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: aiam4205OpenMr. H. Tsujishita, Chief Co-ordinator of Technical Administration Dept., Daihatsu Motor Co., Ltd., 1. Daihatsu-Cho, Ikeda City, Osaka Prefecture, Japan; Mr. H. Tsujishita Chief Co-ordinator of Technical Administration Dept. Daihatsu Motor Co. Ltd. 1. Daihatsu-Cho Ikeda City Osaka Prefecture Japan; Dear Mr. Tsujishita: This responds to your letter requesting an interpretation of several o our standards. First, I would like to apologize for the delay in this response to your letter. I have set forth the responses in the order you asked the questions in your letter.; 1. Standard No. 105, *Hydraulic Brake Systems*. Paragraph S5.2.1 of this standard provides that the parking brak system on a passenger car and some school buses shall be capable of holding the vehicle stationary (*to the limit of traction on the braked wheels*) for 5 minutes in both a forward and reverse direction on a 30 percent grade. You stated that your understanding of this provision was as follows. During the tests to determine compliance with this provision, the axles of the subject vehicle must be locked by the parking brake. Your understanding is that the vehicle is permitted to slide down the 30 percent grade, and would be considered as complying with this provision of Standard No. 105 no matter how it slides as long as the vehicle's axles do not turn. This understanding is correct.; The parenthetical note in section S5.2.1 was included in the standar to address the situation where a particular 30 percent grade might have a low traction coefficient. In this situation, a vehicle might slide down the grade even though its parking brake system had held the vehicle axles locked for the required amount of time. NHTSA did not intend vehicle sliding because of a loss of traction by the tires to be considered a failure of the parking brake system. To make this intent clear, section S5.2.1 specifies that the parking brake system must hold the vehicle stationary only 'to the limit of traction on the braked wheels.' This language allows the standard not to specify the traction coefficient for the 30 percent grade. Since no particular traction coefficient is specified, compliance testing may be conducted on *any* 30 percent grade that satisfies the requirement of S6.9. That section requires that the parking brake test surface be clean, dry, smooth Portland cement concrete.; 2. Standard No. 110, *Tire Selection and Rims*. Paragraph S4.3 of this standard specifies that a placard containin certain safety performance indication shall be permanently affixed to 'the glove compartment door or an equally accessible location.' You asked if the door latch post, the inner surface of the glove compartment box, and the inward-facing surface of the driver's side door would be considered 'equally accessible locations.' Each of these locations could be equally accessible locations.; In several past interpretations, we have explained that locations fo the placard would be considered equally accessible if two conditions were met. These were:; >>>1. The alternative location must result in the placard bein positioned so that the vehicle operator can readily refer to it, and; 2. The alternative location must keep the placard relatively free fro exposure to substances that could destroy the placard or render it illegible.<<<; If you position the placard on any of your three alternative location so that the vehicle operator can easily refer to it and where the placard would be protected from substances that could destroy it, we would consider each of those alternative locations as 'equally accessible locations' for the purposes of Standard No. 110.; 3. Standard No. 302, *Flammability of Interior Materials*. Paragraph S4.1 of Standard No. 302 sets forth a listing of th components of vehicle occupant compartments that must be certified as complying with the flammability resistance requirements of paragraph S4.3. You listed nine components not specifically listed in paragraph S4.1 and asked whether those components were required to be certified as meeting the flammability resistance requirements. The answer to your question depends on whether the components are designed to absorb energy on contact by occupants in the event of a crash.; Paragraph S4.1 represents a complete listing of all components in ne vehicles that must comply with the flammability resistance requirements. Any component not identified in paragraph S4.1 is not subject to the flammability resistance requirements. The only item on that listing that might be applicable to the nine components about which you asked is '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.' Thus, you must determine which of the nine components you asked about are so designed. We would assume that knee bolsters are designed to absorb energy on contact by occupants in the event of a crash. These and any other of the nine components so designed must be certified as complying with the flammability requirements of Standard No. 302. Any of the nine components not designed to absorb energy are not required to comply with the flammability requirements.; 4. Part 575.101. *Consumer Information Regulations, Vehicle Stoppin Distance*.; You noted that S575.101 requires vehicle manufacturers to disseminat information about the minimum stopping distance for groups of passenger cars. Section 575.101(c) requires that each passenger car in the group to which the stopping distance information applies shall be capable of performing at least as well as the information indicates, *under the test conditions and procedures specified in S6 and S7 of Standard No. 105. This specification was added in an amendment published on January 6, 1976 (41 FR 1066). Before that amendment, S575.101 had specified separate test conditions and procedures for the stopping distance information. Those conditions specified that the vehicle's brakes were to be burnished and then the stopping distance was to be measured. In place of those conditions, S575.101(c) now specifies that the stopping distance information should express the *minimum* stopping distances that can be met or exceeded by each vehicle in the group to which the information applies, using the test conditions and procedures of Standard No. 105. Since stopping distances decrease after burnish, the post-burnish results represent the *minimum* stopping distances that can be met or exceeded by the vehicles. Therefore, the pre-burnish stopping distances need not be reflected in the stopping distance information manufacturers make available to consumers.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0246OpenMr. Fred C. Zimmer, Evans, Gentithes and Meermans, 220 East Market Street, Warren, Ohio 44481; Mr. Fred C. Zimmer Evans Gentithes and Meermans 220 East Market Street Warren Ohio 44481; Dear Mr. Zimmer: Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 15 USC 1381 et. seq., the National Highway Safety Bureau issued Federal Motor Vehicle Safety Standard 109 (FMVSS-109). This standard set forth strength, bead unseating, endurance, high speed and labeling requirements for passenger car tires manufactured on or after January 1, 1968, for use on cars manufactured after 1948. This standard does not apply to other types of tires. A copy of FMVSS-109 is enclosed. A manufacturer self-certifies that the tire meets the minimum requirements of the standard by molding the symbol 'DOT' into the tire. Subsequent identification of the tire as a 'second' would not negate the certification.; The National Highway Safety Bureau is currently testing many bran /size tires to verify their conformance to Federal Motor Vehicle Safety Standard No. 109. The tests are conducted at independent laboratories under contract to the Government. Results of these tests are released to the public in a monthly summary.; The test results does not reflect the Bureau's position on the matter Favorable test results should not be interpreted as necessarily establishing that a specific tire is in conformity with the standard, similarly, unfavorable test results should not be interpreted as establishing nonconformance.; Copies of individual test reports con be obtained, for a fee of $3.0 per publication, from the Clearinghouse for Federal Scientific and Technical Information, Springfield, Virginia 22151. Should sufficient data be left remaining on the tire in question for proper identification you may wish to avail yourself of this service.; There is an organization which could possibly furnish you with the nam of an individual capable of analyzing the causes of tire failures. Their name and address is: America Council of Independent Laboratories, Incorporated. 1714 West Capitol Avenue, Houston, Texas 77007.; I trust this information will be useful to you, and I appreciate thi opportunity to be of assistance.; Sincerely, Francis Armstrong, Director, Office of Compliance, Moto Vehicle Programs; |
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ID: aiam2781OpenF. W. Flowers, Jr., General Engines Co., Inc., Interstate 295, Thorofare, NJ 08086; F. W. Flowers Jr. General Engines Co. Inc. Interstate 295 Thorofare NJ 08086; Dear Mr. Flowers: This responds to your January 13, 1978, letter asking whether prior t September of 1976, the National Highway Traffic Safety Administration (NHTSA) required the GAWR determination to be based upon an 'unrestricted' speed of 60 miles per hour.; The NHTSA requires that a vehicle's GAWR be based upon an unqualifie speed of 60 miles per hour. This GAWR computation is then inserted on a vehicle's certification plate by the manufacturer to inform users of the safe GAWR. However, it is permissible to then list at the bottom of a certification plate different GAWR's based upon reduced speeds. If you intended one of your vehicles to operate under a reduced speed with a higher GAWR, you should have marked the correct GAWR on the certification label computed at 60 miles per hour and listed the higher GAWR's for the reduced speeds at the bottom of the plate.; The 1976 amendment to which you refer, Standard No. 120, continues t require the same approach to GAWR as has been the agency's practice for many years. The only difference incorporated by the 1976 amendment is that those vehicles that are unable to attain speeds of 50 miles per hour in 2 miles need not base their determination on the 60 miles per hour figure. These vehicles may compute their GAWR's at a reduced speed. Nonetheless, they are still permitted to list at the bottom of the certification plate higher GAWR's for further reduced speeds.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5044OpenMr. Scott D. Boone Van Conversions, Inc. 5255-Suite 16 Hull St. Richmond, VA 23224; Mr. Scott D. Boone Van Conversions Inc. 5255-Suite 16 Hull St. Richmond VA 23224; "Dear Mr. Boone: This responds to your letter of September 4, 199 requesting information on standards applicable to vans you manufacture for use by day care centers. These vehicles have a 21 passenger capacity. During a September 16 phone conversation between Mary Versailles of my staff and Mr. George Croft of Van Conversions, Inc., Mr. Croft indicated that your company purchases incomplete vehicles manufactured by Ford (the E-250 chassis) and completes them into finished vehicles, by such operations as installing seats and seat belts. According to Mr. Croft, the completed vehicles have a gross vehicle weight rating (GVWR) of less than 10,000 pounds. Mr. Croft stated that your company was particularly interested in new requirements for lap/shoulder belts. I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (the Safety Act, 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. Your company would be considered a final-stage manufacturer under our regulations. As a final stage manufacturer, your company's certification responsibilities would depend on the information provided by the manufacturer of the incomplete vehicle. Under 49 CFR Part 568, the incomplete vehicle manufacturer must furnish your company with a document which states one of the following three things concerning the incomplete vehicle, for each of the safety standards: 1. The vehicle when completed will conform to the safety standard if no alterations are made to any identified components of the incomplete vehicle. 2. The vehicle when completed will conform to the safety standard if specific conditions are followed by the final-stage manufacturer. 3. Conformity with the safety standard is not substantially affected by the design of the incomplete vehicle, so the incomplete vehicle manufacturer makes no representation as to conformity with the standard. Your company, as the final stage manufacturer, is required to certify that each vehicle you complete complies with all applicable safety standards. Such certifications may be based entirely upon the incomplete vehicle manufacturer's instructions and advice set forth in the document furnished with the incomplete vehicle. The 21 passenger vehicles your company manufactures would be considered 'buses' under NHTSA regulations. NHTSA defines a 'bus' as 'a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons.' (49 CFR 571.3). In addition, your 21 passenger vehicles might be considered 'school buses' if the day care center to which you sell the vehicle would be considered a school. A day care center would be considered a school if the function of the facility was primarily educational, rather than custodial. A 'school bus' is defined as 'a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.' With respect to seat belts, Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, requires a bus, other than a school bus, with a GVWR of 10,000 pounds or less to have a lap/shoulder belt at every outboard seating position, and either a lap belt or a lap/shoulder belt at every other seating position. Standard No. 208 requires a school bus with a GVWR of 10,000 pounds or less to have a lap/shoulder belt at the driver's and right front passenger's seating positions, and either a lap belt or a lap/shoulder belt at every other seating position. I am enclosing two publications for your information. The document titled 'Federal Motor Vehicle Safety Standards and Regulations' will provide you with a summary description of the requirements of each standard, and a list of the types of vehicles to which each standard applies. The other document is a general information sheet for manufacturers which highlights the relevant Federal statutes and regulations, and explains how to obtain copies of the regulations. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam3893OpenMr. John Humphrey, General Manager, Fleet Maintenance Division, Office of Fleet Management, United States Postal Service, Delivery Services Department, 475 L'Enfant Plaza, SW, Washington, DC 20260-7200; Mr. John Humphrey General Manager Fleet Maintenance Division Office of Fleet Management United States Postal Service Delivery Services Department 475 L'Enfant Plaza SW Washington DC 20260-7200; Dear Mr. Humphrey: This is in reply to your letter of January 15, 1985, to Taylor Vinso of this office asking for a waiver of the maximum height requirement so that the Postal Service may install center stop lamps on its new delivery trucks mounted from 75 to 83 inches above the road surface.; You do not need an exemption in order to install the lamp at the heigh you desire. First, Standard No. 108 requires the installation of a center high mounted stop lamp on passenger cars only, and not on trucks. Secondly, the 72-inch limitation on stop lamp mounting height imposed by Standard No. 108 for stop lamps applies only to the stop lamps that are mounted on either side of the vertical centerline. There is no limitation on the mounting height of the center lamp, when required on a vehicle, or prohibition against mounting it above 72 inches on a vehicle that is not required to have it.; We appreciate the interest of the Postal Service in reducing rear en accidents but would like to point out that the efficacy of the lamp on vehicle (sic) other than passenger cars is unknown. Our studies showed that the lamp was most effective at the approximate eye height of the driver in a following vehicle, and also as an alert to the driver behind who saw the highmounted light through the intervening car. Thus, the Postal Service with its lights mounted above the rear door should not expect its vehicles in service necessarily to replicate this agency's test experience.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0616OpenMr. Carl H. Johnson, Director, Olin Corporation, Energy Systems Division, East Alton, Illinois 62024; Mr. Carl H. Johnson Director Olin Corporation Energy Systems Division East Alton Illinois 62024; Dear Mr. Johnson, This is in response to your letter of February 22, 1972, in which yo asked for my 'comments reconciling' the position of the NHTSA concerning the rulemaking on Warning Devices (Docket 4-2) with the Bureau of Motor Carrier Safety proposal regarding the carrying of the triangular devices by regulated carriers. You suggested that there was an inconsistency between the statements in a letter that I sent to several Congressmen that we 'anticipate that fusees will continue to be in wide use after the adoption of the rule,' and the BMCS proposal that motor carriers be required to carry the triangular devices.; I do not agree that there is an inconsistency. Fusees are in wide us by groups that would be unaffected by the proposed BMCS rule, State and local police come immediately to mind. Furthermore, ever motor carriers would be free to carry fuses in addition to the required triangular devices if they wished.; I did not state or imply that the NHTSA and BMCS regulations, if an when issued, would have no effect whatsoever on the market for fusees. Obviously, a market that is created or augmented by a government regulation may well be affected when the regulation is changed.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1904OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street West, Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your letter of March 17, 1975, requestin clarification of the requirement and demonstration procedure for sliding doors specified in Federal motor vehicle safety standard No. 206, *Door Locks and Door Retention Components*.; You have indicated that it is your understanding that derailment of th guide roller or track and slide combination is permissible under Standard No. 206 as long as door stoppers and door locks withstand the specified transverse load. This interpretation is correct. Standard No. 206 requires in S4.3 that the track and slide combination *or other supporting means* for each sliding door not separate when a transverse load of 4,000 pounds is applied, with the door in the closed position. Since the track and slide combination is not designed to bear loads at the closed position, derailment of the combination is of no consequence. Other supporting means must support the test load.; You have also outlined three demonstration procedures and asked whethe they 'fall within the intent' of S5.3 of Standard No. 206. While all three procedures might satisfy the literal requirements of S5.3, procedure 'C' most thoroughly implements the intent of Standard No. 206.; The bench test fixture described in 'A' is particularly troublesome. O the Toyota vehicle in question, resistance against a transverse load applied at the leading edge appears to depend heavily on the lock at the trailing edge. Since the resistance of this lock must be transmitted to the leading edge stoppers through the door itself, the door plays an important role in the performance of the entire system. Yet the rigid door described in 'A' would almost certainly behave differently than an actual door, in which case the test results would not demonstrate compliance with S4.3.; A similar problem exists with regard to procedure 'B', in that th rigid pillar employed might provide much more resistance to bending than the actual vehicle pillar. Bending of the pillar at the door's leading edge would substantially lessen the resistance to opening provided by the stoppers (B & C in your Fig. 1).; Standard No. 206 does not set out separate requirements for every doo design. Indeed, this standard was adopted in anticipation that most sliding doors would incorporate a track- and-slide combination as a supporting means. Where a different design is employed, as in this instance, procedure 'C' best fulfills the intent of the standard by providing the most authentic demonstration.; Please do not hesitate to write if we can be of further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3939OpenThe Honorable Dick Cheney, House of Representatives, Washington, DC 20515; The Honorable Dick Cheney House of Representatives Washington DC 20515; Dear Mr. Cheney: Thank you for your letter requesting clarification of the Department' regulations pertaining to the use by school districts of commercial-type buses as activity buses. I appreciate this opportunity to respond to your concerns.; You requested clarification of whether the National Traffic and Moto Vehicle Safety Act prohibits the sale of a used commercial-type bus to a school district for use on activity trips. The Act only applies to the manufacture and sale of new motor vehicles. Thus, persons selling a *used* bus to a Wyoming school district are not subject to the Act's requirement to sell certified school buses, and a used commercial-type bus, regardless of its model year, may be sold as an activity bus.; You also had several questions about Highway Safety Program Standar No. 17, *Pupil Transportation Safety*. You are correct that states have the discretion to adopt all or part of Standard No. 17, and that the standard has no direct effect on the purchase of used buses by local school districts. Congress has given the Department the discretion under the Highway Safety Act not to insist that a State comply with every requirement of the highway safety standards. While the Department has stressed the importance of a strong pupil transportation program, consistent with Standard No. 17, the Department has not insisted that the States comply with every feature of the standard.; You asked whether Wyoming school districts can obtain an administrativ waiver from the requirements of Standard No. 17 if Wyoming has adopted the standard as its own policy. Since a state has the discretion to adopt and amend Standard No. 17 as it determines to be necessary for its highway safety program, the effect of Standard No. 17 on Wyoming school districts is a matter for the state to decide. An administrative waiver from NHTSA is therefore not necessary.; I trust this letter has clarified our regulations for school buses. With best wishes. Sincerely, Elizabeth Hanford Dole |
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ID: aiam5414OpenSamson Helfgott, Esq. Helfgott & Karas, P.C. 60th Floor Empire State Building New York, NY 10118-6098; Samson Helfgott Esq. Helfgott & Karas P.C. 60th Floor Empire State Building New York NY 10118-6098; "Re: Your Ref. No.: 12.065 Dear Mr. Helfgott: We have received you letter of July 1, 1994, to Paul Jackson Rice, former chief counsel of this agency, on behalf of your client Harold Caine, with respect to whether a certain supplementary lighting system would be permissible under Federal Motor Vehicle Safety Standard No. 108. You have enclosed copies of two previous letters that this Office has sent you on other supplementary lighting systems developed by Mr. Caine. You state that 'Mr. Caine is considering the possibility of utilizing a combination of red and amber lighting arrangement to be placed along the side of trucks and other vehicles.' Since you later ask 'whether the presence of the red and amber lights on the sides of the vehicle would be permissible under Standard No. 108', we interpret this as meaning that the red and amber lamps would be in addition to those red and amber lamps that are presently required on the sides of vehicles (the side marker lamps) by Standard No. 108. However, your letter fails to state the number and candela of the lamps, and how they would be arrayed along the side of the vehicle. As we understand it, during normal vehicle operation, the amber side lamps of the system would be activated. When the brake pedal is applied, the amber lamps are extinguished and the required stop lamps and red side lamps of the system would be activated. As you know from previous correspondence, supplementary lighting equipment is prohibited only if it impairs the effectiveness of lighting equipment that is required by Standard No. 108. Standard No. 108 specifies that front and intermediate side marker lamps (those at or near the midpoint of the length) shall be amber, and that rear ones shall be red. If, in the Caine system, the amber supplementary lamps are mounted to the front of the vehicle side and the red supplementary lamps to the rear of the vehicle side (i.e., amber from front to and including the midpoint, red, after the midpoint to the rear), we do not see that the supplementary system would have an impairing effect upon the stop lamps or rear side marker lamps and reflectors. If, however, the system consists of alternating red and amber lamps displayed along the side of the vehicle, then the potential for confusion as to orientation of the trailer could result, impairing the effectiveness of the color code of the required side marker lamps. We assume that the candela of the lamps in the Caine system is no greater than that permitted for the side marker lamps that are required by Standard No 108, but if the candela is greater, that would also create the potential for impairment if the array alternates red and amber lamps. You have also asked 'whether there are any prohibitions that might prevent utilization of this structure on the sides of the vehicles.' We know of none, however, it is possible that some States might have laws that would affect this. As we are unable to advise you on State law, we suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3313OpenMr. Brian Gill, American Honda Motor Co., Inc., 100 W. Alondra Blvd., P.O. Box 50, Gardena, CA 90247; Mr. Brian Gill American Honda Motor Co. Inc. 100 W. Alondra Blvd. P.O. Box 50 Gardena CA 90247; Dear Mr. Gill:#This responds to your letter of April 22, 1980, askin two questions about Standard No. 101-80, *Controls and Displays*.#Your first question concerns whether a display incorporated in the tachometer instrument face that shows which gear position has been selected by the automatic transmission control lever is an 'informational readout display.' You explained that the display 'consists of 5 stacked transparent screens on which are printed 'D', '2', 'N', 'P', 'R' to identify the transmission control lever positions. Each screen is illuminated by an incandescent bulb which is energized selectively through contacts at the control lever.'#The display which you have described is not an informational readout display. Section 4 of the standard defines 'informational readout display' as 'a display using light-emitting diodes, liquid crystals or other electro illuminating devices where one or more than one type of information or message may be displayed.' As explained in the June 26, 1978, preamble to the final rule establishing Standard No. 101-80, the agency did not want to inhibit the development of electronic 'readout' panels which present the driver with specific information concerning vehicle and environmental conditions affecting safety. The preamble further described these devices as displays 'capable of exhibiting information and warning with word messages and not with symbols.' The device you have described uses symbols instead of words and conventional incandescent bulb technology instead of electronic technology and thus is not an informational readout display.#The display you have described is a gauge. Section 4 of the standard defines 'gauge' as 'a display that is listed in S5.1 or in Table 2 and is not a telltale.' Section 5.1 and Table 2 do not identify the automatic gear position as a telltale. Likewise, an automatic gear position display does not meet the definition of 'telltale.' Section 4 of the standard defines 'telltale' as 'a display that indicates, by means of a light-emitting signal, the actuation of a device, a correct or defective functioning or condition, or failure to function.' In this case, the display does not indicate the activation of a device since a transmission is always activated. Likewise, the display does not indicate that the transmission is functioning correctly or improperly or has failed to function. Section 5.3.3 provides that the light intensity of each gauge shall be continuously variable. The display you have described does not comply with section 5.3.3, since it only has two light intensities.#Your second question concerns 'a display adjacent to the shift control lever which shows the transmission shift level sequence. The identifying characters 'P', 'R', 'N', '2', 'D', are shown on a transparent screen, the position selected is indicated by a colored panel which moves with the shift control level.' You explained that the 'colored panel *only* is illuminated when the headlights are switched on showing which position is selected, the other positions on the display are not illuminated.' [Emphasis in the original]#You asked whether the display is exempt from the illumination requirements of the standard because it is 'a hand- operated control mounted upon a...floor console' or because it is a 'telltale.' Section 5.1 and Table 2 of the standard classify an automatic gear position indicator as a display. Thus, an automatic gear position indicator cannot be a 'hand-operated vehicle control.'#Further, the display that you have described is not a 'telltale.' As explained above, an automatic gear position display is a gauge. According to your description, the display '*only* is illuminated when the headlights are switched on.' Section 5.3.3 of the standard requires the light intensity for gauges to be continuously variable. Since the illumination for the display you have described apparently is not variable, it would not comply with the standard.#If you have any further questions, please let me know.#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.