Interpretation ID: 1982-3.26
TYPE: INTERPRETATION-NHTSA
DATE: 11/30/82
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: CAPACITY OF TEXAS INC.
TITLE: FMVSS INTERPRETATION
TEXT:
Dear Mr. Wright:
This responds to your letter of October 11, 1982, concerning regulations specifying the type of steering system required in vehicles. In particular, you asked if a mechanical link is required in the steering system or whether a hydraulic system is acceptable. As explained below, a manufacturer can use either a mechanical or hydraulic system to meet the requirements of the applicable Federal Motor Vehicle Safety Standards.
There are two Federal Motor Vehicle Safety Standards that apply to vehicle steering systems: Standard No 203, Impact Protection for the Driver Steering Control System, and Standard No. 204, Steering Column Rearward Displacement. Both standards, copies of which are enclosed, establish performance requirements to protect the driver from steering column-related injuries in a crash. Any type of steering system, either mechanical or hydraulic, can be used as long as it meets the applicable requirements of those standards.
If you have any further questions please let me know.
Sincerely,
Original Signed By Frank Berndt Chief Counsel
Frank Berndt Chief Counsel National Highway Traffic Safety Administration Room 5219 400-7th Street Southwest Washington, D.C. 20590
I have been investigating all regulations pertaining to the type of steering required in vehicles for (trucks, tractors) highway and off-highway use.
It is my understanding there is no type of regulations requiring a mechanical link in the system, and that a straight hydraulic system is acceptable.
I contacted Steve Oesch, from your department and he researched the issue and found no reference to the type of system allowed.
I would appreciate a letter from you confirming that there are no regulations or requirements that require any certain type of steering arrangement.
Thank you, Sincerely yours,
Gene Wright Vice-President, Manufacturing CAPACITY OF TEXAS, INC.