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: aiam1275OpenMr. David J. Humphreys, Paulson and Humphreys, 1140 Connecticut Avenue, NW., Washington, DC 20036; Mr. David J. Humphreys Paulson and Humphreys 1140 Connecticut Avenue NW. Washington DC 20036; Dear Mr. Humphreys: This is in reply to your communication of September 20, 1973 requesting our review of a sample owner notification letter, regarding a safety related defect in certain Apache Camping Trailers, for purposes of conformity to 49 CFR Part 577, Defect Notification.; We believe the reference in the first sentence of the second paragraph that a defect *may* exist, to be inconsistent with the regulation. This statement is apparently intended to meet the requirement of Section 577.4(b). This subsection, however, requires a particular statement and does not permit the use of 'may' or similar expression. The statement required is not solely one of fact, but rather one of law, and the opening sentence of Section 577.4(b) shows clearly that the statement is required where the defect potentially exists in the vehicles or equipment in question. We also believe your references in other parts of the letter to 'possible defect' suffer from the same deficiency.; In other respects, we believe your notification letter conforms to Par 577.; Sincerely yours, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4077OpenMr. William von Raab, The Commissioner of Customs, United States Customs Service, 1301 Constitution Avenue, N.W., Washington, DC 20229; Mr. William von Raab The Commissioner of Customs United States Customs Service 1301 Constitution Avenue N.W. Washington DC 20229; Dear Mr. von Raab: This responds to your letter suggesting a potential enforcement proble with the new Federal motor vehicle theft prevention standard promulgated by the National Highway Traffic Safety Administration (NHTSA). As you noted, the Customs Service will be the agency responsible for enforcing the provisions in the theft prevention standard requiring subject vehicles and parts to be properly marked and certified before they are imported into the United States. You stated that it was essential that the Customs Service be provided a list of 'authorized individuals or companies which have been found by the Department of Transportation to possess the capability and integrity to properly certify imported vehicles and parts.' Accordingly, you requested that we provide you with such a list. The Department of Transportation does not authorize individuals or companies to engage in the business of importing and modifying vehicles. Therefore, we cannot provide you with a list such as you requested.; This issue arises primarily with respect to 'direct importers'. Thes direct importers are individuals and commercial enterprises that obtain foreign cars not originally manufactured for sale in the United States, bring them into this country under bond, and modify the cars so that they can be certified as being in compliance with the U.S. vehicle safety, emissions, and bumper standards. This is commonly referred to as the automotive 'gray market'. The statutes mandating the Federal safety, emissions, and bumper standards (15 U.S.C. 1397(b)(3), 42 U.S.C. 7522(b)(2), and 15 U.S.C. 1916(b)(3)) explicitly authorize vehicles not in compliance to be brought into this country under bond. However, the Theft Act (15 U.S.C. 2021 *et seq*.) contains no such provision. Therefore, direct importers must modify all their subject vehicles to comply with the theft prevention standard before the vehicles are imported, and must certify that the vehicles are in compliance at the time of entry.; You stated in your letter that the theft prevention standard could b read to allow any person to certify compliance of an imported vehicle with the standard and that the Customs Service would have no way to judge the authenticity of the certification or the 'ability of the party to certify to compliance at the time of importation.' You suggested that vehicles and parts could be imported without being properly marked, if Customs had to accept the certification of any person importing such vehicles or parts.; We do not believe that reliance on the importers' certifications wil cause the enforcement problems you fear. If subject vehicles or parts bear a certification that complies with the requirements of the theft prevention standard, the Customs Service should allow those vehicles or parts to be imported. NHTSA enforcement personnel will conduct spot checks of the direct importers' vehicles and parts. If we discover that some direct importers are certifying compliance with the theft prevention standard without actually marking in accordance with that standard, we will take appropriate enforcement actions. We expect these actions will help deter any direct importers or other manufacturers who are tempted to falsely certify compliance with the theft prevention standard.; Although we share your concern that all authorized manufacturers an importers of motor vehicles comply with the theft prevention standard, we have no authority to require any person or entity to register with the Department of Transportation and show a capability to comply with the standard *before* importing a vehicle. We do currently collect information about importers *after* they have imported a vehicle, as does the Customs Service. However, the fact that a potential importer has not previously imported a vehicle has no legal significance for our enforcement efforts.; I appreciate your concern for the effective enforcement of our thef prevention standard. Please feel free to contact me if you have any further suggestions or ideas in this regard.; Sincerely, Elizabeth Hanford Dole |
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ID: aiam0937OpenMr. Harry W. Protzeller, Dyna-Plastics, Incorporated, P.O. Box 9284, 3205 Forge Road, Shreveport, LA 71109; Mr. Harry W. Protzeller Dyna-Plastics Incorporated P.O. Box 9284 3205 Forge Road Shreveport LA 71109; Dear Mr. Protzeller: This is in reply to your letter of November 30, 1972, to the Federa Register concerning an interpretation of Federal Motor Vehicle Safety Standard No. 108.; You have asked whether a side marker lamp may be combined opticall with a taillamp as long as requirements of Standard No. 108 applicable to each lamp are met. The answer is yes, S4.4.1 permits this combination.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3618OpenMr. J. L. Campbell, Jr., 12813 95th Avenue, N.E., Kirkland, WA 98033; Mr. J. L. Campbell Jr. 12813 95th Avenue N.E. Kirkland WA 98033; Dear Mr. Campbell: I have recently received a copy of your letter to Senator Gorto concerning the difficulties small manufacturers of motor vehicles have in complying with Federal standards. To alleviate these difficulties, you suggested that blanket exemptions from the bumper regulations and the Federal motor vehicle safety standard on side door strength be granted to all 4-wheel vehicles under 800 pounds dry weight.; As explained more fully below, this agency does not have authority fro Congress to grant an exemption from the bumper standard for the ultra-lightweight vehicles you describe. Such authority would require new legislation. However, we do have authority either to exclude all of those vehicles from the side door strength standard or to exempt particular manufacturers of those vehicles from that standard.; Congress set forth the guidelines under which this agency could issu exemptions from the bumper standard in section 102(c)(1) of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1912(c)(1)). Exemptions may be granted only to passenger motor vehicles manufactured for a special use. While neither the Cost Savings Act nor this agency has defined 'special use', the Cost Savings Act is explicit that a vehicle can be exempted only if two conditions are met: (1) the vehicle is manufactured for a special use, (2) compliance with the bumper standard would unreasonably interfere with that use. The example Congress cited for such a vehicle was a Jeep with snow removal equipment on the front. The agency believes that the purpose of an ultra-lightweight passenger vehicle is essentially the same as that of a lightweight vehicle such as the Toyota Starlet, Honda Civic or Ford Escort, i.e., to carry passengers. The agency does not view that purpose to be a special use within the meaning of section 102. Further, even if the first condition could be met, it is not clear that the second one could be. Hence, an amendment to the Cost Savings Act would have to be made by the Congress before we could grant an exemption from the bumper standard to your ultra-lightweight passenger motor vehicles.; Concerning your request regarding Standard No. 214, side door strength NHTSA formerly excepted motor vehicles (other than trailers and motorcycles) of 1,000 pounds or less curb weight from all safety standards. However, that exception was eliminated in 1973 (38 F.R. 12808, May 16, 1973). At that time, the agency stated that manufacturers seeking relief from compliance problems peculiar to these vehicles could either petition for amendments to individual standards or petition for an exemption under section 123 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410).; These options remain the ones available to manufacturers o ultra-lightweight vehicles. Thus, one option is to submit a petition for rulemaking under 49 CFR Part 552 requesting the agency to amend Standard No. 214 to exclude those vehicles from that standard's applicability provision. I should point out that few, if any, petitions of this type have been submitted since the agency's May 1973 notice and none have been granted. Also, you should be aware that the rulemaking process is often a lengthy one.; The other option is for a manufacturer to submit a petition for th exemption of his vehicles from a particular standard. I have enclosed a copy of 49 CFR Part 555 which sets forth the information that a manufacturer must include in its petition. Exemption petitions are not uncommon and are often granted at least in part. Also, because fewer procedural steps are necessary, the exemption process is typically much faster than the amendment process. Should you wish to submit an exemption petition, you may find useful the enclosed copies of section 123 of the Safety Act and Standard No. 214, *Side Door Strength* (49 CFR S 571.214).; If you need any further assistance or information on either of thes subjects, please do not hesitate to contact me. We try to minimize the regulatory difficulties experienced by small manufacturers to the extent we can do so consistent with our legislative authority.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1625OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P. O. Box 898, Sacramento, CA, 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P. O. Box 898 Sacramento CA 95804; Dear Mr. Heath: This is in reply to your letter of September 3, 1974, asking nin questions about motorcycle sidecars.; The Office of Crash Avoidance replied to these questions by letter o September 5, 1974, and I generally concur with their comments, but wish to make the following observations with respect to Questions 2 and 7. The answer to Question 2 assumes that the motor cycle is initially sold with the sidecar attached. In the event that an item of motor vehicle equipment (of which a sidecar is an example) would prevent compliance of the motorcycle's reflector device with the visibility requirements, pursuant to S4.3.1.1 of Standard No. 108 an auxiliary reflector must be provided. A location on the sidecar would be appropriate. Standard No. 108, however, does not cover sidecar *per se* and hence does not require a reflective device or any other lighting equipment on them.; With respect to Question 7, Standard No. 119 applies only to motorcycl tires and not to tires designed exclusively for use on sidecars. We are, however, seriously considering proposing an amendment that would include sidecar tires. Standard No. 120, still in the internal discussion stage, would then cover sidecar tire rims when formally proposed.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4427OpenMr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 18881 U.S. 31 North Westfield, IN 46074; Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing Inc. 18881 U.S. 31 North Westfield IN 46074; "Dear Mr. Lawler: This responds to your request for an interpretatio of Standard No. 208, Occupant Crash Protection (49 CFR /571.208). Specifically, you noted that a final rule published July 6, 1988 (53 FR 25337) upgrades the safety belt requirements for heavy vehicles manufactured on or after September 1, 1990. One of the new requirements for those safety belts is that, if an automatic locking retractor (ALR) is used, that retractor 'shall not retract webbing to the next locking position until at least 3/4 inch of webbing has moved into the retractor.' Standard No. 208 sets forth this requirement in section S4.3.2.2 for trucks and multipurpose passenger vehicles with a gross vehicle weight rating of more than 10,000 pounds, and in section S4.4.2.2 for buses. You asked whether an ALR that depended on a mechanism external to the retractor itself to prevent it from retracting webbing to the next locking position would comply with S4.3.2.2 and S4.4.2.2. The answer to your question is no. The agency explained in detail the reasons why the final rule did not adopt the proposed requirement for all heavy vehicle safety belts to be equipped with emergency locking retractors only, see 53 FR 25338-25340. The proposed prohibition of ALR's in heavy vehicles was based on the tendency of current designs of ALR's to become progressively tighter around an occupant as the vehicle travels over potholes or other jarring surfaces of the road. However, NHTSA acknowledged in the final rule that some newer designs of ALR's do not exhibit this tendency. In response to these newer designs of ALR's, the agency said: Therefore, this rule has been expanded from the proposal, in order to permit ALR's with anti-cinch capability to be installed in heavy vehicles. For the purposes of this rule, anti-cinch capability is determined by examining the working of the retractor after it has locked after the initial adjustment of the safety belt. 53 FR 25339. This language explicitly states that the 'working of the retractor' is what determines whether an ALR on a heavy vehicle belt complies with the requirements of Standard No. 208. Since the focus is exclusively on the 'working of the retractor,' an ALR must comply with these requirements without depending upon any external mechanisms to assist it. Any ALR that cannot satisfy these requirements without the assistance of external mechanisms would not comply with Standard No. 208's requirements for ALR's on heavy vehicles. This conclusion is reinforced by the agency's statement that: 'NHTSA believes it is appropriate to measure compliance with this new 3/4 inch minimum webbing travel requirement for ALR's in Standard No. 208 under the same conditions currently specified for determining compliance with the existing 1-inch maximum webbing travel requirement for ALR's in Standard No. 209.' 53 FR 25340. The 1-inch maximum webbing travel requirement for ALR's is set forth in section S4.3(i) of Standard No. 209. Since Standard No. 209 became effective in 1968, the agency has determined whether ALR's comply with this requirement by examining the performance of the retractor itself without any assistance from external mechanisms. As explained in the final rule, the same procedure (examining the performance of the retractor itself without any assistance from external mechanisms) will be used to measure compliance with the minimum webbing travel requirements in Standard No. 208. In your letter, you requested that we issue an interpretation that any ALR that complies with Standard No. 209 can rely on the use of an external mechanism, such as your company's 'Komfort-Lok,' to comply with the minimum webbing travel requirements of Standard No. 208 for ALR's on safety belts in heavy vehicles. I cannot do so, for the reasons explained above. Any ALR used on a heavy vehicle safety belt must satisfy the minimum webbing travel requirements in Standard No. 208 by the working of the retractor itself, without the use of any external mechanisms. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam4132OpenThe Honorable Leon E. Panetta, Member, United States House of Representatives, 380 Alvarado Street, Monterey, CA 93940; The Honorable Leon E. Panetta Member United States House of Representatives 380 Alvarado Street Monterey CA 93940; Dear Mr. Panetta: Thank you for your letter on behalf of your constituent, Mr. Joh Cormick of San Luis Obispo, California, regarding Federal regulations for wheelchairs on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) administers Federal laws applying to school buses.; Your constituent requested information about two sets of Federa regulations relating to school bus drivers. He first asked about any regulations issued by the Department of Justice for fingerprint checks of school bus drivers. I understand that those questions have been referred to the Justice Department for reply. His second set of concerns, which you asked us to review, pertain to regulations issued by California that permit temporary placement of wheelchairs in the aisle of school buses during operation of the vehicles. Mr. Cormick believes this is unsafe since a wheelchair might impede access from the school bus in the event of an accident and asks what effect Federal law might have on State adoption of such a regulation.; As explained below, Federal law does not prohibit States from issuing regulation for the temporary placing of wheelchairs in school bus aisles. While NHTSA has issued a number of recommendations to the States for operational requirements for school buses, States establish regulations for school bus use, such as the one described by your constituent. Mr. Cormick is thus correct in contacting State officials to express his concerns and suggestions.; Since your constituent asks how Federal school bus regulations affec regulations issued by the States, I would like to begin with some background information on our school bus regulations. This agency administers two sets of regulations for school buses. The first set, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966, applies to the manufacture and sale of new motor vehicles and includes NHTSA's motor vehicle safety standards for new school buses. Those school bus safety standards set performance standards for various aspects of school bus safety, such as windows and windshields, fuel systems, emergency exits and seating systems. Under the Vehicle Safety Act, manufacturers of new buses must certify that their buses comply with our school bus safety standards if the vehicles are intended for carrying school children, and sellers of new school buses must ensure that complying school buses are only sold. The requirements of the Vehicle Safety Act and our school bus safety standards are Federal requirements which apply directly to school bus manufacturers and sellers and are thus not dependent on State adoption.; On the other hand, the second set of regulations we have for schoo buses is contingent on State implementation. This set, issued under the Highway Safety Act of 1966, applies to Federal funding of State highway safety programs. Each State submits a highway safety program which is reviewed and approved by NHTSA each year. Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed), contains guidelines for various aspects of pupil transportation programs including school vehicle identification, maintenance, and driver qualifications. One of its recommendations is that school bus drivers meet all special physical, mental and moral requirements established by the State agency having responsibility for pupil transportation. Since States set the procedures for selecting school bus drivers, State officials would be able to provide Mr. Cormick with more information about California's policies governing school bus driver selection and examination.; Because we regulate the manufacture and sale of new school buses an not their use, we would have no authority to prohibit school bus users from placing wheelchairs in aisles of school buses. Further, no recommendations for accommodating wheelchairs in school buses have been made in Program Standard No. 17. However, we are concerned about practices that might affect the safety provided by school buses (such as impeding access to school bus exits) and we encourage States to ensure that school children are transported in the safest possible manner. Mr. Cormick's school district might want to consider using school buses that have seating positions specially modified to accommodate students in wheelchairs. Those vehicles have wheelchair positions to which wheelchairs can be firmly secured, which provides safer accommodations to all occupants of the school bus.; Please contact me if you or your constituent have any furthe questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1330OpenMr. James H. Swinghammer, Assistant Chief Engineer, Young Daybrook, Inc., Plant No. 51, 117 North Main Street, Bowling Green, OH 43402; Mr. James H. Swinghammer Assistant Chief Engineer Young Daybrook Inc. Plant No. 51 117 North Main Street Bowling Green OH 43402; Dear Mr. Swinghammer: This is in reply to your letter of November 16, 1973 asking about th proper location of identification lamps on one-man truck-tractor cabs that are offset from the vertical centerline of the vehicle. In your view 'when the Law is applied to one (1) man cabs, the possibility exists that oncoming traffic would interpret the truck as not being in its proper traffic lane.'; As you have pointed out, front identification lamps are required b Table II of Standard No. 108 to be 'as close as practicable to the tope(sic) of the vehicle. . . as close as practicable to the vertical centerline. . . .' The 'vertical centerline' is that of the vehicle which is usually that of the cab as well. However, an identification lamp arrangement around the vertical centerline of an offset cab is considered to meet the standard.; We are not aware that an actual safety problem is presented by th current practice of mounting identification lamps around the centerline of offset cabs, and the fact that you produce less than 1,000 vehicles per year does not relieve you of the requirement of providing these lamps.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4562OpenErman Jackson, Sales Manager Trailmaster Tanks, Inc. P. O. Box 161759 1121 Cantrell-Sansom Road Fort Worth, TX 76161-1759; Erman Jackson Sales Manager Trailmaster Tanks Inc. P. O. Box 161759 1121 Cantrell-Sansom Road Fort Worth TX 76161-1759; "Dear Mr. Jackson: This is in response to your letter which requeste our interpretation of the applicability of certification requirements to your company. You indicate that you attached a new body to a truck chassis that has been in service for a number of years. Your customer believes that Trailmaster Tanks, Inc., (Trailmaster) should have issued a new final-stage manufacturer certificate at the time of the mounting of the new body. Trailmaster, on the other hand, is of the opinion that the final-stage manufacturer certificate is only issued when the chassis is new. You asked me whether your company was required by Federal law or regulations to certify that the new body on the used truck chassis complies with all applicable safety standards. The answer to your question depends on whether the used chassis consisted of any new components and, if not, whether the used components of the chassis came from different vehicles, as explained below. As a general matter, our safety standards and certification requirements apply to vehicles only before the first sale of the vehicle in good faith for purposes other than resale. Generally speaking, vehicles that are produced from a chassis that has already been sold to the public are not considered new vehicles, and are not subject to our safety standards or certification requirements. However, there is a special provision in our regulations for vehicles that are produced by combining new and used components. This provision is in 49 CFR 571.7(e), which provides: (e) Combining new and used components. When a new cab is used in the assembly of a truck, the truck will be considered newly manufactured for purposes of paragraph (a) of this section, the application of the requirements of this chapter, and the Act, unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components are from the same vehicle. This regulation means that a party attaching a new body to an old chassis is not required to attach a new certification label or make any certification under Federal law if that party simply uses the engine, transmission, and drive axle that are installed on the old chassis at the time the party receives the old chassis. Based on your statement that the truck 'was not modified in any way' at the time the new body was installed on the old chassis, this would appear to be the case in your situation. If this is true, you were not required to make any certification in connection with this vehicle. On the other hand, if you substituted a new engine, transmission, or drive axle in the old chassis when you attached the new body, the vehicle was considered newly manufactured under 571.7(e) and your company was required to certify the vehicle in accordance with Part 567. Similarly, if you substituted used components on the old chassis at the time you attached the new body, the vehicle was considered newly manufactured unless at least two of the three specified components (engine, transmission, and drive axle) were from the same vehicle. It should be noted that, even if the vehicle created when you attached a new body to a used truck chassis did not result in a newly manufactured vehicle pursuant to 49 CFR 571.7(e), your company was still subject to the provisions of section 108(a)(2)(A) of the Safety Act. This section prohibits any manufacturer, distributor, dealer or motor vehicle repair business from 'knowingly rendering inoperative' any equipment or element of design installed on a vehicle in compliance with our safety standards. In other words, no manufacturer, dealer, distributor, or repair business can modify used vehicles by removing or defeating any of the systems or devices that were installed on the vehicle to comply with an applicable safety standard. The modifier in the first instance must determine if the modifications constitute a prohibited 'rendering inoperative' violation. However, the agency can reexamine the modifier's determination in the context of an enforcement proceeding. I believe you can use the information presented in this letter to determine whether or not the vehicle your company made was considered a newly manufactured vehicle, subject to our safety standards and certification regulations. If you have any further questions or need additional information, please feel free to contact us. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam0872OpenMr. L. A. Ferguson, Project Engineer, Frigiking Division, Cummins Engine Company, Inc., 10858 Harry Hines Boulevard, Dallas, TX, 75220; Mr. L. A. Ferguson Project Engineer Frigiking Division Cummins Engine Company Inc. 10858 Harry Hines Boulevard Dallas TX 75220; Dear Mr. Ferguson: This is in reply to your letter of September 28, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to the plastic air discharge chambers or combination air chamber-unit housings of the air-conditioning units you manufacture for use in motor vehicles. You ask whether this equipment must meet the requirements of the standard.; The portion of an item of a motor vehicle equipment that forms part o a component listed in the standard will normally be subject to the standard. From the photographs of your equipment that you submitted, we would consider an air discharge chamber or combination air chamber-unit housing that forms part of the surface of a front or side panel to be incorporated into the panel and therefore subject to the standard. The air discharge chamber or combination chamber-unit housing of your roof-mounted equipment is not a part of the 'headlining,' and accordingly would not be subject to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.