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: aiam2808OpenMr. Bruce Baldwin Mohs, President, Mohs Seaplane Corporation, 2355 University Avenue, Madison, WI 53705; Mr. Bruce Baldwin Mohs President Mohs Seaplane Corporation 2355 University Avenue Madison WI 53705; Dear Mr. Mohs: This is in reply to your letter of May 5, 1978, asking 'what i necessary for the rewriting of [Motor Vehicle Safety Standard No.] 108 to include my . . . system for vehicle identification.' As you have described this reflective device, it is a polyvinyl extrusion in which is placed polyester tape which 'becomes a continuous reflector down the side of a vehicle - amber toward the front, red on the rear half of the vehicle and red across the back.' You state that in your experimental installation you are 'retaining the 3' spot reflectors as required in Standard 108.'; If your material conforms to Federal Specification L-S-300 and, as use on the vehicle, meets the performance standards in Table 1 of SAE Standard J495d, 'Reflex Reflectors,' March 1967, it could be used as the front and rear reflex reflectors required by Standard No. 108. However, if it does not meet this specification, Standard No. 108 would not prohibit the sale and installation of your system as original equipment, or as an aftermarket accessory, provided it is supplementary to the side and rear reflectors required by Standard No. 108. Thus, no Federal 'approval' of your system is required. A change in Standard No. 108 is required only if you believe your system should be mandatory on all motor vehicles. In the event you wish to petition for such an amendment of Standard No. 108, I enclose a copy of our rulemaking procedures.; Yours truly, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4525OpenMr. Koji Tokunaga Manager, Engineering Isuzu Motors America, Inc. 21415 Civic Center Drive Southfield, MI 48076-3969; Mr. Koji Tokunaga Manager Engineering Isuzu Motors America Inc. 21415 Civic Center Drive Southfield MI 48076-3969; "Dear Mr. Tokunaga: This letter responds to your inquiry in which yo ask a number of questions concerning Federal motor vehicle safety standard (FMVSS) 124, Accelerator Control Systems. I apologize for the delay in this response. In your letter, you describe a new accelerator control system that operates through electrical rather than mechanical signals. You state that the moving components of this system are the accelerator pedal, stepping motor arm, linkage, and the throttle lever. When a driver depresses the accelerator pedal, a pedal sensor converts the displacement into a proportional electric signal. The signal goes through a control unit to a position switch, and then to a stepping motor. This stepping motor works to move the motor's arm and linkage, and they in turn work the throttle lever. Therefore, you say, the engine speed is controlled in proportion to the amount of accelerator pedal displacement. You further inform us that Isuzu already has distributed vehicles equipped with this system in Japan, and that the company would like to market this kind of vehicle in the United States. You present three questions and a diagram of the system components, and request an agency response. First, please be aware that in issuing this interpretation, NHTSA is neither approving, certifying, nor endorsing your new accelerator control system. Under the National Traffic and Motor Vehicle Safety Act, each manufacturer must certify that its product meets agency safety standards, or other applicable standards. However, based on the information you supplied in your letter, I have the following responses. Question I: In this vehicle, Isuzu considers the battery that drives the stepping motor to be one of the energy sources under S5.1, and the return springs (accelerator pedal and throttle lever return springs) the other sources. Is this interpretation correct? We do not have enough information to state whether the battery that drives the stepping motor, or the return springs would be considered energy sources under S5.1. Section S5.1 of Standard 124 requires, among other things, that there be a minimum of two energy sources capable of returning the throttle to idle whenever the driver removes the opposing actuating force, or if there is a single severance or disconnection in the accelerator control system. With respect to the battery, if all system elements are operating properly, then it would appear that removing the actuating force will cause the electrical circuit from accelerator pedal sensor to stepping motor to return the throttle to idle. On the other hand, if there is a failure caused by a severance or disconnection in the accelerator control system between the pedal and the stepping motor, it is not clear to me whether the stepping motor will return to zero, and bring the throttle springs back to idle, or lock the arm and linkage in an 'open-throttle' position. Similarly, it is not clear to me that the accelerator pedal and throttle return springs are capable of returning the throttle to idle in the event of a failure caused by an ACS severance or disconnection. (While you include the throttle lever in your description of the accelerator control system, the agency considers it as part of the fuel metering device. However, as NHTSA explained in the preamble to 124, an energy source under the Standard may be attached to the fuel metering device. 37 FR 20033, September 23, 1972. ) Ordinarily, the agency would have no difficulty in finding that either of the throttle return springs is an energy source capable of returning the throttle to idle. But I cannot tell from your description and diagram whether a severance or disconnection in the electrical system would cause the throttle to lock in a position other than idle. I would make the same observation with respect to the accelerator pedal. I can not tell from the information you supplied what impact a severance or disconnection failure would have on the pedal. For example, it is not apparent whether some element in the electrical system senses a severance or disconnection in the accelerator control system, so that a sensor transmits a signal to the appropriate energy sources that the throttle should return to idle. If the pedal and return springs can operate mechanically and in concert to return the throttle to idle in the event of a failure in the accelerator control system caused by a severance or disconnection, then together they may be an energy source under the Standard. Question 2a: Is a severance in electric wires in this system a severance or disconnection within the meaning of S5.2? Isuzu considers negative because electric wires are not a moving part. A severance or disconnection of the electric wires in this system would be a severance or disconnection within the meaning of S5.2 of Standard 124. Section S4.1 of Standard 124 defines a 'driver-operated accelerator control system' as 'all vehicle components, except the fuel metering device, that regulate engine speed in direct response to movement of the driver-operated control and that return the throttle to the idle position upon release of the actuating force.' You stated in your letter that, in this new system, when the driver depresses the accelerator pedal, the mechanical displacement is converted into electrical signals. These electrical signals are transmitted by wires to a control unit that regulates engine speed in direct response to pressure on the accelerator pedal, again by means of wires that connect the control unit's electrical signal to the appropriate components. Thus, the control unit, all of the components to which it is connected, and the wires that make those connections are 'vehicle components ... that regulate engine speed in direct response to movement of the driver-operated control and that return the throttle to the idle position upon release of the actuating force.' Under S4.1, then, the control unit, the components to which it is connected, and the wires that make the connection are components of the driver-operated accelerator control system. Section S5.2 of Standard 124 requires that the throttle return to idle 'from any accelerator position or any speed...whenever any one component of the accelerator control system is disconnected or severed at a single point.' Please note that this language does not limit the requirement to disconnections or severances of components that are moving parts. Thus, all severances or disconnections of any component of the accelerator control system are within the ambit of the standard. In this case, since the wires are a component of the accelerator control system, the throttle must return to idle whenever a wire is disconnected or severed. Question 2b: If a severance in electric wires were a severance or disconnection under S5.2, what about a short-circuiting that may result from such a severance? Does the Standard require that the throttle returns to the idle position even in such a condition? Yes. Section S5.2 of Standard 124 requires the throttle to return to the idle position whenever any component of the accelerator control system is disconnected or severed at a single point, regardless of the other consequences of the disconnection or severance. In the case of this system, this language requires the throttle to return to idle when any wire is severed, even if the severance results in a short circuit. Question 2c: Our understanding is that a failure (other than severance or disconnection) of a system component itself (i.e. a failure in the accelerator pedal sensor with pedal position switches, control unit, throttle valve position switch, or stepping motor) is not subject to the throttle return requirement under the Standard. Is this correct? Your understanding is partially correct. Standard 124 addresses those circumstances where (1) the driver removes the opposing actuating force, and (2) a severance or disconnection in the ACS causes a failure. Therefore, you are correct that Standard 124 addresses only those failures resulting from a severance or disconnection within the system. However, for electrical systems, shorted or open circuits are the consequence of a change in one or more of the electrical components in the system. The agency would consider such a change a disconnection or severance in the context of this Standard. Question 3: It is our interpretation that the battery and the electric wires from the battery to the control unit are not a part of the accelerator control system under this definition. (That is, the definition of 'driver-operated accelerator control system.') Is this interpretation correct? No, your interpretation is incorrect. We have set out the definition of 'driver-operated accelerator control system' in section S4.1 above, in response to your Question 2a. With respect to your electrical accelerator control system, the electrical impulse that travels between the vehicle battery and the control unit is a direct consequence of the driver's applying an actuating force to the accelerator pedal. Given this aspect of your system's design, both the vehicle battery and the electric wires from the battery to the control unit fall within the definition of 'driver-operated accelerator control system.' I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam1009OpenTom Caine, Esq., Legal Counsel, Goodyear Tire & Rubber Company, Akron, OH, 44316; Tom Caine Esq. Legal Counsel Goodyear Tire & Rubber Company Akron OH 44316; Dear Mr. Caine: This is to confirm your conversation with Dave Schmeltzer of thi office in which he informed you that a spare tire that is installed in a new vehicle within the occupant compartment would not have to meet the requirements of Standard No. 302 if it is not designed to absorb energy on contact by occupants in the event of a crash. However, this ruling is limited to the actual tire and would not apply to the wheel housing cover of a spare tire since that would be a component specified in S4.1 of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3034OpenMr. Howard J. Bogner, Federal Government Relations Manager, Minnesota Mining & Manufacturing Company, 1101 Fifteenth Street, S.W., Washington, D.C. 20005; Mr. Howard J. Bogner Federal Government Relations Manager Minnesota Mining & Manufacturing Company 1101 Fifteenth Street S.W. Washington D.C. 20005; Dear Mr. Bogner: This is in reply to your letter of June 18, 1979, asking about 'th history of the implementation of FMVSS 108 and the dates as to these proceedings.'; I assume that you are interested in the initial standards and not th many amendments that have occurred at frequent intervals since the first effective dates. An advance notice of proposed rulemaking was published in the *Federal Register* on October 8, 1966, inviting suggestions for all the initial Federal motor vehicle safety standards. The initial motor vehicle lighting requirement were proposed on November 30, 1966 (31 FR 15212, corrected at 31 FR 15600). Standard No. 108 published on February 3, 1967, however, (32 FR 2408, establishing 23 CFR 255.21, effective January 1, 1968) applied only to vehicles whose overall width was 80 inches or more. On the same day the agency (then known as the National Traffic Safety Agency, Department of Commerce) proposed 'MVSS No. 112' to become effective January 1, 1968, to cover all vehicles whose width was less than 80 inches (32 FR 2418). The same notice also proposed amendments to the just-issued Standard No. 108 which were adopted on December 16, 1967 (32 FR 18032) with varying effective dates. Instead of adopting 'Standard No. 112', the agency also amended Standard No. 108 on December 16, 1967 (32 FR 18033) to incorporate the proposed '112' requirements, for vehicles under 80 inches in overall width, but with an effective date of January 1, 1969. At least one amendment occurred before January 1, 1969 (See 33 FR 2994, February 15, 1968), and one interpretation (See 32 FR 8808, June 21, 1967), defining 'overall width'. A petition for review of boat trailer lighting requirements was filed in 1968, and the requirements upheld (See *Boating Industry Association* v. *Boyd*, 409 F.2d 408 (7th Cir., 1969, rehearing denied).; This is the history of the early days of Standard No. 108. The onl 'documentation' that might still exist would be microfiche copies of docket comments (Docket No. 9) which are warehoused in Virginia. The head of our technical reference service, Ms. Winifred Desmond (426-2728) may be able to assist you with these.; If you have any further questions you may call me at 426-9511. Sincerely, Z. Taylor Vinson, Senior Staff Attorney |
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ID: aiam1459OpenMr. Robert L. Carleton, President, Timpte, Inc., 5990 Washington Street, Denver, CO 80216; Mr. Robert L. Carleton President Timpte Inc. 5990 Washington Street Denver CO 80216; Dear Mr. Carleton: This responds to your April 2, 1974, request for a procedure to permi the manufacture of semi- trailers which do not comply with Standard No. 121, *Air brake systems*, after the standard's effective date.; Our authority to enforce standards under S108(a)(1) of the Nationa Traffic and Motor Vehicle Safety Act of 1966 prohibits the sale of a vehicle which does not comply with applicable standards. We are unable to permit by regulation what is prohibited by this section of the law.; We do have under consideration petitions to delay the effective date o Standard 121 as it applies to trailers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3464OpenMs. Fran Anderson, Jellybean Express, 5131 Franklin Blvd., Sacramento, CA 95820; Ms. Fran Anderson Jellybean Express 5131 Franklin Blvd. Sacramento CA 95820; Dear Ms. Anderson: This responds to your letter of September 9, 1981, concerning th Federal flammability requirements applicable to seat covers for child restraints. As explained below, if the seat cover is sold as an item of original equipment on a child restraint system, it must meet the flammability requirements of Safety Standard No. 213, *Child Restraint Systems*. If the seat cover is sold as an item of aftermarket equipment, it is not covered by the standard. However, we would urge you to consider voluntarily complying with the standard.; Standard No. 213, *Child Restraint Systems* (49 CFR 571.213), set performance requirements for child restraints as pieces of motor vehicle equipment. Section 5.7 of the standard provides that, 'Each material used in a child restraint system shall conform to the requirements of S4 of Safety Standard No. 302 (S571.302.)' Standard No. 302, *Flammability of Interior Materials*, provides that when tested under specified conditions, material may not have a burn rate of more than 4 inches per minute (copy enclosed). Thus, if your seat cover is sold as a component on a new child restraint, that child restraint must comply with the requirements of S5.7 of Standard No. 213. Under the National Traffic and Motor Vehicle Safety Act (the Act, 15 U.S.C. 1392 *et seq*., copy enclosed), manufacturers have the responsibility of certifying that they comply with all applicable standards. The agency does not grant prior approval or conduct tests to support a manufacturer's certification. Therefore, I am returning the sample of your seat cover.; Although Standard No. 213 only covers the manufacture of items o original equipment in child restraints, sale of your seat cover as an item of aftermarket equipment is indirectly affected by Section 108(a)(2)(A) of the Act. That section provides:; >>>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....<<<; Thus, none of the persons mentioned could not (sic) knowingly instal your seat cover on a used child restraint if it renders inoperative the restraint system's compliance with Standard No. 213. However, the prohibitions of the Act and the standard do not cover sale of your cover as an aftermarket device nor its installation solely by the vehicle or equipment owner.; Regardless of whether your seat cover must comply with Standard No 213, as a manufacturer of motor vehicle equipment you have defect responsibilities under sections 151 *et seq*. of the Act. Those sections provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of safety-related defects in their products and remedy those defects free of charge. If your covers are highly flammable, this could be regarded as a safety- related defect.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3937OpenMr. Robert L. Hart, 19459 Manor, Detroit, MI 48221; Mr. Robert L. Hart 19459 Manor Detroit MI 48221; Dear Mr. Hart: This is in reply to your letter of February 11, 1985, to former Chie Counsel Frank Berndt asking for an interpretation that a combination stop lamp-rear view mirror you have invented would be permissible under paragraph S4.4.1 of Standard No. 108.; That paragraphs precludes combining a center high-mounted stop lam with any other lamp or reflective device. You have concluded that the prohibition applies only to passenger cars manufactured after September 1, 1985, 'and does not prohibit application of my device to vehicles manufactured prior to the effective date of the mandate.'; Actually, S4.4.1 does not apply to your device at all. The lam established by the standard is one that is mounted on the vertical centerline of the vehicle, at or near the rear window with no relationship to the forward left side of the vehicle where your combination lamp-mirror would be located. Standard No. 108 does contain in paragraph S4.1.3 a prohibition against additional lighting devices that impair the effectiveness of the lighting equipment required by the standard. But on the basis of the facts as you have presented them to us, we cannot say that impairment would exist. We therefore conclude that your device is not prohibited by Standard No. 108 as either original or replacement equipment on any motor vehicle.; However, Motor Vehicle Safety Standard No. 111, *Rearview Mirrors* does relate to your device. Passenger cars are required to be equipped with an outside rear view mirror on the driver's side, under paragraph S5.2.2 '...neither the mirror nor the mounting shall protrude farther than the widest part of the vehicle body except to the extent necessary to produce a field of view meeting or exceeding the requirements of S5.2.1.' Some of your designs show the lamp portion at the left end of the device's housing resulting in a wider unit than one incorporating a mirror alone. We recommend that you re-examine these designs with paragraph S5.2.2 in mind, relocating the lamp to the area either above or below that of the mirror surface if you conclude that the combination mounting would not comply with Standard No. 111.; There is no similar mounting requirement for driver's side mirrors o vehicles other than passenger cars, and your designs for mirrors on these vehicles would appear permissible under Standard No. 111.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2625OpenMr. Charles Owen Verrill, Jr., Patton, Boggs & Blow, 1200 Seventeenth Street, N.W., Washington, D.C. 20036; Mr. Charles Owen Verrill Jr. Patton Boggs & Blow 1200 Seventeenth Street N.W. Washington D.C. 20036; Dear Mr. Verrill: This responds to your April 20, 1977, petition to amend Standard No 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. In your petition, you request that the National Highway traffic Safety Administration (NHTSA) permit the use of tires that have a maximum load rating of not less than 95% of the gross axle weight rating (GAWR) and not less than 95% of the gross vehicle weight rating (GVWR). Your petition is denied.; The problem addressed by your petition concerns a revision in the 197 Tire and Rim Manual that alters the load rating of tires. In effect, this revision will result in lower load ratings for certain tires. According to the facts you submit, the change in tire load rating will be implemented by tire manufacturers throughout the next few months which may not provide vehicle manufacturers sufficient time to correspondingly alter the GAWRs of their vehicles in accordance with the new tire load ratings. Therefore, for a short period of time, you allege that it will be impossible to obtain tires that correspond to the GAWR indicated on the vehicle.; To alleviate the above problem, you recommend rulemaking that woul permit vehicle manufacturers to install on their vehicles tires with load ratings slightly less than the GAWR of each axle. The NHTSA cannot permit the relief you request even for the limited time you propose. The intent of our tire standards is to provide minimum requirements for tires to ensure adequate safety. One of these minimum requirements mandates that the tire load rating be at least equal to the GAWR. Your request would have us reduce this minimum requirement. Since the matching of tires on a vehicle with the GAWR of each axle is such a basic principle of safety, the agency concludes that it would not be in the interest of safety to grant your request. Further, such an amendment might violate Section 202 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 *et seq*.), which requires that motor vehicles be equipped 'with tires which meet the maximum permissible load standards when such vehicle is fully loaded...'; As you may know, the label requirements of Standard No. 120 whic become effective in September permit you to list suitable tire and rim combinations on the vehicle. You need not equip a vehicle, however, with the tires indicated on the label. In this case, you may equip a trailer with any trailer tire that has a load rating equal to or greater than the GAWR of its associated axle. This may help resolve part of your problem with respect to a short term problem with matching tires on the vehicle with those indicated on the vehicle label.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0618OpenMr. Kent Chen, Import Manager, Mid-North American Import Export Company, Division of Charles, Incorporated, P. O. Box 529, Council Bluffs, IA 51501; Mr. Kent Chen Import Manager Mid-North American Import Export Company Division of Charles Incorporated P. O. Box 529 Council Bluffs IA 51501; Dear Mr. Chen: This is in reply to your letter of February 26, 1972, regardin importation of truck tires that were manufactured in Spain.; At the present time, the *proposed* Federal Motor Vehicle Safet Standard No. 119 that will apply to truck tires is in preparation. We expect that it will be issued in the very near future and that it will become effective on or about September 1, 1972.; Until then, truck tires are subject only to Regulation Part 574 - Tir Identification and Recordkeeping, which became effective May 22, 1971. Importation of truck tires for use on the public roads and highways requires compliance with Regulation Part 574. We are enclosing a copy of the regulation so that you may be informed of your obligations as an importer. You may use the listed tires or sell them to distributors and dealers if regulation requirements are satisfied.; We are also enclosing a pamphlet that contains additional guideline concerning importation of motor vehicles and equipment.; Apparently the tires described in your letter are manufactured in th Torrclavego, Santander, Spain plant of General Fabrica Espanola del Caucho, S.A. (General Tire International) and if manufactured since May 22, 1971, would be identified by the code marking *AB*.; Please let us know if we can be of further assistance in this matter. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam2275OpenHonorable Delbert L. Latta, House of Representatives, Washington, DC 20515; Honorable Delbert L. Latta House of Representatives Washington DC 20515; Dear Mr. Latta: Thank you for your March 23, 1976, request for consideration of th views of a constituent that provision of air cushion restraint systems in passenger cars would be too costly, and that motor vehicle regulation should concentrate on used vehicles because they are equipped with fewer safety and emission features.; As you are aware, the National Traffic and Motor Vehicle Safety Ac (the Act) (15 U.S.C. S 1391 *et seq*.) directs the Secretary of Transportation to issue motor vehicle standards that will reduce the number of accidents and deaths, and the severity of injuries, that occur on our nation's highways. The National Highway Traffic Safety Administration (NHTSA) of the Department of Transportation evaluates the available means to meet this goal. Restraining vehicle occupants to protect them against impact with the vehicle interior in a crash offers one of the greatest opportunities for improving motor vehicle safety. Reliance on existing seatbelt systems has prevented only a small portion of the death and injuries that occur from impact with the vehicle interior. For this reason, other means of providing restraint are under consideration. I can assure you that the issues of purchase cost, replacement cost, and the alternatives to air cushions are being included in this consideration.; The safe operation of motor vehicles has traditionally been regulate by the individual States and not the Federal Government. While the Act does not authorize the retrofit of safety devices to vehicles in use, the NHTSA has issued a highway safety program standard for State periodic motor vehicle inspection programs (23 CFR S 1204.4). Part 570, *Vehicle in Use Standards* (49 CFR Part 570), sets forth a procedure for inspection of older vehicles for use by the States in implementing the program standard. Also, the NHTSA has established demonstration diagnostic inspection projects that include emission as well as safety inspection of vehicles in use.; I have no basis for comment on the reported decision by Allstat Insurance Company not to consider the effects of bumper modification in establishing its premium structure.; I trust that this response will answer your constituent's questions. Sincerely, William T. Coleman, Jr. |
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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.