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: aiam4437OpenMr. Doug Cole National Van Conversion Association, Inc. 2 West Main St., Suite 2 Greenfield, IN 46140; Mr. Doug Cole National Van Conversion Association Inc. 2 West Main St. Suite 2 Greenfield IN 46140; "Dear Mr. Cole: This responds to your letter asking about the tes procedures of Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials. I regret the delay in responding. In your letter, you explained that the National Van Conversion Association (NVCA) gathers samples of materials used for vehicle floor coverings, seat covers, etc., in van conversions to determine the compliance of the material with Standard No. 302. In your test program, you have found that many samples do not appear to comply. You said that a closer look at the conditions under which these samples were tested revealed that use of support wires affected whether many materials passed or failed the standard's test. You ask for clarification as to when support wires are used in Standard No. 302 testing. The conditions and procedures under which Standard No. 302 compliance testing is conducted using support wires are stated in paragraphs S5.1.3 and S5.3(a) of the standard. Basically, these two paragraphs specify, respectively, that support wires are used: (1) when testing a specimen 'that softens and bends at the flaming end so as to cause erratic burning,' to keep the specimen horizontal, and (2) when testing a specimen that has an available width of not more than 2 inches, to position and mount the specimen on the U-shaped frames used in the test. Standard No. 302 makes no provision for using the wires other than in these two situations. The agency follows the test procedure specified in Standard No. 302 when testing vehicles for compliance with the requirements of the standard. The agency uses heat-resistant wires as specified in S5.1.3 when there is a reasonable expectation that a test specimen will bend or curl while burning. NHTSA bases its determination about the likelihood of bending or curling on observations made in previously-conducted compliance tests of the specimen, or on the agency's knowledge of or testing experience with materials similar to a test specimen. I would like to point out that manufacturers are not required by Standard No. 302 to test the flammability of their vehicles in only the manner specified in the standard. The standard only sets the procedure that the agency will use in its compliance testing. Thus, a manufacturer is not required to use wires only with specimens that are anticipated to bend or curl, or that are too small to fit in the test frame without wires. However, manufacturers must exercise due care in making their certification of compliance that their product will meet the standard's requirements when tested by the agency according to the specified procedures of the standard. Whether a manufacturer meets that due care standard when using heat-resistant wires in situations other than those described in Standard No. 302 is a matter that can be determined only in the context of an enforcement proceeding. Please contact us if you have any further questions. Sincerely, Erika Z. Jones Chief Counsel /"; |
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ID: aiam3258OpenMr. J. W. Lawrence, Manager, Reliability & Government Standards, White Motor Corporation, 35129 Curtis Boulevard, Eastlake, OH 44094; Mr. J. W. Lawrence Manager Reliability & Government Standards White Motor Corporation 35129 Curtis Boulevard Eastlake OH 44094; Dear Mr. Lawrence:#This responds to your letter of January 15, 1980 which requested an interpretation of Federal Motor Vehicle Safety Standard No. 101, *Controls and Displays*. You described a control to be included in heavy duty truck tractors which would operate the cab marker lights and some of the trailer lamps and asked whether Safety Standard 101 would permit labeling of the control with the words 'marker lamps.'#We have concluded, for the reasons stated below, that Safety Standard 101 would not permit the control to be labeled in the fashion you suggest. However, it would permit labeling of the control with the symbol for clearance lamps designated therein accompanied by the words 'Clearance Lamps' or the abbreviation 'Cl Lps' and by the words 'marker lamps.'#With respect to vehicles including trucks with gross vehicle weight ratings exceeding 10,000 pounds manufactured before September 1, 1980, S4 of Safety Standard 101 permits manufacturers to comply with its requirements or with those of Safety Standard 101-80. S4.2.1 of Safety Standard 101 requires that a control which operates clearance lamps, identification lamps and/or side marker lamps be identified with the words 'Clearance Lamps' or the abbreviations 'Cl Lps' as shown in Table I Column 2 of the standard. In addition, S4.2.1 provides that such a control may also be identified by one of the symbols for clearance lamps shown in Columns 3 and 4 of Table I. (See Table I, Footnote 3.) S5.2.1 of Safety Standard 101-80 requires that such a control be labeled with the symbol for clearance lamps shown in Column 3 of Table I of the standard. However, this symbol may be accompanied by the word or abbreviation shown in Column 2 (i.e., Clearance Lamps or Cl Lps) and additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. (See Table I, Footnote 3.) The requirements of Safety Standard No. 101-80 will become mandatory and will supercede those of Safety Standard 101 for all vehicles to which it applies which are manufactured on or after September 1, 1980.#According to your product description, the control which you propose to label with the words 'marker lamps' would operate some of the trailer lamps and the cab marker lamps which also serve as clearance lamps. Thus, the control would be considered to operate clearance lamps and marker lamps and would be subject to the provisions of Safety Standard 101, Table I, Footnote 3. Accordingly, on vehicles manufactured *before* to September 1, 1980, the control you propose either must be identified in one of the following methods:#>>>1. with the words 'CLEARANCE LAMPS' or the abbreviations 'CL LPS', or#2. with the words or abbreviations shown in method number 1 above accompanied by the symbol shown in Column 3 of Table I or by the symbol shown in Column 4, Table I, of Safety Standard No. 101, or#3. with the symbol for clearance lamps shown in Column 3, Table I, of Safety Standard 101-80, or#4. with the symbol noted in method number 3 above accompanied by the words 'clearance lamps' or the abbreviations 'Cl Lps' as shown in Column 2 of Table I of Safety Standard 101-80, or#5. with the symbol and the words or abbreviations noted in method number 4 above accompanied by any additional clarifying words or symbols the manufacturer may choose.<<<#If the control you have proposed is included in vehicles manufactured on or after September 1, 1980, it must be identified as indicated in method number 3 above and may be identified as indicated in method number 4 or 5 above. Use of method number 5 above would permit use of the words 'marker lamps' in addition to the required symbol and the words 'Clearance Lamps' or the abbreviation 'Cl Lps.'#I hope that you will find this response helpful and have not been inconvenienced by our delay in sending it to you.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam1265OpenMr. Gene J. Shapiro, The Temple Building, Suite 707, Seventy-seven West Washington Street, Chicago, IL 60602; Mr. Gene J. Shapiro The Temple Building Suite 707 Seventy-seven West Washington Street Chicago IL 60602; Dear Mr. Shapiro: This is in reply to your letter of August 28, 1973, concerning Federa Motor Vehicle Safety Standard No. 218, 'Motorcycle Helmets.' You request information regarding the American National Standards Institute (ANSI) Standard Z90.1, and all existing State standards or regulations requiring the use of headgear by motorcyclists.; First, it appears you may be under the impression the Z90.1 standar and its revisions were issued by the Federal Government. This is not the case. Although the requirements of Federal Motor Vehicle Safety Standard No. 218 are largely, though not entirely, based on the Z90.1-1971 Standard published by the American National Standards Institute, the Institute is a private organization neither sponsored nor supported by the Federal Government. You will have to write to the ANSI if you want any information concerning the Z90.1 standard and its revisions.; You may obtain the existing State standards or regulations requirin the use of headgear by motorcyclists from the Department of Motor Vehicles in each State, respectively. However, it may interest you to know that any State or local requirements for the design or performance of motorcycle helmets, that have a bearing on safety, will have to be identical to the requirements of the Federal standard when the Federal standard goes into effect.; A copy of Standard No. 218 and a copy of the National Traffic and Moto Vehicle Safety Act of 1966, are enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4067OpenMr. Benjamin R. Jackson, Executive Director, Automobile Importers Compliance Association, 1607 New Hampshire Avenue, N.W., Washington, DC 20009; Mr. Benjamin R. Jackson Executive Director Automobile Importers Compliance Association 1607 New Hampshire Avenue N.W. Washington DC 20009; Dear Mr. Jackson: This responds to your letter requesting an interpretation of 49 CF Part 541, *Federal Motor Vehicle Theft Prevention Standard*. Specifically, you noted that section 541.5(d)(2)(iii) requires the original equipment parts on vehicles subject to the theft prevention standard to have the required markings entirely within the target area specified for the part by the original manufacturer of the vehicle. You stated that it was possible that target areas specified by the original manufacturer might be suitable for marking by means of labels, but not suitable for marking by means of inscription. If this situation were to occur, you asked if Part 541 could be interpreted to permit manufacturers that must mark by means of inscription to place those markings outside the target area designated by the original manufacturer. Part 541 cannot be so interpreted.; In the case of inscribed markings, S541.5(d)(2)(iii) specifies that th required markings shall be 'placed entirely within the target area specified by the original manufacturer for that part.' This requirement applies to *all* markings inscribed for the purposes of Part 541, whether done by an original manufacturer or a direct importer.; The policy bases underlying this requirement were explained at lengt in the preamble to the final rule establishing Part 541. *See* 50 FR 43166, at 43172, October 24, 1985. First, it is important that all parts be marked in the same target area so that investigators will know exactly where to look on a part for the required marking. The investigator would be alerted to possible suspicious activity if the marking were outside the target area. Second, the different target areas for original equipment and replacement parts marking are intended to ensure that there will be an adequate separation between the areas where the different types of parts will be marked. This will ensure that a thief cannot obliterate an original equipment part marking and affix a counterfeit replacement part marking directly over the area where the original equipment part marking was located.; Both of these purposes would be undercut if original manufacturers an direct importers were allowed to designate different target areas for marking vehicles in the same line. Accordingly, Part 541 explicitly requires only one target area for the required marking on each part of a covered line.; We do not believe that your concern about inscribing markings on curve surfaces is well- founded. The agency knows of a number of means of inscribing numbers on curved surfaces that would permit direct importers to mark those surfaces within the $15 cost limit set forth in section 604(a)(2) of the Cost Savings Act.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4572OpenThe Honorable Howard Wolpe U.S. House of Representatives Washington, D.C. 20515; The Honorable Howard Wolpe U.S. House of Representatives Washington D.C. 20515; "Dear Mr. Wolpe: Thank you for your letter to former Secretary Burnle on behalf of your constituent, Mr. Dennis Furr of Lansing, Michigan. I've been asked to respond to your letter since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety. Mr. Furr is concerned about the potential safety problems that may result if school bus seats are being overloaded. In particular, Mr. Furr asks whether NHTSA's Highway Safety Program Guideline (HSPG) No. 17, Pupil Transportation Safety (23 CFR /1204.4), is consistent with Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222), with regard to seating specifications. Mr. Furr is particularly interested in how manufacturers are calculating the number of seating positions on a bench seat. I am pleased to address your constituent's concerns. Before I begin, I want to note that we have answered a number of similar inquiries from Mr. Furr in past years. We have two sets of 'regulations' for school buses. The first, issued under the Vehicle Safety Act, includes our motor vehicle safety standards which apply to the manufacture and sale of new school buses. Compliance with these standards is mandatory for new vehicle manufacturers, and is enforced by this agency with civil penalties. FMVSS No. 222, with which your constituent is concerned, is one such safety standard. The second set of 'regulations,' or guidelines, for school buses was issued under the Highway Safety Act. Guidelines issued under this Act are not mandatory for the states, rather, they are recommended practices. Highway Safety Program Guideline No. 17, to which Mr. Furr frequently refers in his letter, consists of recommendations to the States for operating their school buses and pertains to Federal funding of State highway safety programs. Both FMVSS No. 222 and Guideline No. 17 contain specifications for school bus seating. Paragraph S4.1 of FMVSS No. 222 states: 'The number of seating positions considered to be in a bench seat is expressed by the symbol W, and calculated as the bench width in inches divided by 15 and rounded to the nearest whole number.' The guideline for seating accommodations in HSPG 17 states: Seating should be provided that will permit each occupant to sit in a seat in a plan view lateral location, intended by the manufacturers to provide seating accommodation for a person at least as large as a 5th percentile adult female, as defined in 49 CFR 571.3. Mr. Furr appears to see a conflict between the formula used in calculating the forces to be applied to the seats of large school buses under FMVSS No. 222, on the one hand, and the use by States and manufacturers of 13-inch seating positions for rating the capacity of a 39-inch seat, on the other hand. I believe that Mr. Furr's belief in the existence of a conflict rests on a misunderstanding. We view Standard No. 222 and HSPG 17 as complementary, not inconsistent. HSPG 17 reflects NHTSA's belief that all school bus passengers should be seated in the interest of safety. To that end, the guideline provides that there should be a seating position for each passenger and that the position should be at least large enough to accommodate a 5th percentile adult female. The hip width (sitting) of a 5th percentile adult female is 12.8 inches. The figure '15' in FMVSS No. 222's compliance formula is not a minimum requirement for the width of a seating position. It is the number which is used to establish the number of designated seating positions and ensures that the forces applied to the seat during compliance tests are reasonable reflections of the crash forces that would be involved in a real-world crash. It is also the number which ensures that the width of the smallest seat is approximately equal to the hip width of the 5th percentile female. That is consistent with HSPG 17 which provides that seating positions shall be at least large enough for a 5th percentile female. Use of the figure '15' in the FMVSS No. 222 formula results in a minimum seating position width of 12.67 inches (for a 38-inch wide seat.) That is only slightly smaller than the 12.8 inch hip width of the 5th percentile female. For a 39-inch wide seat, the single position width is 13 inches, which is slightly larger than the hip width of a 5th percentile female. It should be remembered, however, that the number of seating positions derived from the FMVSS No. 222 formula is not meant to be a measure of the absolute capacity of the bus for all size occupants. We recognize that, in practice, school buses transport a tremendously wide variety of student sizes. For example, a bus that may be capable of easily accommodating 65 preschool or elementary students may be capable of carrying only 43 high school students. When the bus is used to transport students of widely varying ages and sizes, reasonable accommodations may vary between those values. The decision on how many passengers may be comfortably and safely accommodated, therefore, is a decision that must be reached by the bus operator, in light of the ages and sizes of passengers involved. NHTSA does not have the authority under either the Highway Safety Act or Vehicle Safety Act to regulate how States use school buses. Therefore, NHTSA could not preclude a State from carrying more passengers on a bench seat than there are designated seating positions. However, this agency agrees with Mr. Furr that a student should not sit on a seat unless the student can sit fully on the seat instead of sitting only partially on the seat and thus only being partially protected by the compartmentalization. We believe that Mr. Furr's concerns as they apply to public schools would be best addressed by his working with the local school board and state officials. Mr. Furr is also concerned about a reference in our occupant crash protection standard (No. 208) to a 95th-percentile adult male occupant size. He asks why FMVSS No. 222 uses a 15-inch seat dimension, when FMVSS No. 208 references the 95th-percentile adult male occupant size in specifying occupant sizes which safety belts must adjust to fit. Both FMVSS No. 208 and FMVSS No. 222 are directed at providing occupant crash protection. Both of these standards set forth comprehensive requirements that are directed at protecting occupants likely to be inside a vehicle in a crash. With regard to school buses, the agency determined that the crash protection requirements should be developed taking into account the full size range of passengers typically riding on school buses. If we designed the force and deflection (energy-absorbing) characteristics of the seats for the 95th percentile males, the seats may be too stiff for a small child. Finally, Mr. Furr asks whether, when voluntarily installing safety belts on large school buses, States are violating Federal law by using S4.1 of FMVSS No. 222 in determining how many positions (and belts) there are on a bench seat. The answer is no. FMVSS No. 222 requires safety belts only for the passenger positions of small (10,000 pounds or less GVWR) school buses. Under S5 of the standard, belts on a small school bus bench seat are installed at 'W' seating positions, as determined under S4.1. If a State wishes to order belts on its new large school bus and to use the same method for determining the number of belts to be installed, the State may do so. I hope this information is helpful. If you have any further questions, please do not hesitate to contact me. Sincerely, Diane K. Steed"; |
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ID: aiam1770OpenMr. Alberto Negro, Director Fiat,Research & Development,Parklane Towers West,One Parklane Boulevard,Dearborn, Michigan 48126; Mr. Alberto Negro Director Fiat Research & Development Parklane Towers West One Parklane Boulevard Dearborn Michigan 48126; Dear Mr. Negro:#This responds to your December 30, 1974, questio whether the requirements if S5.3.2 of Standard No. 105/75, *Hydraulic brake systems*, would be satisfied by the use of a 4- to 8-second activation of the brake indicator lamp, activated when the ignition switch is placed in the 'on' position. S5.3.23 requires:#>>>S5.3.2 All indicator lamps shall be activated as a check of lamp function either when the ignition (start) switch is turned to the 'on' (run) position when the engine is not running, or when the ignition (start) switch is in a position between 'on' (run) and 'start' that is designated by the manufacturer as a check position.<<<#A 4- to 8-second activation when the ignition switch is placed in the 'on' position as a check of brake indicator lamp function would satisfy the requirements if S5.3.2.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4088OpenGrace Cheng, Yue Loong Motor Engineering Center, P.O. Box 510, Taoyuan, Taiwan 330, REPUBLIC OF CHINA; Grace Cheng Yue Loong Motor Engineering Center P.O. Box 510 Taoyuan Taiwan 330 REPUBLIC OF CHINA; Dear Ms. Cheng: Thank you for your letter of February 5, 1986, concerning th requirements of Standard No. 208, *Occupant Crash Protection*. You asked whether S4.1.2.3.1(a) of the standard requires a vehicles with a manual, nondetachable Type 2 seat belt assembly that conforms to Standard No. 209, *Seat Belt Assemblies*, to meet the frontal crash protection requirements of S5.1 in a perpendicular impact.; The answer is that such a Type 2 safety belt system currently does no have to meet the frontal crash protection requirements of the standard. However, we have recently set 30 mph frontal crash protection requirements for manual Type 2 safety belts used in the frontal outboard seating positions in future passenger cars. The dynamic test requirement for manual safety belts would go into effect on September 1, 1989, if the automatic restraint requirement of Standard No. 208 is rescinded. A copy of the notice on dynamic testing of manual safety belts is enclosed.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0862OpenMr. J. Richard Schlen, Schlen Body and Equipment Co., P. O. Box No. 229, Carllnville(sic), IL 62626; Mr. J. Richard Schlen Schlen Body and Equipment Co. P. O. Box No. 229 Carllnville(sic) IL 62626; Dear Mr. Schlen: This is in reply to your letter of September 22 to Mr. Ed Leysath o this Office regarding interpretations of FMVSS No. 108 on required mounting of marker lights on your dump trailers.; In answer to your first problem, a combination front clearance and sid marker lamp must meet the requirements for both, therefore, the full 180-degree visibility is required. If you determine that it is not practicable to mount the combination lamp in your alternate location, because of a greater possibility of damage, then separate lamps should be considered.; In answer to your second problem, because of the configuration and en use of your dump semi-trailers, your interpretation that rear clearance lamps mounted in a light box just below the rear trailer crossmember are as high as practicable is correct.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam4122OpenThe Honorable Ralph Davenport, South Carolina Legislature, P.O. 1301, Spartanburg, SC 20394; The Honorable Ralph Davenport South Carolina Legislature P.O. 1301 Spartanburg SC 20394; Dear Mr. Davenport: This is to follow up on your phone conversation with Stephen Oesch o my staff concerning the effect of Federal regulations on the tinting of motor vehicle windows. I hope the following discussion answers your questions.; Some background information on how Federal motor vehicle safety law and regulations affect the tinting of vehicle windows may be helpful. Our agency is authorized, under the National Traffic and Motor Vehicle Safety Act, to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. We have issued Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70% in areas requisite for driving visibility, which includes all windows in passenger cars).; You first asked if the Federal motor vehicle safety standards apply t foreign vehicles sold in the United States. As with all our standards, Standard No. 205 applies to any new vehicle, whether made by a foreign or domestic company, manufactured for sale in the United States. Thus, no manufacturer or dealer is permitted to install solar films and other sun screen devices, such as the one described in your letter, in *new* vehicles without certifying that the vehicle continues to be in compliance with the light transmittance and other requirements of the standard. Violation of Standard No. 205 can result in Federal civil penalties of up to $1,000 for each violation. In addition, a manufacturer of a vehicle that does not comply with our standards is required to remedy any noncompliances in its vehicles.; You also asked how Federal law affects businesses that tinted th windows of used vehicles. After a vehicle is first sold to a consumer, modifications to a vehicle are affected by section 108(a)(2)(A) of the Vehicle Safety Act. That section prohibits commercial businesses from tampering with safety equipment installed on a vehicle in compliance with our standards. Thus, no dealer, manufacturer, repair business or distributor can install a sun screen device for the owner of the vehicle, if the device would cause the window not to meet the requirements of Standard No. 205. Violation of the section 108(a)(2)(A) can result in Federal civil penalties of up to $1,000 for each violation.; Section 108(a)(2)(A) does not affect vehicle owners, who may themselve alter their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, the owner may install sun screening devices regardless of whether the installation adversely affects the light transmittance. Individual States govern the operational use of vehicles by their owners and therefore it is within the authority of the States to preclude owners from using sun screens in their vehicles.; If you need further information, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1320OpenJ. B. H. Knight, Rolls-Royce Motors Limited, Car Division, Crewe Cheshire CWI, 3PL England; J. B. H. Knight Rolls-Royce Motors Limited Car Division Crewe Cheshire CWI 3PL England; Dear Mr. Knight: This is in reply to your letter of October 16, 1973, requesting clarification of S7.2 of Federal Motor Vehicle Safety Standard No. 301 (9-1-75) (Docket No. 70-20, Notice 2).; As you are aware, a proposed amendment to Federal Motor Vehicle Safet Standard No. 301 (9-1-75) was published on August 20, 1973 with an anticipated September 1975 effective date (Docket No. 73-20, Notice 1). In the event that the proposed amendment of loading conditions is adopted, the present passenger car requirement, that the vehicle be at its GVWR during testing, will be superseded by the requirement that the passenger car be loaded 'to its unloaded vehicle weight plus its rated cargo and luggage capacity weight, secured in the luggage area, plus the weight of the necessary dummies.' under these specifications, rear sear occupant weight will not be a factor of the test load condition unless a specific test requirement calls for dummies to be placed in designated rear seating positions. The proposed amendment would also make it unnecessary to firmly fix the dummies to the vehicle as is presently the case under S7.2.; We have also noted your views on luggage capacity weight and ar placing your letter in Docket No. 73-20 as a comment to be considered.; If you require any further clarification, please do not hesitate to le us know.; Sincerely, Lawrence R. Schneider, 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.