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: aiam3685OpenThe Honorable Charles H. Percy, United States Senate, Washington, DC 20510; The Honorable Charles H. Percy United States Senate Washington DC 20510; Dear Senator Percy: This responds to your letter of April 11, 1983 (Ref. 3098500010 requesting information on behalf of your constituent, Mrs. D. Parutti. Mrs. Parutti is concerned about the growing practice of persons installing darkly tinted film on passenger car windows. She believes this is a dangerous practice because it prevents other drivers from seeing inside the vehicles. Following is a discussion of the implications under Federal law of installing these tinting films.; A Federal regulation already exists which, under certain circumstances precludes the practice referred to by Mrs. Parutti. The National Highway Traffic Safety Administration has the authority to govern the manufacture of new motor vehicles and motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, we have promulgated Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance. This specification for light transmittance precludes darkly-tinted windows in new automobiles.; The agency has stated in past interpretations that solar films such a the type referred to in Mrs. Parutti's letter are not glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, that manufacturer or dealer has to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Section 108(a)(1) prohibits any person from offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards.; After a new vehicle has been sold to the consumer, he may alter hi vehicle as he pleases, so long as he adheres to all State requirements. Under Federal law, the owner could install the tinting film on glazing in his vehicle whether or not such installation adversely affected the light transmittance and abrasion resistance of his vehicle's glazing. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. Render inoperative' means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the Federal safety standards. Thus, none of those persons may knowingly install a solar film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.; The individual States must govern the operational use of vehicles b their owners since the agency does not have authority in this area. Thus, it would be up to the States to preclude owners from applying films or one-way glass on their own vehicles. Mrs. Parutti may wish to contact the National Committee on Uniform Traffic Laws (555 Clark Street, Evanston, Illinois 60204) to find out which States have laws that would preclude owners from placing solar film on their automobile windows.; Please contact Hugh Oates of my staff if you have any further question (202- 426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2997OpenMr. Paul Utans, Product Compliance, Subaru of America, Inc., 7040 Central Highway, Pennsauken, NJ 08109; Mr. Paul Utans Product Compliance Subaru of America Inc. 7040 Central Highway Pennsauken NJ 08109; Dear Mr. Utans:#This is in response to your letter of March 26, 1979 requesting our interpretation of whether the turn signal identification symbol which you propose meets the requirements of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The answer is yes. As long as the turn signal symbol is displayed in the horizontal mode, as shown in Table 1, it will comply with the standard. Small additional arrows that will not be confused with the turn signal symbol may be incorporated to indicate movement of the control. Your thin vertical arrows do not appear to pose any possibility of causing such confusion.#Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam1342OpenSheller Globe Corporation, Lima, OH; Sheller Globe Corporation Lima OH; In response to your telegram of December 6 NHTSA would consider the us of a roof emergency exit as appropriate to meet the requirements to S5.2.1 of standard No. 217 if it were impracticable to use a rear exit because, as you state, retooling an existing configuration would be excessively expensive.; Richard B. Dyson, Assistant Chief Counsel, N40-30, National Highwa Traffic Safety Administration, Department of Transportation; |
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ID: aiam0380OpenGerhard P. Riechel, Esq., Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Gerhard P. Riechel Esq. Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Riechel:#This is in replay to your letter of June 2 requestin confirmation of certain matters concerning compliance of the 1973 model Volkswagen Type I (Beetle) and Type II (Station Wagon) vehicles with Motor Vehicle Safety Standard No. 101.#We confirm that the arrangement, identification, and illumination of the heater and defroster controls as described at the meeting of May 25 between representatives of this agency and Volkswagen, and as presented in your letter of June 2, appear to meet the intent of Standard No. 101. Specifically, the requirement of paragraph S4.3 that control identification 'shall be illuminated whenever the headlamps are activated' does not necessarily require the installation of a separate light source to illuminate the identification of each control. Thus, if the ambient illumination emanating from the dash panel provides sufficient illumination to identify heater and defroster controls mounted on the drive shaft tunnel, then the illumination requirement would appear to be met. We agree that the use of contrasting lettering on the control knobs increases the likelihood that this method of compliance would meet the intent of Standard No. 101.#Sincerely, Robert L. Carter, Acting Associate Administrator, Motor Vehicle Programs; |
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ID: aiam5478OpenMs. Lori A. Hawker 20 Begonia St. Casper, WY 82604; Ms. Lori A. Hawker 20 Begonia St. Casper WY 82604; "Dear Ms. Hawker: This responds to your letter asking about safet regulations for a product you wish to manufacture. You describe the product as 'bunting' that fits inside an infant-only car seat. (An infant-only seat is lightweight and is easily used as an infant carrier to carry an infant to and from the car.) The bunting is intended as a substitute for a blanket. You state that the bunting has slots through which the harness on the car seat is threaded and the buckle of the harness is attached to the car seat. You believe that, when properly installed, 'the bunting in no way interferes with the adjustment or function of the safety straps or buckle mechanism.' By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. The following represents our opinion based on the information in your letter. There is currently no Federal motor vehicle safety standard (FMVSS) that directly applies to your product. Our standard for 'child restraint systems,' FMVSS 213, applies to 'any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less.' (S4 of FMVSS 213) The standard does not apply to child seat accessories that are sold separately from the child seats, such as car seat pillows, pads and bunting. While no FMVSS applies to the bunting, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. 30118-30121 concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. In addition, while it is unlikely that the bunting would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, 49 U.S.C. 30122 prohibits those businesses from installing the device if the installation 'makes inoperative' compliance with any safety standard. Standard 213 specifies flammability resistance requirements for infant seats. Any person listed in 30122 who installs the bunting must ensure that the product does not vitiate the seat's compliance with those flammability resistance requirements. The prohibition of 30122 does not apply to individual owners who install equipment in their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to degrade the safety of their vehicles. I would like to close with the following remarks. It is crucial for the safety of an infant that the straps of its infant seat retain the baby's torso in a crash. Excessive slack in the straps due to the straps binding up on a fabric liner in the seat (such as bunting material), or because of excessive compression of the liner, can cause shoulder straps to move off an infant's shoulders. As a consequence, the infant can be ejected from the seat. We know that you recognize the importance of the straps in a crash, and that you believe that the bunting will not interfere with their adjustment or function. We underscore the importance of this feature. Bunting material that degrades the ability of an infant seat to restrain its occupant would be an obvious safety problem. I hope this information has been helpful. If you have any other questions, please feel free to contact Deirdre Fujita of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam1968OpenMr. Dennis M. Dykiel, Hendrickson Mfg. Company,8001 West Forty-Seventh Street, Lyons, Illinois 60534; Mr. Dennis M. Dykiel Hendrickson Mfg. Company 8001 West Forty-Seventh Street Lyons Illinois 60534; Dear Mr. Dykiel: #Please forgive the delay in responding to your lette of March 26, 1975, requesting an interpretation of the masking requirements of Federal Motors Vehicle Safety Standard No. 106-74, *Brake Hoses*. #The requirement that the label on a brake hose remain visible after painting was amended on March 17, 1975, (40 FR 12088, Docket No. 1-5, Notice 16) to permit the label to remain masked if (1) the masking material is affixed in such a way that no adhesive contacts any part of the label and (2) the masking is manually removable. Since the requirement that the label be masked or visible, rather than obscured, is a vehicle requirement, it is not effective until September 1, 1975. Vehicles manufactured before that date may contain hose which has been painted over. #Sincerely, James C. Schultz, Chief Counsel; |
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ID: aiam3955OpenMr. L. D. Pitts, Jr., P. O. Box 52592, Houston, TX 77002; Mr. L. D. Pitts Jr. P. O. Box 52592 Houston TX 77002; Dear Mr. Pitts: Thank you for your letter of March 12, 1985, asking about the effect o our regulations on a product you would like to manufacture. I hope the following discussion explains that effect.; You described your product, which you call a glare- shield, as 1/8-inch thick sheet of 'Lexan' plastic with a special scratch resistant coating. Your product is designed to be mounted inside a motor vehicle, as close to the windshield as possible, to reduce glare-related vision problems caused by the sun. You stated that your product would cover the entire windshield and is designed to be held in place by three or six latches. The latches can be released by the driver and the shield can be removed from the car.; Pursuant to the National Traffic and Motor Vehicle Safety Act, we hav issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials,* (49 CFR 571.205) which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; Any manufacturer, dealer or other person who installs tinting films o other sun screen devices, such as the one described in your letter, in *new* vehicles must certify that the vehicle as altered continues to comply with the requirements of the standard. Thus, for example, the light transmittance through the combination of the sun-screening material and the glazing must be at least 70 percent in the case of glazing used in windows requisite for driving visibility. Similarly, the combination must also meet the other applicable requirements of the standard, such as the abrasion resistance requirements.; After a vehicle is sold to the consumer, owners may themselves alte their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, an owner may install any device regardless of whether the installation adversely affects light transmittance. The agency does, however, urge owners not to install equipment which would render inoperative the compliance of a vehicle with our standards. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from using sun screens on their vehicles.; If a manufacturer, dealer, distributor or motor vehicle repair busines installs the sun screen device for the owner of a used vehicle, then S108(a)(2)(A) of the Vehicle Safety Act may apply. That section provides that none of those persons may knowingly render inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a Federal motor vehicle safety standard. Violation of the 'render inoperative' provision can result in Federal civil penalties of up to $1,000 for each violation.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2647OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body & Equipment Assoc., Inc., 5530 Wisconsin Ave., Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body & Equipment Assoc. Inc. 5530 Wisconsin Ave. Suite 1220 Washington DC 20015; Dear Mr. Crampton: This responds to your July 22, 1977, request for clarification of m July 21, 1977, letter to you stating that, in the case of brake and axle modifications to change the function of a used vehicle from that for which it was originally manufactured, it is the NHTSA's view that degradation of the brake system would only occur as prohibited by the National Traffic and Motor Vehicle Safety Act (S 108(a)(2)(A)) if portions of the brake system originally installed are removed, disconnected, or otherwise rendered inoperative. You asked whether a change in 'function' of a vehicle would include a modification that simply increases the load-carrying capacity or stability of a vehicle to carry out the same task for which it was originally manufactured.; The answer to your question is no. In the NHTSA's view, the changes yo describe would only increase the capabilities of the vehicle to perform its originally manufactured function. Thus, the 'element of design' that constitutes the original braking system of the vehicle could be knowingly degraded by the installation of an additional axle that does not provide the capability that would have been required for it if installed in the new vehicle.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5182OpenJohn Paul Barber, Esq. Legislative Counsel American Association of Blood Banks 8101 Glenbrook Road Bethesda, Maryland 20814-2749; John Paul Barber Esq. Legislative Counsel American Association of Blood Banks 8101 Glenbrook Road Bethesda Maryland 20814-2749; Dear Mr. Barber: This responds to your letter asking whether secon stage manufacturers may affix additional certification labels with a new gross vehicle weight rating (GVWR) on vehicles. You asked this question in the context of the Federal Highway Administration's commercial driver's license program which applies in part to commercial vehicles with a GVWR of 26,001 pounds or more. You stated in your letter that your organization has advised its members that second stage manufacturers that convert buses to bloodmobiles have the authority under 49 CFR Parts 567 and 568 to affix an additional label with a new GVWR to newly converted vehicles as well as to vehicles already in use. You stated, however, that you have since received a legal opinion from a private party asserting that those regulations preclude affixing an additional label to vehicles already in use. You enclosed a copy of your earlier advice (American Association of Blood Banks Bulletin; "92-5), which reads in part as follows: Many bloodmobiles have a gros vehicle weight rating of 26,001 or more pounds. This renders the bloodmobiles commercial motor vehicles requiring an operator with a commercial driver's license. However, options may be available to avoid the classification of bloodmobiles as commercial motor vehicles on the basis of their gross vehicle weight rating. . . . When originally constructed, buses will be given gross vehicle weight ratings in excess of 26,000 pounds. When converted for use as bloodmobiles, their actual weight is reduced to two or three thousand pounds less than the 26,000 pound threshold, yet many converters do not change the gross vehicle weight rating. By federal regulation, vehicle converters have the authority to affix an additional label containing a new gross vehicle weight rating, to newly converted vehicles as well as to vehicles already in use. Title 49 Code of Federal Regulations, Sections 567 and 568. I am pleased to have this opportunity to explain our regulations to you. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue safety standards applicable to new motor vehicles and new motor vehicle equipment. NHTSA does not, however, approve motor vehicles or motor vehicle equipment. Instead, under the Safety Act, manufacturers are required to certify that their products meet all applicable safety standards. I will first discuss the issues you raise concerning new vehicles. Under NHTSA's certification regulations (Parts 567 and 568), manufacturers must assign a GVWR to a new vehicle. The term GVWR is defined in 49 CFR Part 571.3 as 'the value specified by the manufacturer as the loaded weight of a single vehicle.' The GVWR informs vehicle owners how heavily the vehicle may safely be loaded. It also affects the vehicle's loading and other test conditions for the safety standards to which the vehicle must be certified, and at which NHTSA conducts any compliance testing. NHTSA expects the GVWR to reflect a manufacturer's good-faith evaluation of the vehicle's size, weight and load carrying capacity. The only express regulatory limitation on the GVWR that manufacturers may assign to their vehicles is set forth in 49 CFR Part 567. Section 567.4(g)(3) provides that the assigned GVWR 'shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity.' See also section 567.5. You asked about the authority of persons who convert buses to bloodmobiles to reduce the GVWR of the vehicle. I note that, assuming that the conversion takes place before the first sale of the vehicle for purpose other than resale, i.e., while the vehicle is still new, the converter would be considered either a 'final stage manufacturer' or an 'alterer,' depending on the circumstances. A final stage manufacturer is a person who performs such manufacturing operations on an incomplete vehicle that it becomes a complete vehicle. See 49 CFR Part 568.3. An alterer is a person who modifies a previously certified, new motor vehicle. See 49 CFR Part 567.6, 567.7, and 568.8. A final stage manufacturer is ordinarily responsible for making the final assignment of GVWR for a vehicle that it completes. See 49 CFR Part 567.5(c). (Special requirements apply if the incomplete vehicle manufacturer or an intermediate vehicle manufacturer assume legal responsibility for all duties imposed by the Safety Act.) However, as discussed below, a final stage manufacturer may, as a practical matter, need to assign to the completed vehicle a GVWR that is consistent with that specified by the incomplete vehicle manufacturer. Incomplete vehicle manufacturers (typically GM, Ford or Chrysler) are required to furnish with the incomplete vehicle a document which specifies, among other things, the GVWR of the completed vehicle for which the incomplete vehicle is intended (i.e., the GVWR that is appropriate for the incomplete vehicle when completed) and statements concerning how the design of the incomplete vehicle affects conformity with safety standards. See 49 CFR Part 568.4. Moreover, manufacturers of chassis-cabs are required also to attach a certification label concerning the conformance of the chassis-cab with safety standards. See 49 CFR Part 567.5(a). (A chassis-cab is an incomplete vehicle, with a completed occupant compartment, that requires only the addition of cargo-carrying, work- performing, or load-bearing components to perform its intended function.) If a final stage manufacturer wishes to base its certification on the incomplete vehicle document or other information furnished by the incomplete vehicle manufacturer, as the vast majority of final stage manufacturers do in actual practice, the final stage manufacturer will likely need to assign to the completed vehicle a GVWR that is consistent with that specified by the incomplete vehicle manufacturer. I note that, since most safety performance requirements are easier to meet at lower loads than higher loads, it is possible that a final stage manufacturer might be able to justify assigning a reduced GVWR to some vehicles. We would urge the final stage manufacturer to consult with the incomplete vehicle manufacturer about such an action. As indicated above, the reduced GVWR would need to comply with the requirement set forth in 49 CFR Part 567.4(g)(3), and we would expect it to reflect the manufacturer's good-faith evaluation of the vehicle's size, weight and load carrying capacity. I note that the final stage manufacturer is subject to the same basic requirements concerning GVWR as a single stage manufacturer. I have enclosed a copy of an April 29, 1991 letter to Mitsubishi which discusses the issue of reducing the GVWR of certain vehicles. An alterer has a more limited certification responsibility. Under 49 CFR Part 567.7, an alterer must allow the original certification label to remain on the new vehicle and must affix an additional label which states that, as altered, the vehicle 'conforms to all applicable Federal Motor Vehicle Safety Standards affected by the alteration.' If the GVWR of the vehicle as altered is different from that shown on the original certification label, the modified value must be provided. I note, however, that since an alterer only certifies a vehicle with respect to the alterations it makes, the alterer would only have a basis to change the GVWR if the alterations are relevant to GVWR. You also asked whether manufacturers may affix additional labels with a new GVWR to vehicles after they are sold for purposes other than resale, i.e., after they become used vehicles. As discussed above, the term GVWR refers to 'the value specified by the manufacturer as the loaded weight of a single vehicle,' and the GVWR is assigned by the vehicle's manufacturer as part of the certification process. Therefore, for purposes of NHTSA's regulations, a vehicle's GVWR is fixed as of the time of its first sale to a consumer. The only exception to this is if the manufacturer seeks to correct an error (e.g., calculation error or typographical error) regarding the originally assigned GVWR. We recognize that certain modifications that might be made to a used vehicle (e.g., adding or deleting an axle) could make the originally assigned GVWR inappropriate for the vehicle as modified. While not required by our regulations, we believe it would be appropriate in such situations to add a label to the vehicle which indicates the appropriate loaded weight of the modified vehicle. You also asked whether the affixing of a new label with an adjusted GVWR would have the effect of rendering existing bloodmobiles noncommercial motor vehicles for purposes of the Commercial Motor Vehicle Safety Act. Since the commercial driver's license program is administered by the Federal Highway Administration (FHWA), I have referred this question to that agency. If you wish to speak to someone at that agency about your question, you may contact Charles Medalen, of the FHWA Office of Chief Counsel, at (202) 366-1354. I hope this information is helpful. If you have any further questions about NHTSA's regulations, please feel free to contact Edward Glancy of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure "; |
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ID: aiam5028OpenMr. Joe Wos A & D Lock & Key 238 Faithway Dr. Seffner, FL 33584; Mr. Joe Wos A & D Lock & Key 238 Faithway Dr. Seffner FL 33584; Dear Mr. Wos: This responds to your May 26, 1992 letter asking whethe it is 'legal to repair an automobile that has an airbag deployed and not put the air bag back in.' I am enclosing a copy of a January 19, 1990 letter to Ms. Linda L. Conrad, that explains whether a used car dealer has an obligation to replace a deployed air bag prior to selling the car. The same statutory and regulatory considerations that applied to that situation would apply to the replacement of a damaged air bag steering column (after the air bag has deployed) with a steering column without an air bag. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice 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.