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: aiam2381OpenHonorable M. Caldwell Butler, House of Representatives, Washington, DC 20515; Honorable M. Caldwell Butler House of Representatives Washington DC 20515; Dear Mr. Butler: Your letter of June 23, 1976, forwarding correspondence from one o your constituents, Mr. Ralph L. Lichtfuss, concerning the effect of Federal bumper requirements on insurance costs, has been referred to the National Highway Traffic Safety Administration (NHTSA) by the Federal Trade Commission for reply.; Mr. Lichtfuss cites a newspaper article in which escalating insuranc rates are attributed to inflation. As an example of the inflationary impact in this area, the article's author states that the cost of the 1970 Ford LTD front bumper was $68.00, while the cost of the same component on the 1976 LTD model is $334.90. Mr. Lichtfuss asks whether Federal regulations are responsible for this cost increase and the resulting escalation in insurance premiums.; A part of the increased cost is due to Federal regulation. Federa Motor Vehicle Safety Standard No. 215, *Exterior Protection*, requires that cars be capable of sustaining 5 mph barrier and pendulum impacts without experiencing damage to specified safety components. Compliance with this standard by motor vehicle manufacturers has been achieved by upgrading the vehicle bumper system. Although the new bumpers cost more, they protect vehicles during low-speed crashes far better than the old 'cosmetic' bumpers.; The higher costs are offset to a significant degree by savings i insurance costs. The insurance industry has supported the standard throughout, and currently takes the position that a weakening of the standard would increase liability costs for insured motorists and out-of-pocket expenses for those without collision insurance.; It appears from the insurance industry position, as reflected in th enclosed press release, that the Federal requirements mandating more efficient bumpers are not responsible for increases in automobile insurance rates.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5444OpenHarleigh Ewell, Esq. Regulatory Affairs Division Office of the General Counsel Consumer Product Safety Commission Washington, D.C. 20207; Harleigh Ewell Esq. Regulatory Affairs Division Office of the General Counsel Consumer Product Safety Commission Washington D.C. 20207; Dear Mr. Ewell: This letter responds to your inquiry whether gasolin pump nozzle/hose assemblies (referred to collectively in this letter as 'gas nozzles') are an item of motor vehicle equipment. The answer is no. To answer your question, we conducted a detailed examination of our past interpretations of what constitutes 'motor vehicle equipment' under our statute. As you are aware, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA's authority was recently recodified in title 49 of the U.S. Code. Section 30102(a)(7) (formerly section 102(4) of the National Traffic and Motor Vehicle Safety Act of 1966) defines the term 'motor vehicle equipment' as: (A) any system, part, or component of a motor vehicle as originally manufactured, (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component, or as any accessory or addition to a motor vehicle, or (C) any device or an article ... that is not a system, part, or component of a motor vehicle and is manufactured, sold, delivered, offered, or intended to be used only to safeguard motor vehicles and highway users against risk of accident, injury, or death. (Emphasis added.) The only portion of this definition that gas nozzles could even conceivably fall within is the term 'accessories.' Proceeding by the process of elimination, a gas nozzle is neither a 'system, part, or component' of a motor vehicle as originally manufactured nor as a replacement or improvement for or to a system, part or component because a gas nozzle never becomes part of the vehicle and cannot realistically be considered part of the vehicle's fuel system. For the same reason, it is not an 'addition' to a motor vehicle. A gas nozzle is not a 'device, article, or apparel' because it is not exclusively used as a safeguard from risk of accident, injury, or death. The sole remaining possibility is that gas nozzles may be an 'accessory.' This question is addressed below. The agency has typically used two criteria in determining whether a device is an 'accessory.' These criteria were discussed extensively in a May 25, 1990 letter to Susan Birenbaum, at the time the Acting General Counsel of your commission. The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is intended to be used principally by ordinary users of motor vehicles. If a product satisfied both criteria, then the product has been considered to be an 'accessory.' An allied concept that has been implicit in NHTSA's interpretations is that the item be purchased or owned by the consumer. This concept reinforces the 'ordinary user' concept in the second criterion of the test by generally restricting accessories to consumer items that we believe Congress intended us to regulate. Examples of items that, without the purchase concept, might be accessories include self-serve car wash equipment, and air pumps and even gas pumps themselves. In making this concept explicit, NHTSA will be stating the criteria for determining whether an item is an accessory as follows: (1) A substantial portion of its expected uses are related to the operation or maintenance of motor vehicles, and (2) it is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. Applying these criteria to gas nozzle/hose assemblies, we conclude that they are not accessories. While gas nozzles have a principal use that is arguably related to the operation and maintenance of motor vehicles, gas nozzles fail the second criterion of the test. While they are used by ordinary users of motor vehicles, they are not purchased or acquired by those users. It is therefore our opinion that gas nozzles are not motor vehicle equipment. I hope this information is helpful. If you have any further questions, please feel free to contact us at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0216OpenMr. Raymond L. Springer, President, The Auto Sun Products Company, 529 - 543 Poplar Street, Cincinnati, OH 45214; Mr. Raymond L. Springer President The Auto Sun Products Company 529 - 543 Poplar Street Cincinnati OH 45214; Dear Mr. Springer: Your letter of February 13 indicates that your understanding of th regulatory situation is correct. There is no prohibition in the motor vehicle safety standards against the sale of a non-conforming attachment bolt as a separate item. All that Standard No. 209 requires is that the seat belt assemblies which your firm supplies must be accompanied by conforming attachment bolts.; Before you act on your understanding, however, you should give specia consideration to the consequences of any widespread use of attachment bolts which do not conform to the strength and other requirements of the standard. If, for example, we found that vehicle owners were being induced to secure their aftermarket seat belts to anchorages by the use of attachment bolts that do not provide adequate strength in crash situations, we would be compelled to consider whether the public interest would require rulemaking action aimed at preventing the marketing of such understrength bolts. We appreciate your desire not to evade the regulations or take advantage of what may be considered a loophole in them.; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations; |
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ID: aiam5014OpenJohn J. Jacoby President Cleartec 1919 Paper Mill Road Huntington Valley, PA 19006-5813; John J. Jacoby President Cleartec 1919 Paper Mill Road Huntington Valley PA 19006-5813; "Dear Mr. Jacoby: I have been asked to respond to your April 6, 199 letter to former Secretary Skinner, because our agency, the National Highway Traffic Safety Administration (NHTSA), is the part of the Department of Transportation that administers the program about which you asked. Specifically, your letter asks whether there are any Federal regulations that affect a new product Cleartec has developed. The product, Clean Sweep Strips, is a transparent material applied to the windshield in a herringbone pattern, in the path of the wipers, to clean the wipers. I am pleased to have this opportunity to explain our regulations to you. By way of background information, 103 of the National Traffic and Motor Vehicle Safety Act (Safety Act, 15 U.S.C. 1392) authorizes NHTSA to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests vehicles and items of equipment for compliance with the standards. In addition, the Safety Act requires manufacturers to recall and remedy any motor vehicle or item of motor vehicle equipment that contains a safety-related defect. Your letter states that Clean Sweep Strips could be manufactured into new windshields. If a windshield with Clean Sweep Strips were installed as original equipment by a manufacturer of a new motor vehicle, the manufacturer would have to certify that the vehicle, with the Clean Sweep Strips installed, complies with all applicable safety standards. NHTSA has issued two safety standards, compliance with which might be affected by the installation of your Clean Sweep Strips. First, Standard No. 205, Glazing Materials, establishes a number of requirements for light transmittance, abrasion resistance, and optical deviation and visibility distortion for windshields. Second, Standard No. 104, Windshield Wiping and Washing Systems, establishes requirements for a minimum area that must be wiped by the wiping system, and the frequency at which the wiping system must operate. Any manufacturer that installed your product as original equipment on a windshield would have to certify that the windshield continued to comply with Standards No. 205 and 104 with your product installed. After the first sale to a consumer, a vehicle is no longer required by Federal law to conform to all safety standards. However, 108(a)(2)(A) of the Safety Act provides as follows: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard... This provision means that a manufacturer, dealer, distributor, or repair business cannot install your Clean Sweep Strips on any vehicle if such installation results in the vehicle no longer complying with Standard No. 205 or 104. Violations of this 'render inoperative' prohibition are punishable by civil fines of up to $1,000 per violation. I note that the 'render inoperative' prohibition does not affect modifications made by vehicle owners to their own vehicles. Thus, individual vehicle owners may install your Clean Sweep Strips on their own vehicles, even if this installation causes the vehicles to no longer comply with applicable safety standards. Such installations may be regulated, however, by State law. If you are interested in further information on the provisions of State laws, you may wish to contact the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Virginia 22203. Additionally, under the Safety Act, Clean Sweep Strips would be considered an item of motor vehicle equipment. Your company, as a manufacturer of motor vehicle equipment, would be subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety defects. In the event that NHTSA or a product's manufacturer determines that a product that is an item of motor vehicle equipment contains a safety-related defect, the manufacturer is responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Finally, I have enclosed a general information sheet for new manufacturers which summarizes NHTSA's regulations and explains where to obtain copies of Federal motor vehicle safety standards and other 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, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam4828OpenState Representative Jim Holperin 34th Assembly District P.O. Box 8952 Madison, WI 53708; State Representative Jim Holperin 34th Assembly District P.O. Box 8952 Madison WI 53708; Dear Mr. Holperin: This is in reply to your letter of January 3, l99l to Taylor Vinson of this Office, on behalf of your constitutent LeRoy E. Mueller. Mr. Mueller is a manufacturer of trailers, and is concerned that if he builds certain tilt deck trailers to specifications they will fail to conform to Federal Motor Vehicle Safety Standard No. 108. Specifically, a stationary ramp 'might obscure a clear view of the trailer's tail lights from a 45 degree angle . . . .' You have asked whether his concern 'regarding an obstructed view of the tail light' is a legitimate one. As Mr. Mueller indicates, Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, incorporates by reference SAE Standard J585e, Tail Lamps (Rear Position Lamps), Sept. 1977, which applies to trailers. This standard requires that 'Signal from lamps on both side of the vehicle shall be visible through a horizontal angle from 45 deg. to the left to 45 deg. to the right.' The SAE standard further specifies that 'To be considered visible, the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding reflex, at least 2 square inches in extent, measured at 45 deg. to the longitudinal axis of the vehicle.' We note that stop lamps and rear turn signal lamps must also meet this requirement. You have enclosed a photocopy of a photograph of the rear of a trailer taken from what we assume represents a 45 degree angle to the left of the horizontal centerline of the trailer. Certain lamps, visible from another photocopy of a picture taken on the centerline, appear to be obscured at the 45 degree angle. Thus, it appears that Mr. Mueller's concern to be a legitimate one. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to determine whether his vehicle conforms to all applicable Federal motor vehicle safety standards, and to ensure that it does before affixing a certification of compliance to it upon completion of its manufacture. If this agency has reason to believe that a motor vehicle or item of motor vehicle equipment has been manufactured and/or certified in violation of the Vehicle Safety Act, this agency conducts an investigation and, if appropriate, an enforcement action. However, we would like to point out that if trailer equipment prevents compliance of a required lamp, like a tail lamp, with any of Standard No. 108's requirements, paragraph S5.3.1.1 of the standard permits a manufacturer to install an auxiliary lamp meeting the standard's requirements. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0538OpenMr. Richard I. Moss, Director, Washington Affairs, Trailer Coach Association, P. O. Box 17404, Dulles International Airport, Washington, DC 20041; Mr. Richard I. Moss Director Washington Affairs Trailer Coach Association P. O. Box 17404 Dulles International Airport Washington DC 20041; Dear Mr. Moss: This is in further reply to your letter of August 17, 1972. W indicated in a letter to you of September 8, 1972, that we would respond to your letter when action on petitions for reconsideration of the June 21, 1972, amendment to Standard No. 205 had been completed. Notice of our action has now been published (37 F.R. 24035, November 11, 1972) and a copy is enclosed.; Based upon the November 11, 1972, notice, your conclusions regardin the requirements for certification and marking by prime glazing material manufacturers (paragraph 3.2 of your letter) are for the most part correct. These manufacturers must mark glazing materials in accordance with Section 6 of ANS Z26. They must also certify. The certification must be made by the addition of the symbol DOT and assigned code number only when the glazing is designed as a component of any specific motor vehicle or camper. In other cases certification may be accomplished by any method meeting the requirements of section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403). It may not be accomplished, however, by affixing the DOT and code number.; Your conclusions regarding certification and marking requirements fo persons who cut glazing material from larger sheets (paragraph 3.1 of your letter) are not entirely correct. It is true that such persons must also certify, and that the method for certification my be any that satisfies the requirements of section 114 of the Act. Affixing a label to the material is one such method. You are incorrect, however, in your conclusion that the material need not contain the markings of the prime manufacturer. Section 6 of ANS Z26 requires glazing cut from larger pieces to contain the markings of the manufacturer of the larger piece. As clarified in the notice of November 11, 1972, this requirement is still applicable.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2505OpenLt. C.R. Townsend, Director Motor Vehicle Inspection Division, Oklahoma Department of Public Safety, 3600 north Eastern, P.O. Box 11415, Oklahoma City, Oklahoma 73111; Lt. C.R. Townsend Director Motor Vehicle Inspection Division Oklahoma Department of Public Safety 3600 north Eastern P.O. Box 11415 Oklahoma City Oklahoma 73111; Dear Lt. Townsend: This is in response to your December 16, 1976, letter concerning tire marked 'Reno Farm Tire--Farm Use Only' that are appearing on some passenger cars in Oklahoma. I understand that the DOT symbol is also marked on the sidewalls of these tires, as a certification of conformity to Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires--Passenger Cars*.; Paragraph S6 of the standard precludes the manufacture of farm tires i passenger car tire sizes unless those tires conform to and are certified as conforming to all aspects of the standard. There is not, however, any provision in Standard No. 109 that prohibits the additional marking that you have described on a tire that is manufactured and sold for passenger car use. No safety issue appears to be presented by this situation.; You have also asked who is responsible for compliance with the Tir Identification and Recordkeeping regulation (49 CFR Part 574, copy enclosed). That regulation creates various obligations for tire manufacturers, motor vehicle manufacturers, motor vehicle dealers, and others. Where(sic) a tire manufacturer sells tires to a trailer manufacturer, the presence of the 'Farm Use Only' marking has no effect on those obligations.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0492OpenMr. Stewart N. Metz, Crane Carrier Company, P.O. Box 4508, Tulsa, OK 74104; Mr. Stewart N. Metz Crane Carrier Company P.O. Box 4508 Tulsa OK 74104; Dear Mr. Metz: This is in reply to your letter of November 15, 1971, in which yo requested an opinion as to the requirements of Standard No. 208 that will apply to your vehicles after January 1, 1972. It appears from the information you provided that all of your vehicles have gross vehicle weight ratings of more than 10,000 pounds. They will therefore be subject to the requirements of section S4.3 of the standard. Under this section, you may equip them with either of two restraint options - a passive restraint system, or a seat belt that conforms to the Federal seat belt standard (Standard No. 209). The vehicles will also have to have seats that conform to Standard No. 207, and seat belt anchorages that conform to Standard No. 210.; Copies of each standard are enclosed for your reference. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4982OpenMr. Michael J. Sens Researcher S.E.A., Inc. 7349 Worthington-Galena Road Columbus, OH 43085; Mr. Michael J. Sens Researcher S.E.A. Inc. 7349 Worthington-Galena Road Columbus OH 43085; "Dear Mr. Sens: This responds to your letter to me dated March 26 1992, in which you sought our interpretation of whether the requirements of Federal Motor Vehicle Safety Standards 206, Door Locks and Door Retention Components, 214, Side Door Strength, and 216, Roof Crush Resistance--Passenger Cars,, applied to a 1985 American Motors Corporation (AMC) Jeep CJ- 7. You stated in your letter that AMC classified the vehicle as a 'sport utility vehicle' and that it came with a soft top or an optional fiberglass top, both with removable side doors. By way of background information, the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act), 15 U.S.C., 1381, et seq., as amended, authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards for new motor vehicles and items of motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards. In accordance with 49 CFR 567, Certification, manufacturers of motor vehicles must certify that their products comply with all such standards. Each safety standard applies to specified 'types' of motor vehicles and/or motor vehicle equipment. Motor vehicles are classified into the following types: passenger cars, multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles. A definition for each motor vehicle type is set forth at 49 CFR 571.3. Thus, a 1985 AMC Jeep CJ-7 was required to comply with all safety standards that applied to its vehicle type at the time of its manufacture. In order to determine what safety standards applied to the vehicle, it is first necessary to establish its classification under Part 571.3. The Safety Act places the responsibility for classifying a particular vehicle in the first instance on the vehicle's manufacturer. For this reason, NHTSA does not approve or endorse any vehicle classification before the manufacturer itself has classified a particular vehicle. NHTSA may reexamine the manufacturer's classification during the course of any enforcement actions. While AMC may have marketed the 1985 AMC Jeep CJ-7 as a 'sport-utility vehicle,' it classified it as a multipurpose passenger vehicle for purposes of the Federal motor vehicle safety standards. The term 'multipurpose passenger vehicle' is defined in Part 571.3 as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' It is our opinion that AMC's classification was appropriate, given that the 1985 Jeep CJ-7 is a 4-wheel drive vehicle with an approach angle of 33o, departure angle of 25o, breakdown angle of 18o, axle clearance of 7.8', and minimum running clearance of 8.1', and thus clearly has special features for occasional off-road operation. With specific reference to the three standards you inquired about concerning possible applicability to a 1985 AMC Jeep CJ-7, Standards 214 and 216 applied only to passenger cars at the time the CJ-7 was manufactured. See S2 of Standard 214 and and S3 of Standard 216. Since the 1985 AMC Jeep CJ-7 was classified as a multipurpose passenger vehicle and not a passenger car, those two standards, by their terms, did not apply to it. Standard 206, on the other hand, did apply to multipurpose passenger vehicles as well as passenger cars. However, S4 thereof provided in pertinent part: '. . . C omponents on folding doors, roll-up doors, doors that are designed to be easily attached to or removed from motor vehicles manufactured for operation without doors, . . . need not conform to this standard.' You indicated that the Jeep CJ-7 came with removable side doors, and we understand that the vehicle was manufactured for operation without doors. Accordingly, the AMC Jeep CJ-7 came within the above-quoted exception to Standard 206 and was not subject to its requirements. I hope the above information will be helpful to you. If you have any further questions or need additional information regarding this matter, please feel free to contact Walter Myers of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0168OpenMr. James H. Lawler, Vice President, Tank Truck Service, 15150 Dequindre, Warren, MI 48091; Mr. James H. Lawler Vice President Tank Truck Service 15150 Dequindre Warren MI 48091; Dear Mr. Lawler: Thank you for your letters dated April 7 and June 3, 1969, in which yo request clarification of the Certification Regulations that become effective with vehicles manufactured after August 31, 1969.; You are correct in your interpretation that the certification would b attached to the door post or the other locations in the cab of a vehicle that are specified in section 367.4(c). You should note, however, that the label is not a 'body certification', as you describe it, but certifies that the entire vehicle conforms to applicable safety standards.; With regard to your suggestion that the label should be placed on th body rather than the chassis of the vehicle, since in the case of your vehicles the body is likely to last longer, it has been determined that uniformity of location is of primary importance for enforcement purposes. The life of various components varies, as you know, from one vehicle to another. These regulations do not cover the situations in which used components are recombined with new ones.; Thank you for your cooperation. Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle safety Performance Service; |
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.