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: aiam1922OpenMr. Jim Koester, Dairy Equipment Co., P.O. Box 1289, Madison, WI 53701; Mr. Jim Koester Dairy Equipment Co. P.O. Box 1289 Madison WI 53701; Dear Mr. Koester: This responds to Dairy Equipment's April 3, 1975 request for discussion of what constitutes the manufacture of a trailer in cases where used components from an existing vehicle are involved.; In response to a similar request from the Truck Trailer Manufacturer Association, the National Highway Traffic Safety Administration recently prepared a comprehensive discussion of this subject, a copy of which is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4673OpenLarry S. Snowhite, Esq. Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. 1825 Eye Street, NW Washington, DC 20006; Larry S. Snowhite Esq. Mintz Levin Cohn Ferris Glovsky and Popeo P.C. 1825 Eye Street NW Washington DC 20006; Dear Mr. Showhite: This replies to your letters asking for determination 'that the sale into the aftermarket as well as aftermarket installation of the Advanced Brake Light Device ('ABLD')...would not violate' any of this agency's statutes or regulations. As you have described it, the ABLD 'consists of a sensor attached to the accelerator pedal that senses the rate at which the foot releases the accelerator pedal. This signal is sent to a processor unit, which determines whether the brake lights should be turned on, and the duration of the illumination until the brake is applied. The ABLD is set so that the brake light will go off unless the brake is applied within one second of the ABLD's activation....' You believe that this avoids providing a misleading signal. You further indicate the manufacturer's willingness to alter the time interval if NHTSA's favorable opinion is required for it. You have not defined the term 'aftermarket', but we shall assume that you mean sales to vehicle owners of equipment for installation on their vehicles (as contrasted with sales to dealers for installation on new vehicles before their delivery). There is no Federal motor vehicle safety standard that applies to the system described in your letter. This means that there are no Federal restrictions upon the importation, manufacture, or sale of the ABLD. Under the National Traffic and Motor Vehicle Safety Act (specifically, l5 U.S.C. 1397(a)(2)(A)), as you surmise, modifications to vehicles by a person other than the vehicle owner are permissible as long as they do not 'render inoperative, in whole or in part, any device...installed on...a motor vehicle...in compliance with an applicable Federal motor vehicle safety standard....' The essential question then is whether the installation of the ABLD renders partially or wholly inoperative the vehicle's stop lamps. As you know, in our interpretations on lighting equipment, we have noted a close relationship between the statute's rendering inoperative prohibition for the aftermarket with the standard's impaired effectiveness prohibition for supplementary original equipment. Primarily, maintaining that relationship is done in order to avoid regulatory inconsistency with interpretations under which installation of an item of aftermarket equipment might be deemed acceptable under the National Traffic and Motor Vehicle Safety Act, while its installation as original equipment would violate Standard No. 108. There are two types of supplementary original, or aftermarket, lighting equipment: those that operate independently of the lighting equipment that Standard No. 108 requires, and those that operate in connection with that equipment. A separate red rear fog lamp would be an example of the former. The ABLD is an example of the latter, because it has a direct effect upon the operation of the stop lamp. An aftermarket device that has an effect upon the operation of required lighting equipment cannot be deemed permissible unless that effect is consistent with the operation and purpose of the required equipment. As you stated, the SAE defines a stop lamp as one whose function indicates 'the intention of the operator of a vehicle to stop or diminish speed by braking'. You have argued that 'The ABLD is consistent because it 'clearly and unambiguously indicates' an operator's intent to apply the brake. Your client, however, does not make that claim for the ABLD, it concedes that 'there will be circumstances in which the brake will not be engaged after the ABLD is activated.' The heart of our concern is that while the standard requires the stop lamp to operate in only one particular circumstance, the ABLD causes the stop lamp to operate at an earlier time when the lamp is supposed to be unlighted. Further, the ABLD's activation of the stop lamp indicates only that the operator has released the accelerator. It does not necessarily follow that the brake pedal will later be applied. Under this fact situation, the stop lamps fulfill a purpose other than for which they are installed. This can only create the potential for confusion and dilution of the effectiveness of the stop signal. For the reasons stated above, we have concluded that installation of the ABLD in the aftermarket would render the stop lamps partially inoperative. Because this conclusion does not depend upon whether the ABLD would be acceptable using the different parameters of performance to which it is apparently capable of being adjusted, there appears to be no reason to discuss this matter with you before completion of this interpretation, which would further delay our response. We would like to discuss several other points. You have stated that 'Illuminations of the brake lights for one second or less occur frequently during normal driving without the ABLD', and have sought to allay our concerns with the manufacturer's willingness to reduce the stop lamp activation time from one second to something less if that is required for a favorable interpretation. You have also provided information that the ABLD comes into operation only when the foot is released from the pedal at a rate consistent with an intent to apply the brake, as in an emergency situation. While we appreciate these arguments, we do not find them persuasive. The short periods of illumination to which you refer are occasioned by application of the brake pedal, no matter how brief that application is. The offer to reduce the activation time of the ABLD if it is not followed by a brake application would reduce but not eliminate stop lamp activation for purposes other than to indicate a stop or diminished speed. As for foot-movement time, there appears to be no indication in the University of Michigan study that you submitted that the ABLD was activated in traffic emergencies. The foot-movement time measurements seem consistent with removal of the foot from the accelerator under ordinary traffic situations, and thus there should have been no instances of ABLD activation. Your most recent letter contained a copy of a report of an independent field study of the ABLD in Israel, which 'found that rear-end accidents were reduced by 75 percent.' However, the report states that the ABLD-equipped vehicles ('except a few') were also equipped with center high-mounted stop lamps. Since any reductions in rear-end accidents that were experienced by the test fleets cannot be attributed solely to the ABLD, the data must be viewed as inconclusive. The acceptability for use of the ABLD must also be determined under the laws of the individual States. We are unable to advise you on these laws, and suggest that you get in touch with the American Association of Motor Vehicle Administrators (AAMVA) for further advice. Its address is 4600 Wilson Boulevard, Arlington, VA 22203. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam4389OpenMr. James R. Thompson, Vice President of Marketing, Dutcher Motors, Inc., 100 Western Maryland Parkway, Hagerstown, MD 21740; Mr. James R. Thompson Vice President of Marketing Dutcher Motors Inc. 100 Western Maryland Parkway Hagerstown MD 21740; Dear Mr. Thompson: This letter responds to your inquiry concerning classifying a vehicle the 'TransiTaxi,' which your company manufactures. You inform us that although in 1985 you classified this vehicle as a bus, you now have a question whether this is a proper classification. You state that you use Ford truck components in your vehicle design, and describe your vehicles as larger than the Ford Bronco.; You state further that if you must classify this vehicle as 'passenger car,' you would find it 'financially impossible to go through the crash-testing procedures required.' You ask us to consider issuing either an interpretation or an exemption, cite your maximum annual production of only 500 units as factor, and offer to bring a 'demonstrator' vehicle to Washington. You enclose specifications with your correspondence that say the standard 'TransiTaxi' seats a maximum of seven passengers.; First, please understand that under our certification requirements (4 CFR 567) for the vehicle safety standards, a manufacturer initially determines a vehicle's type using the definitions set out in 49 CFR S571.3, and certifies that the motor vehicle complies with all applicable Federal motor vehicle safety standards applicable to that type. However, a manufacturer's classification does not bind the National Highway Traffic Safety Administration (NHTSA).; Under S571.3, a ''Bus' means a motor vehicle with motive power, excep a trailer, designed for carrying more than 10 persons.' Since your vehicle is designed to carry a maximum of seven passengers, it appears that your vehicle is not a bus.; Your specifications indicate your use of design elements associate with a truck chassis. For example, the front twin I-beam suspension (coil springs) is designed for trucks, and the ground clearances and curb weight more nearly match truck specifications than for other types of; PAGE 2 WAS INADVERTENTLY MISSING FROM THE ORIGINAL Finally, if you wish to certify your Transitaxi as a bus, you may wis to consider using a larger chassis suitable for completion with the requisite seating capacity.; I hope you find this information helpful. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1471OpenMr. J. P. Koziatek, Director, Technical Services, Questor Juvenile Products Company, 771 N. Freedom Street, Ravenna, OH 44266; Mr. J. P. Koziatek Director Technical Services Questor Juvenile Products Company 771 N. Freedom Street Ravenna OH 44266; Dear Mr. Koziatek: This responds to your April 9, 1974, petition to substitute th proposed performance requirements for child harness testing under Standard No. 213, *Child seating systems*, for the performance requirements of Standard No. 209, *Seat belt assemblies*, to which Questor's Model 275 child harness is presently subject. As reasons for the substitution, you cite the inappropriateness of attachment hardware requirements (S4.3(c)) and the configuration of the test device (Figure 7) of Standard No. 209 as well as the desirability of testing to dynamic performance requirements which may become a part of Standard No. 213.; The Standard No. 213 dynamic test values which you recommend are onl proposals at this time. Interested parties have not had a full opportunity to comment on them and the NHTSA has not, of course, had the opportunity to fully evaluate them. For these reasons your petition to substitute these new dynamic tests for the Standard No. 209 static tests is denied.; You state that testing of the Model 275 to the assembly performanc requirements of Standard No. 209 (S4.4(c)) is complicated by the configuration of the test device for Type III harnesses, which is not suited to test a child harness such as the Questor NO. 275 that utilizes the adult front lap belts and the rear adult lap belt or the package shelf as attachment points.; Paragraph S5.3(c) (2) of Standard No. 209 directs that in such a cas 'attachment shall be. . .in accordance with the [manufacturer's] installation instructions'. As adherence to Model 275 installation instructions requires a front and rear adult belt installation (and in some cases a package shelf) the use of an actual vehicle bench seat in a passenger car would be an appropriate method to evaluate the assembly under S4.4(c) of Standard No. 209. Moreover, because the 12-inch extension requirement for an assembly tested under S4.4(c) is based on zero deflection of the test device, the actual vehicle seat should be modified to eliminate deflection.; The NHTSA has previously determined that the requirements of S4.3(c) o Standard No. 209 do not apply to bolts used to secure an adult upper torso restraint, other than the continuous loop type. Similarly, we interpret this provision not apply to the child harness upper torso restraint described in your letter. The bolts would be regulated with respect to strength only by the assembly performance requirements of S4.4(c).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4223OpenMs. Dixie Hawkins, Mid-South Motors, Inc., 2617 Scottsway, Memphis, TN 38115; Ms. Dixie Hawkins Mid-South Motors Inc. 2617 Scottsway Memphis TN 38115; Dear Ms. Hawkins: This is in response to your letter of September 17, 1986, in which yo asked for a determination from the Agency concerning the Tennessee Certificate of Title and the Federal odometer disclosure requirements, 49 C.F.R. Part 580. The Tennessee title cannot be used in lieu of a separate odometer disclosure statement.; The title fails to meet the regulatory requirements because it does no include a space for the buyer's signature. This Agency considers the signature to be essential. It is an acknowledgment that the purchaser is aware of the mileage and prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. Furthermore, the buyer's signature is important to investigative and prosecutorial efforts.; The National Highway Traffic Safety Administration allows the use o the abbreviated disclosure statements such as those which appear on the Tennessee title. Although a shorter disclosure might sacrifice clarity to a degree, the Agency regards this as an acceptable price for gaining the benefits of a combined title and odometer disclosure. When the odometer has been repaired or replaced, the box on the title which should be checked depends on the circumstances surrounding the repair or replacement. If the mileage indicated on the odometer remained the same as before repair or replacement, you should check the box which states:; >>>I hereby certify that to the best of my knowledge the odomete reading as stated above reflects the actual mileage of the vehicle described below.; <<>>I hereby certify that to the best of my knowledge the odomete reading as stated above is not the actual mileage of the vehicle described below, and should not be relied upon.<<<; If you have any questions do not hesitate to call Judith Kaleta a (202) 366-1834.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1021OpenMr. J. W. Kennebeck, Manager, Safety and Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Safety and Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This is in response to your letter of February 26, 1973, in which yo asked a question concerning the relationship of the seat belt interlock and warning system required by Standard No. 208.; You asked whether the informative warning system, required by S7.3.5. to operate when the driver turned the ignition to 'start' position and 'the operation of the seatbelt systems required by S7.4.1 to start the engine has not been performed', is required to operate when the driver turns the ignition to start under the 'free start' provisions of S7.4.3.; The answer is no. The 'start' warning of S7.3.5.4 is only required t operate when a seatbelt operation 'required to start the engine' has not been performed. When the engine is free to start under S7.4.3, the warning is not required. Of course, if the driver puts the vehicle in gear, the warning must sound under the provisions of S7.3.1 if the required seatbelt operations have not been performed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1534OpenMr. Frank R. Schubert,Heavy Vehicle Systems Group,The Bendix Corporation,901 Cleveland Street,Elyria, Ohio 44035; Mr. Frank R. Schubert Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria Ohio 44035; Dear Mr. Schubert:#This responds to your April 29, 1974, request fo approval of your banding designs to meet the requirements of Standard No. 106, *Brake hoses*,for labeling brake hose assemblies.#The NHTSA interprets a band a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From these statements, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of any design.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam3509OpenMr. Ernesto Rodriguez, Cariben, Inc., 144-30 Roosevelt Avenue, Suite 606, Flushing, NY 11354; Mr. Ernesto Rodriguez Cariben Inc. 144-30 Roosevelt Avenue Suite 606 Flushing NY 11354; Dear Mr. Rodriguez: This responds to your letter of September 22, 1981, asking whether an Federal motor vehicle safety standard precludes the importation or sale of your anti-theft device. The device works by blocking the brakes and electric circuits to the motor. In trucks, the clutch is also blocked. Installation of the device requires cutting into a vehicle's braking system.; By way of background information, the agency does not give approvals o vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. We note that the term 'manufacturer' is defined by section 102(5) of the Act to mean 'any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, *including any person importing motor vehicles or motor vehicle equipment for resale*.' Emphasis added. ; The agency does not have any regulations covering anti-theft device that work by preventing release of the brakes.; However, since installation of your device requires cutting into vehicle's braking system, it may affect a vehicle's compliance with other safety standards.; If your device is added to a new motor vehicle prior to its first sale the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. In the case of your device, this would include Safety Standard No. 105, *Hydraulic Brake Systems* (49 CFR 571.105). You will find the specific certification requirements for alterers at 49 CFR Part 567.7, *Certification*. On the other hand, you as the manufacturer of the device would have no certification requirements, because we have no safety standards applicable to your equipment. However, an alterer would probably require information from you in order to make the necessary certification.; If your device is installed on a used vehicle by a business such (sic) garage, the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, which states in relevant part:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . .<<<; Standard No. 105 includes various requirements that might be affecte by installation of your device. We are not able to determine from the drawings included with your letter whether compliance with the standard would be affected. We suggest that you carefully examine all of Standard No. 105's requirements to determine the degree to which installation of your device affects compliance with the standard. Your letter states that when your device is not in use, the vehicle works normally without any interference whatsoever. In addition to requirements specifically concerning stopping performance, the standard also includes requirements related to such things as a split system and the ability to withstand a series of spike stops, which might be affected by your device.; While we do not have any opinion as to the safety of your particula device, we do have a general concern about the safety of anti-theft devices which work by preventing release of the brakes. We note that some manufacturers state in their service manuals that hydraulic brake locking devices should not be used on their vehicles.; Should a safety-related defect be discovered in your device, whether b the agency or yourself, you as the manufacturer would be required under sections (sic) 151 *et seq*. of the Act to notify vehicle owners, purchasers, and dealers and provide a remedy for the defect.; Finally, in addition to the provisions of Federal law discussed above there is a possibility of liability in tort should your device prove to be unsafe in operation. You may wish to consult a local lawyer concerning liability in tort.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4736OpenMr. David R. Martin #113730 EA-118B Tomoka Correctional Institution 3950 Tiger Bay Road Daytona Beach, FL 32124; Mr. David R. Martin #113730 EA-118B Tomoka Correctional Institution 3950 Tiger Bay Road Daytona Beach FL 32124; "Dear Mr. Martin: This responds to your letter to this agency's Publi Affairs Office asking about the application of Safety Standard (FMVSS) No. 301, Fuel System Integrity, to a van used by a correctional institution to transport inmates. Your letter has been referred to me for reply. I regret the delay in responding. As you may know, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act to issue safety standards for new motor vehicles and motor vehicle equipment. NHTSA issued Standard No. 301 to reduce deaths and injuries resulting from fuel spillage in crashes. The standard applies to new vans manufactured on or after September 1, 1976, that have a gross vehicle weight rating (GVWR) of 10,000 pounds or less. Under the Vehicle Safety Act, each manufacturer of a motor vehicle or item of motor vehicle equipment is responsible for certifying that its products meet all applicable safety standards. Thus, if the vans in your letter were manufactured on or after September 1, 1976, the van manufacturer was required to certify their compliance with Standard No. 301. However, even if the vans did not comply with that standard, the Act does not place any responsibility for that noncompliance on the first purchasers and subsequent owners of the vans. Since some states do require that vehicles used for certain purposes comply with our standards, you may wish to address your question to appropriate State authorities in Tallahassee. We regret we cannot provide the testing you seek. NHTSA obtains and tests new vehicles for compliance with FMVSS No. 301. However, since the standard applies only to new vehicles, NHTSA does not conduct compliance tests on vehicles that have already been sold to a consumer. The agency also cannot test every new type or model of vehicle, since it would be impracticable to do so. For your information, Safety Standard No. 217 specifies emergency exit requirements for vans designed to carry 11 or more persons. However, the standard excludes vans purchased for transporting prison inmates. This exclusion resulted from a determination that the standard's requirements were incompatible with the necessity that buses used for transporting inmates be able to confine their occupants in transit. I have enclosed a copy of Standard No. 217 for your information. You also asked whether we require roll bars on vehicles used to transport 12, 13 or 14 passengers. The answer is no. However, NHTSA does have a standard for roof crush protection (Standard No. 216) which requires the roof over the front seating area of cars to meet certain strength requirements. NHTSA has proposed to extend the standard to light trucks and buses (GVWR of 10,000 pounds or less). I have enclosed a copy of that proposal for your information. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam1164OpenMr. J. T. Monk, Taylor Machine Works, Inc., P.O. Box 150, Louisville, MS 39339; Mr. J. T. Monk Taylor Machine Works Inc. P.O. Box 150 Louisville MS 39339; Dear Mr. Monk: This is in reply to your letter of May 25, 1973, to Michael Peskoe o this office, requesting clarification of the regulations regarding the certification of motor vehicles. You enclose an incomplete vehicle document concerning a particular tractor, a certification label you would affix to that tractor after its completion, a drawing of a trailer certification label, and a sample quarterly report of production figures for vehicles manufactured by your company.; Mr. Peskoe indicated to you over the phone that in meeting you certification responsibilities for these vehicles, they are certified independently of each other. It appears from your letter that this approach, which is the correct one, is the approach you are using.; With reference to your responsibilities for the certification of th tractor, if the truck does not have a certification label attached to it when you receive it, it is true that when you complete it by mounting a fifth wheel you must then attach a certification label. The label you enclose (exhibit 1) contains the necessary information in the appropriate order. You should obtain the information for the label primarily from the incomplete vehicle document, but may, as you state, rely on your own engineering judgment or contact the truck manufacturer. If, however, in relying on your own judgment you depart from the information contained in the incomplete vehicle document, you may be responsible for failures of the vehicle to conform to applicable standards and regulations.; The sample trailer certification label which you have submitted is no consistent with the certification regulations. We have taken the position that the information must be presented on the label in the form and in the order specified in the regulations. With respect to your sample label, the regulations do not presently call for a kingpin rating. Although we have just proposed to require a weight rating for the trailer coupling, this information should not now be included on the label. The regulations also do not permit ratings for tandem axles to be stated as tandem ratings. Each axle must be independently identified and a separate rating provided for it. Moreover, tire sizes are permitted to be specified only in conjunction with weight ratings. There are no provisions for the listing of plies, apart from their inclusion in a tire size designation, or for the listing of an inflation pressure. Again, information that is not specifically required cannot be inserted between items of required information, and your drawing of a trailer is not permitted unless it is placed after the required information. Finally, the regulations call for gross vehicle weight rating (the phrase 'gross trailer weight rating' is inappropriate) to follow the gross axle weight ratings, and the order in which you present this information must be reversed. I believe you should reexamine the Certification regulations in order to obtain specific guidance on the order and form of the required information.; The sample quarterly production report you submit conforms to th requirements of section 573.5(b) of the Defect Reports regulations. However, that section requires only the reporting of the number of vehicles, identified by make, model, and model year (if appropriate). While we are happy to receive the additional information you provide, you are not required to furnish it to us.; Yours truly, Richard B. Dyson, Assistant 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.