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: aiam0321OpenMr. Warren S. Sumner, Sales Representative, Hamill Manufacturing Company, 61166 Van Dyke Road, Washington, MI 48094; Mr. Warren S. Sumner Sales Representative Hamill Manufacturing Company 61166 Van Dyke Road Washington MI 48094; Dear Mr. Sumner: This is in reply to your letter of March 16, 1971, in which you as certain questions concerning a child booster seat that you plan to market. You describe the booster seat as a rectangle about 6 inches in height, tapering to 4 inches in the front, and state that it would be advertised for use by children under 50 pounds and would not be designed to fall into the category of child seating systems under Standard No. 213. You also state that your engineers feel a booster chair will 'definitely help more five, six and seven year old children to use seat belts simply because these children will be able to see out of a vehicle.'; While you state that the booster seat 'would not be designed to fal into the category of child seating systems under Standard No. 213,' it is not clear from your description of the device that this is actually the case. If you wish an opinion on this matter, we will provide one, but to do so we will need some additional information. Specifically, we will need to know if the booster seat is to be designed or advertised for use with the vehicle seat belts, and if so, how it will be so designed or advertised.; The questionsyou (sic) ask concerning the booster seat are: (1) Can w set a minimum of 50 or 60 pounds?(2)Exactly (sic) what is the maximum child weight covered under MVSS No. 213? and (3) What recommended weight can we advertise as a minimum for our booster seat?; The answers to these questions do not depend on whether the standar applies to your booster seat. If the device is a child seating system, Standard No. 213 does not specify the minimum or maximum heights or weights for children who may use it. Under the standard, it is up to the manufacturer to determine, based upon the design of each particular child seating system, the heights and weights of children for which he recommends the child seating system.; If the device is not a child seating system, the manufacturer is no required to recommend any heights or weights for children who can use it. Should he choose to do so, however, the heights and weights recommended must be consistent with the safe use of the device.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5573OpenMilford R. Bennett, Director North American Operations Safety Affairs and Regulations General Motors Corporation 30200 Mound Road Warren, Michigan 48090-9010; Milford R. Bennett Director North American Operations Safety Affairs and Regulations General Motors Corporation 30200 Mound Road Warren Michigan 48090-9010; Dear Mr. Bennett: This responds to General Motors' (GM's) inquiry raised in a June 16, 1995 meeting with the agency, regarding the test procedures in Federal Motor Vehicle Safety Standard No. 114 for determining whether a vehicle is in the 'park' position. Under those procedures, a vehicle is deemed to be in park if it ceases rolling within 150 mm. You were concerned that different methods of measuring this distance could result in some vehicles not complying with the requirement that the vehicle roll less than 150 mm. The short answer to your question is that the test procedure is a 'static' measurement procedure. In other words, the agency will not measure the distance that a vehicle has rolled until after the vehicle has completely ceased moving. This agency recently amended Standard No. 114, adding test procedures to determine whether the key can be removed when the transmission is in positions other than the 'park' position and that the transmission remains locked in 'park' after key removal. (60 FR 30006, June 7, 1995) NHTSA initiated that action in response to a petition from the automotive industry alleging that such a procedure was needed to make the standard objective. Section S4.2.1(a)(3) of the amended standard specifies that ' e ach vehicle shall not move more than 150 mm on a 10 percent grade when the transmission or transmission shift lever is locked in 'park.' To demonstrate that the vehicle is in 'park' prior to attempting to remove the key, the test procedures in S5.2(e) and S5.3(b) both state: Drive the vehicle forward up a 10 percent grade and stop it with the service brakes. Apply the parking brake (if present). Move the shift mechanism to the 'park' position. Apply the service brakes. Release the parking brake. Release the service brakes. . . . Verify that vehicle movement was less than or equal to 150 mm after release of the service brakes. In the June 16 meeting with the agency, GM stated that vehicle movement could be measured in two different ways: dynamic or static. GM inquired as to which method NHTSA interpreted the standard as specifying, because the results using these two methods would be different. The 'dynamic' method of measuring vehicle movement was described by GM as measuring the maximum play-out of a spool of wire attached to the front bumper after release of the service brakes. The 'static' method would measure vehicle movement from a reference point on the wheels after the vehicle has come to a complete stop. Under the dynamic method, a portion of the measured play-out would be due to the 'rocking' motion of the vehicle's chassis on its suspension when the transmission engaged. The driveline components would also contribute some movement by temporarily storing some of the kinetic energy of the moving vehicle by flexing and twisting. However, both of these contributions to total rearward movement are temporary, disappearing after the vehicle comes to rest, as in the static measuring method. GM presented test data for certain vehicles and theoretical worst-case calculations of static roll distance on non- production hypothetical vehicles and one test vehicle. The test data showed that dynamic measuring produces larger measurements of roll than does static measuring. NHTSA interprets the limitation on vehicle movement specified in S4.2.1(a)(3) as referring to static movement. The agency did not contemplate using the dynamic method. The agency intends to measure only permanent components of total vehicle movement, using the 'static' method. When conducting compliance testing, NHTSA will measure vehicle movement from a reference point such as the wheel centerline position. The starting time for the measurement will be at the moment before the service brakes are released. The ending time of the measurement will be when the vehicle has completely ceased moving, bouncing, and rocking (i.e., until the vehicle is again 'static'). This agency believes that its confirmation that the static test method is the proper method should relieve any realistic concerns regarding compliance of the 1996 model year vehicles GM tested, and probably of any future vehicles as well. The actual tests GM conducted in preparation for the meeting with NHTSA all showed static roll distances well within the requirements of Standard No. 114. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1863OpenMs. Mary Jo Apone, 23138 Demley Drive, Mt. Clemens, MI 48043; Ms. Mary Jo Apone 23138 Demley Drive Mt. Clemens MI 48043; Dear Ms. Apone: This is in response to your letter of March 21, 1975, commenting on th National Highway Traffic Safety Administration's (NHTSA) January 2, 1975, proposal to reduce the performance requirements of the Federal bumper standard.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost-beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal brought to light additional data. The NHTSA carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency concluded that the existing 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6.)(sic); I would like to point out that the bumper standard, as it currentl exists, has no direct effect on occupant safety in collisions. The safety benefits of the standard relate to the prevention of damage to safety-related components such as headlmaps (sic), fuel and cooling systems and exhaust systems. It is the after-crash dangers that would exist if a vehicle were driven with any of the specified vehicle systems inoperative that the standard focuses on. Therefore, a reduction in the performance requirements would not expose occupants to greater hazards during a collision itself.; We appreciate your interest. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0771OpenMr. Keitaro Nakajima, Director/General Manager, Toyota Motor Sales, U.S.A., Inc., Factory Representative Office, Lyndhurst Office Park, 1099 Wall Street, West, Lyndhurst, NJ, 07071; Mr. Keitaro Nakajima Director/General Manager Toyota Motor Sales U.S.A. Inc. Factory Representative Office Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of June 19, 1972, concerning th application of Standard No. 302, 'Flammability of Interior Materials,' to a pocket which is attached to a front seat back. You ask whether, under S4.2 of the standard, the upper portion of the sample will be tested as an assembly, as this is the manner in which it appears in the vehicle. The upper portion of the sample consists of one material folded over itself, with an adhesion process joining the folded segments at points approximately 3/4 inch apart, across the length of the material. An elastic band is inserted in the fold of the material. The configuration is actually representative of two materials, therefore, with an elastic between them.; Paragraph S4.2 of the standard provides that surface materials i assemblies such as this are tested separately, unless bonded, sewed, or mechanically attached to underlying material (S4.2(a)). The reference to 'bonded, sewed, or mechanically attached' is intended to refer to materials joined uniformly by these methods, at their adjoining surfaces. The adhesion process you have used does not join the materials in this fashion, as there is a significant amount of area where the materials are not joined at all. Consequently, we would not test the assembly in the manner in which it appears in the vehicle, but would treat the material as separate material.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5089OpenMrs. M. Frances Parton 5788 Cypress Cr. Tallahassee, FL 32303; Mrs. M. Frances Parton 5788 Cypress Cr. Tallahassee FL 32303; "Dear Mrs. Parton: This responds to your letter of October 7, 1992 requesting information on whether a 1992 van can be modified by installing swivel bases on the seats so that you can transfer from the seat to a wheelchair. It is unclear from your letter whether the seat you want modified is a front or a rear seat. As explained below, there is no federal requirement that expressly prohibits installing a swivel base on a seat, provided that the seats and belts continue to comply with the applicable safety standards. Some background information on Federal motor vehicle safety laws and regulations may be helpful. Section 103 of the National Traffic and Motor Vehicle Safety Act (the Safety Act, 15 U.S.C. 1392) authorizes NHTSA to issue Federal Motor Vehicle Safety Standards for new motor vehicles and new items of motor vehicle equipment. Manufacturers are required to certify that their products meet all applicable safety standards. Any manufacturer, distributor, dealer, or repair business that modifies a van for you along the lines described in your letter after you have purchased the van would be subject to the requirement of the Safety Act (at 15 U.S.C. 1397(a)(2)(A)) that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard. Since the seats and their safety belts are devices or elements of design installed in the van in compliance with applicable safety standards, this section prohibits any of the named commercial entities from making any modification or repair to the seats and/or their accompanying safety belts if such modification or repair would cause the vehicle no longer to comply with an applicable safety standard. Adding a swivel base to a seat, and presumably moving the seat belts for the seat, could affect compliance with four safety standards: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, and Standard No. 210, Seat Belt Assembly Anchorages. Standard No. 207 establishes strength and other performance requirements for vehicle seats. Standard No. 208 sets forth requirements for occupant protection at the various seating positions in vehicles. Based upon the information in your letter, it appears that the vehicle you wish to have modified would be classified as a multipurpose passenger vehicle (MPV) for purposes of NHTSA's regulations. Standard No. 208 requires an MPV to provide occupant crash protection to belted front seat occupants when the vehicle is crash tested at 30 miles per hour (mph) into a concrete barrier. Standard No. 208 also requires an MPV to have a lap/shoulder belt at every rear outboard seating position, and either a lap belt or a lap/shoulder belt at every other rear seating position. Standard No. 209 sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. Standard No. 210 establishes strength and location requirements for seat belt anchorages. As you can see, with the exception discussed below, there is nothing in Federal law that prohibits persons from adding a swivel base to a seat. Instead, Federal law requires that modifications to a van that include adding a swivel base to a seat be done in such a way that the seats and safety belts continue to provide the safety protection mandated by the safety standards. With respect to Standard No. 208's requirements for front seats, NHTSA has recently received a number of phone calls and letters, from van converters and individuals, suggesting that the crash testing requirement for front seats in MPVs will, in effect, prohibit van converters from modifying vehicles to accommodate the special needs of persons in wheelchairs. The agency has also received a petition from the Recreation Vehicle Industry Association (RVIA) requesting an amendment to the light truck and van crash test requirement 'to eliminate requirements that inadvertently discriminate against individuals with disabilities including individuals who use wheelchairs.' On January 9, 1992, the agency granted the RVIA petition. On August 5, 1992, the agency issued a notice of proposed rulemaking (NPRM) to amend the requirements of Standard No. 208 to give manufacturers of certain light trucks and vans the option of installing non-dynamically tested manual safety belts instead of complying with the dynamic testing requirements. However, the agency is aware that you and others who need to purchase a new vehicle need more immediate relief than a rulemaking can offer. Therefore, as explained in the NPRM, the agency has stated that it will not conduct any dynamic testing under Standard No. 208 of vehicles modified for operation by persons with disabilities while this rulemaking is pending. If you need to have the swivel base added to a front seat, this should allow you to find a converter to make this modification while this decision is pending. 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"; |
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ID: aiam2259OpenMr. L. Frank Hay, President, Beachcomber Industries Ltd., P.O. Box 1660, North Railway Avenue, Morden, Manitoba R0G 1J0; Mr. L. Frank Hay President Beachcomber Industries Ltd. P.O. Box 1660 North Railway Avenue Morden Manitoba R0G 1J0; Dear Mr. Hay: This is in response to your December 31, 1975, letter concernin certification of the travel trailer that you manufacture.; This Department does not certify or otherwise issue advance approval of motor vehicles or motor vehicle equipment. Certification, under applicable law and regulations, must be done by the manufacturer. The Canadian and U.S. motor vehicle safety standards are not identical, so you must ensure that your travel trailers do in fact comply with all of the latter that are applicable. A pamphlet summarizing the U.S. Federal motor vehicle safety standards is enclosed, along with a copy of the regulations governing vehicle certification. The safety standards themselves are set forth in their entirety in Part 571 of Title 49 of the Code of Federal Regulations.; Please note that Section 110(e) of the National Traffic and Moto Vehicle Safety Act (15 U.S.C. S 1399(e)) requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United States to designate a permanent resident of the United States as his agent, upon whom service of all processes, orders, notices, decisions, and requirements may be made. Our records indicate that Beachcomber Industries Ltd. has not complied with this requirement.; The procedural regulations (49 CFR 551.45) for designation of agen pursuant to the Act require:; >>>(1) A certification by its maker that the designation is binding o Beachcomber Industries Ltd. under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made,; (2) The full legal name, principal place of business and mailin address of Beachcomber Industries Ltd.,; (3) Trade names or other designations of origin of the products o Beachcomber Industries Ltd. that do not bear its legal name,; (4) A provision that the designation remain in effect until withdraw or replaced by Beachcomber Industries Ltd.,; (5) A declaration of acceptance duly signed by the agent appointed which may be an individual, a firm, or a U.S. corporation, and; (6) The full legal name and address of the designated agent.<<< In addition, the designation must be signed by one with authority t appoint the agent, the signer's name and title should be clearly indicated beneath his signature.; Please note further that you are required by 49 CFR Part 566 *Manufacturer Identification*, to submit certain information to the NHTSA not more than 30 days after your vehicles begin to be imported into the United States. Copies of this regulation and the procedural regulations for designation of agent are also enclosed for your convenience.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0264OpenMr. John J. Trotsky, President, Juno Industries, Inc., Cassopolis Road, Cassopolis, MI 49031; Mr. John J. Trotsky President Juno Industries Inc. Cassopolis Road Cassopolis MI 49031; Dear Mr. Trotsky: Your letter of August 26, 1970, concerning the compliance of you cut-van motor home with Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components has been forwarded to this office for reply.; You state that the door in the camper body is located so that n portion of a manikin in any designated seating position would project into the door opening in the side view. If, as it appears, you are correct, the door locks and door retention components on that door are not required to comply with Standard No. 206.; You also state that you believe that the doors on the cab comply wit Standard No. 206. As a manufacturer of multipurpose passenger vehicles, you are responsible under the National Traffic and Motor Vehicle Safety Act of 1966 for the compliance of the cab doors with Standard No. 206. Although the van may have been manufactured as a truck, it must, when subsequently converted to a multipurpose passenger vehicle, comply with all multipurpose passenger vehicle standards in effect on the date of manufacture of your motor home. Therefore, you should ascertain, either from the van manufacturer or by your own tests, that the cab doors comply with Standard No. 206.; Please let us know if we can be of further assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5066OpenMr. Spencer A. Darby Vice President, Engineering Sate-lite Manufacturing. Co. 6230 Gross Point Road Niles, IL 60648; Mr. Spencer A. Darby Vice President Engineering Sate-lite Manufacturing. Co. 6230 Gross Point Road Niles IL 60648; "Dear Mr. Darby: This responds to your inquiry about whether a warnin device would comply with Federal Motor Vehicle Safety Standard No. 125, Warning devices (49 CFR 571.125). You were specifically concerned about the implications of adding a battery operated flashing light to a warning device that otherwise complies with the Standard. You stated that placing flashing lights between the reflex reflectors would enhance the device's conspicuity at night. I am pleased to have this opportunity to explain our requirements to you. By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the 'Safety Act') gives the National Highway Traffic Safety Administration (NHTSA) the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 125. The Safety Act provides that no person shall 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any new motor vehicle or new item of motor vehicle equipment unless the vehicle or item of equipment complies with the applicable standard. (See 15 U.S.C 1397(a)(1)(A).) NHTSA has no authority under the Safety Act to approve, certify, or otherwise endorse any commercial product. Instead, the Safety Act establishes a self-certification process under which each manufacturer is required to certify that each of its products meets all applicable Federal Motor Vehicle Safety Standard. (See 15 U.S.C. 1403.) I am enclosing a general information sheet explaining NHTSA's regulations. As your letter states, Standard No. 125 applies to 'devices, without self- contained energy sources, that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.' (emphasis added, see section S3) In other words, Standard No. 125 does not apply to warning devices with self-contained energy sources. In previous interpretations, the agency has determined that the phrase 'self-contained energy sources' includes such things as battery powered lights. Accordingly, a warning device to which a battery operated flashing light was added would not be subject to Standard No. 125. You also asked whether a vehicle required to have three '125 warning triangles' would be required to have three non-lighted complying triangles set out as well. Please be aware that NHTSA does not regulate the use of warning devices. I am forwarding your letter to the Federal Highway Administration (FHWA) which is authorized to regulate some motor vehicle operators and vehicle operations. 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, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam1926OpenHonorable Nelson A. Rockefeller, President of the Senate, Washington, DC 20510; Honorable Nelson A. Rockefeller President of the Senate Washington DC 20510; Dear Mr. President: The purpose of this letter is to inform the Committees on Commerce an on Public Works of recent activities and decisions of the National Highway Traffic Safety Administration relating to the establishment of a Uniform Tire Quality Grading Standard (UTQGS). We are pleased to announce that this standard, required by section 203 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1423), was promulgated on May 20, 1975 (copy enclosed). The rule provides for grading tires in three areas: treadwear, traction, and temperature performance. I believe it will provide the consumer with the information he needs to determine which tire is the best value for him, considering his needs and driving habits.; As I am sure you are aware, we have had our share of problems i developing this rule. It had been our original intention to utilize a control tire against which other tires would be compared. In May of 1974, due to technical problems and time constraints imposed by the court in *Nash* v. *Brinegar*, Civil Action No. 17, D.C. (1974), the decision was made to attempt to utilize a control surface rather than a control tire. In order to investigate the feasibility of this approach, a section of runway at Goodfellow AFB, in San Angelo, Texas, was repaved, to provide a research control surface. At the outset of the research project the question had been raised regarding the applicability of section 301 of the National Traffic and Motor Vehicle Safety Act of 1966 (which provides for specific approval by the above mentioned Committees of the Senate and their counterparts in the House, before constructing facilities for testing in traffic safety) to the construction of the control surfaces. It was then determined that since the action was a short-term effort, and in the nature of a feasibility study, section 301 was not applicable. This research project was successful and forms the basis of the rule.; We have recently obligated a sum of $75,000, in addition to th approximately $750,000 expended for the earlier research project (including $165,000 for the control surface), for the purpose of altering the control surfaces and nearby roadway to enable manufacturers to use these surfaces to meet the requirements of complying with the rule.; Even though the associated conversion costs were less than $100,000, w recognized that alterations to the surfaces in late FY 1976 and FY 1977 will cause total expenditures to rise above that level. Therefore, prior to proceeding with the recent site conversion effort, we focused again on the issue of the applicability of section 301. We determined that the section is inapplicable because the purpose of the control surface is to facilitate testing in a matter which is first and foremost consumer information rather than traffic safety, for, as stated in section 203 of the Act, UTQGS is established 'in order to assist the consumer to make an informed choice in the purchase of motor vehicle tires . . . .'; We will continue to keep you posted on the progress of the UTQGS a manufacturers begin testing. We expect to be able to provide the consumer with information in the near future which will enable him to make the best use of his tire dollars.; Sincerely, James B. Gregory, Administrator |
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ID: aiam2609OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, N.W., Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue N.W. Washington DC 20015; Dear Mr. Crampton: This responds to your April 6, 1977, letter asking whether two propose labels satisfy the requirements for certification and information labels found in 49 CFR Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with NHTSA regulations. From the illustrations you present, it appears that you have closely followed the format suggested in our regulations, and therefore, the labels seem to comply with the agency's requirements. Section S5.3(b) of Standard No. 120 permits the use of both labels when affixed in accordance with Part 567.4(b)- (f).; Sincerely, Joseph J. Levin, Jr., 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.