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
| Interpretations | Date |
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ID: aiam4050OpenMr. R. C. Attwood, ASE (UK) Ltd., Norfolk Street, Carlisle, Cumbria, ENGLAND CA2 5HX; Mr. R. C. Attwood ASE (UK) Ltd. Norfolk Street Carlisle Cumbria ENGLAND CA2 5HX; Dear Mr. Attwood: Thank you for your letter of October 8, 1985, concerning the safet belt anchorage requirements of Standard No. 210, *Seat Belt Assembly Anchorages*. You asked a question about the anchorage requirements that would apply to a two point automatic safety belt, which has a separate manual lap belt. You asked if it is permissible for the two anchorages of the automatic belt and the two anchorages of the manual lap belt to be located outside of the zones specified in Standard No. 210, if three additional anchorages are located within Standard No. 210's zones. As explained below, the design you described would be permissible, assuming that you are voluntarily providing the manual lap belt.; Section S4.1.1 of the standard requires anchorages for a Type 2 safet belt to be provided at each front outboard seating position. Sections S4.3.1 and S4.3.2 set out the location requirements for Type 2 belts. However, S4.3 provides that the anchorages for automatic restraints which meet the frontal crash protection requirements of Standard No. 208, *Occupant Crash Protection*, do not have to meet the location requirements of the standard.; In interpreting the location requirement, the agency has said that al of the anchorages for an automatic belt may be located outside of the zones specified in Standard No. 210, as long as there are the three anchorages for a Type 2 safety belt located within the zone. Since your design for the automatic belt would provide three anchorages within the required zone, it would be permissible as long as the anchorages meet the strength requirements of the standard.; If you are voluntarily providing the manual lap belt, then it anchorages would not have to comply with Standard No. 210 as long as the use of the lap belt would not degrade the ability of the automatic lap belt to comply with Standard No. 208. However, if you are providing the lap belt to comply with the requirements of Standard No. 208, then the lap belt would have to have anchorages complying with Standard No. 210.; I hope this information is of assistance. If you have any furthe questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1252OpenMr. Ray Hartman, Vice President, Engineering, Crown Coach Corporation, 2500 East Twelfth Street, Los Angeles, CA 90021; Mr. Ray Hartman Vice President Engineering Crown Coach Corporation 2500 East Twelfth Street Los Angeles CA 90021; Dear Mr. Hartman: This is in reply to your letter of August 28, 1973, concerning th effective date of Motor Vehicle Safety Standard No. 121. Your direct question is whether the effective date is the starting or completion date for the vehicle's components or the starting date for the vehicle.; Standard No. 121 applies to the vehicle and its effective dat therefore relates to the vehicle, rather than to any of its components. A vehicle completed after the effective date will have to meet the standard, even though it is equipped with a foundation brake system that was manufactured before the effective date.; The vehicle's completion date, rather than its starting date, is th date that determines whether it must conform to the standard. If your company manufactures its vehicles from the ground up, rather than installing a body on a vehicle built by another manufacturer, the relevant completion date is the date you complete your manufacturing operation. However, if you buy an incomplete vehicle, as defined in our regulation on vehicles manufactured in two or more stages (49 CFR Part 568), and complete that vehicle, you may choose as the completion date for purposes of Standard No. 121 the date on which the manufacturer of the incomplete vehicle finished his work, the date on which you completed the vehicle or any date in between.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4400OpenMr. Tom George, P.O. Box 475, Howard, KS 67349; Mr. Tom George P.O. Box 475 Howard KS 67349; Dear Mr. George: Secretary Dole has asked me to respond to your letter to her, in whic you asked why we believe it is necessary to have laws mandating the use of safety belts. You stated that you believe a public education campaign about safety belt use would have been sufficient. I am pleased to have this opportunity to explain our position to you.; During the past decade, 470,000 persons have died on American highways Each year, an estimated 300,000 are injured seriously enough to require hospital treatment. These traffic deaths and injuries have resulted in an annual cost to society of approximately 57 billion dollars resulting from such costs as emergency medical services, long-term medical care and rehabilitation, worker's compensation, welfare payments, and lost tax revenue.; Numerous analyses have shown that safety belts reduce fatalities b 40-50 percent and reduce serious injuries by 45-55 percent. I have enclosed copies of a safety belt fact sheet and several pamphlets we have published explaining how and why safety belts are so effective. Because of the extensive body of evidence about the effectiveness of safety belts, the United States Supreme Court has said, 'We start with the accepted ground that, if used, seatbelts unquestionably would save many thousands of lives and would prevent tens of thousands of crippling injuries.'; This Department and other groups tried many public education efforts t make these facts known to the public, with the anticipation that more people would use safety belts when they knew the facts. Despite these efforts, the rate of usage for safety belts did not change substantially from what it had been in 1967. As recently as 1983, the overall safety belt usage rate for front seat occupants was only slightly above 12 percent.; This trend suggested that public education campaigns *alone* would no substantially reduce unnecessary deaths and injuries on our highways. In an effort to protect their citizens by substantially reducing vehicle-related deaths and injuries, and to reduce the financial burden on their taxpayers, 29 States and the District of Columbia have enacted safety belt use laws. I want to emphasize that each of these State legislatures made their own decisions with respect to safety belt use laws. This Department neither has nor seeks any authority to withhold Federal funds if States do not adopt or repeal safety belt use laws. We do, however, believe that safety belt use laws are more than justified by the possibility of achieving substantial reductions in vehicle-related deaths and injuries, and reducing the financial burden on the taxpayers. The available data show that among front seat occupants, safety belts saved about 2,200 lives in 1986, and 1,750 of those lives were saved in States that have safety belt use laws.; We agree with you, however, that safety belt use laws *alone* may no ensure long-term increased usage of safety belts. Simply requiring persons to wear their safety belts does not get to the heart of the problem of non- usage: lack of knowledge and negative attitudes regarding occupant restraints. Experience has shown that a combination of usage requirements *and* information and education campaigns are the most effective way to get more people to wear their safety belts. Therefore, we have continued our public information and education campaigns about safety belts, as has the State of Kansas. As a result of these combined efforts, our most recent data show that the overall safety belt usage rate for front seat occupants is now slightly above 40 percent.; We in the Department of Transportation are committed to reducing a much as possible the deaths and injuries on our nation's roads. This mission can only succeed with the cooperation and input of concerned citizens like yourself. Thank you for taking the time to express your concerns, and please let us know if you have any further questions or concerns about our programs.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0910OpenMr. Keitaro Nakajima, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, NJ 07071; Mr. Keitaro Nakajima Factory Representative Office Toyota Motor Sales U.S.A. Inc. Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of October 2, 1972, concerning th requirements applicable to a seat belt installed as part of a restraint system conforming to S4.1.2.3 of Standard 208.; You are correct in reading S4.1.2.3 to provide that a seat belt capabl of meeting the injury criteria of Standard 208 is not required to meet Standard 209 except as provided in S7.1 and S7.2 of Standard 208.; We have under consideration a petition from the Japan Automobil Manufacturers Association to amend Standard 209 to reflect the exemption made in Standard 208. The agency's response to the petition will be issued shortly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1602OpenMr. E. M. Bader, Director, Quality Assurance, B. F. Goodrich Tire Company, 500 South Main Street, Akron, OH 44318; Mr. E. M. Bader Director Quality Assurance B. F. Goodrich Tire Company 500 South Main Street Akron OH 44318; Dear Mr. Bader: This is to respond to the draft defect notification letter submitted b B. F. Goodrich at a meeting with NHTSA personnel on September 4, 1974. While we provided you with some preliminary comments at that time, our position regarding your notification is as stated in this letter.; We believe your letter fails to comply with 49 CFR, Part 577, 'Defec Notification' in several respects. Some of our comments are also directed at what we view as a lack of clarity in your letter arising, it seems to us, from some disorganization in the text.; The first sentence in your second paragraph does not follo satisfactorily the requirements of S 577.4(b)(1). This requirement should be met by simply stating, 'The B. F. Goodrich Tire Company has determined that a defect which relates to motor vehicle safety exists in its Space Saver Spare tire.'; Section 577.4(c) requires the notification to describe the defect b including specified information. We believe your letter confuses the items of information and presents them in an order which clouds an understanding of the safety problem. As we understand your presentation of the facts, the item of motor vehicle equipment affected (S 577.4(c)(1)) is the tire, the malfunction that may occur (S 577.4(c)(2)) is an explosion of the tire, and the operating or other conditions that may cause the malfunction to occur (S 577.4(c)(3)) are damaged beads, excessive air pressure, and beads not seated properly on the rim. With respect to this latter requirement, we find the reference to the 'combination' of factors in your second paragraph, and your fourth paragraph, in which you state that 'some or all' of the causal conditions listed can produce the defect, to be inconsistent and too imprecise to conform to the requirement. In addition to describing factors which can singly cause an explosion, if certain combinations of factors must exist in order for the defect to occur these combinations should not be stated generally as you have done, but should be specifically described. Moreover, we indicated to you at the September 4 meeting that we disagree that broken beads and excessive pressure must exist in combination in order for an explosion to occur.; Most importantly, we cannot agree upon your characterization of th bolting of the tire to the wheel before inflation as a precaution the owner can take to reduce the chance that the malfunction will occur under S 577.4(c)(4). Both literally and by implication your second and fourth paragraphs read that if the tire is bolted to the vehicle before inflation, an explosion will not occur. The malfunction, however, is an explosion of the tire, not only those explosions which cause injury. While we agree that bolting the tire to the vehicle before inflation can potentially reduce the chance of injury, it should be characterized only in this fashion. Therefore, both on page 1 of your letter and in the instructions which you begin on page 3 for persons who have need of the tire before its inspection by Goodrich, you must make it absolutely clear that bolting the tire to the vehicle has no effect whatever on whether the tire will explode, but that bolting will serve only to reduce the chance of injury if an explosion occurs.; We have the following points with respect to the remaining provision of your letter. On page 2, in the first complete paragraph, beginning 'In the majority of usage situation...etc,' we find the use of the word 'majority' confusing. The implication to us is that in a minority of situations the danger is not reduced at all. This should be clarified.; The third complete paragraph on page 2 is also confusing. There is n apparent connection between its first and second sentences. If you are attempting to say that despite what earlier labels may say that the instructions provided in this letter should be followed, then this can be stated more clearly.; The use of the word 'solely' in the fourth paragraph on page 2 is disclaimer, prohibited by section 577.6, and should be stricken.; On page 3, we believe the requirements of section 577.4(e)(1) call fo more detail than you have provided in the third paragraph on page 3. We suggest you include a description of the inspection and test cycle. As we indicated to you on September 4, the second and third paragraphs could be combined for clarity. Finally, the second sentence in your second paragraph on page 3 should be reworded to indicate more clearly that the date you have inserted is the date by which repair facilities will have necessary parts and instructions. In its present wording the meaning of the sentence is unclear.; Apart from these deficiencies, we believe your letter conforms to 4 CFR Part 577. At the same time, we believe your letter unnecessarily obscures the safety problem, and hope that, apart from literal compliance with Part 577, this is eliminated in the letter sent to purchasers. You should note that our determination of the conformity of the letter to Part 577 does not in any way indicate our agreement with Goodrich's analysis of the safety defect. We will continue to look into this matter, as appropriate, in order to determine whether Goodrich's analysis of the defect, and its consequent remedy, are fair and accurate statements of the safety problem. You should be aware that if subsequent events do show that attributing the safety defect to a mounting problem does not adequately describe the defect, further notification may be required.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4953OpenMr. Russell J. Eisert 5317 Delano Court Cape Coral, FL 33904; Mr. Russell J. Eisert 5317 Delano Court Cape Coral FL 33904; "Dear Mr. Eisert: This responds to your letter of October 25, 1991 requesting a waiver from the requirements of the Federal motor vehicle safety standards so that you can purchase a new vehicle that has been modified to allow you to operate the vehicle from your wheelchair. The safety requirements for new light trucks and vans were upgraded as of September 1, 1991. Light trucks and vans manufactured on or after that date must be capable of providing occupant crash protection to belted front seat occupants when the vehicle is crash tested at 30 miles per hour (mph) into a concrete barrier. A vehicle that provides this crash protection will increase the safety of vehicle occupants. As a result of this new requirement, this agency has recently received a number of phone calls and letters, from both van converters and individuals like yourself, suggesting that the new light truck and van crash testing requirement will, in effect, prohibit van converters from modifying vehicles to accommodate the special needs of persons in wheelchairs. The agency also received a petition asking for an amendment to the light truck and van crash test requirement in Standard No. 208 'to eliminate requirements that inadvertently discriminate against individuals with disabilities including individuals who use wheelchairs.' On January 9, 1992, this agency granted that petition. You should understand that the granting of a petition for rulemaking signifies that the agency believes a further review of the issues raised in the petition appears to have merit, but it is not a determination that the light truck and van crash test requirement should be amended. Any determination to amend the crash test requirement would be made in the course of a rulemaking proceeding, in accordance with statutory criteria. By addressing the issue comprehensively, in response to this petition for rulemaking, instead of in a piecemeal fashion, in response to each of the individual requests, NHTSA will be able to ensure that the resulting requirement offers persons in wheelchairs the best possible safety protection. However, we are aware that you and others need more immediate relief than rulemaking can offer. To afford more immediate relief, we announced in a January 21, 1992 letter to Representative Porter Goss that this agency will not conduct any crash testing under Standard No. 208 of vehicles modified for operation by persons with disabilities while this rulemaking is pending. We have also notified the van converter mentioned in your letter ofthis policy. This should allow you and others to purchase new vehicles while the rulemaking action is pending. With regard to your request for a waiver to have the rear seats in the van you will purchase moved rearward of the side door, the agency is not aware of any reason that would prevent a van converter from making this modification in such a way that the rear seats would continue to comply with all applicable safety standards after they were moved. There is, therefore, no need for us to grant such a waiver. If you have any further questions or need some additional information, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel cc: American International Conversions FAX 813/586-6627"; |
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ID: aiam5641OpenMr. Jim Schroeder Graco Inc. P.O. Box 1441 Minneapolis, MN 55440; Mr. Jim Schroeder Graco Inc. P.O. Box 1441 Minneapolis MN 55440; Dear Mr. Schroeder: This responds to your inquiry about the Federa Motor Vehicle Safety Standards (FMVSS) with which your trailer must comply. You state that your company plans to manufacture a trailer mounted striper that applies reflective paint stripes to roadways. In a telephone conversation with Mr. Marvin Shaw of my staff, you stated that your trailer will spend a significant amount of time traveling on public roads between job sites. Please note that we are returning the photographs attached to your letter that were marked confidential. As way of background information, the National Highway Traffic Safety Administration (NHTSA) interprets and enforces the laws under which the FMVSSs are promulgated. The statute defines the term motor vehicle as follows: Any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. Whether the agency considers your trailer to be a motor vehicle depends on its use. Based on the available information, it appears that your trailer is a motor vehicle within the meaning of the statutory definition. This conclusion is based on statements in your letter and telephone conversation that the trailer spends extended periods of time on the public roads moving between job sites. Thus, the agency would consider the use of your device on the public roads to be its primary purpose. The following Federal safety standards apply to trailers: Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, which address conspicuity, Standard No. 115, Vehicle Identification Numbers, and Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, while your vehicle is not required to be equipped with brakes, if it is equipped with hydraulic brakes, then you need to use brake hoses and brake fluids that comply with Standard No. 106, Brake Hoses and Standard No. 116, Motor Vehicle Brake Fluids. In addition as a manufacturer of motor vehicles, you would be required to submit identification information to this agency in accordance with 49 CFR Part 566, Manufacturer Identification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. This certification procedure is set out in 49 CFR Part 567. I hope this information is helpful. If you have any further questions about NHTSA s safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Samuel J. Dubbin Chief Counsel Enclosures; |
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ID: aiam2184OpenFile; File; On January 23, 1976, I received a telephone call from Mr. Walt Robbin (750-2600) concerning the interpretation letter mailed from this office to him an January 20, 1976. (The subject of that letter was the application of Standard No. 109's labeling requirements to a 'Radial, Bias Ply Tire'.) Mr. Robbins asked three questions:; 1) Were the four labeling examples set out in the letter intended to b restrictive or merely a model, with respect to the cord materials used in the tires (e.g. would a similar label that specified '3 PLIES 2 POLYESTER BIAS PLIES 1 POLYESTER RADIAL PLY' instead of an aramid radial ply also be permissible)? I explained that, in that respect, the examples were merely a model, so that his suggested alternative would be permissible.; 2) When would the rule that was discussed in the letter be issued? declined to give a prediction, explaining generally the uncertainties in the rulemaking process.; 3) What was the real reason for inclusion of the suggestion that h consult the FTC concerning advertising of the tires in question? I explained that he could take the sentence on its face and that the NHTSA was not, in the letter, taking any position on the use of the word 'radial' in the advertising of such tires.; Mark I. Schwimmer |
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ID: aiam0443OpenMr. Kenneth H. Dickey, Electric Device Corporation, 266 Bradford Drive, Canfield, OH, 44406; Mr. Kenneth H. Dickey Electric Device Corporation 266 Bradford Drive Canfield OH 44406; Dear Mr. Dickey: This is in reply to your letter of September 1, 1971, to Mr. Dougla Toms, Administrator, National Highway Traffic Safety Administration, concerning your request for an interpretation relative to your safety backing system and the Federal Standards.; The use of your School Bus Safety Backing System is neither require nor prohibited in Federal Motor Vehicle Safety Standard No. 108 and the proposed Pupil Transportation Safety Standard. However, it would appear that the regulations of the individual States apply to the use of your system in those States.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam5211OpenMr. Richard Muraski President/CEO Equa-Brake, Inc. 1105 Terminal Way, Suite 202 Reno, NV 89502; Mr. Richard Muraski President/CEO Equa-Brake Inc. 1105 Terminal Way Suite 202 Reno NV 89502; "Dear Mr. Muraski: This responds to your letter requesting a interpretation about the use of your product, the Equa-Brake mechanical auxiliary air brake system. You stated that this product 'increases brake force and improves brake performance on all vehicles that are equipped with air brakes.' You were concerned about whether the use of your product would be affected by an agency decision to deny a petition for rulemaking submitted by the Washington Company. That petition had requested the agency to require a device that regulates air pressure differential between the two wheels on each axle (57 FR 29459, July 2, 1992). As explained below, neither the requirements of Standard No. 121, Air Brake Systems nor those of the National Traffic and Motor Vehicle Safety Act (Safety Act), under which the standard was issued, prohibit the installation of your product in most situations. The one exception is that if your product is installed on a vehicle by a vehicle manufacturer, dealer, or repair business, neither the act of installation nor the operation of the device may render inoperative any device or element of design installed on that vehicle. By way of background information, the National Highway Traffic Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter. NHTSA does not have any specific regulations about auxiliary brake systems. However, since this device is tied to a vehicle's air brake system, it could affect a vehicle's compliance with Standard No. 121. That standard applies to almost all new trucks, buses, and trailers equipped with air brake systems. If the Equa-Brake is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that, with the device installed, the vehicle satisfies the requirements of all applicable safety standards, including Standard No. 121. (See 15 U.S.C. 1397(a)(1) and 49 CFR Part 567. If the device is added to a previously certified new motor vehicle prior to its first consumer purchase, then the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. 49 CFR 567.7. If the device is installed on a used vehicle by a manufacturer, distributor, dealer, or motor vehicle repair business, then the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative, in whole or in 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. 15 U.S.C. 1397(a)(2)(A). Your letter expressed concern about the effect of the agency's decision to deny the rulemaking petition submitted by the Washington Corporation. Please note that the Washington petition requested that the agency amend Standard No. 121 to require a device that regulates a brake system's air pressure differential between two wheels on each axle. In denying the petitioner's request to require such a device, the agency emphasized that its decision not to require a product in no way prohibited the optional installation of the device provided the vehicle continued to comply with the applicable standards. I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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.