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: aiam2976OpenMr. J. B. H. Knight, Chief Car Safety Engineer, Rolls-Royce Motors, Crewe Cheshire, CW1 3PL, England; Mr. J. B. H. Knight Chief Car Safety Engineer Rolls-Royce Motors Crewe Cheshire CW1 3PL England; Dear Mr. Knight:#This responds to your letters of July 11, 1978, an January 18, 1979, concerning Federal Motor Vehicle Safety Standard (FMVSS) 101-80, *Controls and Displays*. I regret the delay in responding to your inquiry. The answers to your questions are as follows:#1. The turn signal control lever used by Rolls-Royce is mounted on the steering column and is positioned horizontally. To operate the turn signals, the lever must rotated either clock-wise or anti-clock-wise. To label the control lever and to indicate the manner of operation, Rolls- Royce is considering placing the arrows of the turn signal symbol so that they point up and down. You ask whether the standard permits that orientation of the arrows.#The answer is no. Section 5.2.1 requires that the turn signal symbol appear perceptually upright to the driver. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle. Complying with the perceptually upright requirement instead of reorienting the symbol to serve other purposes will aid in ensuring quick and accurate identification of the turn signal control. We wish to observe that essentially the same result as that sought by RollsRoyce (sic) in reorienting the turn signal symbol could be achieved by placing curved, thinner arrows next to the symbol to indicate mode of operation.#2. (i) You noted that differing display identification requirements for safety belts appear in FMVSS 101-80 and FMVSS 208. FMVSS 101-80 does not supersede or preempt FMVSS 208 in this area. However, the agency will soon issue a notice that will provide for use of the safety belt symbol in Table 2 of FMVSS 101-80 for the purposes of both standards.#(ii) You are correct in assuming that column 3 of Table 2 should include a reference to FMVSS 105-75 for brake system malfunction displays and a reference to FMVSS 121 for brake air pressure displays. These inadvertent omissions will be corrected in the notice mentioned above. You are also correct in assuming that the options in section 5.3.5 of FMVSS 105-75 are still available.#3. You referred to the statement in the final rule preamble that the visibility requirements of 101- 80 would be deemed satisfied even if minimal movements by the driver were necessary and suggested that this interpretation be incorporated in section 6, conditions, and amplified. The agency does not believe that this step is necessary. The agency does, however, believe it appropriate to amplify its earlier interpretation. By minimal movement, the agency meant head movement of not more than a few inches. By a 'few' inches, we mean up to approximately three inches. As to your suggestion for specifying the size of the driver to be used in determining compliance with the visibility requirements, the agency will consider this suggestion and address it at a future date.#4. You should comply with the speedometer scale requirements in FMVSS 101-80 since the labelling requirements in FMVSS 127 were deleted in the response to reconsideration petitions that was published July 27, 1978 (43 FR 32421).#Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam3664OpenMr. Anton (Tony) Ostermeier, 19240 S. Vermont Avenue, Gardena, CA 90248; Mr. Anton (Tony) Ostermeier 19240 S. Vermont Avenue Gardena CA 90248; Dear Mr. Ostermeier: Thank you for your letter of February 4, 1983, supplying the furthe information we requested on January 28.; The 1955 Mercedes replica which you contemplate building is a hybrid o new and old parts. The body is of your construction and consists of new parts. You fabricate the chassis using new tubing, however, its front cross member may be either a new replacement Mustang part (1974-1978 models) or one actually taken from a vehicle in use. Similarly, the front suspension, differential and rear suspension, and transmissions may be new replacement parts or taken from vehicles in use. You will employ used rear wheel cylinders in the braking system and used engines (either a 1964 Chrysler Slant 6 or a 1969 Chevrolet V-8). Any equipment that has previously been used will be rebuilt to the manufacturer's specifications, and new parts will be incorporated where necessary.; As a general rule, the agency has no requirements for 'used' vehicles Whether a vehicle is treated as new or used depends on the origin of its parts. For example, we regard an assemblage consisting of a new body on the chassis of a vehicle previously registered for use on the public roads as a 'used' motor vehicle and therefore not subject to the Federal motor vehicle standards. On the other hand, the agency will consider a truck newly manufactured when an old cab is replaced with a new one unless at least the engine, transmission, and drive axle of the assembled vehicle are not new and at least two of these components were taken from the same vehicle.; The vehicle you propose to manufacture is somewhat different fro either of these examples, but we have concluded that it is a 'new' motor vehicle and must comply with Federal motor vehicle safety standards applicable to new passenger cars. Not only do previously unused parts appear to predominate in your plans, but, in addition, the old parts that are used will be rebuilt with new parts where necessary, to the manufacturer's original specifications. With the exception of the 1964 engine, the rebuilt components were originally used in vehicles manufactured to meet the Federal motor vehicle safety standards and there appears no reason why your product may not also be manufactured to comply, even though it is a replica of a 1955 car.; Use of the 1964 engine could raise problems of compliance with Safet Standard No. 124, *Accelerator Control Systems*, and with Safety Standard No. 301, *Fuel System Integrity*. However, in that event, we believe that you (as a producer of less than 10,000 vehicles a year) would be eligible to apply for a temporary exemption from those standards, or any other standard where immediate compliance would cause you substantial economic hardship. I enclose an information sheet which tells you where you may obtain a copy of our regulations, including the standards and temporary exemption petition procedures.; If you have further questions, we would be happy to assist you. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1659OpenMr. Harold D. Shall, Legal Counsel, Dana Corporation, P.O. Box 1000, Toledo, OH 43697; Mr. Harold D. Shall Legal Counsel Dana Corporation P.O. Box 1000 Toledo OH 43697; Dear Mr. Shall: This responds to Dana Corporations's October 22, 1974, request for statement by the National Highway Traffic Safety Administration that Standard No. 121, *Air brake systems*, does not require antilock systems on the axles of air-braked trailers subject to the standard, and, if antilock systems are provided, that the standard does not specify the number or location of the speed sensing or logic components which constitute the system.; Standard No. 121 requires that wheels not lock-up under certai conditions (S5.3.1, S5.3.2) but it does not require the use of an antilock system to prevent wheel lockup. If a manufacturer chooses to install an antilock system on his vehicle, the standard requires that an anti-lock warning signal be installed (S5.1.6), that electrical failure of the antilock system not increase the actuation and release times of the service brakes (S5.5.1), and that an antilock system on a trailer be powered through the stop lamp circuit (S5.5.2).; There are no other requirements for antilock systems used on air-brak equipped vehicles subject to Standard No. 121. This means that the manufacturer may choose the number of wheel speed sensors and logic modules that he includes in his antilock system. It should be noted, however, that the 'controlled lock-up' exception of S5.3.1(a) and S5.3.2(a) would not apply to a wheel which is not equipped with a wheel sensor that contributes to the control of the reduction of air pressure.; If the number and location of these components becomes a safety proble in the future, the NHTSA would consider appropriate specifications for them.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4908OpenMr. Frank Kenney Sporting Tailors Manufacturing Co. 100 Cliff Road Weston, MA 02193; Mr. Frank Kenney Sporting Tailors Manufacturing Co. 100 Cliff Road Weston MA 02193; "Dear Mr. Kenney: This responds to your letter concerning th applicability of Federal motor vehicle safety standard No. 302, Flammability of Interior Materials, (49 CFR 571.302, copy enclosed) to your product, a roll bar top or 'Bikini Top' for use on vehicles such as Jeep Wranglers. You explained that the material would consist of three layers: a vinyl top layer, a flame retardant middle layer, and a brushed nylon tricot black backing as the lower layer. In addition, a binding fabric strip would be sewn around the edges of the roll bar top to lend stability and a finished appearance. You also explained that you may supply a tote bag in which the bikini top could be stored. Your questions are addressed below. By way of background information, the National Highway Traffic Safety Administration (NHTSA) has no authority to certify or approve motor vehicles or items of motor vehicle equipment for compliance with the Federal motor vehicle safety standards. Instead, the National Traffic and Motor Vehicle Safety Act (the Safety Act, 15 U.S.C. 1381 et seq.) establishes a 'self-certification' process under which each manufacturer is responsible for certifying that each of its products complies with all applicable safety standards. This agency periodically tests vehicles and items of motor vehicle equipment for compliance with the safety standards, and also investigates alleged defects related to motor vehicle safety. The Safety Act also gives this agency authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. The agency has exercised this authority to establish Standard No. 302. That standard sets forth flammability resistance requirements applicable to all new motor vehicles. If your bikini top is added to a new vehicle, i.e., before the vehicle is sold for the first time to a consumer, then it must comply with Standard No. 302. That standard applies to certain vehicle occupant compartment components, including convertible tops, on new motor vehicles. Your bikini top would be considered a convertible top. Persons selling new vehicles equipped with your convertible top would need to ensure that the vehicles, including your top, conform to Standard No. 302. Standard No. 302 does not directly apply to aftermarket items of motor vehicle equipment, i.e., accessories or additions to motor vehicles sold to owners of used vehicles. Nevertheless, section 108(a)(2)(A) of the Safety Act could affect the use of a product such as yours sold in the aftermarket. That section prohibits manufacturers, distributors, dealers, or repair shops from knowingly 'rendering inoperative' devices or elements of design that were installed in a motor vehicle to comply with the Federal motor vehicle safety standards. NHTSA does not consider it to be a violation of the 'render inoperative' prohibition when a dealer adds a convertible top which enables a vehicle to continue to meet Standard No. 302 and the other safety standards. The prohibitions of section 108(a)(2)(A) do not apply to the actions of a vehicle owner in adding to or otherwise modifying his or her vehicle. Thus, a vehicle owner would not violate the Safety Act by installing your bikini top, even if doing so would negatively affect the safety features of his or her vehicle. You should be aware that, as the manufacturer of an aftermarket item of motor vehicle equipment, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall and remedy of products with defects relating to motor vehicle safety. In the event that 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. I note that, whether or not Standard No. 302 applies to your convertible top, the product's flammability characteristics could be relevant to whether it contained a safety related defect. I will now address your specific questions about Standard No. 302, on the assumption that the standard applies to your product. After explaining your belief that the main part of the material complies with Standard No. 302, you asked whether the binding fabric strip sewn all around the edges of the roll would also have to be made flame retardant. As explained below, the binding fabric strip would have to comply with Standard No. 302. Under sections S4.l and S4.2, any portion of a convertible top which is within 1/2 inch of the occupant compartment air space must meet the standard's flammability requirements. It is our opinion that the binding fabric strip sewn around the edges of your convertible top would be part of the convertible top and thus subject to this provision. I note that it is the agency's longstanding interpretation that a component 'incorporated into' a component that is listed in section S4.1 of Standard No. 302 is subject to the standard. A June 29, 1990 interpretation to Mr. Ed McCarron (copy enclosed) explains this policy in the context of a mattress. In particular, that interpretation addressed whether a fabric 'corner reinforcement' that is stitched on the outside of the mattress cover was subject to Standard No. 302. In answering in the affirmative, the interpretation explained that the corner reinforcement is incorporated into the mattress cover through the stitching process. By analogy, your 'stitched binding strip' would be incorporated into your convertible top and thus subject to Standard No. 302. The interpretation letter to Mr. McCarron further explained the testing procedures related to composite materials. Any components that do not adhere to other materials at every point of contact would be tested separately under S4.2.1. Any components that adhere to other material at every point of contact would be tested as a composite with the other material. The sample enclosed with your letter indicates that the binding fabric strip does not adhere to the main part of the bikini top at every point of contact. Instead, the binding strip is folded over the edge of the main part of the bikini top and held in place by single stitching. Therefore, it would be tested separately from the main part of the bikini top. You also asked whether a tote bag used to store the roll bar top would be required to comply with Standard No. 302. The answer to that question is no. The list of components subject to Standard No. 302 set forth in S4.1 does not include a tote bag or similar item. Finally, you stated that you understand that you must conform to 49 CFR Part 566, Manufacturer Identification, and asked whether there would be anything else that would apply to your product. No NHTSA requirements other than those discussed above would apply to your product. I hope this information is helpful. If you have any further questions, 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: aiam0418OpenMr. A.J. Macho, Holan Company, 4100 W. 150th Street, Cleveland, OH 44135; Mr. A.J. Macho Holan Company 4100 W. 150th Street Cleveland OH 44135; Dear Mr. Macho: This is in reply to your letters of June 30 and August 2 on the subjec of the applicability of Standard No. 210 to multipurpose passenger vehicles, trucks, and buses as amended by notice of March 4, 1971 (36 F.R. 4291). The standard applies to these vehicles effective July 1, 1971, even though the heading published in the *Register* refers only to passenger cars. The application of the standard is controlled by the application section, S2, and not by the heading of the standard. The heading only reflects the substance of the application section and should automatically change whenever the application is changed. Through oversight, the *Federal Register* was given no instructions as to heading changes, and therefore inserted the old heading into the March 4 notice. Since the heading has no substantive role, and since the amendment is only in effect until the revised Standard No. 210 becomes effective January 1, 1972, we have not requested the *Federal Register* to alter the heading.; I hope this is responsive to your question. Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam2425OpenMr. Richard B. Ansell, Anschelewitz, Barr, Ansell & Bonello, 513 Bangs Avenue, Asbury Park, NJ 07712; Mr. Richard B. Ansell Anschelewitz Barr Ansell & Bonello 513 Bangs Avenue Asbury Park NJ 07712; Dear Mr. Ansell: This responds to your September 8, 1976, question whether the window of recreational vehicles' qualify as secondary means of egress' and what Federal requirements would apply to them if they do so qualify.; The only Federal requirement for the provision of emergency exits appl to buses (Standard No. 217, *Bus Window Retention and Release*, 49 CFR 571.217 (copy enclosed)). Bus' is defined by our regulations to mean a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons (49 CFR 571.3). Thus, Standard No. 217 would apply to the vehicle you describe if it is designed to carry more than 10 persons (including the driver) while the vehicle is in motion.; The standard does not use the term secondary means of egress' bu specifies a minimum area of unobstructed opening that may be provided by several means (*e.g.*, emergency door, push-out window').; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0048OpenMr. C. de Castelet, Assistant Director of Research and Development, Renault, Billancourt - Seine, Paris, France; Mr. C. de Castelet Assistant Director of Research and Development Renault Billancourt - Seine Paris France; Dear Mr. de Castelet: Thank you for your letter of December 1, 1967, concerning tests make o the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.; We recognize the validity of a system which takes advantage of th energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing an energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash situation. Therefor any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test as specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.; Your second point concerns the need for a more explicit definition o translational motion. SAE J944 states that the body-block *contracts* the wheel in translational motion. It does not say that this motion must continue after impacting the wheel Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a simulation of an actual crash restrained in translational motion *after* impact. Since the body motion in an actual crash situation will vary somewhat the Bureau feels that a more explicit definition of translational motion is unnecessary.; The third series of test as described in Report No. 207.397 using rigid test fixture and the free flying body-block are compatible with the SAE J944 test procedure.; Your interest in motor vehicle safety is appreciated. Sincerely, William Haddon, Jr., M.D., Director |
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ID: aiam2075OpenMrs. Helen Ginley, 8706 Orchard Avenue, Brooklyn, OH 44144; Mrs. Helen Ginley 8706 Orchard Avenue Brooklyn OH 44144; Dear Mrs. Ginley: This is in response to your letter asking whether the odomete disclosure statement which you enclosed has been properly completed.; 49 CFR Part 580, *Odometer Disclosure Requirements*, which wa promulgated by the National Highway Traffic Safety Administration (NHTSA) under the authority of section 408 of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513), prescribes the content and proper procedure for executing mileage disclosure statements at the time vehicles are transferred from one owner to another.; The form of the statement provided to you by Tommy Barrett, Inc appears in compliance with the provisions of Part 580. The person who completed the statement, however, failed to disclose the vehicle's last plate number. In order to meet the requirements of section 408 of the Cost Savings Act and Part 580, this information must be disclosed in writing to the vehicle purchaser. Although the transferor's address was not correctly filled in, the form has been stamped with what appears to be an appropriate address.; Failure to fulfill the requirements of the Cost Savings Act may subjec the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages, whichever is greater.; Since the license number may have been inadvertently omitted, I woul suggest that you contact Mr. Barrett and inform him of the deficiency in the statement he provided you. You will probably want him to add the information that is currently missing.; For your information, I have enclosed copies of the relevant portion of the Act and regulation.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4772OpenMr. David J. Blackwell Operations Manager Liquidus Limited 37A Shorncliffe Road Toronto, Ontario 48Z 5K2, Canada; Mr. David J. Blackwell Operations Manager Liquidus Limited 37A Shorncliffe Road Toronto Ontario 48Z 5K2 Canada; "Dear Mr. Blackwell: This is in response to your letter asking whethe a certain vehicle that you plan to export to the United States would be subject to the Federal Motor Vehicle Safety Standards. You state that Liquidus has 'designed a system' by customizing an existing road tanker for 'overhead' loading. The vehicle you plan to export would be used for 'aircraft de-icing storage' and 'loading of aircraft de-icing tarmac vehicles while in a fixed location.' The road tanker used in your system was originally built in Canada by a firm that has since gone out of business. I am pleased to have this opportunity to explain our statute and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) authorizes this agency to issue safety standards for new 'motor vehicles' and new items of 'motor vehicle equipment.' Accordingly, your vehicle is subject to the safety standards only if it is considered within the definition of 'motor vehicle' under the Safety Act. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as 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. We have interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Tractors and other agricultural equipment are also not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., certain airport runway vehicles and underground mining vehicles) are not considered motor vehicles, even though they may be operationally capable of highway travel. In addition, items of mobile construction equipment which use the highways only to move between job sites and which typically spend extended periods of time at a single job site are not considered motor vehicles. On the other hand, vehicles that use the public roads on a necessary and recurring basis are motor vehicles. For instance, utility vehicles like the Jeep are plainly motor vehicles, even though they are equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, NHTSA has treated it as a motor vehicle. Further, if a vehicle is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, NHTSA has treated the vehicle as a motor vehicle. This finding was made with respect to dune buggies, notwithstanding the manufacturers' statements that the vehicles were not intended to be used on the public roads. NHTSA has also stated in many prior interpretations that even vehicles that will regularly be used on the public roads will not be considered motor vehicles for the purposes of the Safety Act, if the vehicles have a maximum attainable speed of 20 miles per hour (mph) or less and have an abnormal configuration that readily distinguishes them from other vehicles on the road. We would apply these principles to the vehicle identified in your letter as follows. Your letter stated that this vehicle will be immobilized after it reaches the airport. Assuming this immobilization occurs, this vehicle would appear to be designed and sold solely for off-road use, just like certain other airport runway vehicles. In this case, it would not be a motor vehicle, even though it is operationally capable of highway travel before the immobilization. However, if the vehicle were not subsequently immobilized, and were moved from airport to airport with only a limited stay at any job site, this vehicle might be considered a 'motor vehicle.' This conclusion would be even more likely if a significant percentage of the vehicle's purchasers were to use the vehicle by moving it from airport to airport, notwithstanding your company's intent that the vehicles not be so used. This situation would be analogous to the classification of dune buggies. I hope that this information is helpful. If you have any additional questions, please contact John Rigby of this office by mail at the above address or by telephone at 202-366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1570OpenMr. James P. Coughlin, Vice President - Marketing, Bell Helmets Inc., 2850 East 29th Street, Long Beach, CA 90806; Mr. James P. Coughlin Vice President - Marketing Bell Helmets Inc. 2850 East 29th Street Long Beach CA 90806; Dear Mr. Coughlin: This is in reply to your letter of July 25, 1974, asking whether th statement 'Make no modifications' included in the labeling requirements of Standard 218, *Motorcycle Helmets*, would prohibit the after-market installation of a quick release device which may be attached to a helmet's retention strap. You included an illustration of such a device in your letter.; The answer is no. The statement does not restrict after-marke modifications by a first purchaser for purposes other than resale. It only serves to warn the consumer of the danger of making such modifications.; Yours truly, Richard B. Dyson, 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.