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: aiam0036OpenMr. David A. Phelps, Jr., Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps: This is in response to your letter of November 10, 1967, in which yo requested a clarification of the use of the term 'combined optically' as used in Motor Vehicle Safety Standard No. 108, Sections S3.3(c) and S3.4.4.3.; S3.3(c)>>>*Lamp Combinations and Equipment Combinations*. Two or mor lamps, reflective devices, and items of associated equipment may be combined if the requirements for each lamp, reflective device, and item of associated equipment are met, except that --; (c) No clearance lamp may be combined optically with any taillamp o identification lamp.<<<; This means that no clearance lamp my be combined to use a lense (sic that is common to any other lamp such as a taillamp or identification lamp. The clearance lamp shall have a unique lense (sic).; S3.4.4.3>>>Stoplamps that are combined optically with turn signal lamp need not be operable when the combination is in use as a turn signal or as a vehicular hazard warning signal.<<<; This means that stoplamps that have a lense (sic) that is common wit the turn signal lamps do not have to be operable when the combined stoplamp and turn signal lamp is used primarily as a turn signal or as a hazard warning signal. Stoplamps need not be operable when the combined stoplamp and turn signal lamp unit is used as a hazard warning or turn signal indicator.; We trust these comments will be of assistance in clarifying you problems.; Sincerely, Andrew K. Ness, Acting Director, Office of Performanc Analysis; |
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ID: aiam5234OpenMr. Scott R. Dennison Vice-President - Production Excalibur Automobile Corporation 1735 South 108th Street Milwaukee, WI 53214; Mr. Scott R. Dennison Vice-President - Production Excalibur Automobile Corporation 1735 South 108th Street Milwaukee WI 53214; "Dear Mr. Dennison: Thank you for your letter of April 27, 1993 clarifying your FAX of March 12 to which I responded on April 19. We appreciate your goal of helping people comply with the Federal Motor Vehicle Safety Standards (FMVSS) and those of EPA. We can well understand why, as you put it, 'at times I do not feel I have the right answers for some of these manufacturers.' The regulation of kit cars and vehicles combining old and new parts is a complicated subject, and our opinions usually depend upon the specific facts of individual cases with the result that one may differ in degree from another. Because these are legal opinions, the Office of Chief Counsel is the proper Office within NHTSA to address questions of this nature, rather than the agency's Enforcement office. We are sorry that some of your inquirers 'are afraid to call NHTSA for fear of reprisal.' By this, I think you mean that a call from a small manufacturer might cause NHTSA to initiate enforcement action concerning nonconformance with the FMVSS or agency regulations. The potential of an enforcement action should be sufficient to encourage those engaged in the manufacturing or assembling of motor vehicles to discern their responsibilities under the National Traffic and Motor Vehicle Safety Act and to comply with them. We are willing to assist manufacturers in interpreting the Act and regulations. If they do not wish to write or call us, they can review our interpretation letters which are available to the public in NHTSA's Technical Reference Division. Also, they can consult a private attorney. You enclosed a copy of the 'EPA Kit Car Policy' which we have reviewed, comparing it with NHTSA policy. In most respects, the two policies are congruent. Paragraph 1 of the EPA document fairly expresses NHTSA policy, fully assembled kit cars, and complete kit car packages are 'motor vehicles' under the Act, required to be certified by the manufacturer or kit supplier. If they are not certified, they must be imported by a NHTSA-registered importer (the counterpart to EPA's Independent Commercial Importer), or one who has a contract with a registered importer to certify the kit car (an allowance that we understand does not exist under EPA regulations). I shall return to Paragraph 2 later. Paragraph 3 differs from NHTSA policy, although automotive bodies are not 'motor vehicles' under either EPA or NHTSA's definitions, they are 'motor vehicle equipment' for purposes of NHTSA's jurisdiction. Paragraph 4 essentially states NHTSA policy, kit car body/chassis combinations may be imported as automotive equipment and are subject to NHTSA's regulations. Similarly, any attempt to circumvent the Act or import regulations may be viewed as a violation subject to enforcement. However, NHTSA will also regard as a 'manufacturer' any person importing kits or kit cars for resale, as well as the actual fabricator or assembler of a kit. Paragraph 2 reflects the fact that EPA regulates only engines and emission- related components. A vehicle 'will be considered to be a rebuilt vehicle of a previously certified configuration and will be considered to be covered by that configuration's original EPA certification of conformity' if the engine and all emission-related components and settings conform to those of the previously certified configuration, and if the weight of the completed kit vehicle is not more than 500 pounds greater than that of the originally certified configuration. Under EPA policy, a 'rebuilt vehicle' could be a motor vehicle all of whose parts were new and unused except for its engine and engine-related components. NHTSA has no definition of 'rebuilt vehicle' which would permit a similar interpretation, and while a vehicle as I have described could be covered by the previously existing EPA certification, NHTSA very likely would regard it as a newly manufactured motor vehicle which must be certified as meeting all contemporary FMVSS. It is here that the two agencies most diverge because of the breadth of NHTSA's regulatory authority which encompasses all motor vehicle equipment, and motor vehicles assembled from that equipment. You cite as an example of difficulty 'the treatment of FMVSS with regards to a '23 T-Bucket Hot Rod'. The first question to answer is whether the car has been manufactured primarily for use on the public roads. Factors to consider in this determination are whether the Hot Rod is intended solely for use on closed race tracks, whether it must be trailered from race to race, and whether a State would license it for on road use. If the car has not been manufactured primarily for on road use, then it is not a 'motor vehicle' as defined by the Vehicle Safety Act, and not subject to the FMVSS. If the car is a 'motor vehicle' and entirely assembled from parts from a disassembled motor vehicle or vehicles previously in use, then it is considered a 'used' vehicle, and also not subject to the FMVSS (but subject to state and local standards). On the other hand, if the kit car is entirely comprised of previously unused parts, then it is a new motor vehicle that is required to comply with, and be certified as complying with, the FMVSS (and its manufacturer may be eligible to apply for a temporary exemption from one or more of those standards under 49 CFR Part 555). If the kit car is comprised of parts both previously used and unused, NHTSA's examination of the list of components in each category will enable it to advise whether the kit car must comply with the FMVSS that apply to new vehicles. In addition, we also receive inquiries from those who wish to construct vehicles which use a 'host' chassis from a previously certified vehicle. The Act permits a manufacturer to modify a previously certified vehicle in any manner as long as it does not knowingly render inoperative in whole or in part any device or element of design installed by the original manufacturer in accordance with a Federal motor vehicle safety standard. We interpret this as meaning that, if the manufacturer removes the original body, at the end of the conversion process the resulting motor vehicle must continue to comply with the FMVSS that were in effect when it was originally manufactured. However, a certain divergence from original vehicle compliance is permitted. For example, if a 1982 enclosed passenger car is modified to become a convertible, at the end of the conversion process it is no longer required to meet enclosed car FMVSS but must comply with those that applied to l982 convertibles. The Act does not require that such vehicles be certified but the manufacturer should be prepared to substantiate that it has not rendered inoperative any of the vehicle's original safety equipment, either directly or indirectly (such as a substantial increase in the weight of the vehicle that might affect its crash protection characteristics) in the event NHTSA should so ask. Finally, we note your remark that NHRA and SEMA are debating whether a policy can 'be developed which will allow these builders to produce an authentic replica and stay within the standards.' As I discussed above, the FMVSS would not appear to apply to a replica vehicle such as a Miller racing car from the 1920's that could not be licensed for on road use. However, the FMVSS do apply to vehicles composed of newly manufactured parts that replicate the look of older vehicles. For this reason, 100% authenticity cannot be achieved for a replica required to meet the current FMVSS because of equipment such as the center highmounted stop lamp, side marker lamps and reflectors, and head and other occupant restraints required for safety today. As a general rule, we would not provide temporary exemptions from these standards. In our view, the only viable candidate for an authentic replica is one that is constructed on a 'host' chassis of a vehicle manufactured before January 1, 1968, the date that the first FMVSS became effective, or entirely from used parts. I would also note that much authenticity could result from use of a 'host' chassis manufactured during calendar year l968. Although the appearance of the interior would be affected by compliance with certain FMVSS, the FMVSS requiring side marker lamps and reflectors and head restraints did not become effective until January 1, 1969. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3533OpenMr. Chris Tuerck, Assistant Chief Engineer, K-D Lamp Company, 1910 Elm Street, Cincinnati, Ohio 45410; Mr. Chris Tuerck Assistant Chief Engineer K-D Lamp Company 1910 Elm Street Cincinnati Ohio 45410; Dear Mr. Tuerck: This responds to your letter asking whether your sample turn signal an hazard switch design complies with the labeling requirements of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*.; By way of background information, I would point out that the agenc does not give advance approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to determine whether its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicle or equipment comply with all applicable standards. The following interpretation only represents the agency's opinion based on the information provided in your letter.; Your letter states that the switch is used primarily on Class 7 an Class 8 trucks and truck tractors. We therefore assume that it would only be used on trucks with a GVWR of 10,000 pounds or more. We make that assumption because Standard No. 101-80 includes requirements for a vehicle's displays in addition to its controls if it has a GVWR of less than 10,000 pounds. As explained below, it is our opinion that the sample switch does comply with the labeling requirements of Standard No. 101-80.; The sample turn signal and hazard switch is designed to be clamped ont a vehicle's steering column to the left of the driver and looks something like a box. We assume that the box is to be installed so that the side of the box which has two pushbuttons on it, marked 'R' and 'L,' is on the left. Pressing the 'R' pushbutton, which is located toward the back, activates the right turn signal. Pressing the 'L' pushbutton, which is located toward the front, activates the left turn signal. Both buttons must be pushed simultaneously for the hazard warning signal. Most of the identification for the switch is located on top of the box. Just above the right turn pushbutton is a thick black arrow pointing to the right. Just above the left turn pushbutton is a thick black arrow pointing to the left. Above each pushbutton there is also a triangle outlined in black, i.e., the hazard warning symbol specified by Table 1 of Standard No. 101-80. Between those identifications is located a pushbutton, identified by the use of both words and symbols, which clears the turn signal or hazard warning signal. The top of the box also includes three jewel-type pilot indicators which indicate when the turn signals or hazard warning signal are activated and additional labeling explaining the method of operation for the hazard warning signal.; Section S5.2.1 of Standard No. 101-80 states in relevant part: >>>Vehicle controls shall be identified as follows: (a) Except as specified in S5.2.1(b), any hand-operated control liste in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol. Such a control may, in addition, be identified by the word or abbreviation shown in column 2. Any such control for which no symbol is shown in Table 1 shall be identified by the word or abbreviation shown in column 2. Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. The identification shall be placed on or adjacent to the control. The identification shall, under the conditions of S6, be visible to the driver and , except as provided in S5.2.1.1 and S5.2.1.2, appear to the driver perceptually upright.<<<; Both the turn signal and the hazard warning signal are listed in colum 1 of Table 1 and have symbols designated in Column 3. Therefore, Standard No. 101-80 requires that those controls be identified by the designated symbols.; The primary issue raised by your design is whether the turn signa control symbol specified by Table 1, a pair of arrows, may be split where there are independent controls for the left and right turn signals. As explained below, it is our opinion that the pair of arrows may be split in that particular circumstance.; The symbol for the turn signal control is the same as the symbo specified by Table 2 for the turn signal display. A footnote to Table 2 explains that while the pair of arrows is a single symbol, the two arrows will be considered separate symbols when the indicators for the left and right turn operate independently and may be spaced accordingly.; Table 1 does not include that footnote for the turn signal control. turn signal control would normally be expected to consist of one button or lever and would be required to be identified by the pair of arrows as one symbol. It is our interpretation, however, that the two arrows may be considered separate symbols where there are independent controls for the left and right turn signals, as in your sample switch. Separating the two arrows in such an instance has the advantage of indicating the direction of the signal activated by each pushbutton.; Table 2 also includes a footnote that indicates that the framed area of the turn signal display symbol may be filled in. While Table 1 has a footnote that indicates that the framed areas of several symbols may be filled in, the turn signal control is not among those listed. It is our interpretation, however, in light of the footnote in Table 2, that a manufacturer may fill in the framed areas of the turn signal symbol whether it is used for control or a display.; Thus, the symbols used on the sample switch for the turn signa controls are those specified by Standard No. 101-80.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3163OpenMr. W. G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your October 9, 1979, letter relating to the prope classification of school buses on certification labels.; Your letter is accurate in that school buses may be designated a 'school buses' on their certification labels. The agency thinks that for the purpose of clarity the term 'school bus' should be included on the label to further clarify the particular design of the bus. All other buses that comply only with standards applicable to non-school buses must be certified as 'buses'.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3499OpenMr. L.J.A. Mills, G & C Mills Plastics, Inc., 2309 Langdale Avenue, Suite 5, Los Angeles, CA 90041; Mr. L.J.A. Mills G & C Mills Plastics Inc. 2309 Langdale Avenue Suite 5 Los Angeles CA 90041; Dear Mr. Mills: It has come to our attention that your are distributing auxiliary win deflectors for use on motor vehicles which may not be in compliance with Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*. You received a letter from this agency dated July 13, 1979, and a later letter from the Department of Commerce which may have misled you concerning your responsibilities for complying with Standard No. 205.; This matter was brought to our attention by Mr. Paul Hingtgen who tol the agency you had shown him the correspondence referred to above. I am enclosing copies of two letters we sent to Mr. Hingtgen which explain why and how the previous letter to you from this agency was misleading. From those letters, you will see that auxiliary wind deflectors are considered to be pieces of 'motor vehicle equipment' and, as such, they must be made from glazing materials that are in compliance with Standard No. 205. We hope you will ensure that any wind deflectors you sell or distribute are in compliance with the standard, since you could be subject to substantial civil penalties if you fail to do so. I am also enclosing a copy of Standard No. 205.; If after reviewing the enclosed letters you have any questions, pleas contact Mr. Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2322OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, New Jersey 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: This is in response to your February 23, 1976, letter concerning th rim marking requirements of S5.2 of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; In its present form, S5.2 requires a rim to which the standard applie to be marked with its size designation and, if it is a multi-piece rim, its type designation as well. There is no prohibition on the marking of additional information beyond that which is required. Therefore, the marking of single piece rims with a type designation is permitted.; Please note that, in a notice published on Mary 6, 1976 (41 FR 18659 Docket No. 71-19, Notice 4), the National Highway Traffic Safety Administration delayed the effective dates of several of the standard's requirements. In particular, the effective date of S5.2, *Rim Marking*, was delayed until August 1, 1977. A copy of this notice is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam3860OpenMichael S. Rosenthal, Esq., Assistant Attorney General, State of Georgia Department of Law, 132 State Judicial Building, Atlanta, GA 30334; Michael S. Rosenthal Esq. Assistant Attorney General State of Georgia Department of Law 132 State Judicial Building Atlanta GA 30334; Dear Mr. Rosenthal: This is in response to your letter of October 21, 1983 inquiring as t policy of the National Highway Traffic Safety Administration with respect to routine use by dealers of the 'unknown' block on Odometer Disclosure Statements when there is no actual knowledge that the mileage shown on the odometer is not accurate. I apologize for the delay in answering your inquiry.; On several occasions in the past, this office has issued interpretatio letters expressing disapproval of the practice you describe. I have enclosed copies of three such letters, dated November 14, 1978, February 3, 1978, and October 28, 1976, for your information. It is our position that a statement by the transferor on the odometer disclosure statement that the mileage is unknown when he has no actual knowledge that the mileage is inaccurate significantly inhibits enforcement of the Federal odometer law (Title IV of the Motor Vehicle Information and Cost Savings Act, 15 U.S.C. SS1981-19991 (sic)) by making it more difficult to trace violations through the chain of title.; I hope you find this information helpful. Sincerely, David W. Allen, Assistant Chief Counsel |
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ID: aiam2772OpenMr. James J. Kearney, Vice President, Baltimore Cycles, Inc., 6020 Eastern Avenue, Baltimore, Maryland 21224; Mr. James J. Kearney Vice President Baltimore Cycles Inc. 6020 Eastern Avenue Baltimore Maryland 21224; Dear Mr. Kearney: This is in reply to your letter of January 12, 1978, asking whether th braking system on your Casal mopeds meets Federal requirements.; Table 1 of Federal Motor Vehicle Safety Standard No. 123, *Motorcycl Controls and Displays*, requires that the control for read brakes on motorcycles shall be located at the right foot control (with the option of the left handlebar permissible for motor driven cycles such as mopeds) and operate by depressing to engage. The rear brake on the Casals moped in operated by 'back peddling, similar to a bicycle.' We understand that this is accomplished by application of force to the right foot pedal.; We have concluded that this system meets the requirements of th standard, since the brake is engaged by depressing the right foot pedal.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2288OpenMr. Thomas Kupensky, 4136 Loganway, Youngstown, OH, 44505; Mr. Thomas Kupensky 4136 Loganway Youngstown OH 44505; Dear Mr. Kupensky: This is in reply to your letter of April 8 to the Department o Transportation, regarding your CAUTION and THANK YOU signals which would flash simultaneously with the turn signal lamps on trucks and trailers.; Since such signs, flashing CAUTION or THANK YOU when actually 'turn' i intended, may be confusing in many circumstances, they would be prohibited by paragraph S4.1.3 of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, 'Lamps, Reflective Devices and Associated Equipment,' (copy enclosed), because they would appear to impair the effectiveness of the turn signals. If these signs were manually operated by the driver, separately from the turn signals, at appropriate times, whether flashing or steady burning, they would be considered auxiliary devices which did not impair the effectiveness of the turn signals, and would be permitted by Standard No. 108. In this situation, however, they would be subject to the motor vehicle regulation of the individual States.; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam5058OpenMr. C. Morris Adams 1201 Rockford Road High Point, NC 27260; Mr. C. Morris Adams 1201 Rockford Road High Point NC 27260; "Dear Mr. Adams: This responds to your FAX of September 24, 1992 requesting a ruling regarding the legality of lap belts at the passenger seats on school buses. As explained below, Federal law has long required lap or lap/shoulder belts to be installed at every passenger seating position on small school buses. Federal law has also long permitted, but not required, lap or lap/shoulder belts to be installed at passenger seating positions on large school buses, provided that those belts do not adversely affect the large school bus's compliance with the applicable safety standards. This is still the agency's position. As you know, in 1977, NHTSA issued Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection, which established minimum levels of crash protection that must be provided for occupants of all school buses. For large school buses (those with a gross vehicle weight rating GVWR of more than 10,000 pounds), the standard requires occupant protection through a concept called 'compartmentalization' -- strong, well-padded, well- anchored, high-backed, evenly spaced seats. Small school buses (those with a GVWR of 10,000 pounds or less) must provide 'compartmentalization' and be equipped with lap or lap/shoulder belts at all passenger seating positions. The agency believes that safety belts are necessary in addition to 'compartmentalization' in small school buses because of their smaller size and weight, which are closer to that of passenger cars and light trucks. Ever since 1977, NHTSA has indicated that Federal law permits lap or lap/shoulder belts to be installed at the passenger seating positions on large school buses as long as the vehicle would still comply with all applicable safety standards, including Standard No. 222. NHTSA has no information to indicate that installation of seat belts at the passenger seating positions on a large school bus would affect the bus's compliance with any safety standard.The allegations in your FAX that using seat belts in large school buses will result in crash forces producing concentrated loading on the head, instead of being spread evenly over the upper torso as is the case without a seat belt, are nearly identical with the explanations included in a 1985 Transport Canada report on school bus safety. NHTSA carefully evaluated and considered the Canadian report and these explanations in connection with its rulemaking action considering whether to specify requirements for voluntarily installed seat belts on large school buses. 54 FR 11765, March 22, 1989. After fully considering the Canadian report, the agency stated at 54 FR 11770: NHTSA shares commenters' concerns about any implications that safety belts negatively affect the protection provided to passengers on large school buses. However, the agency is not aware of accident data showing an injury caused or made more serious by the presence of safety belts on a school bus. Furthermore, NHTSA cannot conclude from the Canadian report's findings that belts actually degrade the benefits of compartmentalization to the extent that the supplemental restraint system renders inoperative the safety of large school buses, but the possibility exists that the occupant kinematics shown in the Canadian tests could occur. The agency then identified some possible safety benefits that could result from seat belts in large school buses, benefits that were not considered in the Canadian tests. The agency concluded that, 'Although these benefits are not significant enough to justify a Federal requirement for the installation of safety belts on all large school buses, they are enough to provide a basis upon which the agency will decline to prohibit the installation of belts on large school buses.' 54 FR 11765, at 11770, March 22, 1989. I have enclosed a copy of this notice for your information. As you can see, NHTSA has carefully considered the subject raised in your FAX and reviewed all available information in this area. After that review, the agency concluded that there was no justification for changing its longstanding position that persons that wish to do so should be permitted to install seat belts at passenger seating positions in large school buses. Your letter did not provide any data that NHTSA had not already considered. Hence, there is no basis for the agency to change its longstanding position in this area. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel 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.