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: aiam4204OpenMr. T. E. McConnell, Prince Lionheart, 2301 Cape Cod Way, Santa Ana, CA 92703; Mr. T. E. McConnell Prince Lionheart 2301 Cape Cod Way Santa Ana CA 92703; Dear Mr. McConnell: Thank you for your letter of July 31, 1986, inquiring about the Federa safety standards that apply to roll-up window shades designed to be attached to a vehicle's window by suction cups. The following discussion explains how our safety standards apply to your products.; Some background information on how Federal motor vehicle safety law and regulations affect your product may be helpful. Our agency is authorized, under the National Traffic and Motor Vehicle Safety Act, to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead the Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates other alleged safety-related defects. As explained below, installation of products in new and used vehicles would be affected by our regulations. In addition, any manufacturer of motor vehicle equipment is subject to the requirements of the Vehicle Safety Act concerning the recall and remedy of products with noncompliances or defects related to motor vehicle safety.; We have issued Federal Motor Vehicle Safety Standard No. 205, *Glazin Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; No manufacturer or dealer is permitted to install solar films and othe sun screen devices, such as the ones described in your letter, in *new* vehicles without certifying that the vehicle continues to be in compliance with the light transmittance and other requirements of the standard.; After a vehicle is first sold to a consumer, modifications to a vehicl are affected by section 108(a)(2)(A) of the Vehicle Safety Act. That section prohibits commercial businesses from tampering with safety equipment installed on a vehicle in compliance with our standards. Thus, no dealer, manufacturer, repair business or distributor can install a sun screen device for the owner of the vehicle, if the device would cause the window not to meet the requirements of Standard No. 205. Violation of the 'render inoperative' provision can result in Federal civil penalties of up to $1,000 for each violation.; Section 108(a)(2)(A) does not affect vehicle owners, who may themselve alter their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, the owner may install sun screening devices regardless of whether the installation adversely affects the light transmittance. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from using sun screens in their vehicles.; I am returning, under separate cover, the two samples you provided th agency. If you need further information, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0247OpenMr. Philip N. Shrake, Recreational Vehicle Institute, Inc., 2720 Des Plaines Avenue, Des Plaines, IL 60018; Mr. Philip N. Shrake Recreational Vehicle Institute Inc. 2720 Des Plaines Avenue Des Plaines IL 60018; Dear Mr. Shrake: This is in response to your letter of July 23, 1970, in which you aske for the Bureau's interpretation of the phrase, 'designated seating position that includes the windshield header within the head impact area.'; The phrases 'designated seating position' and 'head impact area' ar both defined in the general Definitions section of the standards, 49 CFR 571.3. The remaining substantive phrase, 'windshield header,' is not defined in the standards. It is intended to refer to the portion of the interior of the vehicle immediately above the top of the windshield, usually but not necessarily a strip a molding separating the glass from the interior roof.; Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs; |
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ID: aiam5045OpenMr. Leonard Marks 211 East Grand Avenue Old Orchard Beach, ME 04064; Mr. Leonard Marks 211 East Grand Avenue Old Orchard Beach ME 04064; "Dear Mr. Marks: This responds to your letter asking how the laws an regulations administered by this agency would apply to a device you intend to market. According to your letter, this device is 'a new adjustable attachment to seat belts which allows the user to lower the level so that it will no longer cut them in the neck and yet give them the safety of the belt.' I am pleased to provide the following information. It is not entirely clear how your proposed device would work. However, we have explained how our regulations apply to several different types of belt positioning devices. One such device is a 'comfort clip,' which is attached to the safety belt and can be positioned by an occupant to introduce and maintain slack in the belt system by physically preventing the belt slack from being taken in by the belt's retractor. We have explained how our regulations apply to comfort clips in a February 7, 1986 letter to Mr. Lewis Quetel (copy enclosed). Another device is one that clips the shoulder belt to the lap belt nearer the middle of the wearer's abdomen. We have explained how our regulations apply to these belt positioning devices in a February 11, 1988 letter to Mr. Roderick Boutin (copy enclosed). Yet another device is a covered foam pad that is fastened around the belt. We have explained how our regulations apply to these devices in a November 22, 1988 letter to Ms. Claire Haven (copy enclosed). Since your device would be considered 'motor vehicle equipment,' within the meaning of the National Traffic and Motor Vehicle Safety Act, I have also enclosed an information sheet for new manufacturers of motor vehicle equipment. This information sheet also explains how to get copies of our regulations. As you will see from reviewing the enclosed letters, aftermarket sales and installation by individual vehicle owners of devices to reposition belts are not prohibited by any Federal statutory or regulatory requirements. Nevertheless, the use of such devices could raise serious safety concerns if the devices inadvertently reduce the safety protection afforded by the original equipment safety belts. I hope this information is helpful. If you have any further questions or need some additional information, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam2780OpenR. L. Ratz, P.E., Product Safety Engineering, Grumman Flxible Corporation, 970 Pittsburgh Drive, Delaware, OH 43015; R. L. Ratz P.E. Product Safety Engineering Grumman Flxible Corporation 970 Pittsburgh Drive Delaware OH 43015; Dear Mr. Ratz: This responds to your recent letter asking whether Safety Standard No 209, *Seat Belt Assemblies*, and Safety Standard No. 210, *Seat Belt Anchorages*, would be applicable to a Type I seat belt assembly used as a securement device for wheelchairs in an urban transit bus.; Safety Standard No. 209 is an equipment standard that is applicable t any seat belt manufactured for use on passenger cars, multipurpose passenger vehicles, trucks or buses. Therefore, the seat belt in question would have to comply with the performance requirements of that standard.; Safety Standard No. 210, however, only specifies requirements for sea belt anchorages at the driver's position on buses. Since the assembly you are concerned with would be at a passenger seating position in the bus, it would not have to comply with the anchorage requirements of Standard No. 210.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3892OpenThe Honorable Dave Durenberger, United States Senate, Washington, DC 20510; The Honorable Dave Durenberger United States Senate Washington DC 20510; Dear Senator Durenberger: Thank you for your recent letter on behalf of your constituent, Mr Pius J. Lacher, the Superintendent of Schools in Mora, Minnesota. Your letter has been referred to my office for reply.; As I understand Mr. Lacher's letter, the Mora public schools would lik to use 12 and 15 passenger vans to transport children to and from extra- curricular activities. Mr. Lacher believes that he is restricted by our Federal regulations to using only large, 72-passenger buses for this purposes. He urges a change in the regulations.; I appreciate this opportunity to clarify our regulations. In thi letter, I would like to explain how our regulations might affect Mora's choice of buses. Before I begin, let me explain that our regulations define a 'bus' as a motor vehicle designed to carry 10 or more passengers. Our regulations require manufacturers and dealers to certify that new buses comply with all applicable motor vehicle safety standards, including our school bus safety standards, when these vehicles are sold to schools.; Our agency has two sets of regulations, issued under different Acts o Congress, that could affect Mora's choice of buses. The first of these, the motor vehicle safety standards issued by our agency under the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563, 15 U.S.C. 1381-1426) apply to the manufacture and sale of new motor vehicles. In a 1974 amendment to the Act, Congress expressly directed us to issue standards on specific aspects of school bus safety, including emergency exits, seating systems, windows and windshields, and bus structure. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. If Mora plans to buy a *new* bus for use as an activity bus, the manufacturer and dealer must certify that the bus complies with the motor vehicle safety standards applicable to school buses. New conventional 12 or 15 passenger vans that are not manufactured to comply with these standards could not be sold for use as school buses.; The Vehicle Safety Act does not prohibit Mora from using vehicles tha carry more than 10 persons. There might, however, be impediments under Minnesota State law. We administer a set of guidelines for state highway safety programs under the authority of the Highway Safety Act (Public Law 89-564, 23 U.S.C. 401-408). These guidelines, called Highway Safety Programs Standards, cover a wide range of subjects, including school buses. Individual states have chosen to adopt some or all of the guidelines as their own policies governing their highway safety program. Highway Safety Program Standard No. 17 (HSPS 17), specifies that a bus used to transport 16 or less students must either be identified with the words 'School Bus' and comply with the standard's requirements for color, mirrors and signal lamps, or be devoid of all of these characteristics. As it happens, however, a bus sold for use as a school bus is required by the Vehicle Safety Act to have warning lights and mirrors (as well as many other safety features). Because it must have this equipment, a 12 or 15 passenger bus in a State whose law fully incorporates HSPS 17 would have to be painted and signed as a school bus. For a state that has adopted this standard as its own policy, these specifications apply to activity buses as well as to the buses used for daily transportation.; I want to stress that HSPS 17 will affect Mora only if Minnesota ha adopted it and if Minnesota accepts our view that the specifications apply to activity buses. If Minnesota chooses to exempt activity buses from being painted, signed, and equipped as school buses, we might disagree with the wisdom of its decision but we would not insist on compliance with HSPS 17 to the extent of taking action against the State. Congress has given us discretion under the Highway Safety Act not to insist that a State comply with every requirement of the highway safety standards. While we have stressed the importance of a strong pupil transportation program, consistent with HSPS 17, we have not insisted that the States comply with every feature of the standard.; Having said this, however, I would like to restate the importance tha our agency attaches to the use of safe buses to transport children. It remains the agency's position that a yellow school bus meeting the motor vehicle safety standards is the safest means of transportation for school children. In the years since buses began to be manufactured with these safety features, there has been a marked improvement in school bus safety. Mora should consider these safety features when the school district decides to buy their school vehicles. Please let me know if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0617OpenMr. Jack Gardner, President, Artcraft - Milwaukee, Inc., 117 West Pittsburgh Avenue, Milwaukee, WI, 53204; Mr. Jack Gardner President Artcraft - Milwaukee Inc. 117 West Pittsburgh Avenue Milwaukee WI 53204; Dear Mr. Gardner: This is in reply to your letter of February 25, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to replacement bus seat covers.; Standard No. 302 does not apply to aftermarket or replacemen materials. It applies only to new vehicles manufactured after September 1, 1972, as of the time of their manufacture, and does not apply to replacement materials used in those vehicles.; We trust this clarifies the situation for you. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3938OpenMr. Gerald A. Lakas, Custom Window Tinting Services, 5016-A 46th Avenue, Hyattsville, MD 20781; Mr. Gerald A. Lakas Custom Window Tinting Services 5016-A 46th Avenue Hyattsville MD 20781; Dear Mr. Lakas: Thank you for your letter concerning our regulations that affec tinting businesses, such as yours. I hope that the following discussion will clarify our regulations and answer the questions you raised.; Please note that in all the correspondence the agency has had with you your attorney, and others concerning your business, we have never stated that it is illegal to add all tinting to the glazing of a motor vehicle. We have stated, however, that it is illegal to add some types and levels of tinting. Let me explain further the effect our regulations on tinting.; *Federal Law* The National Traffic and Motor Vehicle Safety Act authorizes our agenc to issue Federal Motor Vehicle Safety Standards that apply to new motor vehicles and items of motor vehicle equipment. In 1967, the agency issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, which sets performance requirements for glazing materials used in new motor vehicles and glazing materials sold as items of replacement equipment. (A copy of that standard and the American National Standards Institute's code incorporated by reference in our standard has been previously provided to you.); The performance requirements of the standard include ones regulatin the light transmittance and abrasion resistance of glazing. A manufacturer of new vehicles must certify that the glazing in windows requisite for driving visibility, whether clear or tinted, conforms with the light transmittance and other requirements of the standard. Likewise, if a dealer or other person places tinting film on glazing in a new vehicle prior to the sale of the vehicle, that person must certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Thus, for example, the light transmittance through the combination of tinting film and the glazing must be at least 70 percent in the case of glazing used in windows requisite for driving visibility. Similarly, the combination must also meet the abrasion resistance and other requirements of the standard.; In 1974, Congress amended the National Traffic and Motor Vehicle Safet Act to address the problems of persons tampering with safety equipment installed on a motor vehicle after its first sale. The 1974 amendments added section 108(a)(2)(A) to the Act. That section provides, in part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . .<<<; Thus no manufacturer, distributor, dealer, or motor vehicle repai business may add tinting to the glazing materials of a motor vehicle, if that tinting would render inoperative the glazing's compliance with Standard No. 205. Again, section 108(a)(2)(A) does not prohibit tinting, it merely limits the use of tinting. The agency has consistently attempted to explain our interpretation of section 108(a)(2)(A) in letters to vehicle, glazing, and tinting manufacturers, state governments, and individual tinting shops. You indicated that we need to do a better job of conveying our interpretation to all affected persons. We will look at ways to accomplish that goal.; Section 108(a)(2)(A) does not establish any limitations on a individual vehicle owner's ability to alter his or her own vehicle. Under Federal law, individual vehicle owners can themselves install any tinting they want on their vehicles, regardless of whether that tinting would render inoperative the compliance of the vehicle's glazing with the performance requirements of Standard No. 205. The agency, of course, urges individual owners not to install dark tinting on their vehicles.; *State Law* Although the agency does not have the authority to regulate the action of individual vehicle owners, States do have such authority. The agency is aware that a number of States have adopted laws which address the tinting of motor vehicles. Let me emphasize that State laws which are inconsistent with these Federal requirements are preempted. Any State law or regulation which would permit any person to install tinting material on a new vehicle in violation of Standard No. 205 is preempted under section 103(d) of the Vehicle Safety Act. for example, a State law which specifies a transmittance level less than 70 percent for windows requisite for driving visibility in new vehicles would be preempted. The adoption or retention of such a law would have no effect on the illegality of that installation under Federal law. Further, any State law or regulation that would permit manufacturers, distributors, dealers or motor vehicle repair businesses to install tinting materials on a vehicle after its first sale in violation of section 108(a)(2)(A) of the Vehicle Safety Act is also preempted.; *Requirements for Different Vehicles* You asked for an explanation of why there is a difference between th visibility requirements set for passenger cars and other motor vehicles. The agency has generally applied more stringent safety requirements for passenger cars, the most prevalent type of vehicle on the road, and has subsequently applied the same or similar requirements to other vehicle types.; In the case of the glazing requirements, the agency has considered al the windows in a passenger car requisite for driving visibility. The agency has applied different requirements to other vehicles such as vans, because of traditional differences in their construction and use. Many vans are constructed without any windows to the rear of the driver. In addition, the space behind the driver in vans is frequently used to haul objects which prevent an interior view to the rear of the vehicle. Because of this situation, the agency has required trucks, buses and van-type vehicles to have dual outside mirrors to ensure that the driver will have a view to the rear of the vehicle.; *VESC Guidelines* You also asked about the guidelines adopted by the Vehicle Equipmen Safety Commission (VESC). In 1958, Congress authorized the creation of VESC for the purpose of encouraging State cooperation in the establishment and carrying out of traffic safety programs. VESC, however, had no authority to adopt regulatory standards that would directly affect individuals, manufacturers, dealers, distributors, or motor vehicle repair businesses. Although VESC could recommend guidelines, those guidelines would have to be adopted by the States to have the force of law. VESC ceased operations in January 1984. In 1980, VESC adopted a guideline, designated as VESC-20, on the tinting of glazing on used vehicles. Several of the provisions in VESC-20 conflict with the requirements of Standard No. 205. As discussed above, the adoption of VESC-20 by a State would govern the use of tinting by an individual vehicle owner. However, that State law would not affect the use of tinting by manufacturers, distributors, dealers, and motor vehicle repair businesses, whose conduct would still be affected by our regulations.; You asked about Maryland's adoption of a regulation based, in part, o VESC-20. Since VESC- 20 is merely a guideline, Maryland is free to choose the portions of VESC-20 it wishes to adopt, but those portions conflicting with Standard No. 205 are subject to Federal preemption.; *AAMVA Approval* You asked about the effect of a 'notice of equipment compliance' issue to tinting manufacturers by the American Association of Motor Vehicle Administrators (AAMVA), which apparently is a certification by the AAMVA that the material complies with VESC-20. Our regulations do not require a manufacturer of tinting materials to obtain a notice of equipment compliance from AAMVA. Individual States may have adopted regulations which require tinting manufacturers to obtain such notices.; Whether a manufacturer has an AAMVA notice or its tinting material ha been approved by a State has no effect on our regulations. As explained above, if a manufacturer, dealer, distributor, or motor vehicle repair business install tinting film which would render inoperative the glazing materials compliance with Standard No. 205, there would be a violation of section 108(a)(2)(A) of the Vehicle Safety Act.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam1905OpenMr. Steven W. Tarta, 274 LaFayette Avenue, Hawthorne, NJ 07506; Mr. Steven W. Tarta 274 LaFayette Avenue Hawthorne NJ 07506; Dear Mr. Tarta: This is in response to your letter of April 5, 1975, asking whethe your client is an 'alterer, intermediate manufacturer, or final manufacturer or all of the aforesaid.' You described several different types of operations your client performs.; Several distinctions must be drawn to answer the questions you hav asked. These are set forth in Parts 567 and 568 of Title 49 of the Code of Federal Regulations.; 1. An alterer differs from an intermediate manufacturer or a final stage manufacturer in that the alterer does his work on a completed, previously certified vehicle, while the other two categories work on incomplete vehicles. ('Incomplete vehicle' is defined in Part 568.); 2. An intermediate manufacturer differs from a final-stage manufacture in that the former does not complete the vehicle, while the latter does, and certifies it. An intermediate manufacturer typically adds axles, lengthens or reinforces frames, and/or extends air brake lines as necessary in conjunction with these operations. The final-stage manufacturer typically builds a body and mounts it on a chassis-cab, chassis- cowl, or bare chassis to make a truck, bus, or motor home. He also might add a fifth wheel to a chassis-cab to make a truck tractor.; 3. Repair and refinishing of existing bodies (*i.e.*, those already i use) normally do not bring a person into our regulatory scheme at all, since it generally applies to the manufacture of new vehicles. Under the 1974 Amendments to the Vehicle Safety Act, however, the rendering inoperative of devices or elements of design installed in conformity with a safety standard, even on a used vehicle, is prohibited.; 4. With respect to 'transferring bodies to and from new and use vehicles,' our interpretive rule generally has been that the chassis determines whether a vehicle is new or used. Thus, an old body put onto a new chassis constitutes a new vehicle for purposes of the standards and associated regulations (including certification), while a new body put onto a used chassis is considered a used vehicle (made at the time the chassis was completed).; 5. Alterers, intermediate manufacturers, and final-stage manufacturer share the characteristic of doing work that is more than the installation of readily attachable components or minor finishing operations, or work that alters the weight ratings of the vehicles. Other persons who do more minor operations (possibly 'installing grill guards' on your list would fit this description) are outside the direct regulatory scheme. Of course, any vehicle must end up certified by someone, and any manufacturers, dealers, distributors, or repair businesses (probably anyone except the owner, in practice) are under the ban against rendering mandated safety equipment inoperative.; With these distinctions in mind, you should be able to determine th application of the standards and regulations to your client. If after studying this and the regulations you still need help, please let me know.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5415OpenMr. Scott R. Dennison Consultant Excalibur Automobile Corporation 1735 S. 106th Street Milwaukee, WI 53214; Mr. Scott R. Dennison Consultant Excalibur Automobile Corporation 1735 S. 106th Street Milwaukee WI 53214; "Dear Mr. Dennison: We have received your letter of May 31, 1994 petitioning for a temporary exemption from paragraph S4.1.4 of Standard No. 208 on behalf of Excalibur Automobile Corporation (the Federal Express Airbill indicates that it was mailed July 9, 1994). The petition does not, as required by 49 CFR 555.5(b)(7), set forth the reasons why an exemption would be in the public interest and consistent with the objectives of traffic safety. You make the statement that 'the door hinge system incorporated in the Excalibur Cobra has been tested to exceed the FMVSS by over four times the required strength.' Please provide a copy of the test report that demonstrates this performance. Under 555.6(d)(1)(iv), a petitioner is required to provide 'the results of any tests conducted on the vehicle demonstrating that its overall level of safety exceeds that which is achieved by conformity to the standards.' The second page of the petition references a 'Plymouth Sunbird' vehicle for model year 1994. We assume you mean Pontiac, as we are unaware of any Plymouth with this model name. The timing of your letter raises the inference that Excalibur may presently be manufacturing convertibles equipped with manual Type 2 seat belt assemblies. Please inform us as to the number of Cobras that the company may have produced on or after September 1, 1989, that were equipped with driver and passenger manual Type 2 seat belt assemblies. Finally, it has been customary for petitions to be signed by an officer of the manufacturer. We have accepted petitions signed by foreign manufacturers but submitted by a person resident in the United States, on the manufacturer's behalf. Your use of Excalibur's letterhead leads to an assumption that you have the authority to make the representations of the petition, but your title of 'Consultant' does not identify you as a corporate officer. We would appreciate an explanation of your relationship to Excalibur, or, alternatively, the signature of a corporate officer on the petition. We shall hold the petition in abeyance until we have heard further from you. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam4910OpenMr. Martin L. Marinoff 103 Turner Lane Hendersonville, NC 28739; Mr. Martin L. Marinoff 103 Turner Lane Hendersonville NC 28739; Dear Mr. Marinoff: This responds to your letter asking about Federa Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems. You stated that you believe the standard requires vehicles to have a warning light system that indicates loss of pressure or low fluid level in the braking system and asked if this belief is correct. Your understanding about Standard No. 105 is correct. I have enclosed a copy of that standard for your information. The requirements for brake system indicator lamps are set forth at section S5.3 of the standard. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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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.