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: aiam4060OpenMr. Russ L. Bomhoff, Special Projects Director, Precision Pattern Inc., 1643 S. Maize Road, Wichita, KS 67209; Mr. Russ L. Bomhoff Special Projects Director Precision Pattern Inc. 1643 S. Maize Road Wichita KS 67209; Dear Mr. Bomhoff: Thank you for your letter of October 30, 1985, asking about the effec of our regulations on several components you wish to install in the interior of a passenger car. I hope the following discussion answers your questions.; All new vehicles manufactured for sale in the United States must b certified by their manufacturer as complying with the Federal motor vehicle safety standards. If you are installing the components described in your letter in a new vehicle prior to its first sale to a consumer, then you would be considered a vehicle alterer. Under our certification regulation (49 CFR Part 567), a vehicle alterer must certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards. Since you are modifying the interior of the passenger car, you must ensure that the vehicle will still comply with Standard No. 201, *Occupant Protection in Interior Impact*, a copy of which is enclosed.; If you are making these alterations to a used vehicle, then you, as commercial business, would be covered by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. That section prohibits manufacturers, dealers, distributors, and motor vehicle repair shops from knowingly rendering inoperative any element of design installed on a vehicle in compliance with Federal safety standards. Thus, in installing the components you described, you cannot render inoperative the vehicle's compliance with Standard No. 201 or any of our other standards.; The potential effect of Standard No. 201 on each of the components yo asked about is discussed below.; *Front and rear seat cooler consoles*. S3.1 of the standard sets performance requirements for the instrumen panel. S3.1.1(a) of the standard specifically provides that the instrument panel requirements do not apply to console assemblies. We would consider both the front and rear seat coolers to be console assemblies and thus exempt from the requirements of S3.1.; S3.3 of the standard requires interior compartment door assemblie located in an instrument panel, a console assembly, a seat back, or a side panel adjacent to a designated seating position to remain closed under certain test conditions. The purpose of the requirement is to prevent a door from flying open and striking an occupant in a crash. The doors in the front and rear consoles would have to meet this requirement.; *Seat back fold-down tables*. S3.2 of the standard sets performance requirements to limit injurie caused when rear seat occupants strike the seat backs in front of them. You would have to ensure that the seat backs would still comply with S3.2 when the fold- down tables are installed.; The fold-down tables mounted in the seat back and the door do not hav to meet the requirement in S3.3 for interior compartment doors. However, since both those items are hinged surfaces which could fly open in a crash and pose a hazard to an occupant in a crash, we urge you to ensure that the tables will be adequately secured in a crash.; S3.5 of the standard sets requirements for armrests. You would have t ensure that the vehicle will still comply with S3.5 when the fold-down table is installed in the door.; *TV/VCR Cabinet* There are no requirements that apply to the TV/VCR cabinet. If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1798OpenHonorable Warren G. Magnuson, Chairman, Committee on Commerce, United States Senate, Washington, DC 20510; Honorable Warren G. Magnuson Chairman Committee on Commerce United States Senate Washington DC 20510; Dear Mr. Chairman: This is in response to your letter of January 31, 1975, in which yo asked whether the question of a lowering of the bumper impact requirements had been prejudged, and also requested our position on the question of cost-effectiveness of bumper designs.; With respect to your first question, I give you my unqualifie assurance that the question of what bumper impact level should be required has not been prejudged. My mind is certainly still open, and we are examining with keen interest the comments we are receiving on the proposal before any final decision is made. The statement you quoted, that certain factors lead us to believe that the proposed action 'appears to be necessary,' reflects the attitude of tentative judgment that we normally have at the time a proposal is issued. The comments we receive help us to determine whether the 'appearance' of the necessity of an action is realistic.; The problem of obtaining the most cost-effective bumper designs i response to a performance standard is a difficult one. With most standards the problem has not been as significant, because the interest of manufacturers in keeping their costs down generally has coincided with the best interest of the consumer. A bumper that provides significant protection can be such a major weight factor, however, that the cheapest design from a manufacturer's standpoint may not be the least costly to the consumer if lifetime fuel and maintenance costs are figured in.; We are studying the possibility of putting a limit on bumper weight a an explicit requirement of the bumper standard. We have no doubt that the Motor Vehicle Information and Costs Savings Act gives us the legal authority to do this, since weight and the attendant fuel penalty is a major factor in consumer cost. The questions we have at this time involve technology (*e.g.*, how to identify the systems in question so that their weight can be objectively limited without undue design restriction) and policy (*e.g.*, whether weight limitations may lead to new cost-effectiveness problems if manufacturers choose to use exotic materials); I deeply appreciate the interest you have shown in this matter. I a sure our interests coincide: obtaining the greatest net benefits from the bumper systems that consumers buy.; Sincerely, James B. Gregory, Administrator |
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ID: aiam0756OpenMr. Chester R. Ely, President, Mercury Fabricators, 8335 Atlantic Boulevard, Cudahy, CA 90201; Mr. Chester R. Ely President Mercury Fabricators 8335 Atlantic Boulevard Cudahy CA 90201; Dear Mr. Ely: This is in reply to your letter of June 20, 1972, in which you as whether Motor Vehicle Safety Standards No. 206 (Door Locks and Door Retention Components) and 302 (Flammability of Interior Materials) apply to aluminum sleeper cabs which you manufacture for what appears to be installation on truck tractors.; Each motor vehicle safety standard is by its terms applicable t specific types of motor vehicles and motor vehicle equipment. Each vehicle or item of equipment to which a standard applies must conform to the standard until its first purchase by a user. Components which are incorporated into vehicles before their first purchase are considered to be part of the vehicle, and as a practical matter must conform to all standards applicable to it.; Standard No. 302 becomes effective September 1, 1972, and applies t trucks, which includes truck tractors. If a sleeper cab you manufacture is incorporated into a truck before its first purchase by a user, then it must conform to the standard. Moreover, the components to which the standard applies (paragraph S4.1) include mattress covers, and if you determine the standard applies under the criteria we have provided, mattress covers which you furnish must conform to the standard. You indicate you have tested the flammability of the cab utilizing a torch. While you may test for conformity to the standard in any way you choose, whether or not your product conforms to the standard will be determined by NHTSA utilizing the test procedures specified in the standard. Manufacturers who utilize procedures different from those in the standard should take care to correlate the results they obtained to those that would be obtained using the standard's procedures.; Standard No. 206 also applies to trucks, and will become effective fo all side doors leading to passenger compartments on September 1, 1972. Consequently, if the sleeper cabs you manufacture are incorporated into trucks before their first purchase the sleeper cabs must conform to Standard No. 206.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5554OpenMs. Barbara Bailey Administrative Assistant Camp Berachah Christian Retreat Center 19830 S.E. 328th Place Auburn, WA 98092-2212; Ms. Barbara Bailey Administrative Assistant Camp Berachah Christian Retreat Center 19830 S.E. 328th Place Auburn WA 98092-2212; "Dear Ms. Bailey: This responds to your letter and telephone call t Walter Myers of this office asking two questions about new 15-passenger vans that Camp Berachah leased from a dealer. I apologize for the delay in this response. You first asked whether we require the leased vans to comply with our Federal motor vehicle safety standards (FMVSS) for school buses. You also asked whether we require the vans to comply with those FMVSSs if Camp Berachah loaned or subleased them to a school. Subject to a few considerations, the answer to both questions is no. Some background information on our school bus regulations would be helpful. Our regulations require any person selling or leasing a new vehicle to sell or lease a vehicle that meets all FMVSSs applicable to that vehicle. Accordingly, persons selling or leasing a new school bus must sell or lease a vehicle that meets the FMVSSs applicable to school buses. Under 49 U.S.C. 30101, et seq. (referred to as Safety Act), a school bus is any vehicle that carries 11 or more persons and which is likely to be significantly used to transport students to or from school or related events. Thus, persons selling or leasing a new vehicle that carries 11 or more persons and which is likely to be significantly used to carry students is selling or leasing a new school bus. That means that the new vehicle must meet the school bus FMVSSs. The FMVSSs apply only to new vehicles prior to sale to the first retail purchaser. The onus of complying with the school bus regulations is mainly on the seller or dealer to ensure that each new school bus it sells or leases has been certified to the school bus FMVSSs. The purchaser, on the other hand, is not subject to such constraints. Under our school bus regulations, the purchaser is free to use any vehicle to transport school children. That is because this agency does not regulate the use of vehicles once they have been sold at retail. Turning to your questions, we answer no to your first question based on the following. It was unclear from your letter whether Camp Berachah is connected with a school. In directing NHTSA to issue its school bus regulations, Congress considered buses used to transport children to camps connected with schools to be subject to the school bus FMVSSs. However, you clarified the nature of Camp Berachah in your conversation with Mr. Myers. You said that Camp Berachah is independent from any school and is not in any way affiliated with a school. Based on that information, Camp Berachah does not appear to be a school. Thus, our school bus regulations do not require the leasing of complying school buses for Camp Berachah purposes. In your second question, you asked whether the new leased vans had to comply with the school bus FMVSSs if Camp Berachah lent, rented or subleased them to a school. The answer depends on whether the vans are significantly used for pupil transportation, and if so, whether the dealer knew or should have known of such use. New vans that are likely to be significantly used to transport school children would be school buses, and the dealer leasing the new van is required to lease certified school buses. Use of the vans on a one-time or occasional basis would not constitute significant use as a school bus. However, if Camp Berachah were to sublease the vans to a school for long-term use, we believe the use of those vans for school transportation would be significant within the meaning of the Safety Act. Accordingly, the leasing company could not lease a new van for this purpose. You should also note that the states have the authority to regulate the use of vehicles by motorists. Thus, although NHTSA does not require the sale or use of complying school buses in the situations you described, Washington does have such authority. You may wish to contact the state director of pupil transportation to learn more about any state requirements applicable to vehicles used as school buses. In closing, we would like to note that school buses are one of the safest forms of transportation in this country. We therefore strongly recommend that all 15-passenger vans that are used to transport school children be certified as meeting the school bus safety standards. I hope this information is helpful. Should you have any further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2291OpenMr. Gilbert Theissen, 6S Hayden Hall, 33 Washington Square West, New York, NY 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York NY 10011; Dear Mr. Theissen: This is in response to your letter of February 5, 1976, to Mrs Winifred Desmond of this agency concerning braking and rollover characteristics of the Jeep vehicle. We are sorry for the delay in our answer.; The Jeep Corporation is correct in saying that 49 CFR 571.105-75 *Hydraulic Brake Systems*, applies only to passenger cars. It will also apply to school buses manufactured after October 25, 1976. Part 575, Consumer Information Regulations, applies as a whole to all motor vehicles (49 CFR 575.4), but the consumer information item requiring reports on brake performance is limited to passenger cars and motorcycles (49 CFR S 571.101).; With regard to rollover resistance, the agency has issued an advanc notice of proposed rulemaking to collect information on rollover resistance, but no requirement to report on rollover performance exists at this time.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam1517OpenMr. George C. Nield,Engineering advisor,Busby Rivkin Sherman Levy and Rehm,900 17th Street, N.W., Suite 1100,Washington, D.C, 20006; Mr. George C. Nield Engineering advisor Busby Rivkin Sherman Levy and Rehm 900 17th Street N.W. Suite 1100 Washington D.C 20006; Dear Mr. Nield:#This is in response to your letter of JUne 10, 1974, i which you asked for our interpretation of the preemption provisions of the National Traffic and Motor Vehicle Safety Act (sec. 103(d)) with respect to the Pennsylvania position on brake hose. A letter that you enclosed from the Pennsylvania Department of Transportation advised a manufacturer's representative that 'Pennsylvania will continue to approve brake hoses under the SAE Standards for air, hydraulic and vacuum hose,' and that the State 'will continue to require the hose be identified in the same manner as our present regulations.' with the Federally-required labeling placed on 'a separate line' from the State's labeling.#Section 103(d) of the Act, 15 U.S.C 1392(d), plainly prohibits any State from establishing or continuing in effect a safety standard applicable to an item of motor vehicle equipment, where there is an applicable Federal standard, unless the State standard is 'identical to the Federal standard.' This preemption provision takes effect whenever a Federal standard is applicable to the same aspect of performance as the State standard. When the new Federal standard on brake hoses comes into effect, with its testing and labeling requirements, any differing State standards, as Pennsylvania's appear to be will be preempted and void.#Sincerely, Lawrence R, Schneider,Chief Counsel; |
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ID: aiam4715OpenMr. Frederick H. Dambach President Execuline 997 Brook Rd. Lakewood, NJ 08701; Mr. Frederick H. Dambach President Execuline 997 Brook Rd. Lakewood NJ 08701; "Dear Mr. Dambach: This is in response to your letter requesting that reconsider my conclusion in a July 26, 1989, letter to you interpreting emergency exit requirements contained in Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Window Retention and Release. I regret the delay in responding. As is explained below, after reconsideration, I must still conclude that exits located in the roof of a bus do not satisfy the requirement contained in S5.2 of Standard 217, that 40% of the required emergency exit space on a transit bus must be located on each side of the bus. Your August letter argues that roof exits must be counted in determining compliance with S5.2 because the standard does not specifically state that a side is that part of a bus that is perpendicular to the floor. Instead, relying upon provisions of the Federal Highway Administration's (FHWA) regulations at 49 CFR Part 393, you assert that the side of a bus is any part to the left or right of the roof centerline. While this may be true under the FHWA regulations, those regulations are being used in a completely different context than Standard No. 217, and concern lighting and marker requirements and specifications for towing for motor carriers. Standard 217, on the other hand, specifies requirements for the operating forces, opening dimensions, and markings for emergency exits in buses to ensure readily accessible emergency egress from these vehicles. Because of the different purpose and context of Standard 217 and the FHWA regulations, the definition of the word 'side' is not necessarily the same for those regulations. In fact, as I explained in detail in my previous letter to you, the structure and purpose of Standard 217 show that the word 'side' has a different meaning in Standard 217 than it does when used by the FHWA in Part 393. Moreover, and contrary to the assertion in your letter, Standard 217 is not a subpart of Part 393. Standard 217 is found in 49 CFR Part 571. The Standard is a Federal Motor Vehicle Safety Standard (FMVSS), administered by NHTSA. Under Federal law, these standards are applicable to manufacturers (including importers) of motor vehicles. On the other hand, Part 393, administered by the FHWA, is a part of the Federal Motor Carrier Safety Regulations, which are applicable to motor carriers. Although NHTSA and FHWA coordinate with each other to avoid conflicts in our respective regulatory programs, the FHWA does not have authority over motor vehicle manufacturers. Likewise, NHTSA does not have authority over motor carriers. This agency has statutory authority to regulate the manufacture, importation, distribution, and sale of new motor vehicles and new items of motor vehicle equipment. Additionally, our statute prohibits any manufacturer, distributor, dealer, or repair business from 'rendering inoperative' any device or element of design installed on or in a vehicle in compliance with a safety standard. However, this agency has no authority to regulate the operation and use of vehicles. Hence, NHTSA cannot require the vehicles used in your company's fleet to comply with Standard 217 or any other Federal motor vehicle safety standards. However, the individual States are free to regulate the operation and use of vehicles within their borders, provided that those regulations do not contravene any Federal laws or regulations. In this case, the State of New Jersey has chosen to adopt the provisions of Standard 217 and make it applicable to vehicles operated within New Jersey. This choice by the State of New Jersey does not contravene any of this agency's statutes or regulations. Thus, while I appreciate that New Jersey's decision to apply Standard 217 to vehicles operated in the State may have caused you difficulties, the wisdom and fairness of that decision is a matter to be decided by the State of New Jersey, not this agency. I hope this information is helpful. Please contact David Greenburg of this office at (202) 366-2992 if you have any further questions. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1147OpenMr. Charles H. Sturgeon, Traffic Manager, Grove Manufacturing Company, Shady Grove, PA 17256; Mr. Charles H. Sturgeon Traffic Manager Grove Manufacturing Company Shady Grove PA 17256; Dear Mr. Sturgeon: This is in reply to your letter of April 23, 1973, requesting ou confirmation of certain issues discussed by you, and Michael Peskoe and David Fay of NHTSA, in a meeting in Mr. Peskoe's office on April 19, 1973.; It is correct that the NHTSA does not presently employ safet inspectors to inspect vehicles in service. Such inspections are made by inspectors of the Bureau of Motor Carrier Safety in the Federal Highway Administration, and it is true that their primary interest is the enforcement of the Bureau of Motor Carrier Safety regulations (49 CFR Parts 301-398). But if these investigators note violations of NHTSA regulations, the information will be forwarded to NHTSA and appropriate action will be taken.; It is correct that components of a vehicle in service may be added removed, or relocated at the discretion of a vehicle owner without violating NHTSA regulations. However, gross vehicle and axle weight ratings established by the vehicle manufacturer must be based on configurations of the vehicle which the manufacturer expects will be utilized in service. It is also correct that the weight imposed on each axle should not exceed the certified weight rating for each axle, but may be less than the certified weight rating.; Finally, it is correct that gross axle weight ratings may b established with a view towards the weight limitations of States in which the vehicle will be used.; Gross axle and vehicle weight ratings, under NHTSA regulations, ar manufacturers' figures, and may be set at any level as long as the figures are consistent with the limitations specified in the NHTSA certification regulations. However, the weight ratings must also, of course, be consistent with the vehicle's load-carrying capacity.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3480OpenMr. T. Fumima, President, Taiyo Trading USA Inc., 1543 West Olympic Boulevard, Los Angeles, CA 90015; Mr. T. Fumima President Taiyo Trading USA Inc. 1543 West Olympic Boulevard Los Angeles CA 90015; Dear Mr. Fumima: This responds to your letter of June 17, 1981, asking about th applicability of Federal motor vehicle safety standards to a manually operated door opener that you are considering importing. The door opener is designed for passenger cars and taxis and allows the driver to open the rear door by shifting a lever located by the driver's side.; By way of background information, the agency does not give approvals o vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. We note that the term 'manufacturer' is defined by section 102(5) of the Act to mean 'any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, *including any person importing motor vehicles or motor vehicle equipment for resale*.' Emphasis added. ; The agency does not have any regulations covering manually operate door openers. However, installation of such a device may affect a vehicle's compliance with other safety standards. If any standard would be affected, it would probably be Safety Standard No. 206, *Door Locks and Door Retention Components*. For your convenience, we have enclosed a copy of that standard, which includes performance requirements for a vehicle's latch and striker assembly, door hinges, and door locks. However, based on the limited drawings included with your letter, it is not possible for us to determine whether a vehicle's compliance with that standard would be affected. We suggest that you carefully examine the requirements of Standard No. 206 to make that determination.; If your device is added to a new motor vehicle prior to its first sale the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. You will find the specific certification requirements for alterers at 49 CFR Part 567.7, *Certification*. On the other hand, you as the manufacturer of the device would have no certification requirements, because we have no safety standards applicable to your equipment. However, an alterer would probably require information from you in order to make the necessary certification.; If your device is installed on a used vehicle by a business such as garage, the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, which states in relevant part:; >>>No manufacturer, distributor, dealer, or motor vehicle repai 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.<<<; Please feel free to contact us if you have any further questions. Yo may also wish to check with state and local authorities to determine whether the use of your device is affected by their regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4345OpenMr. Gary Harris, Division Quality Control Manager, LSI Safelite, 801 South Wichita, P. O. Box 1879, Wichita, KS 67201; Mr. Gary Harris Division Quality Control Manager LSI Safelite 801 South Wichita P. O. Box 1879 Wichita KS 67201; Dear Mr. Harris: This responds to your letter of February 17, 1987, concerning the us of a DOT code number on glazing material by someone other than the prime manufacturer. I regret the delay in our response. You indicate in your letter that a customer has requested that you, as the prime manufacturer of the glazing material, include in your trademark on each piece of glazing material the DOT code number issued to you. You refer to the particular glazing material in question as 'stock glass', since a customer purchases sheets for glazing material from you and then cuts the glazing into pieces for various unknown applications. You object to this request, because you have no control over the use to which the glazing material will be put. You request our opinion and we offer the following.; The marking and certification requirements for glazing materials ar continued in S6 of Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, and include different marking requirements for a prime manufacturer and other types of manufacturers. (A prime glazing material manufacturer is defined in S6.1 as one who fabricates, laminates, or tempers the glazing material.) The only glazing material which *must* carry the DOT code mark is that produced by a prime manufacturer and designed as a component of a specific motor vehicle or camper. Since you specifically indicate that you do not know the use of which the glazing material will be put, there is no *requirement* that this glazing material carry your manufacturer's code.; The purpose of the manufacturer's code is to help the agency identif the actual manufacturer of the glazing material for the purpose of defect and noncompliance recall campaigns. The difference in the marking requirements was designed to help the agency distinguish between glazing in a motor vehicle that had been manufactured by the prime manufacturer specifically for use in that vehicle and glazing that had been cut, shaped, or otherwise altered before installation. In a July 13, 1976, letter to 'Lucite' Acrylic Sheet Products, we stated that the certification requirements had become widely understood and uniformly practiced throughout the glazing industry, which has aided the traceability of glazing for enforcement purposes. We went on to say that, for these reasons, we were no longer prohibiting the use of the prime glazing manufacturer's code number by the distributor or manufacturer who cuts the glazing, if the prime glazing manufacturer grants permission for such use of the code number to the distributor or manufacturer.; In summary, you may include, if you wish, your DOT code number o glazing material not designed for use in a specific motor vehicle or camper, but sold by you to others. There is no obligation to do so, however. If you have further questions please feel free to contact us.; Sincerely, Erika Z. Jones, 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.