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: aiam0641OpenMr. W. G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in response to your letter of February 7, 1972, in which yo discussed some problems that you have encountered with the regulation on vehicles manufactured in two or more stages (49 CFR Part 568), as applied to the school buses of which you are the final-stage manufacturer. Since the receipt of your letter, Mr. Rumph of your company and Mr. Sweet of the Truck Body and Equipment Association met with Mr. Dyson of this office to discuss the issues raised in your letter. Also, on March 8 you sent a sample letter that you proposed to send to your customers.; As we understand the problem from your letter and the subsequen discussion, it is essentially that you are receiving chassis-cowls from school bus buyers, for mounting of your bodies as a final-stage manufacturer, which are inadequate for the purpose according to the gross vehicle and gross axle weight ratings now included with the incomplete vehicles under our multistage vehicle regulations, 49 CFR Part 568. The problem as you describe it appears to have arisen in the negotiation between the school bus buyers and the dealers from whom they bought the incomplete vehicles, in that the dealers sold chassis that were too lightly equipped with tires and axles for the loaded weight implicit in the buyer's specification, under both our certification regulations and accepted industry practice. You state that your company bears the immediate burden of the problem, because you have invested in the production of several dozen bodies whose installation is held up pending resolution of the problem.; From your discussion we assume that all parties are agreed that th bodies that the customers ordered (and you have built) are the ones that are to be used, and that the chassis that have been furnished to you can be economically modified to meet the requirements of our regulations and be safe for their intended use.; With these assumptions, we suggest the following course of action o your part:; 1. Complete each vehicle as planned. 2. Affix a certification label to each vehicle as you normally do stating on the label weight rating figures that will satisfy our regulations (Part 567) and the axle capacity requirements of the vehicle.; 3. Deliver the vehicle, but concurrently send a written statement b certified mail to the vehicle buyer to the effect that the vehicle *must be modified* in order to conform to the GVWR and GAWR figures on the certification label, both for purposes of safety and to conform to Federal regulations. The letter should advise the buyer to take the vehicle to a dealer of the chassis manufacturer for these modifications immediately upon receiving it. The sample letter you sent on March 8 will be satisfactory if you modify the second and third paragraphs to read as follows:; >>>'Federal Regulations 49 CFR Part 567, *Certification*, requires Blu Bird to certify the front and rear gross axle weight rating (GAWR) and the gross vehicle weight rating (GVWR) of completed vehicles, and specifies a minimum GVWR based on seating capacity.; 'Your vehicle may be shipped as it is, however, the values of GAWR an GVWR shown on the certification plate will be contingent on the chassis modifications indicated above. These changes *must*, in the interest of safety, be made before the vehicle is placed into service, and you should take the vehicle to your chassis dealer as soon as you receive it.'<<<; 4. Send copies of each such statement to (a) Office of Standard Enforcement, National Highway Traffic Safety Administration, Washington, D.C. 20590, (b) the manufacturer of the chassis that was delivered to you, and (c) the dealer from whom the buyer ordered the chassis, if any and where known to you.; This procedure is allowed only as to chassis that have already bee received by Blue Bird as of the receipt of this letter, and it should not be viewed as precedent for future action by any other persons. In the future, Blue Bird as the final-stage manufacturer must take responsibility for the vehicle as completed by it, to the extent of its knowledge of relevant facts.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1953OpenMr. J. W. Kennebeck, Manager, Emissions, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Emissions Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This responds to Volkswagen of America's March 25, 1975, petition fo rulemaking to amend S4.5.3.3 of Standard No. 208, *Occupant crash protection*, to allow, at the manufacturer's option, visual warning lamps which remain activated whenever front outboard safety belts are not in use. Your petition states that it supersedes Volkswagen's February 20, 1975 petition for rulemaking.; Your petition explains that Volkswagen, in offering a passive bel system in its Rabbit model on an optional basis, provides an ignition interlock system and a passenger-side warning system to encourage passive belt usage, although such systems are not required by the standard. You correctly note that a January 16, 1975, letter to Volkswagen from the NHTSA Office of Chief Counsel indicates that additional safety devices such as these are not prohibited by our minimum safety standards, as long as their installation does not have the effect of causing required systems not to comply.; Your petition requests an amendment of Standard No. 208's warnin provisions to permit a visual warning longer than the 4- to 8-second reminder light presently required by S4.5.3.3. You apparently have concluded that language in our January 16 letter prohibits the provision of any additional visual warning with a duration different than 4-8 seconds.; Our January 16 letter states 'additional [safety] devices could not b installed if that installation has the effect of causing the required systems not to comply.' This does not prevent the installation of a second visual warning which operates continuously when seat belts are not in use at either front designated seating position. The manufacturer who provides such additional warning would only have to ensure that the required 4- to 8-second visual reminder required under S4.5.3.3 operates independently of the additional warning.; For this reason, we conclude that Volkswagen may provide the additiona warning it desires without amendment of Standard No. 208. Accordingly, Volkswagen's petition is denied as unnecessary. Please advise the NHTSA if this interpretation does not permit Volkswagen to provide the degree of additional warning for which it petitioned.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam5013OpenThe Honorable Dave Durenberger United States Senate Washington, D.C. 20510-2301; The Honorable Dave Durenberger United States Senate Washington D.C. 20510-2301; "Dear Senator Durenberger: Thank you for your letter of April 28, 1992 concerning a product developed by your constituent, McNaughton Incorporated of Minneapolis, Minnesota. The product is a device to prevent a child from opening the buckle of a safety belt without adult assistance. You requested information on any regulations that pertain to this product. The agency has received inquiries about similar products in the past. While we understand parents' concerns that young children should not be able to easily get out of a safety belt, we have significant reservations about these types of products because they could significantly increase the difficulty of using the buckle release and thus hinder a person attempting to release the belt in an emergency. I am enclosing an August 6, 1986, letter from NHTSA's Chief Counsel to Ms. Ann Boriskie. As this letter explains, your constituent's product could not be installed by a commercial entity without violating Federal law. In addition, installation of your constituent's product by any person would be inconsistent with this agency's policy to encourage vehicle owners not to remove or otherwise tamper with vehicle safety equipment. You also asked for information on how McNaughton Incorporated could become involved in the national safety belt campaign. The Agency is currently working with a variety of public and private sector organizations to increase safety belt use to 70 percent by the end of 1992. The strategy focuses on increased law enforcement efforts coupled with aggressive community-based public information. There are many ways McNaughton can support these efforts. They can consider developing and implementing an in-house safety belt education program targeting their employees or applying for the 70 percent Honor Roll Program. They might be interested in supporting community awareness initiatives that promote the campaign, including the posting of billboards and the inclusion of safety belt messages in their on-going advertising. An expanded list of ideas is attached. If McNaughton Incorporated is interested in additional campaign information, they can contact Susan Gorcowski, Office of Occupant Protection, (202) 366- 2683. I appreciate your interest in the safety of motor vehicles and hope this information is helpful. Sincerely, Jerry Ralph Curry Enclosures"; |
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ID: aiam0211OpenMessrs. Ganglberger and Goerter, Semperit, Oesterreichish-Amerikanishe Gummiwerke Aktiengesellschaft, Werke 2, A-02514 Traiskirchen, N.Oe., Austria; Messrs. Ganglberger and Goerter Semperit Oesterreichish-Amerikanishe Gummiwerke Aktiengesellschaft Werke 2 A-02514 Traiskirchen N.Oe. Austria; Gentlemen: Thank you for your reply to our letter of December 11, 1969 concernin tires marked with the legend 'Farm Use Only Tires'.; Concerning the question you raise in your letter relating to the DO symbol, Standard No. 109 requires that the symbol be between the maximum section width and the bead to protect the lettering from obliteration during use. Therefore, placing the DOT symbol at the widest place on the side wall rib as illustrated in your enclosed drawing would not be permitted.; With regard to your question asking if the approved symbol and th manufacturer's code mark is necessary, the approved symbol signifies that the manufacturer certifies that the tire complies with the Standard and is, therefore, necessary. Tires exported to this country without the symbol would be in violation of the National Traffic and Motor Vehicle Safety Act of 1966. The code number is only required if your company manufactures a tire with a brand name other than its own, The purpose of the code number is to identify the manufacturer of the tire.; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel, Moto Regulations; |
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ID: aiam3597OpenMr. F. E. Bettridge, Board Chairman, Middlekauff, Inc., 1615 Ketcham Avenue, Toledo, OH 43608; Mr. F. E. Bettridge Board Chairman Middlekauff Inc. 1615 Ketcham Avenue Toledo OH 43608; Dear Mr. Bettridge: This is in reply to your petition of July 16, 1982, for a temporar exemption from Federal Motor Vehicle Safety Standard No. 301, *Fuel System Integrity*.; You have told us that 'as a seller and installer of truck bodies, w are frequently called upon to install a body on an incomplete vehicle furnished to us by a major manufacturer through his dealer.' Our regulation on vehicles manufactured in two or more stages (49 CFR Part 568) requires the manufacturer of an incomplete vehicle to furnish, with the vehicle, statements with respect to each of the standards which inform the final stage manufacturer of the vehicle's compliance status. With respect to Standard No. 301, each manufacturer should provide you with a statement of specific conditions of final manufacture under which the completed vehicle will conform or, alternatively, a statement that the vehicle when completed will conform if no alterations are made in identified components of the incomplete vehicle.; These statements afford a basis for your certification of complianc with Standard No. 301 without the necessity of testing. We would like to know which of these statements have been provided and why you may believe your manufacturing operations are such that you could not certify compliance with Standard No. 301.; We would also like to make clear that there is no legal requiremen that you crash test a $10,000 vehicle in order to demonstrate compliance. Certification may be based upon computer simulation, mathematical calculation, or engineering studies. Upon reflection you may decide that you have an adequate basis for certification with Standard No. 301.; Until we hear further from you, we shall hold your petition i abeyance.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4252OpenMr. G.T. Doe General Manager - Product Design Lotus Engineering, Ltd. Norwich, Norfolk NR14 8EZ England GREAT BRITAIN; Mr. G.T. Doe General Manager - Product Design Lotus Engineering Ltd. Norwich Norfolk NR14 8EZ England GREAT BRITAIN; "Dear Mr. Doe: This responds to your letter in which you asked how th conversion of a convertible to a hardtop would affect the applicability of two of our safety standards. I regret the delay in this response. You explained that Lotus proposes to introduce a new two seat convertible into the United States. These cars will be imported into the United States and delivered to dealers and distributors as convertibles. However, you stated that Lotus intends to offer a 'factory manufactured and approved' hardtop conversion for these convertibles. Dealers would remove the convertible canopy and support frame and permanently attach a hard roof to the vehicle. The converted cars would be sold to the public as hardtops. You then asked whether the convertible cars would be treated as hardtops or convertibles for the purposes of Standards No. 208 and No. 216. I would like to set the foundation for answering your specific questions by first addressing a few basic points. The agency has defined a convertible as 'a vehicle whose A-pillar (or windshield peripheral support) is not joined at the top with the B-pillar or other rear roof support rearward of the B-pillar by a fixed rigid structural member.' In this case, your kit will join the A-pillar and B-pillar of the convertible by a fixed rigid structural member. After this conversion, the car would no longer be a convertible, as that term is used by NHTSA. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(1)(A)) provides that, 'No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle ... manufactured on or after the date any Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard except as provided in subsection (b) of this section.' This provision makes clear that a dealer would be prohibited from selling a hardtop passenger car that did not comply with all safety standards applicable to hardtops, even though the passenger car conformed to all standards applicable to convertibles when it was imported and delivered to the dealer. The exceptions set forth in section 108(b) of the Safety Act would not permit a dealer to sell a car that had been converted from a complying convertible into a hardtop without being modified to comply with all safety standard requirements applicable to hardtops. Section 108(b)(1) specifies that the prohibition on selling or offering to sell passenger cars that do not conform with all safety standards does not apply after the first purchase of the car in good faith for purposes other than resale. However, a dealer that converts a car into a different type before the first purchase could not rely on this exception. Section 108(b)(2) specifies that the prohibition on selling nonconforming cars shall not apply to any person who establishes that he or she did not have reason to know in the exercise of due care that the car did not conform to the safety standards, or to a person who holds a certification of conformity from the manufacturer or importer of the car, unless that person knows that the car does not conform. In the case of this proposed conversion, the dealers would hold a certificate of conformity from Lotus or the importer for the convertible version of this car. However, the dealers would also know that they had converted the car into a hardtop, and that they had no certificate of conformity for the car as a hardtop. Further, such dealers would have reason to know that the requirements in the safety standards for hardtops are different from those for convertibles. Finally, the dealers would know that the hardtop version of the car had not been certified as conforming to all applicable standard requirements. Indeed, as alterers of completed vehicles, the dealers would be required to recertify the cars under 49 CFR /567.7. The exceptions to section 108(a)(1)(A)'s prohibition set forth in sections 108(b)(3)-(5) are not applicable in this situation. Hence, dealers could not legally sell these converted cars to the public for the first time, unless the cars conform with all safety standards applicable to hardtop passenger cars. With this background, I will now address your specific questions. They were: 1. Convertibles are not required to conform to the roof crush requirements of Standard No. 216, Roof Crush Resistance - Passenger Cars (49 CFR /571.216). Would the designation of the vehicle as a convertible remain unaffected by the hardtop conversion? ANSWER: As explained above, the answer to this question is no. Any car that is converted to a hardtop before its first sale for purposes other than resale must comply with all standards applicable to hardtops. Assuming such cars do not conform to the rollover test requirements in section S5.3 of Standard No. 208 by means that require no action by vehicle occupants, these cars would be subject to the requirements of Standard No. 216. 2. Would the requirement for seating and restraint system provision remain unaffected by the hardtop conversion? ANSWER: No. It is not clear to which seating requirements you are referring. However, you stated in your letter, 'It is conceivable that, although the shelf would not be recognised as a seating area, small occupants could travel in this area.' The requirements for seating systems are dependent upon the existence of a 'designated seating position.' This term is defined in 49 CFR /571.3 as follows: 'Designated seating position' means any plan view location capable of accommodating a person at least as large as a 5th percentile adult female, if the overall seat configuration and design and vehicle design is such that the position is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats. We cannot determine from your letter if the shelf area is capable of accommodating a 5th percentile adult female, nor can we determine whether the area's configuration and design is such that the position is likely to be used as a seating position while the vehicle is in motion. It appears from the enclosed drawings that any person riding in the shelf area would have to sit on the floor or prop themselves on the wheel wells. If this is true, the shelf area would not be considered to have any designated seating positions. The required occupant restraint system would also be affected by converting the convertibles into hardtops. As explained above, cars that are converted to hardtops by dealers before sale to the public would not be treated as convertibles for the purposes of Standard No. 208, Occupant Crash Protection (49 CFR /571.208). Since the cars would no longer be considered convertibles, they would have to be equipped with lap/shoulder belts at both designated seating positions, pursuant to section S4.1.2.3.1 of Standard No. 208. Additionally, these cars would not be eligible for the exemption for convertibles during the phase-in of the automatic restraint requirements in Standard No. 208. I sent a letter to General Motors (GM) on September 18, 1987, stating that GM may be considered the manufacturer of Lotus cars that are imported into the United States (copy enclosed). Therefore, any Lotus cars that are converted into hardtops would have to be included in GM's annual production to determine compliance with the phase-in requirement, pursuant to sections S4.1.3.1.2, S4.1.3.2.2, and S4.1.3.3.2 of Standard No. 208. I have also sent a copy of this letter to General Motors. Sincerely, Erika Z. Jones Chief Counsel Enclosure cc: J. Douglas Hand, Esq. Legal Staff, General Motors Corporation P.O. Box 33122 Detroit, MI 48232 /"; |
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ID: aiam1050OpenMr. Charles E. Ferreira, Jr. President, General Seating Company, Topton, PA 19562; Mr. Charles E. Ferreira Jr. President General Seating Company Topton PA 19562; Dear Mr. Ferreira: This is in reply to your letter of March 8, 1973, requestin clarification on three points related to Federal Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release.; >>>1. Glass Types. Glazing materials must conform with Standard No 205, Glazing Materials. ANSI Z26, incorporated into Standard No. 205 by reference, can be purchased from the American National Standards Institute, 1430 Broadway, New York, New York 10018. SAE J673a can be purchased from the Society of Automotive Engineers, Two Pennsylvania Plaza, New York, New York 10001.; 2. Locks. Paragraph S5.3.2 reads, When tested under conditions of S6 both before and after the window retention test required by S5.1, each emergency exit shall allow *manual release* of the exit...' (emphasis added).; 3. Tests. Two studies were contracted over the past few years whic related to bus windows. Reports of these studies may be purchased from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22151.; (a) PB 195-231, Study of Bus Side Windows,' by All America Engineering Company. Cost: $3.00; (b) PB 198-772, Escapeworthiness of Vehicles and Occupant Survival Part 1' by University of Oklahoma Research Institute. Cost:$6.00; PB 198-773, Escapeworthiness of Vehicles and Occupant Survival - Part 2 and 3,' by University of Oklahoma Research Institute. Cost: $6.00.<<<; I am enclosing a copy of Standard No. 205. If I can be of further service, please do not hesitate to ask. Sincerely, Robert L Carter, Associate Administrator, Motor Vehicle Programs |
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ID: aiam4602OpenCONFIDENTIAL; CONFIDENTIAL; "Dear CONFIDENTIAL: Thank you for your letter requestin interpretations of how Standards No. 203, Impact Protection for the Driver from the Steering Control System (49 CFR /571.203) and 210, Seat Belt Assembly Anchorages (49 CFR /571.210) apply to a vehicle in which the driver's seating position is equipped with both an air bag and an automatic safety belt. We have concluded that the vehicles described in your letter appear not to be subject to the requirements of Standard No. 203, based on your representation that the driver's position in those vehicles would comply with the occupant protection criteria in section S5.1 of Standard No. 208, Occupant Crash Protection (49 CFR /571.208) by means of the air bag alone. Further, if the manufacturer certifies that the driver's position in those vehicles would comply with the occupant protection criteria in section S5.1 of Standard No. 208 with the automatic safety belts in place, the anchorages for the automatic belts would be exempted from the anchorage location requirements in Standard No. 210. These conclusions are explained below. Before discussing the substantive issues raised in your letter, I would like to respond to your request that NHTSA not publicly release the identities of the vehicle manufacturer or its counsel because the development of vehicles with both air bags and automatic safety belts 'is competitively sensitive.' We hereby grant your request. You provided us with a version of your letter deleting all references to the identity of the manufacturer and its counsel. We will make available to the public your purged version of your letter to us and a version of this letter purged of all references to your identity. Standard No. 203 With respect to Standard No. 203, section S2 of Standard No. 203 provides that the standard 'does not apply to vehicles that conform to the frontal barrier crash requirements (S5.1) of Standard No. 208 by means of other than seat belt assemblies.' The first question is whether S2 exempts from Standard No. 203 those vehicles whose driver's seating position conforms to the frontal barrier crash requirements by means other than belt assemblies, or whether S2 only exempts from Standard No. 203 those vehicles in which both the driver's position and the right front outboard seating position conform to the frontal barrier crash requirements by means other than belt assemblies. After examining the history and purpose of this requirement, we have concluded that vehicles are not subject to Standard No. 203 if the driver's seating position offers the specified occupant protection, for the following reasons. The title of Standard No. 203 explicitly states that it is intended to provide protection for the driver, not for any other vehicle occupants. Moreover, section S2 of Standard No. 203 was promulgated after NHTSA determined that compliance with the requirements of Standard No. 203 could impede the development and installation of a more advanced occupant protection system, such as air bags, at the driver's position. See 40 FR 17992, April 24, 1975. This determination would not apply with respect to any seating positions other than the driver's position, because compliance with the requirements of Standard No. 203 would have no positive or negative effects on the development and installation of occupant protection systems at any other seating positions. Given the history and purpose of Standard No. 203 in general and section S2 in particular, section S2 must be interpreted so that Standard No. 203 does not apply to vehicles whose driver's seating position offers the specified occupant protection. Having determined that one examines only the driver's seating position to see whether a vehicle is exempt from the requirements of Standard No. 203 by virtue of the provision in section S2 of the standard, we must now determine whether a vehicle whose driver's seating position is equipped with both an air bag and an automatic safety belt can be said to conform to S5.1 of Standard No. 208 by means other than seat belt assemblies. We conclude that it can if the manufacturer certifies that the driver's seating position conforms with S5.1 of Standard No. 208 by means of the air bag alone. If the manufacturer certifies that the air bag alone provides the specified occupant protection at the driver's seating position, then, for purposes of S5.1 of Standard No. 208, the installation of the automatic safety belt would be a voluntary action by the vehicle manufacturer. The agency has long stated that manufacturers are free to install systems or components in addition to the required safety systems or components, provided that the additional systems do not destroy the ability of the required systems to comply with the applicable safety standards. Therefore, if a manufacturer certifies that an air bag alone provides the specified occupant protection at the driver's seating position, an automatic safety belt at that seating position would be a safety system installed in addition to the air bag system. The only limitation on the installation of automatic safety belts at such seating positions would be that the combination of the automatic safety belt and the air bag must comply with the requirements of S5.1 of Standard No. 208. If a manufacturer certifies that the driver's seating position in a vehicle complies with S5.1 of Standard No. 208 by means of an air bag alone, that vehicle would be exempt from Standard No. 203 even if an automatic safety belt system were also provided for the driver's seating position. If the manufacturer cannot certify that the driver's seating position complies with the requirements of S5.1 by means of the air bag alone, then both the air bag and the automatic safety belt are necessary to provide the required level of occupant protection. In this case, the vehicle would be subject to Standard No. 203, because it relies on a seat belt system to conform with the requirements of S5.1 of Standard No. 208. Standard No. 210 Section S4.3 of Standard No. 210 provides that: 'Anchorages for automatic and for dynamically tested seat belt assemblies that meet the frontal crash protection requirement of S5.1 of Standard No. 208 (49 CFR /571.208) are exempt from the location requirements of this section.' This exemption is premised on the agency's conclusion that the anchorage location requirements are unnecessary when the same aspects of performance are indirectly tested in dynamic testing. See 50 FR 14589, at 14595, April 12, 1985. That is, the anchorage location requirements are an indirect means of ensuring that a belt system will afford adequate protection to a user in a crash. The dynamic testing requirements directly measure the protection the belt system offers belt users in a frontal crash. Your letter referred to a March 14, 1988 letter we sent to Mr. Karl-Heinz Faber. In his letter, Mr. Faber asked whether standard equipment items in the vehicle would be operational during compliance testing. We responded in part as follows: During its compliance testing, NHTSA combines a test of the occupant crash protection capabilities of automatic or manual safety belts with testing done to determine compliance with other standards. ... In conducting these compliance tests, NHTSA tests vehicles in their 'as delivered' form with all items of standard equipment present in the vehicle. Thus, if a vehicle has devices, such as an air bag system or pre-tensioning devices for the belts, installed in the vehicle as items of standard equipment, NHTSA's compliance testing is conducted with those items in place and fully functioning. In other words, Standard No. 210 does not require that the safety belt alone provide the specified level of occupant protection in order for the anchorages to be exempt from the anchorage location requirements. Such a requirement would be unrealistic, since occupant crash protection depends on the safety belt system working synergistically with other vehicle features, such as energy absorbing instrument panels, collapsible steering columns, and anti-lacerative windshield glass. Because of this synergism, NHTSA has always conducted its Standard No. 208 compliance testing with all items of standard equipment in place and functioning during the test. We would treat an air bag in the same way. Therefore, if the vehicle manufacturer certifies that the driver's seating position complies with the occupant protection criteria in Standard No. 208 with an automatic belt in position and functional during the test, the anchorages for that automatic belt would be exempt from the location requirements in Standard No. 210. This certification by the manufacturer would be based on the protection afforded by the automatic belt and all other standard features in the vehicle, including air bags. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1400OpenMr. Paul J. Kruder, President, CIMS COS., P.O. Box 1610, Akron, Ohio 44309; Mr. Paul J. Kruder President CIMS COS. P.O. Box 1610 Akron Ohio 44309; Dear Mr. Kruder: This is in reply to your letter of January 15, 1974, requestin information on the labeling requirements of Motor Vehicle Safety Standard No. 117. The agency has recently amended Standard No. 117 in accordance with the Court of Appeals decision in *National Tire Dealers' and Retreaders' Association v. Brinegar*. The standard as amended requires only that retreaded tires be permanently labeled with maximum load. All the other information required -- size, tubeless or tube-type, maximum inflation pressure, and radial and bias/belted designation -- may appear on affixed labels. The amendment does allow the use of one permanent label to apply all of the required information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0138OpenMr. R. Hadekel, Chief Engineer, Trico-Folberth Ltd., Great West Road, Brentford, Middlesex, England; Mr. R. Hadekel Chief Engineer Trico-Folberth Ltd. Great West Road Brentford Middlesex England; Dear Mr. Hadekel:#Thank you for your letter of January 1, 1969 concerning your windshield washer system.#Apparently our letter of October 3, 1968, to Mr. B. C. Johnson was misunderstood. In Mr. Johnson's inquiry of August 23, 1968, he stated 'it is easy to deliver 15 cc's of fluid inside the three seconds specified.' The wording of our reply acknowledged that this performance would be acceptable--it was not intended to be a literal interpretation of our requirements or the SAE Recommended Practice.#We learned that the SAE Windshield Wiping Subcommittee plans to revise J942, Passenger Car Windshield Washer Systems, to clarify the particular points you question. Meanwhile, we think the intent of Section S4.2 of Standard No. 104 is satisfied by the following interpretation of the referenced SAE Recommended Practice:#>>>1. Paragraph 3.1 of J942 requires that 75% of the effective wiped area be cleared in 10 wiper cycles or less. Section S4.2.1 of Standard No. 104 requires that these areas be established in accordance with subparagraph S4.1.2.1 of Standard No. 104.#2. The requirement to wipe 75% clear must also be met within 15 seconds as stipulated in paragraph 4.1.3(c) of J942.#3. A washer cycle is defined in paragraph 2.11 of J942 as 'The system actuation sufficient to deliver approximately 15 cc of fluid to the windshield glazing surface.' Note this definition does not actually define the number of actuations necessary to deliver the 15 cc, although the use of the word 'actuation' *appears* to be singular. It is obvious that the intent of paragraph 4.1.3(c) is that this amount of fluid shall be delivered during the 15 second test period.#4. In paragraph 4.4.2(b) of J942 (under the durability test) the Recommended Practice requires: 'For manual systems a single actuation shall consist of actuation of the control for a period not to exceed 3 seconds.' It is important to note that this specifies the time required for the driver to operate the control--not the total time for the washer system to actuate. It appears this definition refers to a *control actuation*, whereas, the definition for 'washer cycle' refers to a *system actuation*. This is borne out in paragraph 2.2 of J942 which defines 'control' as 'A means for actuating the arresting the windshield washer system. The actuation may be coordinated or semi-coordinated with components of the windshield wiper or may be fully independent.'#5. Note that the following sentence in paragraph 4.4.2(b) states: 'For automatic systems an actuation shall consist of one actuation of the control.' This seems to indicate, by inference, that more than one control actuation is acceptable for manual systems.#6. Therefore, the intent of the referenced SAE Recommended Practice by Section S4.2 of Standard No. 104 is that manual washer systems may be actuated more than once to provide the 15 cc of fluid as long as it does not require the operator more than 3 seconds to operate the control for any single system actuation--and the washer system must deliver 15 cc of fluid to clear 75% of the wiped area within 10 cycles and within 15 seconds.#7. Note that any additional system actuations needed to meet the 15 cc requirement will also require that the manufacturer increase accordingly the total number of control actuations for the durability test in Table I, 'Test Sequence' in J942.<<<#We assume that your windshield washing system meets these requirements based upon your explanation of your manual system. However, we wish to point out our concern that the existing regulations do not adequately define washer system performance requirements, since it is possible under the current regulations for the driver to be needlessly occupied with the washer controls during a period of reduced visibility. Accordingly, we expect to up-grade the washer system performance requirements as soon as practicable.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service; |
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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.