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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



Displaying 11561 - 11570 of 16505
Interpretations Date
 

ID: nht95-1.33

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 20, 1995

FROM: Gary Shultz -- Vice President, General Counsel and General Manager, Diamond Star Motors

TO: Edward Glancy. Esq. -- NHSTA

TITLE: None

ATTACHMT: ATTACHED TO 2/10/95 LETTER FROM PHILIP R. RECHT TO GARY SHULTZ (A43; PART 583)

TEXT: Dear Mr. Glancy,

Pursuant to your phone conservation yesterday with Ms. Yolanda Gray, I am sending the included letter addressed to Mr. Recht to your attention for your and his priority attention. This regards our dilemms in how to comply with the Labeling Act under the circumstance of a mid-model year change in our production of one of our carlines from just the U.S. to both the U.S. and Japan. Your attention to this matter is sincerely appreciated.

Attachment

January 20, 1995

Mr. Philip R. Recht Chief Counsel NHTSA 400 7th St. S.W. Washington D.C. 20590

Dear Mr. Recht:

This letter seeks confirmation of compliance with the Automobile Labeling Act. 49 CFR part 583.6 specifies that "each manufacturer, except as specified in 583.5 (f) and (g), shall determine the percentage of U.S./Canadian Parts Content for each carlin e on a model year basis, before the beginning of each model year." Diamond-Star Motors has complied with calculating the percentage of domestic and foreign content of the automobiles we manufacture on a model year basis, and the labels affixed to the car s by our distributor, Mitusbishi Motor Sales of America, Inc., reflect this information.

The problem is the regulations do not mention what to do when there has been a change of plans in the source of production for a [Illegible Words] middle of its model year. One of the carlines currently production will now be manufactured in both the U.S. and Japan which may significantly affect the carline's current calculation for content as well as the final assembly point.

Diamond-Star is therefore requesting confirmation whether the label should be changed to reflect the change in domestic/foreign content in the middle of the model year or whether part 583.6 should be relied on as the authority for determining a carlin e's content only on a one-time model year basis. Further, confirmation is needed as to whether the label should be changed to reflect the final assembly point in accordance with part 583.5 (e).

Since production in Japan will commence soon, an urgent response for clarification is requested. Your time and cooperation is greatly appreciated.

ID: nht95-1.34

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 25, 1995

FROM: Fredd Scheys -- President, S.E.C. Carat Inc.

TO: Mr. John WOMACK -- NHTSA

TITLE: NONE

ATTACHMT: Attached to 1/27/95 letter from Philip R. Recht to Fredd Scheys (A43; Sec. 1397 (b)(2); Also attached to letter dated 3/8/93 from John Womack to Fredd Scheys; Also attached to letter dated 11/16/92 from Paul Rice to Scheys

TEXT: Dear Mr. Womack,

First, I would like to thank you for your information and help on the phone this afternoon.

As said on the phone, I send you the following letters;

1 Letter from Mr. Paul Jackson RICE, dated Nov. 16, 1992

2 Letter from you, dated March 8, 1993

Can you, please, confirm that these answers are still valid as of today. This to keep our records for this particular car as complete as possible.

Please, take note of the new address, fax and phone numbers.

Again, I would like to thank you for your advice and assistance in this for us very important matter.

Sincerely,

ID: nht95-1.35

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 25, 1995

FROM: Paul Pinoski -- Project Engineer, SLP Engineering, Inc.

TO: Philip R. Recht, Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM PHILIP RECHT TO PAUL PINOSKI (A43; STD. 110; PART 567; PART 571); ALSO ATTACHED TO 6/8/94 LETTER FROM JOHN WOMACK TO HAL SULLIVAN

TEXT: Dear Mr. Recht:

I would like to request your assistance in clarifying a component of the definition of vehicle capacity weight listed in 49 CFR 571.110. Could you define the terms rated cargo load and luggage load and explain how these weights are obtained so that I may calculate vehicle capacity weight? My company is in the middle of a production run of a vehicle that we produce for General Motors and we need to fully understand every component of the GVWR. Expedition of this request would be greatly appreciated .

ID: nht95-1.36

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 25, 1995

FROM: Stuart Sacks -- TRADEPRO, INC.

TO: Philip R. Recht, Esq. -- Chief Legal Council, U.S. DEPARTMENT OF TRANSPORTATION, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/25/95 LETTER FROM JOHN WOMACK TO STUART SACKS (A43; STD. 119 PART 574)

TEXT: Dear Mr. Recht:

We are requesting a further interpretation of the Federal Motor Vehicle Standard 119, part 119 S-6.5.

We are considering the immediate possibility of importing tires from The Hangzhou General Rubber Factory, which holds the D.O.T. identification number 7D.

While Standard 109 for passenger tires (Section S-4.3) requires molded D.O.T. code numbers, Standard 119 clearly does not require this for non-passenger tires.

The tires that we are interested in importing from the above factory do not have molded code numbers and the cost of altering these existing molds is prohibitive.

Please respond at your earliest possible convenience so that we might proceed with this matter in full compliance with current regulations.

ID: nht95-1.37

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 27, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Deborah K. Nowak-Vanderhoef -- Attorney, GM

TITLE: NONE

ATTACHMT: Attached to 12/23/94 letter from Deborah K. Nowak-Vanderhoef to Philip R. Recht (OCC 10600)

TEXT: Dear Ms. Nowak-Vanderhoef:

We have received your letter of December 23, 1994, with respect to an alternative to HB3 and HB4 replaceable light sources, and asking for our "guidance as to the most appropriate method for seeking approval of the alternative bulb configurations." Altho ugh your letter is silent on the matter, we understand from Dick Humphrey of your Washington office that GM would like to incorporate the revised light sources in production in the summer of 1995.

You have presented three possible methods for our consideration. The first is to "seek approval" through 49 CFR Part 564. The second is to petition for rulemaking to amend Standard No. 108 to incorporate the revised light sources. The third is to reque st that HB3 and HB4 bulbs be placed in Part 564 with the alternative configurations included on the drawing.

Under the current regulatory scheme for headlamps, there are two regulations that govern the permissibility of replaceable light sources. The first of these, Standard No. 108, prescribes detailed dimensional specifications and performance requirements f or replaceable light sources Types HB1 through HB5. Faced with the possibility of an endless number of new light sources which could not be added to Standard No. 108 without at least two rulemaking notices, NHTSA decided to deregulate the dimensional asp ects of replaceable light sources by establishing Part 564 which sets up an agency procedure for the allowance of new light sources upon receipt of the dimensional information specified in the regulation. However, the new light source must not be interc hangeable with any other replaceable light source, either in Part 564 or Standard No. 108. NHTSA has been petitioned for reconsideration of this restriction but has not yet acted upon it. Further, it can be argued that there is a regulatory inconsisten cy in the different treatment of replaceable light sources, and that NHTSA needs to address this inconsistency.

NHTSA is conscious of the need for regulatory flexibility in both areas and is actively working towards their resolution.

At present, it appears that we could respond positively to petitions for reconsideration of Part 564 by a direct amendment allowing modifications in previous submissions, but we have not completed our examination of the possible safety ramifications of a llowing interchangeability of modified light sources. The inconsistent treatment of light source dimensions can be resolved through transfer of the HB Types to Part 564, but we do not believe that the Administrative Procedure Act permits us to do so with out a formal proposal asking public comment. In the present regulatory climate, we cannot estimate when the appropriate rulemaking notices will appear but GM's letter evidences the need for a less restrictive regulatory scheme, and we are sympathetic to GM's position. It is our best estimate that both final action on Part 564 and that a NPRM on the transfer amendments to Standard No. 108 will have been published by July 1, 1995, but the issuance of a final rule on the transfers may not have occurred a s of that date. I might add that we see no true safety issues presented by the modified light source; the difficulties are all procedural.

For these reasons, GM may wish at this point to petition for rulemaking to add HB3S and HB4S, as you call them, to Standard No. 108. In the less likely event that, during the pendency of the HB3S/HB4S rulemaking, rulemaking is completed to Standard No. 108 that removes the other HB Types and places them in Part 564, HB3S/HB4S could be added to Part 564 as a termination of the rulemaking. If a proposal to amend Standard No. 108 to remove the HB Types has not proceeded to a final rule, HB3S/HB4S could b e added to Standard No. 108 as proposed, which would allow their use in GM's vehicles.

The following scenario is the most likely resolution of GM's problem. Under paragraph 564.5(a), GM is eligible to furnish information on HB3S/HB4S to Part 564 because they do not meet the requirements of S7.7. Since information indicates that they are interchangeable with HB3/HB4, they could not be accepted absent an amendment to Part 564 allowing for changes. Thus, when a response to the petitions for reconsideration of Part 564 is published that allows changes without affecting interchangeability, GM could immediately file HB3S/HB4S information in Part 564 which, upon acceptance, would allow immediate use of the light sources in GM cars. Acceptance would also moot any rulemaking that might then be underway to add HB3S/HB4S to Standard No. 108 pur suant to a GM petition for rulemaking.

You have also suggested that a single new submission to Part 564 could consist of the HB3/HB4 information currently part of Standard No. 108 with the alternative configurations of HB3S/HB4S included on the drawing. Given paragraph S564.5(a)'s specific e xclusion of Standard No. 108 light sources from Part 564, we could not accept for Part 564 a submission that included a light source meeting the requirements of S7.7 of Standard No. 108.

Our rulemaking and legal staff would be willing to talk with you further if you wish.

Sincerely

ID: nht95-1.38

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 27, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Fredd Scheys -- President, S.E.C. Carat, Inc.

TITLE: NONE

ATTACHMT: Attached to 1/25/95 Fax from Fredd Scheys to John Womack; Also attached to 3/8/93 letter from John Womack to Fredd Scheys; Also attached to 11/16/92 letter from Rice to Scheys

TEXT: Dear Mr. Scheys:

This responds to your FAX of January 25, 1995, to John Womack of this Office asking whether the interpretation letter sent to you on November 16, 1992, and confirmation letter sent you on March 8, 1993, remain valid.

This confirms that these letters remain valid. We note that the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) was recodified in July 1994. The correct citation today is 49 U.S.C. Chapter 301 - Motor Vehicle Safety.

The first full paragraph of the second page of the November 16, 1992, letter refers to "Title 15, United States Code, section 1397(b)(2)." Under the recodification, the citation has become "Title 49 United States Code, section 30122(b)". Further, the qu oted phrase in that paragraph that reads "knowingly rendering inoperative in whole or in part any device of element of design installed in accordance with a Federal motor vehicle safety standard" has been restated to read "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." But the meaning remains the same and there is no substantive change in the prohibition.

Sincerely,

Philip R. Recht

ID: nht95-1.39

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 27, 1995

FROM: J. Randle Schick, Assistant Chief Counsel, Illinois Dept. Of Transportation

TO: Susan Kunkel; John Womack

TITLE: SB 52

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO EDWARD GOWER (A43; PART 571.3)

TEXT: The Chief Counsel has asked me to respond to your question whether he concurs with Mr. Myers' interpretation of the United States Code. I do not concur with his interpretation that a vehicle dealer is prohibited by federal law from selling a van, which is not a school bus, with a capacity of more than 10 passengers to be used for school transportation.

The Federal Motor Vehicle Safety Standards are manufacturing standards. A school bus must be manufactured to certain federal standards. The manufacturer must certify to the dealer that a school bus has been manufactured to that standard. Federal law d oes not take the next step and require the dealer to sell only school buses for school transportation. State law, and only state law, governs the operation of school buses by schools and sets those requirements. If schools are authorized by state law t o use vans which are not school buses, a school can do so and can purchase a van for that purpose.

I believe what Mr. Myers had in mind is that if a school is shopping for a school bus, the dealer has to sell the school a bus that is certified as a school bus.

ATTACHMENT

SENATE BILL NO. 52

89th GENERAL ASSEMBLY

State of Illinois

1995 and 1996

(Prefiled January 10, 1995)

Introduced January 11, 1995, By Senator Watson

SYNOPSIS AS INTRODUCED

105 ILCS 5/29-6.3 new 625 ILCS 5/1-182 from Ch. 95 1/2, par. 1-182 625 ILCS 5/11-1414.1 from Ch. 95 1/2, par. 11-1414.1 Amends the School Code to provide that school districts may transport up to 15 students to and from interscholastic or school sponsored activities in a van under certain conditions. Amends the Vehicle Code to provide that these vans do not fall under the definition of a "school bus". Effective immediately.

Fiscal Note Act may be applicable

AN ACT concerning school property and transportation, amending named Acts.

Be it enacted by the People of the State of Illinois, represented in the General Assembly:

Section 5. The School Code is amended by adding Section 29-6.3 as follows:

(105 ILCS 5/29-6.3 new)

Sec. 29-6.3. Transportation to and from specified interscholastic or school sponsored activities. Any school district may transport not more than 15 students to and from an interscholastic athletic or other interscholastic or school sponsored activi ty in a motor vehicle designed for the transportation of not less than 7 nor more than 16 persons commonly referred to as a van, provided that the van is operated by or for the district under a rental or for hire arrangement entered into by the district with respect to the specific activity in connection with which such transportation is to be furnished, and provided further that any school district furnishing transportation for students under the authority of this Section shall insure against any loss or liability of the district resulting from the maintenance, operation, or use of the vehicle in a company licensed and authorized to write such coverage in this State.

Section 10. The Illinois Vehicle Code is amended by changing Sections 1-182 and 11-1414.1 as follows:

(625 ILCS 5/1-182) (from Ch. 95 1/2, par. 1-182) Sec. 1-182. School bus.

(a) "School bus" means every motor vehicle, except as provided in paragraph (b) of this Section, owned or operated by or for any of the following entities for the transportation of persons regularly enrolled as students in grade 12 or below in connect ion with any activity of such entity:

Any public or private primary or secondary school;

Any primary or secondary school operated by a religious institution; or

Any public, private or religious nursery school.

(b) This definition shall not include the following:

1. A bus operated by a public utility, municipal corporation or common carrier authorized to conduct local or interurban transportation of passengers when such bus is not traveling a specific school bus route but is:

On a regularly scheduled route for the transportation of other fare paying passengers; Furnishing charter service for the transportation of groups on field trips or other special trips or in connection with other special events; or

Being used for shuttle service between attendance centers or other educational facilities.

2. A motor vehicle of the First Division.

3. A motor vehicle designed for the transportation of not less than 7 nor more than 16 persons that is operated by or for a public or private primary or secondary school, including any primary or secondary school operated by a religious institution, for the purpose of transporting not more than 15 students to and from interscholastic athletic or other interscholastic or school sponsored activities.

(Source: P.A. 83-299.)

(625 ILCS 5/11-1414.1) (from Ch. 95 1/2, par. 11-1414.1) Sec. 11-1414.1. School transportation of students. (a) Every student enrolled in grade 12 or below in any entity listed in paragraph (a) of Section 1-182 of this Code who is transported in a seco nd division motor vehicle owned or operated by or for that entity, in connection with any official activity of such entity, must be transported in a school bus or a bus described in subparagraph (1) of paragraph (b) of Section 1-182.

(b) This Section shall not apply to any second division vehicle being used by such entity in a parade, homecoming or similar school activity, nor to a motor vehicle designed for the transportation of not less than 7 nor more than 16 persons while that vehicle is being operated by or for a public or private primary or secondary school, including any primary or secondary school operated by a religious institution, for the purpose of transporting not more than 15 students to and from interscholastic ath letic or other interscholastic or school sponsored activities. (Source: P.A. 83-299.)

Section 99. Effective date. This Act takes effect upon becoming law.

ID: nht95-1.4

Open

TYPE: INTERPRETATION-NHTSA

DATE: January 3, 1995

FROM: Richard Kreutziger -- Exec. Dir., NYSBDA

TO: Walter Myers -- Counsel Staff, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 2/13/95 LETTER FROM PHILIP R. RECHT TO RICHARD KREUTLIGER (A43; STD. 217; PART 571.3)

TEXT: I MUCH APPRECIATE YOUR RETURNING MY TELEPHONE CALL THIS DATE.

THE QUESTION AS POSED TO YOU ON THE TELEPHONE RELATING TO THE AMENDED FMVSS 217 PERTAINS DIRECTLY WITH THE PROTRUSION OF THE "FLIP" SEAT THAT IS POSITIONED DIRECTLY TO THE REAR OF THE LEFT SIDE (CENTER) EMERGENCY DOOR.

AS NOTED ON THE FOLLOWING DRAWING - THE BOTTOM OF THE FRAMEWORK OF THE "FLIP" SEAT DOES EXTEND BEYOND THE "DOOR OPENING". THE EXTENSION VARIES UP TO A MAXIMUM OF 3/4 INCH. EVEN WITH THIS "INVASION" OF THE DOOR OPENING THERE IS NO OBSTRUCTION TO THE DOOR LATCH MECHANISM - AND A DIMENSION OF 11.75" OF CLEAR "AISLE" SPACE IS PROVIDED. THIS AISLE SPACE IS CLEAR TO THE LONGITUDINAL BODY CENTER LINE.

THE DIMENSION IS ACQUIRED THRU THE LOCATION OF THE FORWARD SEAT, IN ACTUAL PRODUCTION THE SEAT AT THE FORWARD EDGE OF THE LEFT SIDE (CENTER) EMERGENCY DOOR IS LOCATED MORE FORWARD THAN THAT AS DEPICTED FROM THE FMVSS DRAWING.

AS PER OUR VERBAL CONVERSATION - AND YOUR UNDERSTANDING AT THE TIME OF THAT VERBAL CONVERSATION OF THE "QUESTION" YOU COMMENTED THAT "AS LONG AS THERE WAS 30 CENTIMETERS (11.7 +") THERE SHOULD BE NO SERIOUS PROBLEM OR OBJECTION".

HOPE THE WRITTEN QUESTION IS PRESENTED PROPERLY AND THAT THE FOLLOWING DRAWING IS ACCEPTABLE - THAT I CAN ASSUME TO HEAR FROM YOU WITH WRITTEN CONFIRMATION PROMPTLY.

THANK YOU.

ID: nht95-1.40

Open

TYPE: INTERPRETATION-NHTSA

DATE: February 2, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Kenneth Sghia-Hughes -- Research Engineer, Solectria Corporation

TITLE: NONE

ATTACHMT: Attached to 12/8/94 letter from Kenneth Sghia-Hughes to Chief Counsel (OCC 10572)

TEXT: Dear Sir:

We have received your letter of December 8, 1994, with respect to the applicability of two Federal motor vehicle safety standards to electric vehicles.

With respect to Standard No. 301 Fuel System Integrity, you believe that the language of S3 implies that "it applies to all passenger vehicles, but to only those trucks with GVWR of 10,000 pounds or less and that use fuel with a boiling point above 32 de grees F." You conclude, however, that "this standard appears not to apply to electric vehicles with no liquid fuel."

Under S3 of Standard No. 301, the standard applies to certain specified vehicles that "use fuel with a boiling point above 32 degrees F". The use of the fuel is not stated. Obviously, electric vehicles do not use liquid fuel for propulsion, but some of them do use a small amount of liquid fuel in their heating systems. Standard No. 301 would apply to an electric vehicle with a fuel-fired heating system.

With respect to Standard No. 102 Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect, you ask for "a clarification of this standard with regard to single speed transmissions" and, if it is applicable, ask that S3.1.3 "be rewritten or interpreted to include the initial activation of EV motor controllers as well as engine starters."

NHTSA has previously concluded that electric vehicles with single speed transmissions are excluded from Standard No. 102 (58 FR at 4646). I enclose a copy of the Federal Register notice reflecting this conclusion.

Sincerely,

Philip R. Recht

ID: nht95-1.41

Open

TYPE: INTERPRETATION-NHTSA

DATE: February 2, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Gerard Bonvin -- Auto Cheyenne USA Inc.

TITLE: NONE

ATTACHMT: Attached to 12/15/94 letter from Gerard Bonvin to Philip Recht (OCC 10566)

TEXT: Dear Mr. Bonvin:

This is in reply to your letter of December 15, 1994, with respect to the relationship of certain DOT regulations to the Cheyenne, a small front-wheel drive utility vehicle that you wish to import and distribute in the United States.

You have asked the following questions:

"What are the procedure to follow in order to be categorize Small Volume manufacturer?"

Your question assumes that we have a category of "small volume manufacturer." We do not, and there is no exclusion from the Federal motor vehicle safety standards (FMVSS) based upon the volume produced by the manufacturer. All motor vehicles must comply with all FMVSS, unless the agency has exempted them from one or more of the standards. We do recognize limited production volume in the regulation under which a manufacturer who produces less than 10,000 motor vehicles of all types may apply for a temp orary exemption on the basis that compliance would cause it substantial economic hardship, and must provide production information as part of its application.

"Is there really a big difference on the test in order to certified between small volume and over 10000 vehicles?"

As indicated above, if a manufacturer produces less than 10,000 vehicles, that fact is relevant only if that manufacturer wishes to file a hardship exemption application. If a small volume manufacturer has not been exempted, it must comply with the same requirements as apply to those whose yearly production exceeds 10,000.

"Is there any difference between two seaters or four seaters on crash test?"

That is a question to be answered by a vehicle manufacturer. If a four-seater is heavier than a two-seater, the difference in weight could make a difference in whether a vehicle with a borderline design passes or fails a crash test.

"Is there a rear crash impact?"

Yes. FMVSS No. 301 Fuel System Integrity specifies a 30 m.p.h. moving barrier rear impact test.

"Do we need Air Bags if we have Seat belts?"

Currently, vehicles like the Cheyenne are not required to have air bags. However, as explained below, air bags are one means of complying with a the automatic protection requirement which is being phased in for vehicles like the Cheyenne, and eventually the Cheyenne will be required to have air bags for both the driver and right front passenger.

Generally, Jeep-type vehicles are considered to be "multipurpose passenger vehicles" (MPVs). Based on your description, we also assume that the Cheyenne will have a GVWR of 8,500 pounds or less. A requirement in FMVSS No. 208, Occupant Crash Protection , which is being phased in requires a specified percentage (varying by year) of each manufacturer's light trucks (a category which includes MPVs with a GVWR of 8,500 pounds or less) manufactured on or after September 1, 1994 to be equipped with automatic crash protection. The two types of automatic crash protection currently offered are automatic safety belts and air bags.

A recent amendment of FMVSS No. 208 will require at least 80 percent of each manufacturer's light trucks manufactured on or after September 1, 1997 and before September 1, 1998 to be equipped with an air bag and a manual lap/shoulder belt at the driver's and right front passenger's seating positions. All light trucks manufactured on or after September 1, 1998 must be equipped with an air bag and a manual lap/shoulder belt at these seating positions.

"Do we need a buzzer for the seat belt?"

Yes, an audible warning indicator is required.

"Is the dashboard need to be padded?"

We cannot answer your question. That decision is to be made by the manufacturer if its tests show that the dashboard is within the head impact area and that some type of padding is necessary to meet FMVSS No. 201 Occupant Protection in Interior Impact. The FMVSS are performance standards and we do not impose design restrictions on the manufacturer, such as requiring that the dashboard be padded.

"Is there any specific ways on how to install the windshield?"

No, because that would be design restrictive and, as noted above, the FMVSS are performance standards. The performance requirement for windshields is in FMVSS No. 212 Windshield Retention which specifies what the windshield mounting must do in a 30 mph frontal barrier crash. However, if the MPV is an open vehicle with a fold-down windshield, FMVSS No. 212 does not apply to it.

"What is the surface of the windshield that need to wiped? As far as Windshield Wipers, how many cycles and how many different speed?"

You will find the answers to your questions in FMVSS No. 104 Windshield Wiping and Washing Systems. For a copy of these and all our regulations, you should have a copy of "Title 49 Code of Federal Regulations Parts 400-999". This is available from the U.S. Government Bookstore at ARCO Plaza, C-Level, 505 South Flower Street, Los Angeles.

Sincerely,

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.