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: aiam3933OpenMr. Hayley Alexander, Marketing Consultant, The LondonCoach Co., Inc., P.O. Box 1183, Mt. Clemens, MI 48043; Mr. Hayley Alexander Marketing Consultant The LondonCoach Co. Inc. P.O. Box 1183 Mt. Clemens MI 48043; Dear Mr. Alexander: This is in reply to your letter of March 25, 1985, asking for ou comments on your planned London Taxi marketing program.; Under the program, products of Carbodies Ltd. of Coventry, England would be imported 'devoid of an engine, transmission, and finished interior.' LondonCoach would then install 'an American engine, transmission and driveshaft, interior seats, coverings and details, and various exterior cosmetic trim items.' However, a 'representative' vehicle with the modifications mentioned above will have undergone all testing necessitated by the standards, at the Motor Industry Research Association in England. Vehicles would be certified by Carbodies as meeting the standards prior to importation, and LondonCoach Co., Inc., in the role of alterer, would attach the label attesting to continued compliance required by 49 CFR Section 567.7 upon completion of the modifications.; Under the National Traffic and Motor Vehicle Safety Act, certificatio of compliance of a motor vehicle can only be provided by the manufacturer or importer of a completed motor vehicle. Certification of compliance with at least four Federal motor vehicle safety standards is directly dependent upon the manner in which the Carbodies vehicles are completed by LondonCoach: Standard No. 124, *Accelerator Control Systems*, Standard No. 207, *Seating Systems*, Standard No. 301, *Fuel System Integrity*, and Standard No. 302, *Flammability of Interior Materials*. Therefore, LondonCoach is the only party who can certify compliance of the completed vehicle with Federal motor vehicle safety standards. As the manufacturer, LondonCoach is also responsible for assigning and affixing the vehicle identification number (VIN) to each vehicle, according to the requirements of Standard No. 115, *Vehicle Identification Number--Basic Requirements*, and 49 CFR Part 565, *Vehicle Identification Number--Content Requirements*.; The Carbodies products are an assemblage of items of motor vehicl equipment and should be labeled as equipment items for importation into the United States. Carbodies should certify that each item of motor vehicle equipment that is covered by a Federal motor vehicle safety standard complies with such standard. Those items are brake hoses, new pneumatic tires, brake fluid, surface glazing, seat belt assemblies, and lamps, reflective devices, and associated equipment. This certification should free LondonCoach, as the importer, from the obligation under 19 CFR 12.80 to post a compliance bond upon entry into the United States.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2271OpenMr. Roger E. Stange, President, Norton Triumph Corporation, P.O. Box 275, Duarte, California 91010; Mr. Roger E. Stange President Norton Triumph Corporation P.O. Box 275 Duarte California 91010; Dear Mr. Stange: This is in reply to your letter of April 1, 1976, which requests a interpretation of Motor Vehicle Safety Standard No. 123 as it applies to a motor-driven cycle that your company intends to import.; "The speedometer on this machine displays both minor numerals and mino graduations at 5 mph intervals. Paragraph S5.2.3 and Column 3 of Table 3 of Standard No. 123 require that, if a motorcycle is equipped with a speedometer, 'Major graduations and numerals shall appear at 10 mph intervals, minor graduations at 5 mph intervals.' S5.2.3 also states that the abbreviations used in Column 2 and 3 are j minimum requirements and 'appropriate word may be spelled in full.' It is your interpretation that 'if the abbreviations used in Column 3 are minimum requirements ... the speedometer in question meets the minimum requirements and is therefore in conformity with the standard.'"; The 'abbreviations' only refer to words and not to numerals o graduations. However, since there is no specific prohibition against providing minor numerals at the minor graduations, we have concluded that Standard No. 123 allows a motorcycle manufacturer to furnish a speedometer with them if he so chooses.; Yours truly, Stephen P. wood, Assistant Chief Counsel |
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ID: aiam3899OpenMr. Ernest Farmer, Director, Pupil Transportation, Tennessee State Department of Education, Office of Commissioner, Cordell Hull Building, Nashville, TN 37219-5335; Mr. Ernest Farmer Director Pupil Transportation Tennessee State Department of Education Office of Commissioner Cordell Hull Building Nashville TN 37219-5335; Dear Mr. Farmer: This responds to your letter to me regarding our motor vehicle safet standards for school buses. You asked several questions about Standard No. 222, *School Bus Passenger Seating and Crash Protection*, and Standard No. 301, *Fuel System Integrity*. In a telephone conversation you had on February 8, 1985, with Ms. Hom of my staff, you also asked about the safety standards that apply to vans carrying 10 or less persons that are used to transport school children.; To begin, I would like to explain that the motor vehicle safet standards issued by our agency apply to the manufacture and sale of new motor vehicles. As you know, in 1974, Congress expressly directed us to issue standards on specific aspects on school bus safety. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. A manufacturer or dealer who sells a new bus to a school must sell a bus that complies with the motor vehicle safety standards applicable to school buses.; Under our regulations, a 'bus' is defined as a motor vehicle designe for carrying 11 or more persons. 'School bus' is defined as a bus that is sold for purposes that include carrying students to and from school or related events (excluding buses sold as common carriers in urban transportation). A van type vehicle, constructed on a truck chassis, carrying 10 persons or less is classified as a multipurpose passenger vehicle (MPV). New MPV's sold to schools need not meet the school bus safety standards, since these vehicles are not buses. However, there are many motor vehicle safety standards applicable to MPV's. New MPV's must be certified by their manufacturers as complying with these safety standards. I have enclosed a list of the motor vehicle safety standards applicable to MPV's, as you requested.; The first question in your letter asked whether we require 'Type A vehicles which carry 15 to 22 passengers to comply with the provisions of Standards Nos. 222 and 301. Over the telephone, you explained that these vehicles are school buses with gross vehicle weight ratings (GVWR) of 10,000 pounds or less.; The answer to this question is yes. Standard No. 222 applies to al school buses. However, the requirements of the standard vary depending on the GVWR of the bus. Standard No. 301 applies to all school buses that use fuel with a boiling point above 32 degrees F. A new school bus must be certified as complying with the applicable requirements of these safety standards.; The first part to your second question asked, 'Does NHTSA consider 14- inch crash barrier installed in front of standard 39-inch bench seats on the right side of the aisle in these vehicles to be in compliance with FMVSS 222?'; The answer to this question is that there is no violation of Standar No. 222's restraining barrier requirements. This is because the restraining barrier requirements do not apply to school buses of 10,000 pounds or less GVWR. Paragraph S5(b) of the standard lists the requirements that apply to these smaller school buses, and the restraining barrier requirements found in paragraph S5.2 are not listed in S5(b). If a manufacturer voluntarily chooses to install a restraining barrier in these buses, there is no violation of Standard No. 222 if the barrier is not as wide as the designated seating positions behind it.; The second part of this question asked, 'Would seat belts on the fron row of seats void the crash barrier requirement in this statement for Type A vehicles? (We are aware that NHTSA requires seat belts on all Type A vehicles)'; The answer to this question is similar to that given above. Restrainin barriers on school buses with GVWR's of 10,000 pounds or less are not required by Standard No. 222. Since these smaller school buses are equipped with seat belts, the standard does not regulate seat spacing in these vehicles.; The third part of this question asked, 'Would the location of the ga tank between frame members also void the requirement in FMVSS 301 for a protection barrier?'; The answer is that Standard No. 301 sets performance requirements tha each school bus must meet, it does not require specific designs, such as a protective barrier. A manufacturer can position its gas tank at any location as long as it can meet the performance requirements of the standard at that location.; Your third question asked, 'Does NHTSA require the installation of metal shield between the exhaust system and the gas tank when such locations are 12 inches or less from each other? (Note: We have some Type A vehicles with variations of 6 to 8 inches that supposedly have NHTSA approval.)'; Neither Standard No. 301 nor any of the agency's other standards se any requirements concerning the installation of metal shields between the exhaust system and the gas tank.; If you have further questions, please do not hesitate to contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4872OpenMr. Paul R. Kirchgraber Souvenirs of the Future Suite 201-71 3435 Ocean Park Blvd. Santa Monica, CA 90405; Mr. Paul R. Kirchgraber Souvenirs of the Future Suite 201-71 3435 Ocean Park Blvd. Santa Monica CA 90405; Dear Mr. Kirchgraber: This is in reply to your letter of April 16 1991, with respect to which Federal motor vehicle safety standards, if any, must be met in order to sell an exterior tire/wheel cover with reflective characteristics that will help to make 'the vehicle more visible to the surrounding traffic.' In addition, you 'want to be certain that the reflective nature of the fabric used in this cover does not present a safety hazard', and ask for the citation to 'appropriate federal test standards from the code of federal regulations for similar automotive accessories.' There are no Federal motor vehicle safety standards that establish performance requirements for reflective material of this nature, or for wheel coverings on exterior-mounted tires. The standard on vehicle lighting, Motor Vehicle Safety Standard No. 108, does prohibit, as original equipment, the installation of a 'reflective device or other motor vehicle equipment' that impairs the effectiveness of lighting equipment required by the standard. It is theoretically possible that your material could create glare in the eyes of a following operator so that (s)he would fail to respond to a stop signal, or a turn signal. The samples submitted with your letter are too small for us to judge its reflectivity, and we suggest that you conduct your own tests, approaching a vehicle with the tire cover from the rear, with headlamps on the lower beam. This, to us, is preferable to your redesigning the material to conform to any federal test standard relating to reflectivity. Although the color of lighting equipment on the rear is generally red, with amber permitted for turn signals, and white required for back up lamps, we do not believe that the use of additional colors would create any confusion. In short, we believe that the wheel cover will be perceived for the wheel cover it is. I hope that this responds to your concerns. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0098OpenMr. John W. Carlin, Calumet Corporation, P. O. Box 389, Kaukauna, WI 54130; Mr. John W. Carlin Calumet Corporation P. O. Box 389 Kaukauna WI 54130; Dear Mr. Carlin: Thank you for your letter of July 22, 1968, to Mr. George C. Nield concerning the applicability and effective date of Motor Vehicle Safety Standard 108.; Standard No. 108 is applicable to new vehicles manufactured on or afte the effective date of the standard. Initial Standard No. 108 was published on February 3, 1967, and became effective January 1, 1968. The initial standard is applicable only to vehicles that are 80 inches or more in overall width. Revised Standard No. 108 was published on December 16, 1967, and becomes effective January 1, 1969. The revised standard is applicable to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers and motorcycles, regardless of overall width, however, the special requirements for vehicles that are 80 inches or more in overall width have been identified in the standard. Copies of the initial and revised standard are enclosed for your information.; In reply to your specific questions, information is provided a follows:; >>>1. With respect to your first question, Standard No. 108 i applicable to trailers manufactured for personal use by an individual and for commercial use.; 2. With respect to your second question, Revised Standard No. 108 effective January 1, 1969, specifies the lighting requirements for trailers that are less than 80 inches in overall width.; 3. With respect to your third question, the regulations of individua States and of the Bureau of Motor Carrier Safety (for vehicles engaged in interstate commerce) presently govern the lighting required on trailers that are less than 80 inches in overall width. Effective January 1, 1969, these trailers will be subject to the requirements of Revised Standard No. 108. Installation and location requirements for the individual lamps are contained in the referenced SAE standards (see Table III of Standard No. 108) and in Table IV of Standard No. 108.<<<; Also enclosed is a copy of the notice of 'Certification Requirement, which provides information on the manufacturer's certification of vehicles that are subject to the Federal motor vehicle safety standards.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam0562OpenMr. Paul M. Frank, Blumberg, Singer, Ross, Gottesman & Gordon, 245 Park Avenue, New York, NY, 10017; Mr. Paul M. Frank Blumberg Singer Ross Gottesman & Gordon 245 Park Avenue New York NY 10017; Dear Mr. Frank: In response to your letter of December 9, 1971, it is correct tha Standard No. 302, 'Flammability of Interior Materials,' applies only to motor vehicles (passenger cars, multipurpose passenger vehicles, trucks, and buses) manufactured on or after September 1, 1972. The standard does not apply to replacement or aftermarket seat covers.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5330OpenMr. Derrick Barker John Martin Designs 1 Clifton St. Stourbridge, West Midlands DY8 3XR; Mr. Derrick Barker John Martin Designs 1 Clifton St. Stourbridge West Midlands DY8 3XR; Dear Mr. Barker: This responds to your letter concerning the buckl release requirement of Federal Motor Vehicle Safety Standard No. 213, 'Child Restraint Systems.' I apologize for the delay in responding. You asked for the 'tensile load requirements for the buckle and tongue.' There is no specific requirement in Standard 213 for the tensile force that a child restraint buckle must withstand. Instead, the buckle must maintain its integrity when the child restraint is subjected to a simulated frontal impact at 30 mph with either a six-month-old (17 pounds (lbs.)) or three-year-old (33 lbs.) sized dummy restrained in the car seat. At the conclusion of the simulated impact, the force required to depress the latch button to release the buckle is measured and must be 16 lbs. or less. You also asked for a copy of Procedure D of the American Society for Testing and Materials Standard D756-78. Section S5.4.2 of FMVSS No. 213 sets forth those requirements by making reference to section S4.3(b) of FMVSS No. 209. which, in turn, leads to the reference to Procedure D of ASTM D756-78. The material you requested is enclosed. In addition, you asked for a list of laboratories that test child safety seats and buckles. NHTSA does not endorse particular test laboratories. However, I can provide you with a list of laboratories we are aware of that conduct child restraint compliance tests. There may be other laboratories that can test child safety seats and buckles. Please contact Ms. Deirdre Fujita of my staff if you have further questions. Sincerely, John Womack Acting Chief Counsel Enclosures; |
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ID: aiam0132OpenMr. J.B.H. Knight, Chief, Development and Car Safety Engineer, Rolls-Royce Limited, Motor Car Division, Pym's Lane, Crewe, Cheshire, England; Mr. J.B.H. Knight Chief Development and Car Safety Engineer Rolls-Royce Limited Motor Car Division Pym's Lane Crewe Cheshire England; Dear Mr. Knight: Thank you for your letter of November 8, 1968, requesting clarification of the 30g horizontal inertia load direction specified in Standard No. 201, as published in the *Federal Register* on October 25, 1968.; In section S3.3.1(c), 'Subject the interior compartment door latc system to a horizontal inertia load of 30g in a longitudinal direction...' means both forward and rearward directions. In addition, the loads specified in S3.3.1(a) are applied in both the inboard and outboard and the up and down directions. This is consistent with similar type requirements in Standard No. 206.; You state that a forward and rearward 30g inertia load requirement i more stringent than the alternative procedure of S3.3.1(b), the barrier test. The Bureau believes, and one large manufacturer so stated in his comments, that the most meaningful test of the ability of an interior compartment door to remain closed is one which considers the distortion an deformation loads that occur in a collision. A barrier or equivalent dynamic test is the best way of realistically evaluating the ability of these doors to remain closed. The bureau, therefore, believes that the barrier test is as stringent a requirement as S3.3.1(c).; Sincerely, William Haddon, Jr., M.D., Director |
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ID: aiam1689OpenMr. Curtis Eddy, Vice President - Engineering, Matlock Truck Body and Trailer Corporation, P. O. Box 7385, Nashville, TN 37210; Mr. Curtis Eddy Vice President - Engineering Matlock Truck Body and Trailer Corporation P. O. Box 7385 Nashville TN 37210; Dear Mr. Eddy: This is in reference to your defect notification campaign (NHTSA No 74-0203) concerning trailers equipped with Standard Forge axles which may have defective brake shoes.; The letter which you have sent to the owners of the subject trailer does not completely meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoes. Part 577.4(b), however, requires that in cases where a vehicle manufacturer is notifying owners of vehicles, the letter must state that a defect exists in the vehicle itself. The reference to motor vehicle equipment applies only to equipment campaigns where vehicles are not directly involved. Your letter also fails to adequately evaluate the risk to traffic safety as required by Part 577.4(d) since it does not state that the vehicle crash without warning may occur. Although the statement that reduced braking power or lockup may result may suggest the possibility of a crash to many owners, it is not entirely adequate.; Although mailing of a revised notification letter will not be required it is expected that in the event that another defect notification campaign ever becomes necessary in the future, the notification letters conform completely with the regulations.; A copy of Part 577 is enclosed. If you desire further information please contact Messrs. W. Reinhart or James Murray of this office at (202) 426- 2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam4171OpenFrederick B. Locker, Esq., Locker Greenberg & Brainin, P.C., One Penn Plaza, New York, NY 10001; Frederick B. Locker Esq. Locker Greenberg & Brainin P.C. One Penn Plaza New York NY 10001; Dear Mr. Locker: This responds to your June 4, 1986 letter to Mr. Francis Armstrong, th former Director of this agency's Office of Vehicle Safety Compliance. In that letter, you referred to the preliminary compliance test data sheet showing that the Kolcraft 'Flip N Go' booster seat failed to comply with section S5.2.4 of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). You stated that this preliminary noncompliance finding was based on a misinterpretation and misapplication of section S5.2.4. I conclude that Mr. Armstrong was acting on a correct interpretation of that section and properly applied it to the Kolcraft 'Flip N Go' booster seat.; For your information, section S5.2.4 reads as follows: >>>*Protrusion limitation*. Any portion of a rigid structural componen within or underlying a contactable surface, or any portion of a child restraint system surface that is subject to the requirements of S5.2.3 shall, with any padding or other flexible overlay material removed, have a height above any immediately adjacent restraint system surface of not more than 3/8 inch and no exposed edge with a radius of less than 1/4 inch.<<<; You asserted that S5.2.4 does not apply to the 'Flip N Go' Seat. As yo read S5.2.4, it applies only to child restraint systems that are also subject to S5.2.3. You note that the 'Flip N Go' seat is not recommended for children weighing less than 20 pounds, so the requirements of S5.2.3 are not applicable to it. You then conclude that the requirements of S5.2.4 should also not be applicable to that seat.; Your assertion is, however, based upon the misplacing of the firs comma in your quotation of S5.2.4. As S5.2.4 was quoted in your letter, the comma appeared as follows 'restraint system surface, that is subject.' In fact, there is no comma in that location. One does appear earlier: 'contactable surface, or any portion.' As you see from the correct version of S5.2.4 set forth above, it applies to both--; >>>(1) any portion of a rigid structural component within or underlyin a contactable surface, *AND; (2) any portion of a child restraint system surface that is subject t the requirements of S5.2.3.<<<; Since we both agree that the 'Flip N Go' seat is not subject to th requirements of S5.2.3, the question is whether all portions of its rigid structural components within or underlying a contactable surface satisfy the requirements of S5.2.4. Section S4 of Standard No. 213 defines a 'contactable surface' as 'any child restraint system surface (other than that of a belt, belt buckle, or belt adjustment hardware that may contact any part of the head or torso of the appropriate test dummy, specified in S7, when a child restraint system is tested in accordance with S6.1.' The preliminary compliance test data sheet for the 'Flip N Go' seat indicates that four different surfaces on the shield and shield support arms appear to fail to comply with the requirements of S5.2.4.; The first surface listed as not appearing to comply with S5.2.4 was th horizontal upper-forward edge of the shield, which has a radius of less than 1/4 inch. Your response is that this surface is not capable of being contacted by the child's head or neck. We disagree with you. However, even if the test dummy's head and neck failed to contact this edge, the dummy's torso *would* contact that surface. The torso contact would make the edge a contactable surface under S5.2.4, which prohibits the edge from having a radius of less than 1/4 inch. Accordingly, this edge does not appear to comply with S5.2.4, regardless of whether it is contacted by a child's head, neck, or torso.; The outboard left and right vertical edges of the shield support arm appear not to comply with two requirements of S5.2.4. First, the edges have radii of less than 1/4 inch. Second, the edges protrude more than 3/8 inch above the immediately adjacent shield surface. Your response to this was that the entire shield surface is integral and must be considered as a whole. When consider in this way, you stated that the edges of the shield support arms comply with S5.2.4. We cannot agree with your interpretation.; There is no basis in Standard No. 213 for your position that 'integral shields are considered as a whole for the purposes of S5.2.4. The only question under S5.2.4 is whether a contactable surface incorporates projections or narrow edges that could subject the child occupant to pressure point loading in the event of a crash. If the contactable surface incorporates such projections or narrow edges, it does not comply with S5.2.4. Since the edges of the shield support arms on the 'Flip N Go' seat are contactable surfaces which incorporate projections and have edge radii that are prohibited by S5.2.4, the edges of the shield support arms do not appear to comply with S5.2.4.; The third surfaces noted as not appearing to comply with S5.2.4 wer the inboard vertical surfaces of the shield support arms, because those surfaces have edges with radii of less than 1/4 inch. Your response to this was to repeat your integral shield argument and to state that Standard No. 213 does not require oblique crash simulations. This latter point was in response to the following statement in the preliminary compliance test data report: 'These edges and those described in (2) above could be contacted by the occupant in oblique crashes.'; This statement is not the reason for the preliminary determination tha those edges do not comply with S5.2.4 of Standard No. 213. It was included only to point out the actual safety hazard that could be presented to occupants of the 'Flip N Go' seat in a crash. The reason for the preliminary determination is that these edges appear to be contactable surfaces within the meaning of S4, and the edges have radii of less than 1/4 inch. I apologize for any confusion the statement about oblique crashes may have caused.; The fourth surface noted as not appearing to comply with S5.2.4 was th extreme bottom horizontal surface of the shield, with a radius of less than 1/4 inch. Additionally, that surface is supported by seven smaller vertical ribs, five of which are contactable and have edge radii of less than 1/4 inch. The data sheet concluded, 'All of these edges may be contacted by the occupant's thighs or lower abdomen.'; You responded to this by repeating your integral shield argument, an stating that the requirements of S5.2.4 are applicable only to situations involving head impact protection. Accordingly, you stated that S5.2.4 was not intended to address contact with the shield by an occupant's thighs or lower abdomen.; As noted above, section S5.2.4 requires all portions of the shiel within or underlying a 'contactable surface' to have no protrusions. A contactable surface refers to portions of the restraint that may contact any part of the head or *torso*. Section S4 of Standard No. 213 defines the term 'torso' as 'the portion of the body of a seated anthropomorphic test dummy, excluding the thighs, that lies between the top of the child restraint seating surface and the top of the shoulders of the test dummy.' Thus, the thighs would not be considered part of the torso, but the lower abdomen would. Section S5.2.4 is intended to prevent or reduce injuries to the torso, including the lower abdomen. Thus, any edge contactable by the test dummy's lower abdomen must have a radius of at least 1/4 inch to comply with S5.2.4. Since these edges have smaller radii, they do not appear to comply with that section.; Please contact our Office of Vehicle Safety Compliance if you have an further responses or comments on the preliminary noncompliance determination.; Sincerely, Erika Z. Jones, 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.