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: aiam5075OpenUnder Secretary Ministry of Commerce and Industry P. O. Box No. 2944 KUWAIT; Under Secretary Ministry of Commerce and Industry P. O. Box No. 2944 KUWAIT; "Dear Mr. Under Secretary: This responds to your letter concernin United States tire regulations. You stated that some companies have been reported to be dumping defective and rejected tires in your country. In response to that situation, the Ministry of Commerce and Industry issued a decree requiring that all imported tires must be new, must comply with international standards, and must be accompanied by a quality certificate issued by an independent, officially recognized authority which has the capability of testing and proving the quality of the tires in accordance with the standards. You stated that you have been unable to obtain such a certificate from the United States, but have received one from a company called Societe Generale de Surveillance, which issues a certificate for each shipment separately and does only visual tests and not laboratory testing. You stated that you have studied this agency's tire standards and posed a series of questions to us which I will endeavor to answer below. By way of background information, under the National Traffic and Motor Vehicle Safety Act of 1966, ('Safety Act,' 15 U.S.C. 1381 et seq.), the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards for new motor vehicles and new motor vehicle equipment. Tires are considered motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards. Manufacturers of motor vehicles and motor vehicle equipment must certify that their products meet all applicable safety standards. All new tires sold in the United States for use on passenger cars must be certified as complying with Standard No. 109 (49 CFR Part 571.109), and all new tires sold for use on other motor vehicles must be certified as complying with Standard No. 119 (49 CFR Part 571.119). These standards specify performance requirements (strength, endurance, high speed performance, and for passenger car tires only, resistance to bead unseating), marking requirements (treadwear indicators and labeling information), and tire and rim matching information requirements. The process of certifying compliance with the applicable safety standards under the Safety Act is considerably different in the United States than in other countries. For example, the European nations require manufacturers to deliver tires to a governmental entity for testing. After the governmental entity tests the tires, the government approves those tires for use and assigns an approval code to the tires. The Safety Act, on the other hand, establishes a 'self-certification' process for tires sold in the United States. Under this process, the tire manufacturer, not a governmental entity, certifies that its tires comply with applicable safety standards. The Safety Act does not require that a manufacturer base its certification on a specified number of tests. A manufacturer is only required to exercise due care in certifying its tires. It is the responsibility of the individual tire manufacturer to determine initially what test results, computer simulations, engineering analyses, or other information it needs to enable it to certify that its tires comply with Federal tire safety standards. Once a manufacturer has determined that its tires meet all requirements of the safety standards, it certifies such compliance by molding the letters 'DOT' onto at least one sidewall of each certified tire. This agency does not perform any pre-sale testing or approval of tires. Rather, NHTSA randomly tests certified tires to determine whether the tires do, in fact, comply with applicable standards. For these enforcement checks, NHTSA purchases tires 'off the shelf' from retail tire dealers and tests those tires according to the procedures specified in the standards. If the tires pass the tests, no further action is taken. If the tires fail the tests and are determined not to comply with the standards, the tire manufacturer is required to remedy the noncompliance without charge. With the above background in mind, I now turn to your specific questions: 1. Must all tires manufactured and sold in the United States bear the 'DOT' mark? Answer: Yes, assuming that the tires are intended for use on motor vehicles. The 'DOT' symbol molded onto at least one side of the tire is the manufacturer's certification that that tire complies with all applicable safety standards. 2. What are the bases for granting the right to use the 'DOT' mark by tire manufacturers? Answer: The use of the 'DOT' symbol on tires is a requirement imposed on tire manufacturers and not a right which is granted. 3. Is the 'DOT' symbol required for tires intended both for domestic consumption and for export? Answer: NHTSA's safety standards do not apply to motor vehicles or motor vehicle equipment which are intended solely for export. Therefore, the 'DOT' symbol is required only for tires intended for use in the United States. 4. Is there a validity time for the use of the 'DOT' symbol? Answer: No. The symbol constitutes the manufacturer's certification that, at the time a new tire is manufactured, that tire complies with all applicable Federal safety standards. 5. What is the relationship between your administration and the Department of Transportation concerning the implementation of the 'DOT' symbol? Answer: NHTSA is a subordinate agency of the United States Department of Transportation. 6. What are the legal responsibilities of manufacturers by using the 'DOT' symbol? Answer: As indicated above, by placing the 'DOT' symbol on a tire the manufacturer certifies that, under the provisions of the Safety Act, the tire complies with all applicable Federal safety standards. 7. What are the responsibilities of manufacturers in case of violations of the 'DOT' symbol's role? Answer: If a tire is determined not to comply with a safety standard, the manufacturer is required to remedy the noncompliance without charge. In addition, violations of Safety Act provisions may result in civil fines. I hope that the information in this letter is helpful to you. Should you have any further questions, however, please feel free to contact Mr. Walter Myers of my staff at this address or by telephone at (202) 366-2992, FAX (202) 366-3820. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0298OpenMr. J.T. Hite, III, President, Yarbrough Manufacturing Company, Inc., P.O. Box 848, 921 Mayfield Road, Arlington, TX 76010; Mr. J.T. Hite III President Yarbrough Manufacturing Company Inc. P.O. Box 848 921 Mayfield Road Arlington TX 76010; Dear Mr. Hite: This is in reply to your letter of January 21, 1971 concerning Tir Identification and Record Keeping regulations. Enclosed for your information is a copy of the Tire Identification and Record Keeping Regulation (49 CFR 574).; The regulation does not provide for exemptions or waivers, however, yo will note that under S 574.10 of the regulation vehicle manufacturers are required to keep records of tires on or in the vehicle when shipped to the dealer. Under the conditions you describe in your letter S 574.9(b) appears to be the relevant section and requires that the vehicle dealer record the name, address, etc. of the purchaser and forward this information to the tire manufacturer.; I hope this letter is responsive to the question you raise. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5560OpenMr. Mayo D. Tubbs Visionary Lighting Systems 1409 Sweetgum Circle Keller, TX 76248; Mr. Mayo D. Tubbs Visionary Lighting Systems 1409 Sweetgum Circle Keller TX 76248; Dear Mr. Tubbs: Thank you for providing a FAX copy of your letter o April 27, 1995, to Philip Recht. As Taylor Vinson explained to you when you phoned, the agency had no record of receiving your original letter. Our letter of April 13, 1995, to you was based upon your representation that the strip lights in your system would be 'Aviation Green'. We advised you that use of this color has the potential to create a measure of confusion rather than caution, thereby affecting the effectiveness of the mandatory side lighting equipment, i.e., amber front side markers, red rear side markers, and red and white conspicuity striping or red reflectors. You have asked whether our response would be different if the strip lamps were red or amber in color, as shown in the drawings of a van trailer in your Attachment A. In this scheme, amber lamps would be located on the side of the trailer, and red lamps on the rear. Because these colors are associated with caution, we do not believe that they would impair the effectiveness of any of a trailer's required lighting equipment. You expressed your understanding that, if the three rear identification lamps are installed at the top of a trailer, the clearance lamps can be mounted at the bottom and vice versa, as reflected in the drawings shown in your Attachment C. This is not exactly correct. Table II of Standard No. 108 requires identification lamps, without exception, to be mounted 'as close as practicable to the top of the vehicle.' While clearance lamps also are required to be 'as near the top as practicable' (Table II), when the rear identification lamps are mounted at the extreme height of the vehicle the rear clearance lamps need not be located as close as practicable to the top of the vehicle (paragraph S5.3.1.4). This configuration is reflected in the drawing on Attachment C titled 'Identification Lights on Top'. The drawing 'Identification Lights on Bottom' does not depict a location for identification lamps that conforms to Table II. Because clearance lamps are intended to indicate the overall width of the vehicle, the exception originated to accommodate trailer designs in which the widest part of the trailer was the fenders. In the van configuration shown on Attachment C, it would be practicable for both identification and clearance lamps to be mounted at the top of the trailer, and that is the location preferred by this agency for clearance lamps, notwithstanding S5.3.1.4. If there are other questions you have, Taylor Vinson will be happy to answer them for you. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1870OpenMr. David A. Tenquist, Marketing Department, Novus, Inc., 5301 B Edina Industrial Blvd., Minneapolis, MN 55435; Mr. David A. Tenquist Marketing Department Novus Inc. 5301 B Edina Industrial Blvd. Minneapolis MN 55435; Dear Mr. Tenquist: This is in reply to your letter of March 12, 1975, inquiring as t whether any safety regulation of the National Highway Traffic Safety Administration applies to the 'Novus Windshield Repair Kit,' manufactured by your firm.; An advertising brochure for the product states that the material use in the process 'is a special waterproof epoxy that not only fills the fissure in the glass but also bonds the crack surfaces to prevent formation or extension of radial cracks.'; There is no safety regulation of the National Highway Traffic Safet Administration, nor any other Federal law or regulation, which prohibits the use of such a material 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 the result of damage sustained in shipment could cause the windshield to fail to meet the performance requirement of Motor Vehicle Safety Standard No. 205 (49 CFR S 571.205) and we would therefore discourage use of the Novus kit on new windshields.; Please do not hesitate to contact us if we may be of furthe assistance.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0762OpenMr. Walker Sandbach, Executive Director, Consumers Union, 256 Washington Street, Mount Vernon, NY 10550; Mr. Walker Sandbach Executive Director Consumers Union 256 Washington Street Mount Vernon NY 10550; Dear Mr. Sandbach: This is in response to your letter of June 28, 1972, forwarding to us report to be published in the August issue of *Consumer Reports*, which raises numerous issues concerning child restraints and the efficacy of Motor Vehicle Safety Standard No. 213, 'Child Seating Systems.' You contend, based on testing you performed, that the static performance tests of the standard are meaningless, and that dynamic tests should be adopted.; We agree that a dynamic test should be included in the standard, and w discuss below our efforts and intentions in this regard. We also believe, however, that devices which conform to Standard No. 213 provide significant impact protection for children which is not available otherwise, and that the present standard has served a useful purpose in the development of effective child restraints and the removal from the marketplace of marginal products. We have pursued a vigorous enforcement policy with respect to the standard which has discovered and corrected numerous cases of noncompliance.; The 1,000-pound static test imposed by Standard No.213 was determine by the NHTSA to be an adequate first step in the development of standards for child seating systems. This determination was based, in part, on the state of the art of the development of these devices, and the financial resources of the affected industry. The limitations of the static test have been known for some time, and in the NHTSA *Program Plan for Motor Vehicle Safety Standards*, published in October 1971, the NHTSA made clear its intention to develop a dynamic test to measure the performance of all child restraint devices.; We believe the most effective way to utilize a dynamic test is t couple it with realistic injury criteria that reflect the ability of children to withstand crash impacts. This is the approach taken for adults by Standard No. 208, Occupant Crash Protection. Although we have developed adult injury criteria as part of our work on that standard, further work must be done to correlate these criteria with the protection needed for children.; Rather than delay dynamic testing until this work is completed however, the NHTSA plans to propose interim dynamic tests using other performance criteria which are presently being developed through research at the University of Michigan. We are also sponsoring other research on the problem of the development of realistic child dummies. Another problem in the development of a dynamic test for child seating systems, or any other performance requirements for them, is that the performance of the child seat is in large measure dependent upon the design and construction of the vehicle in which it is placed. Because manufacturers can market these devices economically only if they are suitable for large numbers of vehicles, an endless number of variables occur, with a resultant difficulty in prescribing reasonable 'worst case' test conditions.; We are presently working to provide answers to these questions, and ar hopeful that the research projects presently under way will provide data in the near future on which we can proceed. You mention that you will be submitting to us a petition for rulemaking regarding the standard. We request that you also submit to us any data which might assist us in solving these problems.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam5130OpenMr. Dale E. Dawkins Director Vehicle Compliance and Safety Affairs Chrysler Corporation CIMS 415-03-17 1200 Chrysler Drive Highland Park MI 48288-0857; Mr. Dale E. Dawkins Director Vehicle Compliance and Safety Affairs Chrysler Corporation CIMS 415-03-17 1200 Chrysler Drive Highland Park MI 48288-0857; "Dear Mr. Dawkins: This responds to your letter of December 16, 1992 to the Administrator informing the agency about the intent of Chrysler Corporation to manufacture 10 Chesapeake Consortium Electric Vehicles (CCEV) under NHTSA Temporary Exemption 92-1. According to your letter, these vehicles are 'almost identical' to the TEVans for which the agency granted the temporary exemption, except that they will utilize an AC electrical motor, while the ones which were the subject of the exemption petition will be powered by a DC electrical motor. You seek no broader exemption as the combined volumes of CCEVs and TEVans 'will not exceed the maximum units of the petition that was granted.' You have submitted this information to us so that NHTSA will have a clear understanding of the content of your electric vehicle development program and the extent of the exemptions under which these vehicles will be manufactured. It appears that you would like confirmation from NHTSA that the CCEV vehicles are covered by Temporary Exemption 92-1. In order for the agency to provide this confirmation, it must determine that CCEV and TEVans are essentially the same vehicle and that none of the minor differences between the vehicles affects the findings made by the agency in issuing the TEVan exemption. In granting Chrysler's exemption petition covering three standards, the Administrator first found that the exemption would facilitate the development and field evaluation of a low emission motor vehicle. We do not believe that the change in electrical propulsion from DC to AC affects this finding. The Administrator next found that an exemption from the three standards would not unduly degrade the safety of the vehicle. You state that ' b ased on our engineering judgement, there is no significant difference between the CCEV or TEVan in terms of overall vehicle safety.' While you may have used the word 'significant' in an excess of caution, it implies that there are differences between CCEV and TEVan and that there is a difference in overall vehicle safety between the CCEV and TEVan, although not an important one from Chrysler's viewpoint. We would appreciate your identification of the differences between the vehicles, and of the differences, if any, in the safety between the CCEVs and TEVans that may have led to Chrysler's engineering conclusion. With this information, we shall be better able to evaluate whether the two vehicles are essentially the same and whether there is any undue degradation in safety that might render it inappropriate to consider the CCEVs covered by the TEVan exemption. We appreciate your calling our attention to this matter. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0332OpenHugh A. Blackwell, Fleming, Robinson & Bradshaw, Attorneys at Law, 1212 American Building, Charlotte, NC 28202; Hugh A. Blackwell Fleming Robinson & Bradshaw Attorneys at Law 1212 American Building Charlotte NC 28202; Dear Mr. Blackwell: This is in response to your letter of April 14, 1971, concerning th Tire Identification and Record Keeping Regulation. The answers given you by Mr. David Schmeltzer in your telephone conversation are, for the most part, correct. This letter is to confirm those answers where appropriate and reply to the unanswered questions you raised.; The numbered paragraphs correspond to the numbered questions in you letter.; 1. The regulation speaks of a three year retention period for th information required by section 574.7(a) and the same three year period would be considered an appropriate length of time to retain the records required by section 574.7(c).; 2. The regulation specifies that each manufacturer or brand name owne shall record and maintain the records required by the regulation. Therefore, the regulation allows anyone to maintain those records but the legal responsibility may not be shifted. Thus, a brand name owner may have the manufacturer maintain the required records, but he remains legally responsible for their maintenance.; 3. Under the regulation, the distributors and dealers are required t submit the required information to the brand name owner, or the tire manufacturer, whoever has the legal responsibility of maintaining the records or to the manufacturer's designee. In other words, the person responsible for maintaining the records is the person who should receive the records unless he designates someone else to receive them.; 4. The tire manufacturer is required to furnish a means of recordin the required information to distributors and dealers, but not to brand name owners. However, this does not preclude the possibility of an arrangement whereby the tire manufacturer supplies the brand name owner the means for recording the required information.; 5. The records required by Part 574 need not be kept for reclassifie tires. However, Standard No. 109, the passenger car tire standard, sets forth requirements for maintaining records for reclassified tires.; 6. Under the regulation, the brand name owner has no obligation t supply information to the tire manufacturer.; 7. Your understanding that brand name owners are not responsible fo keeping records of reclassified tires under Standard No. 109 is correct.; 8. Tires which are manufactured for off public road use are no considered to be items of motor vehicle equipment under either the Act or the regulation.; 9. The repurchasing obligations for the manufacturer or brand nam owner for tires in the hands of dealers and distributors in the event of a defect notification, are contained in Section 111 of the Act. There are no repurchasing obligations under the Act which relate to the first purchaser for purposes other than resale of the tire involved in the defect notification.; 10. Because the legal responsibility for defect notifications rest with the brand name owner, as well as the tire manufacturer (Section 113(f) of the Act) the requirements of Section 113(d) also apply to the brand name owner. We consider copies of notices received from either the manufacturer or the brand name owner as fulfilling the requirements of Section 113(d). It has been our practice to notify both the manufacturer and brand name owner in the event of a defect described as a result of our investigation.; 11. The brand name owner will be required to give a defect notificatio when he receives information that a defect has been determined whether that information comes from the manufacturer or from the Administrator or from his own knowledge.; 12. The certification regulations are satisfied, in the case of tires by the symbol 'DOT' embossed on the sidewall of the tire. This is the manufacturer's certification that the tire complies with the tire standard.; 13. At this point in time, there are no regulations requirin performance of technical data to be furnished with new or retreaded tires. However, at any time, the National Highway Traffic Safety Administration has the authority to require such information pursuant to Section 112(d) of the Act.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam1489OpenMr. Andy K. Holen, Purchasing Manager, Weyerhaeuser Company, Tacoma, WA 98401; Mr. Andy K. Holen Purchasing Manager Weyerhaeuser Company Tacoma WA 98401; Dear Mr. Holen: This responds to your April 29, 1974, request to be apprised of th Standard No. 121 requirements concerning air brakes on trucks and trailers.; Standard No. 121, like all Federal motor vehicle safety standards, is manufacturer requirement, not a user requirement. While it places obligations on the vehicle manufacturers to construct their vehicles so that they conform to the standard, it does not place any responsibilities on you as a user of air brake-equipped vehicles.; If you would nevertheless like to examine the current requirements they may be obtained from the Government Printing Office as explained in the enclosed brochure, or from commercial or library sources as part of Chapter V of Title 49 of the Code of Federal Regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4371OpenMr. Hisashi Tsujishita, Chief Co-ordinator, Technical Administration Department, Daihatsu Motor Co., Ltd., 1.Daihatsu- cho, Ikeda City, Osaka Prefecture, JAPAN; Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Department Daihatsu Motor Co. Ltd. 1.Daihatsu- cho Ikeda City Osaka Prefecture JAPAN; Dear Ms. Tsujishita: Thank you for your letter requesting an interpretation of th requirements of three of our safety standards. This letter responds to your questions concerning Standard No. 201, *Occupant Protection in Interior Impact*. I have previously responded to your requests for interpretations of the other two standards. I regret the delay in this response.; Your questions concern the requirements of S3.5.1(b) of the standard which provides that 'Along not less than 2 continuous inches of its length, the armrest shall, when measured vertically in side elevation, provide at least 2 inches of coverage within the pelvic impact area.' You expressed concern about determining whether several different armrest designs comply with that requirement. Specifically, you provided three examples and asked how the requirement would apply to each example. Your example I11.1 is an armrest that, when viewed in side elevation (i.e., a view in which a person is looking from in front or behind an armrest to determine how the armrest projects from the door surface) has a flat surface. Example I11.2 is an armrest that has a slightly curved surface. Example I11.3 is an armrest with a surface that is steeply angled inward toward the door. Because of the angling of the armrest, it has a sharp projection at its top.; You believe that examples I11.1 and I11.2 comply with the requiremen of S3.5.1(c). You also believe that example I11.3 would not comply because of its sharp projection. However, you expressed concern about what criteria should be used to distinguish example I11.2 from example I11.3.; S3.5.1(c) of Standard No. 201 does not set any radius of curvatur requirements for armrest surfaces. Thus, a manufacturer is not required to provide an armrest with a flat surface. The only requirement is that the armrest provides at least two inches of coverage within the pelvic impact area. The purpose of the requirement is to reduce potential injuries to an occupant by ensuring that the armrest has a minimum surface area that will spread the force resulting from an occupant impacting the armrest in a crash. Thus, for this requirement to have a meaningful effect, an armrest should be designed to ensure that there is at least two inches of contact between the surface of the armrest and the pelvic impact area of an occupant. If your examples I11.1 and I11.2 provide two inches of coverage within the pelvic impact area, they would appear to comply, since they present an essentially flat surface. Based on your drawing, it appears that the steep inwardly sloping angle of the armrest shown in example I11.3 may not contact a minimum of two inches of the pelvic impact area. One method of determining the degree of occupant contact would be to measure the amount of contact between a test dummy and the armrest in a static push test or in a dynamic side impact test. We share your concern that an armrest not have sharp projections which could concentrate potentially harmful forces on an occupant striking the armrest.; Finally, you provide a drawing of an additional armrest. Briefl described, the armrest has a slightly curved surface with a decreasing radius within the pelvic impact area. At the top of the portion of the armrest within the pelvic impact area there is a small indentation. The agency has previously said, in an interpretation letter of July 1, 1893 to MMC Services, Inc., that bezels and other indentations are not precluded by the standard. However, the area of the indentation will not be measured in determining whether the armrest provides two inches of coverage if the indentation is so deep that it cannot be contacted. Based on your drawing, the indentations shown in your proposed armrest is shallow and would be contactable by an occupant. Thus, the surface area of the indentation would be counted in determining whether the vehicle complied.; Finally, I would point out that S3.5.1(c) is one of three optiona means of compliance that manufacturers may choose. A manufacturer may also meet the requirements of Standard No. 201 by complying with either S3.5.1(a) or S3.5.1(b), in which case it is not necessary to provide two inches of coverage with the pelvic impact area.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1173OpenMr. Dennis E. David, Legislative Coordinator, Kawasaki Motors Corporation, 1062 McGaw Avenue, Post Office Box 11447, Santa Ana, California 92711; Mr. Dennis E. David Legislative Coordinator Kawasaki Motors Corporation 1062 McGaw Avenue Post Office Box 11447 Santa Ana California 92711; Dear Mr. David: In your letter of June 21, 1973, to Mr. Schneider, you ask whethe Standard No. 123 precludes use of a device that, when activated, does not allow and automatic return of the throttle to idle.; "As you have observed, Standard No. 123 specifies that if a twist-gri throttle is provided, its manner j of operation shall be 'self-closing to idle ... after release of hand.' This requirements is without qualification and means that at any time the operator's hand is removed from the throttle, the throttle shall automatically return to idle. Therefore, a motorcycle equipped with the device you describe would not comply with Standard No. 123."; Yours truly, Assistant Chief Counsel |
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.