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: aiam4098OpenDawn B. Brown, Esq., Currier, Zall & Shepard, 207 Main Street, P. O. Box L, Nashua, New Hampshire 03061-2938; Dawn B. Brown Esq. Currier Zall & Shepard 207 Main Street P. O. Box L Nashua New Hampshire 03061-2938; Dear Ms. Brown: This responds to your January 2, 1987 letter asking a number o questions concerning certain aspects of automatic transmissions. You ask first if there is a Federal motor vehicle safety standard (FMVSS) relating to the permissibility of a transmissions design which allows a driver to remove the key from the ignition while the transmission is in drive. You state your belief that 'Standard 114, 49 CFR 571.113 is relevant,' and ask whether that standard ever has been interpreted for a purpose other than to prevent unauthorized use of a motor vehicle. (We assume that the citation of 571.113 instead of 571.114 was a typographical error.) You ask further if there are any Federal safety standards that address whether a vehicle should 'jump from park to drive when left in park.' Finally, you ask whether there are standards other than 114 'that govern these problems.'; As it currently is written, Standard 114 requires a manufacturer t install a key-locking system that prevents starting a vehicle engine and also prevents either, steering a vehicle or moving a vehicle forward under its own power whenever the key is removed. Thus, the standard does not directly require that the vehicle be in park before a driver can remove the ignition key.; In 1968, when Standard 114 was adopted, the stated purpose was t 'reduce the incidence of accidents resulting form unauthorized (motor vehicle) use.' 33 *Federal Register* 6471, April 27, 1968. The agency based this goal on evidence showing that: 'Cars operated by unauthorized persons are far more likely to cause unreasonable risk of accident, personal injury and death than those which are driven by authorized individuals.' (See the preceding citation.) Neither the Standard nor the language in the preamble to it states any other goal.; In 1980, this agency amended Standard 114 to prevent a driver fro inadvertently locking the steering wheel of a moving vehicle by removing the ignition key or shutting off the engine (45 Federal Register 85450, December 29, 1980). However, after receiving petitions for reconsideration and studying the question further, NHTSA decided that while this kind of inadvertent activation might be a safety problem in certain vehicles, the problem did not then warrant requiring additional steps to protect against inadvertent lock-up. Therefore, the agency rescinded the 1980 amendment. The agency stated that it would continue to monitor complaints on the subject, and initiate rulemaking should new data warrant it (46 Federal Register 32251, 32253, June 22, 1981).; Currently, the agency is re-evaluating whether data warrants amendin Standard 114 to improve key-locking systems by reducing the prospect of a driver s inadvertently locking the steering column while a motor vehicle is moving.; As to your question about the existence of a FMVSS which directl addresses the permissibility of a design which allows a car to jump from 'park' to 'drive' when a driver leaves the car in 'park,' the answer is there is no such standard. However, NHTSA has received a number of letters complaining of this phenomenon and, using its authority not only to issue FMVSS but also require the recall and remedy of vehicles and equipment with safety-related defects, has conducted investigations based on these complaints. A listing of the defects investigations can be obtained from: Technical Reference Division, NHTSA, Room 5108, 400 7th St., S.W., Washington, D.C. 20590.; I hope you find this information helpful. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4831OpenMr. J. C. Brown President MidAmerica Design Service 10206 Lima Road Ft. Wayne, IN 46618; Mr. J. C. Brown President MidAmerica Design Service 10206 Lima Road Ft. Wayne IN 46618; Dear Mr. Brown: This is in reply to your letter of February 8, l99l, t the attention of Taylor Vinson of this Office. Your company has been asked to 'develop a high mounted stop light and turn signal to be installed into the door of over the road trailers.' You have not found a reference in Standard No. 108 to such a lamp, and you have concluded that, as long as you add to the trailer's existing lamps without eliminating any of its lighting devices that are standard equipment, you will be in compliance. You have asked us for our opinion on this matter. You are correct that the requirement for a center high mounted stop lamp does not extend to trailers. Moreover, trailers are not included in the agency's pending rulemaking to extend the requirements to vehicles other than passenger cars. Although your design appears to combine the stop lamp and turn signal, a combination prohibited for passenger cars, you are under no Federal legal obligation to design a center high mounted stop lamp for trailers that complies with Standard No. 108. As the lamp is not intended to replace original equipment required by Standard No. 108, it is permissible under section S5.1.3 of the standard as long as it does not impair the effectiveness of the lighting equipment that the standard requires. The judgment of whether impairment exists is initially that of the trailer manufacturer, who certifies compliance with all applicable Federal motor vehicle safety standards. If that decision appears clearly erroneous, NHTSA will review it and inform the manufacturer accordingly. Assuming that the trailers for which the lamp is intended have an overall width of 80 inches or more, your lamp would be mounted in closest proximity to the three-unit identification lamp cluster, which Table II of Standard No. 108 requires to be located 'as close as practicable to the top of the vehicle.' Identification lamps indicate to following drivers the presence of a large vehicle in the roadway ahead. It is possible that an activated center stop lamp or adjacent turn signal could mask the light from these lamps. However, these trailers are also equipped with clearance lamps, which serve the same purpose of identifying a large vehicle. Thus, it would appear that your device would not impair the effectiveness of the identification lamps within the prohibition of section S5.1.3. We assume that the turn signal portion of the lamp is a supplement to others on the trailer that are located to comply with the 83-inch maximum mounting height imposed by Table II. I hope that this is responsive to your concern. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0521OpenMr. Earl S. Everhart, Jr., Vice President - Engineering, Maxim Motor Division, Middleboro, MA 02346; Mr. Earl S. Everhart Jr. Vice President - Engineering Maxim Motor Division Middleboro MA 02346; Dear Mr. Everhart: This is in response to your letter concerning the requirements o Federal Motor Vehicle Safety Standard No. 206. Your letter was forwarded to us November 10, 1971, by Mr. Stan Haransky, Associate Director of the Truck Body and Equipment Association, Inc.; You ask whether the standard would prohibit the manufacture of fir trucks without side doors on the cabs. According to your letter, the trucks are built without side doors in order to allow firemen to enter and exit the cabs quickly during emergencies.; Standard 206 does not require that any type of motor vehicle b equipped with side doors. The standard requires only that if a vehicle subject to it has hinged or sliding side doors, they must conform with the standard's performance requirements for hinges, locks and latches.; Please write if I can be of any further assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5373OpenPaul L. Anderson, President Van-Con, Inc. P.O. Box 237 123 William Street Middlesex, NJ 08846-0237; Paul L. Anderson President Van-Con Inc. P.O. Box 237 123 William Street Middlesex NJ 08846-0237; "Dear Mr. Anderson: This responds to your letter of May 2, 1994 requesting information on which of the recent amendments to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413, November 2, 1992, and 57 FR 57020, December 2, 1992), would apply to Type A-1 school buses. Your letter notes that Type A- 1 school buses have a capacity of 16-20 passengers and a gross vehicle weight rating (GVWR) of less than 10,000 pounds. The recent amendments to Standard No. 217 set new requirements for the provision of emergency exits based upon the seating capacity of the school bus (S5.2), set performance requirements for emergency exit window and emergency roof exit release (S5.3), revised the extension requirements for side doors and set extension requirements for emergency roof exits (S5.4), and revised the identification requirements (S5.5). The effect of each of these amendments on Type A-1 school buses is discussed separately below. Provision of Emergency Exits (S5.2) The recent amendments listed above revised S5.2.3 to specify the number and type of exits required on school buses, including Type A-1 school buses. This section states: The area in square centimeters of the unobstructed openings for emergency exit shall collectively amount to at least 432 times the number of designated seating positions in the bus. The amount of emergency exit area credited to an emergency exit is based on the daylight opening of the exit opening. The section also specifies the type of emergency exits which must be installed to meet this requirement. All school buses, including Type A-1 school buses, are required to have either a rear emergency exit door or a side emergency exit door and a rear push-out window. These are the same exits required by Standard No. 217 before the recent amendments. After deducting the daylight opening of the front service door and the required exit(s), any remaining exit area must be provided by installing additional exits in the following order: (1) a side emergency exit door, (2) a emergency roof exit, and (3) any combination of emergency exit doors, emergency roof exits, and emergency exit windows. Please note that, while these new requirements apply to all school buses, it is unlikely that a 20 passenger school bus will require additional exits. Under the new requirements, a school bus with 21 designated seating positions (20 passengers plus the driver) is required to provide 9,072 square centimeters of exit area. A school bus with a front service door and either of the mandatory options (rear emergency exit door or side emergency exit door and rear push-out window) should easily exceed this amount. To illustrate, in the past, the agency has estimated that the average front service door has a daylight opening of 12,916 square centimeters. For school buses with a GVWR of 10,000 pounds or less, a rear emergency door that is the minimum size required to meet the extension requirements has a daylight opening of 6,270 square centimeters. A side emergency door that is the minimum size required to meet the extension requirements has a daylight opening of 6,954 square centimeters. A rear push- out window that is the minimum size required has a daylight opening of 5,002 square centimeters. Emergency Exit Release (S5.3) The recent amendments added performance requirements for the release mechanisms for emergency exit windows and emergency roof exits on school buses. As explained above, the recent amendments should not require either of these types of exits to be installed on Type A-1 school buses. However, if either of these types of exits are voluntarily installed on Type A-1 school buses, the release mechanisms must comply with these requirements. In the recent amendments to Standard No. 217, some of the performance requirements, including the release requirements in S5.3, apply to 'each' emergency exit. This language extends these requirements to any emergency exit door in a school bus, including voluntarily installed ones. Other requirements apply to 'required' emergency exits. (See, for example, S5.5.3(c) discussed below.) Those requirements do not apply to voluntarily installed emergency exits. Emergency Exit Extension (S5.4) The amendments of the extension requirements also apply to Type A-1 school buses. The recent amendments revised the extension requirements for side doors on school buses with a GVWR of more than 4,536 kilograms (10,000 pounds) and set extension requirements for emergency roof exits on school buses with a GVWR of more than 4,536 kilograms (10,000 pounds). These amendments also affect school buses with a GVWR of 10,000 pounds or less, as the requirements specify that these vehicles are to comply with the same requirements as school buses with a GVWR of more than 10,000 pounds (except for the minimum size for rear emergency exit doors). If a Type A-1 school bus has a side emergency exit door, that exit is required to comply with the amended requirements concerning access to the exit. Under the new requirements, side emergency exit doors are required to provide an opening at least 114 centimeters high and 61 centimeters wide. In addition, an aisle 30 centimeters wide (referenced to the rear edge of the door) must be provided from the longitudinal centerline of the bus to the exit. A seat bottom is allowed within this aisle if it flips up when not in use such that it no longer is within the aisle. Finally, no portion of a seat or restraining barrier may block access to the latch. In addition, if an emergency roof exit is installed in a Type A-1 school bus, it is required to provide an opening at least 41 centimeters high and 41 centimeters wide under the new requirements. Finally, all emergency exit doors, including emergency exit doors on Type A-1 school buses, are required to have a 'positive door opening device' that, among other things, prevents the door from closing if it has been opened beyond a certain point (see, S5.4.2.1(a)(3)). Emergency Exit Identification (S5.5) Finally, the recent amendments revised the identification requirements (S5.5) for exits on all school buses, including Type A-1 school buses. As revised, each required emergency exit is required to be marked with the words 'Emergency Door' or 'Emergency Exit,' as appropriate. For emergency exit doors, the location of this marking was not changed by these amendments. For emergency window exits and emergency roof exits, location requirements were added. In addition, each required emergency exit must be outlined with retroreflective tape. Please note however, that the identification requirements do not apply to voluntarily installed emergency exits (i.e., exits in excess of those required by S5.2.3). You should be aware that there was a discrepancy concerning the size of the retroreflective tape caused by the metric conversion in the final rule. I have enclosed is a copy of a July 7, 1993 letter to Mr. Thomas D. Turner of the Blue Bird Body Company which discusses this issue. As explained in that letter, we plan to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. Until the correction is issued, NHTSA will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape. To summarize and answer your specific questions, Type A-1 school buses typically would not be affected by the recent amendment requiring either emergency roof exits or emergency window exits. However, required emergency exits (including a rear emergency exit door) are required to be outlined with retroreflective tape. In addition, all exits (required and voluntary) must comply with the new performance requirements for release and extension. With respect to your receipt of an oral interpretation from agency staff, I would also like to emphasize that, to the extent there are questions concerning the meaning of any NHTSA standard or regulation, the only agency interpretations which are authoritative and which therefore can be relied upon by manufacturers are those issued in writing by the Chief Counsel. We have reminded agency staff not to make formal, or informal, oral statements that might be misinterpreted by manufacturers as official agency guidance on which they may safely rely. Please note that recent delay of the effective date of the recent amendments applies only to provision of emergency exits (S5.2) (59 FR 22997, May 4, 1994). The other amendments were effective on May 2, 1994. I also note that the May 4 notice does not state 'that it only applys (sic) to School Buses with capacity of 24 to 90 passengers.' The notice does refer to tables in a previous NPRM which listed the types of exits required under the proposal for buses with a capacity in that range. I have also enclosed a copy of the recent final rules for your use. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam0171OpenMr. Henry T. Skipper, Jr., Vice-President, Sales, Great Dane trailers, Incorporated, Lathrop Avenue, P.O. Box 1159, Savannah, GA 31402; Mr. Henry T. Skipper Jr. Vice-President Sales Great Dane trailers Incorporated Lathrop Avenue P.O. Box 1159 Savannah GA 31402; Dear Mr. Skipper: This is in reply to your letter of August 4, 1969, in which you aske whether the name of your company may be placed on the certification label affixed to vehicles manufactured by another company.; The question of 'private brand' manufacturing was raised at variou stages of rulemaking in respect to the certification regulations. It was decided that the certification label on a vehicle must show the name of the actual manufacturer. This information is important in the enforcement of standards and regulations under the Act. The Vehicle Safety Act, moreover, places primary responsibility for conformity to the standards, and for certification of conformity, on the manufacturer, and the regulations are designed to implement that intent. You should note, however, that as a distributor of the vehicles in question you share the responsibility for compliance with the standards to the extent of your knowledge, and participate in the certification by passing it along to dealers or other distributors.; We are pleased to be of assistance. Sincerely, Dowell H. Anders, Acting Chief Counsel |
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ID: aiam2662OpenMr. Malcolm B. Mathieson, Engineering Manager, Thomas Built Buses, Inc. 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. Malcolm B. Mathieson Engineering Manager Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Mathieson: This responds to your August 25, 1977, letter asking several question about the applicability of Standard No. 217, *Bus Window Retention and Release*, to buses other than school buses.; You first state your conclusion that paragraph S5.2 of the standar applies only to buses other than school buses. Your interpretation of S5.2 is correct. Secondly, you state that S5.2.1 applies to all buses with GVWR's of more than 10,000 pounds. This assertion is incorrect. See S5.2.3. Paragraph S5.2.1 applies only to buses other than school buses that have GVWR's greater than 10,000 pounds.; Your final inquiry pertaining to Standard No. 217 concerns th requirement for unobstructed emergency exits in both school and non-school buses. You first correctly state that paragraphs S5.4 through S5.4.2.1 describe the required size of the unobstructed openings for school buses. You then claim that there is no equivalent description for the size of unobstructed openings required in buses other than school buses. This last statement is not entirely accurate. The amount of unobstructed emergency exit openings required for buses other than school buses is detailed in S5.2. This section establishes requirements for the total area of unobstructed emergency exit openings and for the location of those exits. This section also specifies the extent to which the area of each exit is to be counted in determining compliance with the total unobstructed opening requirement. Therefore, although the standard does not specify minimum size requirements for individual exits in buses other than school buses, the standard does contain other requirements for unobstructed openings in buses other than school buses.; You concluded in your letter that buses other than school buses are no required to use the parallelepiped device in determining whether their rear exits comply with the requirements. This conclusion is accurate. For purposes of clarity, however, you should note that Standard No. 217 does not mandate rear doors in buses other than school buses. Those buses can utilize either rear exits or roof exits. Further, regardless of the fact that you use a rear emergency door in buses other than school buses, you must insure that you also provide the other mandatory exits and the correct area of unobstructed openings as described in paragraphs S5.2 through S5.2.2.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3970OpenHouston N. Tuel, Jr., Esq., Coder & Tuel, Suite 172, 8801 Folsom Boulevard, Sacramento, CA 95826; Houston N. Tuel Jr. Esq. Coder & Tuel Suite 172 8801 Folsom Boulevard Sacramento CA 95826; Dear Mr. Tuel: This responds to your letter of February 4, 1985, inquiring about th applicability of 49 CFR Part 566, *Manufacturer Identification*, and 49 CFR Part 573, *Defect and Noncompliance Reports*, to your client, Stockton Dodge. I regret the delay in our response.; You asked whether Stockton Dodge, as a vehicle alterer, would b considered a manufacturer under the statutory definition of 'manufacturer' in the National Traffic and Motor Vehicle Safety Act as amended, 15 U.S.C. 1391, *et seq.* (the Act). Based on the information given, the answer is yes.; You state that Stockton Dodge purchases previously certified Dodge van from Chrysler Corporation and converts them into school buses which are intended to be sold directly to school districts. The modifications made by your client include adding seats, strengthening the roof structure, and adding required warning lights and emergency equipment. You state that Stockton Dodge will certify the altered vehicles according to the requirements of 49 CFR Part 567.7, as complying with all Federal motor vehicle safety standards applicable to school buses.; Stockton Dodge sent a letter to the Administrator, dated March 7, 1985 stating that, beginning February 15, 1985, its school bus division would become a final-stage manufacturer. Stockton Dodge stated that they would purchase Dodge B350 vans from Chrysler Corporation which school bus options and would add equipment to alter these vehicles to Type 2 school buses, weighing under 10,000 GVWR. Under our regulations, your client is not considered a final-stage manufacturer because the definition of final-stage manufacturer in 49 CFR Part 568 applies to a person who finishes an incomplete vehicle.; This agency considers Stockton Dodge an alterer of previously certifie motor vehicles, as indicated in your letter, who must comply with the certification requirements of 49 CFR 567.7. Your client's alterations change the vehicle type from a multipurpose van to a school bus and affect components necessary for compliance with safety standards. For these reasons, Stockton Dodge is a manufacturer within the meaning of the Act, as stated above. Stockton Dodge's letter dated March 7, 1985, contains the information required to be submitted under 49 CFR Part 566, *Manufacturer Identification*. The agency will consider this letter as the manufacturer identification for Stockton Dodge as an alterer.; This agency has also determined that an alterer is considered manufacturer for the purposes of notification and recall for defects or noncompliance under the Act and is subject to the requirements of 49 CFR Part 573, *Defect and Noncompliance Reports*.; Please note that, under paragraph S4.1 of Standard No. 115, *Vehicl Identification Number--Basic Requirements* (VIN), Stockton Dodge, as the alterer, should use the VIN assigned by Chrysler Corporation, the original manufacturer of the vehicles.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2398OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This is in response to your letter of August 24, 1976, in which you as whether emergency exits required by a State beyond those required by Standard No. 217, *Bus Window Retention and Release*, are subject to the performance requirements outlined in S4(b) of Standard No. 220, *School Bus Rollover Protection*.; Standard No. 220 requires that all emergency exits provided i accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits provided in accordance with Standard No. 217' and, therefore, would not be subject to the requirements os S4(b) of Standard No. 220.; You should note that Standard No. 217, in addition to mandating th provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2232OpenMr. Lawrence MacEachern, Cal Light Co., 50 Oak Court, Walnut Creek, CA, 94596; Mr. Lawrence MacEachern Cal Light Co. 50 Oak Court Walnut Creek CA 94596; Dear Mr. MacEachern: In your latest letter, dated February 17, 1976, you asked 'Does th Federal motor vehicle safety standards allow the use of one half of an automobile headlight system on a motorcycle?'; There is no Federal prohibition against an owner modifying hi motorcycle to use any lighting configuration, though there may be State or municipal restrictions. The answer where a manufacturer is involved, however, depends upon the type of automobile headlamp system used. Motor Vehicle Safety Standard No. 108 requires a motorcycle to be equipped with a headlamp system conforming to SAE Standard J584, *Motorcycle and Motor Driven Cycle Headlamps*, April 1964. Two options allowed are use of a single 7 inch sealed beam unit, or of one 5 3/4 inch Type 1 and one 5 3/4 inch Type 2 sealed beam unit, provided these headlamps meet the requirements of SAE J579a, *Sealed Beam Headlamp Units for Motor Vehicles*, August 1965. Thus, 'one half' of a two-headlamp, or of a four-lamp circular lens passenger car headlighting system could be used on a motorcycle. But use of a system comprised of one Type 1A plus Type 2A (rectangular lens), is not currently permitted under Standard No. 108.; Since there is an equivalence of performance between rectangular an circular lens headlamp systems, if you wish to merchandise a two-lamp (Type 1A plus Type 2A) rectangular system for use on motorcycles, you may wish to submit an additional petition for an amendment of Standard No. 108.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3073OpenMr. James Tydings, Specifications Engineer, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Specifications Engineer Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your July 20, 1979, letter asking a questio concerning Standard No. 217, *Bus Window Retention*. You ask whether paragraph S5.4.2.1(a) permits the parallelepiped device to compress the seat cushion when it is inserted in a school bus emergency exit in accordance with the test procedures of the standard. The answer to your question is no.; Paragraph S5.4.2.1(a) states that each rear emergency exit must provid 'an opening large enough to permit unobstructed passage of a rectangular parallelepiped device...' If the parallelepiped device compresses the seat cushion while being inserted in the bus, its passage is not unobstructed as required by the standard. Accordingly, the National Highway Traffic Safety Administration concludes that the device must enter the vehicle without compressing the seat cushion.; Sincerely, Frank Berndt, Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.