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
| Interpretations | Date |
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ID: aiam4872OpenMr. Paul R. Kirchgraber Souvenirs of the Future Suite 201-71 3435 Ocean Park Blvd. Santa Monica, CA 90405; Mr. Paul R. Kirchgraber Souvenirs of the Future Suite 201-71 3435 Ocean Park Blvd. Santa Monica CA 90405; Dear Mr. Kirchgraber: This is in reply to your letter of April 16 1991, with respect to which Federal motor vehicle safety standards, if any, must be met in order to sell an exterior tire/wheel cover with reflective characteristics that will help to make 'the vehicle more visible to the surrounding traffic.' In addition, you 'want to be certain that the reflective nature of the fabric used in this cover does not present a safety hazard', and ask for the citation to 'appropriate federal test standards from the code of federal regulations for similar automotive accessories.' There are no Federal motor vehicle safety standards that establish performance requirements for reflective material of this nature, or for wheel coverings on exterior-mounted tires. The standard on vehicle lighting, Motor Vehicle Safety Standard No. 108, does prohibit, as original equipment, the installation of a 'reflective device or other motor vehicle equipment' that impairs the effectiveness of lighting equipment required by the standard. It is theoretically possible that your material could create glare in the eyes of a following operator so that (s)he would fail to respond to a stop signal, or a turn signal. The samples submitted with your letter are too small for us to judge its reflectivity, and we suggest that you conduct your own tests, approaching a vehicle with the tire cover from the rear, with headlamps on the lower beam. This, to us, is preferable to your redesigning the material to conform to any federal test standard relating to reflectivity. Although the color of lighting equipment on the rear is generally red, with amber permitted for turn signals, and white required for back up lamps, we do not believe that the use of additional colors would create any confusion. In short, we believe that the wheel cover will be perceived for the wheel cover it is. I hope that this responds to your concerns. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0098OpenMr. John W. Carlin, Calumet Corporation, P. O. Box 389, Kaukauna, WI 54130; Mr. John W. Carlin Calumet Corporation P. O. Box 389 Kaukauna WI 54130; Dear Mr. Carlin: Thank you for your letter of July 22, 1968, to Mr. George C. Nield concerning the applicability and effective date of Motor Vehicle Safety Standard 108.; Standard No. 108 is applicable to new vehicles manufactured on or afte the effective date of the standard. Initial Standard No. 108 was published on February 3, 1967, and became effective January 1, 1968. The initial standard is applicable only to vehicles that are 80 inches or more in overall width. Revised Standard No. 108 was published on December 16, 1967, and becomes effective January 1, 1969. The revised standard is applicable to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers and motorcycles, regardless of overall width, however, the special requirements for vehicles that are 80 inches or more in overall width have been identified in the standard. Copies of the initial and revised standard are enclosed for your information.; In reply to your specific questions, information is provided a follows:; >>>1. With respect to your first question, Standard No. 108 i applicable to trailers manufactured for personal use by an individual and for commercial use.; 2. With respect to your second question, Revised Standard No. 108 effective January 1, 1969, specifies the lighting requirements for trailers that are less than 80 inches in overall width.; 3. With respect to your third question, the regulations of individua States and of the Bureau of Motor Carrier Safety (for vehicles engaged in interstate commerce) presently govern the lighting required on trailers that are less than 80 inches in overall width. Effective January 1, 1969, these trailers will be subject to the requirements of Revised Standard No. 108. Installation and location requirements for the individual lamps are contained in the referenced SAE standards (see Table III of Standard No. 108) and in Table IV of Standard No. 108.<<<; Also enclosed is a copy of the notice of 'Certification Requirement, which provides information on the manufacturer's certification of vehicles that are subject to the Federal motor vehicle safety standards.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam0562OpenMr. Paul M. Frank, Blumberg, Singer, Ross, Gottesman & Gordon, 245 Park Avenue, New York, NY, 10017; Mr. Paul M. Frank Blumberg Singer Ross Gottesman & Gordon 245 Park Avenue New York NY 10017; Dear Mr. Frank: In response to your letter of December 9, 1971, it is correct tha Standard No. 302, 'Flammability of Interior Materials,' applies only to motor vehicles (passenger cars, multipurpose passenger vehicles, trucks, and buses) manufactured on or after September 1, 1972. The standard does not apply to replacement or aftermarket seat covers.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5330OpenMr. Derrick Barker John Martin Designs 1 Clifton St. Stourbridge, West Midlands DY8 3XR; Mr. Derrick Barker John Martin Designs 1 Clifton St. Stourbridge West Midlands DY8 3XR; Dear Mr. Barker: This responds to your letter concerning the buckl release requirement of Federal Motor Vehicle Safety Standard No. 213, 'Child Restraint Systems.' I apologize for the delay in responding. You asked for the 'tensile load requirements for the buckle and tongue.' There is no specific requirement in Standard 213 for the tensile force that a child restraint buckle must withstand. Instead, the buckle must maintain its integrity when the child restraint is subjected to a simulated frontal impact at 30 mph with either a six-month-old (17 pounds (lbs.)) or three-year-old (33 lbs.) sized dummy restrained in the car seat. At the conclusion of the simulated impact, the force required to depress the latch button to release the buckle is measured and must be 16 lbs. or less. You also asked for a copy of Procedure D of the American Society for Testing and Materials Standard D756-78. Section S5.4.2 of FMVSS No. 213 sets forth those requirements by making reference to section S4.3(b) of FMVSS No. 209. which, in turn, leads to the reference to Procedure D of ASTM D756-78. The material you requested is enclosed. In addition, you asked for a list of laboratories that test child safety seats and buckles. NHTSA does not endorse particular test laboratories. However, I can provide you with a list of laboratories we are aware of that conduct child restraint compliance tests. There may be other laboratories that can test child safety seats and buckles. Please contact Ms. Deirdre Fujita of my staff if you have further questions. Sincerely, John Womack Acting Chief Counsel Enclosures; |
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ID: aiam0132OpenMr. 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: Thank you for your letter of November 8, 1968, requesting clarification of the 30g horizontal inertia load direction specified in Standard No. 201, as published in the *Federal Register* on October 25, 1968.; In section S3.3.1(c), 'Subject the interior compartment door latc system to a horizontal inertia load of 30g in a longitudinal direction...' means both forward and rearward directions. In addition, the loads specified in S3.3.1(a) are applied in both the inboard and outboard and the up and down directions. This is consistent with similar type requirements in Standard No. 206.; You state that a forward and rearward 30g inertia load requirement i more stringent than the alternative procedure of S3.3.1(b), the barrier test. The Bureau believes, and one large manufacturer so stated in his comments, that the most meaningful test of the ability of an interior compartment door to remain closed is one which considers the distortion an deformation loads that occur in a collision. A barrier or equivalent dynamic test is the best way of realistically evaluating the ability of these doors to remain closed. The bureau, therefore, believes that the barrier test is as stringent a requirement as S3.3.1(c).; Sincerely, William Haddon, Jr., M.D., Director |
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ID: aiam1689OpenMr. Curtis Eddy, Vice President - Engineering, Matlock Truck Body and Trailer Corporation, P. O. Box 7385, Nashville, TN 37210; Mr. Curtis Eddy Vice President - Engineering Matlock Truck Body and Trailer Corporation P. O. Box 7385 Nashville TN 37210; Dear Mr. Eddy: This is in reference to your defect notification campaign (NHTSA No 74-0203) concerning trailers equipped with Standard Forge axles which may have defective brake shoes.; The letter which you have sent to the owners of the subject trailer does not completely meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoes. Part 577.4(b), however, requires that in cases where a vehicle manufacturer is notifying owners of vehicles, the letter must state that a defect exists in the vehicle itself. The reference to motor vehicle equipment applies only to equipment campaigns where vehicles are not directly involved. Your letter also fails to adequately evaluate the risk to traffic safety as required by Part 577.4(d) since it does not state that the vehicle crash without warning may occur. Although the statement that reduced braking power or lockup may result may suggest the possibility of a crash to many owners, it is not entirely adequate.; Although mailing of a revised notification letter will not be required it is expected that in the event that another defect notification campaign ever becomes necessary in the future, the notification letters conform completely with the regulations.; A copy of Part 577 is enclosed. If you desire further information please contact Messrs. W. Reinhart or James Murray of this office at (202) 426- 2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam4171OpenFrederick B. Locker, Esq., Locker Greenberg & Brainin, P.C., One Penn Plaza, New York, NY 10001; Frederick B. Locker Esq. Locker Greenberg & Brainin P.C. One Penn Plaza New York NY 10001; Dear Mr. Locker: This responds to your June 4, 1986 letter to Mr. Francis Armstrong, th former Director of this agency's Office of Vehicle Safety Compliance. In that letter, you referred to the preliminary compliance test data sheet showing that the Kolcraft 'Flip N Go' booster seat failed to comply with section S5.2.4 of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). You stated that this preliminary noncompliance finding was based on a misinterpretation and misapplication of section S5.2.4. I conclude that Mr. Armstrong was acting on a correct interpretation of that section and properly applied it to the Kolcraft 'Flip N Go' booster seat.; For your information, section S5.2.4 reads as follows: >>>*Protrusion limitation*. Any portion of a rigid structural componen within or underlying a contactable surface, or any portion of a child restraint system surface that is subject to the requirements of S5.2.3 shall, with any padding or other flexible overlay material removed, have a height above any immediately adjacent restraint system surface of not more than 3/8 inch and no exposed edge with a radius of less than 1/4 inch.<<<; You asserted that S5.2.4 does not apply to the 'Flip N Go' Seat. As yo read S5.2.4, it applies only to child restraint systems that are also subject to S5.2.3. You note that the 'Flip N Go' seat is not recommended for children weighing less than 20 pounds, so the requirements of S5.2.3 are not applicable to it. You then conclude that the requirements of S5.2.4 should also not be applicable to that seat.; Your assertion is, however, based upon the misplacing of the firs comma in your quotation of S5.2.4. As S5.2.4 was quoted in your letter, the comma appeared as follows 'restraint system surface, that is subject.' In fact, there is no comma in that location. One does appear earlier: 'contactable surface, or any portion.' As you see from the correct version of S5.2.4 set forth above, it applies to both--; >>>(1) any portion of a rigid structural component within or underlyin a contactable surface, *AND; (2) any portion of a child restraint system surface that is subject t the requirements of S5.2.3.<<<; Since we both agree that the 'Flip N Go' seat is not subject to th requirements of S5.2.3, the question is whether all portions of its rigid structural components within or underlying a contactable surface satisfy the requirements of S5.2.4. Section S4 of Standard No. 213 defines a 'contactable surface' as 'any child restraint system surface (other than that of a belt, belt buckle, or belt adjustment hardware that may contact any part of the head or torso of the appropriate test dummy, specified in S7, when a child restraint system is tested in accordance with S6.1.' The preliminary compliance test data sheet for the 'Flip N Go' seat indicates that four different surfaces on the shield and shield support arms appear to fail to comply with the requirements of S5.2.4.; The first surface listed as not appearing to comply with S5.2.4 was th horizontal upper-forward edge of the shield, which has a radius of less than 1/4 inch. Your response is that this surface is not capable of being contacted by the child's head or neck. We disagree with you. However, even if the test dummy's head and neck failed to contact this edge, the dummy's torso *would* contact that surface. The torso contact would make the edge a contactable surface under S5.2.4, which prohibits the edge from having a radius of less than 1/4 inch. Accordingly, this edge does not appear to comply with S5.2.4, regardless of whether it is contacted by a child's head, neck, or torso.; The outboard left and right vertical edges of the shield support arm appear not to comply with two requirements of S5.2.4. First, the edges have radii of less than 1/4 inch. Second, the edges protrude more than 3/8 inch above the immediately adjacent shield surface. Your response to this was that the entire shield surface is integral and must be considered as a whole. When consider in this way, you stated that the edges of the shield support arms comply with S5.2.4. We cannot agree with your interpretation.; There is no basis in Standard No. 213 for your position that 'integral shields are considered as a whole for the purposes of S5.2.4. The only question under S5.2.4 is whether a contactable surface incorporates projections or narrow edges that could subject the child occupant to pressure point loading in the event of a crash. If the contactable surface incorporates such projections or narrow edges, it does not comply with S5.2.4. Since the edges of the shield support arms on the 'Flip N Go' seat are contactable surfaces which incorporate projections and have edge radii that are prohibited by S5.2.4, the edges of the shield support arms do not appear to comply with S5.2.4.; The third surfaces noted as not appearing to comply with S5.2.4 wer the inboard vertical surfaces of the shield support arms, because those surfaces have edges with radii of less than 1/4 inch. Your response to this was to repeat your integral shield argument and to state that Standard No. 213 does not require oblique crash simulations. This latter point was in response to the following statement in the preliminary compliance test data report: 'These edges and those described in (2) above could be contacted by the occupant in oblique crashes.'; This statement is not the reason for the preliminary determination tha those edges do not comply with S5.2.4 of Standard No. 213. It was included only to point out the actual safety hazard that could be presented to occupants of the 'Flip N Go' seat in a crash. The reason for the preliminary determination is that these edges appear to be contactable surfaces within the meaning of S4, and the edges have radii of less than 1/4 inch. I apologize for any confusion the statement about oblique crashes may have caused.; The fourth surface noted as not appearing to comply with S5.2.4 was th extreme bottom horizontal surface of the shield, with a radius of less than 1/4 inch. Additionally, that surface is supported by seven smaller vertical ribs, five of which are contactable and have edge radii of less than 1/4 inch. The data sheet concluded, 'All of these edges may be contacted by the occupant's thighs or lower abdomen.'; You responded to this by repeating your integral shield argument, an stating that the requirements of S5.2.4 are applicable only to situations involving head impact protection. Accordingly, you stated that S5.2.4 was not intended to address contact with the shield by an occupant's thighs or lower abdomen.; As noted above, section S5.2.4 requires all portions of the shiel within or underlying a 'contactable surface' to have no protrusions. A contactable surface refers to portions of the restraint that may contact any part of the head or *torso*. Section S4 of Standard No. 213 defines the term 'torso' as 'the portion of the body of a seated anthropomorphic test dummy, excluding the thighs, that lies between the top of the child restraint seating surface and the top of the shoulders of the test dummy.' Thus, the thighs would not be considered part of the torso, but the lower abdomen would. Section S5.2.4 is intended to prevent or reduce injuries to the torso, including the lower abdomen. Thus, any edge contactable by the test dummy's lower abdomen must have a radius of at least 1/4 inch to comply with S5.2.4. Since these edges have smaller radii, they do not appear to comply with that section.; Please contact our Office of Vehicle Safety Compliance if you have an further responses or comments on the preliminary noncompliance determination.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1373OpenLewis S. Hollins, Esq., Attorney at Law, One Chester Drive, Great Neck, NY 11021; Lewis S. Hollins Esq. Attorney at Law One Chester Drive Great Neck NY 11021; Dear Mr. Hollins: Dr. Gregory has asked me to respond to your client's request fo approval of the 'Hollins system' interlock device. In an earlier version, the system was the basis of a petition for an alternative to Standard 208's seatbelt interlock system. That petition was denied by the NHTSA (38 FR 9830, April 20, 1973, and 38 FR 16072, June 20, 1973) as was a petition for reconsideration of our decision (38 FR 33110, November 30, 1973).; Standard 208 establishes performance requirements, but the NHTSA doe not approve or disapprove specific equipment designs. Any design can be used to satisfy Standard 208 which fulfills the performance requirements. We have considered Mr. Hollins' proposal and, as set our (sic) in the *Federal Register*, have determined that his requested changes to the performance requirements are not justified. We feel that our consideration of Mr. Hollins' petition has been full and complete, and that further petitions on this subject will be repetitious within the meaning of 49 CFR S553.35(c).; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4521OpenMrs. Alice Collins 703 Cohassett Ave. Lake Wales, FL 33853; Mrs. Alice Collins 703 Cohassett Ave. Lake Wales FL 33853; "Dear Mrs. Collins: This is a response to your letter of January 15 1988. I apologize for the delay in responding to your letter. In your letter, you described yourself as a parent of school-age children, and as a volunteer who drives children to school-related activities in your 1986 Plymouth Voyager mini-van. You stated that in the 1986-1987 school year, the U.S. Department of Transportation decided that Voyager Mini-Vans were 'unsafe.' You go on to say that 'the classification of M.P.V. was used on all mini-vans,' and suggest that it is a mistake to characterize your Voyager as a multipurpose passenger vehicle (MPV) because it is more like a passenger car than a truck. You concluded by asking us to change the decision that the Plymouth Voyager mini-van is unsafe. You raised other concerns in telephone conversations with Joan Tilghman, a member of my staff. First, I will address the request in your letter that the Department change what you believe is a decision concerning the safety of your vehicle. Then, I will address the matters you raised in conversations with Ms. Tilghman. Let me begin by assuring you that the agency has never stated that the Plymouth Voyager is 'unsafe.' Except in the context of a specific enforcement proceeding, NHTSA does not make blanket determinations that vehicles are 'safe' or 'unsafe.' Instead, we establish safety standards, and manufacturers must certify that each of their vehicles complies with all applicable standards. If we determine that a group of vehicles fails to comply with an applicable standard, or that a group of vehicles contains a defect related to motor vehicle safety, we order the manufacturer to recall the vehicles. Again, we make these determinations only in the context of an enforcement proceeding. There has been no such proceeding with respect to the 1986 Plymouth Voyager. With respect to your suggestion that it was a mistake to classify the Voyager as an MPV, it is the manufacturer's responsibility to determine, in the first instance, what a vehicle's classification should be. Chyrsler has classified the Voyager as an MPV, and so must certify that the Voyager meets all Federal safety standards applicable to that vehicle class. We have no information which suggests that Chrysler's classification of the Voyager is incorrect under our classification criteria. In your conversations with Ms. Tilghman, you explained that the Tallahassee, Florida school district will not permit parents to transport school children to school-sponsored or school-related events in MPVs, such as the Voyager. However, you stated that the district will permit parents to transport children to school-sponsored or school-related events in passenger cars. You said that the school district is following a recommendation by this agency that Florida school districts not condone transporting children to school-related events in buses other than certified school buses. Your understanding is that NHTSA made this recommendation to the State of Florida in an April 25, 1986 letter to Mr. Arnold Spencer, and repeated the recommendation in an August 7, 1986 letter to Mr. Larry McEntire. I have enclosed copies of both letters for your information. As you see, NHTSA made no such recommendation in either letter. Instead, we explained that we do not regulate the use of vehicles by owners, nor do we require the use of particular vehicles for particular purposes. There is no Federal prohibition against vehicle owners using their own vehicles to transport school children to school-related events. We also noted that the individual States have authority to establish any such regulations, in accordance with the principles of federalism set out in our Constitution. The State of Florida had already made its own decision to adopt and implement this policy before we were contacted by either Mr. Spencer or Mr. McEntire on this subject. Any changes to that policy would also reflect a decision by the State of Florida, not the Federal government. In the letter to Mr. Spencer, we made the observation that Florida's policy that school boards not condone transporting school children in vehicles that are not certified as complying with our school bus safety standards, 'is consistent with our belief that school buses certified to our school bus safety standards are the safest means of transportation for school children.' This was not a recommendation to the State of Florida, but a statement of our belief about the superior safety afforded to school children by buses that are certified as complying with our school bus standards. That belief continues to be supported by data showing that school buses continue to have one of the lowest fatality rates for any class of motor vehicle. Large school buses are the safest form of ground transportation in the United States because the passenger seats are 'compartmentalized' (special seat padding and spacing, and high seat backs), and because of the vehicle's size and weight (which generally reduce an occupant's exposure to injury-threatening crash forces), the drivers' training and experience, and the extra care other motorists usually take when they are near a school bus. I am sending you information on the agency's New Car Assessment Program (NCAP). NCAP is an experimental program in which we test light-duty vehicles, MPVs among them, to see how well they perform in a high-speed crash. You will find test results for vehicles that NHTSA has tested over the past few years, including results for the 1984 and 1987 Plymouth Voyager. Also, you will find the agency's April, 1988 report to Congress titled, 'Safety Programs for Light Trucks and Multipurpose Passenger Vehicles.' I hope you find this information helpful. If you have further questions, please contact Joan F. Tilghman, of my staff, at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosures"; |
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ID: aiam0831OpenZundapp-Werke GMBH Munchen, 8 Munchen 8, Anzinger Str. 1-3, Germany; Zundapp-Werke GMBH Munchen 8 Munchen 8 Anzinger Str. 1-3 Germany; Gentlemen: Your letter of August 8 and your follow-up letter of August 22 to Mr Francis Armstrong, Director, Office of Standards Enforcement, concerning the lighting requirements for motor-driven cycles, were forwarded to this Office for consideration and reply.; The lighting requirements specified in Federal Motor Vehicle Safet Standard No. 108 are identical for a motorcycle and a motor-driven cycle (except for headlamps, see SAE J584 April 1964), because the latter is defined in Part 571 of the standards as 'a motorcycle with a motor that produces 5- brake horsepower or less.'; In addition, the answers to your specific questions follow -- >>>1. Must the stop-light of a motor-driven cycle be operated by han and foot brake?; *Answer* - Yes. Paragraph S4.5.4 of FMVSS No. 108 requires the stop lamps on eac vehicle to be activated upon application of the service brakes, and since both the hand and foot brakes are service brakes, the application of either must activate the stop lamps.; 2. Does there exist any regulations concerning the light intensity o the brake-light?; *Answer* - Yes. Currently stop lamps must conform to the photometric requirement specified in SAE Standard J575d. Paragraph S4.1.1.6 of FMVSS No. 108 also requires that vehicles manufactured on or after January 1, 1973, be equipped with stop lamps meeting the candlepower requirements for Class A turn signal lamps in SAE J575d.; 3. Are turn signals prescribed? *Answer* - Yes. Class B turn signal lamps (see SAE J575d) are required o motorcycles manufactured on or after January 1, 1973, and should be mounted as specified in Table IV of FMVSS No. 108 (copy enclosed for your information).; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle 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.