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: aiam0605OpenMr. Louis Goldberg, Product Manager - Industrial Mastics, Daubert Chemical Company, 709 Enterprise Drive, Oak Brook, IL, 60521; Mr. Louis Goldberg Product Manager - Industrial Mastics Daubert Chemical Company 709 Enterprise Drive Oak Brook IL 60521; Dear Mr. Goldberg: This is in reply to your letter of February 14, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to industrial deadeners and underbody coatings that you manufacture for use in motor vehicles. You describe three uses of these products: as an undercoating, a deadener, and an adhesive, and enclose three brochures, each describing a different product.; Standard No. 302 applies to motor vehicles, and from a lega standpoint, manufacturers of component parts are not subject to its requirements. As the completed vehicle must comply with the standard, however, vehicle manufacturers, on whom the burden of compliance does rest, must ascertain that components they use in their vehicles do meet the standard's requirements.; In this context, and with reference to your products, paragraph S4.2 o the standard (copy enclosed), requires that certain portions of vehicle components, including composites consisting of both surface and underlying materials, meet the specified burn-rate requirements. (A notice of proposed rulemaking, published May 25, 1971, also enclosed, would modify to some degree this provision.) Where composites are involved, compounds used between the layers of the composite are required to meet the requirements as part of the composite. Thus, while we cannot make an exact determination from the general descriptions in your letter, it is quite possible that when your products are used as deadeners or adhesives they would appear in composites that are required to meet the standard. Whether the material actually comes into contact with passengers is not a criterion.; At the same time, under the standard only completed vehicles will b tested. We note from the brochures you have enclosed that your materials are not flammable after drying. If this is the case, you should not have a problem with conformity, as your material will be tested, where appropriate, in what we would assume would be its dry state.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1917OpenHonorable Alan Cranston, United States Senate, Washington, D.C. 20510; Honorable Alan Cranston United States Senate Washington D.C. 20510; Dear Senator Cranston: #I am writing in response to your letter o April 14, 1975, in which you requested information on Federal Motor Vehicle Safety Standard No. 106-74 (49 CFR Part 571.106-74) and its relation to the enclosed letter you had received from Mr. Thomas Z. Marshall of San Francisco. #Standard No. 106-74 specifies performance and labeling requirements of motor vehicle brake hose, brake hose end fittings, and brake hose assemblies. Because labeling applied to hose and end fittings cannot satisfactorily identify the manufacturer of an assembly made up of those components, S7.2 of the standard (by incorporating S5.2.4) requires certain assemblies to be labeled by means of a band. By identifying the manufacturer and the date of production, this permits both the enforcement of the standard's performance requirements and the tracing of defective assemblies. #Mr. Marshall appears to have misunderstood some aspects of the standard. While each manufacturer of brake hose assemblies must initially inform the NHTSA of the identifying designation he intends to use on his bands, these is no requirement that he keep records of assemblies made or send such records to this agency. In addition, the bands need not be metallic, but may be of other materials which are less expensive to produce. Mr. Marshall has correctly pointed out, however, that the standard in its present form specifies the same requirements for large manufacturers, repair shops, and individual truck owners. In recognition of the burdens thus imposed on a person who manufactures only a small number of assemblies, the NHTSA proposed an amendment of the definition of brake hose assembly, to exclude certain assemblies from the requirements of the standard (40 Fr 8962, March 4, 1975, copy enclosed). We expect to act on that proposal in the near future. #Sincerely, James C. Schultz, Chief Counsel; |
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ID: aiam5407OpenMr. Walter Lavis 2467 Rt. 10 Bldg. 3 Apt. 7B Morris Plains, NJ 07950; Mr. Walter Lavis 2467 Rt. 10 Bldg. 3 Apt. 7B Morris Plains NJ 07950; "Dear Mr. Lavis: We have received your letter of June 6, 1994, wit respect to your 'Saf-T-Flec' reflectors. You say that you have been informed by a NHTSA representative that 'using the standard DOT approved reflector tape would allow the use of my reflector for the trucking industry.' Judging from the red, white, and amber samples you have enclosed, your 'reflectors' appear to be retroreflective tape which adheres to a semicircular aluminum base and is intended for vertical mounting on the side and back of vehicles. Several potential customers have asked whether your concept was 'DOT approved', and you have asked for a reply. The Department of Transportation has no authority to 'approve' items of motor vehicle equipment. We advise inquirers whether manufacture or use of any particular item of equipment is prohibited or permitted under the Federal motor vehicle safety standards and associated regulations. However, if an item is deemed permissible, this must not be represented as 'approval' by DOT. Your letter is somewhat unclear as to the intended use and market for Saf-T- Flec. The fact that you have enclosed a highlighted copy of S5.1.1.4 leads us to believe that one application you envision for Saf-T-Flec is as a substitute for original equipment side reflex reflectors. This substitution is permitted if the reflective material conforms to Federal Specification L-S- 300 (September 7, 1965) and, as used on the vehicle, meets the performance standards of SAE Standard J594f Reflex Reflectors, January 1977. Accordingly, if your red and amber samples meet these two requirements, they may be used as the side front, intermediate, and rear reflex reflectors that Tables I and III require on trucks and trailers. However, Standard No. 108 does not allow sheeting material to be used on the rear of vehicles in lieu of reflex reflectors. What if your reflectors do not meet the two specifications listed above? In this instance, they may be used as supplementary side reflectors to the reflectors that are required by Standard No. 108, and you may employ amber devices for this use as well as red and white. As supplementary equipment, they are subject to the Federal restriction only that they not impair the effectiveness of the required reflex reflectors. We do not believe that additional reflectors would have this effect. Supplementary lighting equipment such as additional reflectors is subject to the laws of the individual states. We are not able to advise you as to their acceptability under state laws. The American Association of Motor Vehicle Administrators (AAMVA) provides opinions on state law. AAMVA's address is 4600 Wilson Blvd., Arlington, Va. 22203. As you may know, S5.7 of Standard No. 108 requires red and white retroreflective material to be applied to the side and rear of large trailers that have been manufactured since November 30, 1993 (those whose overall width is 80 inches or more and whose GVWR is more than 10,000 pounds). This material may be retroreflective sheeting or reflectors. If sheeting is used, it must meet the photometric specifications of Figure 29. If reflectors are used, they must conform to SAE J594f, and provide specified minimum millicandela/lux at specified light entrance angles. Your initial question indicates that you may be interested in marketing Saf-T-Flec for use as a substitute for the conspicuity materials that conform to Standard No. 108. Manufacturers of conspicuity sheeting certify it with the material in a flat vertical plane (as evidenced by the DOT-C2 marking on your white sample). We have reservations whether the curved red and white Saf-T-Flec devices could meet the photometric specifications of Figure 29, for sheeting, or J594f and the millicandela/lux specifications of S5.7.2.1(b) or (c) for reflectors. Amber is not one of the specified colors for conspicuity treatment, and could not be used as a substitute. I hope that this answers your questions. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2268OpenHonorable Herman E. Talmadge, Chairman, Committee on Agriculture and Forestry, United States Senate, Washington, DC 20590; Honorable Herman E. Talmadge Chairman Committee on Agriculture and Forestry United States Senate Washington DC 20590; Dear Mr. Chairman: This is in response to your letter of April 1, 1976, forwardin correspondence from Mr. James A. Graham concerning the recently issued Part 581 bumper standard.; On March 4, 1976, the National Highway Traffic Safety Administratio (NHTSA) published a Federal bumper standard (41 FR 9346, 49 CFR Part 581) under the authority of Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The standard, effective September 1, 1978, specifies limitations on damage to non-safety related as well as safety-related vehicle components in low-speed collisions. Several manufacturers, including Gulf and Western Manufacturing Company, have filed petitions for reconsideration of the standard in conformance with NHTSA rulemaking procedures (49 CFR 553.35).; It is NHTSA's policy to issue a notice of action taken on petitions fo reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Mr. Graham in his letter.; I assure you that Mr. Graham's comments and the information containe in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0255OpenIng. Andrea Catanzano, Automobili Lamborghini, 40019 S. Agata Bolognese (Bologna), Italio; Ing. Andrea Catanzano Automobili Lamborghini 40019 S. Agata Bolognese (Bologna) Italio; Dear Dr. Catanzano: Thank you for your letter of September 23 informing us of lamborghini' continue progress towards compliance with Federal motor vehicle safety standards.; I want to remind you that Standard No.. 211 precludes the use of whee nuts, wheel discs, and hub caps that incorporate winged projections, such as the one shown in the Espada photograph which I enclose. We have seen several Espadas manufactured in 1969 with wheels identical to this one, and were informed in one instance that the winged projections had been shipped form Italy with the car. Such a shipment violates the spirit, if not the letter of Standard No. 211.; There is no charge for the 'Program Plan for Motor Vehicle Safet Standards', enclosed at your request.; Sincerely, Lawrence R. Schneider, Acting Deputy Chief Counsel |
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ID: aiam2792OpenMr. R. G. Wilkins, Product Safety and Reliability, Grove Manufacturing Co., Shady Grove, PA 17256; Mr. R. G. Wilkins Product Safety and Reliability Grove Manufacturing Co. Shady Grove PA 17256; Dear Mr. Wilkins: This responds to your recent letter asking whether plastic glazin materials may be used on the superstructure operator cabs of mobile construction cranes. Apparently, the upper superstructure cab is used only for craning operations and is distinct from the cab used to drive the crane over public highways.; Under Federal Motor Vehicle Safety Standard No. 205, *Glazin Materials* (49 CFR Part 571.205), plastic glazing may be used only in locations to the rear of the driver in trucks or truck tractor cabs and only at levels not requisite for driving visibility. Therefore, plastic glazing could not be used in the windshield or windows to the right or left of the driver in the main driving cab of the mobile crane. It is our interpretation, however, that the superstructure operator cab is, effectively, to the rear of the driver when the vehicle is being used on the highway and could be equipped with plastic glazing materials meeting the requirements of Standard No. 205. This interpretation assumes that the operator cab cannot be used to drive the mobile crane on the highway. If the operator cab could be used as the driving cab, plastic glazing could only be used in locations to the rear of the driver at levels not requisite for driving visibility.; Please contact this office if you have any questions concerning thi interpretation.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5057OpenThe Honorable Dave Durenberger United States Senate 1020 Plymouth Building 12 S. 6th Street Minneapolis, MN 55402; The Honorable Dave Durenberger United States Senate 1020 Plymouth Building 12 S. 6th Street Minneapolis MN 55402; "Dear Senator Durenberger: Thank you for your letter on behalf of you constituent, Mr. Mark Gassert, regarding the installation of the Drivemaster One-Arm-Drive hand control system in a van. I am pleased to have this chance to provide you the following information. Section 103 of the National Traffic and Motor Vehicle Safety Act (the Safety Act, 15 U.S.C. 1392) authorizes NHTSA to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and new items of motor vehicle equipment. Manufacturers are required to certify that their products meet all applicable safety standards. NHTSA periodically tests certified products to ensure that they do, in fact, comply with applicable standards, and investigates allegations that products contain defects related to motor vehicle safety. If a new vehicle were altered by installation of adaptive controls prior to the vehicle's first sale to a consumer, the person making the installation would be considered an 'alterer' and would be required by 49 CFR Part 567, Certification, to certify that the vehicle continues to comply with all applicable safety standards affected by the alteration. Based upon the information in Mr. Gassert's letter, it appears that requirements for new light trucks and vans in Standard No. 208, Occupant Crash Protection, which were upgraded as of September 1, 1991, may be preventing him from purchasing a new van with a hand control system. Light trucks and vans manufactured on or after that date must be capable of providing occupant crash protection to belted front seat occupants when the vehicle is crash tested at 30 miles per hour (mph) into a concrete barrier. A vehicle that provides this crash protection will increase the safety of vehicle occupants. As a result of this new requirement, this agency has recently received a number of phone calls and letters, from van converters and individuals, suggesting that the new light truck and van crash testing requirement will, in effect, prohibit van converters from modifying vehicles to accommodate the special needs of persons in wheelchairs. The agency has also received a petition from the Recreation Vehicle Industry Association (RVIA) requesting an amendment to the light truck and van crash test requirement 'to eliminate requirements that inadvertently discriminate against individuals with disabilities including individuals who use wheelchairs.' On January 9, 1992, the agency granted the RVIA petition. On August 5, 1992, the agency issued a notice of proposed rulemaking (NPRM) to amend the requirements of Standard No. 208 to give manufacturers of certain light trucks and vans the option of installing non-dynamically tested manual safety belts instead of complying with the dynamic testing requirements. I have enclosed a copy of the NPRM with this letter. Because of the importance of this subject, the agency has decided it is more appropriate to address it comprehensively, in the context of a rulemaking, instead of in a piecemeal fashion, in response to letters presenting individual cases and individual aspects of the subject. By addressing this subject comprehensively, NHTSA will be able to ensure that the resulting requirement offers persons in wheelchairs the best possible safety protection. However, the agency is aware that Mr. Gassert and others who need to purchase a new vehicle need more immediate relief than a rulemaking can offer. Therefore, as explained in the NPRM, the agency has stated that it will not conduct any dynamic testing under Standard No. 208 of vehicles modified for operation by persons with disabilities while this rulemaking is pending. This should allow Mr. Gassert and others to purchase a new vehicle while this decision is pending. I hope you find this information helpful. If you have any other questions, please feel free to contact me at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam3880OpenMr. H. Tsujishita, Daihatsu Motor Co., Ltd., No.7,2-Chome, NIHONBASHI-HONCHO, Chuo-ku, Tokyo, Japan; Mr. H. Tsujishita Daihatsu Motor Co. Ltd. No.7 2-Chome NIHONBASHI-HONCHO Chuo-ku Tokyo Japan; Dear Mr. Tsujishita: This responds to your letter of November 26, 1984, requesting severa interpretations of Standard Nos. 201, 208, and 210. The answers to your questions raised in Attachments I, II, and III of your letter are discussed below.; In attachment I of your letter, you asked about the requirement o S3.5.1(c) of Standard No. 201. You were specifically concerned about the language which provides that the length of the armrest is to be measured vertically in side elevation. You provided a drawing of an armrest and asked if the length is to be measured as shown in section (dimension) b of your Figure 1.; The purpose of the requirement is to ensure that there is at last inches of coverage within the pelvic impact area. For this requirement to be meaningful, the covered surface must be contactable by the vehicle occupant. The vehicle occupant would not contact the base of the arm rest illustrated in your drawing. Therefore, the measurement should be made at dimension a in section A-A or dimension c in section B-B as shown in your Figure 1.; On question one of Attachment II, you asked about the application o Standard Nos. 208 and 209 to a safety belt system you are developing to meet S4.1.2.1 of Standard No. 208. The system consists of a two point automatic belt and a Type 1 manual safety belt. You asked which requirements of Standard No. 209 apply to such an automatic belt. I have enclosed an interpretation letter of August 7, 1981 to Volkswagen which explains the application of Standard No. 209 to an automatic belt.; In question two of Attachment II, you state that your vehicle will hav four anchorages for each front outboard seating position (two anchorages for the automatic belt and two for the Type 1 seat belt assembly). You said that S4.4.1 of Standard No. 210 requires seat belt anchorages for Type 2 safety belts at each front outboard seating position and you asked what is meant by anchorages for a Type 2 belt. You also asked whether you must install any other anchorages at those positions in your vehicle.; Paragraph S4.1.1. of Standard No. 210 requires anchorages for a Type seat belt assembly to be installed for each forward-facing outboard designated seating position in passenger cars. This is true regardless of whether the seating position is equipped with an air bag and a lap belt, with a single diagonal automatic belt or with any other system. Safety Standard No. 210 is independent of Safety Standard No. 208, *Occupant Crash Protection*. A Type 2 belt requires three anchorages (two for the lap portion of the belt and one for the upper torso restraint). The presence of the Type 2 anchorages in vehicles will allow vehicle owners to install easily Type 2 belts at their own initiative if they desire to do so for whatever reason. For example, if a single diagonal automatic belt system has been damaged, an owner may wish to replace it with a Type 2 manual belt system.; Under paragraph S4.3 of Safety Standard No. 210, anchorages fo automatic belts are exempted from the location requirements of the standard. This exception was provided for in the standard to allow manufacturers to experiment with various automatic belt designs to determine the optimum anchorage locations in terms of both effectiveness and comfort (43 FR 53440, Nov. 16, 1978). If, however, anchorage points for an automatic belt do not fall within the location specified in the standard for Type 2 belts, the manufacturer would have to provide additional anchorage points that could be used by a properly located Type 2 manual belt. Thus if your lap belt and upper torso anchorages fall within the location requirements for Type II belts, you would not have to provide any additional anchorages.; In question three of Attachment II, you asked what strength tes applies to anchorages used with an automatic belt and to the manual lap belt used in your system. You illustrated the test procedures you plan to use in your Figure 3. As explained below, the procedure shown in Figure 3(1) is correct and the procedure shown in Figure 3(2) is partially correct.; The agency has stated in an interpretation letter of July 23, 1980 t Mazda that the anchorages for a single diagonal automatic belt should be tested with a 3,000-pound force for purposes of Standard No. 210, in accordance with the test procedures of paragraph S5.2. This is the same force that is required for testing the upper torso portion of a Type 2 seat belt system. This force requirement is applicable whether the single diagonal automatic belt is used alone or whether it is used in conjunction with a manual lap belt. The anchorages for the manual lap belt, however, would be required to withstand test forces of 5,000 pounds under paragraph S4.2.1 for Standard No. 210. The anchorages for the manual lap belt and for the automatic belt must separately meet their respective force requirements and would not have to be tested simultaneously since they are separate systems.; In question one of the Attachment III, you requested the agency t clarify the words 'fold' and 'tumble' used in S7.4.6 of Standard No. 208. You stated your understanding that 'fold' means to move the seat back forward as shown in your Figure 4-a and 'tumble' means to move both the seat cushion and seat back forward as shown in your Figure 4-b. Your understanding of both words is correct.; In question two of Attachment III, you asked the meaning of the wor 'receptacle' as used in paragraph S7.4.6.2 of Standard No. 208. The word 'receptacle' refers to the devices into which an occupant would insert the tang of a safety belt to fasten the belt.; I hope this satisfactorily answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1014OpenMr. R. Debesson, General Secretary, E.T.R.T.O., 49, Rue Barathon, 03-Montlucon, France; Mr. R. Debesson General Secretary E.T.R.T.O. 49 Rue Barathon 03-Montlucon France; Dear Mr. Debesson: This is in reply to your submission No. 65/109 of January 23, 1973 petitioning that temporary exemption from Motor Vehicle Safety Standard No. 109 be provided for European tire manufacturers who manufacture high speed tires. Your petition points out that Standards No. 109 does not allow the manufacture of high speed tires designed to be inflated to relatively high inflation pressures, but which do not have commensurate load-carrying ability at those pressures. You indicate that such tires are commonly used in Europe for high speed passenger cars, and have hot produced safety problems.; The temporary exemption regulations (49 CFR 555, copy enclosed), i accordance with the statutory authority under which they were issued (P.L. 92-548), apply only to manufacturers of motor vehicles. They do not apply to manufacturers of motor vehicle equipment, and the relief which they provide is accordingly not available to tire manufacturers.; The NHTSA is of the opinion that the requirements of Standard No. 109 emphasizing the load-carrying as well as the high speed capability of passenger car tires, should be suited to driving condition which predominate in the United States. Despite the facts, as you mention, that it is possible for motorists to exceed postal speed limits, and that areas do exist where speed limits are not posted, the NHTSA believes the high speed requirements of Standard No. 109 are sufficient to guard against tire failures under these conditions. At the same time, the NHTSA will consider petitions to amend Standard No. 109, submitted pursuant to NHTSA procedural rules (49 CFR 553.31, .33), and E.T.R.T.O. is free to petition to amend the standard to include requirements for European-type high speed tires. Your petition should contain full supporting data for the amendments requested. We would expect you as well to include possible performance requirements for such tires.; You refer briefly in your letter to the performance of these tires whe tested pursuant to the planned Uniform Tire Quality Grading regulation. The NHTSA plans to publish in the very near future a revised notice of proposed rulemaking regarding this regulation, and we will be pleased to receive your comments to that proposal when it is published.; Yours truly, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3029OpenMr. John Cordner, Technical Assistant, Product Compliance, Subaru of America, Inc., 7040 Central Highway, Pennsauken, NJ 08109; Mr. John Cordner Technical Assistant Product Compliance Subaru of America Inc. 7040 Central Highway Pennsauken NJ 08109; Dear Mr. Cordner: This is in response to your letter of May 23, 1979, addressed to Ms Eileen T. Leahy of my staff, in which you provide further information in support of your earlier request for this agency's opinion as to whether a 1980 4WD Hatchback Sedan to be imported by Subaru of America can be classified as a multi-purpose passenger vehicle (MPV).; As I stated to you in my letter of May 31, 1979, the fact that vehicle is equipped with four-wheel drive is not, in itself, sufficient to qualify the vehicle as an MPV, as that term is defined in 49 CFR S 571.3. Your second letter lists six other features of the 1980 hatchback sedan which you state are designed to permit occasional off-road use. The additional features you describe are: a ground clearance of 8.07 inches, or 1.57 inches higher than a similar 2WD vehicle, adjusting devices to permit an additional 0.78 inches of ground clearance front and rear, an engine undercover to protect the engine from rocks and other debris, a clutch cover to prevent entry of dust and sand, bumper overriders to protect front and rear bumpers, and a tubular guard in front of the air dam for protection from rocks and other debris.; The ground clearance you describe exceeds that specified in th definition of automobiles 'capable of off-highway operation' contained in the fuel economy regulations (49 CFR S 523.5(b)(2)(iv)). In addition, the other features you describe appear to be designed to protect various parts of the vehicle from damage from rocks, sand and other types of debris that are more likely to be encountered in off-road driving. Therefore, all of the items you mention can be considered 'special features for occasional off-road operation' when determining the proper classification of the vehicle for purposes of compliance with Federal Motor Vehicle Safety Standards.; Since the vehicle as you have described it in your letters has severa features in addition to four-wheel drive that make it suitable for occasional off-road use, it is the agency's opinion that the 4WD Hatchback Sedan would qualify as a multipurpose passenger vehicle.; Sincerely, Frank Berndt, 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.