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: nht93-6.29OpenDATE: September 2, 1993 FROM: Donald W. Vierimaa -- Vice President-Engineering, Truck Trailer Manufacturers Association TO: John Womack -- Acting Chief Counsel, NHTSA COPYEE: TTMA Engineering Committee; Tank Conference Engineering Committee; The 3M Company; Reflexite TITLE: Conspicuity ATTACHMT: Attached to letter dated 2/7/94 from John Womack to Donald W. Vierimaa (A42; Std. 108) TEXT: We request three interpretations pertaining to S5.7 of FMVSS 108. Conversion from S1 to English linear dimensions May we consider the following nominal English dimensions equivalent for the purpose of compliance with S5.7 of FMVSS 108? FMVSS 108 English English Citation Item Metric (actual**) (nominal) 5.7.1.3(b) Length of 300 mm 11.8 inches 12 inches red or white +/- 150 mm +/- 5.9 inches +/- 6 inches block of (150 mm (5.9 inches (6 inches sheeting to 450 mm) to 17.7 in.) to 18 inches) 5.7.1.3(d) Width of Grade 50 mm min* 1.9 inches 2 inches DOT C2 sheeting 5.7.1.3(d) Width of Grade 75 mm min* 2.9 inches 3 inches DOT C3 sheeting 5.7.1.3(d) Width of Grade 100 mm min* 3.9 inches 4 inches DOT C4 sheeting 5.7.1.4(b) Edge of white 75 mm min. 2.9 inches 3 inches sheeting to any lamp 5.7.1.4(c) Edge of red 75 mm min. 2.9 inches 3 inches sheeting to an amber lamp 5.7.1.4.1(a) Height of 1.25 m 49.2 inches 49 inches horizontal sheeting on rear 5.7.1.4.1(b) Length of 300 mm min* 11.8 inches 12 inches sheeting in upper contours of trailer
5.7.1.4.2(a) Height of 1.25 m 49.2 inches 49 inches horizontal sheeting on side of trailer 5.7.1.4.2(b) Alternative 25 mm min* 0.98 inches 1 inch width of two strips of Grade DOT C2 sheeting and their separation 25 mm max 0.98 inches 1 inch 5.7.1.5 Sheeting 3 mm min 0.118 inches 1/8 (0.125) certification inch character height 5.7.1.5 Sheeting 300 mm max 11.8 inches 12 inches certification marking separation 5.7.2.2(b) Alternative 100 mm max 3.9 inches 4 inches reflex reflector center to center separation 5.7.2.3 Reflex 3 mm min 0.118 inches 1/8 (0.125) reflector inch certification character height * Assumed to be minimum. ** Significant decimal places for comparison. The nominal English dimensions without underlining would appear to be acceptable conversions since they exceed the minimum metric dimensions. The nominal English dimensions underlined would, however, exceed the metric maximum dimension. SAE J1322 JUN85, "Preferred Conversion Values for Dimensions in Lighting - Inch-Pound Units/S1," describes how English units may be converted to S1 (metric) units, but does not describe how to convert S1 units to English Units. Vertical Location of Rear and Side Sheeting Cargo tank trailers may have a "vertical" surface only at their "belt line" which may be as high as 90 inches (2.3 m) above the ground. Retroreflective sheeting could, however, be located much closer to the ground, but for some cargo tank trailers this may place the sheeting on non-vertical surfaces. In our comment of March 31, 1992 to Docket No. 80-9; Notice 4 we stated that "it is not clear from the proposed rulemaking as to where retroreflective material should be placed on curved surfaces of tank and some dump trailers or angled surfaces of some dump trailers." One manufacturer of retroreflective sheeting states that "the sheeting could be applied at a maximum angle of 30 degrees to the vertical." This manufacturer reports that "An angle greater than this provides less conspicuity as defined by NHTSA." May retroreflective sheeting be located significantly higher than 1.25 m above the road surface if there is no vertical surface lower than this height without installing structure just for the sheeting? Upper Contour Sheeting May the horizontal and vertical sheeting to the right and left upper contours of the trailer body required per S5.7.1.4.1(b) be of the dimensions and location shown in the enclosed figures 1 through 5? Since a number of trailer manufacturers are presently installing conspicuity treatments in accordance with S5.7 of FMVSS 108 as standard equipment or at the request of their customers, your timely response is desirable. |
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ID: 06-005429as-6OpenMr. Kiminori Hyodo Deputy General Manager, Regulation & Certification Koito Manufacturing Co., Ltd. 4-8-3, Takanawa Minato-Ku Tokyo Japan Dear Mr. Hyodo: This responds to your letter, in which you seek clarification as to the definition of the optical axis for a lower beam headlamp using light-emitting diodes (LEDs) under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically, you asked how one would determine the optical axis for a LED lower beam headlamp, where respective LEDs provide different light intensities or beam configurations. As discussed below, it is our opinion that the optical axis for a visual/optical aim headlamp is the reference axis necessary to assure proper horizontal and vertical alignment of the optical aiming equipment. It is up to the manufacturer to decide how to determine that axis and to select the location of the required marking. This interpretation would apply to any visually/optically aimed headlamp regardless of light source type. 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. FMVSS No. 108 specifies requirements for original and replacement lamps, reflective devices, and associated equipment. 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. Your letter asked what constitutes the location of the optical axis in a situation in which LEDs of varying intensity are used in a headlamp. You described a situation in which one LED from an array of LEDs serves to provide the dominant intensities toward the center of the beam pattern and determines a major characteristic of a cut-off. You asked if it would be appropriate to use that element to determine the optical axis. You also ask this question assuming a condition where respective LEDs are directed differently to constitute respective parts of the low-beam illumination. These questions caused the agency to closely examine the meaning of optical axis in order to assure proper headlamp aiming. In your letter, you cited a prior agency interpretation (December 21, 2005 letter to Mr. Takayuki Amma) regarding lower beam headlamps using several LEDs of equal light intensities, and our conclusion that the optical axis shall always correlate to the actual photometric output of the lamp. In view of your latest inquiry, we reexamined our 2005 interpretation relative to the determination of the optical axis. In our 2005 interpretation, we expressed agreement that the optical center would serve as an optical axis of a lower beam headlamp. We also agreed with your recommended approach and said that for LED lower beam headlamps, the optical center should be determined as the geometric center of the portion of the lens that is illuminated by the LED light sources. While we continue to believe this could be a valid approach, manufacturers may choose other methods as well. For example, with LED light sources of varying intensity, a manufacturer could conclude that the geometric center of the illuminated lens might not be accurate for marking the lamp for aiming purposes. The agency notes that the term optical axis as used in FMVSS No. 108 may be inconsistent with the encyclopedic definition of the phrase. For visually/optically aimed headlamps, the term optical axis, as it is used in Standard No. 108, refers to the reference axis (a.k.a. mechanical axis) of the headlamp. Given this, we have reexamined a second point from the 2005 letter, in which we stated that the center of the emitted light is always taken to be the center of the optical axis. In saying this, we were quoting a January 14, 1976 letter of interpretation to the Department of California Highway Patrol. Upon closer examination, the 1974 letter addressed the optical axis (i.e., the mechanical or reference axis) in turn signals, not headlamps. As turn signals are symmetrical, the center of light emitted should always constitute the reference axis. However, as headlamps are asymmetrical, the quoted portion of the 1974 letter does not apply to headlamps. Paragraph S7.8.5.3(f) of FMVSS No. 108 requires that a visually/optically aimed headlamp include a mark or markings identifying the optical axis of the headlamp. The location of this mark or markings is to be determined by the headlamp manufacturer. Once chosen, the mark establishes the reference axis that will be used to assure proper horizontal and vertical alignment of the aiming screen or optical aiming equipment with the headlamp being aimed. NHTSA will use this mark to identify the reference axis, and will conduct its compliance testing accordingly. Finally, we note that this interpretation broadens flexibility for manufacturers under the rule and, as such, does not amount to a change implicating compliance issues for manufacturers currently relying on the opinions in our previous letters. If you have any further questions, please contact Ari Scott of my staff at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel ref:108 d.5/25/07 |
2007 |
ID: 06-007609drnOpenJames Freiburger, Senior Staff Engineer Thomas Built Buses, Inc. 1408 Courtesy Road High Point, NC 27260 Dear Mr. Freiburger: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials, regarding a requirement that in school buses, exposed edges shall be banded. You state that you manufacture a school bus that has bonded in place glass panels that do not open in locations that include the windshield, panels in the drivers area, doors and rear stationary glass. You ask whether the glass panel edge must be banded even when the edge is not exposed to the seated school bus passengers. Second, you ask whether glass used in the passenger and driver windows that is encased in the windows frame work would satisfy the banding requirement. Discussion FMVSS No. 205 has incorporated by reference American National Standard for Safety Glazing Materials for Glazing Motor Vehicles and Motor Vehicle Equipment Operating on Land Highways-Safety Standard (ANSI/SAE Z26.1-1996). Section 6, Edges, of ANSI/SAE Z26.1-1996 states: In vehicles except school buses, exposed edges shall be treated in accordance with SAE J673 Automotive Safety Glazing. In school buses, exposed edges shall be banded. Your first question asks whether the bonded in place glass panels must be banded. The photographs you enclosed are difficult to see clearly, but it appears that the bonded in place glass panels are attached to the window frame without encasing the edges of the glass within the frame. It appears that the glass is made to adhere to the frame and that there are one or more edges of the glass that are exposed on the exterior of the bus.[1] You believe that the answer to the first question is no, that exposed edges in ANSI/SAE Z26.1-1996 refers to edges exposed to the seated school bus passengers. We do not agree. Nothing in Section 6 of ANSI/SAE Z26.1-1996, or any other part of FMVSS No. 205, limits the banding requirement only to edges exposed to seated school bus passengers. Moreover, if we were to read Section 6 as you suggest, an implication could be that exposed edges of the glass on the exterior of the bus need not be treated at all, which would seem to raise the possibility of the edges posing an unreasonable risk of laceration. There could also be different safety risks in post-crash situations depending on whether the exposed edges are banded. Because of these issues, we cannot, by interpretation, apply the banding requirement only to edges that are exposed to seated school bus occupants, or only to windows that can be opened. Your second question related to school bus glazing encased in the windows frame work. You ask if encasing the windows in the frame work would be considered banded. Our answer is that, if all edges of the window were encased in the window frame, there would be no exposed edges and thus no need for banding. Finally, you also raised the issue of whether a State can change the FMVSS requirement because the State believes they are requiring a higher level of safety, or if the State must accept a bus built to FMVSS requirements. The National Traffic and Motor Vehicle Safety Act generally states that (49 U.S.C. 30103(b)(1)) when a Federal motor vehicle safety standard is in effect, a State may prescribe or continue in effect a standard applicable to the same aspect of performance as that Federal standard only if the standard is identical to the Federal standard; however, a State may prescribe a standard for a motor vehicle obtained for the States own use that imposes a higher performance requirement than that required by the otherwise applicable FMVSS. We cannot answer your specific question without more information about the State law at issue and the vehicles to which the State standard applies. I hope this information is helpful. If you have any further questions, please contact Ms. Dorothy Nakama at this address or at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel ref:205 d.5/21/07 [1] Your photographs appear to show a windshield (Picture number 1); glass panels to the right of the front door (Picture number 2); triangular glazing to the left of the drivers side window (Picture number 3); glass panels on either side of the emergency exit door (Picture number 4); and a rear view of the bus showing pieces of glazing in the rear emergency exit door (Picture number 5). All photos appear to show the glazing bonded to the frame in a manner that does not encase the glazing in the frame. |
2007 |
ID: 77-2.40OpenTYPE: INTERPRETATION-NHTSA DATE: 05/25/77 FROM: FRANCIS ARMSTRONG -- NHTSA DIRECTOR OFFICE OF STANDARDS ENFORCEMENT MOTOR VEHICLE PROGRAMS TO: TOM SCHOFIELD -- A. N. DERINGER & CO. TITLE: NONE TEXT: Dear Mr. Schofield: This is in response to your recent inquiry concerning the importation of motor vehicles for resale. Such importation makes you a "manufacturer" under the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) (15 USC 1381 et seq.) and subject to the regulations listed as items two through ten on the last page of this letter. As a general rule, under section 108(a)(1)(A) of the Act, all motor vehicles, new or used, manufactured on or after January 1, 1968, must conform to all applicable Federal Motor Vehicle Safety Standards (FMVSS) in order to be imported into the United States. The regulation governing the importation of motor vehicles is Title 19, Code of Federal Regulations, Part 12.80 (19 CFR 12.80). If you import a vehicle not certified by the original manufacturer, you must submit within 90 days of the entry a compliance statement to substantiate that the vehicle has been brought into conformity. Your statement must identify the manufacturer, contractor, or other person who has brought the vehicle into conformity, and must describe in exact detail the nature and extent of the work performed. Failure to substantiate that the vehicle has been brought into conformity or sale of the vehicle before release of bond, renders you liable for imposition of civil penalty of up to $ 1,000 per vehicle and/or assessment of liquidated damages in the amount of the value of the bond required by 19 CFR 12.80(c). Section 114 (15 USC 1403) of the Act and Title 49, Code of Federal Regulations, Part 567 (49 CFR 567), require that manufacturers permanently affix a tag or label to a motor vehicle certifying that it conforms to all applicable FMVSS. Prior to your sale of a vehicle, you as the "manufacturer" are also required to certify conformance with all applicable FMVSS by permanently affixing the certification label specified, see 567.2(b) and 567.4(g)(1). This label shall be affixed at the time of submission of your compliance statement. If you determine in good faith that any vehicle imported and sold by you does not conform with any of the applicable FMVSS or contains a safety-related defect, section 151 (15 USC 1411) of the Act requires that you furnish notification to the Secretary and to owners in accordance with section 153 (15 USC 1413) and to remedy without cost the failure to conform or defect in accordance with section 154 (15 USC 1414). Since in all probability the trucks referenced in your conversation with Mr. Robert W. Aubuchon, a member of my staff, fall into the classification of vehicles manufactured in two or more stages, we are enclosing a copy of 49 CFR 568. As requested the points of contact for certification matters in the companies you referenced are: Mr. J. C. Eckhold Director, Auto Safety Office Ford Motor Co. The American Road Dearborn, Michigan 48121 Mr. David E. Martin Manager, Auto Safety Engineering Dept. Environmental Activities Staff General Motors Technical Center Warren, Michigan 48090 Mr. L. W. Moore Manager, Reliability and Warranty International Harvester Co. P.O. Box 1109 Fort Wayne, Indiana 46801 Mr. James W. Lawrence Manager, Safety and Environmental Engineering Truck Group White Motor Corp. P.O. Box 91500 Cleveland, Ohio 44101 You should also note that under 49 CFR 566 you are required to submit certain identifying information and a description of your product to the Administrator, National Highway Traffic Safety Administration. It should also be noted that before offering a motor vehicle or item of motor vehicle equipment for importation into the United States, a foreign manufacturer is required to register an "Agent-for-Service" of process as set forth in 49 CFR 551.45 and to furnish the information required by 49 CFR 566. Federal regulations concerning anti-pollution emission control devices are not the responsibility of the Department of Transportation. For guidance in this area it is suggested that you write the Environmental Protection Agency, Director, Mobile Source Enforcement Division, 401 M Street, S.W., Washington, D.C. 20460 You are advised to carefully examine the Act, Importation Regulations, and FMVSS as well as other regulations listed below to insure that you fully understand the extent of the responsibilities you incur upon the importation of a motor vehicle for resale. Enclosed for your information and guidance is a copy of the following: 1. The National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1381 et seq.) 2. 49 CFR 551, "Procedural Rules" 3. 49 CFR 566, "Manufacturer Identification" 4. 49 CFR 567, "Certification" 5. 49 CFR 571, "Federal Motor Vehicle Safety Standards" 6. 49 CFR 574, "Tire Identification and Recordkeeping" 7. 49 CFR 575, "Consumer Information" 8. 49 CFR 577, "Defect Notification" 9. 49 CFR 580, "Odometer Disclosure Requirements" 10. 19 CFR 12.80, "Importation Regulations" 11. Where to Obtain Motor Vehicle Safety Standards and Regulations 12. Form HS-189, "General Requirements of FMVSS" Should you have other questions, please contact Mr. Robert Aubuchon, a member of my staff, telephone number 202-426-1693. 13. ENCLOSURES Sincerely, |
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ID: Hyundai_S7v2OpenMr. Robert Babcock Dear Mr. Babcock: This responds to your request for an interpretation regarding the seat belt warning provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant crash protection, that pertain to the audible warning requirement. You asked if a two-second delay is permissible before the audible signal is activated. As explained below, a system as you described would not comply with the audible warning provision of FMVSS No. 208. S7.3 of FMVSS No. 208 establishes a warning requirement to alert vehicle drivers that their seat belt is not fastened. S7.3 provides manufacturers with several options for complying with this requirement. Under each option, a continuous or intermittent audible signal must activate when the vehicle ignition is moved to the "on" or "start" position and drivers safety belt is not in use (S7.3(a)(1) and (2)). The audible signal must sound for a period of not less than four seconds and not more than eight seconds. In your letter, you asked if a delay was permitted between the time a vehicles ignition is moved to the "on" or "start" position and when the audible signal is activated (assuming the drivers seat belt is not fastened). You stated that self-diagnostic programs may cause a short delay (up to 2 seconds) prior to the vehicle system being capable of functioning fully, and thus may delay the activation of the audible warning for that same period. You asked if this delay, which occurs after the ignition switch is moved to the "on" or "start" position, is permitted under S7.3 of FMVSS No. 208. As explained above, S7.3 requires the audible signal to activate when the vehicle ignition is moved to the "on" or "start" position. Therefore, the short delay you described would not be permissible. If you have any additional questions, please contact Mr. Chris Calamita of my staff at (202) 366-2992. Sincerely, Stephen P. Wood ref:208 |
2005 |
ID: 20822.ztvOpenMr. Timothy J. Flanagan Dear Mr. Flanagan: This is in reply to your letter of October 6, 1999, requesting permission "to install additional lighting for visibility and safety purposes" on PECO Energy Company emergency service vehicles. You report that your vehicles currently are equipped with an "amber strobe light on the roof and the regular hazard lights." You would like to add "additional strobe lights in the rear and front" of your vehicles to be used while the vehicles are stationary, and state that this additional lighting "will not interfere with any other warning or safety devices on the vehicle such as headlights or turn signals." Strobe lamps are not permitted as original equipment on motor vehicles. This is because all lamps with which a vehicle is supplied must be steady burning, except for turn signals and hazard warning signals, and headlamps which may be automatically flashed for signaling purposes (see S5.5.10 of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment). We regard a strobe lamp as one that flashes, and hence prohibited as original equipment. As for vehicles in the field, such as yours, Federal law (49 U.S.C. 30122) prohibits manufacturers, dealers, distributors, and motor vehicle repair businesses from making inoperative safety equipment installed in accordance with FMVSS No. 108 (and any other applicable FMVSS as well). Installation of a strobe lamp would create a noncompliance with FMVSS No. 108 which we equate with "making inoperative" within the meaning of the statute. However, the list of persons prohibited from making safety modifications affecting compliance do not include vehicle owners. Thus, if PECO Energy has its own vehicle repair facilities, your company may install the strobe lamps without violating Federal law. Use of these lamps is subject to the laws of Pennsylvania. If you have any questions, you may call Taylor Vinson of this Office (202-366-5263). Sincerely, |
2000 |
ID: nht73-1.36OpenDATE: 07/26/73 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Signal-Stat Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of July 10, 1973, to Mr. Schneider asking which SAE Standard incorporated into Standard No. 108 applies to turn signal operating units, SAE J589 or J589a. The correct standard is SAE J589. You noted that the tables in the standard refer to J589, while paragraph S5.1 states that subreferenced standards shall be those published in the 1970 edition of the SAE Handbook. The key word in S5.1 is "subreferenced", i.e., referred to only in an SAE standard itself referenced in the Federal standard. J589 is directly referenced, not subreferenced and the number identified is correct. An example of a subreferenced standard would be J575, which is mentioned in J589. Your truly, July 10, 1973 Office of Chief Counsel -- National Highway Traffic Safety Administration Attention: L. Schneider Gentlemen: We will appreciate in obtaining your interpretation relative to the testing regulations of the "Turn Signal" operating units. I. FMVSS#108, paragraph S.5.1 states: "S5. 1 SAE Standards and Recommended Practices subreferenced by the SAE Standards and Recommended Practices included in Tables I and III and paragraphs S4.1.4 and S4.5.1 are those published in the 1970 edition of the SAE Handbook". The 1970 SAE edition of SAE Standards contains SAE J-589a for Turn Signal operating units. II. On the other hand, Tables I & III of FMVSS #108 specifies SAE J-589 for Turn Signal operating units. Is it a conflict between paragraph S5.1 and the Tables I and III of FMVSS #108? Please inform which of the two mentioned SAE Standards is applicable for 1973, J-589a or J-589. Thank you for your cooperation. Very truly yours, SIGNAL-STAT CORPORATION -- Rene Politis, Director, Product Reliability and ASSURANCE DEPT. |
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ID: nht95-1.57OpenTYPE: INTERPRETATION-NHTSA DATE: February 8, 1995 FROM: Mark Warlick TO: Ed Glancy -- Chief Counsel TITLE: NONE ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM PHILIP R. RECHT TO MARK WARLICK (A4; PART 571) TEXT: Re: FMVSS 208 The attached document is taken from the R.V.I.A. handbook A Guide to FMVSS, April 23, 1991. My questions pertain to item number 3. Is the statement about the minimum number of designated seating positions required as there are sleeping accommodations s till in effect? If so, where can I find it in the October 1, 1993, CFR 49 manual? And, what is the "definition" or "defined area" that makes up one sleeping position? Attachment FMVSS 208: Occupant Crash Protection This standard specifies requirements for both active and passive occupant crash protection systems. Applicability: Passenger cars, MPVs, trucks, and buses Requirements: All designated seating positions (DSP) must be belted 1. MPVs with GVWR of 10,000 pounds or less a. Other than motorhomes: Type 2 at each front outboard DSP; Type 1 elsewhere; warning system for front (See Figure 208-1 for description of Type 1 and 2 seat belts) b. Motorhomes: Type 1 may be used for front outside DSP, unless windshield header is within head impact area (Type 2 must be used); Type 1 elsewhere; warning system for front 2. MPVs with GVWR of more than 10,000 pounds Either a Type 1 or Type 2 at each designated seating position 3. There must be a belt at each DSP; it is the NHTSA's position that, as a minimum, there must be as many DSPs as there are sleeping accommodations (if the vehicle actually has that many "seats") 4. "Designated Seating Position": Any plan view location capable of accommodating a person at least as large as a 5th percentile adult female if the overall seat configuration and design and vehicle design is such that the position is likely to be used while the vehicle is in motion 5. Belts must meet the requirements of FMVSS 209 |
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ID: nht92-5.42OpenDATE: June 26, 1992 FROM: Becky Plank -- Executive Director, National Mobility Equipment Dealers Association TO: Office of the Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 9/15/92 from Paul Jackson Rice to Becky Plank (A39; Std. 301; Part 567) TEXT: Our Association consists of dealers that modify vehicles for the disabled. We have enclosed a set of our guidelines,along with an information brochure, for your perusal. As you will note, the guidelines/standards are for our members to follow for installation of adaptive equipment. To our knowledge, there are no other guidelines/standards in the market. We are aware that we must follow the FMVSS when installing or modifying a vehicle that is not adaptive- equipped. Currently there is a controversy in our membership over a fuel tank issue involving FMVSS 301. One of the modifications our members perform is lowering a floor, on a full size van. When an individual drives from their wheelchair, they sit higher, thus causing them to bend their head forward to have a clear view from the windshield. Therefore, the adaptation is necessary in order to lower the eye level of a wheelchair driver, for safer operation of the van. There was a problem with the design of the new Ford van, in that their fuel tank is larger and mounted mid-ship. When Ford Motor Company realized the hardship they had created for the disabled, they designed an after-market fuel system that complies with FMVSS. Some of our members categorically state that they can lower the mid-ship OEM tank. Taking into consideration that the OEM fuel fill line needs to be changed, along with the mounting brackets, as well as other fuel lines; our question is - will this lowered system have to be crash tested due to the original fuel system being changed. Based on the foregoing, we would like a legal interpretation of FMVSS 301. We would appreciate your response regarding this very important matter as soon as possible. |
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ID: LEDlamp.1OpenMr. Takayuki Amma Dear Mr. Amma: This responds to your letter, in which you seek clarification as to whether your proposed headlighting system would meet the requirements for a "combination headlighting system" under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically, your letter explained that you wish to combine an "integral beam lower beam headlamp" that uses LEDs (wired in series), with a "replaceable bulb upper beam headlamp". As discussed below, we believe that your proposed design with an LED array would be permissible, provided that it meets the applicable photometric requirements of the standard. As an initial matter, we note that your letter was in the first instance submitted under a request for confidentiality, but the agency denied that request in a separate letter dated June 20, 2005. In a July 13, 2005 e-mail to Eric Stas, you stated that you would not be appealing that determination. 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 approval of motor vehicles or motor vehicle equipment, and we do not determine compliance of a vehicle or item of motor vehicle equipment outside the context of an actual enforcement proceeding. Instead, manufacturers are required to self-certify that their products conform to all applicable safety standards that are in effect on the date ofmanufacture. FMVSS No. 108 specifies requirements for original and replacement lamps, reflective devices, and associated equipment. The following represents our opinion regarding the applicability of our regulations on your proposed product based upon the facts set forth in your letter and your demonstration of the lamp in a meeting at NHTSA headquarters in Washington, D.C. Your letter described a proposed vehicle front lighting system with two headlamps, which you consider to be a "combined headlighting system" under S7.6 of our standard. Your letter stated that this system design would include all of the forward lighting equipment required by FMVSS No. 108 and that it would meet the relevant requirements of the standard for each item (e.g. , meeting S7.4 for the integral beam headlamp and meeting S7.5 for the replaceable bulb headlamp). We understand that your proposed system would include an array of six LEDs that would provide the lower beam headlamp illumination and that you believe it would meet the standards lower beam photometric requirements. We also understand that the LED portion of the lower beam would remain activated and contribute toward meeting the standards upper beam photometric requirements. Your letter stated that the upper beam portion of the lamp would have an independent reflector and a replaceable light source, while sharing the same lens and housing with the LED lower beam lamp. In your letter, you also expressed your opinion that the LED lower beam portion of the lamp constitutes a single, simultaneously-aimable light source unit, which is part of an "integral and indivisible optical assembly" which includes the lens, reflector, and LED light source. As discussed in the meeting with NHTSA staff, you stated that you consider the array of LEDs to constitute a single light source, because they are wired in a series, such that failure of a single LED causes all of the LEDs to cease operation. You further stated that because the lower beam lamp is an integral beam headlamp, the entire lamp would need to be replaced in the event of a burned out or damaged LED. Furthermore, referencing the definition of "integral beam headlamp" contained in S4 of Standard No. 108, your letter stated that "[t]here is no restriction on the number of light sources useable for the headlamp". As you are aware, paragraph S7, Headlighting Requirements, of FMVSS No. 108 requires vehicles to be equipped with one of several permissible headlighting system options, whose specifications are set forth in the standard (i.e. , systems conforming to the requirements of S7.3, 7.4, 7.5, or S7.6). Of relevance here, paragraph S7.6, Combination Headlighting System, provides that such systems "shall be comprised of either two headlamps designed to conform to the requirements of S7.6.2, or any combination of four headlamps designed to conform to the requirements of S7.3.7, S7.4, or S7.5 of this standard". Paragraph S7.6.2 states that for combination headlighting systems consisting of two headlamps, each headlamp shall be designed to conform to Figure 17-1 (Photometric Test Point Values for Mechanical Aim Headlighting Systems) or Figure 17-2 (Photometric Test Point Values for Visual/Optical Aim Headlighting Systems) and shall be a combination of two different headlamp types chosen from the following types: a Type F headlamp, an integral beam headlamp, and a replaceable bulb headlamp. A portion of the headlamp that contains an integral beam headlamp must be designed to conform to the requirements of S7.4(c) through (h) of this standard. A portion of the headlamp that contains a replaceable bulb headlamp must be designed to conform to the requirements of S7.5. Under paragraph S4, "integral beam headlamp" is defined as "a headlamp (other than a standardized sealed beam headlamp designed to conform to paragraph S7.3 or a replaceable bulb headlamp designed to conform to paragraph S7.5) comprising an integral and indivisible optical assembly including lens, reflector, and light source, except that a headlamp conforming to paragraph S7.8.5.2 or paragraph S7.8.5.3 may have a lens designed to be replaceable". The definition of the term "integral beam headlamp" does not place a limitation on the number of light sources in such lamp. However, under S7.4(b), there are locational requirements which correspond to whether each headlamp has one or two light sources. As we explained in our December 30, 1992 letter of interpretation to Mr. T. Kouchi, we have previously considered lamps with LEDs (which as a practical matter always have multiple LEDs) to have multiple light sources, with each LED constituting a single light source. However, the situation where a number of LEDs are wired in series, such that they would operate or fail as a single unit, is different than the ones we have previously addressed. Because you have wired the LEDs as a series, failure of one LED would cause all of the LEDs to cease functioning. Thus, in such cases, we agree that the entire array of LEDs is a single light source, regardless of the hardware involved. Therefore, we believe that a combination headlighting system with an integral beam lower beam headlamp using LEDs would be permissible, if such LEDs are wired in series and allow the headlamp to meet the photometric requirements of the standard. We also note that it may be possible for a lower beam headlamp with LEDs to meet the requirements of a different alternative under paragraph of S7.4, Integral Beam Headlighting System, by using beam contributors, each of which would contribute to meeting the headlamps photometric requirements (see S7.4(a)(2) and (d)). Your letter also requested clarification regarding what constitutes the "optical center" of a lower beam headlamp, which you suggest should be the geometric center of the portion of the lens that is illuminated by the LED light sources. You argued that this approach would provide the appropriate geometric reference for measuring the "distance to floor and between the lamps" and that it would also serve as an "optical axis" to ensure proper horizontal and vertical aiming of the headlamp, as well as determine a correct alignment to the photometer axis. You seek confirmation that in determining the relative location of the lower beam and upper beam light sources, the "optical center" of the LED lower beam headlamp shall be used and that a design where the optical center of the LED lower beam headlamp is placed most outboard and above the upper beam light source, such lamp would be considered to conform to the requirements of S7.4(b) and (c), as well as S7.5(d)(2) and (3). We agree that for LED lower beam headlamps with a clear lens (i.e. , where light passes through the lens without being optically redirected), the optical center should be determined as the geometric center of the portion of the lens that is illuminated by the LED light sources. Over the last several decades, the agency has replied many times to requests for interpretation regarding the center of lamps, but requests have all involved filament bulb lamps. We note that in a 1984 final rule responding to petitions for reconsideration under FMVSS No. 108, the agency referred to "optical center" as the reference center during photometric measurement (see 49 FR 20818 (May 17, 1984)), and in our January 14, 1976 letter of interpretation to the Department of California Highway Patrol, we stated that the center of the emitted light is always taken to be the center of the optical axis. In the case of a clear lens LED headlamp, we believe that your recommended approach is consistent with these prior statements. Although not referenced in our standards, we note that the Society of Automotive Engineers (SAE) standard J1889, L.E.D. Lighting Devices, provides two options for determining the "LED lighting device light center". The first option is to determine the geometric center of the total illuminated area of the lamp, and the second option is to determine the geometric center of all of the individual LED light source centers. However, the agency does not believe that the second option is a valid method for measuring the optical center, because it may not correlate to the actual photometric output of the lamp (e.g. , different LEDs could have varying intensities). If you have any further questions, you may call Mr. Eric Stas of my staff at (202) 366-2992. Sincerely, Stephen P. Wood ref:108 |
2005 |
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The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
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