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: aiam2789OpenMr. Eduardo A. Santiago, 1137 Barium Road, Modesto, CA 95351; Mr. Eduardo A. Santiago 1137 Barium Road Modesto CA 95351; Dear Mr. Santiago: This responds to Raycor Industries' March 13, 1978, question whethe Standard No. 121, *Air Brake Systems*. applies to an air dryer that is installed in the air brake system of trucks that must comply with the standard.; The answer to your question is no. Paragraph S3 (Applicability) o Standard No. 121 states that the standard applies to trucks, buses, and trailers equipped with air brake systems (with some specified exceptions). The standard therefore applies only to vehicles, and does not apply to motor vehicle equipment such as the Raycor air dryer unit. The vehicles in question must, of course, conform to Standard No. 121 following installation of the device, if the installation occurs prior to the first purchase in good faith for purposes other than resale.; A copy of Standard No. 121 is enclosed for your information. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3032OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your May 21, 1979, letter confirming your discussion with Roger Tilton of my staff relating to the emergency exit requirements of school buses that are constructed with an additional exit door. The additional door is installed so that the vehicle can be better used as a general transit vehicle when not in use for school purposes.; The statements that you make in your letter are, for the most part accurate. However, your third statement which indicates that the additional door could not be marked as an emergency exit is not entirely accurate. Additional emergency exits in school buses, beyond those required by Standard No. 217, *Bus Window Retention and Release*, must comply with the emergency exit requirements applicable to exits in non-school buses. If the door to which you refer is not designed or constructed as an emergency exit but rather is designed as an additional door for the routine loading and unloading of passengers, it need not be labeled as an emergency exit. If on the other hand the door is intended as an emergency exit and is constructed in accordance with the emergency exit requirements for doors in non-school buses, it should be labeled as an emergency exit in accordance with the labeling requirements for exits in non-school buses.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3462OpenMr. J. Kawano, General Manager, U.S. Representative Office, Toyota Motor Co., Ltd., One Harmon Plaza, Secaucus, NJ 07094; Mr. J. Kawano General Manager U.S. Representative Office Toyota Motor Co. Ltd. One Harmon Plaza Secaucus NJ 07094; This responds to your letter of February 3, 1981, asking two question about Safety Standard No. 105, *Hydraulic Brake Systems*. The questions were asked in regard to a type of brake reservoir you are considering producing which would service both the braking system and the clutch.; The first question is whether an interpretation you have made o section S5.4.2 of the standard is correct. The essential issue to that question is whether hydraulic fluid which is available to the clutch, either for normal use or in the event of clutch failure, can be counted as part of the minimum capacity required by section S5.4.2 for the braking system. The agency interprets the standard to require that the minimum fluid capacity requirements for brake reservoirs be met by fluid which is not available to the clutch, either during normal use or in the event of clutch failure. Thus, as will be explained below, your interpretation is incorrect.; Safety Standard No. 105 establishes requirements for a vehicle' braking system, including minimum capacity requirements for the reservoirs. Neither this standard nor any other Federal motor vehicle safety standard includes requirements for the reservoirs of a vehicle's clutch. While nothing prohibits a manufacturer from producing a master cylinder which service both the vehicles braking system and clutch, the minimum fluid capacity requirements for reservoirs must be met separately for a vehicle's braking system.; The first sentence of section S5.4.2 states: >>>Reservoirs, whether for master cylinders or other type systems shall have a total minimum capacity equivalent to the fluid displacement resulting when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position (as adjusted initially to the manufacturer's recommended setting) to a fully worn, fully applied position, as determined in accordance with S7.18(c) of this standard.<<<; This section specifies the total minimum fluid capacity that vehicle's braking system reservoirs must have. That amount is determined by reference to the vehicle's braking system, i.e., by the fluid displacement which results when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position to a fully worn, fully applied position. The purpose of this requirement is to assure that a vehicle's braking system reservoirs have adequate fluid capacity to service the brakes.; The agency interprets section S5.4.2 to require that the minimum flui capacity requirements for brake reservoirs be met by fluid which is solely available to the brakes. If fluid is available to both the brakes and the clutch, some of that fluid is available to both the brakes and the clutch, some of that fluid will be used by the clutch in normal service and thus be unavailable to the brakes. In the event of clutch failure, all of the common fluid may be used by the clutch. Therefore, while Standard No. 105 does not prohibit manufacturers from producing master cylinder with reservoirs that have some fluid available to both the braking system and clutch, non of that common fluid may be counted toward meeting the minimum fluid capacity requirements of section S5.4.2.; Your interpretation of section S5.4.2 is incorrect because it count common fluid toward meeting these requirements. In reference to Figure 1 that you attached with your letter, no fluid above the top of the wall dividing X and Y from Z should be counted toward meeting section S5.4.2's requirements.; We are aware that this interpretation conflicts with our July 10, 1974 interpretation that you attached with your letter and regret any inconvenience. That interpretation indicated that all five designs included in your letter of May 24, 1974, appeared to conform to section S5.4.1, providing that the reservoir capacity requirements of section S5.4.2 were met. That interpretation did not properly consider the requirements of section S5.4.2, as discussed above. It should have indicated that designs (3) and (4) do not comply with Standard No. 105 because they cannot meet section S5.4.2's minimum capacity requirements without counting fluid that is common to the braking system and clutch.; Your letter also asked about which fluid should be counted i determining the minimum warning level specified in section S5.3.1(b). That section refers to a drop in the level of brake fluid in any master cylinder reservoir compartment to less that the recommended safe level specified by the manufacturer or to one-fourth of the fluid capacity of that reservoir compartment, whichever is greater.; The minimum warning level is thus determined by the fluid capacity o each compartment rather than by the total capacity of the reservoir, unless the manufacturer recommends a higher safe level. In reference to Figure 1 that you attached with your letter, the compartments in question are X and Y. Thus, the warning level for compartment X must not be less than 1/4 of the capacity of X. Similarly, the warning level for compartment Y must not be less that 1/4 the capacity of Y. Since there may be safety advantages to higher warning levels, particularly where the capacity of individual compartments is small in relation to the capacity of the reservoir, you may wish to specify a higher warning level such as that indicated in Figure 1, i.e., at a level above the wall separating X form Y.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3198OpenMr. Jack D. Rainbolt, Chief Engineer, Air Brakes Transportation Division, BF Goodrich Company, P.O. Box 340, Troy, OH 45373; Mr. Jack D. Rainbolt Chief Engineer Air Brakes Transportation Division BF Goodrich Company P.O. Box 340 Troy OH 45373; Dear Mr. Rainbolt: This responds to your October 29, 1979, letter asking about brak adjustments prior to testing for compliance with Standard No. 121, *Air Brake Systems*. In your letter, you ask that the agency permit up to three adjustments during the burnish for dynamometer testing.; By letter of interpretation and by preamble to our November 197 Federal Register Notice (39 FR 39880), adjustments were permitted during the burnish procedures in S6.1.8 and S6.2.6 for the purpose of controlling brake temperature. According to agency information at the time of those interpretations, controlling brake temperature was the only reason that would require the use of brake adjustments during burnish. In a subsequent letter to the agency, you requested that we modify that position in light of your experience with disc brakes and their need for adjustment during burnish for dynamometer testing for reasons other than temperature control. The agency denied that request in April of 1979 while suggesting that the NHTSA would reconsider if more supporting data were supplied.; In response to the agency's request for more data, you have submitte another request for interpretation. To support this request, you have provided information in you letter and have also provided other information directly to our technical staff. As a result of this information, the agency agrees that adjustments during the burnish procedures may be necessary for reasons other than temperature control. Accordingly, the agency will permit adjustments during the burnish procedures for the sections cited above for any reason.; The standard presently is silent on the issue of how many brak adjustments may be made during burnish. As discussed with you and your staff we are considering limiting the number of adjustments to three during the burnish tests. However, no limitation is in effect at this time. The agency will undertake rulemaking shortly to limit the number of adjustments during burnish and encourages manufacturers to limit adjustments to three in the interim.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4348OpenMarzia Puccioni Jones, Alpex Manufacturing Company, 10926 'J' Street, Omaha, NE 68137; Marzia Puccioni Jones Alpex Manufacturing Company 10926 'J' Street Omaha NE 68137; Dear Mr. Jones: This letter responds to your letter enclosing a prototype horn/ligh and requesting information on its 'legality.' The horn/light is intended to be installed on the roof of a pickup truck or van. The light is located on the rear of the horn and would be visible to following drivers. The light comes on when the driver presses the horn button to sound the horn and goes off when the horn button is released. I regret the delay in this reply.; You asked whether the horn complies with safety and other pertinen regulations, whether the light at the back of the horn must be red or amber, whether it is permissible to mount the horn on the cab of a pick-up truck or van roof, and whether the horn is 'DOT-approved,' or if it would be in violation.; The National Highway Traffic Safety Administration (NHTSA) issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment pursuant to its authority under the National Traffic and Motor Vehicle Safety Act. However, NHTSA does not approve motor vehicles or motor vehicle equipment, nor does it endorse any commercial product. Instead, the Vehicle Safety Act establishes a 'self- certification' process under which each manufacturer must certify that its product meets applicable safety standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; There is only one standard which may apply to your product if it i installed on new vehicles. Standard 108, *Lamps, Reflective Devices, and Associated Equipment*, applies to vehicle lighting. As we understand your product, its light is not intended to serve as any of the lights required by the standard on a van or pickup. Therefore, the requirements directed to those types of lights would not be applicable. However, there is a general requirement that might affect your horn/light. S4.1.3 prohibits the installation of any light that would impair the effectiveness of any required light. The activation of the light on your product could lead following drivers to believe incorrectly that the vehicle equipped with your product is stopping. Repeated false stopping signals might reduce the following driver's responsiveness to the activation of the vehicle's brake lights.; If your product is installed as aftermarket equipment, it would not b subject to any requirement in Standard No. 108. Standard No. 108 covers aftermarket lighting equipment only to the extent that the aftermarket light replaces required original lighting equipment. Because there is no original equipment requirement for the kind of light you described, the standard does not apply to your aftermarket product.; Regardless of whether your product is affected by any of our standards please be aware that if you or the agency finds your product to contain a safety-related defect after you market the product, you are responsible for conducting a notice and recall campaign under S154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C 1414).; Further, you should be aware that State law may apply to products suc as your horn/light. You may wish to consult the State and local transportation authorities in the areas where you intend to market your horn.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3177OpenMr. Frank Dana, Haynsworth, P.O. Box 2048, Greenville, SC 29602; Mr. Frank Dana Haynsworth P.O. Box 2048 Greenville SC 29602; Dear Mr. Dana: This is in response to your telephone conversation with Kathy DeMete of my staff on Friday, December 21, 1979. You asked for the status of section 580.5(a)(1) of Title 49 of the Code of Federal Regulations. That section exempts from the odometer disclosure requirements anyone transferring a vehicle having a gross vehicle weight rating of more than 16,000 pounds. That exemption is part of the regulation, originally issued in January 1973, which prescribes rules requiring a transferor of a motor vehicle to make a written disclosure to the transferee concerning the odometer reading and its accuracy.; In January 1977, the exemption was declared void by the United State District Court for the District of Nebraska on the grounds that the National Highway Traffic Safety Administration (NHTSA) has exceeded its authority in fashioning the exemption. Notwithstanding the court's decision, the NHTSA believes that it has the authority to create exemptions for vehicles for which the odometer reading is not relevant. The exemption, consequently, remains a part of the odometer disclosure regulations.; For your information, I have enclosed copies of the statement submitted by Freightliner, White, and the National Association of Motor Bus Operators, which support the exemption for larger vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4718OpenMr. Gary R. Balanza P.O. Box 88112 Honolulu, HI 96830; Mr. Gary R. Balanza P.O. Box 88112 Honolulu HI 96830; "Dear Mr. Balanza: This is in reply to your letter asking for a interpretation whether your invention 'will interfere with the standard equipment' required by Motor Vehicle Safety Standard No. l08. I regret the delay in responding. Your invention, 'Pinlights', is described as an auxiliary lighting system designed to fit an automobile's side contours. Its purpose is to light up the entire length of a vehicle, so that it will be more conspicuous at night. We note your uncertainty as to 'number of stripes allowed on a car', 'colors allowed on a car', and 'maximum brightness allowable.' There are two ways to approach your invention under the National Traffic and Motor Vehicle Safety Act, our authority for the issuance of the motor vehicle lighting standard, Standard No. l08. The first is as an item of original equipment, in place on the vehicle at the time it is bought by its first owner. You have asked the correct question: does the invention impair the effectiveness of the lighting equipment required by Standard No. l08? The equipment most likely to be impaired are the side marker lamps and reflectors. These items are located near the front and rear of the vehicle, to enhance vehicle conspicuity by affording an approximation of vehicle length, and an indication of the vehicle's front and rear. The lamps are amber to the front, and red to the rear. Your invention would be located along the side of the vehicle, from front to rear. This suggests that the color of your device should similarly be amber to the front and red to the rear, so as not to impair the effectiveness of the directional function of the side marker lamps. The second way to approach your invention is as an item available in the aftermarket. Standard No. l08 does not apply to a vehicle in use. However, as it applies to your question, the Vehicle Safety Act prohibits modifications by manufacturers, distributors, dealers, or motor vehicle repair businesses if they render inoperative, in whole or in part, any of the required lighting equipment. In most cases, we consider an impairment of new vehicle equipment to be equivalent to a partial inoperability. Further, if installation of aftermarket equipmentdirectly affects the performance of original equipment (such as a reduction of light output through an interference with the wiring), that would certainly be considered a partial inoperability. Lighting equipment that is not covered by Standard No. l08 remains subject to the requirements of each State in which a vehicle on which it is installed is registered and/or operated. We are unable to advise you on State laws, and suggest that, for an opinion, you write the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Stephen P. Wood Acting Chief Counsel /"; |
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ID: aiam3527OpenMr. Robert J. Carter, Director, Consumer and Technical Affairs, Woodhill Permatex, 18731 Cranwood Parkway, Cleveland, OH 44128; Mr. Robert J. Carter Director Consumer and Technical Affairs Woodhill Permatex 18731 Cranwood Parkway Cleveland OH 44128; Dear Mr. Carter: This responds to your recent letter concerning a product yo manufacture which is used to repair breaks in automobile windshields. You ask whether such a repair product would conflict with any present motor vehicle safety standards.; The National Highway Traffic Safety Administration has issued Federa Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair product such as you describe, however. There is no Federal regulation which would prohibit the use of such a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new windshield which may require repair as a result of damage sustained, for example, in shipment could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, which would be the responsibility of the person selling the windshield. Therefore, we do not recommend use of windshield repair kits prior to the first purchase of a new windshield by a consumer.; Please contact Hugh Oates of my staff if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5559OpenMr. Ron Hooker Missouri Department of Agriculture P.O. Box 630 Jefferson City, MO 65102-0630; Mr. Ron Hooker Missouri Department of Agriculture P.O. Box 630 Jefferson City MO 65102-0630; "Dear Mr. Hooker: This responds to your question about whether th State of Missouri has authority to promulgate regulations relating to the safety of motor vehicles powered by alternative fuels, particularly compressed natural gas (CNG). The short answer is that while Missouri is generally preempted in this area, it could issue its own more stringent safety standard for State-owned vehicles. Federal law will preempt a State law if (1) there is a Federal safety standard in effect, (2) the State law covers the same aspect of performance as that Federal standard, and (3) the State law is not identical to the Federal standard. Specifically, section 30103(b) of Title 49 of the United States Code states that (b) Preemption. - (1) When a motor vehicle safety standard is in effect under this chapter, a State or political subdivision of a State may prescribe or continue in effect a standard applicable to the same aspect of performance of a motor vehicle or motor vehicle equipment only if the standard is identical to the standard prescribed under this chapter. However, the United States Government, a State, or a political subdivision of a State may prescribe a standard for a motor vehicle or motor vehicle equipment obtained for its own use that imposes a higher performance requirement than that required by the otherwise applicable standard under this chapter. State safety standards applicable to CNG fuel system integrity are generally preempted by Federal law. The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standard (FMVSS) No. 303, Fuel system integrity of compressed natural gas vehicles. (59 FR 19659, April 25, 1994, copy enclosed). The Standard specifies frontal barrier and rear barrier crash tests conducted at 30 mph and a lateral moving barrier crash test conducted at 20 mph. The Standard applies to passenger cars, multipurpose passenger vehicles, trucks and buses that have a gross vehicle weight rating (GVWR) of 10,000 pounds or less and use CNG as a motor fuel. It also applies to school buses regardless of weight that use CNG as a motor fuel. The Standard takes effect September 1, 1995. Accordingly, after September 1, 1995, Missouri could only issue its own safety standard applicable to CNG vehicle fuel system integrity if the State safety standard is identical to FMVSS No. 303. The one exception to requiring such identical standards is that Missouri could prescribe a standard for motor vehicles obtained for its own use, provided the State law imposed a higher performance requirement than the level of performance prescribed by FMVSS No. 303. Thus, Missouri could issue its own more stringent safety standard for State-owned vehicles. NHTSA further notes that Missouri is free to issue safety standards applicable to the fuel system integrity of vehicles powered by other alternative fuels (e.g., liquid propane, hydrogen), since the agency has not issued any FMVSS applicable to other alternative fuels. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure "; |
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ID: aiam3874OpenMr. Gordon G. Berge, Mandan Public School District, Central Administration Building, 309 Collins Avenue, Mandan, ND 58554; Mr. Gordon G. Berge Mandan Public School District Central Administration Building 309 Collins Avenue Mandan ND 58554; Dear Mr. Berge: This responds to your December 3, 1984 letter to the National Highwa Traffic Safety Administration (NHTSA) concerning the use of Greyhound-type buses to transport school children to school-related activities. You stated that the Mandan Public School District is considering purchasing 1963 and 1965 model year Greyhound-type buses for the purposes of transporting elementary and secondary students to activity events. Your first question asked whether this would be allowed under our regulations on school buses.; To begin, I would like to explain that there are two sets o regulations, issued under different Acts of Congress, that could affect Mandan's choice of buses. The first of these, the motor vehicle safety standards issued by our agency under the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563, 15 U.S.C. 1381-1426) apply to the manufacture and sale of new motor vehicles. In a 1974 amendment to the Act, Congress expressly directed us to issue standards on specific aspects of school bus safety, including emergency exits, seating systems, window and windshields, and bus structure. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. If Mandan had planned to buy a *new* bus for use as an activity bus, the manufacturer and dealer must certify that the bus complies with the motor vehicle safety standards applicable to school buses.; Since Mandan plans to buy 1963 and 1965 model year buses, however, th Vehicle Safety Act standards do not apply. There is nothing under that Act to prevent Mandan from buying a bus that was manufactured before the effective date of the school bus safety standards for school use. There might, however, be an impediment under State law, if North Dakota has adopted the provisions of the standard on school transportation issued by our agency under the Highway Safety Act (Public Law 89- 564, 23 U.S.C. 401-408). This standard, Highway Safety Program Standard No. 17 (HSPS 17), specifies that a bus used to transport more than 16 pupils to and from school should be painted yellow, be equipped with special mirrors and warning lights, and be marked 'School Bus.' We have ruled that the States should apply these specifications to activity buses as well as to the buses used for daily transportation.; I want to stress that HSPS 17 has no direct effect on Mandan's purchas of 1963 and 1965 model year buses. HSPS 17 will affect Mandan only if North Dakota has adopted it and if North Dakota accepts our view that the specifications apply to activity buses. If North Dakota chooses to exempt activity buses from being painted, signed, and equipped as school buses, we might disagree with the wisdom of its decision but we would not insist on compliance with HSPS 17 to the extent of taking action against the State. Congress has given us discretion under the Highway Safety Act not to insist that a State comply with every requirement of the highway safety standards. While we have stressed the importance of a strong pupil transportation program, consistent with HSPS 17, we have not insisted that the States comply with every feature of the standard.; Having said this, however, I would like to restate the importance tha our agency attaches to the use of safe buses to transport children. It remains the agency's position that a yellow school bus meeting the motor vehicle safety standards is the safest means of transportation for school children. It may not be the most comfortable for long trips, since it lacks the reclining seats and restroom facilities of the Greyhound-type buses, but it has safety features that the Greyhound-type buses that you are considering lack, such as seat backs designed to cushion impacts, windows that prevent ejections, and exits that facilitate escape after crashes. In the years since buses began to be manufactured with these features, there has been a marked improvement in school bus safety. These are features that Mandan should consider before it decides to buy a Greyhound-type bus.; Your second question asked whether Mandan may charter Greyhound-typ buses from a common carrier to transport students to school-related events.; Again, Mandan would not be precluded from chartering Greyhound-typ buses if North Dakota has not adopted our view that the specifications of HSPS 17 apply to activity buses.; If you have any further questions, please do not hesitate to contac us.; Sincerely, Frank Berndt, Chief Counsel |
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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.