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: aiam1050OpenMr. Charles E. Ferreira, Jr. President, General Seating Company, Topton, PA 19562; Mr. Charles E. Ferreira Jr. President General Seating Company Topton PA 19562; Dear Mr. Ferreira: This is in reply to your letter of March 8, 1973, requestin clarification on three points related to Federal Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release.; >>>1. Glass Types. Glazing materials must conform with Standard No 205, Glazing Materials. ANSI Z26, incorporated into Standard No. 205 by reference, can be purchased from the American National Standards Institute, 1430 Broadway, New York, New York 10018. SAE J673a can be purchased from the Society of Automotive Engineers, Two Pennsylvania Plaza, New York, New York 10001.; 2. Locks. Paragraph S5.3.2 reads, When tested under conditions of S6 both before and after the window retention test required by S5.1, each emergency exit shall allow *manual release* of the exit...' (emphasis added).; 3. Tests. Two studies were contracted over the past few years whic related to bus windows. Reports of these studies may be purchased from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22151.; (a) PB 195-231, Study of Bus Side Windows,' by All America Engineering Company. Cost: $3.00; (b) PB 198-772, Escapeworthiness of Vehicles and Occupant Survival Part 1' by University of Oklahoma Research Institute. Cost:$6.00; PB 198-773, Escapeworthiness of Vehicles and Occupant Survival - Part 2 and 3,' by University of Oklahoma Research Institute. Cost: $6.00.<<<; I am enclosing a copy of Standard No. 205. If I can be of further service, please do not hesitate to ask. Sincerely, Robert L Carter, Associate Administrator, Motor Vehicle Programs |
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ID: aiam4602OpenCONFIDENTIAL; CONFIDENTIAL; "Dear CONFIDENTIAL: Thank you for your letter requestin interpretations of how Standards No. 203, Impact Protection for the Driver from the Steering Control System (49 CFR /571.203) and 210, Seat Belt Assembly Anchorages (49 CFR /571.210) apply to a vehicle in which the driver's seating position is equipped with both an air bag and an automatic safety belt. We have concluded that the vehicles described in your letter appear not to be subject to the requirements of Standard No. 203, based on your representation that the driver's position in those vehicles would comply with the occupant protection criteria in section S5.1 of Standard No. 208, Occupant Crash Protection (49 CFR /571.208) by means of the air bag alone. Further, if the manufacturer certifies that the driver's position in those vehicles would comply with the occupant protection criteria in section S5.1 of Standard No. 208 with the automatic safety belts in place, the anchorages for the automatic belts would be exempted from the anchorage location requirements in Standard No. 210. These conclusions are explained below. Before discussing the substantive issues raised in your letter, I would like to respond to your request that NHTSA not publicly release the identities of the vehicle manufacturer or its counsel because the development of vehicles with both air bags and automatic safety belts 'is competitively sensitive.' We hereby grant your request. You provided us with a version of your letter deleting all references to the identity of the manufacturer and its counsel. We will make available to the public your purged version of your letter to us and a version of this letter purged of all references to your identity. Standard No. 203 With respect to Standard No. 203, section S2 of Standard No. 203 provides that the standard 'does not apply to vehicles that conform to the frontal barrier crash requirements (S5.1) of Standard No. 208 by means of other than seat belt assemblies.' The first question is whether S2 exempts from Standard No. 203 those vehicles whose driver's seating position conforms to the frontal barrier crash requirements by means other than belt assemblies, or whether S2 only exempts from Standard No. 203 those vehicles in which both the driver's position and the right front outboard seating position conform to the frontal barrier crash requirements by means other than belt assemblies. After examining the history and purpose of this requirement, we have concluded that vehicles are not subject to Standard No. 203 if the driver's seating position offers the specified occupant protection, for the following reasons. The title of Standard No. 203 explicitly states that it is intended to provide protection for the driver, not for any other vehicle occupants. Moreover, section S2 of Standard No. 203 was promulgated after NHTSA determined that compliance with the requirements of Standard No. 203 could impede the development and installation of a more advanced occupant protection system, such as air bags, at the driver's position. See 40 FR 17992, April 24, 1975. This determination would not apply with respect to any seating positions other than the driver's position, because compliance with the requirements of Standard No. 203 would have no positive or negative effects on the development and installation of occupant protection systems at any other seating positions. Given the history and purpose of Standard No. 203 in general and section S2 in particular, section S2 must be interpreted so that Standard No. 203 does not apply to vehicles whose driver's seating position offers the specified occupant protection. Having determined that one examines only the driver's seating position to see whether a vehicle is exempt from the requirements of Standard No. 203 by virtue of the provision in section S2 of the standard, we must now determine whether a vehicle whose driver's seating position is equipped with both an air bag and an automatic safety belt can be said to conform to S5.1 of Standard No. 208 by means other than seat belt assemblies. We conclude that it can if the manufacturer certifies that the driver's seating position conforms with S5.1 of Standard No. 208 by means of the air bag alone. If the manufacturer certifies that the air bag alone provides the specified occupant protection at the driver's seating position, then, for purposes of S5.1 of Standard No. 208, the installation of the automatic safety belt would be a voluntary action by the vehicle manufacturer. The agency has long stated that manufacturers are free to install systems or components in addition to the required safety systems or components, provided that the additional systems do not destroy the ability of the required systems to comply with the applicable safety standards. Therefore, if a manufacturer certifies that an air bag alone provides the specified occupant protection at the driver's seating position, an automatic safety belt at that seating position would be a safety system installed in addition to the air bag system. The only limitation on the installation of automatic safety belts at such seating positions would be that the combination of the automatic safety belt and the air bag must comply with the requirements of S5.1 of Standard No. 208. If a manufacturer certifies that the driver's seating position in a vehicle complies with S5.1 of Standard No. 208 by means of an air bag alone, that vehicle would be exempt from Standard No. 203 even if an automatic safety belt system were also provided for the driver's seating position. If the manufacturer cannot certify that the driver's seating position complies with the requirements of S5.1 by means of the air bag alone, then both the air bag and the automatic safety belt are necessary to provide the required level of occupant protection. In this case, the vehicle would be subject to Standard No. 203, because it relies on a seat belt system to conform with the requirements of S5.1 of Standard No. 208. Standard No. 210 Section S4.3 of Standard No. 210 provides that: 'Anchorages for automatic and for dynamically tested seat belt assemblies that meet the frontal crash protection requirement of S5.1 of Standard No. 208 (49 CFR /571.208) are exempt from the location requirements of this section.' This exemption is premised on the agency's conclusion that the anchorage location requirements are unnecessary when the same aspects of performance are indirectly tested in dynamic testing. See 50 FR 14589, at 14595, April 12, 1985. That is, the anchorage location requirements are an indirect means of ensuring that a belt system will afford adequate protection to a user in a crash. The dynamic testing requirements directly measure the protection the belt system offers belt users in a frontal crash. Your letter referred to a March 14, 1988 letter we sent to Mr. Karl-Heinz Faber. In his letter, Mr. Faber asked whether standard equipment items in the vehicle would be operational during compliance testing. We responded in part as follows: During its compliance testing, NHTSA combines a test of the occupant crash protection capabilities of automatic or manual safety belts with testing done to determine compliance with other standards. ... In conducting these compliance tests, NHTSA tests vehicles in their 'as delivered' form with all items of standard equipment present in the vehicle. Thus, if a vehicle has devices, such as an air bag system or pre-tensioning devices for the belts, installed in the vehicle as items of standard equipment, NHTSA's compliance testing is conducted with those items in place and fully functioning. In other words, Standard No. 210 does not require that the safety belt alone provide the specified level of occupant protection in order for the anchorages to be exempt from the anchorage location requirements. Such a requirement would be unrealistic, since occupant crash protection depends on the safety belt system working synergistically with other vehicle features, such as energy absorbing instrument panels, collapsible steering columns, and anti-lacerative windshield glass. Because of this synergism, NHTSA has always conducted its Standard No. 208 compliance testing with all items of standard equipment in place and functioning during the test. We would treat an air bag in the same way. Therefore, if the vehicle manufacturer certifies that the driver's seating position complies with the occupant protection criteria in Standard No. 208 with an automatic belt in position and functional during the test, the anchorages for that automatic belt would be exempt from the location requirements in Standard No. 210. This certification by the manufacturer would be based on the protection afforded by the automatic belt and all other standard features in the vehicle, including air bags. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1400OpenMr. Paul J. Kruder, President, CIMS COS., P.O. Box 1610, Akron, Ohio 44309; Mr. Paul J. Kruder President CIMS COS. P.O. Box 1610 Akron Ohio 44309; Dear Mr. Kruder: This is in reply to your letter of January 15, 1974, requestin information on the labeling requirements of Motor Vehicle Safety Standard No. 117. The agency has recently amended Standard No. 117 in accordance with the Court of Appeals decision in *National Tire Dealers' and Retreaders' Association v. Brinegar*. The standard as amended requires only that retreaded tires be permanently labeled with maximum load. All the other information required -- size, tubeless or tube-type, maximum inflation pressure, and radial and bias/belted designation -- may appear on affixed labels. The amendment does allow the use of one permanent label to apply all of the required information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0138OpenMr. R. Hadekel, Chief Engineer, Trico-Folberth Ltd., Great West Road, Brentford, Middlesex, England; Mr. R. Hadekel Chief Engineer Trico-Folberth Ltd. Great West Road Brentford Middlesex England; Dear Mr. Hadekel:#Thank you for your letter of January 1, 1969 concerning your windshield washer system.#Apparently our letter of October 3, 1968, to Mr. B. C. Johnson was misunderstood. In Mr. Johnson's inquiry of August 23, 1968, he stated 'it is easy to deliver 15 cc's of fluid inside the three seconds specified.' The wording of our reply acknowledged that this performance would be acceptable--it was not intended to be a literal interpretation of our requirements or the SAE Recommended Practice.#We learned that the SAE Windshield Wiping Subcommittee plans to revise J942, Passenger Car Windshield Washer Systems, to clarify the particular points you question. Meanwhile, we think the intent of Section S4.2 of Standard No. 104 is satisfied by the following interpretation of the referenced SAE Recommended Practice:#>>>1. Paragraph 3.1 of J942 requires that 75% of the effective wiped area be cleared in 10 wiper cycles or less. Section S4.2.1 of Standard No. 104 requires that these areas be established in accordance with subparagraph S4.1.2.1 of Standard No. 104.#2. The requirement to wipe 75% clear must also be met within 15 seconds as stipulated in paragraph 4.1.3(c) of J942.#3. A washer cycle is defined in paragraph 2.11 of J942 as 'The system actuation sufficient to deliver approximately 15 cc of fluid to the windshield glazing surface.' Note this definition does not actually define the number of actuations necessary to deliver the 15 cc, although the use of the word 'actuation' *appears* to be singular. It is obvious that the intent of paragraph 4.1.3(c) is that this amount of fluid shall be delivered during the 15 second test period.#4. In paragraph 4.4.2(b) of J942 (under the durability test) the Recommended Practice requires: 'For manual systems a single actuation shall consist of actuation of the control for a period not to exceed 3 seconds.' It is important to note that this specifies the time required for the driver to operate the control--not the total time for the washer system to actuate. It appears this definition refers to a *control actuation*, whereas, the definition for 'washer cycle' refers to a *system actuation*. This is borne out in paragraph 2.2 of J942 which defines 'control' as 'A means for actuating the arresting the windshield washer system. The actuation may be coordinated or semi-coordinated with components of the windshield wiper or may be fully independent.'#5. Note that the following sentence in paragraph 4.4.2(b) states: 'For automatic systems an actuation shall consist of one actuation of the control.' This seems to indicate, by inference, that more than one control actuation is acceptable for manual systems.#6. Therefore, the intent of the referenced SAE Recommended Practice by Section S4.2 of Standard No. 104 is that manual washer systems may be actuated more than once to provide the 15 cc of fluid as long as it does not require the operator more than 3 seconds to operate the control for any single system actuation--and the washer system must deliver 15 cc of fluid to clear 75% of the wiped area within 10 cycles and within 15 seconds.#7. Note that any additional system actuations needed to meet the 15 cc requirement will also require that the manufacturer increase accordingly the total number of control actuations for the durability test in Table I, 'Test Sequence' in J942.<<<#We assume that your windshield washing system meets these requirements based upon your explanation of your manual system. However, we wish to point out our concern that the existing regulations do not adequately define washer system performance requirements, since it is possible under the current regulations for the driver to be needlessly occupied with the washer controls during a period of reduced visibility. Accordingly, we expect to up-grade the washer system performance requirements as soon as practicable.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service; |
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ID: aiam2105OpenMr. O.D. Hunter, Director of Training and Publications, DPD Mfg. Co., Inc., Box 18327, Serna Station, San Antonio, Texas 78286; Mr. O.D. Hunter Director of Training and Publications DPD Mfg. Co. Inc. Box 18327 Serna Station San Antonio Texas 78286; Dear Mr. Hunter: "This is in response to your letter of j September 22, 1975 requesting information concerning the applicability of Federal motor vehicle safety standards to automatic cruise control devices."; As you were advised by telephone, Motor Vehicle Safety Standard No 124, *Accelerator Control Systems*, does not preclude the use of cruise control units. while Standard No. 124 requires that the accelerator control device return to 'idle' when the operator removes his foot from the accelerator or when the system itself fails, the term 'idle position' is defined in S4.1 of the standard to include the position set by a throttle setting device. The rationale for not regulating automatic speed control devices is found in the preamble to the standard, issued in April 8, 1972 (37 FR 7097), which states:; >>>The rule does not contain requirements for automatic speed contro devices. It was found that although nine recall campaigns involving 61,176 vehicles have concerned these devices, no relationship to accelerator overspeed accidents could be established from automatic speed controls. Of the 540 multi-disciplinary accident reports that were studied in formulating the final rule, none mentioned the automatic system.<<<; There are no other Federal motor vehicle safety standards which ar concerned with the use of automatic cruise control devices.; I trust this information will be useful to you. I have enclosed a cop of Standard No. 24 for your future reference.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4878OpenMr. Masaharu Morino Manager, Far East Department Guy B. Barham Company 500 North Nash Street El Segundo, California 90245; Mr. Masaharu Morino Manager Far East Department Guy B. Barham Company 500 North Nash Street El Segundo California 90245; "Dear Mr. Morino: This responds to your request for an interpretatio of Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps (49 CFR 571.211). In your letter, you enclosed two samples of 'spinner' hubcaps, a product sheet describing several different designs of spinner hubcaps, and a letter from the New York Area Director of the U.S. Customs Service regarding spinner hubcaps. You asked whether these 'spinner' hubcaps may legally be imported into this country from Taiwan. The answer is no. Spinner hubcaps may not legally be manufactured or sold in the United States, nor may they legally be imported into the United States. I have enclosed copies of this agency's March 16, 1988 letter to Representative Terry L. Bruce, a May 13, 1987 letter to Representative William E. Dannemeyer, and a November 13, 1987, letter to Mr. William J. Maloney. These letters reaffirmed past interpretations stating that spinner hubcaps do not comply with the requirements of Standard No. 211, and have not complied with that Standard since it became effective on January 1, 1968. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) makes it illegal to 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any hubcaps that do not comply with Standard No. 211 (Emphasis added.). We would consider each sale or offer for sale of spinner hubcaps to be a separate violation of this statutory provision. Section 109 of the Safety Act (15 U.S.C. 1398) specifies a civil penalty of up to $1000 for each violation of Section 108(a), up to a maximum of $800,000. In your letter, you stated that some spinner hubcaps are currently being manufactured in the U. S. Thank you for alerting us to this situation. We have referred this information to our enforcement staff for appropriate action. I have also sent a copy of this letter to the Area Director of Customs for the New York Seaport. Sincerely, Paul Jackson Rice Chief Counsel Enclosures cc: Area Director of Customs New York Seaport New York, New York 10048 re: CLA-2-87:S:N:N1:101 835326"; |
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ID: aiam0092OpenMr. Toyotaro Yamada, Manager, Toyota Motor Company, Ltd., 231 Johnson Avenue, Newark, NJ 07108; Mr. Toyotaro Yamada Manager Toyota Motor Company Ltd. 231 Johnson Avenue Newark NJ 07108; Dear Mr. Yamada: Thank you for your letter of June 27, 1968, in which you requeste clarification of the term 'optically combined' as applied to motor vehicle lights.; 'Optically combined' in this context means that the same lens area i used for more than one function such as tail and stop lights or stop and turn signal lights or tail, stop and turn signal lights. The normal means used to accomplish this 'optically combined' lamp has been to incorporate a single dual-filament bulb with a reflector and lens.; Since the design of your Toyata (sic) Crown combination stop, tail an turn signal lamp is such that a different part of the lens area is used for the turn signal lamp, we do not interpret it to be optically combined with the tail and stop lamp.; The concurrence of the above interpretation with yours and that of th California Highway Patrol should not be construed to be an approval of your design. The results of recent research on lighting and signaling reviewed by this Bureau indicate that signal lights should be separated 4 1/2 to 5 inches minimum (centerline to centerline separation.) Although no dimensions are specified on your drawing it appears to be approximately full scale with a separation distance of 2 1/4 inches between the stop and turn signal lamps. The steady-burning stop lamp may therefore 'wash out' or significantly reduce the effectiveness on the turn signal lamp. Federal Motor Vehicle Safety Standard 108 does not require a minimum separation distance between signal lights, however, upon completion of our present research contracts on rear lighting and signaling, we may consider such a requirement in the future.; Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam5290OpenMr. Jerome Cysewski 1404 Lewis Avenue Billings, MT 59102; Mr. Jerome Cysewski 1404 Lewis Avenue Billings MT 59102; Dear Mr. Cysewski: This responds to your letter asking about th applicability of Federal requirements to two vehicles. I apologize for the delay in our response. According to your letter, one vehicle is a 13,600 pound cement silo that has tandem axles. The second vehicle is a 6,400 pound aggregate batch plant that has a single axle. The cement silo and batch plant are mounted on their own trailers, and are equipped with electric brakes. Each vehicle is pulled by a one ton truck with hydraulic brakes. You also stated that both vehicles are mobile but are designed to be towed for off-the-road set and positioning. I am pleased to have this opportunity to explain our regulations to you. By way of background information, this agency, the National Highway Traffic Safety Administration (NHTSA), issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The Safety Act 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.' (Section 102(3)) If a vehicle is a motor vehicle under the definition, then the vehicle must comply with all applicable Federal motor vehicle safety standards. However, if a vehicle is not a motor vehicle under this definition, then the vehicle need not comply with the agency's safety standards because such a vehicle is outside the agency's scope of authority. Whether NHTSA considers a construction vehicle, or similar equipment, to be a motor vehicle depends on the use for which it is manufactured. It is the agency's position that this statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. In instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time, such vehicles are considered motor vehicles for purposes of the Safety Act, since the on-highway use is more than 'incidental.' Your letter does not provide sufficient information for us to determine the extent to which the two vehicles would use the public roads. Nor can we determine whether the on-highway use of the vehicles would be merely incidental and not the primary purpose for which they are manufactured. However, you should be able to determine whether the vehicles are considered motor vehicles based on the information set forth above. If the vehicles are considered motor vehicles under the Safety Act, they would be required to meet all safety standards applicable to trailers. Enclosed is an information sheet which identifies Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers. 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, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam0568OpenMr. K. Nakajima, Director/General Manager, Toyota Motor Company, Ltd., Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Toyota Motor Company Ltd. Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This letter is in response to your inquiry of January 6, 1972 regarding the relationship of Standards No.208 and No.216.; You interpret Standard 216, paragraph *S3. Application*, which state that the Standard does not apply to passenger cars 'that conform to the rollover test requirements (S5.3) of Standard 208 by means that require no action by vehicle occupants,' as follows:; >>>1. From August 15, 1973, the effective date of Standard 216, t August 15, 1977, passenger cars are not required to meet Standard 216 if they conform to the 'first option' of Standard 208.; 2. For the period of August 15, 1973, through August 14, 1975 passenger cars which are designed to conform to the 'second' or proposed 'third' option of Standard 208 are not required to meet Standard 216 if they meet the rollover requirements (S5.3) by passive means (when tested under the applicable conditions of S8), even though in Standard 208 the rollover requirement is specified only for 'option 1.'<<<; These interpretations are correct. Please write if we can be of furthe assistance.; Sincerely yours, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2555OpenMiss Irene Glessner, 276 Birch Avenue, Elsmere Manor, Wilmington, DE 19805; Miss Irene Glessner 276 Birch Avenue Elsmere Manor Wilmington DE 19805; Dear Miss Glessner: This responds to your March 21, 1977, letter asking whether a tir dealer is required to record the serial numbers of the tires he sells.; The National Highway Traffic Safety Administration (NHTSA) promulgate regulations pertaining to tires. One of these regulations, Part 574, *Tire Identification and Recordkeeping*, requires tire dealers and distributors to obtain information when the tire is sold and to forward that information to the tire manufacturer. I am enclosing a copy of this regulation for your information. In S574.7 of the regulation you will find the exact information for which a tire dealer is responsible.; A tire dealer would not be responsible for the ultimate recall o tires. The information which a dealer submits to a manufacturer enables the manufacturer to undertake recalls. Failure to record and submit the information to a manufacturer would be a violation of Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966 (as amended) (15 U.S.C. 1381, 1397). Each violation is punishable by a civil penalty of $1,000 up to a maximum of $800,000 for a series of violations (15 U.S.C. 1398).; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.