NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: 08-006631 version 3OpenChris Tinto, Vice President Toyota Motor North America, Inc. Washington Office 601 Thirteenth Street, NW Suite 910 South Washington, DC 20005 Dear Mr. Tinto: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 101, Controls and Displays, as it applies to Toyotas electronic keyless system with push button activation on gasoline engine vehicles and hybrid vehicles. We provide our response below. In your letter, you stated that Toyota currently utilizes an electronic keyless system with push button activation on both gasoline engine vehicles and hybrid vehicles. In the gasoline engine vehicles, the push button is identified by the words Engine Start Stop, i.e., the identifying words specified in Tables 1 and 2 of FMVSS No. 101. In the hybrid vehicles, the push button is identified by the word Power and the ISO power on/off symbol. In the future, Toyota wishes to use a common push button for both its gasoline engine vehicles and its hybrid vehicles. It is considering adopting one of two options. The first option is a push button labeled with the ISO engine start symbol and the ISO engine shut-off symbol.[1] The second option is a push button labeled with the ISO power symbol.[2] You asked whether these options would be permitted under FMVSS No. 101. The FMVSS No. 101 requirements at issue can be summarized as follows. That standard specifies requirements for the location, identification, and illumination of motor vehicle controls, telltales and indicators. More specifically, the standard specifies that each covered vehicle that is fitted with a control, a telltale or an indicator listed in Table 1 or Table 2 must meet the requirements of this standard for the location, identification, color and illumination of that control, telltale or indicator. Engine start controls are listed in Table 2, and engine stop controls are listed in Table 1. The identification specified by this standard for these controls is the wording Engine Start and Engine Stop, respectively. The tables include a footnote for these two controls that states: Use when engine control is separate from the key locking system. The standard also provides that supplementary symbols, words or abbreviations may be used at the manufacturers discretion in conjunction with any symbol, word, or abbreviation specified in Table 1 or Table 2. I will now address the question you asked separately for gasoline engine and hybrid vehicles. Gasoline engine vehicles In your letter, you note FMVSS No. 101s requirement that engine start and engine stop controls be identified by the words Engine Start and Engine Stop. You argue, however, that these identification requirements do not apply to your vehicle based on the footnotes stating that this identification is to be used when the engine control is separate from the key locking system. You state that Toyotas electronic keyless system with push button activation is designed so that the key locking system is activated by pushing the Engine Start Stop button which leads to communication between the electronic/electrical key and ECU in the vehicle. Toyotas view is that given this linkage, the Engine Start Stop control is not separate from the key locking system, and is therefore not required to be labeled Engine Start and Engine Stop. You believe further that it is permissible instead to identify the button with the ISO power symbol or the ISO engine start.and engine shut-off symbols. In considering your question, we note that the footnotes in question have been included in FMVSS No. 101 for decades. We believe the rationale for the footnotes is as follows. In vehicles with a traditional mechanical key locking system which is combined with the engine start/stop function, the location where the mechanical key is inserted is obvious given its physical characteristics, and drivers are ordinarily familiar with turning the key in such systems to start and stop the engine. There has therefore been no need to require separate identification to enable drivers to know that this control is used to start and stop the vehicle. This rationale is not relevant to an electronic keyless system with push button activation. There is no reason to assume that drivers will know the function of the push button unless it is identified. As discussed above, FMVSS No. 101 specifies identification requirements for Engine Start and Engine Stop controls, and we believe the specified words are appropriate for your system. Hybrid vehicles In a January 20, 2003 interpretation letter to Toyota, we addressed how FMVSS No. 101s requirements in this area apply to hybrid vehicles. For reasons discussed below, we concluded that the standard's requirements for labeling "Engine Start" and "Engine Stop" controls would not apply to your hybrid vehicles "Power" button, and that identification of the button would be at the option of the manufacturer. In your incoming December 2002 letter that led to that interpretation, you described a planned Toyota hybrid vehicle that would provide motive power by using both an electric motor and a gasoline engine. This vehicle would be turned on by the driver inserting the key and depressing a "Power" button. "Turning on" this vehicle would mean that the vehicle was activated to be propelled by the electric motor, not that the engine was actuated. After such activation of the vehicle, the engine would automatically start when the ECU determined that the vehicle needs extra power. Similarly, the engine would automatically stop when the ECU determined that the vehicle does not need the engine to provide additional power. You stated in the December 2002 letter that Toyota believed that the identification requirements for engine start and engine start controls would not apply to this vehicle's "Power" button, because the engine is neither started nor stopped by this button. You also stated that Toyota planned to use the word "Power" along with the ISO power symbol to label the button. In our January 2003 interpretation, we agreed that since the button at issue on Toyota's hybrid vehicle would neither start nor stop the engine, it was not covered by Standard No. 101's requirements for engine start and engine stop controls. We stated that since the standard does not otherwise specify requirements for this control, its identification was at the option of the vehicle manufacturer. Toyota was therefore free to identify it by means of the word "power" and the ISO power symbol. While there appear to be differences between the Toyota vehicle discussed in our January 2003 interpretation and the current one (e.g., the earlier vehicle apparently did not have an electronic keyless system), we assume that the vehicle characteristics that led us to conclude that the button at issue was not a control that started or stopped the engine have not changed. Therefore, the identification of this control is at the option of the manufacturer, and either of the suggested two options described in Toyotas letter to us may be used. I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely yours, Stephen P. Wood Acting Chief Counsel ref:101 d.7/24/09 |
2009 |
ID: nht88-2.34OpenTYPE: INTERPRETATION-NHTSA DATE: 05/27/88 FROM: TEVES, ALFRED -- TEVES TECHNICAL SERVICE TO: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL TITLE: BRAKE FLUID RESERVOIR DESIGN ACCORDING TO FMVSS 105 REQUEST FOR INTERPRETATION ATTACHMT: OCTOBER 9, 1981 LETTER FROM BERNDT TO KAWANO, OCTOBER 3, 1988 LETTER FROM JONES TO BURKARD, EBNER, AND TEVES, FEBRUARY 3, 1981 LETTER FROM KAWANO TO BERNDT, JULY 10, 1974 LETTER FROM DYSON TO NAKAJIMA, AND MAY 24, 1988 LETTER FROM TEVES TO GREG ORY TEXT: during his visit at NHTSA on May 17th, 1988 Mr. Ebner presented our new brake system to your experts. We request an interpretation of S 5.4.2 (reservoir capacity) and S 5.3.1/b (Fluid level indicator) of FMVSS 105, with respect to the proposed brake fluid reservoir shown in the attachment. Essential is the existence of an ancillary brake unit in this new brake system. This ancillary brake unit serves the brake circuits 1 and 2 directly. Compared with a conventional reservoir the proposed brake fluid reservoir's distinctive feature is the exit for the ancillary unit. This ancillary unit serves the brake circuits 1 and 2. When the brake pedal is released, the used brake fluid will flow back to the reservoir. This unit does not cause any additional fluid volume. Teves interprets standard 105 S 5.4.2 and S 5.3.1/b) as follows: 1. The total minimum capacity of a reservoir shall be equivalent to the fluid displacement resulting when all the wheel cylinder or caliper pistons serviced by the reservoir move from a new lining, fully retracted position to a fully worn, fully applied position. 2. Reservoir systems utilizing a portion of the reservoir for a common supply to two or more subsystems, individual partial compartments shall each have a minimum volume of fluid equal to at least the volume displaced by the master cylinder piston servi cing the subsystem, during a full stroke of the piston. 3. The total amount of the fluid shall be solely available for the brakes. 4. The ancillary unit shall not use brake fluid for other purposes than for the brake circuits. 5. A drop in the level of brake fluid in any master cylinder reservoir compartment to less then the recommended safe level specified by the manufacturer ot to one-fourth of the fluid capacity of that reservoir compartment, which ever is greater. The ancillary unit does not diminish the built in safety features of the reservoir. In case of a circuit failure, volume 1 resp. volume 2 remains still available for the brakes and the fluid level indicator lamp gives a warning to the driver. In case of a fluid leakage in the ancillary unit, the unit is switched off. The fluid level indicator lamp and additional a separate warning lamp gives a warning to the driver. The fluid volumes 1 and 2 remain in the reservoir and are fully usable fo r applying the brakes with the master cylinder. Accordingly, we believe that the proposed brake fluid reservoir described in this letter and presented to your experts fulfils the requirements S 5.4.2 and S 5.3.1 (b) of FMVSS 105. We ask that you confirm our interpretation at your earliest convenience. FMVSS 105, S 5.4.2: V = V[1] + V[2] + V[3] + V[4] V: GREATER OR EQUIVALENT TO FLUID DISPLACEMENT RESULTING WHEN ALL W/C MOVE FROM A NEW LINING POSITION TO A FULLY WORN LINING POSITION. MAX V[4] FLI V[3] V[1] V[2] BRAKE BRAKE ANCILLARY UNIT CIRCUIT 1 CIRCUIT 2 SERVICING BRAKE CIRCUIT 1+2 FMVSS 105, S 5.3.lb V[1] + V[3] >/- 0.25 (V[1] + V[3] + V[4]) V[2] + V[3] >/- 0.25 (V[2] + V[3] + V[4]) V[1] VOL. DISPLACEMENT EQUIVALENT TO A V[2] >/- FULL STROKE OF THE RELATED M/C-PISTON. TEVES MASTER CYLINDER RESERVOIR DESIGN ACCORDING TO FMVSS 105 3-34513-07 |
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ID: 571.209 -- Inflatable Seat Belt Assembly -- Autoliv -- 16-003634 -- 05.22.2017OpenMr. David Prentkowski Dear Mr. Prentkowski: This responds to your letter concerning the application of Federal Motor Vehicle Safety Standard (FMVSS) No. 209, Seat Belt Assemblies, to an inflatable seat belt assembly your company is developing. You ask which strength test applies to a structural sew pattern that connects the assemblys conventional webbing to its inflatable portion. Specifically, you ask us to confirm your tentative conclusion that the sew pattern is subject to the assembly performance requirements contained in S4.4(b)(2). As explained below, S4.4(b)(2) applies to the sew pattern, but it is not the only applicable strength requirement. The sew pattern, along with the rest of the restraint, must also meet the webbing breaking strength requirement in S4.2(b). What follows is our analysis of your question based on the facts you provided. Description of Your Product From the description in your letter and a follow-up phone conversation with Daniel Koblenz of my staff on January 19, 2017, we understand your product to be a Type 2 seat belt assembly with a continuous pelvic and upper torso restraint. The restraint is constructed from a segment of conventional webbing that is connected by a sew pattern to an inflatable portion. The unsewn end of the restraints conventional webbing is connected to a retractor mechanism that can be pillar-mounted or parcel shelf-mounted, and the unsewn end of the restraints inflatable portion is connected to an anchor that includes a gas generator that fills the inflatable portion in certain crash modes. While your product is in use, the sew pattern is typically located behind the occupants shoulder between the occupant and the retractor mechanism. Requirements FMVSS No. 209 contains two breaking strength requirements that Type 2 seat belt assemblies must meet: one for the entire seat belt assembly and one specifically for the webbing. As to seat belt assemblies, S4.4(b) states, in relevant part: Type 2 seat belt assembly. Except as provided in S4.5, the components of a Type 2 seat belt assembly including webbing, straps, buckles, adjustment and attachment hardware, and retractors shall comply with the following requirements when tested by the procedure specified in S5.3(b): (2) The structural components in the upper torso restraint shall withstand a force of not less than 6,672 N. As to webbing, S4.2(b) states, in relevant part: The webbing in a seat belt assembly shall have not less than the following breaking strength when tested by the procedures specified in S5.1(b): . . .Type 2 seat belt assembly. . . 17,793 N for webbing in upper torso restraint. Please note that, under FMVSS No, 209 S4.1(i), all straps that are used in a seat belt assembly to sustain restraint forces must meet the webbing requirements of S4.2. FMVSS No. 209 S3 defines a strap as a narrow nonwoven material used in a seat belt assembly in place of webbing. These two breaking strength requirements are both applicable, which means that an assemblys upper torso webbing (or a strap subject to webbing requirements) is subject to both S4.4(b)(2) and S4.2(b). However, because the breaking strength requirement for the upper torso webbing (17,793 N) is greater than the breaking strength requirement for the upper torso assembly components (6,672 N), the question of whether webbing (or a strap subject to webbing requirements) complies with FMVSS No. 209s breaking strength requirements effectively turns on whether it meets the webbing-specific requirements of S4.2(b). Discussion
a. The sew pattern is integrated into the upper torso restraint and cannot be tested in isolation. Before discussing which breaking strength requirement applies to the sew pattern, it is necessary to clarify what the sew pattern is. In your letter, you mistakenly discuss the sew pattern as though it is a discrete component with its own compliance requirements that are severable from the requirements that apply to the two restraint segments that the sew pattern connects. While past interpretations have considered hardware components as discrete components, the sew pattern is inherently different than a hardware component. The sew pattern is not a discrete component; it is a manufacturing material that is integrated into and made a part of the upper torso restraint. For this reason, we have determined that the entire upper torso restraintincluding the sew pattern, conventional webbing and inflatable segmentsshould be treated as a single integrated component for the purpose of determining whether it is subject to the breaking strength tests in S4.4 and S4.2. b. The upper torso restraint is a structural component that is subject to S4.4(b)(2). In your letter, you state (and we agree) that the sew patternand by extension, the upper torso restraint that it holds togetheris structural. You believe that, because the upper torso restraint is a structural component, it must meet the assembly performance requirement in S4.4(b)(2). We agree that S4.4(b)(2) applies. We do, however, wish to note that this letter supersedes a 1973 letter to Takata Kojyo Co., which determined that S4.4(b)(3) was the relevant requirement.[1] c. The upper torso restraint is also a strap that is subject to S4.2(b). We have determined that the upper torso restraint falls within the definition of strap. Accordingly, the upper torso restraint, including its subcomponents, must meet the breaking strength requirements of S4.2(b). Our conclusion that the entire upper torso restraint is a strap is rooted in both the definition of strap and our previous interpretations of that definition. As noted earlier, FMVSS No. 209 defines a strap as a narrow nonwoven material used in a seat belt assembly in place of webbing.[2] We interpret the term nonwoven material here to include any restraint material that is not purely constructed out of webbing (i.e., woven) material. This means that a restraint constructed from both woven and nonwoven materials and that is used in place of webbing is considered a strap. Accordingly, we determined in a 2010 letter to Mr. Kazuo Higuchi that the inflatable portion of an inflatable seat belt assembly that was constructed from an inflatable bladder encased in woven fabric fell within the definition of strap.[3] Consistent with our determination in the Higuchi letter, we have concluded here that the upper torso restraint of your seat belt assembly fits within the definition of strap. Like the inflatable segment in the Higuchi letter, the upper torso restraint in your seat belt assembly is constructed from a combination of woven material (the conventional webbing) and nonwoven material (the inflatable portion and the sew pattern), and is used in a seat belt assembly in place of webbing. Therefore, the entire upper torso restraintincluding the conventional webbing, inflatable portion, and sew patternis a strap. Because the upper torso restraint is a strap, it is subject to S4.1(i), which states that [a] strap used in a seat belt assembly to sustain restraint forces shall comply with the requirements for webbing in S4.2. As noted above, S4.2(b) requires that webbing in the upper torso portion of a seat belt assembly withstand a force of at least 17,793 N. Therefore, to comply with FMVSS No. 209, your seat belt assembly must be able to withstand a force of at least 17,793 N when tested in the manner prescribed by S4.2. Please note that, as stated in the Higuchi letter, NHTSA will not disassemble the restraint when testing it.
Other Issues Please be aware that, as a strap the upper torso restraint must meet all of the S4.2 requirements for webbing, not just those for strength and abrasion. We felt it necessary to clarify this point given your statement: [W]e understand that both the webbing and inflatable seat belt portions of the system would need to meet the strength and abrasion resistance requirements as specified in FMVSS 209. FMVSS No. 209 S4.1(i) requires that straps comply with the requirements for webbing in S4.2. There are a number of requirements in S4.2 in addition to strength and abrasion resistance.
If you have any questions, please contact Daniel Koblenz of my staff at (202) 366-2992.
Sincerely,
Stephen P. Wood Acting Chief Counsel NCC0200:Dkoblenz:3/2/17:revised 4/20/17:62992(cyb 5/3/17) Reprinted with edits 5/3/17 and 5/22/17 S:\INTERP\209\571.209 -- Inflatable Seat Belt Assembly -- Autoliv -- 16-003634 -- 05.22.2017.docx [1] The April 9, 1973 letter to Takata Kojyo Co. is NHTSAs sole prior interpretation directly discussing the breaking strength requirements for restraint sew patterns (available at https://isearch.nhtsa.gov/gm/73/nht73-6.15.html). Takata Kojyo had asked about a structural sew pattern in an upper torso restraint that connected two conventional webbing segments of different widths. In NHTSAs response, the agency concluded that the entire restraint, including both webbing segments and the sew pattern, should be considered a single component, but also that the restraint was a common pelvic and upper torso restraint which must meet [the requirements of S4.4(b)(3)] regardless of whether sewing or other means is used to make the belt assembly. We believe that NHTSAs analysis in the Takata Kojyo letter incorrectly interpreted the word common in S4.4(b)(3) to refer to components that are physically part of both the upper torso and pelvic restraints, such as a continuous loop restraint. We believe that common in S4.4(b)(3) instead refers to the load that a given component experiences in a crash scenario. If a component experiences only upper torso (or pelvic) crash loads, it is considered to be part of the upper torso (or pelvic) restraint, respectively, for purposes of S4.4(b). Conversely, if the component experiences both upper torso and pelvic crash loads, it is considered to be common. Because the upper torso portion of a restraint only experiences upper torso loads, we do not consider it to be a common component under S4.4(b)(3) even if it is part of a continuous loop restraint. [2] S3. Note also that webbing is defined in S3 as a narrow fabric woven with continuous filling yarns and finished selvages. [3] See letter to Kazuo Higuchi (May 7, 2010), available at https://isearch.nhtsa.gov/files/08_004614%20209.htm. See also TK Holdings, Inc. Interpretation Request (July 8, 2009), available at https://www.regulations.gov/document?D=NHTSA-2010-0067-0002 (explaining that the inflatable portion of the subject inflatable seat belt assembly is constructed of some woven material, some coated fabric and some knit material). |
2017 |
ID: 86-6.7OpenTYPE: INTERPRETATION-NHTSA DATE: 12/08/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Roger Hagie -- Government Relations Manager, Kawasacki Motors Corp. USA TITLE: FMVSS INTERPRETATION ATTACHMT: 10/20/83 letter from F. Berndt to BMW of North America, Inc. TEXT:
Mr. Roger Hagie Government Relations Manager Kawasaki Motors Corp. USA P.O. Box 25252 Santa Ana, CA 92799-5252
Dear Mr. Hagie:
This is in response to your letter of April 26, 1985, asking for an interpretation of Motor Vehicle Safety Standard No. 108. I regret the delay in responding to your letter.
Specifically, you have called our attention to a proposed motorcycle accessory, consisting in part of a "nylon mesh which is stretched in front of the headlamp lens" and intended to protect the "headlamp from damage by stones or other road debris." You have asked whether this accessory would be permissible under paragraph 54.1.3 of Standard No. 108 which in effect allows optional equipment that does not impair the effectiveness of the lighting equipment that the standard does require. You have advised us that "the nylon mesh does cause some reduction in the photometric output of the lamp" but that testing of the specific headlamp that the mask is designed to fit "has determined that with the mesh in place, light output is still more than 1208 of the minimums specified by SAE J584.. . " You have quoted a 1983 letter from the former Chief Counsel giving two examples of impairment, one a plastic cover causing a dislocation of beam pattern, or a cover that is subject to accelerated hazing or cracking, but you have stated that it is unclear whether any degree of impairment is unacceptable, or only an impairment that causes light output to fall beneath the minimum photometrics prescribed by Standard No. 108.
Because Federal motor vehicle safety standards are minimum performance standards, the fact that the mesh causes some reduction in photometric output does not mean that it "impairs" the effectiveness of the headlamp unless it reduces light output below the minimum levels imposed by the standard. You have stated that with the mesh installed light output is still more than 120% of the minimum required. If Kawasaki is satisfied that this output will be met with any original equipment headlamp, then it may certify compliance with Standard No. 108 of any motorcycle on which the mesh is an original equipment accessory.
The question of the permissibility of the mesh as an after market accessory is not easily answered. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibits actions by manufacturers, distributors, dealers, and motor vehicle repair businesses that "render operative in whole or in part" equipment which has been installed to comply with a Federal vehicle safety requirement. We would view dealer-installation of the mesh as rendering a headlamp partially inoperative if it resulted in a diminution of headlamp light output below the standard's minimum level. The prohibition does not apply to owner modifications. Whether an owner modification is legal is answerable under the laws of the States where a vehicle is registered and operated. A further observation is that although an original equipment headlamp-mesh combination may meet or exceed the minimum photometrics, it is possible that a replacement headlamp would fall beneath the threshold of photometric compliance with the mesh in place. We suggest that you consider these safety issues before proceeding to offer the accessory.
Sincerely,
Erika Z. Jones Chief Counsel
April 26, 1985
Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590
RE: Request for Interpretation, FMVSS 108
Dear Sir:
Kawasaki Motors Corp., U.S.A. requests an interpretation of the acceptability of a proposed motorcycle accessory, a device to cover and protect the leading surface of a motorcycle fairing and headlamp from damage by stones or other road debris.
More specifically, the product consists of a vinyl or leather "mask" which fits snugly to the front of the fairing and incorporates a nylon mesh which is stretched in front of the headlamp lens. Our question relates to the issue of whether this mesh covering over the headlamp lens is permissible according to FMVSS 108. Your attention is directed to the letter of October 20, 1983 from then Chief Counsel Frank Berndt to Karl-Heinz Ziwica of BMW North America (file ref. NOA-30), copy attached.
In this letter, Mr. Berndt indicates that NHTSA has "concluded that headlamp covers for motorcycles are not per se prohibited by Standard 108." Mr. Berndt continues to indicate " if they impair the effectiveness of the headlamp." He goes on to describe two examples of impaired effectiveness that the agency would presumably consider contrary to the intent of FMVSS 108: an extreme installation angle of the cover or deterioration of the cover itself.
What remains unclear from Mr. Berndt's letter is whether any degree of impairment of the light output is to be considered unacceptable, or whether the unacceptable level might be reached if the impairment caused light output to drop below the photometric standards applicable to the lamp.
In the case of the mask under consideration by Kawasaki, the nylon mesh does cause some reduction in the photometric output of the lamp. However, testing of the specific headlamp that this mask is designed to fit has determined that with the mesh in place, light output is still more than 120% of the minimums specified by SAEJ584, the applicable standard. Thus, while some "impairment" is acknowledged, performance with the mask in place still exceeds the requirements of FMVSS 108.
In conclusion, Kawasaki seeks NHTSA's opinion whether a mesh headlamp cover which is not subject to hazing, cracking or discoloration, and which does not cause light output to drop below the minimum levels specified by FMVSS 108 would be considered in Compliance with FMVSS 108 if offered for sale on a specific Kawasaki motorcycle.
Thank you for your attention to this matter.
Sincerely,
KAWASAKI MOTORS CORP., U.S.A.
Roger Hagie Government Relations Manager See 10/20/83 letter from F. Berndt to BMW of North America, Inc. |
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ID: 10456Open Ms. Darlene Skelton Dear Ms. Skelton: This responds to your letter to Mr. Barry Felrice, Associate Administrator for Safety Performance Standards of this agency, in which you asked the applicability of our Federal motor vehicle safety standards (FMVSS) to three specific scenarios. I apologize for the delay in responding. By way of background information, under the provisions of Chapter 301 of Title 49 U. S. Code, the National Highway Traffic Safety Administration (NHTSA) has authority to issue FMVSSs applicable to new motor vehicles and new items of motor vehicle equipment. All new motor vehicles and new items of motor vehicle equipment must comply with all applicable FMVSSs in effect on the date of manufacture, and manufacturers must certify such compliance by affixing to each vehicle a manufacturer's certification label. Among other requirements, the certification label must contain the gross vehicle weight rating (GVWR) of each vehicle and the gross axle weight rating (GAWR) of each axle on the vehicle, identified in order from front to rear. a. Your first question referred to a situation in which the GVWR exceeded the tire load ratings. Specifically, you alluded to the case of a fire truck with four rear mounted tires, each rated at 7,000 pounds (lb), that were installed on a 31,000 lb. axle. You stated that the final stage manufacturer received a letter from the tire manufacturer raising the tire inflation pressures from 100 to 110 or 115 pounds per square inch and limiting the driving to not more than 7 miles at a speed not to exceed 55 miles per hour. You asked whether such practices violated the FMVSSs. Paragraph S5.1.2 of FMVSS No. 120, Tire selection and rims for motor vehicles other than passenger cars, provides in pertinent part:
[T]he sum of the maximum load ratings of the tires fitted to an axle shall be not less than the gross axle weight rating (GAWR) of the axle system as specified on the vehicle's certification label required by 49 CFR part 567. In other words, the load ratings of the tires on motor vehicles other than passenger cars must be at least equal to the weight ratings of the axles on which the tires are installed. The standard makes no provision for changing the tire inflation pressures or driving at restricted speeds or limiting the distances the vehicle may travel to compensate for discrepancies in the load and weight ratings. The facts you provided us, however, are not sufficient on which to base an opinion as to whether there has been a noncompliance in that instance. We would have to know all the facts and circumstances relevant to the tire manufacturer's alleged actions, including input from the manufacturer itself, before we could arrive at a conclusion in that regard. b. Your second question referred to vehicles in which axles had been rerated. You cited a situation in which a manufacturer increased the GAWR of fire trucks because fire trucks do not cycle as much as tractor trailer trucks. Thus, the manufacturer increased the GAWR of fire trucks from 22,000 to 24 000 lbs. NHTSA defines the GAWR as: [T]he value specified by the vehicle manufacturer as the load-carrying capacity of a single axle system, as measured at the tire-ground interface (emphasis added). A manufacturer's assigning different GAWRs to axles on different vehicles is not prohibited by our FMVSSs. In fact, manufacturers routinely assign different GAWRs and GVWRs to different vehicles based on the various equipment options and add-ons, particularly with respect to emergency vehicles. In any case, NHTSA expects that the GAWR(s) stated on the vehicle's certification label correctly reflects the manufacturer's certification that the vehicle complies with all FMVSSs applicable to that vehicle. c. Your final question asked whether it was a violation of the FMVSS for manufacturers to take the air supply for their vehicle horns off the air supply for the vehicle's brakes. The answer is, in general, no. FMVSS No. 121, Air brake systems, specifies performance and equipment requirements for braking systems on motor vehicles other than passenger cars that are equipped with air brake systems. The standard does not prohibit the use of air pressure from the brake air supply for the horn, but doing so could affect the vehicle's compliance with the standard. If the horn operating off the brake air supply is installed as original equipment on a new vehicle, the manufacturer is required to certify that the vehicle complies with all applicable FMVSSs, including FMVSS No. 121. If the horn is added to a previously certified new vehicle, the person so modifying the vehicle would be an alterer who would be required to certify that, as altered, the vehicle continues to comply with all of the FMVSSs affected by the alteration. If the horn were installed on a used vehicle by a vehicle repair business, that business would not be required to attach a label or recertify the vehicle. It would, however, have to make sure that it did not knowingly make inoperative any part of a device or element of design installed on or in the vehicle in compliance with an applicable FMVSS. In addition, hoses connected to air horns could be subject to Safety Standard No. 106, Brake hoses. They are subject to the standard if they transmit or contain the brake air pressure used to apply force to a vehicle's brakes, i.e., if a failure of the hose would result in a loss of air pressure in the brake system. If this would be the case, the hoses are "brake hoses" and must comply with Standard No. 106. If a check valve or other device is used to prevent loss of pressure, then the hose would not contain or transmit the air pressure and would not be required to comply with the brake hose standard. I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely,
Philip R. Recht Chief Counsel ref:106#120#121#567 d:4/10/95
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1995 |
ID: nht95-2.25OpenTYPE: INTERPRETATION-NHTSA DATE: April 10, 1995 FROM: Philip R. Recht -- Chief Counsel, NHTSA TO: Darlene Skelton -- President, National Institute of Emergency Vehicle Safety, Inc. TITLE: NONE ATTACHMT: ATTACHED TO 6/16/94 LETTER FROM DARLENE E. SKELTON TO BARRY FELRICE TEXT: Dear Ms. Skelton: This responds to your letter to Mr. Barry Felrice, Associate Administrator for Safety Performance Standards of this agency, in which you asked the applicability of our Federal motor vehicle safety standards (FMVSS) to three specific scenarios. I apologi ze for the delay in responding. By way of background information, under the provisions of Chapter 301 of Title 49 U.S. Code, the National Highway Traffic Safety Administration (NHTSA) has authority to issue FMVSSs applicable to new motor vehicles and new items of motor vehicle equipmen t. All new motor vehicles and new items of motor vehicle equipment must comply with all applicable FMVSSs in effect on the date of manufacture, and manufacturers must certify such compliance by affixing to each vehicle a manufacturer's certification lab el. Among other requirements, the certification label must contain the gross vehicle weight rating (GVWR) of each vehicle and the gross axle weight rating (GAWR) of each axle on the vehicle, identified in order from front to rear. a. Your first question referred to a situation in which the GVWR exceeded the tire load ratings. Specifically, you alluded to the-case of a fire truck with four rear mounted tires, each rated at 7,000 pounds (lb), that were installed on a 31,000 lb. axle. You stated that the final stage manufacturer received a letter from the tire manufacturer raising the tire inflation pressures from 100 to 110 or 115 pounds per square inch and limiting the driving to not more than 7 miles at a speed not to excee d 55 miles per hour. You asked whether such practices violated the FMVSSs. Paragraph S5.1.2 of FMVSS No. 120, Tire selection and rims for motor vehicles other than passenger cars, provides in pertinent part: [The] sum of the maximum load ratings of the tires fitted to an axle shall be not less than the gross axle weight rating (GAWR) of the axle system as specified on the vehicle's certification label required by 49 CFR part 567. In other words, the load ratings of the tires on motor vehicles other than passenger cars must be at least equal to the weight ratings of the axles on which the tires are installed. The standard makes no provision for changing the tire inflation pressur es or driving at restricted speeds or limiting the distances the vehicle may travel to compensate for discrepancies in the load and weight ratings. The facts you provided us, however, are not sufficient on which to base an opinion as to whether there has been a noncompliance in that instance. We would have to know all the facts and circumstances relevant to the tire manufacturer's alleged actions, including input from the manufacturer itself, before we could arrive at a conclusion in that regard. b. Your second question referred to vehicles in which axles had been rerated. You cited a situation in which a manufacturer increased the GAWR of fire trucks because fire trucks do not cycle as much as tractor trailer trucks. Thus, the manufacturer increased the GAWR of fire trucks from 22,000 to 24 000 lbs. NHTSA defines the GAWR as: [The] value specified by the vehicle manufacturer as the load-carrying capacity of a single axle system, as measured at the tire-ground interface (emphasis added). A manufacturer's assigning different GAWRs to axles on different vehicles is not prohibited by our FMVSSs. In fact, manufacturers routinely assign different GAWRs and GVWRs to different vehicles based on the various equipment options and add-ons, partic ularly with respect to emergency vehicles. In any case, NHTSA expects that the GAWR(s) stated on the vehicle's certification label correctly reflects the manufacturer's certification that the vehicle complies with all FMVSSs applicable to that vehicle. c. Your final question asked whether it was a violation of the FMVSS for manufacturers to take the air supply for their vehicle horns off the air supply for the vehicle's brakes. The answer is, in general, no. FMVSS No. 121, Air brake systems, specifies performance and equipment requirements for braking systems on motor vehicles other than passenger cars that are equipped with air brake systems. The standard does not prohibit the use of air pressure from the brake air supply for the horn, but doing so could affect the vehicle's compliance with the standard. If the horn operating off the brake air supply is installed as original equipment on a new vehicle, the manufacturer is required to certify that the vehicle complies with all applicable FMVSSs, including FMVSS No. 121. If the horn is added to a previous ly certified new vehicle, the person so modifying the vehicle would be an alterer who would be required to certify that, as altered, the vehicle continues to comply with all of the FMVSSs affected by the alteration. If the horn were installed on a used vehicle by a vehicle repair business, that business would not be required to attach a label or recertify the vehicle. It would, however, have to make sure that it did not knowingly make inoperative any part of a device or element of design installed on or in the vehicle in compliance with an applicable FMVSS. In addition, hoses connected to air horns could be subject to Safety Standard No. 106, Brake hoses. They are subject to the standard if they transmit or contain the brake air pressure used to apply force to a vehicle's brakes, i.e., if a failure of the h ose would result in a loss of air pressure in the brake system. If this would be the case, the hoses are "brake hoses" and must comply with Standard No. 106. If a check valve or other device is used to prevent loss of pressure, then the hose would not contain or transmit the air pressure and would not be required to comply with the brake hose standard. o I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. |
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ID: nht94-1.65OpenTYPE: INTERPRETATION-NHTSA DATE: February 22, 1994 FROM: Robin L. Fennimore, Spectrum Engineering Group TO: Office of Chief Council, NHTSA TITLE: School Bus Safety Standards Our File: 94057 ATTACHMT: Attached to letter dated 6/28/94 from John Womack to Spectrum Engineering Group (A42; STD 206; FMVSS 217) TEXT: We are currently reconstructing a motor vehicle accident involving a 16-passenger, mini school bus. As a result of this investigation, several questions have risen concerning design modifications performed on the right front entrance door of the vehicle ; specifically, whether they are controlled by and in compliance with any and all applicable FMVSS. We would appreciate your assistance in resolving these concerns. A 1988 Ford Econoline Cargo Van was purchased as an incomplete vehicle and later fitted with a school bus body by Midbus of Lima, Ohio. A copy of the van's I.D. plate and a Mid Bus brochure is enclosed for your reference. This vehicle was outfitted wit h a remote door opening/closing apparatus and latching mechanism, although maintained the original Ford van door. The O.E.M Ford latch/hinge mechanism was disabled by removing the striker plate. On January 13, 1989, the operator of the bus lost control of the vehicle, striking both a tree and a utility pole. The collision allegedly caused the operator to be ejected from the vehicle through the right front passenger door. Given this information, would you please respond to the following questions: 1) Would this vehicle be classified as a "multi-purpose passenger vehicle", a "bus" or a "school bus"? 5 2) Does FMVSS 206 and/or FMVSS 217 apply to the right front entrance door of this vehicle? 3) Which FMVSS would apply to the right front entrance door, (particularly its loading requirements)? Can you provide copies of the versions of these documents effective in 1988? 4) Can you please provide copies of the 1988 FMVSS 206 and 217? If you have any questions or concerns, please do not hesitate to contact me at (203) 272-1111. If there are any fees associated with this request, we will be happy to reimburse your office. |
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ID: 1983-1.40OpenTYPE: INTERPRETATION-NHTSA DATE: 04/13/83 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Andial TITLE: FMVSS INTERPRETATION TEXT:
APR 13 1983 NOA-30
Mr. Arnold H. Wagner Andial 3207 S. Shannon Street Santa Ana, California 92704
Dear Mr. Wagner:
This responds to your February 2, 1983, letter asking whether a child seat that you plan to produce must comply with Standard No. 213, Child Restraint Systems. From the description of your child seat, it appears that the answer is yes.
Standard No. 213 states in section 4 that a child restraint system is any device used to restrain, seat, or position children who weigh not more than 50 pounds. It is not necessary that a seat be equipped with its own restraint devices to fall within the ambit of the standard. If a device is designed to seat or position a child within the designated weight range, that device must comply with the requirements.
The instructions that accompanied your letter showed how the seat should be installed for children from three to six years of age and subsequently for children in the age range of six to ten. Certainly children in the three to six age bracket would fall within the weight range (50 pounds or less) designated in the standard. Since this is the case, it appears that your child seat is designed to seat or position children of the size specified in the standard and would therefore be required to comply with the requirements of the standard.
Sincerely, Frank Berndt Chief Counsel February 2, 1983 Mr. Frank Berndt Chief Council US Department of Transportation N.H.T.S.A. 400 Seventh Street, S.W. Washington, D.C. 20590 Re: Approval of child restraint, by means of 3 point type belt system
Dear Mr. Berndt:
Enclosed please find copies of a letter from Arvin/Calspan to us, and a copy of the installation instructions of said restraint. We understand that the application of FMVSS No. 213 restraint designs does not cover our particular system, and a formal decision is needed in order to get it safety approved.
We would like to ask you to consider our request at your earliest convenience.
Sincerely
Arnold H. Wagner Sec/Tres.
AHW/mgm
January 24, 1983
Mr. Arnold Wagner Andial 3207 S. Shannon Street Santa Ana, CA 92704
Dear Mr. Wagner:
We received your child restraint last week and have examined the restraint and the installation instructions. The design of this restraint (i.e., use of a three-point belt system) is not addressed in the Department of Transportation's Federal Motor Vehicle Safety Standard No. 213 (FMVSS 213).
We have been informed by the Department of Transportation that a formal decision is required with regard to the applicability of FMVSS No. 213 to restraint designs which are not specifically addressed in this safety standard. A request for a formal decision should be sent to:
Mr. Frank Berndt Chief Council U. S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590
I would suggest that you include a copy of your installation instructions.
A brochure of Calspan's child restraint testing capabilities is included with this letter. Our recommendation for a sled test program follows:
Sled Test #1 - Two restraints placed side-by-side on the sled (see Photograph #2 in brochure). One restraint will be occupied by a 3- year-old size dummy (15 kg) with the restraint installed as suggested for 9-18 kg children and the other restraint occupied by a 6-year-old size dummy (22 kg) with the restraint installed as suggested for 15-25 kg children. This test would be performed at 30 mph as required in FMVSS 213 Configuration 1.
Sled Test #2 - One restraint occupied by a 3-year-old size dummy with the restraint attached to the seat by means of a lap belt only, tested at 20 mph. This should satisfy the requirements of FMVSS No. 213, Configuration II.
Although FMVSS No. 215 only requires testing with the three-year-old size dummy, we have included a test with the larger six-year-old size dummy since your restraint is designed for use by larger children.
Calspan charges one thousand dollars ($1,000) U. S. funds for each sled test, regardless of the number of dummies used. This price includes high-speed movie films, electronic data, and photographs for each test and analysis and reporting of all relevant data. I look forward to hearing from you soon. We would like to perform these sled tests in February if this is convenient for you. Sincerely yours,
Barbara J. Kelleher Staff Associate Transportation Research/Physical Sciences kd Enc. |
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ID: 07-002450asOpenMs. Lynn Schultz SB Solutions LLC 1907 Brooks Ct. West Bend, WI 53090-1789 Dear Ms. Schultz: This responds to your letter regarding the disconnection of the front lights on trucks, when using an auxiliary attachment, under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically, you asked whether it would be permissible for a motor vehicle repair business to modify a vehicle with a special plow that includes a set of auxiliary front vehicle lamps. When attached, this plow would disconnect the high and low beam headlights, the turn signals, and the front marker lamps on the truck. As discussed below, it would be acceptable to disconnect these lamps on trucks if the auxiliary lamps on the snow plow met all of the requirements of FMVSS No. 108 for the disconnected lamps. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. Chapter 301). NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to self-certify that their products conform to all applicable safety standards that are in effect on the date of manufacture. NHTSA selects a sampling of new vehicles and equipment each year to determine their compliance with applicable FMVSSs. If our testing or examination reveals an apparent noncompliance, we may require the manufacturer to remedy the noncompliance, and may initiate an enforcement proceeding if necessary to ensure that the manufacturer takes appropriate action. A relevant provision of Federal law with respect to equipping a vehicle with a snow plow is 49 U.S.C. 30122(b), which specifies that: A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard prescribed under this chapter unless the manufacturer, distributor, dealer, or repair business reasonably believes the vehicle or equipment will not be used (except for testing or a similar purpose during maintenance or repair) when the device or element is inoperative. Ordinarily, if a motor vehicle repair business disconnected the front lights on trucks, it would be a violation of 30122. However, assuming the plow contains a set of auxiliary lamps that meets all of the requirements of FMVSS No. 108 for the lamps being replaced, it would be permissible to disconnect the lamps in this instance. As you have not fully described the characteristics of the auxiliary[1] lamps, or the precise nature of the trucks you plan to install this snow plow on, we cannot say whether your specific design would comply with FMVSS No. 108. We note, however, that you state that the auxiliary lights would have the Hi and Lo beam headlamps, turn [signal] lamps, and marker lamps. Standard No. 108 requires headlamps, turn signals, and parking lamps on the front of the vehicle. If the vehicle is over 80 inches wide, clearance and identification lamps are also required on the front of the vehicle. All of these lamps must conform, when installed, to the performance and location requirements set forth in FMVSS No. 108. Finally, we are enclosing a 1999 letter of interpretation issued by NHTSA to a different manufacturer of auxiliary lamps for use with vehicles on snow plows.[2] This letter explains in some detail the responsibilities and potential liabilities of manufacturers and installers with regard to the installation of these lighting devices, and it is our hope that it assists you with any further questions you may have. If you have any further questions, please contact Ari Scott of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel Enclosure ref:108 d.4/29/08 [1] While you have referred to these lamps as auxiliary, generally NHTSA uses that term to describe supplemental lamps not required by FMVSS No. 108. In the situation you describe, these auxiliary lamps would be serving as lamps required by the standard. [2] January 22, 1999 letter to Mr. Fred Kelly, available at http://isearch.nhtsa.gov. |
2008 |
ID: nht93-6.11OpenDATE: August 13, 1993 EST FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Kenneth E. Ross TITLE: None ATTACHMT: Attached to letter dated 6/14/93 from Kenneth E. Ross to Consumer Coordinator, NHTSA (OCC 8830) TEXT: This responds to your letter requesting information about a product that attaches to an automobile's back window. In a telephone conversation with Marvin Shaw of my staff, you stated that your product is a two to three inch high LED sign that extends along most of the rear window. The sign displays any message that the driver chooses. While we do not have information about State or local laws, I am pleased to have this opportunity to explain the applicability of Federal law on your product. By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the National Traffic and Motor Vehicle Safety Act ("Safety Act") establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable Federal motor vehicle safety standards (FMVSSs). In response to your question, NHTSA currently has no FMVSSs that directly apply to the product you wish to manufacture. I note, however, that there are other Federal requirements that indirectly affect you and your product. Under the Safety Act, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in SS151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Automotive accessory equipment that a dealer adds before sale of a vehicle must not create a noncompliance with the FMVSSs to which the vehicle manufacturer has certified compliance. For instance, your LED sign should be mounted so that it does not block the field of view required by FMVSS No. 111, Rearview Mirrors. Similarly, for the vehicle to remain in compliance, your system must not impair the effectiveness of the lighting equipment required by FMVSS No. 108, Lamps, Reflective Devices, and Associated Equipment. In particular, the placement of your sign might impair the effectiveness of the center highmounted stop lamp (CHMSL) if it can be operated simultaneously with the CHMSL or at a time when the turn signals are flashing. In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to S108(a)(2)(A) of the Safety Act, which states: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ...." It is conceivable that your product, when placed on a vehicle's rear window, could "render inoperative" the vehicle's ability to comply with FMVSS No. 108 and FMVSS No. 111. Persons in the aforementioned categories that install your product must ensure that such installation does not render inoperative the safety protection provided by the applicable standards. Specifically, your product should be mounted so that it does not interfere with the CHMSL or turn signal lamps nor block the field-of-view required by FMVSS No. 111. The "render inoperative" prohibition of S108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your product were placed on a rear window by the vehicle owner, then the render inoperative provision would not apply. Nevertheless, in the interest of safety, you should ensure that your product does not adversely affect a vehicle's rear lamps or rearward visibility. We are unable to advise you as to whether the laws of any State address this topic. You should consult the American Association of Motor Vehicle Administrators for an opinion. Its address is 4600 Wilson Boulevard, Arlington, Va. 22203. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.
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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.