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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.”

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NHTSA's Interpretation Files Search



Displaying 7961 - 7970 of 16514
Interpretations Date
 search results table

ID: 77-2.18

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: ASTM Subcommittee F9.10

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 2, 1977, letter asking whether the National Highway Traffic Safety Administration (NHTSA) still emphasizes or frequently conducts tubeless tire resistance to bead unseating tests as authorized by Standard No. 109, New Pneumatic Tires.

As you know, the bead unseating test procedure was adopted from the Society of Automotive Engineers Practice J918. It is our understanding that the SAE continues to use this procedure for tire performance tests. The NHTSA is of the opinion that the bead unseating test procedure is a viable laboratory evaluation of the compatibility of a tire and rim combination. This has become especially important since 1975, when the table of approved alternative rims of Appendix A of Standard No. 110, Tire and Rim Selection, was deleted, and the tables of standards organizations were adopted. The bead unseating test provides an additional verification of the tire and rim combinations listed in the yearbooks of these organizations.

Standard No. 109 requires several tire performance tests: physical dimensions, resistance to bead unseating, strength, endurance, and high speed performance. The NHTSA compliance testing is conducted on a random selection basis. In the case of tires, not every test is conducted on each brand of tire selected for compliance testing. Therefore, the bead unseating test is not always conducted during compliance testing. However, the agency does conduct bead unseating tests whenever appropriate and will continue to do so.

SINCERELY,

ASTM

March 2, 1977

Chief Counsel National Highway Traffic Safety Administration

The ASTM Subcommittee F-9.10 on the Structural Integrity of Tires has been developing a Standard Test Procedure for Unseating the Bead of a Tubeless Passenger Car Tire from the Rim. The draft of this Proposed Standard Test Procedure was approved by the Subcommittee and submitted to the F-9 Main Committee for ballot. The Test Procedure is essentially that of the Bead Unseating Test contained in the National Highway Traffic Safety Administration test MVSS 109 put in ASTM format.

Discussion of five negative ballots which were received disclosed that there exists considerable doubt concerning the validity of the Bead Unseating Test among the engineers representing the tire producing companies. The principal objections to it are:

a. It is believed that the unseating test does not reflect actual field results, nor performance characteristics.

b. The test is not functional for all current sizes (profiles, construction, etc.) of tires.

c. The origin and data base of the bead unseating test, as well as the reasons for its incorporation into the repertoire of testing, are not clear to the persons presently involved in tire test work.

d. That the regulatory bodies no longer emphasize nor do they frequently conduct the test.

The Task Group is planning a survey to obtain information from the tire producing companies which will assist in the resolution of (a) and (b) above. Since the test originated with the motor car companies and was developed by their representatives in the tire committee of the Society of Automotive Engineers, the Task Group expects to obtain the early history of the test from the SAE group to resolve (c).

It is the purpose of this inquiry to the National Highway Traffic Safety Administration to determine whether that regulatory group no longer emphasizes nor frequently conducts the test as stated in (d) above. Is this the present situation? Does NHTSA consider that this test has lost significance since it was adopted as part of the original MVSS 109.

The ASTM Subcommittee F-9.10 would appreciate a response from NHTSA to clarify the situation in which the passenger tubeless tire bead unseating test is presently considered and conducted by them.

Louis Marick, Chairman Subcommittee F-9.10

ASTM

March 2, 1977

Chief Counsel National Highway Traffic Safety Administration

Enclosed is a copy of a letter from ASTM subcommittee F9.10 on the Structural Integrity of Tires questioning the validity of the "Bead Unseating Test Procedure MVSS109" which is being considered for development as an ASTM Standard.

The purpose of my letter is to request your response to the problem presented and ask that you reply directly to:

Mr. Louis Marick, Chairman ASTM Subcommittee F9.10 339 Merriweather Road Grosse Pointe, Mich 48236 Your assistance on this standards development project will be sincerely appreciated.

William T. Cavanaugh Managing Director

CC: L. MARICK; F. CECIL BRENNER -- NHTSA

ID: 77-2.19

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Onics Holdings, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 29, 1977, letter asking whether several vehicles that you describe would be considered "vehicles other than passenger cars" for purposes of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

Vehicles other than passenger cars includes: multipurpose passenger vehicles, trucks, buses, motorcycles, and trailers, all of which are defined in the Code of Federal Regulations, Title 49, Part 571.3. Since the vehicles you describe appear to fall within the definition of multipurpose passenger vehicle or truck, they are considered "vehicles other than passenger cars." Accordingly, they must comply with the rim marking requirements of Standard No. 120.

SINCERELY,

ONICS HOLDINGS INC.

March 29, 1977

NHTSA Office of the Chief Counsel

I note that for wheel rim marking purposes you define a "vehicle other than passenger car" as a "multipurpose passenger vehicle (MPV), truck, bus, motorcycle, or trailer". Would you be kind enough to give me a ruling as to whether the following vehicles fall into this category:

General Motors Pickups, Type C and K (100 Series)

General Motors Blazers, Type C and K (100 Series)

General Motors Suburban, Type C and K (100 Series)

General Motors Vans, Type G (100 Series)

Similar vehicles made by other manufacturers

I would appreciate a reply at your earliest convenience as the matter is urgent.

Stuart A. Mossman President

ID: 77-2.2

Open

TYPE: INTERPRETATION-NHTSA

DATE: 03/29/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pupil Transportation Service - Commonwealth of Virginia

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 18, 1977, letter asking whether Standard No. 222, School Bus Passenger Seating and Crash Protection, permits the use of a two-passenger front-row seat with a corresponding two-passenger front-row restraining barrier. Secondly, you ask whether the State of Virginia can require the use in joints of discrete fasteners and welding, and not adhesives, without conflicting with the requirements of Standard No. 221, School Bus Body Joint Strength. Finally, you ask who must certify that a vehicle complies with Standard No. 105, Hydraulic Brake Systems.

The NHTSA has issued an interpretation allowing the use of a two-passenger front-row seat with a two-passenger restraining barrier. This can be accomplished by the use of a two-passenger seat cushion and a three-passenger seat back as you suggest. I am enclosing a copy of the NHTSA interpretation for your information.

Regarding your second question concerning the use of adhesives in bus body joints, the Federal bus body joint standard requires only that joints meet a specified strength requirement. The NHTSA does not require any particular type of joint construction. Therefore, the purchaser and manufacturer can decide upon any method of joint construction as long as the joint meets Federal strength specifications.

Your final question asks who must certify that a small school bus (under 10,000 pounds) is in compliance with Standard No. 105, Hydraulic Brake Systems. To assign responsibility for the certification of multi-stage vehicles, NHTSA has issued Part 568, Vehicles Manufactured in Two or More Stages (enclosed). The manufacturer of an "incomplete-vehicle" (such as a cab-chassis) must provide documentation to the intermediate- and final-stage manufacturer of the vehicle on how to complete it so that it complies with all applicable standards. It is the responsibility of the final-stage manufacturer to affix a certification label unless the incomplete- or intermediate-stage manufacturer assumes this responsibility.

On a related matter concerning small school buses, it is our understanding that school buses weighing under 10,000 pounds will be available after April 1, 1977.

SINCERELY,

COMMONWEALTH of VIRGINIA STATE DEPARTMENT OF EDUCATION

February 18, 1977

Frank A. Berndt, Chief Counsel National Highway Traffic Safety Administration This is in further regard to my questions mentioned during our telephone conversation on February 17, 1977 and my conversation with Mr. Roger Tilton of your office on this date. As indicated to you and Mr. Tilton, written questions would be submitted. They are as follows:

1. FMVSS 222

1. Will standard allow for a two passenger right front barrier to allow wider entrance into aisle?

2. Can right front seat be a two passenger cushion with a three passenger back allowing all other seats to be a three passenger seat?

2. FMVSS 221

1. Will State of Virginia be able to require the use of discreet fasteners and welding only in the joining of panels without the use of adhesives? If not, why?

3. Question of certification and availability of completed van conversion type school bus under 10,000 lbs. GVWR.

Who will certify compliance with FMVSS 105?

Do you have information or position which indicate such small school buses can comply with April 1, 1977 requirements of federal standards?

Do you have information which indicate such small buses will be available after April 1?

Your response to these questions is needed at the earliest possible date because many local school districts are in the process of bidding for purchase of school buses which comply with both state and federal standards.

R. A. Bynum, Supervisor Pupil Transportation Service

ID: 77-2.20

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 28, 1977, letter asking whether it is legal to certify a school bus manufactured after April 1, 1977, if the bus is painted a color other than National School Bus Glossy Yellow.

The certification requirements of the National Highway Traffic Safety Administration are found in Part 567, Certification (49 CFR 567). This part requires that a manufacturer certify that the vehicle he manufactures complies with all applicable Federal motor vehicle safety standards promulgated under the National Traffic and Motor Vehicle Safety Act of 1966 (as amended) (the Act) (15 U.S.C. 1381). No safety standard promulgated under the Act requires that school buses be painted school bus yellow. Therefore, failure of a manufacturer to produce a school bus of that color would not be a violation of the Act, and his certification of the bus compliance with motor vehicle safety standards would not be affected.

Pupil Transportation Standard No. 17, promulgated under the authority of the Highway Safety Act of 1966 (23 U.S.C. 401 et seq.), controls the color of school buses. This standard requires that all vehicles operating as school buses be painted National School Bus Glossy Yellow. Since this standard applies to the operation of school buses and not their construction, compliance with its requirements is not a prerequisite to motor vehicle safety standard certification.

ID: 77-2.21

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bandag of Nassau, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 10, 1977, letter asking whether it is permissible for you to use a DOT number assigned to another tire retreader when you perform special retread work in your plant for the other retreader who lacks facilities to do the work himself.

Standard No. 117, Retreaded Pneumatic Tires, requires that the retreader apply a DOT symbol and identification number to the tire. The DOT symbol indicates conformance with Federal regulations. The number enables the National Highway Traffic Safety Administration (NHTSA) to identify the retreader that manufactures the tire. To permit one manufacturer to use the identification number of another would impair the NHTSA enforcement actions. Accordingly, you would not be permitted to use any DOT number other than your own on tires you retread.

SINCERELY,

BANDAG OF NASSAU, INC.

March 10, 1977

U.S. Department of Transportation

Re: DOT Regulations

If two individuals are both financially interested in two distinct corporate tire entities -- one party operating the one retread plant and the other party operating the second retread plant -- each plant having its own DOT identification marker, is it permissable to use both DOT markers in the first plant to enable them to process special work that cannot be done in the second plant.

We shall appreciate your advising us on this matter.

L. Wenderoth

ID: 77-2.22

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Bendix Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Bendix Corporation's March 29, 1977, request for confirmation that the manual adjustment of automatic adjusters is acceptable following the burnish procedures of Standard No. 121, Air Brake Systems, at the option of the manufacturer.

The procedure that you recommend is not permitted by any provision of Standard No. 121. The NHTSA would consider some provision to deal with the overadjustment of automatic adjusters upon receipt of technical data showing justification for such action. Based on consideration of the data received and a petition for amendment, the agency could commence a rulemaking proceeding in accordance with established procedures.

I have enclosed a copy of a similar interpretation made to Rockwell International.

Sincerely,

ATTACH.

Bendix

Heavy Vehicle Systems Group

John Snow -- Administrator, National Highway Traffic Safety Administration

March 29, 1977

Subject: Request for Interpretation: FMVSS '121'

Ref.: Brake Burnish Procedures S6.1.8.1 and S6.1.8.2

Dear Mr. Snow:

The Bendix Corporation, Heavy Vehicle Systems Group (HVSG) respectfully requests clarification of the portions of S6.1.8.1 and S6.1.8.2, which permit adjustment of the brakes as recommended by the vehicle manufacturer after the burnish procedure. Specifically, clarification is requested that either S-Cam or wedge brakes equipped with automatic adjusters can be adjusted as recommended by the vehicle manufacturer, as well as those equipped with manual brake adjusters.

As permitted by the subject paragraphs, vehicle manufacturers have, in the past, manually adjusted the brakes; especially S-Cam brakes, after the burnish procedure. The affect of this has been to generate a large amount of background data and vehicle compliance testing starting with given brake chamber strokes.

In an effort to promote safety by maintaining a predictable level of good braking, assuring good brake balance and eliminating the possibility of vehicles being operated with S-Cam brakes badly out of adjustment, Bendix has introduced an automatic slack adjuster. Since the adjustment maintained by an automatic slack adjuster is influenced by several factors, including brake and drum temperature, and lining and drum design and conditions, the stroke maintained by an automatic slack adjuster after the burnish procedure will likely be different than that which has been used by the vehicle manufacturers for compliance testing.

It is the opinion of the Bendix Corporation (HVSG) that the use of automatic slack adjusters does not prohibit the vehicle manufacturer from adjusting the brakes, if desired, after the burnish procedure. A vehicle manufacturer advised us that it is reluctant to introduce this device, unless assurance can be given that requalification testing will not be required with the strokes that exist after the burnish test procedure.

We would be pleased to discuss the details of this matter if any additional information is necessary.

Very truly yours,

R. W. Hildebrandt -- Group Director of Engineering

ID: 77-2.23

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Weber Aircraft

TITLE: FMVSS INTERPRETATION

ATTACHMT: ATTACHED TO LETTER DATED 08/16//88, TO GLENN L. DUNCAN FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 207; LETTER DATED 08/30/79 TO ROBER J. WAHLS FROM FRANK A. BERNDT; LETTER DATED 02/01/88 TO ERICA Z. JONES FROM GLENN L. DUNCAN RE UNITED TOOL AND STAMPING INC FMVSS 207 SEATING SYSTEM; LETTER DATED 11/16/87 TO ERICA Z. JONES FROM GLENN L. DUNN RE FMVSS 207 SEATING SYSTEM OCC-1278

TEXT: This responds to your letter of February 25, 1977, requesting an interpretation concerning the force requirements specified in Safety Standard No. 207, Seating Systems, and Safety Standard No. 210, Seat Belt Assembly Anchorages. You ask whether the specified forces are intended to be "limit loads" (those loads under which no permanent set, yielding or permanent deformation is allowed) or "ultimate loads" (those loads under which structural integrity must be maintained even though permanent set, yielding or permanent deformation takes place) (your terms and definitions).

Under the requirements of Standard No. 210, the anchorage of a seat belt assembly must be able to withstand certain designated forces when tested in accordance with the procedures of the standard. Paragraph S4.2.3 of Standard No. 210 provides that permanent deformation or rupture of a seat belt anchorage or its surrounding area is not considered to be a failure, if the required force is sustained for a specified period of time. Therefore, the force requirements of Standard No. 210 could be considered "ultimate loads," as you define that term.

The agency interprets the force requirements of Standard No. 207 to allow some deformation of the seats during the force test, provided structural integrity is maintained. Therefore, the force requirements of Standard No. 207 could also be considered "ultimate loads," as you define that term.

Please note, however, that if seats are displaced to an extent that the agency determines occupant safety is threatened, a determination could be made under provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1381, et seq.) that the vehicle contains a safety related defect and sanctions could be imposed on the manufacturer.

Please contact our office if you have any further questions.

SINCERELY,

Frank A. Berndt Acting Chief Counsel

Feb. 25, 1977

National Highway Traffic Safety Administration Attention: Chief Counsel's Office

Subject: Motor Vehicle Safety Standard No. 207 & 210

Ref: Telecon G. Cress and R. Nelson, 2-25-77

Our test facility has been approached by several manufacturers of vehicle seating systems. These manufacturers have requested that we test (and provide a report) to the requirements of MVSS Nos. 207 and 210. In reviewing the MVSS requirements, a question has arisen. It is on the definition or interpretation of the phrase, "shall withstand the following forces" as used in MVSS 207, Paragraph S4.2. In the aircraft industry, load or force requirements are usually designated as limit loads (those loads under which no permanent set, yielding or permanent deformation is allowed) or ultimate loads (those loads under which structural integrity must be maintained even though permanent set, yielding or permanent deformation takes place).

As an example, if the structure in Figure 1 (attached) were subjected to a limit load of 20 times the weight of the seat, the seat would retain its full capabilities to function. There would be no permanent deflection or degradation of the structure due to the limit load application. If the structure in Figure 1 were subjected to an ultimate load of 20 times the seat weight, the seat could assume the posture shown in Figure 2 as long as it supported the test load for from 3 to 10 seconds. The question is, "May we consider the forces specified in MVSS 207 (and also MVSS 210) as ultimate loads?"

Thank you for your assistance.

WEBER AIRCRAFT, Division of Walter Kidde & Company, Inc.

Gordon P. Cress Chief, Structures & Test

ATTACH.

DIRECTION OF TEST LOAD

PRE & POST TEST (LIMIT LOAD)

FIGURE 1

DIRECTION OF TEST LOAD

POST TEST (ULTIMATE LOAD APPLICATION)

FIGURE

(Graphics omitted)

ID: 77-2.24

Open

TYPE: INTERPRETATION-NHTSA

DATE: 04/29/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: SEMA

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 24, 1977, letter asking about the applicability of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, to aftermarket rims.

Your first assumption that vans and light truck models are classified as vehicles other than passenger cars is correct. Accordingly, rims manufactured for use on these vehicles must comply with the requirements of the standard. Where the rims may be used in the aftermarket either on passenger cars or vehicles other than passenger cars, they must comply with the requirements of Standard No. 120.

On a related matter concerning the aftermarket, you question whether Standard No. 120 has applicability to rims sold for use on used vehicles. Section S3 of the standard states that the requirements apply to motor vehicles other than passenger cars and to rims for use on those vehicles. This indicates that the standard is both a motor vehicle and an equipment standard. Since it is an equipment standard, the requirements apply to all rims manufactured for use on the specified vehicles regardless of whether the rim will be original equipment or sold in the aftermarket.

SINCERELY,

March 24, 1977

Roger Tilton Office of Chief Counsel National Highway Traffic Safety Administration

Since I have not heard from you in the past few days, I will assume that the enclosed report from the "Consumer Product Safety Guide" is completely fallacious. As I mentioned during our phone conversation, our association is attempting to provide the aftermarket wheel manufacturers in our membership with timely information concerning the Federal Motor Vehicle Safety Standard 120, rim marking requirements, and I do have several questions that pertain to the standard.

We have made the assumption that the van and light truck models in the domestic fleet fall under the category of vehicles other than passenger cars, and would like to know if our assumption is correct. Also, in the February 7, 1977 Federal Register, Page 7142, the discussion of rim marking requirements states that "these marking requirements have no bearing on the use of the rim on passenger cars, except as future labeling requirements in Standard No. 110 might prohibit one or more of the items required by S5.2. This eventuality is considered to be extremely unlikely." We find that the most common bolt circle patterns for wheels are common to both passenger cars and light trucks and vans, and the aftermarket generally does not market separate wheels for trucks and passenger cars. We would like to know if the statement quoted above means that a wheel that has a common application for light trucks and passenger cars can, or must, have the rim markings required by FMVSS 120 by August 1, 1977.

We have also noted that the standard is promulgated to fulfill Section 202 of the National Traffic and Motor Vehicle Safety Act, which pertains to equipment requirements for new vehicles or vehicles before the first purchase thereof. We, therefore, request a legal opinion on whether the FMVSS 120 can be construed to apply to a true aftermarket wheel which is purchased by the vehicle owner, usually some time after the first purchase.

This may be a moot point, for in fact, the aftermarket manufacturers market the same wheel models for light truck applications, passenger car applications, new vehicle applications (dealership changeover), and aftermarket. But a legal opinion on the questions that I have raised would be most helpful at this time.

Your assistance would be very much appreciated, and I trust that if you have any questions on this matter, you won't hesitate to call on me.

Paul J. Ryan Staff Engineer

Consumer Product Safety Guide

Rim Requirement Repeated, Mobile Homes De-regulated by NHTSA

A requirement that wheel rims of motor vehicles other than passenger cars be labeled as to their normal dimensions manufacturer, and date of manufacture has been withdrawn by the National Highway Safety Administration. The requirement had been previously issued with a delayed effective date. The NHTSA stated that the (Illegible Word) of the requirement had not interfered with certification and defect actions, and because enforcement might lead to economic waste, the agency has decided it is unnecessary. In responding

ID: 77-2.25

Open

TYPE: INTERPRETATION-NHTSA

DATE: 05/01/77 EST

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Department of Education - New Jersey

TITLE: FMVSS INTERPRETATION

ID: 77-2.26

Open

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Coach & Equipment

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 15, 1977, letter asking whether the head and knee form impact requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection, apply to the stanchion post and cross bars installed in your buses.

School buses with gross vehicle weight ratings of 10,000 pounds or less are not required to have restraining barriers as mandated in S5.2 of the standard for larger buses. Therefore, there is no requirement that you install stanchions, cross bars, or panels in the buses you manufacture. Should you choose to install these devices, they would not be required to be as wide as the seat. Similarly, there would be no requirement pertaining to forward or rearward movement of these devices.

The leg protection zone as defined in S5.3.2 of the standard is measured with reference to seat backs and restraining barriers. Since the devices you mention are not considered as either seat backs or restraining barriers, the leg protection zone requirements do not apply.

The head protection zone requirements, on the other hand, apply to any contactable surface located within the zone defined in S5.3.1 of the standard. Since part of the stanchion to which you refer creates a contactable surface within the head protection zone, it must meet the requirements of the standard specified in S5.3.1.

SINCERELY,

Coach & Equipment Sales Corporation

March 15, 1977

Roger Tilton Counsel National Highway Traffic Safety Administration

Enclosed is a colored print which depicts the head and knee impact zone as we presently understand the standard.

The questions which we feel are pertinent to our problems are as follows:

1. Utilizing a 1" O.D. steel tube section located as shown will both the head and knee impact zone areas require padding to meet the individual pad requirements?

2. Must the stanchion and cross bar be as wide as the seat on each side?

3. For compliance with the standard would a steel (padded) panel be required on each, or either side?

4. Would the stanchion post and cross bar section require any restrictions relating to movement fore and aft?

Perhaps with the mails crossing paths we both will have a better understanding late this week.

I have also enclosed, for your information, our 1976 brochure showing our pre April 1, 1977 production unit.

If we have any further questions we will contact you directly and would much appreciate your doing likewise.

Richard L. Kreutziger Executive Vice President

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.