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
| Interpretations | Date |
|---|---|
| search results table | |
ID: aiam2812OpenMr. Doug Mills, Rt. 1 Box 149, Tellico Plains, TN 37385; Mr. Doug Mills Rt. 1 Box 149 Tellico Plains TN 37385; Dear Mr. Mills: This responds to your recent letter asking additional question concerning the responsibilities of a person converting a pick-up truck into a dump truck, under Federal motor vehicle safety standards and regulations. This office explained the general responsibilities of a person who alters a certified vehicle in a letter to your associate, Mr. Henry Brown, dated February 1, 1978. You now ask questions regarding specific aspects of the conversion operating and whether they can be accomplished without destroying a vehicle's compliance with safety regulations.; Unfortunately, it is impossible for the National Highway Traffic Safet Administration (NHTSA) to answer your specific questions. It is the responsibility of the manufacturer or vehicle alterer to determine whether his vehicle is in compliance with applicable safety standards and to certify that vehicle. The NHTSA cannot review an alteration procedure such as the one with which you are concerned and state that it can or cannot be done in compliance with Federal regulations. There are no safety regulations which require a specific number of bolts or specific bolt locations, for instance. Likewise, Safety Standard No. 301-75, *Fuel System Integrity*, is specified only in terms of performance requirements, so the NHTSA cannot tell you whether a modified fuel filler neck will destroy a vehicle's compliance with the standard.; As stated in our previous letter, a person who alters a pick-up truc to convert it to a dump truck must certify that the truck remains in compliance with all applicable safety standards. Further, the person who makes the conversion must assure that the alterations do not result in any 'safety related defects' whether or not there is a specific safety standard that is applicable. Therefore, you must determine for yourself whether the number of bolts you use, the bolt strengths and the bolt locations will result in safety hazards.; I can answer your question number 8 regarding possible liability fo removal and alteration of the truck bumper. The Federal safety standard for bumpers is only applicable to passenger cars, so you may alter a truck bumper with impunity provided the action does not result in a safety related defect.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam3700OpenMr. Dean A. Fialka, Western Bus Sales, Inc., 311 N.E. 2nd, Gresham, OR 97030; Mr. Dean A. Fialka Western Bus Sales Inc. 311 N.E. 2nd Gresham OR 97030; Dear Mr. Fialka: Ms. Lauretta Carlson of our Regional Office in Seattle has forwarded t us a copy of a letter to you dated April 21, 1983, from the Motor Vehicles Division, Department of Transportation, Oregon, with reference to the 'Conspicuity Package' on school buses. Oregon appears not to approve the white reflectors in this package. Ms. Carlson has asked us to respond directly to you.; The portions of the conspicuity package that trouble Oregon are th eight white reflex reflectors on the rear (installed on the extreme edge of the vehicle to define its height and width), and the seven white reflex reflectors on each side (defining the overall length and height of the bus). The Oregon letter says that the laws of that State allow only red and yellow reflectors to the rear and sides of the vehicle and it finds 'no indication that the white reflex reflectors are approved by the federal code.'; Paragraph S4.1.3 of Federal Motor Vehicle Safety Standard No. 10 permits the installation as original equipment of other lamps and reflectors not specified by the standard provided that the additional equipment does not 'impair the effectiveness' of lighting equipment required by Standard No. 108. The agency therefore has no present basis for concluding that white reflectors 'impair the effectiveness' of red and yellow reflectors and lamps required by Standard No. 108. Thus, under Federal law, a school bus may be manufactured and sold with the white reflectors.; Further, use of white reflectors may aid safety. Although the Nationa Highway Traffic Safety Administration has not conducted research on improving the conspicuity of school buses, it has contracted for a study of that issue with respect to large vehicles of similar sizes such as trucks and tractor-trailer combinations. The preliminary results indicate that outlining the sides and rear of large vehicles with red and white reflex striping is the best way to improve conspicuity, verification awaits field tests which have not been scheduled to date. Use of white reflectors, while not as effective as red and white striping, probably enhances conspicuity.; The use of a bus with these reflectors, however, is subject to Orego law. Although under Federal law a State may not have a vehicle safety standard covering the same aspect of performance as a Federal vehicle safety standard unless it is identical to it, the white reflectors are not required by a Federal standard and are thus subject to regulation by any State in which the school bus is registered.; I hope that this letter provides a satisfactory clarification. Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam2238OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P. O. Box 937, Fort Valley, GA, 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P. O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to several questions raised by Blue Bird Body Compan concerning the applicability of school bus safety standards to certain bus types under the newly-issued redefinition of school bus (40 FR 60033, December 31, 1975). The new definition (effective October 27, 1976) reads:; >>>'School bus' means a bus that is sold, or introduced in interstat commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.>>>; In your February 24, 1976, letter you ask whether buses utilized t transport athletic teams and school bands to and from athletic events qualify as school buses under the definition that becomes effective October 27, 1976, and, if so, whether they must therefore comply with all applicable Federal motor vehicle safety standards.; From your description of the use of an 'activity bus' to transpor students to and from athletic events related to the students' school, it would be included as a school bus under the new definition if it were sold for this use. It appears clear that the manufacturer and dealer in these cases would both be aware that the purchasing school intended to use the bus to transport students to events related to their school, such as athletic events involving school teams. In close cases, the knowledge of parties to the sales transaction would be determinative of whether the bus was 'sold. . . for purposes that include carrying students to and from school or related events. . . .' Any bus determined to be a school bus under the new definition would be required to meet all applicable standards in effect on the date of its manufacture.; Your December 16, 1975, letter asks whether transit buses that ar based on a basic school bus design must meet the requirements of Standard No. 217, *Emergency Exits*, that apply to buses other than school buses. Since receipt of your letter, the redefinition of school bus has been issued and Standard No. 217 has been amended by the addition of requirements for school buses. In answer to your question, only a bus that is sold for purposes that include carrying students to and from school qualifies as a school bus. A bus designed and sold for operation as a common carrier in urban transportation would be required to meet the requirements of Standard 217 for buses other than school buses.; Your separate question regarding the configuration of emergency exit has been answered in an earlier interpretation of the provision you question. A copy of that interpretation is enclosed.; Your March 4, 1976, letter asked whether the new definition of schoo bus includes buses that are sold for transportation of college-age students. You argued that an intent to include buses other than those for the transportation of preprimary-, primary-, and secondary-school students would go beyond the statutory definition added to the National Traffic and Motor Vehicle Safety Act by the Motor Vehicle and Schoolbus (sic) Safety Amendments of 1974 (15 U.S.C. S1391(14)), and apply the standards to a broader variety of vehicles than those for which they were developed. The NHTSA finds this argument to have merit. It therefore withdraws its discussion of the breadth of the regulatory definition of school bus that appeared in the December 31, 1975, preamble. The agency will not consider buses sold for the transportation of college-age students to be school buses.; You also asked if any motor vehicle safety standard requires tha school buses be painted yellow. No motor vehicle safety standard requires yellow paint. At this time, however, Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, requires installation of warning lights, and this would entail the use of yellow paint by the operator under Pupil Transportation Standard No. 17.; In an area unrelated to school bus definition, you asked in a Februar 20, 1976, letter whether the description of vehicle roof appearing in S5.2(b) of Standard No. 220, *School Bus Rollover Protection*, applies to determination of roof size under S5.2(a) and S5.2(b). The description is intended to apply to roof measurement under both S5.2(a) and S5.2(b).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0205OpenMr. C. L. Eshelman, President, Eshelman, Inc., 621 N.E. 30th Terrace, Miami, FL 33137; Mr. C. L. Eshelman President Eshelman Inc. 621 N.E. 30th Terrace Miami FL 33137; >>>Re: Consumer Information--Certification-- Distributions<<< Dear Mr. Eshelman: This is in reply to your letter of December 20, 1969, in which yo responded to our inquiry concerning consumer information on vehicles sold by your company.; You stated that your Golden Eagle cars are 'made from new mode Chevrolets without any mechanical change,' and that the 'consumer information and the warranty book as supplied by General Motors are passed along to the consumer with the vehicle.' You also stated that you place a label next to the GM certification label, quoting language similar to that specified in the Certification Regulations for the distributor who alters a vehicle, 49 CFR S 367.6. We are enclosing a copy of the Certification Regulations: please note that the abovementioned distributor statement, if it is applicable, requires the month and year of alteration to be stated immediately after the name of the distributor.; The question whether the procedure you have outlined in respect t certification is acceptable depends on whether the alterations that you perform on the Chevrolets are sufficiently minor to place you in the category of 'distributor' rather than 'manufacturer'. In order to make this determination, we need and would like to receive more detailed information on the work that you do on the vehicles.; The question whether the practice you describe, of passing on th General Motors consumer information, is acceptable depends on whether the information is actually correct for the vehicles as you alter them. The weight of the final vehicle, for example, is an important factor in the vehicle's performance in all three areas of acceleration, braking, and tire reserve load. We should mention that you are fully responsible, subject to the penalties specified in section 109 of the National Traffic and Motor Vehicle Safety Act, for ensuring that the correctness of the consumer information that you provide with your vehicles is not adversely affected by the work that you do on them, whether you are ultimately placed in the category of manufacturer or distributor.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations; |
|
ID: aiam5007OpenStephen E. Selander, Esq. Legal Staff General Motors Corporation New Center One Building 3031 West Grand Boulevard P. O. Box 33122 Detroit, Michigan 48232; Stephen E. Selander Esq. Legal Staff General Motors Corporation New Center One Building 3031 West Grand Boulevard P. O. Box 33122 Detroit Michigan 48232; "Dear Mr. Selander: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 114, Theft Protection, in connection with an electronic locking ignition system that you are developing. You asked whether an electronic code, which would be entered into the locking system by the vehicle operator to permit operation of the system, would be included within the standard's definition of 'key.' As discussed below, the answer to your question is yes. By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter. You described the operation of your planned locking ignition system as follows. When an electronic code is entered into the locking system by the operator, a match is made with an electronic code stored in the system's memory. When the correct match occurs, the operator may move the locking system out of the 'lock' position to other positions such as 'accessory', 'off,' 'on', or 'start', in order to activate the vehicle's engine, motor, or accessories. You also stated that, with the locking system out of the 'lock' position, the transmission can be shifted out of the 'park' position in order to operate the vehicle. The transmission shift lever must be returned to the 'park' position before the locking system may be put back into the 'lock' position. Placement of the locking system back into the 'lock' position would automatically cause removal of the electronic code from the system. At that time, re-entry of the electronic code would be necessary to operate the vehicle. Section S4.2 of Standard No. 114 requires each vehicle to have a key-locking system that, whenever the key is removed, will prevent-- (a) normal activation of the vehicle's engine or other main source of motive power, and (b) either steering, or forward self-mobility, or both. The term 'key' is defined in S3 of the standard to include 'any other device designed and constructed to provide a method for operating a locking system which is designed and constructed to be operated by that device.' We agree that an electronic code which is entered into a locking ignition system by the vehicle operator to permit operation of the system comes within this definition. For GM's planned system, removal of the key would occur when the locking system is placed back into the 'lock' position by the operator, since the electronic code is automatically removed from the system at that time and the vehicle will not operate unless the code is re-entered. Therefore, under section S4.2, placement of the locking system back into the 'lock' position (i.e., removal of the key) must prevent normal activation of the vehicle's engine and either steering, or forward self-mobility, or both. We note that section S4.5 of Standard No. 114 requires (except under limited specified circumstances) a warning to the driver to be activated whenever the key required by section S4.2 has been left in the locking system and the driver's door is opened. For GM's planned system, activation of the warning would be required (other than under the limited specified circumstances) if a driver opened the door without placing the locking system back into the 'lock' position, since the electronic code (key) would remain in the locking system in that situation. Standard No. 114 also has several other requirements related to keys. Of particular note is one set forth in a new section S4.2.1, which takes effect on September 1, 1992. Under that section, the key-locking system required by S4.2 in each vehicle which has an automatic transmission with a 'park' position must (except under limited specified circumstances) prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. I hope this information is helpful. If you have any additional questions, please contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
|
ID: aiam2668OpenMr. Richard A. Rechlicz, Executive Secretary, Wisconsin School Bus Association, 2830 No. Brookfield Road, Box 403, Brookfield, WI 53005; Mr. Richard A. Rechlicz Executive Secretary Wisconsin School Bus Association 2830 No. Brookfield Road Box 403 Brookfield WI 53005; Dear Mr. Rechlicz: This responds to your August 29, 1977, letter requesting a interpretation of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, that would permit the measurment of seat spacing at any point along the width of the seat back.; The National Highway Traffic Safety Administration (NHTSA) ha previously responded to a similar request for an interpretation of the measurement of seat spacing. I am enclosing a copy of that letter for your information. In that letter, the NHTSA stated that measurement of seat spacing must be made from the seating reference point to the surface of the seat back or restraining barrier, exclusive of portions which protrude from the basic contour of the surface. This interpretation prohibits the measurement of seat spacing from the seating reference point to the side tubing which protrudes from the basic contour of the seat.; The NHTSA has received your second letter requesting rulemaking on th issue of seat spacing. That letter is being treated as a petition for rulemaking and will be processed according to agency rulemaking procedures.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam0655OpenMr. Gary Walters, Walters Company...U.S.A., P.O. Box 3463, Enid, OK 73701; Mr. Gary Walters Walters Company...U.S.A. P.O. Box 3463 Enid OK 73701; Dear Mr. Walters: Thank you for your letter of March 7, 1982, requesting the lates information regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 301, clarification of 'leakage' and comments regarding U.S. Patent No. 3,610,263.; An amendment to FMVSS No. 301 will be issued in the near future i response to the Notice of Proposed Rule Making published earlier, 35 F.R, 13799. The substance of this action involves extending the scope of the rule as indicated in the Notice, but the details of the final amendment will not be disclosed before issue. A copy of the Notice is enclosed.; Paragraph S4.4 does not mention leakage but refers to fuel spillag which is defined in S3. There is no assurance that this proposal will remain intact in the final rule since the comments from the industry, continued research, and development work, and many other inputs will influence the course of this rule making.; We are not in a position to comment of the features of any particula device, since our concern is primarily with performance requirements in order to permit originality and choice of different means for design of improved performance. We appreciate the information about your patented fuel tank safety valve assembly, and shall place a copy of this patent in our Docket No. 70-20. This docket is a public file to receive information and comments on matters pertaining to the rule making action on fuel system integrity.; We appreciate you interest in motor vehicle safety. Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
|
ID: aiam1947OpenMr. Stan Haransky, Truck Body and Equipment Association, 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Truck Body and Equipment Association 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This responds to your request for a determination whether a mobil water tower trailer equipped with air brakes would be subject to the requirements of Standard No. 121, *Air brake systems*.; The answer to your question is yes. From the description supplied t you by Klein Products, the trailer does not appear to qualify for exclusion from the standard.; I would like to advise you that the National Highway Traffic Safet Administration recently proposed exclusion of this vehicle type from Standard No. 121, and we invite the submission of comments from the Truck Body and Equipment Association or Klein Products on our proposal.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2392OpenMr. Bing Johnson, 135 Jade Cove Drive, Roswell, GA, 30075; Mr. Bing Johnson 135 Jade Cove Drive Roswell GA 30075; Dear Mr. Johnson: This is in response to your letter of August 16, 1976, in which you as about our regulations concerning the modification of 'vans' to make them suitable for camping. The modifications you propose to make include the installation of plumbing, water, electricity, and additional seating.; The National Traffic and Motor Vehicle Safety Act (15 U.S.C. SS1381 *et seq*.) prohibits the manufacture, offer for sale, sale, introduction in interstate commerce or importation of a motor vehicle that does not comply with all applicable standards in effect on the date of its manufacture. This prohibition does not apply (except for importation) after the first purchase of the vehicle in good faith for purposes other than resale.; The manufacturer must comply with all applicable safety standard established by the National Highway Traffic Safety Administration (NHTSA). His certification appears on a completed vehicle. It would be your responsibility to ensure that the vehicle continues to comply with all applicable safety standards after your modifications. Under Part 567 of our regulations, you must attach a label to the vehicle that states that, as altered, the vehicle continued to conform to the standards.; From the description of the modification you describe, it appears tha you might affect the compliance of the vehicle with the following standards: Standard No. 207, *Seating Systems*, Standard No. 208, *Occupant Crash Protection*, Standard No. 210, *Seat Belt Assembly Anchorages*, and Standard No. 302, *Flammability of Interior Materials*. It should be noted that any additional weight created by your modifications or a change in the distribution of weight could also affect the vehicle's compliance with other safety standards whose test procedures require a barrier crash test.; We also would point out that if you modify a Ford 'Econoline' in al probability you would change the vehicle classification from a truck to a multipurpose passenger vehicle. This should be noted on the certification label that you attach to the vehicle.; I have enclosed an information sheet that explains where you may obtai copies of these regulations.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
|
ID: aiam5457OpenMr. Bruce Monnie Senior Designer Advanced Design Associates Tigard, OR 97223; Mr. Bruce Monnie Senior Designer Advanced Design Associates Tigard OR 97223; "Dear Mr. Monnie: This responds to your letter asking about Federa requirements for a product you have developed to improve the securement of child safety seats. You stated that the product is a one-piece steel bracket which 'is installed on the seatbelt of the vehicle, to prevent slippage between the lap and shoulder portions of the seatbelt and to tighten up slack in the lap portion of the seatbelt.' You indicated that the product would be installed on a temporary basis and that it would be sold in the 'aftermarket' to persons owning child restraint systems. You request an interpretation of whether Standards No. 209, 213, or any other standard would apply to your device. By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. The agency does not approve, certify or endorse any vehicles or equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet all applicable standards. The following represents our opinion based on the facts provided in your letter. There is currently no Federal motor vehicle safety standard that would apply to your product. It appears from your description of the product that it would be a type of device that we call a 'locking clip.' A locking clip is a bracket into which a vehicle's lap and shoulder belt webbing is threaded. A locking clip tightens the webbing around a child safety seat and prevents the safety seat from moving easily. We have no safety standard that applies to locking clips. Standard 209 sets forth requirements for new seat belt assemblies. However, since your product would not be installed as part of a new seat belt assembly, the standard would not apply. Standard 213 is our standard for child restraints. It applies to 'any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less' (S4 of Standard 213). Since your device would not itself restrain, seat or position a child, it would not be a child restraint system. Therefore, Standard No. 213 would not apply to your product. While no FMVSS applies to your product, your device is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. 30118-30121 concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 49 U.S.C. section 30122, which prohibits them from installing the device if the installation 'makes inoperative' compliance with any safety standard. It appears unlikely from the nature of your product that it would be placed in vehicles by commercial businesses instead of child restraint owners. However, if your product were to be installed by persons in those categories, they must ensure that its installation does not compromise the safety protection provided by a child restraint system or the vehicle belt system. The prohibition of section 30122 does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Please note that we have a concern about the possible misuse of your device. Our safety standards require specific levels of performance for a vehicle's safety belt system. For example, Standard 208 has requirements that ensure that a vehicle's lap and shoulder belts are installed to distribute the crash forces over the skeletal structure of the occupant. The safety standards also have requirements for belts to automatically lock and retract. Your device attaches to the belt system, and will stay in place until the consumer removes it. Since it attaches to the belt system, it could affect the ability of the system to protect an adult occupant, or a child restrained without a child safety seat. We suggest that you provide clear instructions to the consumer to remove the device from the belt webbing when the belt system is used without a child restraint system. In closing, I note for your information that NHTSA published a final rule in October 1993 requiring the safety belts in new motor vehicles to be capable of tightly securing child safety seats, without the necessity of the user's attaching any device, such as a locking clip, to the seat belt webbing, retractor, or any other part of the vehicle. The rule applies to vehicles manufactured on or after September 1, 1995. I have enclosed a copy of the rule. I hope this information has been helpful. If you have any other questions, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosures"; |
|
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.