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 |
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ID: aiam1846OpenHonorable Hubert H. Humphrey, United States Senate, Washington, DC 20510; Honorable Hubert H. Humphrey United States Senate Washington DC 20510; Dear Senator Humphrey: This responds to your letter of March 4, requesting consideration o Mr. Robert Bjorklund's view that Federal standards require disc brake systems on pick-up and 1-ton trucks.; There is no Federal motor vehicle safety standard which requires dis brakes on trucks or any other vehicles. The only brake standard applicable to trucks at this time is Standard No. 121, *Air brake systems*, and this standard is limited to the performance of trucks which the manufacturer chooses to equip with air brakes. Mr. Bjorklund describes his vehicles as pick- ups and 1-ton trucks, which to our knowledge, are equipped only with hydraulic brake systems. Therefore they are not subject to any Federal brake performance standard.; We conclude that the manufacturers of these vehicles have made th decision that their products should be equipped with disc brakes.; Sincerely, William H. Marsh, Executive Secretary |
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ID: aiam2293OpenMr. Gilbert Theissen, 6S Hayden Hall, 33 Washington Square West, New York, NY 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York NY 10011; Dear Mr. Theissen: This is in response to your letter of February 5, 1976, to Mrs Winifred Desmond of this agency concerning braking and rollover characteristics of the Jeep vehicle. We are sorry for the delay in our answer.; The Jeep Corporation is correct in saying that 49 CFR 571.105-75 *Hydraulic Brake Systems*, applies only to passenger cars. It will also apply to school buses manufactured after October 25, 1976. Part 575, Consumer Information Regulations, applies as a whole to all motor vehicles (49 CFR 575.4), but the consumer information item requiring reports on brake performance is limited to passenger cars and motorcycles (49 CFR S 571.101).; With regard to rollover resistance, the agency has issued an advanc notice of proposed rulemaking to collect information on rollover resistance, but no requirement to report on rollover performance exists at this time.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam5556OpenK. Howard Sharp, Esq. Arnason Law Office P.O. Box 5296 Grand Forks, ND 58206-5296; K. Howard Sharp Esq. Arnason Law Office P.O. Box 5296 Grand Forks ND 58206-5296; "Dear Mr. Sharp: We have received your letter of May 12, 1995 requesting an interpretation of Motor Vehicle Safety Standard No. 108 on behalf of your client, NYTAF Industries. You are concerned that installation of a NYTAF lighting system on the rear of trailers might be considered to impair the effectiveness of the required rear lighting equipment within the meaning of paragraph S5.1.3. The NYTAF Auxiliary Rear Lighting System NYTAF has developed 'an auxiliary signaling system for heavy duty vehicles' which 'displays a verbal message appropriate to the particular potential hazard.' According to Exhibit A of your letter, a draft information brochure, the specific words displayed are: 'Wide Turn', 'Braking', 'Wide Load', 'Caution', 'Help', 'Backing', and 'Long Load'. In addition, right and left facing arrowheads indicate the direction of turning. Drivers cannot alter these messages or program the system to accept personal messages. The brochure depicts the message unit 'on the rear of the trailer frame directly below the trailer body in the center putting the display panel on approximately the same horizontal plane as the tail lights and brake lights.' Words are provided by light-emitting diodes (L.E.D.). According to your letter, the L.E.D. display 'is somewhat more intense than existing brake lights, turn and tail lamps.' Exhibit B 'Operation Summary' explains how the system operates with respect to each message, e.g., 'Braking' is 'activated and illuminated in conjunction with brake lights.' Applicable Requirement of Standard No. 108 Paragraph S5.1.3 of Standard No. 108 states that 'No additional lamp, reflective device or other motor vehicle equipment shall be installed before first purchase of a vehicle in good faith for other than resale that impairs the effectiveness of lighting equipment required by Standard No. 108 .' Prior Interpretations of S5.1.3 Relating to Message Boards In the past, the agency has advised that the determination of impairment is initially made by the manufacturer of the motor vehicle on which the supplementary equipment is installed, when it certifies that the vehicle complies with all applicable Federal motor vehicle safety standards. Unless that determination is clearly erroneous, NHTSA will not question it. Thus, NHTSA's interpretations are generally cautionary in tone rather than prohibitive. I enclose copies of two interpretations relating to message boards intended for the rear parcel shelves of passenger cars. The first is a letter of August 17, 1989, to Alan S. Eldahr ('Eldahr'). The relevant language of Eldahr is that a rear window message board 'sending messages unrelated to vehicle stops, could confuse and distract a driver following, and in that sense impair the effectiveness of the center lamp.' The second is a letter dated August 13, 1993, to Kenneth E. Ross ('Ross'). The Ross letter discusses the relation of message boards to the aftermarket, as well as the notification and remedy obligations which would fall upon NYTAF as a manufacturer of automotive accessory equipment. Relationship of Eldahr to NYTAF Eldahr indicates that there is less possibility of impairment existing if the message visible to a following driver is related to the lamp function that occurs simultaneously, as happens, for example in the NYTAF system, when stop lamp activation is accompanied by the word 'Braking.' We suggest that vehicle manufacturers installing the NYTAF system follow this guideline in their determinations of whether impairment exists. NYTAF might also wish to reconsider the intensity of the L.E.D. display which you say is 'more' than that of the existing rear lighting equipment, especially as it may affect reaction to the stop signal. The intensity should not be so great as to divert driver attention to the message rather than to the stop signal. There are several areas of Exhibit B 'Operation Summary' which require more specific comment. 'Caution' is activated in conjunction with the hazard warning system. Standard No. 108 requires these systems to simultaneously flash all turn signal lamps, and not sequentially as Exhibit B states. Exhibit B should be corrected to reflect this if it is to be distributed publicly, as we do not understand that the NYTAF system is intended to create sequential flashing of turn signals when operated in the hazard signal mode. The sole explanation of 'Help' is that it is to be activated manually. In our view, a flashing 'Help' while the trailer is in motion would be more likely to impair rear lighting equipment than if it is operable only when the trailer is at rest. In addition, Exhibit B does not indicate whether the 'Help' message is overridden by other messages when related lighting systems are activated. We are unsure of the purpose of 'Clearance Marker' which is operated 'in conjunction with parking lights.' Standard No. 108 does not require truck tractors to be equipped with parking lamps. We believe that you meant taillamps. We do not view this lamp as having an impairing effect upon the taillamps. The name of the lamp is somewhat misleading, as it would be mounted at the center of a vehicle whereas a 'clearance lamp' is intended to indicate a vehicle's overall width. Additionally, on certain trailer designs the three identification lamps are mounted around the vertical centerline in the same location in which you have stated the NYTAF system will be mounted. With respect to the close proximity of the two lighting systems, we believe that the brightness of the NYTAF device compared with that of the identification lamps could impair their ability to signal the presence of a large vehicle in the roadway ahead, the intended function of these lamps. Finally, we note that the color red would indicate a backing function. Although trailers are not required to have backup lamps, Standard No. 108 specifies that the color white shall be used for backup lamps, and we believe that the public has come to associate an activated white lamp on the rear of a vehicle as indicating that the vehicle is in reverse gear. Your client may wish to reevaluate this function in light of possible liability concerns. We hope that these guidelines will be helpful to NYTAF. If you have any further questions, Taylor Vinson will again be happy to answer them (202-366- 5263). Sincerely, John Womack Acting Chief Counsel 2 Enclosures"; |
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ID: aiam5043OpenMr. Peter E. Reinert Counsel - Transaction General Electric Company One Plastics Avenue Pittsfield, MA 01201; Mr. Peter E. Reinert Counsel - Transaction General Electric Company One Plastics Avenue Pittsfield MA 01201; "Dear Mr. Reinert: This responds to your letter requesting a interpretation of Standard No. 205, Glazing Materials (49 CFR 571.205). Specifically, you asked about the certification and marking responsibilities of your company, General Electric (GE), and your distributors under section S6 of Standard No. 205. This interpretation is based on my understanding of the statements in your letter as well as statements made by GE's representatives Mr. Timothy Commons and Mr. Bruce Torry in a July 8, 1992 meeting with Mr. Clark Harper of this agency's Office of Vehicle Safety Standards and Mr. Marvin Shaw of my staff. We understand that GE manufactures large sheets of LEXAN polycarbonate which are used in both motor vehicle and non-vehicle applications. You explained that under a contractual agreement with GE, your distributors have agreed to mark the LEXAN sheet with GE's manufacturer code mark and the symbol DOT (which you refer to as the DOT number). In other words, GE is sending LEXAN sheets without the manufacturer code mark and the symbol DOT to its distributors who then mark the sheets with this information before shipping them to their motor vehicle customers. You asked whether shipping LEXAN sheets without the manufacturer code mark and symbol DOT to GE's distributors is consistent with GE's responsibilities as a prime glazing material manufacturer having its own DOT number. I note that Mr. Commons and Mr. Torry raised additional questions about GE's certification responsibilities under Standard No. 205. Specifically, they questioned whether GE was a manufacturer of raw material rather than a prime glazing material manufacturer, and if GE were not a prime glazing material manufacturer, whether each of GE's distributors would be required to mark the LEXAN sheets with its own DOT number rather than GE's number. Your company's questions are addressed below. Standard No. 205 specifies performance requirements for glazing for use in motor vehicles. Section S6 of Standard No. 205 establishes marking and certification requirements for manufacturers and distributors of glazing materials. Different marking and certification requirements apply depending upon whether an entity is a prime glazing material manufacturer or a manufacturer that cuts sections of glazing material to which Standard No. 205 applies. Further distinction in certification requirements for prime manufacturers depends on whether the glazing is designed for use in a specific motor vehicle or camper, or whether the glazing is designed to be cut into components for use in motor vehicles or items of motor vehicle equipment. None of the marking and certification requirements would apply to manufacturers of raw materials. Section S6.1 defines a 'prime glazing material manufacturer' as 'one who fabricates, laminates, or tempers the glazing material.' If an entity performs any one of these operations, it must comply with the marking and certification requirements set forth in S6.1 through S6.3 of Standard No. 205. Before addressing the question posed in your letter, I will respond to your representatives' question concerning whether GE might be a manufacturer of a raw material and thus not be subject to Standard No. 205's marking and certification requirements. In support of this view, they stated that distributors frequently undertake what they termed significant fabricating operations (e.g., drilling, routing, and polishing the glazing) beyond merely cutting the glazing, and thus in such situations should be considered the 'prime glazing material manufacturer.' Notwithstanding your representatives' contentions, we consider GE to be the prime glazing material manufacturer in the situation at hand. GE's activities involve a fundamental manufacturing operation that constitutes fabrication of glazing. In contrast, the distributor's operations, though arguably more extensive than mere cutting, constitute relatively minor finishing operations to an item of glazing that has been fabricated by another company. Since GE fabricates the glazing, it is the prime glazing material manufacturer under S6.1. This determination renders moot your representatives' follow-up question about the distributor's marking responsibilities if GE were not a prime glazing material manufacturer. I will now summarize the marking and certification requirements that apply to GE, as a prime glazing material manufacturer, and to its distributors. S6.1 requires every prime glazing material manufacturer to mark all glazing materials it manufactures with the following information in accordance with section 6 of the American National Standard (ANS) Z26: (1) the words 'American National Standard' or the characters 'AS,' (2) a number identifying the item of glazing, (3) a model number assigned by the manufacturer that identifies the type of construction of the glazing material, and (4) the manufacturer's distinctive designation or trademark. In addition to the information required by S6.1, if an item of glazing material is designed to be used in a specific motor vehicle, then S6.2 requires each prime glazing material manufacturer to certify such an item of glazing with the symbol 'DOT' and a manufacturer's code mark assigned by this agency. The purpose of requiring the manufacturer's code mark is to help NHTSA identify the actual manufacturer of the glazing material for the purpose of defect and noncompliance recall campaigns. Section S6.3 requires each prime glazing material manufacturer to certify compliance with Standard No. 205 for each piece of glazing designed to be cut into components for use in motor vehicles pursuant to the requirements of section 114 of the Safety Act. Under section 114, certification of an item of glazing 'may be in the form of a label or tag on such item or on the outside of a container in which such item is delivered.' Sections S6.4 and S6.5 set forth requirements that apply to each manufacturer or distributor who cuts a section of glazing material to which Standard No. 205 applies for use in a motor vehicle or camper. Section S6.4 requires the manufacturer or distributor to mark that material in accordance with section 6 of ANS Z26. Section S6.5 requires the manufacturer or distributor to certify that its product complies with Standard No. 205, pursuant to section 114. You asked whether shipping LEXAN sheets without GE's manufacturer code mark and the symbol DOT to GE's distributors is consistent with GE's responsibilities as a prime glazing material manufacturer that has its own DOT number. Under the above requirements, the only type of glazing that a prime glazing material manufacturer is required to mark with its manufacturer code mark and the symbol 'DOT' is glazing designed as a component of a specific motor vehicle or camper. GE, as a prime glazing material manufacturer, is not required to mark glazing with the symbol 'DOT' and its manufacturer's code mark if such glazing is not designed as a component of a specific motor vehicle or camper. As for sheets of glazing that a manufacturer or distributor will cut into components for motor vehicles, GE and GE's distributors may contractually agree to have the distributor mark the LEXAN sheets and glazing cut from such sheets with GE's manufacturer code mark. However, there is no requirement for either GE or its distributors to so mark the glazing. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam2786OpenMr. Donald L. Fowler, Ullman, Fowler & Jeffries, Inc., 2231 Devine Street, Columbia, SC 29205; Mr. Donald L. Fowler Ullman Fowler & Jeffries Inc. 2231 Devine Street Columbia SC 29205; Dear Mr. Fowler: This responds to your March 6, 1978, letter asking about the complianc responsibilities of a final-stage manufacturer who mounts a body on a motor vehicle chassis. In the situation you describe, the chassis would have been tested for compliance with the standards by the chassis manufacturer and the body would have been tested by the body manufacturer. You ask whether the final assembler would be required to crash test the vehicle as assembled.; The chassis manufacturer has responsibilities for compliance wit Federal safety standards that are outlined in Part 567, *Certification*, and Part 568, *Motor Vehicles Manufactured in Two or More Stages*, of our regulations. The chassis manufacturer must include with its chassis an incomplete vehicle document that describes how to complete the vehicle without impairing the compliance of the chassis with Federal safety standards. Although not required by our regulations, body manufacturers often provide documents addressing the compliance of their vehicle bodies with applicable safety standards. If a body that complies with Federal standards is mounted in accordance with the instructions of the incomplete vehicle document, the final-stage manufacturer can ordinarily assume that the completed vehicle complies with the safety standards. Based upon this assumption, it can certify that the vehicle complies with all applicable standards.; By following the instructions of the incomplete vehicle manufacture and relying upon the statements of the body manufacturer, the final-stage manufacturer would be considered to have exercised due care in ensuring that the vehicle complies. However, if the final-stage manufacturer does not follow the incomplete vehicle manufacturer's instructions or in some way makes a major modification that would affect the compliance of the vehicle, it might become necessary for it to undertake some further testing to ensure continued compliance. The amount of further testing, in these instances, would depend upon the extend of modification of the vehicle body or chassis.; For your information, our safety standards and regulations are locate in Volume 49 of the Code of Federal Regulations Parts 501 *et seq*. I am enclosing a sheet which details the applicability of Federal standards to various vehicles.; If after reading this letter, you still have questions that require meeting, contact Roger Tilton of my staff.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3894OpenMr. Bernt Svensson, Marketing Director, Viskafors Gummifabrik AB, Box 2059, S-515 02 Viskafors, SWEDEN; Mr. Bernt Svensson Marketing Director Viskafors Gummifabrik AB Box 2059 S-515 02 Viskafors SWEDEN; Dear Mr. Svensson: This responds to your letter to Ms. Kathleen DeMeter of my staff asking for information on how to get a new temporary spare tire size included in the tire tables following Standard No. 109, * New Pneumatic Tires -- Passenger Cars* (49 CFR S571.109). The agency rescinded tire tables in Standard No. 109 in a final rule published at 46 FR 61473, December 17, 1981. I have enclosed a copy of that rule together with a current copy of Standard No. 109 for your records.; Section S4.4.1 requires tire manufacturers to provide a listing of th rims that may be used with each tire size it produces. Section S4.2.1(c) requires a tire's load rating be the load rating for that size specified in a submission under S4.4.1. This may be provided by the manufacturer in a document furnished to each of the manufacturer's dealers, to this agency, and to the pubic upon request. Alternatively, the manufacturer may use the data for that tire size shown in a current publication of one of the standardization organization listed in S4.4.1(b). Your company will have to use one of these two means of complying with this requirement, instead of relying on the tire tables, as was formerly done.; The current publication of the American standardization organizatio the Tire & Rim Association) shows no listing for the tire size about which you inquired. It is possible that the size is listed by one of the other standardization organization of your choosing or submit the data directly to this agency, all your dealers and the public, upon request.; Should you have any further questions on this matter, please contac Mr. Stephen Kratzke of my staff at this address.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0241OpenMr. Richard Alexander, Capitol Tire Distributors, 2837 North Tecome Street, Indianapolis, Indiana 46218; Mr. Richard Alexander Capitol Tire Distributors 2837 North Tecome Street Indianapolis Indiana 46218; Dear Mr. Alexander: This is in reply to your letter of June 6, 1970, asking if you ar violating the National Traffic and Motor Vehicle Safety Act, or, regulations issued pursuant to it, if you distribute tires marked seconds.; Neither the Act nor the regulations prohibit the sale of tires marke seconds. manufacturers are required to certify that their product complies with Federal motor vehicle safety standards and do so by labeling each tire they certify with the symbol 'DOT'. Tires that are certified by the manufacturer and marked 'seconds' are not necessarily unsafe, as the 'second' may de due to a cosmetic defect not affecting the tire's performance. In such cases, the distributer of the tire would not be in violation of the act.; Sometimes a tire manufacturer will make a tire that he believes i defective in a way that affects the safety of the tire. Often, that manufacturer will mark the tire 'farm use only' or 'non-highway use' and then sell it. In such instances, he is supposed to remove the dot symbol. Enclosed is a copy of a notice of proposed rulemaking dealing with this problem which may be of interest to you or your members.; Thank you for your interest in the motor vehicle safety program. Sincerely, Lawrence R. Schneider, Assistant Chief Counsel, Regulation |
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ID: aiam5413OpenMr. Richard J. Quigley 5886-b Fernflat Road Aptos, CA 95003; Mr. Richard J. Quigley 5886-b Fernflat Road Aptos CA 95003; Dear Mr. Quigley: This responds to your request for an interpretatio of whether a drawing you provided would meet S5.6.1(e) of Standard No. 218, Motorcycle helmets, that specifies motorcycle helmets be labeled with the symbol DOT. The answer is no. Your drawing, approximately 2 cm. high, consists of three figures that you believe are the symbol 'DOT.' For the letter 'D,' the right side of the letter is not curved, but is formed by a series of jagged lines at the top and bottom of the letter that meet in a straight line parallel to the line that forms the left side of the 'D'. In lieu of the letter 'O,' your drawing depicts what appears to be a corporate logo, with a cartoon eagle inside a circle, and the name of a company written on the circle. The letter 'T' is formed like a conventional 'T,' with straight sides. S5.6.1(e) of Standard No. 218 specifies the symbol DOT: (e) ... This symbol shall appear on the outer surface, ... in letters at least 3/8 inch (1 cm) high, ... (Emphasis added.) Because the symbol DOT constitutes the manufacturer's certification that the helmet conforms to Standard No. 218, there must be no ambiguity in the symbol. In your drawing, the corporate logo is clearly not the letter 'O'. Using the corporate logo in lieu of the letter 'O' may confuse consumers and others as to whether the manufacturer has certified the helmet as conforming with Standard No. 218. Thus, the drawing you have provided does not meet S5.6.1(e) of Standard No. 218. If you have any questions, please contact Ken Weinstein of my staff at (202) 366-5263. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0611OpenMr. K. Krueger, Technical Development, Liaison Engineer, Volkswagen of America, Inc., Englewood Cliffs, NJ, 07632; Mr. K. Krueger Technical Development Liaison Engineer Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Krueger: This is in reply to your letter of December 6, 1971, in which you as several questions regarding the test procedures of Standard No. 302, 'Flammability of Interior Materials,' and list certain components asking whether they are subject to the standard. While we indicated to you in our letter of February 17, 1972, that we are considering amendments to the standard which affect the questions you raise, we are responding, because of the limited time remaining before the standard becomes effective, to your questions based on the standard as presently written, indicating where appropriate, those areas where modifications may be made.; The three questions you raise regarding the test procedures of th standard are restated in part below, followed by our response.; >>>1. How is a part whose largest dimension is less than one inch an which is subject to the requirements of S4.1 to be tested under S5? You state that many small parts of Volkswagens would fall through the wire grid if required to be tested.; If a component fits the criteria of S4.1, it is required to meet th standard's requirements regardless of its size. In testing, however, manufacturers are not required to follow the procedures set forth in the standard, but may modify those procedures as long as results obtained can be correlated sufficiently that the manufacturer can show he exercised due care in attempting to meet the requirements. In the case of components that are too small to be supported by the wire grids, we believe manufacturers would be free to space the wire grids so that, at the very least, the component can be supported, and still avail themselves of a due care defense. One other alternative, although not as easily correlated to the standard, would be to test samples of the material of which the component is manufactured in sizes large enough to be supported by the test device as described in the standard.; 1(a). If the specimen held in the frame offers less than 1.5 inches o material from its open end to its clamped end, does it have to be tested under MVSS 302?; The answer to this question is similar to the one above. There is n exemption for small components in the standard. However, minor modifications to the test procedure may be made without jeopardizing the ability of a manufacturer to demonstrate, should the need arise, that he has exercised due care. In this case, we believe that a manufacturer could begin timing before the flame had traveled 1.5 inches, or again, could test larger samples of the material of which the component is made.; 1.(b). If a small specimen held in the frame offers less than 2 inche of material for progression of the flame after timing has begun, and if the material stops burning before it has burned for 60 seconds from the start of timing, does it meet the requirements of S4.3?; The provisions of S4.3 that you refer to are intended to reflect th performance of samples described in the test procedures of S5. These requirements are intended to provide an exemption for self-extinguishing materials, and not to exempt small samples that are consumed by fire before two minutes elapse. The standard establishes burn-rate requirements, and manufacturers should keep this in mind in determining whether particular components comply. If your component is such that it is consumed by fire because of its size before the two-minute period, then we would expect modifications to the procedure, of a nature described above, to be made in order that a determination of the burn rate of the material is obtained.; 2. 'We do not understand the applicability requirements of S4.1 specifically the latter part of the paragraph which states, ' . . ., and any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.'' You then list certain components and ask whether they fall within the quoted language.; This provision is presently under review by NHTSA, and may be modifie in the amendment to be published in the near future. Any such change may also affect the problems you appear to have in testing very small components, as indicated by your previous questions. However, as presently written, the phrase refers to those components which are in fact designed to be energy absorbing. This determination must be made by the manufacturer, based upon the design of his vehicles. It does not appear to us that any of the components you list would necessarily fall within the quoted language.; The list you provide includes numerous gaskets, or gasket-typ components such as (a) windshield gasket, (b) side door insulating rubber, (c) door gaskets, (h) rubber boots at base of gear shift and hand brake levers, (l) gaskets for sliding sun roof, and (m) gasket between steering column and firewall. If these items are not within the above-quoted language of S4.1, we would not consider them to be covered by any other language of that paragraph.; With reference to the open truck compartments in Type 2, Type 3, an Type 411 vehicles (your paragraph (d)), we consider areas in passenger vehicles where occupants can ride, such as the rear of station wagons, to be within the occupant compartment, and the components listed in S4.1 that appear in these areas must meet the requirements.; With reference to paragraph (e), we would consider the battery cover if it is part of the floor, to be a floor covering within S4.1 However, we do not consider electric cables (f) to be within any of the enumerated items of S4.1. In addition, the brake fluid reservoir (g) would only be included if it is within the 'any other interior materials . . .' language of S4.1.<<<; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1903OpenMr. John C. Latzer, Mobilefreeze Co., Inc., P.O. Box 691, Parsons, KS 67357; Mr. John C. Latzer Mobilefreeze Co. Inc. P.O. Box 691 Parsons KS 67357; Dear Mr. Latzer: This responds to your April 15, 1975, question whether the Mobilefreez 'Mark Twain Marine' boat trailer, which consists of a platform whose primary cargo- carrying surface is 18 inches above the ground and supported by two 29-inch-high longitudinal support beams which rise from the outer edges of this surface, would qualify as a heavy hauler trailer. 'Heavy hauler trailer' is defined in S4 of Standard No 121, *Air brake systems*, as follows:; >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics: (1) Its brake lines are designed to adapt to separation or extension of the vehicle frame, or (2) Its body consists only of a platform whose primary cargo-carrying surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; From your description, the 29-inch-high beams do not serve as side from the trailer but simply as longitudinal load-bearing members of the vehicle's cargo-carrying surface. You state that these beams would be placed under the platform except for the necessity that the trailer bed be lower than normal.; If the beams in question do not in fact serve as sides but rather a part of the vehicle frame, the National Highway Traffic Safety Administration concludes that the 'Mark Twain Marine' boat trailer qualifies as a heavy hauler trailer which is not required to conform to Standard No. 121 until September 1, 1976.; Yours truly, Richard B. Dyson, Assistant 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.