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
| Interpretations | Date |
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ID: 03076Dashney_type1_positioningbeltOpenMr. Howard Dashney Dear Mr. Dashney: This responds to your December 19, 2002, letter to the National Highway Traffic Safety Administration (NHTSA) and subsequent phone conversation with Deirdre Fujita of my staff, concerning the application of Federal motor vehicle safety standards to the installation of "positioning belts" on large (over 10,000 pounds gross vehicle weight rating) school buses. You inquire on behalf of the Michigan Association for Pupil Transportation (MAPT), which represents various school bus fleet administrators, including public and private school bus fleets, private contractors, and Head Start fleet operators. You explained that MAPT members have been informed by the Michigan Department of State Police, Motor Carrier Division (MCD), that they will no longer be able to use positioning belts in their school buses. You explain that positioning belts are used to hold special-needs students upright in their seats when they cannot remain upright on their own, and/or to control the movement of students with behavioral problems. You state that the belts are attached to the seat frames or seat backs of the school bus seats and "are not meant for or used as protection in a crash." You further explain that MCD inspectors have prohibited the use of the belts because they believe that the belts do not comply with Federal standards. You ask two questions regarding this situation. I note that we have also received a related inquiry from Sgt. Sharron Vancampen of the MCD, asking about use of the positioning devices on school buses. Because your letters ask about the same situation, we will respond to you both simultaneously and will copy you both on our responses. First, you ask whether large school buses must meet the Federal motor vehicle safety standards (FMVSSs) that apply to buses. The answer is yes. Under our definitions of motor vehicles (49 CFR 571.3) a "school bus" is a type of "bus." Thus, a school bus must meet all FMVSSs applying to "school buses" and those applying to "buses." Second, you ask if the MCD is correct in its interpretation of our standards.[1] Based on the information you provided in your letter and on the phone, generally speaking, few NHTSA requirements apply to the situation presented. We assume that the positioning belts are being installed on used (not new) buses by MAPT members. The installation of the belts is not in itself a violation of NHTSA requirements. According to the information you provided, the belts presumably meet all applicable requirements of the Federal motor vehicle safety standard for seat belt assemblies, FMVSS No. 209. Thus, the sale of these belts to your members did not violate Federal requirements. The belts are being used to restrain and/or position children, some of whom weigh 50 pounds or less. As such, there is an issue as to whether the belts are "child restraint systems" subject to FMVSS No. 213. We believe the answer is no, because the belts are Type 1 seat belt assemblies (i.e., lap belts), and Type 1 seat belts are excluded from the definition of "child restraint system" in S4 of FMVSS No. 213, Child Restraint Systems. Your members installation of the positioning belts is not directly regulated by an FMVSS. Safety standards that apply to installation of seat belts, FMVSS No. 208, Occupant Crash Protection, and FMVSS No. 210, Seat Belt Assembly Anchorages, are "vehicle standards" applying only to new vehicles. The general rule is that installation of aftermarket equipment is not subject to the requirements set forth in vehicle standards. However, there is another statutory provision that might affect MAPT members installation of the belts. If a vehicle is modified after its first sale, 49 U.S.C. 30122 provides, in pertinent part: A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard. School buses are certified as meeting Federal school bus safety standards. Seats on a large school bus are certified to the "compartmentalization" requirements of FMVSS No. 222, School Bus Passenger Seating and Crash Protection. The compartmentalization concept calls for sturdy yet yielding well-padded high-backed seats to protect passengers. With respect to Standard No. 222, the compartmentalized school bus seats are elements of design installed in compliance with this safety standard. The "make inoperative" prohibition requires any entity listed in 30122 to ensure that the school buses will continue to afford the occupant protection required by Standard No. 222, even with the positioning belts attached to them. Note, however, that the make inoperative prohibition does not apply to modifications vehicle owners make to their own vehicles. Thus, Federal law would not apply to a situation where MAPT members installed the belts in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. Nonetheless, NHTSA urges owners to exercise care in modifying their vehicles so as not to degrade the safety provided by the original systems. Further, States have the authority to regulate the use of motor vehicles, including the manner in which school buses are modified and operated. Note also that, notwithstanding your intent in using the belts only as "positioning belts," as a practical matter the belts could act similarly to "lap belts" in a crash. NHTSA recommends that lap belts be installed only on "seat belt ready" school bus seats (seats that are able to withstand the forces generated in a crash), and also in a manner that meets FMVSS No. 210. To summarize, the sale of the seat belts to MAPT members did not violate the FMVSSs. The installation of the belts on the school bus seats by the MAPT members was not subject to an FMVSS, if the members modified their own vehicles. If a manufacturer, distributor, dealer, or motor vehicle repair business modified the vehicle, the modifier must be sure not to make inoperative any part of the school bus seat installed in compliance with FMVSS No. 222 or any other Federal safety standard. We recommend that lap belts be properly installed on "seat belt ready" seats on school buses. Please contact Deirdre Fujita at (202) 366-2992 if you have further questions. Sincerely, Jacqueline Glassman ref:VSA#209#213 [1] We lack the resources to make a detailed analysis of the memorandum you enclosed from your counsel arguing against the validity of the MCDs conclusions, except to note, as discussed earlier in this paragraph, that the memorandum is incorrect in concluding that school buses need not meet the FMVSSs that apply to buses. We may not necessarily agree with the memorandums other interpretations of the FMVSSs. Further, keep in mind that we cannot interpret the requirements of other Federal agencies. As to compliance with Head Start or other Federal regulations, you should direct your question to the agency involved.
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2003 |
ID: 0322Open Mr. Tom Determan Dear Mr. Determan: This is in reply to your letter of September 2, 1994, to Taylor Vinson of this Office. You have inquired about the mounting height requirements specified in Motor Vehicle Safety Standard No. 108 for side marker lamps and reflex reflectors installed on tank trucks. You understand that "side marker lamps must be mounted at any height above 15" from ground level, and reflex reflectors must be mounted between 15" and 60" from ground level." You are correct. Standard No. 108 (Tables II and IV) specifies that side reflex reflectors on trucks shall be mounted not less than 15 inches nor more than 60 inches above the road surface, and that side marker lamps must be mounted not less than 15 inches above the road surface. This means that side marker lamps may be placed at heights greater than 60 inches. Noting your thought that enforcement personnel are mistakenly applying requirements for trailers to tank trucks of your customers, I would like to say that the requirements are the same for trailers, except that, under Table II which applies to trailers whose overall width is 80 inches or more, the rear side marker lamps are subject to the same 60-inch height limitation as the side reflex reflectors. I hope that this is helpful in resolving your problem. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:12/7/94
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1994 |
ID: 0324Open Mr. Rishi Gupta Dear Mr. Gupta: This is in reply to your FAX of August 29, 1994, to Richard Van Iderstine of this agency. For future reference, requests for interpretations of U.S. Federal motor vehicle safety regulations should be addressed to the Office of Chief Counsel. You have asked whether the size and types of aiming pads you propose to place on headlamps manufactured by Autolite conform to DOT specifications. You describe these headlamps as "a 7" round and a 200 x 142 mm rectangular replaceable halogen sealed beams [which] use a replaceable halogen bulb (HB2)." You enclosed diagrams showing "aiming pad's position as per SAE J1383 - 1992" (Figures 1 and 3), and in the manner you wish to place them on the Autolite lamps (Figures 2 and 4). We understand that these replaceable bulb headlamps are intended to be sold as replacements for sealed beam headlamps of the same dimensions. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, is the DOT specification that applies to Autolite's headlamps. The aimability performance requirements for non-sealed beam headlamps are found in S7.8. of Standard No. 108. S7.8 allows any aiming pad pattern that will fit on the headlamp and that will allow any one of the available aiming adapters described in SAE J602 to be used on the headlamp. Specifically, S7.8.1 in pertinent part allows non- sealed beam headlamps to be equipped with aiming pads to be used with the photometric procedures of SAE J1383 APR85 (not "1992" as you wrote) when being tested for photometric compliance, and to serve for the aiming reference when the lamp is installed on a motor vehicle. S7.8.5 allows an installed headlamp system to be aimable with an externally applied aiming device. Under S7.8.5.1, this aiming device shall be the equipment specified in SAE Standard J602 OCT80 Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Units. You write that the aiming pad sizes and types you wish to use are identical to those on headlamps sold by Hella, and that ETL Testing Laboratories has told you that the aiming pad positions and types meet DOT specifications. This indicates that Autolite's headlamps would be mechanically aimable with SAE J602 equipment, and therefore permissible as meeting Standard No. 108. We recommend that Autolite verify mechanical aimability with SAE J602 equipment before certifying compliance with Standard No. 108. Our engineering staff has reviewed your letter and asks that we point out the following errors in Autolite's Figures Nos. 2 and 4. Under both Figures, there is a reference to "HB-2 (H4 P43t)." The HB2 light source is not the same as the H4 P43t light source. The HB2 is a light source permitted by Standard No. 108 while the H4 P43t is not permitted by the Standard for motor vehicles. Under the drawing, the dimension "68.5" should be "68.58 +/- 0.51" (see Figure 4-4 of Standard No. 108). The dimensions of "32" and "52.0" must be the sum of two dimension "A"s from Figure 4-4, thus the sum is 42.16 +/- 0.25 + 42.16 +/- 0.25 = 84.32 +/- 0.50, not 84 as nominally calculated. Finally, with respect to Figure 4 only, because this lamp is intended to replace a 200 x 142 mm sealed beam lamp, the position of the aiming pads are not, but should be identical to the 200 x 142 mm sealed beam to facilitate mechanical aim when only one headlamp is replaced. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:10/26/94
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1994 |
ID: 0391Open Mr. Harry L. Williams, Jr. Dear Mr. Williams: We have received your letter mailed on September 27, 1994, with respect to the permissibility under Federal law of your invention, Willy Lights. This product appears to consist of lights installed on wheel rims. You enclosed a copy of a memorandum to you on this subject dated October 24, 1988, from Greg Novak, an engineer with the Nevada Division of the Federal Highway Administration. After consulting with members of this agency, Mr. Novak wrote you that there were no regulations that prohibited the use of lighted wheel rims but that they could not "interfere with any standard safety equipment on a vehicle." You have asked whether this interpretation remains valid, and, if the lamps are not prohibited, the color permissible for the lamps. You have not provided a detailed description of your device, such as the amount of illumination provided by the lights. Mr. Novak's advice that there are "no regulations prohibiting the use of lighted wheel rims" must be qualified. There are no Federal regulations that specifically prohibit the sale and installation of lighted wheel rims, but there may be regulations governing the use of lighted wheel rims issued by the individual States. We have no knowledge of State laws on this matter and suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment establishes the requirements for original lighting equipment for motor vehicles. Standard No. 108, in effect, prohibits the installation of supplementary lighting equipment such as Willy Lights before the initial sale of a vehicle if it impairs the effectiveness of the equipment required by Standard No. 108. Thus, if Willy Lights were sufficiently bright to mask in whole or in part the side marker lamps and reflectors and any lamps mounted on the front and rear that wrap around the sides, Standard No. 108 would prohibit their installation. The seller (dealer) of the new vehicle has the responsibility of ensuring that the vehicle remains in compliance with Standard No. 108 when it installs supplementary lighting equipment, that is to say, the responsibility of determining whether or not impairment exists. This agency does not question such determinations unless they appear clearly wrong. There is a similar prohibition for supplementary lighting equipment installed after the initial sale of a vehicle. When Willy Lights are installed by a manufacturer, dealer, distributor, or motor vehicle repair business, they must not make inoperative any of Standard No. 108's required equipment. With respect to Willy Lights, we would regard the question of making inoperative as equivalent to the question of impairing effectiveness. If it is concluded that Willy Lights do not impair new vehicle equipment, then one can conclude that its installation on a used vehicle will not have an operative effect on 108's equipment. However, the States retain the right to say whether or not Willy Lights may be used within their borders. The color of the lamps may also be important in any determination of impairment or inoperability. Under Standard No. 108, required side marking equipment at or near the front of a vehicle must be amber in color, and red at or near the rear. To lessen the chance of confusion in a driver approaching from the side who may never have seen lighted wheel rims, we believe that it would be preferable to follow Standard No. 108's color code. Use of different colors, such as white or green, could cause momentary confusion in the eyes of an approaching driver, leading to the conclusion that the required side lighting equipment has been impaired or made partially inoperative by Willy Lights. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:10/21/94
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1994 |
ID: 0394Open Samson Helfgott, Esq. Re: Your Ref. No.: 12.065 Dear Mr. Helfgott: We have received your letter to John Womack, the former Acting Chief Counsel of this agency, responding to his letter to you of July 20, 1994. Thank you for enclosing a copy of his letter for ready reference. Our previous letter to you was without the benefit of the diagram of the Caine system which you have now enclosed. The system is intended to be placed "along the side of trucks and other vehicles." It consists of three red lamps mounted over three amber (yellow) ones, the array installed between the amber front side marker lamp and the red rear side marker lamp. In normal operation the amber lamps are used as "running lights" but will be turned off when the red lamps are illuminated in a steady burning state upon application of the brake pedal. The three amber lamps will flash to indicate that the vehicle is turning. All six lamps will flash when the hazard indicator switch is on. If the turn signal is on and the driver's foot is on the brake pedal, the amber lamps will flash while the red ones illuminate in a steady burning state. At 32 candela, the turn signal lamps will be at a higher intensity than the running lamps which operate at 3 to 5 candela. These are within NHTSA specifications. You ask whether this system will be in violation of Standard No. 108. This office has corresponded with you on lighting matters on a number of occasions and you are well aware that supplementary lighting equipment is prohibited as original equipment only if it impairs the effectiveness of lighting equipment that is required by Standard No. 108. This determination is to be made by the manufacturer or dealer who installs the equipment and NHTSA will not question it unless it is clearly erroneous. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:12/8/94
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1994 |
ID: 04-002102drnOpenMr. A. Bret Miller Dear Mr. Miller: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 122, Motorcycle Brake Systems. You wish to know whether a prototype design of a three-wheeled motorcycle would meet FMVSS No. 122s requirement for "a parking brake of a friction type with a solely mechanical means to retain engagement." As explained below, the answer is no. The National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs for new motor vehicles and new items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards. In your letter you describe your product, the "Sport Trike," as using "automotive (General Motors) disc brakes on all three wheels with a conventional hydraulic split service (master cylinder) brake system." You described the parking brake as follows:
Section S5.1.4, Parking brake, of FMVSS No. 122 states: "Each three-wheeled motorcycle shall be equipped with a parking brake of a friction type with a solely mechanical means to retain engagement." We have reviewed the written description of your parking brake design, which describes the service brakes on each of the three wheels as "hydraulically applied." We have also reviewed the drawing. Based on the drawing, we note that although the parking brake is actuated by a mechanical lever, the parking brake in fact is retained by hydraulic means. S5.1.4 specifies that a three-wheeled motorcycle must have a parking brake of a friction type "with a solely mechanical means to retain engagement." (Emphasis added.) The requirement for a three-wheeled motorcycle to have a parking brake with "solely mechanical means to retain engagement" would preclude a parking brake design relying even in part on hydraulics for retention of engagement. Thus, a three-wheeled motorcycle with your proposed parking brake design would not meet FMVSS No. 122. The confidential drawing you provided has been returned under separate cover. I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman ref:122 |
2004 |
ID: 04-002108drn-3OpenMr. Tom Hoholik Dear Mr. Hoholik: This responds to your request for an interpretation concerning National Highway Traffic Safety Administration (NHTSA) requirements which your product, the "Line Guide," must meet. Your product is designed to help drivers of motor homes, fifth wheel trucks, buses, and those who tow trailers stay in their highway lanes, without "constantly checking their mirrors." Your website, www.gadgetinc.com, provides information about the Line Guide. A photograph of a Line Guide shows a horizontal black rod attached to a bar with two rubber suction cups. Three vertical prongs (which you call stems), at equal distances from each other, project from the horizontal rod. The Line Guide mounts directly on the dashboard using Velcro or windshield with suction cups, with power supplied through the vehicles cigarette lighter. Your website states:
The Line Guide is sold both with and without light emitting diodes (LEDs). If the unit is mounted facing the road, the lights will shine on the windshield. If the unit is mounted facing the driver, the LEDs can be viewed directly. By way of background information, NHTSA is authorized to issue the Federal Motor Vehicle Safety Standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards. NHTSA has not issued any FMVSSs that are directly applicable to your product. We note that if your product was installed in a vehicle by a manufacturer or other business, they would have responsibilities relating to ensuring that the vehicle met, or continued to meet, all FMVSSs with the product installed. However, given that your product is mounted to the vehicle by Velcro or suction cups and is powered by the cigarette lighter, we assume that it would be installed by vehicle owners. In this situation, our safety standards would not affect the sale or installation of your product. Beyond compliance with relevant Federal safety standards, manufacturers of motor vehicle equipment have additional responsibilities, including a requirement to notify purchasers about safety-related defects and to provide a remedy free of charge, even if their equipment is not covered by a safety standard. 49 U.S.C. 30118-30120. In addition, you should be aware that other governmental entities may have authority over your product. For example, the Departments Federal Motor Carrier Safety Administration (FMCSA) has jurisdiction over commercial vehicles and interstate motor carriers operating in the United States. You may wish to contact FMCSA for further information about any FMCSA regulations that may apply to your system. In addition, States have the authority to regulate the use and licensing of vehicles operating within their jurisdictions. Therefore, you may wish to check with the Department of Motor Vehicles in any State in which the equipment will be sold or used regarding any such requirements. I have enclosed a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman Enclosure |
2004 |
ID: 04-003224drnOpenThomas D. Turner, Vice Chairman Dear Mr. Turner: This responds to your letter dated April 13, 2004, asking for a technical amendment to correct two errors in Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release. We concur that the errors should be corrected. You ask that the National Highway Traffic Safety Administration (NHTSA) revise the emergency exit window force application requirement at S5.3.3.2 of FMVSS No. 217, which reads in part: "In the case of windows with one release mechanism, the mechanism shall require two force applications to release the exit." You state that aJune 13, 1994, letter from former Acting Chief Counsel John Womack to the Blue Bird Body Company confirmed that the wording of S5.3.3.2 is in need of correction. You are correct that in the June 1994 letter, the agency determined that the wording is susceptible to being misread as requiring two force applications to open the single release mechanism. In that letter, the agency said that the requirement should have been worded: "In the case of windows with one release mechanism, the exit shall require two force applications to open." (Emphasis added.) In a March 20, 1996, letter to Blue Bird, the agency affirmed the interpretation of the June 13, 1994, letter. You ask that we proceed with issuing a technical amendment to correct S5.3.3.2. However, you ask that S5.3.3.2 be corrected by adding the words underlined in the following text: "In the case of windows with one release mechanism, the mechanism shall require one or two force applications to release the exit."(You also ask for an identical correction of a roof exit requirement in S5.3.3.3 that is similarly worded: "In the case of roof exits with one release mechanism, the mechanism shall require one or two force applications to release the exit.") Your suggested wording is different than the correction discussed in the previous letters. Discussion This letter affirms the position expressed in the agencys June 13, 1994, and March 20, 1996, letters that, under S5.3.3.2, in the case of windows with one release mechanism, the exit shall require two force applications to open. Similarly, under S5.3.3.3, in the case of roof exits with one release mechanism, the exit shall require two force applications to open. However, we do not agree with your suggested wording. By stating that the mechanism shall require "one or two force applications to release the exit," it permits the mechanism to release (open) the exit upon a single force application. We believe that a single force application is insufficient because, for exits with one release mechanism, there is a potential for ejections through exits if the exit could be opened with just a single force. For example, passengers could be thrown against such a release mechanism in a rollover and accidentally ejected through the opening. (A discussion of NHTSAs concern about ejection through exits with a single action release mechanism can be found in the final rule issuing S5.3.3.2 and S5.3.3.3, 57 FR 49413; November 2, 1992.) Accordingly, the agency continues to interpret S5.3.3.2 and S5.3.3.3 as specifying, for windows and roof exits with one release mechanism, that the exit shall require two force applications to open. We plan to conduct rulemaking to address this matter as resources permit. If you have any further questions at this time, please contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman ref:217 |
2004 |
ID: 04-003303Suzuki_benchseatOpenKenneth M. Bush, Regulations Manager Dear Mr. Bush: This responds to your letter asking about the procedures set forth in Federal Motor Vehicle Safety Standard(FMVSS) No. 214, "Side Impact Protection," for positioning a test dummy in the rear seat of vehicles. Different positioning procedures are specified in S7.1.3 of FMVSS No. 214 for bench seats and for bucket or contoured seats. You ask whether the National Highway Traffic Safety Administration would consider two particular vehicle rear seats as bench seats or as bucket or contoured seats. Our answer is that we would consider both as bench seats. The first rear seat you ask about is shown in photograph 1 of your letter. You describe the seat as: "a bench-type seat with split folding seatbacks, but without fore/aft seat adjustment. The seat has three seating positions with stitching and contours that outline two rear outboard passenger seating positions". The second seat, shown in photograph 2 of your letter, is "the rear seat of a sport-utility vehicle". This seat is also a bench-type seat that has three seating positions. The seat is split 60%/40%, and the two sections have independent fore/aft and seatback adjustments". FMVSS No. 214 does not define the terms "bench seats," "bucket seats" or "contoured seats". However, seats are commonly considered bench seats when their separate sections are side-by-side, as shown in your photographs, even when they are separately adjustable. While the seat in photograph 1 is slightly contoured, we do not believe that it is contoured to a degree that it should be regarded as a contoured seat. Since we regard the seat you ask about as a bench seat, the dummy positioning procedures specified in S7.1.3(a) would apply. I hope this information is helpful. If you have further questions, please contact Deirdre Fujita of my staff at (202) 366-2992. Sincerely, Jacqueline Glassman ref:214 |
2004 |
ID: 04-003879-2drnOpenRod Nash, P.E. Dear Mr. Nash: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School Bus Passenger Seating and Crash Protection.You ask how the standard applies to school bus seats that are adjoining, yet have individual sized backs for each passenger" and "unique cushions for each student."You enclosed copies of product literature from Freedman Seating Company that indicates that each seat is 17 inches wide, and that two seats together are 35 inches. You first ask about the test procedure in S5.1.3, Seat performance forward. S5.1.3 specifies that school bus passenger seats must deflect in a specified manner when force is applied through a loading bar that is centered behind the seat back. The loading bar is described in S6.5 of FMVSS No. 222. S6.5 specifies, "the length of the loading bar is 102 mm less than the width of the seat back in each test. " You ask whether the "width of the seat back" as stated in S6.5 refers to the width of one seat back or the width of both seat backs together. Our answer is that in this situation the two seats would be considered as a single "seat" for the purposes of FMVSS No. 222. Our answer is consistent with an August 16, 2004, interpretation letter to American Suzuki Motor Corporation, on FMVSS No. 214, Side Impact Protection. In the letter to Suzuki, we noted that the term "bench seats" is not defined in FMVSS No. 214 and stated:"However, seats are commonly considered bench seats when their separate sections are side-by-side, as shown in your photographs, even when they are separately adjustable. " Therefore, the width of the seat back used in the determination of the length of the loading bar would be the overall width of both seat backs together. The seat back width would be measured on a horizontal plane 406 mm above the seating reference point across both seat backs and the loading bar would be 102 mm shorter than this measurement. Your second question asks about the correct method of determining the necessary projected surface area of the seat back under S5.1.2 of FMVSS No. 222. S5.1.2 states:
Although your letter asks about "the correct place to determine seat back width," in fact the requirement for projected surface area is based on seat bench width. Thus, the required projected surface area is calculated by multiplying 508 times the seat bench width, which in this case encompasses both adjoining seats, and then multiplying by 0.9. In your example, the seat bench width is 889 mm (35 inches). The projected area is calculated excluding the V-shaped notch area in the back seat in the same manner that the area of the radius of the corners of conventional seat backs is removed (reference TP-222-03). I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman ref:222 |
1990 |
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.