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: aiam2117OpenHonorable Jamie L. Whitten, House of Representatives, Washington, D.C. 20515; Honorable Jamie L. Whitten House of Representatives Washington D.C. 20515; Dear Mr. Whitten: This is in further reply to your letter of October 3, 1975, for Mr Charles Russel of WJLJ, regarding tire failures on ambulances in Tupelo, Mississippi.; Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 the Department's National Highway Traffic Safety Administration (NHTSA) has issued Federal Motor Vehicle Safety Standard No.109, 49 CFR 571.109, which specifies performance and labeling requirements for new tires for use on passenger cars. Among the labeling requirements is that such tires must have their load ratings molded into or onto both sidewalls. Standard No. 119, 40 CFR 571.119, establishes similar requirements for new tires for use on trucks, buses, trailers, motorcycles, and multipurpose passenger vehicles (MPV's). The choice of standard applicable to a given tire depends on that tire's primary intended use. These standards apply to tires, and not to vehicles.; To ensure that new vehicles are equipped with proper tires, the NHTS has also issued Standard No. 110 for passenger cars and a proposed new Standard No. 120 that would apply to vehicles other than passenger cars. Briefly, Standard No. 110 requires each new passenger car to be equipped with tires which meet Standard No. 109 and which are of sufficient load carrying capacity, as evidenced by the load ratings found on the sidewalls. As proposed, Standard No. 120 would require MPV's (including ambulances) to be equipped with tires which meet either Standard No. 109 or No. 119, and which are of sufficient load carrying capacity. In the case of Standard 119 tires, sufficiency of load carrying capacity would be calculated directly from the tires' load ratings. In the case of Standard 109 (passenger car) tires mounted on an MPV, sufficiency would be determined by dividing the tire load ratings by a 110 percent correction factor before comparing these ratings with the vehicle's weight ratings. The use of passenger car tires on new ambulances would thus not be prohibited by the new standard, provided this load rating correction factor is applied. This provision would recognize an established practice which has not been found to present a safety hazard. Passenger car tires generally provide a softer, more comfortable ride than truck tires, because the latter operate at higher inflation pressures, and thus may even more desirable on ambulances, provided they are of adequate load carrying capacity. The NHTSA expects to issue Standard No. 120 in the near future.; For your convenience, I am enclosing copies of Standards Nos. 109, 110 119, and the proposed Standard No. 120.; Sincerely, William T. Coleman, Jr. |
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ID: aiam4610OpenAIR MAIL; AIR MAIL; "Mr. R. Yamauchi Seat Belt Engineering Department Nippon Seiko K.K. 12 Kirihara-cho Fujisawa, JAPAN Dear Mr. Yamauchi: This responds to your letter asking for an interpretation of Standard No. 209, Seat Belt Assemblies (49 CFR /571.209). I regret the delay in responding. Your questions concerned a seat belt assembly that is designed with a dual mode retractor. The retractor for this system generally functions as an emergency locking retractor (ELR). However, the retractor can be converted to an automatic locking retractor (ALR) to facilitate securing a child restraint at that seating position. The retractor converts from an ELR to an ALR when the webbing is completely extended. The retractor converts back to an ELR when most of the webbing has been retracted. You posed the following questions. 1. Is this retractor considered an ELR? If so, is it required to comply with the performance requirements for ELR's, or is it required to comply with the performance requirements for both ELR's and ALR's? Response: Your letter did not provide sufficient information to allow us to answer this question. However, in a July 3, 1984 letter to Mr. Donald Schwentker, we explained the criteria we use to determine whether a dual mode retractor such as you described is considered an ELR or an ALR for the purposes of our safety standards. To briefly restate the criteria, section S4.1(g) of Standard No. 209 specifies adjustment requirements for all seat belt assemblies. We examine the functioning of the retractor during normal operation by occupants within the weights and dimensions set forth in S4.1(g)(3) of Standard No. 209. If 100 percent extension of the webbing is likely to occur during normal operation of the belt assembly by those occupants (thereby converting the retractor into an ALR), the retractor would be considered an ALR. If during normal operation of the belt assembly by the specified occupants the retractor would function exclusively as an ELR, the retractor would be considered an ELR. Using these criteria, the length of the webbing used in the belt assembly will ultimately determine whether a dual mode retractor would be considered an ELR. If the webbing is long enough that a 95th percentile adult male would not extend the webbing 100 percent during normal operations (including fastening and unfastening the belt or leaning forward to adjust the radio or other controls on the instrument panel), the retractor would operate exclusively as an ELR and would be treated as such for the purposes of our safety standards. If, on the other hand, normal operations by a 95th percentile adult male would result in 100 percent extension of the webbing, the retractor would be considered an ALR for the purposes of our standards. Your letter did not provide any information about the length of the webbing to be used in the belt assembly, so we cannot offer any opinion about whether the retractor for the belt assembly would be considered an ELR or an ALR. 2. You noted that section S5.2(k) of Standard No. 209 requires that ELRs be subjected to 45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension. You stated if dual mode retractors were treated as ELRs, this requirement would present serious problems, since 100 percent webbing extension would convert the retractor to an ALR and the subsequent retraction to 50 percent extension would not convert the retractor back to an ELR. Hence, when the webbing returned to 50 percent extension after 100 percent extension, the retractor would be an ALR. In this mode, the retractor would lock the webbing at 50 percent extension and no further cycles would be possible. To avoid this problem, you asked if you could test the retractor by subjecting it to 45,000 additional cycles between 0 percent extension and 100 percent extension. You asserted that this testing should be permitted, because it is a more stringent test of the retractor. Response: This question may reflect a misunderstanding of the differing responsibilities imposed on a manufacturer that is certifying compliance with a safety standard and on the agency when it is testing for compliance with a safety standard. You, as a manufacturer, are not required to conduct testing before certifying that your belt assemblies comply with Standard No. 209. Instead, the National Traffic and Motor Vehicle Safety Act requires that you exercise 'due care' in making such certifications. It is up to the manufacturer in the first instance to determine what data, test results, computer simulations, engineering analyses, or other information it needs to enable it to certify that each of its products comply with all applicable safety standards. If a manufacturer chooses to conduct testing, the manufacturer is free to modify any or all parts of the test procedure specified in the standard, provided that the manufacturer can show that the results obtained using these modified test procedures are sufficient to satisfy the 'due care' standard. You have the responsibility in the first instance to decide whether the substitution of an alternative test is sufficient to establish due care in making certifications based on this modification of the standard. This determination involves assessing whether the results of the alternative test procedure are good predictors of the results of the test procedure specified in the standard. When the agency conducts its compliance testing, however, it is required to follow the compliance tests specified in the applicable standard. Thus, the agency would not substitute cycles between 0 and 100 percent extension for the cycles between 50 and 100 percent extension that are specified in Standard No. 209. If this retractor were treated as an ELR for purposes of Standard No. 209, applying the criteria set forth above in response to your first question, we would test the retractor solely as an ELR. To do this, we would disengage or disconnect the features that convert the retractor to an ALR at 100 percent webbing extension. The retractor would then be tested in accordance with the procedures set forth in S5.2(k) of Standard No. 209. I hope this information is helpful. Please let me know if you have any further questions or need additional information on this subject. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1412OpenMr. W. G. Milby, Project Manager, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Project Manager Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of December 19, 1973, asking whethe Blue Bird may use the manufacturing date of incomplete vehicles it manufactures, to be completed at a later time, as the date by which conformity to applicable safety standards is to be determined. You indicate that Blue Bird manufactures both incomplete and complete vehicles.; The Certification and Vehicles Manufactured in Two or More Stage regulations (49 CFR Parts, (sic) 567, 568) allow only final-stage manufacturers to certify conformity to applicable standards as of the manufacture date of an 'incomplete vehicle.' A person who manufactures the entire vehicle, including the chassis, is not a final-stage manufacturer within the intent of the regulation, and such a vehicle must be certified as of the date of its completion.; Part 568 clearly intends that multistage vehicles will be manufacture by more than one party. As your letter points out, the documentation required by Part 568 is unnecessary when only one manufacturer is involved. Moreover, the justification in the regulations for allowing a final-stage manufacturer to utilize the manufacture date of the incomplete vehicle is based partially on the fact that he has no control over the configuration of the incomplete vehicle, and that the incomplete vehicle manufacturer has no control over when and how the vehicle is completed. This justification does not exist when a single party builds the entire vehicle.; To permit a manufacturer of a complete vehicle to choose a date othe than the completion date for purposes of conformity would present this agency with serious enforcement problems. Which standards would apply would depend on how 'separate' were a single company's manufacturing operations. Due to the endless possibilities that may arise in this regard, it is difficult to envision fair and objective critieria (sic) by which this decision could be made. Finally, providing the relief you request would allow a manufacturer to avoid compliance with a forthcoming standard by manufacturing large numbers of incomplete vehicles for completion by him at a later time.; You should note that the legal status of Parts 567 and 568 is unclear due to the recent Court decisions in the *Rex Chainbelt* case. You will encounter no problems, however, by continuing to follow the regulations until further agency action is taken.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4240OpenThe Honorable Ted Stevens, United States Senate, Washington, DC 20510; The Honorable Ted Stevens United States Senate Washington DC 20510; Dear Senator Stevens: Thank you for your letter on behalf of your constituent, Ms. Bridge Ernst, regarding our regulations for safety belts on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.; In her letter to you, Ms. Ernst enclosed materials issued by th National Coalition for Seat Belts on School Buses which explained why the Coalition believes safety belts should be required by Federal law on all school buses. You asked us to discuss the main counter-arguments against such a requirement, and asked also whether any Federal legislation has been introduced recently to increase the safety requirement on school buses. I am pleased to respond.; I would like to begin with some background information on our schoo bus regulations. The National Traffic and Motor Vehicle Safety Act of 1966 authorizes NHTSA to issue motor vehicle safety standards for new motor vehicles, including school buses. Pursuant to that authority, NHTSA issued a comprehensive set of motor vehicle safety standards to improve school bus safety. Our school bus safety standards apply to various aspects of vehicle performance, including school bus windows and windshields, emergency exits, fuel systems and passenger seating and crash protection.; The safety belt issue your constituent raises involves the safet standard we issued for school bus passenger crash protection, Federal Motor Vehicle Safety Standard No. 222. Standard No. 222 requires that large school buses provide passenger crash protection through a concept called 'compartmentalization.' Compartmentalization requires that the interior of the school bus be improved with protective seat backs, additional seat padding, and better seat spacing and performance. These interior features are intended to keep occupants in their seating area during an accident. They ensure that a system of crash protection is provided to passengers independent of their actions to use safety belts. Standard No. 222 requires safety belts for passengers in smaller school buses since belts are needed on those vehicles to provide adequate crash protection.; The information from the Coalition that Ms. Ernst enclosed in he letter to you states that safety belts are needed on all school buses to protect children and keep them within their seating compartment in the event of a collision or rollover. We believe that effective passenger crash protection and containment is already provided by compartmentalization and that it would be inappropriate to issue a Federal mandate for safety belts on all school buses. While the effects of compartmentalization are expected to be greater in crashes involving front or rear impacts, the standard also has potential in side impacts and rollovers by minimizing the 'hostility' of the crash environment and by limiting the range of movement of an occupant in those two types of crashes.; For your information, I have enclosed a DOT report, 'Seat Belts i School Buses' (June 1985), which provides a thorough discussion of the safety belt issues raised by your constituent. As explained in the report, school buses in this country have compiled an excellent safety record. In addition to meeting compartmentalization requirements, large school buses incorporate more safety by virtue of their greater mass, higher seating height and high visibility to other motorists. Thus, the need for safety belts to mitigate against injuries and fatalities is not the same as that for other vehicles, such as passenger cars. Because the safety record of large school buses is very good, we must conclude that a Federal requirement for the installation of safety belts is not justified at this time.; The Coalition's material enclosed by Ms. Ernst included a statemen indicating that NHTSA 'supports local district seat belt programs.' NHTSA permits the voluntary installation of safety belts for passengers on large school buses if the purchaser wishes to have belts installed. We believe that such a decision should be made by individual schools and school districts that have made a reasoned assessment of their particular pupil transportation needs. However, because there are many effective ways to improve pupil transportation safety, such as improving driver training and school bus maintenance programs, it would be inappropriate for us to endorse local district programs for safety belts on school buses. Therefore, for purposes of clarification, we neither support nor discourage school districts' decisions to install safety belts on their large school buses.; You asked about any Federal legislation that had been recentl introduced to increase the safety of school buses. The Administration has not proposed any legislation affecting school buses. However, two bills were introduced in the 99th Congress concerning school buses. H.R. 3129 contained a provision calling for a school bus safety study to determine the measures most effective in protecting the safety of school children. H.R. 749 proposed incentive grants to the States encouraging the adoption and enforcement of laws requiring the use of safety belts in school buses. Neither H.R. 3129 nor H.R. 749 was enacted.; In addition, NHTSA has issued a notice of proposed rulemaking to amen Standard No. 222 by setting performance requirements for safety belts voluntarily installed in large school buses. If adopted, this rule would require safety belts voluntarily installed on new large school buses to meet Federal safety belt standards for strength and proper installation.; We are evaluating the comments submitted on our proposal and a fina decision on the rulemaking action is expected in the near future.; I hope this information is helpful. Please contact my office if we ca be of further assistance.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3585OpenMr. Ron Gustafson, Furudals Buruks Kursinternat, 790 70 FURUDUAL Sweden; Mr. Ron Gustafson Furudals Buruks Kursinternat 790 70 FURUDUAL Sweden; Dear Mr. Gustafson: This responds to your letter of June 28, 1982, asking abou requirements applicable to child restraints sold in the United States as well as any necessary permits or licenses. You also asked about any U.S. testing organizations, procedures or standards for child restraints.; All child restraints sold in the U.S. must conform with the minimu performance requirements of Federal Motor Vehicle Safety Standard No. 213, *Child Restraint Systems*. The standard also sets out the test procedures that are used to measure the performance of child restraints. There are no other performance requirements or test procedures applicable to child restraints. I am enclosing a copy of the standard.; You are not required to obtain a permit or license from this agenc prior to selling a child restraint in the U.S., nor are you required to obtain approval from any U.S. testing organization. As a manufacturer of motor vehicle equipment, you are required by Part 566, *Manufacturer Identification*, of our regulation to submit certain identifying information to the agency. I have enclosed a copy of Part 566.; In addition, you would be required by the National Traffic and Moto Vehicle Safety Act (15 U.S.C. S1392 *et seq*.) to certify that your child restraint complies with all applicable Federal Motor Vehicle Safety Standards. Under the Act, you would also be responsible for conducting a notification and remedy campaign for any safety-related defect in your product. I am enclosing a copy of the Act, which defines your responsibilities as a manufacturer.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1042OpenMr. John W. Griffin, Sr., 109 Lakemont Drive, Augusta, GA; Mr. John W. Griffin Sr. 109 Lakemont Drive Augusta GA; Dear Mr. Griffin: This is in response to your letter of February 27, 1973, concerning th effective date of the new Federal odometer law.; The provisions of the law (Public Law 92- 513) went into effect o January 18, 1973, with the exception of the disclosure requirements, which were implemented by regulations adopted by this agency effective March 1, 1973.; The regional office of the National Highway Traffic Safet Administration nearest to you is in Atlanta. The address is Lawrence E. Thompson, Regional Administrator, NHTSA, Suite 400, 1720 Peachtree Road, N.W., Atlanta (sic) Georgia 30309.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5001OpenMs. Anne Volmerange 11041 Vena Ave. Mission Hills, CA 91345; Ms. Anne Volmerange 11041 Vena Ave. Mission Hills CA 91345; "Dear Ms. Volmerange: I have been asked to respond to your letter t Mr. Clarke Harper of our Rulemaking division. Your letter requests authorization from NHTSA to replace the automatic two point shoulder belt installed in your vehicle with a manual lap/shoulder belt. I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (the Safety Act, 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. NHTSA has exercised this authority to establish Standard No. 208, Occupant Crash Protection (49 CFR 571.208). Standard No. 208 sets forth requirements for safety belt installation in all vehicle types. In addition, S4.1.4.1 of Standard No. 208 provides that passenger cars manufactured on or after September 1, 1989 must be equipped with automatic crash protection. Vehicles equipped with automatic crash protection protect their occupants by means that require no action by vehicle occupants. Compliance with the automatic crash protection requirements of Standard No. 208 is determined in a dynamic crash test. That is, a vehicle must comply with specified injury criteria, as measured on a test dummy, when tested by this agency in a 30 mph barrier crash test. At this time, manufacturers are not required to use a specific design of automatic crash protection to meet the requirements of Standard No. 208. Instead, each automobile manufacturer is allowed to select the particular design for the automatic crash protection installed in its vehicles. The two types of automatic crash protection currently offered on new passenger cars are automatic safety belts (which help to assure belt use) and air bags (which supplement safety belts and offer some protection even when safety belts are not used). There are several different designs of automatic belts available, and many manufacturers are installing air bags accompanied by conventional manual lap/shoulder safety belts. Based on your description, it appears that the manufacturer of your vehicle has chosen to install diagonal automatic shoulder belts at the front outboard seating positions. The manufacturer has certified that, in a 30 mph frontal crash into a concrete barrier, a test dummy restrained only by the automatic belt in your car would not experience injury-producing forces in excess of the levels specified in Standard No. 208. After a vehicle equipped with automatic crash protection has been sold to a retail purchaser, such as yourself, the provision in Federal law that affects modifications to the automatic crash protection system is section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section provides that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard. With regard to your vehicle, the automatic safety belts are a 'device or element of design installed in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard.' Removal of the automatic belts would render them inoperative. Therefore, Federal law prohibits your dealer, any other dealer, and any manufacturer, distributor, or motor vehicle repair business from removing the existing automatic belts in your car and replacing them with manual belts. Please note that this Federal prohibition does not prevent you from removing the automatic belts from your own car. However, we encourage vehicle owners not to tamper with the occupant protection systems installed in their vehicles. If you were to remove the automatic belts yourself and improperly install manual belts, you would be putting yourself and other vehicle occupants at substantially greater risk of injury in a crash. 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"; |
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ID: aiam0203OpenMr. 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--Distributons (sic)<<< 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 that 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 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 paced in the category of manufacturer or distributor.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Assistant Chief Counsel fo Regulations; |
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ID: aiam2394OpenMr. 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. SS 1381 *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. Under these provisions, you are responsible for the compliance of any vehicle that you modify up to and including the time of first purchase 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 modifications 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 |
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ID: aiam5451OpenMr. Joe Kover 463 West Creekside Lane Kaysville, UT 84037; Mr. Joe Kover 463 West Creekside Lane Kaysville UT 84037; Dear Mr. Kover: This responds to your letter of July 25, 1994, to Jer Medlin of this agency. You have presented several questions regarding an electric circuit that you have designed for use in motor vehicles, and which you call a Light Control Unit (LCU). The LCU automatically turns off the headlamps and tail and parking lamps when the ignition is turned off if the lamps have been activated. The LCU also automatically turns on the headlamps and the tail and parking lamps whenever the windshield wipers are turned on. If the LCU fails when the lights are on, a Light Bus Monitor will automatically restore them. You have the following questions: 'Would a motor vehicle operator be in violation of the federal motor vehicle safety standards by maintaining both the head and tail/park lights on during the hours of daylight?' No. The Federal motor vehicle safety standards do not tell an owner when it is or is not permissible to use safety equipment. 'Does the LCU meet the federal motor vehicle safety standards? Could the LCU be integrated into the light system of new production vehicles or currently registered vehicles,' The Federal motor vehicle safety standard on lighting, Standard No. 108, does not apply to supplementary lighting devices such as the LCU. The LCU is permissible on new vehicles provided it does not impair the effectiveness of lighting equipment required by the standard. We do not see that it has this effect. It is permissible to be installed on currently registered vehicles by manufacturers, distributors, dealers or motor vehicle repair businesses provided that it does not make inoperable any part installed in accordance with a Federal motor vehicle safety standard. We do not see that the LCU has this effect either. You have also told us that the LCU may be used to operate lamps as Daytime Running Lamps (DRLs) by maintaining the light switch in the on position when the wiper switch has been turned off. One feature of this function is that the LCU 'allows the operator to turn off either the head lights only or both the head lights and tail/park lights via the light switch.' Your question is 'If the operator should elect to employ the LCU as a DRL unit does it meet the federal motor vehicle safety standards?' Under Standard No. 108, a DRL system is a system of any pair of lamps on the front of a vehicle (other than parking lamps or fog lamps) that is automatically activated and that is automatically deactivated when the operator places the headlamp control in the on position. Further, DRLs can be lower beam headlamps operated at full voltage. Assuming that the LCU turns the lower beam headlamps on rather than the upper beam ones, your system would function as a DRL meeting the requirements of Standard No. 108 when the lower beam headlamps are automatically activated by the windshield wipers and deactivated by turning off the ignition. However, the feature that allows the headlamps to be turned off manually (whether or not simultaneously turning off the parking lamps and taillamps) is not part of a DRL system as specified by Standard No. 108. Your final request is that we 'include the federal specifications for electronic devices.' We are unsure what you mean by this as we have no 'specifications for electronic devices.' I enclose a copy of S5.5.11 of Standard No. 108, the DRL specifications. Sincerely, Philip R. Recht 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.