweepers as examples of this motor vehicle class. Following the rationale of necessary and recurring road use, we have excluded from the definition such farm vehicles as mobile feed mixers used strictly in feedlot operations. We believe, however, that the trailers in question have a primary function of highway transportation of bulk produce form the field to the plant.; The Act does not provide a specific exemption for vehicles used i agricultural pursuits. The only reference in the Act to agricultural vehicles is a provision in Title III (as it appeared in 1966) that authorized 'research, development, and testing relating to the safety of machinery used on highways or in connection with the maintenance of highways (with particular emphasis on tractor safety' (S 301). We have interpreted this provision to express Congress' intent that specialized machines which have a strictly non-transportation function (e.g., paving machines, road graders, farm combines, and farm tractors in particular) are not motor vehicles.; With regard to exemption for the trailers in question, we have on request outstanding to exempt these trailers from the parking brake requirements of the standard, because current designs in response to our requirements conflict with the use of these vehicles. We agree that a design that requires parking brake application upon disconnection of the air supply can interfere with storage and marshalling of these vehicles if brake release is not assured after long periods of disconnection. Because of this specific problem in agricultural pursuits, we have decided to undertake rulemaking to exempt these vehicles from that requirement for a year in order to permit manufacturers to modify their designs to solve the problem. We expect to issue a proposal shortly.; I hope that I have been responsive to your questions, and I welcom further opportunity to clarify our interpretations of the National Traffic and Motor Vehicle Safety Act of 1966.; Sincerely, James B. Gregory, Administrator |
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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.