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: aiam4702OpenMr. Satoshi Nishibori Nissan Research & Development, Inc. 750 17th Street N.W., Suite 902 Washington, D.C. 20006; Mr. Satoshi Nishibori Nissan Research & Development Inc. 750 17th Street N.W. Suite 902 Washington D.C. 20006; "Dear Mr. Nishibori: This responds to your January 16, 1990 letter t Mr. Robert Hellmuth, the Director of this agency's Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars (49 CFR 571.120). Specifically, S5.1.2 of Standard No. 120 provides that when a passenger car tire is used on vehicles other than passenger cars, the tire's load rating shall be reduced by dividing it by 1.10 before calculating the sum of the load ratings of all of the original equipment tires on the vehicle. S5.3.2 through S5.3.5 establish requirements for certain information about the tires and rims to be labeled on the vehicle. S5.3.2 sets forth lettering size and format requirements for the labeling. S5.3.3 through S5.3.5 require the labeling to provide the following information: the 'size designation of tires....appropriate (as specified in S5.1.2) for the GAWR' be given on the label, the size and type designation of rims 'appropriate for those tires', and the 'cold inflation pressure for those tires'. Your question was whether the cold inflation pressure set forth on the label in response to S5.3.5 of Standard No. 120 must reflect the 1.1 reduction factor set forth in S5.1.2 for passenger car tires. You suggested in your letter, and in your January 18, 1990 meeting with agency staff, that S5.3.5 does not require the 1.1 reduction factor to be taken into account when determining the cold inflation pressure to be specified. Instead, you suggested that Standard No. 120 requires the vehicle manufacturer to specify an inflation pressure that is adequate to support the tire's share of the gross axle weight rating (GAWR), without regard to the 1.1 reduction factor. I cannot agree with your suggested interpretation. You asserted that S5.3.5 merely requires the label to include the 'cold inflation pressure for those tires,' without referring to S5.1.2 and its 1.1 reduction factor. You contrasted this requirement with that in S5.3.3, which expressly refers to S5.1.2 and the 1.1 reduction factor. You asserted that this difference in wording showed that the 1.1 reduction factor need not be considered when specifying the cold inflation pressure on the label in response to S5.3.5. This argument is not persuasive. The load-carrying capability of a tire generally varies with the inflation pressure of that tire, i.e., a tire can carry a greater load at a higher inflation pressure and a lesser load at a lower inflation pressure. Hence, a reference to inflation pressure alone, without any corresponding load-carrying capability to which that inflation pressure applies would be meaningless. If S5.3.5 of Standard No. 120 were interpreted to require the manufacturer to specify some inflation pressure, without regard to any load that must be borne by the tire at that inflation pressure, the vehicle manufacturer could specify an extremely high or low inflation pressure. Such a specification would be useless or even dangerous for the consumer, and contrary to the purposes of the labeling requirements. You implicitly recognize that such an interpretation is unacceptable when you argue on page 1 of your January 16, 1990 that S5.3.5 of Standard No. 120 must be interpreted to require the manufacturer to recommend an inflation pressure 'that will permit the tires to safely carry Gross Axle Weight Rating loads and will provide good vehicle ride characteristics.' In other words, Nissan agrees that the inflation pressure specified in response to S5.3.5 cannot be an extreme value such as 1 psi, instead, it must be determined with reference to some load that the tires will carry. The question then becomes what loading must be considered to determine if the specified inflation pressure complies with S5.3.5. This question is answered by reading the labeling requirement of S5.3.5 in connection with the other labeling requirements in S5.3, instead of considering S5.3.5 in a vacuum. S5.3.2 sets forth the format and lettering size for the labels to be placed on all vehicles manufactured on or after December 1, 1984. The information that must appear on such labels is set forth in S5.3.3, S5.3.4, and S5.3.5 of Standard No. 120. S5.3.3 specifies that the label shall include information on 'the size designation of tires (not necessarily those on the vehicle) appropriate (as specified in S5.1.2) for the GAWR.' (Emphasis added). On any reading of this emphasized language, it is beyond dispute that the 1.1 reduction factor set forth in S5.1.2 must be considered when specifying the appropriate tire size designation pursuant to S5.3.3. Following this, S5.3.4 requires information on the size and type designation of rims 'appropriate for those tires' to appear on the label. The reference to 'those' tires in S5.3.4 indicates that the tires are the tires previously specified in S5.3.3. Similarly, when S5.3.5 requires the cold inflation pressure for those tires to appear on the information label, the language is referring back to the tires specified in S5.3.3. Since NHTSA agrees with your statements that S5.3.3 incorporates the 1.1 reduction factor of S5.1.2 to determine compliance with S5.3.3, and since S5.3.5 refers to the tires specified in S5.3.3, the 1.1 reduction factor set forth in S5.1.2 must be considered to determine ocmpliance with S5.3.5 of Standard No. 120. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1500OpenMr. Jim Coughlin, Vice President-Marketing, Bell Helmets Inc., 2850 East 29th Street, Long Beach, CA 90806; Mr. Jim Coughlin Vice President-Marketing Bell Helmets Inc. 2850 East 29th Street Long Beach CA 90806; Dear Mr. Coughlin: This is in reply to your letter of May 1, 1974, concerning th requirements of Standard No. 218, *Motorcycle Helmets*. You mentioned that Bell is producing some helmets to the Snell standard 'irrespective of the DOT standard,' and you enclosed the labels Bell is using to allow the consumer to differentiate the helmets produced to the Snell standard. The labels you enclosed contain the following notice:; >>>*IMPORTANT*: THIS HELMET IS MANUFACTURED FOR RACING AND OTHER HIG PERFORMANCE USES ONLY, AND IS NOT REGULATED BY THE U.S. DEPT. OF TRANSPORTATION. IT IS NOT FOR USE ON PUBLIC STREETS, ROADS AND HIGHWAYS.<<<; We do not consider this notice acceptable. We believe that the phrase '...AND OTHER HIGH PERFORMANCE USES ONLY...,' would mislead the consumer into thinking that a helmet with this notice is safer for use on public roads than a helmet produced to Standard 218. Accordingly, the phrase '...and other high performance uses only...' should not be used to describe the purpose of helmets produced to the Snell standard. Instead, we suggest that the following language be inserted: '...and similar off- road sports only...'.; You also ask how to determine which helmets you manufacture qualify a 'fitting' the size C headform. Any 'fit-all' or other helmets that are designed to fit a range of head sizes that includes the approximate dimensions of the size C headform must meet the requirements of Standard 218. A helmet is considered not to fit a size C headform only if it is clearly intended by its manufacturer to be used only by persons whose heads are either larger or smaller than the size C headform.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2286OpenMr. Gilbert Theissen,6S Hayden Hall,33 Washington Square West,New York, New York 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York New York 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 S571.101).#With regard to rollover resistance, the agency has issued an advance 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: aiam5543OpenMs. Teresa Thompson 1686 Desoto Trail Dalton, GA 30721; Ms. Teresa Thompson 1686 Desoto Trail Dalton GA 30721; "Dear Ms. Thompson: We have received your letter of April 6, 1995, wit respect to an automotive deceleration signal. You have asked for information 'on how to have this product tested and approved as well as information on the legal ramifications and liabilities for the product.' The Department of Transportation neither tests nor 'approves' products. What it does do is to advise whether motor vehicle equipment is permitted under the statutes and regulations for whose administration it is responsible. In this instance, the appropriate regulation is Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. This standard specifies requirements for only certain items of lighting equipment but it also has an effect on lighting equipment that is not specified in the standard. That is to say, if an item of lighting equipment is not allowable for a manufacturer or dealer to install as original equipment (i.e., equipment on the vehicle at the time of its original sale), in most cases it won't be allowable in the aftermarket for manufacturer or dealer installation on used vehicles as well. As you describe it, the signal is provided by 'a strobe light with an independent power supply, which upon heavy breaking (sic), will activate a strobe for five seconds and on impact for ten minutes.' The prototype 'is approximately 4' by 3' and may be attached to a rear window.' Federal laws cover brake activation of your strobe signal. Standard No. 108 requires turn signal lamps, hazard warning signal lamps, and school bus warning lamps to flash. Headlamps and side marker lamps may be flashed for signaling purposes. But all other lamps provided as original equipment must be steady- burning. We regard a strobe lamp as one that flashes. For this reason, the deceleration signal you describe could not be installed as original equipment. Further, its installation on a used vehicle would take the vehicle out of compliance with Standard No. 108. Notwithstanding the discussion above, there is no Federal prohibition on the sale of the strobe signal device, and Federal law does not prevent the vehicle owner from installing it on a used vehicle (however, manufacturers, dealers, distributors, and motor vehicle repair businesses may not do so), no matter what effect the strobe signal may have upon compliance with Standard No. 108. However, the States have the right to decide whether use of the strobe signal is permissible. We aren't able to provide you with information on State laws, and suggest that you seek an opinion from the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22303. We can't advise you on your potential liabilities either, and suggest that you contact your attorney for an opinion on the applicability of local law. In addition, it is important to note that Standard No. 108 prohibits supplementary original lighting equipment that impairs the effectiveness of the original lighting equipment required by Standard No. 108. The proximity of your strobe device in the rear window to the center highmounted stop lamp required by Standard No. 108 raises the possibility of impairment, especially if the strobe is of a color other than red, or so bright as to mask the center stop lamp signal. I am sorry to be unable to offer you more encouragement at present, as we share your concern with the negative effects of fog and rain on drivers and vehicles. It is obvious that you have given much thought to this problem. Noting that you are testing a prototype, this agency would be interested in receiving any data you have or may develop showing a positive effect of the strobe signal upon the frequency and severity of rear end collisions. You may send this to Michael Perel, Office of Research and Development, NHTSA, Room 6206, 400 Seventh St. SW, Washington, DC 20590. It is conceivable that at some time in the future we would allow the center stop lamp to flash under conditions of rapid deceleration. This could open the way to permissibility of an additional lamp such as yours. I note that, to the extent that your device were only to activate upon impact and not during conditions of rapid deceleration, it would not be prohibited by Standard No. 108. Such a device would be permissible as a supplement to, or substitute for, a vehicle's hazard warning signal system. We do not know whether it would be permissible under State laws (see discussion above). If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0741OpenMr. David Rothschild II, Executive Vice President, David Rothschild Company, Post Office Box 20, Columbus, GA, 31902; Mr. David Rothschild II Executive Vice President David Rothschild Company Post Office Box 20 Columbus GA 31902; Dear Mr. Rothschild: This is in reply to your letter of April 11, 1972, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether the standard applies to motor homes and recreational vehicles being towed. You also ask what type of certificate or guarantee is required of a fabric manufacturer.; Standard No. 302 applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. It does not apply to trailers, the vehicle category which includes mobile homes and other towed recreational vehicles, and these vehicles are consequently not subject to its requirements. With respect to your questions regarding certification by fabric manufacturers, the standard applies to motor vehicles, and it is the vehicle manufacturer who bears the responsibility to certify, under the National Traffic and Motor Vehicle Safety Act, that the vehicle conforms to the standard. There are no Federal requirements regarding certification to this standard imposed on fabric suppliers. However, manufacturers who purchase materials from such suppliers may require some form of certification or guarantee from them that the materials meet the standard.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam1853OpenMr. Leonard F. Blanda, Director of Safety, CINCUSAREUR, APO NY 09403; Mr. Leonard F. Blanda Director of Safety CINCUSAREUR APO NY 09403; Dear Mr. Blanda: This responds to your question whether a recent amendment of Standar No. 208, *Occupant crash protection*, which modified the requirement for a seat belt warning system, would make legal the disconnection of warning systems which conformed to earlier requirements.; The answer to your question concerning vehicle owners is yes Disconnection of safety devices is subject to a Federal statue, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391 et seq.), as recently amended (P.L. 93-492). For your information, I will summarize the relevant provisions on disconnection.; The Safety Act prohibits knowing disconnection of safety devices afte the first retail sale, as well as before this sale, with three exceptions.; First, after December 26, 1974, a *private party* may disconnect *any devices *after* sale. Generally, a manufacturer, distributor, dealer, or repair business may not knowingly disconnect safety devices except during repair of the vehicle.; Second, after December 26, 1974, any person, including a new ca dealer, may disconnect the ignition interlock and *continuous* buzzer (but *not* the warning *light*) at any time *after* sale of 1974- or 1975-model passenger car. This does not include the 8-second buzzer found on the newest 1975 models.; Third, a *dealer* may disconnect the ignition interlock an *continuous* buzzer (but *not* the warning *light) at the request of the first purchaser *before sale* of the new vehicle. This is the only exception to the rule that no person may disconnect any safety devices prior to sale. This does not include disconnection of the 8-second buzzer found on the newest 1975 models.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam5113OpenMr. Terry Wagar Technical Services Bureau State of New York Department of Motor Vehicles Division of Vehicle Safety Services The Governor Nelson A. Rockefeller Empire State Plaza Albany, NY 12228; Mr. Terry Wagar Technical Services Bureau State of New York Department of Motor Vehicles Division of Vehicle Safety Services The Governor Nelson A. Rockefeller Empire State Plaza Albany NY 12228; "Dear Mr. Wagar: This responds to your letter asking about the repai of glazing in in-service motor vehicles that were originally designed to comply with Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205). You were specifically concerned about the safety of a repair process known as 'Ultra B-O-N-D' which you explained involves injecting a liquid through a crack in a windshield. The repaired area is then exposed to a lamp, scraped with a razor blade, and cleaned. You explained that after this process is completed, the crack is 'not as visible.' By way of background information, the National Traffic and Motor Vehicle Safety Act (Safety Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable to new motor vehicles and new motor vehicle equipment. Pursuant to this authority, the agency has issued Standard No. 205, which establishes performance requirements for all windows (called 'glazing' in the Standard) in new motor vehicles and for all new replacement windows for motor vehicles. The Federal motor vehicle safety standards do not apply to vehicles and motor vehicle equipment after their first sale to a consumer. The Safety Act does include a provision that prohibits manufacturers, distributors, dealers and motor vehicle repair businesses from 'rendering inoperative' any device or element of design installed on or in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard. However, that provision does not require those entities, in repairing a damaged vehicle, to restore it to its original level of performance. The States do have the authority to regulate motor vehicle repairs and the condition of in-service vehicles, and this agency encourages them to take steps to ensure the safe operating condition of vehicles-in-use. (The Federal Highway Administration has in-service requirements for commercial motor vehicles used in interstate commerce.) I regret that we are unable to provide any information concerning the safety of the 'Ultra B-O-N-D' process. We suggest that, in developing criteria for the condition of in-use glazing, including the permissibility of certain types of repairs, that you consider such factors as whether particular damage, even after repair, would adversely affect driver visibility, would likely become more serious during normal use (e.g., a small crack becoming a large crack), would reduce the ability of the windshield to retain unrestrained occupants in the vehicle, or would otherwise adversely affect vehicle safety. In addition, if the windshield is so extensively damaged that it cannot be repaired using the 'Ultra B-O-N-D' process, and must be replaced, the new windshield should be installed in accordance with the vehicle manufacturer's instructions. In the event of an accident, an improperly installed windshield may allow unrestrained occupants to be ejected from the vehicle with resulting personal injury. I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0311OpenMrs. Barbara G. Rothschild, 2134 Springdale Drive, Columbus, GA 31906; Mrs. Barbara G. Rothschild 2134 Springdale Drive Columbus GA 31906; Dear Mrs. Rothschild: This is in response to your letter of January 29, 1971, in which yo inquired whether a particular safety belt system, described in a patent application, would qualify as a 'passive restraint' within the meaning of the Occupant Crash Protection standard. We have delayed an answer to your inquiry, pending issuance of amendments to that standard that were made on March 10, 1971 (36 F.R. 4600), in response to petitions for reconsideration.; You describe your system as one in which 'you have to manually pivo the belt in order to take your seat in the car'. From that point on, however, everything is automatic . . .' The issue, then is whether such a system is a 'means that require[s] no action by vehicle occupants,' in the words of the standard.; Our position is that such a system would not meet the above requiremen of the standard, since it is a system that does require action by the occupant, *i.e.*, pivoting the belt. By 'no action' is meant just that--no action by occupants other than would be required if the protective system were not present in the vehicle. We recognize that in some cases, the action that is required may be relatively slight. In terms of regulatory categories, however, we consider it important to distinguish 'no-action' systems from 'forced-action' systems, of which the most commonly discussed example is the seat belt with an ignition interlock. Your system appears clearly to come within the forced-action category.; Please note that although we are glad to provide interpretations i response to specific questions such as yours, the National Highway Traffic Safety Administration generally does not issue overall 'approvals' of any vehicle or motor vehicle equipment, with respect to conformity with the standards.; Sincerely, Douglas W. Toms, Acting Administrator |
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ID: aiam2402OpenMr. R. L. Ratz, Product Safety Engineer, The Flxible Company, 970 Pittsburgh Drive, Delaware, OH, 43015; Mr. R. L. Ratz Product Safety Engineer The Flxible Company 970 Pittsburgh Drive Delaware OH 43015; Dear Mr. Ratz: This is in reply to your letter of September 7, 1976, to Mr. Dyson formerly of this office, requesting a confirmation that an interpretation of Motor Vehicle Safety Standard No. 108, rendered to the Southern California Rapid Transit District on August 5, 1974, is still valid, and that it can be extended to include identification lamps as well.; In our earlier letter we advised the District that the installation o wiring by a manufacturer enabling a purchaser to connect it to normally steady-burning clearance lamps, enabling them to be flashed to signal a crime in progress would not violate S4.6(b) which requires clearance lamps to be steady-burning, or S4.1.3 that prohibits installation of motor vehicle equipment which impairs the effectiveness of the lighting equipment required by Standard No. 108. This will confirm that that interpretation is still valid.; Your letter, however, raises two additional issues which deserve to b answered for the record. The first is whether the bus manufacturer rather than the purchaser may make the connection, and the second is whether identification lamps may also be included in the warning system. Since it is our opinion that use of the clearance lamps in an emergency mode creates an item of lighting equipment not required by Standard No. 108 and hence outside its coverage, we have concluded that the manufacturer may connect both clearance and identification lamps to the emergency circuit without any resultant nonconformances with S4.6(b) and S4.1.3.; I hope this is responsive to your request. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4885OpenMr. Takashi Odaira Chief Representative Emission & Safety Isuzu Technical Center of America, Inc. 41050 Vincenti Court Novi, Michigan 48375; Mr. Takashi Odaira Chief Representative Emission & Safety Isuzu Technical Center of America Inc. 41050 Vincenti Court Novi Michigan 48375; "Dear Mr. Odaira: This responds to your letter requesting a interpretation on whether the Isuzu 2-door Coupe is subject to the rear seat requirements set forth in the final rule on Standard No. 214, Side Door Strength, published on October 30, 1990 (55 FR 45722). As noted by your letter, the rear seat requirements do not apply to passenger cars which have rear seating areas that are so small that the SID dummy cannot be accommodated according to the specified positioning procedures. The issues raised by your letter are addressed below. By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment meet applicable standards. The following provides our opinion based on the facts provided in your letter. Your letter describes the positioning of the SID as follows: In this vehicle, when the SID dummy is seated at the rear outboard passenger position according to the specified positioning procedures, the dummy's head comes into contact with the roof and backlight glass which have steep slopes. To avoid the interference, in our test, the head was tilted forward as much as possible and, in addition, the upper torso was also tilted forward, away from the seat back. Only in this way, could we accommodate the dummy in the seating area without changing the orientation of the thorax midsagittal plane, or affecting the H-point. You noted, however, that '(t)his condition . . . obviously does not meet the positioning procedure of paragraphs S7.l.3(a) and (b), which provides, 'The upper torso of the test dummy rests against the seat back.'' You stated that it is therefore your interpretation that the vehicle cannot accommodate the SID dummy and that the rear seat requirements are not applicable to it. You requested our views regarding your understanding. In the preamble to the October 1990 final rule, NHTSA noted that, for some vehicles where the roof has a steep rear slope, the SID head can be tilted so as to accommodate the test dummy without changing the specified orientation of the thorax midsagittal plane or affecting the H-point (two of the specifications in the S7 positioning procedure). The agency also noted that there are some cars with rear seating areas that are so small that the SID dummy cannot be accommodated according to the specified positioning procedures, even if the head is adjusted fore-aft. Section S3 of Standard No. 214 provides that the rear seat requirements do not apply to 'passenger cars which have rear seating areas that are so small that the SID dummies cannot be accommodated according to the positioning procedure specified in S7.' Thus, if any aspect of the positioning procedure, including the specification that the upper torso rests against the seat back, cannot be met, the vehicle is not required to meet the rear seat requirements of Standard No. 214. With regard to whether the Isuzu 2-door Coupe is subject to Standard No. 214's rear seat requirements, NHTSA cannot make a determination that the rear seat requirements do not apply to a vehicle based solely on a description and photographs of that test procedure. If the agency should conduct a compliance test for the vehicle, it would attempt to position the SID dummies in the rear seat according to the specified seating procedure. If NHTSA were unable to position SID dummies in the rear of the vehicle according to the specified procedure, it would conclude that the rear seat requirements do not apply to that particular vehicle. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice 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.