Interpretation ID: aiam4614
DC 205l5;
"Dear Mr. Nowak: Thank you for your letter on behalf of you constituents, Ms. Eugenia M. Pierakos and Mr. James L. Pierakos. Ms. Pierakos and Mr. Pierakos are president and sales manager, respectively, of a firm which is the western New York state dealer for Jaeger Industries, Inc., a Canadian manufacturer of curbside recycling equipment. They stated that Jaeger has had difficulty obtaining data/regulations that apply to a type of vehicle manufactured by Jaeger, and specifically asked about regulations related to the use of chain steering for dual steering applications, brakes, and throttle. According to the Pierakos' letter, Jaeger has spoken with two officials of the National Highway Traffic Safety Administration, and no one has provided that company with any definitive answers. Ms. Pierakos and Mr. Pierakos requested assistance in obtaining the necessary information. I note that we do recall speaking with a representative of Jaeger by telephone. We were not able to provide definitive answers to that company by telephone, since it is our policy not to provide oral interpretations of our safety standards. This policy is for the benefit of the person requesting the interpretation and the agency. It ensures that there are no misunderstandings as to the question or response, and that there is an opportunity for appropriate review of the interpretation within the agency. The policy also enables us to place all interpretations in the docket, so that the public has access to each interpretation. While we advised Jaeger that they could submit their questions in writing, our records do not show any written request from that company. I will now provide what information I can in response to the Pierakos' request. By way of background information, 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 new motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. Enclosed is a pamphlet which provides information for new manufacturers of motor vehicles and motor vehicle equipment. Among other things, the pamphlet explains where to obtain motor vehicle safety standards and regulations. As indicated above, Ms. Pierakos and Mr. Pierakos specifically asked about regulations concerning chain steering for dual steering applications, brakes, and throttle, that would apply to the vehicle manufactured by Jaeger. Information included with the letter indicates that the vehicle in question is an air-braked truck with a gross vehicle weight rating over 30,000 pounds. NHTSA has not issued any standards for 'chain steering.' Moreover, no standard prohibits a manufacturer from providing dual steering. With respect to brakes, Standard No. l2l, Air Brake Systems, establishes performance and equipment requirements for braking systems on vehicles equipped with air brake systems, and Standard No. l06, Brake Hoses, specifies labeling and performance requirements for brake hose, brake hose assemblies and brake hose end fittings. Standard No. l24, Accelerator Control Systems, sets forth requirements for a vehicle's throttle. Also, Standard No. l0l, Controls and Displays, includes requirements related to the steering wheel, brakes, and throttle. If the Pierakos, or Jaeger, have any specific requests for interpretation of these or other applicable safety standards, we would be happy to respond to such requests. I note that one of the enclosures included with Ms. Pierakos and Mr. Pierakos' letter is a drawing from Jaeger which includes the following statement: 'This document contains proprietary information and it shall not be used or reproduced or its contents disclosed in part or whole without prior written authorization.' Since the drawing could become subject to a request for release under the Freedom of Information Act, I am returning to you the copy of the drawing included with your letter. I hope this information is helpful. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures";