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: aiam2851OpenRolan B. Senior, Utah State Tax Commission, Motor Vehicle Division, 1095 Motor Avenue, Salt Lake City, UT 84116; Rolan B. Senior Utah State Tax Commission Motor Vehicle Division 1095 Motor Avenue Salt Lake City UT 84116; Dear Mr. Senior: Thank you for your letter of August 10, 1978, requesting approval t use Utah's proposed Certificate of Title as a substitute for the Federal odometer disclosure form required by 49 CFR Part 580.; The proposed Certificate of Title which you enclosed with your lette differs from the Federal odometer disclosure form in the following ways:; (1) The Utah Certificate of Title contains no reference to State o Federal law,; (2) the set of certifications relating to the distance the vehicle ha travelled are shortened by adopting the format recommended by the American Association of Motor Vehicle Administrators,; (3) the certifications relating to alteration of the odometer ar deleted, and; (4) the transferee is not required to sign the statement. The only suggestions that we have are that you include a reference t either State or Federal law and the signature of the transferee (buyer). The purpose of the reference to the law is to alert the purchaser to the fact that the odometer information is a legal requirement, the violation of which is punishable. The purpose of the transferee's signature is to ensure that he or she has seen the disclosure statement and to prevent him or her from later claiming that no statement was received. With these changes Utah's Certificate of Title will be in substantive conformity with the Federal odometer law, despite its differences from the Federal form. Therefore, pursuant to 49 CFR 580.4(f)(2), I hereby grant your request to use Utah's Certificate of Title, with the changes noted above, as a substitute for the Federal form.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam4086OpenThe Honorable Bobbi Fiedler, House of Representatives, 1607 Longworth House Office Building, Washington, D.C. 20515; The Honorable Bobbi Fiedler House of Representatives 1607 Longworth House Office Building Washington D.C. 20515; Dear Ms. Fiedler: Thank you for your letter enclosing corresponence (sic) from you constituent, Mr. William Griffiths of Newbury Park, who asked several questions about our regulations for safety belts on passenger motor vehicles, buses and school buses. Your letter has been referred to my office for reply.; Your constituent asked why safety belt designs vary between differen seating positions and among different types of motor vehicles. He observes that some vehicles have a combination of pelvic and upper torso restraints ('lap and shoulder belts') in the front seats, while providing only lap belts for the rear seats. He further notes that safety belts are not required for passengers in buses and school buses. Apparently Mr. Griffiths believes that shoulder belts are uncomfortable and feels that they should not be installed in the front seats of passenger motor vehicles.; I am pleased to have this opportunity to clarify our requirements fo your constituent. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards for all new motor vehicles and items of motor vehicle equipment. Federal Motor Vehicle Safety Standard (FMVSS) No. 208, *Occupant Crash Protection*, establishes performance requirements for the protection of vehicle occupants in crashes. Under FMVSS No. 208, motor vehicle manufacturers must provide lap and shoulder belts for front outboard passenger positions in order to comply with the standard. Since persons in the front seating positions of an automobile should be protected from rigid structures forward of those positions, such as the windshield pillars, we believe that an upper torso restraint of some kind is necessary. Our requirements differ for the rear seating positions, where only a lap belt need be provided, because the area forward of those positions does not contain the relatively hard surfaces found in the areas surrounding the front seats.; As Mr. Griffiths has noted, our safety standards for buses and schoo buses do not require safety belts for passengers. NHTSA does not require safety belts for transit-type buses because the crash forces experienced by those vehicles are less severe than those of lighter vehicles in similar collisions. Also, the safety record for transit buses is good. Accordingly, we believe that revising our requirements for their seating systems would not reduce injuries substantially. Safety belts are not required for passengers in large school buses because those vehicles are required to provide high levels of occupant crash protection through a concept called 'compartmentalization.' Compartmentalization requires that the interior of large school buses be constructed so that children are protected without the need to use safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, and improved seat spacing and performance.; Your constituent might be interested to know that we have addressed hi concern regarding the discomfort some passengers experience with safety belts equipped with shoulder restraints. We have taken steps to improve the comfort and convenience of safety belt systems by a recent amendment to our safety standards. A copy of the amendment is enclosed.; I hope this information is helpful. Please do not hesitate to contac my office if you have further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3743OpenMs. Pamela Cox, NADA Management Education, National Automobile Dealers Association, 8400 Westpark Drive, McLean, VA 22102; Ms. Pamela Cox NADA Management Education National Automobile Dealers Association 8400 Westpark Drive McLean VA 22102; Dear Ms. Cox: This responds to your request to Mr. Stephen Kratzke of my staff t verify the record retention checklist your organization plans to distribute to its members. The checklist indicates that automobile dealers must maintain records of 'New and retread tires, name, address of purchaser, tire seller and identification number,' and 'Tires on each vehicle sold.' This is not an accurate description of the recordkeeping requirements imposed on automobile dealers with respect to tire sales.; For your information, I have enclosed a copy of 49 CFR Part 574, *Tir Identification and Recordkeeping*. The tire registration requirements applicable to motor vehicle dealers are set forth in section 574.9. Motor vehicle dealers are *not* required to register the tires on each vehicle sold, they are only required to register tires in two instances. First, if the dealer is selling a new vehicle, the tires must be registered by that dealer only if the vehicle is equipped with tires other than those installed on the vehicle or furnished with it by the vehicle manufacturer. In the far more common situation where the dealer delivers a new vehicle with the original equipment tires installed on or furnished by the vehicle manufacturer, the vehicle dealer has no registration responsibility for those tires.; Second, if the motor vehicle dealer is selling a used vehicle o leasing a vehicle for more than 60 days, the dealer must register the tires on that vehicle only if he has installed new tires on it. Again, it is more usual for a used vehicle to be equipped with the used tires already on it, and, in that case, the vehicle dealer is not required to register the tires. Moreover, tire registration is not required for any dealer when a vehicle is equipped with retreaded tires, even if the dealer installed the retreaded tires on the vehicle.; Even when motor vehicle dealers are required to register tires, the are only required to record the purchaser's name and address if the dealer's business is owned or controlled by a tire company. I presume this would be a very unusual situation. This agency published an interim final rule establishing voluntary tire registration requirements for 'independent' dealers in the Federal Register of May 19, 1983 (copy enclosed). 'Independent' dealers means those whose business is not owned or controlled by a tire manufacturer. When one of your members is required to register tires and qualifies as an independent dealer, he must simply record the tire identification number(s) of the tire(s) sold on a registration form provided by the tire manufacturer, together with the dealer's name and address, and give the form to the tire purchaser. It is up to the purchaser to fill in his or her name and address on the form and return it to the manufacturer. The dealer is not required to retain any record of this. Even if the motor vehicle dealer were owned or controlled by a tire manufacturer, that dealer would simply be required to complete the entire registration form and return it to the tire manufacturer, and the tire manufacturer would be required to retain a record of the registration form for three years.; I trust that this information will help you in your efforts to educat your members about their responsibilities under Federal laws. If you need any further assistance in those efforts, please contact Mr. Kratzke at this address or at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1284OpenMr. Robert G. Beaumont, President, Sebring Vanguard, Inc., P.O. Box 1479, Sebring Air Terminal, Sebring, FL 33870; Mr. Robert G. Beaumont President Sebring Vanguard Inc. P.O. Box 1479 Sebring Air Terminal Sebring FL 33870; Dear Mr. Beaumont: This is in response to your request for clarification of the meaning o 'truck chassis' as it appears in the definition of 'multipurpose passenger vehicle.'; The term 'truck chassis' has been used in the Motor Vehicle Safet Standards since their initial issuance in 1967. It was not explicitly defined at that time although it was and is in common use within the motor vehicle industry.; In light of the notice proposing redefinition of multipurpose passenge vehicle and the comments on that proposal, we are considering the desirability of further explanation of the term.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2502OpenMr. Carlyle Holtan, Director of Transportation, Administrative Offices, Oconomowoc Public Schools, 7077 Brown Street, Oconomowoc, WI 53066; Mr. Carlyle Holtan Director of Transportation Administrative Offices Oconomowoc Public Schools 7077 Brown Street Oconomowoc WI 53066; Dear Mr. Holtan: This responds to your February 3, 1977, letter asking whether the ne school bus definition (effective April 1, 1977) precludes the use of vans which seat less than 10 passengers from transporting children to and from school.; The Motor Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L 93-492) authorized the NHTSA to redefine the term 'school bus' to include all motor vehicles which seat 10 or more passengers and which transport children to and from school. The NHTSA redefined the term in accordance with the wishes of Congress for the purpose of prescribing safety requirements for buses that fall within the definition. The definition does not preclude the use of vans or any other type of motor vehicle which seat fewer than 10 passengers from transporting children to and from school. Such vehicles may transport children without complying with the school bus safety requirements.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4985OpenMr. William H. Spain Touch Wood 5417 Caldwell Mill Road Birmingham, AL 35242; Mr. William H. Spain Touch Wood 5417 Caldwell Mill Road Birmingham AL 35242; "Dear Mr. Spain: This responds to your letter of January 21, 1992, t Taylor Vinson of this office, with reference to your 'Auxiliary Lighting Device'. I understand that you have also discussed the Device on the phone with Mr. Vinson on March 3, and with Mr. Van Iderstine of the Office of Rulemaking on March 26. You have referenced sections S5.1.3, S5.1.1.11, S5.3.1.1, S5.5.3 and S5.5.10(a) of Motor Vehicle Safety Standard No. 108, and ask for an 'initial first impression as to whether or not we might have a problem.' In your experience, 'it is not an uncommon occurrence for a tractor/trailer to lose its taillamps due to a circuit or wiring malfunction.' When this occurs, you point out that the driver's only choice is to activate his hazard warning system, which is not its intended purpose, and which defeats the normal turn signal circuits. Your Device would permit the operator of the tractor to employ the rear turn signal lamps as surrogate taillamps if the vehicle's standard taillamps were inoperative. Specifically, 'a reduced voltage is fed through both right and left rear turn signal circuits to cause both turn signal lamps to illuminate at a reduced brilliance equal to that of a normal tail lamp.' The Device has an alternative function. It permits the turn signal lamps to be used at full intensity as fog lamps to increase rear visibility. The activation of the turn signal switch within 1/2 second overrides the Device and allows normal operation of the turn signal lamps. The Device is activated through a toggle switch on the dash, which glows to indicate to the driver that it is engaged. The applicability of the National Traffic and Motor Vehicle Safety Act of 1966 (the 'Act') and Motor Vehicle Safety Standard No. 108 to tractor-trailer combinations is not well defined. Standard No. 108 is, in essence, a manufacturing standard that applies to individual motor vehicles. It ceases to apply at the time of purchase by its first owner (other than the manufacturer or dealer). Once a vehicle is sold, questions of continued compliance with the standards, including Standard No. 108, must be answered with reference to the Act. The question presented by your letter concerns a device added to one vehicle before its first sale that is intended to affect the lighting performance on another vehicle after the sale of the second vehicle (i.e., when it has become a 'vehicle in use', to use the statutory term). We recently provided another interpretation of the applicability of Standard No. 108 and the Act to towing and towed vehicle combinations which I would like to discuss, as it provides a basis for our interpretation to you, but is nevertheless distinguishable from it by its facts (letter of April 3, 1992, to Echlin Corp.) The Echlin Corp. device (the 'Control') was intended to control trailer sway by allowing the towing vehicle's driver to apply the towed vehicle's brakes through modulated pressure by use of a hand control in the towing vehicle. The wiring of the Control was such that the trailer stop lamps were not activated when the Control was in use. Standard No. 108 and the laws of some States require that the stop lamps be activated when the service brakes are applied. We informed the manufacturer of the Control that, under the specific facts of the case, the question was not one to be answered under Standard No. 108 as applying to new vehicles, but to be answered under the Act as it affects vehicles in use. The Act contains a general prohibition (l5 U.S.C. 1397(a)(2)(A)) against knowingly rendering inoperative, in whole or in part, any device or element of design on a vehicle in use that has been installed in accordance with a Federal motor vehicle safety standard. The prohibition applies to any manufacturer, dealer, distributor, or motor vehicle repair business. With respect to the Control, the dealer of the towed vehicle adds the Control to the towing vehicle (a vehicle in use) at the time that the towed vehicle is purchased. In our opinion, the legal question was whether the dealer of the towed vehicle had rendered the stop lamps of the towed vehicle partially inoperative by its installation of the Control on the towed vehicle. In our opinion, it was not the installation of the Control but its use that was critical. The user of the Control, the vehicle operator, is not covered by the prohibition. Therefore, we informed Echlin that the sale and use of the Control does not violate the Act. This interpretation can also be viewed as stating that 'inoperability' as the word is used in the statute must result from a direct act, and not an indirect one. This, however, was not our intent. We do not believe that a person should be excused from responsibility simply because an intervening agency is required to operate a device that that person has manufactured or sold. Although many of the facts concerning the use of the Control and your Device are similar, the fact of importance in this instance is the primary purpose of the equipment in question. The primary purpose of the Control was to control trailer sway, not to affect the operation of the stop lamps. The primary purpose of your Device is to affect vehicle lighting, by serving as surrogate and supplementary lighting equipment. A further fact in difference is that you envision the Device to be installed as part of the manufacture of the tractor trailer, and not added by the dealer of the trailer to a tractor trailer in use. This raises the question of the certification that the Act requires by the truck tractor manufacturer of compliance with Standard No. 108, specifically S5.1.3. As your letter indicates, you are aware that S5.1.3 prohibits the installation of additional lamps or reflectors 'or other motor vehicle equipment that impairs the effectiveness of lighting equipment required by' Standard No. 108. It is manifest that installation of the Device has no effect upon the lighting equipment of the vehicle on which it is installed, the truck tractor. The question is whether S5.1.3 can be read as prohibiting the installation of a device on one vehicle that may affect the operation of lighting equipment on another vehicle. We believe that S5.1.3. can be so read because the term 'lighting equipment required by' Standard No. 108 is general in nature, and not restricted to the vehicle on which the additional equipment is installed. Although Standard No. 108 does not establish lighting requirements to be met by combinations of towing and towed vehicles, we interpret S5.1.3 as prohibiting installation of any original equipment on the towing vehicle that could impair the effectiveness of the lighting equipment required by Standard No. 108 to be installed on a towed vehicle. The determination of whether impairment exists is initially made by the manufacturer in certifying compliance of the towing vehicle to all applicable Federal motor vehicle safety standards. If a manufacturer installs as original equipment on one motor vehicle a device whose sole purpose is to affect the lighting performance of another motor vehicle, then that manufacturer must take into account whether that device would impair the effectiveness of the other vehicle's lighting equipment in certifying compliance to S5.1.3. If that decision appears clearly erroneous, NHTSA may make its own determination in order to effect compliance with Standard No. 108. We turn first to the question of the use of the Device as a surrogate taillamp on a vehicle equipped with red rear turn signal lamps. When used as a taillamp surrogate, the Device would substitute one steady-burning red rear light for another. If, as you indicate, the intensity of the surrogate taillamp is no greater than that of the original taillamp (and thereby maintains the ratio of difference required in combination turn signal- taillamps), there would appear to be no impairment of rear lighting equipment. When used as a fog lamp on a vehicle equipped with red rear turn signal lamps, the taillamps are not disabled, and the Device activates the turn signal lamps at full intensity in a steady burning mode. Commonly, combination rear lamps on large vehicles also include the stop function as well. Because of the similarity of intensity between the steady burning fog lamp and the stop function provided by the same filament, or the stop function in an adjacent lamp, we believe that the stop signal would be impaired when the Device is used as a fog lamp in a lamp configured as described in this paragraph. When used on a trailer equipped with the amber turn signal lamps that Standard No. 108 permits, different considerations apply. All lamps that serve as marker lamps on the rear (taillamps, identification lamps, clearance lamps) are required by Standard No. 108 to be red in color. On a trailer equipped with amber rear turn signals, the use of your Device would result in a pair of steady burning amber marker lamps on the trailer rear where, heretofore, the motoring public has not been accustomed to seeing them. Thus, the question arises under S5.1.3 whether the effectiveness of the required red rear lighting equipment is impaired when the Device activates steady burning amber rear lamps. You are aware of this possibility, but have pointed out to Mr. Vinson that the Device is intended for use when the taillamps are not available. Because taillamps, identification lamps, and clearance lamps share the same wiring, inoperability of the taillamps often means inoperability of the other rear marker lights. Thus, the steady burning amber lamps provided by the Device may be the only operating marker lamps on the rear of the vehicle. You believe that this is preferable to no lights at all. We would agree that, in this circumstance, there would be no impairment of required rear lighting equipment within the meaning of S5.1.3. However, the Device provides no safeguards against operation of the amber turn signal lamps in the taillamp mode when the taillamps (and other rear marker lamps) remain operative. Further, it permits operation of the amber turn signal lamps in the fog lamp mode regardless of the operability of the other rear marker lamps. Because the Device is intended for use only under conditions of reduced visibility, such as night and fog, when the headlamps are activated, there is a potential for confusion when a motorist is confronted with simultaneously operating steady burning red and amber lamps. In this situation, a conclusion could be drawn that the utilization of the Device to create a steady burning amber lamp could, within the meaning of S5.1.3, impair the effectiveness of the lighting equipment that is required to be red. You told Mr. Vinson of your willingness to provide a warning with the Device cautioning against its use when the taillamps are operative, and we appreciate your concern with the issue. You may wish to reexamine the efficacy of amber lamps as fog lamps. We understand that the most effective rear fog lamps are red, and that red is the only color permitted in Europe. You pointed out in your letter that, absent the Device, the tractor operator might choose to employ the flashing hazard warning lights for other than their intended purpose. We believe that today's motorists interpret flashing red or amber hazard lamps on moving vehicles as a signal that the vehicle is moving slower than the stream of traffic, and that caution is advised. Thus, safety may be enhanced when the hazard lamps flash, as they provide a contrast with the steady burning but less intense red rear taillamps. Finally, even if acceptable under the regulations and statutes administered by this agency, vehicles engaged in the commercial aspects of interstate commerce are subject to the regulations of the Office of Motor Carrier Standards (OMCS) Federal Highway Administration, and to the regulations of the individual States where the trailer is operated. We are not able to advise you of their restrictions, if any. You may write the Director, OMCS, Room 3404, 400 Seventh Street, S.W., Washington, D.C. 20590 for an interpretation. The American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, may be able to provide you with an interpretation of State laws. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam2152OpenMr. Charles J. Calvin, President, Truck Trailer Manufacturer Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin President Truck Trailer Manufacturer Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: This responds to the Truck Trailer Manufacturer Association's Novembe 17, 1975, request that the NHTSA reconsider its opinion that modification of existing tank trailers to increase their volumetric capacity and length does not constitute manufacture of a new air-braked trailer that must comply with Standard No. 121, *Air Brake Systems*. This opinion appears in a letter of August 28, 1975, to Stainless Tank and Equipment, Inc.; The National Traffic and Motor Vehicle Safety Act (the Act) authorize the issuance of motor vehicle safety standards (15 U.S.C. S 1392(a)) and prohibits, among other things, the manufacture of a motor vehicle on or after the date any applicable standard takes effect unless the vehicle conforms to the standard, and is so certified (15 U.S.C. S 1397(a)(1)(A), 1403). With the 1974 Amendments, (15 U.S.C. S 1397(a)(2)(A)) no manufacturer, distributor, dealer, or repair business may perform modifications that render inoperative any device or element of design required by a standard. However, unless the modifications performed are so extensive as to constitute legally the manufacture of a new vehicle, the standards that continue to apply to a vehicle are those in effect at the time of its original manufacture, not those that may have come into effect at a later date.; The modification of a tank trailer to increase its volumetric capacit and length does not, in our view, constitute the manufacture of a new vehicle in the typical situation (about an 18-inch increase in length). For this reason, Standard No. 121 does not apply to existing vehicles that are modified in accordance with your description.; This response does not address the issue of compliance with Federa motor carrier regulations raised in your November 17, 1975, letter.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0495OpenMr. Ed Baringer, Manager, Penn-Ohio Chapter, 25 East Boardman Street, Youngstown, OH 44503; Mr. Ed Baringer Manager Penn-Ohio Chapter 25 East Boardman Street Youngstown OH 44503; Dear Mr. Baringer: In your letter of November 23, 1971, you asked how your members coul make sure that the seat belts they install in their trucks conform to the applicable motor vehicle safety standards. As far as the belts themselves are concerned, each belt made after the seat belt standard (No. 209) became effective in 1967 is required to (sic) marked with the year of manufacture. So long as the belt bears a date after 1967, it will have had to conform to the seat belt standard and your members should use the date as a guide in purchasing belts.; The provision of anchorages for the belts is a somewhat more comple problem. A new truck - manufactured after July 1, 1971 -is required to have anchorages for lap belts at all seating positions (and, in some cases, anchorages for shoulder belts). Although older trucks were sometimes provided with anchorages, many were not, and for these you will have to follow the location and instructions of Standard No. 210 in order to comply with the Motor Carrier Safety Regulations. Although the Motor Carrier Safety Regulations do not establish strength requirements for anchorages, their strength should be of concern to you and in this area you may have to rely on the manufacturer, rather than the dealer, for advice on reinforcement of the vehicle structure.; Our legal staff is centralized in Washington and there are no fiel representatives of the agency who could assist you in matters relating to the standards. As much as we would like to send someone to address your group, the workload of the upcoming months prevents such a trip. However, we have found that many questions can be satisfactorily answered by letter. If your group could assemble a detailed list of questions, we will try to answer them as fully as possible.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0180OpenMr. John Thomas, Staff Engineer, Motor Vehicle Safety, International Harvester Company, Motor Truck Division, P. O. Box 1109,Fort Wayne, IN 46801; Mr. John Thomas Staff Engineer Motor Vehicle Safety International Harvester Company Motor Truck Division P. O. Box 1109 Fort Wayne IN 46801; Dear Mr. Thomas: This is in reply to your letter dated June 19, 1969, in which yo request approval of an alternative to the specified certification label location in accordance with Part 367.4(c) of the regulations. Due to an oversight, your letter has not reached me until now, and I apologize for the delay in responding.; Your proposed label location for models MA-1200 and MA-1500 Metro, o the panel below the wing glass, as shown in your enclosed sketch, is approved.; Sincerely, Robert Brenner, Acting Director |
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ID: aiam5382OpenThe Honorable John A. Boehner Member, United States House of Representatives 5617 Liberty Fairfield Road Hamilton, Ohio 45011; The Honorable John A. Boehner Member United States House of Representatives 5617 Liberty Fairfield Road Hamilton Ohio 45011; Dear Congressman Boehner:: This responds to your letter of April 7 1994, to the Department of Transportation (DOT) on behalf of your constituents, John Cail Sr. and James Lipps of Eaton. Messrs. Cail and Lipps have requested your assistance in obtaining DOT 'approval and color code designation' for their 'Life Lites' system. This is a stop lamp system consisting of two 18-inch long 1/2-inch wide devices intended to be mounted on the front of a vehicle alongside the windshield pillars, to emit a light of either purple or coral. The system is activated with the rear stop lamps when the brakes are applied, and it is intended to warn observers to the front of a vehicle that the vehicle is braking. It 'could be mounted to most existing vehicles and could be readily incorporated into new car designs.' The National Highway Traffic Safety Administration (NHTSA)is the component of DOT that is responsible for motor vehicle safety under the National Traffic and Motor Vehicle Safety Act. The Act does not authorize NHTSA to 'approve' or disapprove safety inventions such as Life Lites. We do advise, however, whether such inventions are permitted under the Act and applicable regulations such as the Federal motor vehicle safety standards. The fact that a device may be permitted under NHTSA laws must not be interpreted as our approval or endorsement of it. The standard that applies to motor vehicle lighting is Standard No. 108 Lamps, Reflective Devices and Associated Equipment. Life Lites emitting either color may be installed as original equipment by the manufacturer, distributor, or dealer at the time a vehicle is sold to its first purchaser provided that it does not impair the effectiveness of any of the frontal lighting equipment required by Standard No. 108 such as headlamps and turn signals. The materials you enclosed show a color closeup newspaper photo of a Life Lite in operation, its relatively low output does not appear sufficient to impair headlamp effectiveness. There would be concern, however, if it were to distract attention from an operating turn signal and, in this sense, impair its effectiveness. However, the responsibility for determining whether supplemental original lighting equipment impairs the effectiveness of the required lighting equipment rests with the installer, and NHTSA will not question this determination unless it appears clearly erroneous. Life Lites that are sold in the aftermarket and intended for vehicles in use, are prohibited by the Act if their installation by a manufacturer, distributor, dealer, or motor vehicle repair business 'knowingly renders inoperative, in whole or part' the required motor vehicle lighting equipment. Though the words are different between the Act and Standard No. 108, in this instance we would equate partial inoperability with impairment of effectiveness and the same considerations would apply. However, the Act does not prohibit vehicle owners under any circumstances from installing Life Lites themselves if they are able to do so. But the legality of Life Lites of either color and under any scenario remains subject to the laws of any State in which the device is operated. We are unable to advise your constituents of the laws of the individual States, and suggest that they write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. Sincerely, John Womack Acting 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.