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: aiam3256OpenMr. Frank J. Douthitt, Douthitt, Mitchell & Paul, P.O. Box 549, 201 N. Bridge Street, Henrietta, TX 76365; Mr. Frank J. Douthitt Douthitt Mitchell & Paul P.O. Box 549 201 N. Bridge Street Henrietta TX 76365; Dear Mr. Douthitt: This responds to your March 19, 1980, letter asking whether it is lega for a manufacturer to build a chassis that would normally have a high gross axle weight rating (GAWR) while continuing to certify the combined axle and chassis to a lower GAWR and gross vehicle weight rating (GVWR). The answer to your question is yes.; The chassis-cab manufacturer and the final-stage manufacturer whe certifying the proper GVWR and GAWR must consider the entire vehicle and its capacity to sustain the load for which it is designed. Therefore, if a manufacturer installs a heavy axle but does not reinforce the frame to correspond with the heavier axle, it must select a GVWR that reflects the capacity of the weaker frame rather than the stronger axle. The GAWR can be any amount appropriate for a given axle without regard to the vehicle's GVWR, provided the sum total of the Gross Axle Weight Ratings (GAWR) is not less than the Gross Vehicle Weight Rating (GVWR).; Your problem arises because the contract for purchase of th chassis-cab specified only the GAWR without insisting that the GVWR be similarly increased. This is entirely a private contractual matter and no Federal regulation of which we are aware has been violated.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4593OpenThe Honorable Leon E. Panetta House of Representatives Washington, DC 20515; The Honorable Leon E. Panetta House of Representatives Washington DC 20515; "Dear Mr. Panetta: This letter responds to your inquiry on behalf o your constituent, Mr. Botelho. You asked whether Federal regulations require mirrors to be placed on the right side of vehicles and whether such mirrors must be convex in nature. Mr. Botelho expressed his objection to requiring convex mirrors, because he believes convex mirrors distort images and cause objects to appear further away than they actually are. I am pleased to have this opportunity to explain this requirement and its background for you. Standard No. 111, Rearview Mirrors (49 CFR /571.111, copy enclosed)) establishes performance and location requirements for the rearview mirrors installed in new vehicles. Specifically, a passenger car whose inside rearview mirror does not meet the field of view requirements of section S5.1.1 must have an outside mirror on the passenger side of either unit magnification or a convex mirror. In a September 2, 1982 final rule amending Standard No. 111, the National Highway Traffic Safety Administration (NHTSA) explained that convex mirrors offer safety benefits by providing an expanded field of view to the rear, thereby reducing the need for the driver to turn around to view the rear directly. On the other hand, some users of convex mirrors that were used to the images shown by conventional plane mirrors incorrectly perceived that the object shown in the convex mirror was further to the rear than it actually was. Additionally, some users of convex mirrors experienced double vision, eyestrain, and nausea. After considering these potential advantages and disadvantages, NHTSA amended Standard No. 111 so that it does not require any vehicle to be equipped with convex mirrors, but it permits the use of convex mirrors on the passenger side of cars and light trucks, provided that the convex mirror meets certain additional requirements. The additional requirements applicable to convex mirrors on the passenger side of cars and light trucks are: 1. A maximum radius of curvature for the convex mirror. This limits the range of convexities to which drivers will be exposed. It also ensures that the field of view will be noticeably greater than for a plane mirror. 2. A minimum radius of curvature for the convex mirror. This ensures that the image size in the convex mirror will be adequate and distortion will not be excessive. 3. A stringent maximum permissible variation in the radius of curvature over the surface of the convex mirror. This requirement, which is more stringent than the European requirement in this area, also ensures that convex mirrors will have low distortion. 4. A warning etched on the convex mirror that objects shown in the mirror are closer than they appear. This requirement ensures that the driver who may not be familiar with convex mirrors will not be misled by the image size of the convex mirror and the apparent distance to the object. Hence, we agree with Mr. Botelho that the areas he has identified are potential problems unique to convex mirrors. However, our standard includes special requirements for convex mirrors to minimize the potential problems identified by Mr. Botelho and other potential problems that were identified in research studies of convex mirrors. We are not aware of any data showing that convex mirrors that comply with those special requirements present any unacceptable problems for drivers. I hope this information is helpful. If you have any further questions or need any additional information on this subject, please let me know. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam4439OpenArt Look, Marketing Executive Burke Communication Industries 1165 North Clark Street Chicago, IL 60610; Art Look Marketing Executive Burke Communication Industries 1165 North Clark Street Chicago IL 60610; "Dear Mr. Look: Your letter of October 30, 1987, addressed t Administrator Diane Steed, was referred to me for reply. You are apparently seeking this Department's approval of your product which you describe as a new warning device for stopped motor vehicles. As explained below, we do not provide approvals for products. Your product is made of inflatable plastic material that you describe as 'flexible and extremely durable.' When a user inflates your device, the product takes the shape of a cone standing about 18' high. The pictures you enclose indicate that the inflatable part of the cone has three broad alternating stripes. Two of the stripes are orange, and a 6' 'reflective' white stripe is sandwiched between them. Your cone sits on a non-inflatable, spherical, black base filled with 'approximately' 3 lbs. of sand. You state that your device has many advantages over the warning device currently specified in Federal Motor Vehicle Safety Standard 125, Warning Devices. Among the advantages you list are that your device is 'more visible at night, up to 1,000 ft. away,' that it '(is) not affected by winds up to 50 MPH,' and that if struck, it 'will return to an upright position' without damaging the vehicle involved. You state your company's intention to package your device in a corrugated container with three inflatable cones to a kit, including both a 'new-type double-action hand pump' and instructions for proper use of your device. Let me begin with some general information about this agency. The National Highway Traffic Safety Administration (NHTSA) is an agency of the Department of Transportation, and has authority under the National Traffic and Motor Vehicle Safety Act (the Safety Act) to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. However, NHTSA does not approve nor certify motor vehicles or motor vehicle equipment, or endorse any commercial product. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is required to certify that its products meet all applicable safety standards issued by this agency. Periodically, NHTSA conducts tests to determine whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects. One of the safety standards issued by this agency is Standard 125, Warning Devices, which sets uniform performance requirements for certain devices that are designed to be carried in a motor vehicle and used when needed to warn approaching traffic when the vehicle is disabled and stopped in or by the side of the road. The Standard applies to any such device that does not have a self-contained energy source (such as a battery). Your product falls under this Standard. Thus, it must meet the requirements of Standard 125, such as those on configuration, color, and reflectivity. Failure to comply with a standard renders the manufacturer subject to a civil penalty of $1,000 for each violation and a maximum penalty of $800,000 for a series of violations. In addition, the Safety Act requires a manufacturer to recall and remedy or replace a noncomplying item of motor vehicle equipment. As the above discussion suggests, you do not need approval from NHTSA or any other agency in the Department of Transportation to market your product. However, you do need both to ensure that your product meets Standard 125's requirements and to certify compliance. Our preliminary review of your product indicates that you may not be able to make that certification. For example, it appears that your product may not comply with the color, reflectivity, configuration, and stability requirements of Standard 125. If your product fails to meet these or other Standard 125 requirements, you cannot legally market it as a warning device. I hope you find this response helpful. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam0929OpenMrs. Katherine C. Little, Edgewood Motorcycle Shop, 1711 Pulaski Highway, Edgewood, MD 21040; Mrs. Katherine C. Little Edgewood Motorcycle Shop 1711 Pulaski Highway Edgewood MD 21040; Dear Mrs. Little: This is in reply to your letter of November 30, 1972, asking if yo have to maintain a record of the tires you sell and register or is it sufficient to mail the requested information to the tire manufacturer or the tire manufacturer's designee.; Under Part 574.8 of the Tire Identification and Record Keepin regulation (49 CFR Part 574) a tire dealer is recorded to submit the required information to the tire manufacturer or his designee but is not required to keep a separate record of the tires sold.; Sincerely, David Schmeltzer, Assistant Chief Counsel |
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ID: aiam2914OpenJames P. Bally, Esq., Messrs. Brownfield, Kosydar, Bowen, Bally & Sturtz, 140 East Town Street, Columbus, OH 43215; James P. Bally Esq. Messrs. Brownfield Kosydar Bowen Bally & Sturtz 140 East Town Street Columbus OH 43215; Dear Mr. Bally: We understand that you are interested in an interpretation of th relationsip (sic) of a rear lighting system, developed by your client Mr. Leno Bevilacqua, to Federal motor vehicle lighting requirements. As you described this device in your letter of September 29, 1978, to the Nevada Department of Highways:; >>>'The device will project a green light for the vehicle which woul be in a constant or accelerated speed, a yellow light for the vehicle in a decelerated moving state and a red light for the vehicle which would be stopping.'<<<; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices, and Associated Equipment*, (49 CFR 571.108) neither requires nor expressly prohibits a lighting device of this nature as original equipment on motor vehicles. One section of the standard, however, S4.1.3, prohibits the installation of all original lighting equipment not mandated by the standard 'that impairs the effectiveness of lighting equipment required by this standard.' While we make no judgment with respect to Mr. Bevilacqua's 18-inch long 1 1/2 inch high rectangular device, I think it important to note that the agency's research into rear green signal lights indicate that there may be disadvantages rather than advantages to such a lighting system. One major disadvantage is the problem of confusing the unfamiliar colored rear lamps in urban environments having multicolored lights.; Standard No. 108 does not cover this device as an aftermarket item, an it would therefore be subject to regulation by the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3606OpenMr. Shizuo Suzuki, Nissan Motor Co., Ltd., Suite 707, 1919 Pennsylvania Avenue, N.W., P.O. Box 57105, Washington, DC 20037; Mr. Shizuo Suzuki Nissan Motor Co. Ltd. Suite 707 1919 Pennsylvania Avenue N.W. P.O. Box 57105 Washington DC 20037; Dear Mr. Suzuki: This responds to your request for an interpretation concerning Standar No. 101, *Controls and Displays*. You asked several questions concerning informational readout displays. The answers to your questions are as follows.; >>>1. If one type of information is displayed by an electr illuminating device such as a light-emitting diode, can I define this as an IRD?<<<; The answer to this question is yes. Section S4 of Standard No. 10 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.' [Emphasis added.] Thus, the type of system you describe comes within Standard No. 101's definition of informational readout display. In reference to the specific wording of your question, I would note that it is the definition in the standard, rather than a particular characterization by the manufacturer, that is determinative as to whether a display is an informational readout display.; >>>2. Do you think that the description 'other electro illuminatin device' includes normal electric bulbs?<<<; The answer to this question is no. The requirements applicable t informational readout displays are an exception to the usual requirements for displays, which ordinarily use normal electric bulbs. The preamble to the final rule establishing the requirements of the present Standard No. 101 explained that the reason for the exception was to 'permit the continued development of informational readout displays.' 43 FR 27541, June 26, 1978. This was necessary since current technology does not enable manufacturers to produce informational readout displays which can exhibit symbols (as opposed to words) or certain colors. Thus, while section S5.2.3 of Standard No. 101 makes the use of certain symbols and colors mandatory for traditional displays, the use of symbols and colors is optional for informational readout displays.; If 'other electro illuminating device' was interpreted to includ normal electric bulbs, traditional displays would come within the definition of informational readout display. Such an interpretation would render meaningless Standard No. 101's requirements for the mandatory use of certain symbols and colors for displays. It is thus clear that the term 'other electro illuminating device' does not include normal electric bulbs. Rather, the term was included within the definition of informational readout display, along with light-emitting diodes and liquid crystals, to avoid preventing the use of new electronic technology other than light-emitting diodes and liquid crystals.; Your third and fourth questions both contemplate that the answer t your second question is yes, rather than no. In reference to your question as to why the agency amended Standard No. 101 to permit the use of green as an alternative to blue or blue-green for the headlamp high beam telltale, the reason is that the agency does not interpret the standard's definition of informational readout display to include a mere colored light using light-emitting diode technology. To be an informational readout display, it must include information in the form of words or symbols. Since such a colored light is not an informational readout display, it must meet the color requirements of Standard No. 101. On February 1, 1982, the agency published a notice in the *Federal Register* (47 FR 4541) which proposed, among other things, an interpretive amendment to the definition of informational readout display to make that point clear. We have enclosed a copy of that notice for your convenience.; Your fourth question suggests that the definition of informationa readout display should be interpreted to include only displays providing more than one type of information. As explained in the answer to your first question, such an interpretation would be inconsistent with the wording of the standard's definition of informational readout display. The agency recognizes, however, that it is likely that most if not all informational readout displays will include more than one type of information, though it is possible that some manufacturers might use LED or similar technology for displays providing only one type. In any event, the agency is not aware of a need to revise the standard's requirements to exclude displays presenting only one type of information from the definition of informational readout display.; >>>5. According to the current regulation, is it possible to integrat telltales with other instrument displays in an informational readout display?<<<; The light intensity requirements of Standard No. 101 currently preven informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section specifies that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; We would note, however, that the notice of proposed rulemaking referre to above proposes an amendment to Standard No. 101 that would permit informational readout displays to be used as telltales. The agency is in the process of analyzing the comments received in response to that notice.; Our answer to your fifth question also covers your sixth question. hope this fully responds to your inquiry.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1115OpenMr. Mel Turner, Manager, Heavy Duty Division, Automotive Service Industry Association, 230 North Michigan Avenue, Chicago, IL 60601; Mr. Mel Turner Manager Heavy Duty Division Automotive Service Industry Association 230 North Michigan Avenue Chicago IL 60601; Dear Mr. Turner: This is in reply to your letter of March 26, 1973, to Mr. Georg Shifflett of my staff, enclosing a letter from Mr. I. Warren Simpson of Standard Parts Corporation. Mr. Simpson's questions, as amplified in a phone conversation we had with him following your suggestion, are restated below, and followed by our responses.; 1. When 'glyder kits' are installed, is the installer considered to b a manufacturer and therefore responsible for certification? (We understand 'glyder kits' to mean a cab with chassis, less power train and rear axle.); Whether a vehicle must be certified depends upon whether it is 'completed vehicle', as that term is defined in 49 CFR S 568.3 (Vehicles Manufactured in Two or More Stages), copy enclosed. If the installation of a glyder kit produces a 'completed vehicle', the installer must certify the vehicle, as specified in 49 CFR Parts 567, 568, as conforming to all applicable Federal Motor Vehicle Safety Standards.; In cases involving the refurbishing of a used chassis, the NHTS considers the refurbished vehicle to be a used vehicle, for which no certification is necessary. However, the implication from your letter is that a glyder kit installation involves a new chassis (only the rear axle and power train are used) and consequently the completed vehicle will be a new vehicle which must be certified.; There is also the possibility that a glyder kit, when installed, wil be an 'incomplete vehicle' (also defined in 49 CFR 568.3). An incomplete vehicle is not certified. Rather, its manufacturer prepares, and ships with it pursuant to Part 568, a document containing information on steps that the final-stage manufacturer must take in order to bring the vehicle, as completed, into conformity with applicable Federal standards.; 2. Are we required to know the first purchaser for purposes other tha resale (users) of the vehicle when we complete the vehicle for a dealer?; Section 113(f) of the National Traffic and Motor Vehicle Safety Act (1 USC 1402(f)) requires each manufacturer of motor vehicles to maintain records of the names and addresses of the first purchaser (other than a dealer and distributor) of motor vehicles produced by that manufacturer. In completing a vehicle for a dealer, you are the final-stage manufacturer of the vehicle, and are responsible for maintaining the names and addresses of first purchasers. The information can be obtained from the dealers for whom you complete vehicles.; 3. If the vehicles are involved in a 'defect notification' campaign ar we, as final-stage manufacturer (we install fifth wheels), required to participate?; Under the National Traffic and Motor Vehicle Safety Act, a manufacture of motor vehicles is responsible for notifying owners of vehicles that he manufacturers (sic). Usually, for multi-stage vehicles, the incomplete vehicle manufacturer will issue notification for defects covering those vehicle parts or components which he assembled or manufactured. Final stage manufacturers, like yourself, would do likewise. Under the Defect Notification regulations (49 CFR Part 577), if any one manufacturer who participates in the manufacture of a multi-stage vehicle conducts a notification campaign, the other manufacturers will not be required to do so. You may, however, be called upon to furnish to the manufacturer conducting the campaign the names and addresses of purchasers for vehicles you have completed.; 4. 'How can a distributor safely attach a fifth wheel? (Any fram failure is our liability since the OEM is very specific about neither, welding, drilling, or cutting the frame.)'; This agency is not in a position to give advice in this regard. Th problem should be worked out between the incomplete and final-stage manufacturer.; We are enclosing the following pertinent publications: >>>1. The National Traffic and Motor Vehicle Safety Act 2. Part 567, 'Certification', and Part 568, 'Vehicles Manufactured i Two or More Stages.'; 3. Part 573, 'Defect Reports.' 4. Part 577, 'Defect Notification.'<<< If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam3128OpenMr. Kei Matsui, Toyo Kogyo Co. Ltd., P.O. Box 18, Hiroshima, 730-91 Japan; Mr. Kei Matsui Toyo Kogyo Co. Ltd. P.O. Box 18 Hiroshima 730-91 Japan; Mr. Matsui: This is in response to your letter of May 11, 1979, requesting th National Highway Traffic Safety Administration's (NHTSA) views on whether the inclusion of optional equipment on certain Mazda models would be sufficient to create a number of different series within that model.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree on commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line', denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; Based in the facts presented, it is apparent that models equipped wit different optional equipment could each be designed a 'series' if Mazda desired. Nonetheless, the definition of a 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If the difference between the potential series are superficial and a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4317OpenMs. Robin Bender Stevens, Health Policy and Planning Consultant, ECRI, 5200 Butler Pike, Plymouth Meeting, PA 19462; Ms. Robin Bender Stevens Health Policy and Planning Consultant ECRI 5200 Butler Pike Plymouth Meeting PA 19462; Dear Ms. Stevens: Thank you for your letter of March 26, 1987, asking several question about how our regulations on safety belts would apply to side and rear-facing seats in emergency medical vehicles. I hope the following discussion answers your questions.; You explained in your letter that most emergency medical vehicles hav a rear-facing seat that is typically located behind the driver's seat. The photographs you sent with your letter show that in one of the two vehicle designs you photographed, the rear-facing seat appears to be a typical vehicle seat, referred to as a 'captain's chair,' often used in a van-type vehicle. In the other emergency vehicle design show in your photographs, there is a rearward-facing, bench-type seat with a padded seat pan and back installed directly behind the driver.; You further explained that, depending on the number of stretchers th vehicle is designed to carry, there may be another seating area in the vehicle. In single-stretcher vehicles, there is a squad bench, which your photographs show is a set of storage compartments with a padded top, located next to the stretcher. You explained that emergency personnel may sit on the squad bench to attend the the(sic) patient while the vehicle is in motion. You further explained that personnel in dual-stretcher vehicles sit on the empty stretcher to attend to the patient. You said that use of a safety belt in those positions is too restrictive to allow emergency personnel to provide acute care to patients during transports.; Standard No. 208, *Occupant Crash Protection*, sets requirements fo the installation of occupant restraints in motor vehicles. The emergency medical vehicles shown in your photographs would be classified as multipurpose passenger vehicles under our regulations since they are designed to carry 10 or fewer persons and are built on a truck chassis. Standard No. 208 requires manufacturer of new multipurpose passenger vehicles to install a safety belt for each designated seating position. Part 571.3 of our regulations defines, impart, a designated seating position as:; >>>any plan view location capable of accommodating a person at least a large as 5th percentile female, if the overall seat configuration and design and vehicle design 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.<<<; The agency considers the two types of rearward-facing seats in th emergency medical vehicles you photographed to be designated seating positions. Those seats are designed and built in the same manner as conventional vehicle seats in that they have a padded seat pan and a high padded seat back. In fact, the one seat appears to be a conventional 'captain's chair' which has been mounted in a rearward-facing position. The two rearward-facing seats are also designed to be used on a routine basis by an emergency medical personnel as the vehicle travels to its destination.; In contrast, the agency does not consider as squad bench or a stretche to be a designed or built in the same manner as a conventional vehicle seat. Although they have the equivalent of a seat pan, they do not have a seat back. Most importantly, both the squad bench and stretcher are meant to be used on a temporary basis as auxiliary seating position by emergency medical personnel as they provide treatment to a patient. Thus, as an auxiliary seating area, they would not be considered a designated seating position and therefore not subject to the safety belt installation requirement of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1545OpenMr. R. W. Hilderbrandt, Heavy Vehicle Systems Group, Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hilderbrandt Heavy Vehicle Systems Group Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hilderbrandt: This responds to your May 10, 1974, request for interpetation (sic) o the volume requirements for service brake chambers in S5.2.1.2 and S5.1.2.1 of Standard No. 121, *Air Brake Systems:*; >>>S5.1.2.1 The combined volume of all service reservoirs and suppl reservoirs shall be at least twelve times the combined volume of all service brake chambers at maximum travel of the pistons or diaphragms.<<<; You also requested that reservoir volume be based on manufacture 'rated volume' based on the designed volume of the reservoir.; In testing for compliance with S5.1.2.1 and S5.2.1.2, the NHTSA wil accept a manufacturer's published 'rated volume' of the brake chamber with the piston or diaphragm at maximum travel. This means that the manufacturer may specify the full stroke of the piston or diaphragm and compute the 'rated volume' based on the designed volume of the chamber and the full stroke he has established. This volume may be somewhat larger than 'nominal brake chamber displacement' which does not necessarily account for the void ahead of the relaxed diaphragm or piston, the so-called 'pre-fill volume.' This volume must be included because it must be pressurized along with the displaced volume.; In the absence of manufacturer's published ratings, the NHTSA wil measure the brake chamber volume with the push rod at maximum stroke.; With regard to air reservoir volumes, the NHTSA will determine th volume of reservoirs by actual measurement. As a practical matter, air reservoirs are simple structures whose volumes are relatively easy to measure.; Sincerely yours, Robert L. Carter, Associate Administrator, Moto Vehicle Programs; |
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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.