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: aiam5493OpenMr. Dietmar K. Haenchen Manager, Vehicle Regulations Volkswagen of America, Inc. 3800 Hamlin Road Auburn Hills, MI 48326; Mr. Dietmar K. Haenchen Manager Vehicle Regulations Volkswagen of America Inc. 3800 Hamlin Road Auburn Hills MI 48326; "Dear Mr. Haenchen: This responds to your follow up request for a interpretation of marking requirements in 49 CFR part 541 Federal Motor Vehicle Theft Prevention Standard, for high theft vehicle lines' replacement parts. I apologize for the delay in our response. We reiterate our position in a July 1, 1994 letter to you, that Volkswagen is required to continue marking replacement parts of the Corrado line, in model year 1995 and thereafter. The reason for this position follows. In your earlier request for an interpretation, you explained that the Volkswagen Corrado line, a high theft line, was parts marked (pursuant to 49 CFR part 541) in model years (MYs) 1990 through 1994. For MY 1995, NHTSA granted a part 543 exemption from parts marking for the Corrado line, based on the inclusion of an approved antitheft device as standard equipment on all models in the Corrado line. (58 FR 28434, May 13, 1993). However, you informed us in your letter that the Corrado will not be sold in the United States for MY 1995. In a July 1, 1994 interpretation letter to you, we determined that since Volkswagen will not sell the exempted MY 1995 Corrado line with the antitheft device, in the United States, the part 543 exemption would not apply, and Volkswagen must continue to mark the replacement parts for the Corrado line. In your follow up letter, you wrote that the MY 1994 Corrado line has, as standard equipment, the antitheft device that was the subject of the part 543 exemption for MY 1995. You state that since the Corrado line with the approved antitheft device was sold in the United States, replacement parts for the Corrado line should not be subject to marking in MY 1995 and thereafter. We do not agree with your position. 49 CFR 543.7(d) specifies that part 543 exemptions apply only to lines that: (1) are the subject of the grant, and (2) are equipped with the antitheft device on which the line's exemption was based. The MY 1994 Corrado line does not meet the first condition, i.e., it is not the subject of a grant of an exemption from parts marking. The part 543 exemption for the Corrado line begins with MY 1995. (See 58 FR 28434). You have earlier written that no MY 1995 Corrado line with the exempted device, will be sold in the U.S. As stated in our July 1, 1994 letter, since no exempted line, equipped with the antitheft device will be sold in the U.S., Volkswagen must continue to mark any Corrado replacement parts, subject to part 541, as long as the replacement parts are offered for sale in the U.S. I hope that this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam5186OpenMr. Shawn Shieh Ventures International USA 1141 N. Columbus Ave., Suite 303 Glendale, CA 91202; Mr. Shawn Shieh Ventures International USA 1141 N. Columbus Ave. Suite 303 Glendale CA 91202; Dear Mr. Shieh: This replies to your undated letter to the Office o Enforcement, NHTSA, asking questions about an emergency communication product intended to be permanently mounted in the back window of an automobile. The product uses light emitting diodes to form messages for the drivers of following cars to read. I enclose a copy of a letter dated August 17, 1989, that the agency sent to Alan S. Eldahr who asked for our comments on a similar device. The same advice applies to your product. As you will see, our opinion is that the product is of doubtful legality under Federal law when used on passenger cars manufactured on or after September 1, 1985, which are equipped with center highmounted stoplamps. In addition, the product must not create a noncompliance with the Federal field of view requirements for interior rear view mirrors. Thus, we cannot answer your question about the maximum size of a permanent structure to be installed in an automobile because that will vary from car to car. With respect to your other questions, there are no Federal specifications for the material of the base support. The 'restriction' on the product's wiring is that it must not interfere with the functioning of any Federally required lamp on the vehicle. This agency is the only government agency you have to consult on the product. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam2643OpenMr. Richard L. Kreutziger, Executive Vice-President, Coach & Equipment Sales Corporation, P.O. Box 36, Penn Yan, NY 14527; Mr. Richard L. Kreutziger Executive Vice-President Coach & Equipment Sales Corporation P.O. Box 36 Penn Yan NY 14527; Dear Mr. Kreutziger: This responds to your June 8, 1977, letter asking where a school bu sidewall ends and the bus roof begins for purposes of complying with the head protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; You enclosed a sketch detailing the bus sidewall and roof structure. O that sketch, you have a section of the bus labeled 'A' where the sidewall and roof structure join. You have called this a quarter panel section. However, from your sketch, it appears that this panel is divided into two segments, with one extending upward from the window a short distance and connecting with a second more rounded section that continues over the top of the bus. The National Higheay Traffic Safety Administration (NHTSA) has determined that your interpretation that the section labeled 'A' need not comply with the requirements of the standard is incorrect. The agency concludes that the portion of the 'quarter panel' that is a continuation of the bus sidewall is exempted from the requirements. However, the rounded portion of the panel that is merely a continuation of the roof must comply with the standard.; In your other sketch you present a roof drawing of a larger school bus The agency has determined that the section you have labeled 'roof section' is the only section of the drawing subject to the head protection zone requirements of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3951OpenT. J. Adams, Jr., Auction Insurance, Inc., 2130 Highland Ave., P.O. Box 55399, Birmingham, AL 35255-5399; T. J. Adams Jr. Auction Insurance Inc. 2130 Highland Ave. P.O. Box 55399 Birmingham AL 35255-5399; Dear Mr. Adams: This is in response to your letter of May 16, 1985, regarding th National Highway Traffic Safety Administration's (NHTSA's) opinion regarding the manner in which an odometer disclosure statement should be completed.; You indicate that, as an insurer of auctions, you expect that you ma purchase and re-market certain automobiles which have inaccurate or rolled back odometer readings. The Odometer Disclosure regulations, 49 CFR Part 580, provide for the inclusion of two sets of certifications on Odometer Disclosure Statements. Of the first set, you indicate that you will check the third statement, indicating that the odometer reading does not reflect the actual mileage of the vehicle.; You correctly point out, however, that none of the three statements i the second set provides for this situation. In your letter, you request an exception which would permit you to check the first statement, and cross out the last line which reads, 'and I have no knowledge of anyone else doing so'.; NHTSA grants you this exception, provided this last line, thoug crossed out, can still be read. We believe it is essential that a consumer understand that which the transferor is *not* certifying as well as that which he is. Alternatively, NHTSA would have no object if you wrote in and checked a fourth statement which would read:; >>> I hereby certify that the odometer of said vehicle was no altered, set back, or disconnected while in my possession.<<<; If written in, this statement must be included on the odomete statement itself. To avoid the possibility of its being separated from the statement, it may not be attached on a separate piece of paper.; If you have any further questions, please do not hesitate to let u know.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam0384OpenMr. J. M. Craig, President, Gator Trailers Corporation, 1925 East Beaver Street, P.O. Box 38051, Station 'G', Jacksonville, FL 32206; Mr. J. M. Craig President Gator Trailers Corporation 1925 East Beaver Street P.O. Box 38051 Station 'G' Jacksonville FL 32206; Dear Mr. Craig: This is in reply to your correspondence of June 3, 1971, requestin information on how you can receive copies of agency proposed and final regulations, and requesting clarification of certain provisions of an amendment to the Certification regulations (49 CFR Part 567) that was published April 14, 1971.; With reference to your request to receive copies of agency rulemakin publications, we are in the process of establishing a procedure whereby members of the public will be able to receive copies of such publications on a continuing basis for a nominal charge. Until this procedure is implemented, however, upon return of the enclosed mailing list questionnaire your name will be placed on a mailing list to receive copies of relevant materials.; With reference to the amendment to the Certification regulations, yo ask whether section 567.4(g)(1)(iii)(3) requires all options to be shown with their respective gross vehicle weight ratings, pointing out that various tire size options are available with your vehicles, each of which may change the GVWR. You also ask whether the requirements of section 567.4(f)(1)(iii)(4), 'Gross Axle Weight Rating', apply to trailers.; The gross vehicle weight rating is a value specified by th manufacturer. While the manufacturer may list for it the precise weight of a fully loaded vehicle, considering all options, he is free to set the weight more arbitrarily if he so chooses. The manufacturer should establish the weight rating, however, with the understanding that his vehicle will be loaded to it in determining compliance with certain motor vehicle safety standards.; With reference to your second question, the gross axle weight rating i applicable to trailers. Many trailers are designed so that only a portion of the vehicle's weight is carried on the axle, with the remainder carried by the towing vehicle. In such cases the gross axle weight rating will be different from the gross vehicle weight rating.; Please write if you have further questions. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2213OpenDavid E. Martin, Director, Automotive Safety Engineering, General Motors Corporation, General Motors Technical Center, Warren, MI 48090; David E. Martin Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Martin: This is in response to General Motors' October 28, 1975, petition t amend Federal Motor Vehicle Safety Standard No. 301, Fuel System Integrity. You requested an amendment that would permit the removal of trailer hitches before testing a vehicle for compliance with the rear moving barrier crash requirements. For the reasons set out below, the petition is denied.; As far as the National Highway Traffic Safety Administration (NHTSA) i concerned, the primary issue presented by the petition is whether the presence of a trailer hitch will compromise the crashworthiness of a vehicle or, in particular, whether it will diminish the integrity of the vehicle's fuel system. We believe that a new vehicle that is delivered to a purchaser with a trailer hitch, be it removable or permanently attached, should be in compliance with all standards without further modification.; You have suggested that requiring original equipment hitches to b attached during barrier crash testing would not have a significant effect on motor vehicle safety because such hitches make up only 5 percent of the trailer hitch market and there is no standard applicable to hitches that are sold in the aftermarket. However, Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, specifies 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...<<<; Therefore, aftermarket trailer hitches must also be installed in such way that compliance with Standard No. 301-75 is preserved.; You have also suggested that the rear moving barrier crash test i inappropriate as applied to vehicles that have trailer hitches attached, because the rigid, flat-faced moving barrier would but an unrealistically concentrated load on a trailer hitch. The NHTSA disagrees with this argument. Because the effect of Standard No. 215 has been to control the height and contour of bumpers and increase their rigidity, a vehicle's performance in the test prescribed in the standard does in fact tend to reflect its performance on the road.; For these reasons, the NHTSA has concluded that the amendment you hav suggested would diminish the level of motor vehicle safety and, therefore, that your petition should be denied. Indeed, for this agency to do otherwise would violate Section 108 of the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. 1392 note), concerning amendment or repeal of the fuel system integrity standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3052OpenMr. R. Hiribarren, Director, Mini-Comtesse, Z.I. de Saint Barthelemy d'Anjou, BP 815, 49008 Angers Cedex, France; Mr. R. Hiribarren Director Mini-Comtesse Z.I. de Saint Barthelemy d'Anjou BP 815 49008 Angers Cedex France; Dear Mr. Hiribarren: This responds to your May 21, 1979, letter asking whether the tw vehicles that you manufacture, the Comtesse and the Super-Comtesse, would be considered as mopeds for the purpose of applying Federal motor vehicle safety standards.; The National Highway Traffic Safety Administration (NHTSA) define motor-driven cycle (moped) as 'a motorcycle with a motor that produces 5-brake horsepower or less.' A motorcycle is defined as 'a motor vehicle with motive power having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.' Further, the application of some standards to mopeds depends upon their having a maximum speed obtainable in 1 mile of 30 mph or less.; The Super-Comtesse that you manufacture, since it has 4 wheels, woul not qualify as a motorcycle or as a moped. Since this vehicle has many of the aspects of a passenger car, it would be required to comply with the passenger car safety standards. The Comtesse, since it operates on three wheels, would be considered a motorcycle. If the Comtesse meets the other definitional requirements applicable to mopeds, it would be required to comply with the standards applicable to motorcycles or motor-driven cycles.; All Federal motor vehicle safety standards are located in Volume 49 o the Code of Federal Regulations in Part 571. Many of the standards are applicable to passenger cars. Only a few standards apply to motorcycles or motor-driven cycles. I am enclosing a package of information pertaining to the applicability of safety standards to mopeds.; The NHTSA has studied three-wheeled vehicles in the past and has ha serious reservations about the safety of these vehicles. I am enclosing a copy of an agency notice issued on this subject. We hope that your vehicle does not have similar safety problems.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4797OpenMr. S. Kadoya Manager Safety and Technology Mazda Research and Development of North America, Inc. 1203 Woodbridge Avenue Ann Arbor, MI 48105; Mr. S. Kadoya Manager Safety and Technology Mazda Research and Development of North America Inc. 1203 Woodbridge Avenue Ann Arbor MI 48105; Dear Mr. Kadoya: This responds to your request for interpretations o several safety standards and the Bumper Standard, in connection with a planned 'active' suspension system. I regret the delay in responding to your letter. Your questions are responded to below. By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by this agency, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter. According to your letter, Mazda is concerned about the protocol of compliance testing of vehicles equipped with an active suspension system. This concern arises because many standards do not specify a suspension height that is to be used during compliance testing. As you noted, this has not been a concern for conventional suspension systems, since they do not provide for variable height. Mazda's planned active suspension system would be actuated by hydraulic fluid or compressed air, with control pressure being developed by a hydraulic pump or air compressor driven off the engine. Consequently the active suspension system would be operational only when the vehicle's engine is operating. At vehicle speeds in excess of 'z' mph, where z is greater than 35 mph, the suspension height would be lowered by 'x' mm from the nominal or design position for vehicle operation. If the engine/vehicle were not used for several consecutive days, pressure in the control system would fall such that the suspension height may be lowered from the nominal or design position for vehicle operation by 'y' mm, where y is greater than x. The suspension height would return to the nominal or design position for vehicle operation after such an extended period of inoperation almost immediately after starting the vehicle's engine. Before discussing your specific questions, I would like to discuss more generally the issue of how compliance is determined in situations where a standard down not specify a particular test condition. In issuing Federal motor vehicle safety standards, NHTSA attempts to specify all relevant test conditions. The agency does this as part of ensuring that its standards are objective and practicable. As a practical matter, however, it is not possible to specify every conceivable test condition. This is particularly true for ones which may only be relevant to as-yet-undeveloped technologies. In cases where a standard does not specify a particular test condition, we believe there are several relevant factors to consider in interpreting the standard. First, in the absence of specification of a particular test condition, we believe there is a presumption that the requirements need to be met regardless of such test condition, since the standard does not include any language which specifically limits applicability of its requirements to such test condition. For example, where a standard does not specify suspension height, its requirements may need to be met at all heights to which the suspension can be adjusted. Before reaching such a conclusion, however, we also consider the language of the standard as a whole and its purposes. Even if a standard is silent as to a particular test condition, the language of the standard or its purposes may indicate limitations on such test condition. Finally, in situations where a limitation on a particular test condition may appear to be appropriate, we also must consider whether the limitation is sufficiently clear, both with respect to justification and specificity, to be appropriate for interpretation. For example, in a situation where it may appear to be reasonable to limit a particular test condition but it is not obvious what particular limitation should be adopted, it would be inappropriate to select a particular limitation by interpretation. Instead, such a decision should be reached in rulemaking. I will now address the specific questions asked in your letter. Standard No. 108, Lamps, Reflective Devices, and Associated Equipment In asking about Standard No. 108, you stated the following: NHTSA has previously issued an interpretation of the requirements of FMVSS No. 108, at the request of a confidential applicant and dated February 12, 1985, with respect to active suspension equipped vehicles. This interpretation stated that the requirements of FMVSS 108 must be meet (sic), ...at any time in which...' lamps, reflective devices, and associated equipment are to be, '...operated for its intended purpose.' Consequently, headlamps, tailamps, stoplamps, the license plate lamp, and side marker lamps, must comply with the location requirements of FMVSS No. 108 whenever the vehicle's ignition is in the 'on' position. Conversely, reflex reflectors, and turn signal lamps that also function as hazard warning signal flashers must comply with the location requirements when the vehicle's ignition is in either the 'on' or 'off' position. However, it is Mazda's interpretation that hazard warning flashers are not intended to be operational for a period of days, but rather for a period of hours, at maximum, only. You then asked two questions, (1) whether Mazda's understanding of the subject NHTSA interpretation is accurate, and (2) whether Mazda's interpretation of the maximum intended operating duration of hazard warning signal flashers is correct. I note that the February 1985 interpretation was written in the context of a vehicle with a variable height system actuated by hydraulic fluid. In that particular system, the hydraulic pressure relaxed over a period of about three hours after the ignition was turned off, with the result that the vehicle assumed a lower height than it would have during driving. NHTSA stated the following: We believe that the minimum height requirement should be met for any lamp at any time in which it is operated for its intended purpose. Since vehicles at rest do not require use of headlamps, the minimum height requirement would be measured at the point after the ignition is on and when the car begins to travel (your letter implies that the time lag between turning on the ignition and restoration of a complying mounting height is a matter of seconds). On the other hand, the hazard warning signal lamps are frequently operated when the vehicle is stopped, and therefore the minimum mounting height of turn signal lamps, through which they operate, must be met with the ignition off, even if the system requires three hours to deplete itself and lower the vehicle to its minimum height. With respect to your question of whether Mazda's understanding of the interpretation is correct, I would like to note two points. First, while you state that 'the requirements of FMVSS 108' must be met at any time in which lamps, reflective devices, and associated equipment are to be operated for their intended purpose, out interpretation was limited to standard's minimum height requirement. While we are prepared, if asked, to address other requirements, out interpretations should be understood to be limited to their specific facts and conclusions. Second, while our interpretation only addressed headlamps and hazard warning signal lamps, you applied the interpretation for headlamps to tailamps, stoplamps, the license plate lamp, and side marker lamps, and the interpretation for hazard warning signal lamps to reflex reflectors. We concur with this application, with respect to Standard No. 108's minimum height requirement. We do not agree with Mazda's suggested interpretation of the maximum intended operating duration of hazard warning signal flashers. You would apparently like us to conclude that Standard No. 108's minimum height requirement for hazard warning signal flashers does not apply after a vehicle's ignition has been turned off for a matter of days. In addressing how Standard No. 108 applies in the absence of a specification for vehicle height, our February 1985 interpretation differentiates between situations where the vehicle is operating and where it is not. Looking at the purposes of the requirements in question, we believe it is obvious that the minimum height requirement for headlamps is only relevant in situations where the vehicle is operating, while the minimum height for hazard warning signal lamps is also relevant to situations where the vehicle is stopped and the ignition turned off. However, we believe that any determination that Standard No. 108's minimum height requirement for hazard warning signal flashers should not apply after a specified number of hours after the ignition has been turned off is one that would need to be addressed in rulemaking. It is therefore my opinion that the minimum mounting height of hazard warning signal lamps must be met at all heights with the ignition off, even if the system requires days to deplete itself and lower the vehicle to its minimum height. If you believe that a time limitation should be placed on this requirement, I note that you can submit a petition for rulemaking requesting such a change. Standard No. 111, Rearview Mirrors You requested an interpretation of section S5.1.1 of Standard No. 111, which generally requires a passenger car's rearview mirror to 'provide a field of view with an included horizontal angle measured from the projected eye point of at least 20 degrees, and sufficient angle to provide a view of level road surface extending to the horizon beginning at a point not greater than 200 feet to the rear of the vehicle...' You noted that since the specified procedures for determining the location of the driver's eye reference points are made referenced to point with the vehicle's cabin, your active suspension system would not affect these measurements. However, different vehicle heights would be relevant to whether there is a view of level road surface extending to the horizon beginning at a point not greater than 200 feet to the rear of the vehicle. You stated that, based on 'intended purpose,' Mazda's interpretation of Standard No. 111 is that the requirements of this standard are to be met when the vehicle's ignition is in the 'on' position as rearview mirrors are not intended to be used when the vehicle's engine is not operating. You then asked two questions, (1) whether Mazda's interpretation of the requirements of FMVSS No. 111 with respect to the state of the vehicle's switch is correct, and (2) for the purpose of compliance testing to the requirements of FMVSS No. 111, what means of maintaining the intended suspension height for a given speed and operating condition would be satisfactory to NHTSA. We agree that the field of view requirement specified in S5.1.1 for rearview mirrors need not be met for vehicle heights that only occur when the engine is not on, since the requirement is only relevant in situations where the vehicle is operating. However, the requirement would need to be at all vehicle heights that occur during vehicle operation, under the loading conditions specified in S5.1.1. With respect to the issue of how suspension height should be maintained for purposes of compliance testing, you note early in your letter that, for reasons of practicality and safety, a vehicle's engine is not actually operational during compliance testing. However, since the active suspension system derives its power from the vehicle's engine, the system's ability to maintain and regulate suspension height is only possible during engine operation. You therefore indicated that Mazda is seeking guidelines (for several standards) by which Mazda may be able to establish a means to maintain the intended suspension height for compliance testing purposes in the absence of engine operation. We are not able, in an interpretation, to specify a particular means for maintaining suspension height for compliance testing in the absence of engine operation. However, the basic principle that should be followed in selecting a means for maintaining suspension height is that is should not result in different test results than would occur if testing could be conducted with suspension height being maintained by engine operation, i.e., what would happen in the real world. This should be relatively straightforward for section S5.1.1 of Standard No. 111, since the test is static, For a crash test, it is important that a vehicle not be altered in any way that would change the vehicles's crash performance relevant to the aspect of performance being tested. Standard No.204, Steering Control Rearward Displacement In asking about Standard No. 204, you stated the following: Section S4 of this standard specifies the compliance parameter for this standard. Section S5 specifies the testing conditions to determine compliance with this standard. Section S5.1 specifies that the vehicle be loaded to its unloaded vehicle weight. Section S5.5 specifies that the vehicles fuel tank be filled with Stoddard solvent to any capacity between 90 and 95 percent of the total capacity of the tank. Mazda's interpretation of the requirements of this standard is that they are to be met when the vehicle's ignition switch is in the 'on' position only. Furthermore, Mazda interprets the vehicles suspension height pursuant to S5.1 and S5.5 to be the intended suspension height for the vehicle given the conditions of S4, i.e., 30 mph vehicle speed and steered wheels are positioned straight ahead. You then asked whether Mazda's interpretation of the requirements of FMVSS No. 204 are correct. As discussed below, we agree that Standard No. 204's requirements need to be met only at the suspension height that occurs at a 30 mph vehicle speed and with steered wheels positioned straight ahead. Standard No. 204 specifies requirements limiting the rearward displacement of the steering control into the passenger compartment to reduce the likelihood of chest, neck, or head injury. These requirements must be met in a 30 mile per hour perpendicular impact into a fixed collision barrier. While the standard specifies a number of test conditions, it does not specify suspension height. Looking at the Standard No. 204 as a whole, we believe it is clear that NHTSA explicitly decided to limit the standard's evaluation of steering control rearward displacement to how vehicles perform in a 30 mph perpendicular impacts, even though the requirements have relevance at lower and higher speeds. Therefore, we agree that the standard's requirements need to be met only at suspension heights that occur at a 30 mph vehicle speed and with steered wheels positioned straight ahead. With respect to Mazda's question concerning means of maintaining intended suspension height for compliance testing, please see our discussion provided with respect to Standard No. 111. THIS DATABASE WOULD NOT ACCEPT THE COMPLETE LETTER - DUE TO ITS LENGTH. THIS IS PART I. PART II IS ALSO DATED OCTOBER 2, 1990 AND COVERS QUESTIONS ON STANDARDS 208, 301 AND THE BUMPER STANDARD, PART 581. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam1595OpenMr. John H. Mueller, Manager,Engineering Standards,The Weatherhead Company,300 East 131st Street,Cleveland, Ohio 44108; Mr. John H. Mueller Manager Engineering Standards The Weatherhead Company 300 East 131st Street Cleveland Ohio 44108; Dear Mr. Mueller:#Thank you for letter of August 14, 1974, pointing ou a discrepancy in the constriction test requirements for hydraulic brake hose found in Federal Motor Vehicle Safety Standard No. 106-74.#We are considering a change in out nest notice concerning Standard 106-74, so that S6.7.2(c) will conform with S5.3.1 as that paragraph was amended by Notice 11 (39 F.R. 24012).#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam3402OpenMr. William G. Finn, Merchandizing Manager, Continental Products Corporation, 1200 Wall Street West, Lyndhurst, NJ 07071; Mr. William G. Finn Merchandizing Manager Continental Products Corporation 1200 Wall Street West Lyndhurst NJ 07071; Dear Mr. Finn: This is in response to your letter of April 22, 1981, regardin marketing of Continental's ContiContact steel belted mud and snow tire as an all-season tire. You ask whether there are any governing criteria for what constitutes an all- season tire, and, if a tire is advertised as an all-season tire, whether it must be graded under the Uniform Tire Quality Grading (UTQG) Standards. You also ask whether it would be legal to market this tire as an all-season tire.; As you know, deep tread, winter-type snow tires are not within th coverage of the UTQG regulation (49 CFR S575.104(c)(1)). On May 24, 1979, the National Highway Traffic Safety Administration published in the Federal Register its interpretation that all-season tires are not considered deep-tread, winter-type snow tires within the meaning of the regulation (44 F.R. 30139). All-season tires were described in that notice as those with a tread depth which permits safe operation throughout the year. The notice indicated the agency's intention to exempt from the coverage of the standard 'a strictly limited class of tires, the deep tread rubber and tread design of which makes year round use on passenger cars inadvisable.' Thus, a tire offered for sale by its manufacturer or brand name owner as suitable for all-season use could not be considered a deep tread, winter-type snow tire for UTQG purposes.; With regard to the legality of marketing the ContiContact tire as a all-season tire, mud and snow tires must meet Federal safety standards in the same manner as other passenger car tires. Also, a tire not suitable for its intended use could be considered to contain a safety-related defect in performance, construction, or materials, for purposes of the recall authority of Title I, Part B of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1411, *et seq*.). Beyond these limitations, statutes and regulations administered by NHTSA do not restrict the sale of all-season tires.; Sincerely, Frank Berndt, 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.