NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: nht76-3.2OpenDATE: 07/16/76 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Jeep Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in response to Jeep Corporation's March 9, 1976, petition for rulemaking as supplemented by its letter of April 1, 1976. The petition requested an amendment of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, that would add the following sentence at the end of S7.1.6(b): For the purposes of this section, unloaded vehicle weight does not include the weight of work-performing accessories. The supplement to the petition included a list of 15 examples of such work-performing accessories. The amendment would require the National Highway Traffic Safety Administration (NHTSA) to remove these accessories before performing compliance testing pursuant to the standard. In Section 108 of the Motor Vehicle and Schoolbus Safety Amendments of 1974, (15 U.S.C. 1392 note), Congress directed that the fuel system integrity standard take effect in the form in which it had been most recently published. Conditions for amending the standard were specified in Section 108(b) as follows: Amendment or Repeal of Standard. -- The Secretary may amend the standard described in subsection (a) in order to correct technical errors in the standard, and may amend or repeal such standard if he determines such amendment or repeal will not diminish the level of motor vehicle safety. The practical result of the amendment requested by Jeep would be that certain vehicles would not, as is presently specified, be required to conform to the standard in the form in which they are actually delivered to purchasers and used on the highways. In fact, the presence of work-performing accessories could seriously degrade a vehicle's performance in the standard's barrier crash tests. We therefore cannot conclude that the requested amendment "will not diminish the level of motor vehicle safety." Furthermore, the amendment goes beyond the mere correction of technical errors in the standard. Consequently, Jeep's petition must be and is hereby denied. Despite this denial, however, the NHTSA interprets the term "unloaded vehicle weight" in a manner that provides some of the relief that Jeep has requested. The term is defined in 49 CFR Part 571.3 as follows: 'Unloaded vehicle weight' means the weight of a vehicle with maximum capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants. The "weight of a vehicle" includes the weight of those accessories that are installed on a vehicle before delivery and are not ordinarily removed. Among such accessories are the following: air bag suspension systems draw bars headlamp and radiator protectors helper-springs hitches pintle hooks power take-offs push bumpers step bumpers and side steps tire carriers wreckers The weight of those accessories that are ordinarily removed from a vehicle when they are not in use, however, is not included in the "weight of a vehicle". Consequently, accessories in this latter group would be removed by the NHTSA prior to testing for conformity to Standard No. 301-75. Among these are the following: snow plows spreaders tow bars Categorization of winches, the remaining accessory that you have listed, depends on the nature of the particular winch. One that is generally removed only when its presence interferes with other vehicle functions would be included in the evaluation of "unloaded vehicle weight". A portable winch that is ordinarily removed after use, however, would not be included in that evaluation. SINCERELY, Jeep Corporation April 1, 1976 James B. Gregory Administrator National Highway Traffic Safety Administration U.S. Department of Transportation On March 9, 1976 the Jeep Corporation petitioned the Administrator of the National Highway Traffic Safety Administration for rulemaking to exempt work-performing accessories from the test requirements of FMVSS No. 301, Fuel System Integrity, as the standard applies to multi-purpose vehicles and light trucks. This letter transmits additional information to supplement our March 9 petition. It has occurred to us that a summary of the types of available work-performing accessories referenced in our petition might be of benefit to you in your efforts to evaluate the merits of the Jeep petition. We, therefore, submit the following list of work-performing accessories, or work-related accessories, for your information and review: Air bag suspension systems Draw bars Headlamp and radiator protectors Helper springs Hitches Pintle hooks Power take-offs Push bumpers Snow plows Spreaders Step bumpers and side steps Tire carriers Tow bars Winches Wreckers In addition, we have attached copies of the booklet "Jeep Vehicle Special Equipment and Jeep Vehicle Accessories Catalog" which includes illustrations of the type of accessories and devices discussed above as well as descriptions of other factory-approved equipment and accessories that are available on these unique vehicles. We request your prompt and favorable acceptance of this petition since less than five months remain before FMVSS No. 301 becomes effective as applied to MPV's and light trucks. George E. Brown Executive Director - Vehicle Emissions & Safety ATTACHMENTS Jeep Corporation March 9, 1976 James B. Gregory Administrator National Highway Traffic Safety Administration U.S. Department of Transportation RE: Petition For Rulemaking Federal Motor Vehicle Safety Standard No. 301, Fuel System Integrity On October 16, 1975, Jeep Corporation submitted a petition to amend the definition of "unloaded vehicle weight" so that work-performing accessories would not be included. That petition was subsequently denied (your letter N40-30) on the grounds that the NHTSA has adopted a policy of evaluating potential dynamic testing problems with heavy or protruding accessories on a "standard-by-standard" basis. In accord with that stated NHTSA policy, Jeep Corporation, herewith, submits the attached petition to amend Federal Motor Vehicle Safety Standard No. 301, Fuel System Integrity, so that the test conditions specified by the standard do not include the work-performing accessories used on trucks and multi-purpose vehicles. George E. Brown Executive Director Vehicle Emissions and Safety March 9, 1976 PETITION TO AMEND FEDERAL MOTOR VEHICLE SAFETY STANDARD (49 CFR PART 301) FUEL SYSTEM INTEGRITY Pursuant to Section 124 of the National Traffic and Motor Vehicle Safety Act, Jeep Corporation petitions the Administrator of the National Highway Traffic Safety Administration to undertake rulemaking to amend Motor Vehicle Standard No. 301, Fuel System Integrity, so that the test conditions specified by the standard do not include work-performing accessories for trucks and multipurpose vehicles. Thus, the test conditions for Standard No. 301 would then be consistent in this respect with those for Standard No. 219, Windshield Zone Intrusion. The Jeep Corporation requests the Administrator's consideration of this petition for the amendment to Motor Vehicle Safety Standard No. 301, Fuel System Integrity, for the following reasons: Currently, the Test Conditions of Standard No. 301, Fuel System Integrity, Are Not Consistent with Those of Standard No. 219, Windshield Zone Intrusion In the preamble to the proposal for Standard No. 219, Windshield Zone Intrusion, Docket No. 74-21; Notice 2, the Administrator stated: "Finally, the NHTSA is continuing to promote compatibility and economy in barrier crash testing by adopting vehicle loading and dummy restraint requirements in Standard No. 219 identical to those set out in proposed amendments to Standard No. 301, Fuel System Integrity, 49 CFR 571.301 (40 FR 17036, April 16, 1975)." Jeep Corporation fully supports the Administrator's efforts to promote compatibility and economy in barrier testing; however, the requirements for Standard No. 219 and 301 do not provide the desired compatibility or economy. Section 7.7b of Standard No. 219 referring to the test loading and dummy requirements for multi-purpose passenger vehicles, trucks, and buses states: "For the purposes of this section, unloaded vehicle weight does not include the weight of work performing accessories." Standard No. 301 does not provide for the exemption of work-performing accessories and, therefore, is not compatible with Standard No. 219 and thus requires clarification regarding the loading conditions for barrier testing. Barrier Tests Including Work-Performing Accessories Would Not Be Representative of Normal Production Vehicles Multi-purpose vehicles, because of their nature, are used in many ways with equipment not typical of normal passenger car usage. Barrier tests involving work-performing accessories would not be representative of most production vehicles. For example, the barrier test results of a truck with a snow plow on its front and carrying a salt spreader on its rear should not be used to depict base vehicles because of the possible protection offered to the base vehicle by its work-performing devices. Excessive Barrier Test Requirements May Cause Some Accessories Specifically Engineered for Jeep Vehicles to be Removed From the Marketplace Jeep Corporation offers a full range of work-performing accessories ranging from snow plows and push plates to power winches and wrecker assemblies. Such accessories are highly desirable to customers who want to more fully utilize the multi-purpose features of their Jeep vehicles or who want to utilize the capabilities of any class of vehicle for recreational or work purposes. These accessories, which are marketed as Jeep Special Equipment, are specifically designed to be compatible with Jeep vehicles, thereby requiring a minimum of vehicle modification, and are offered either as factory-installed or dealer add-on equipment. Aftermarket universal-type accessories may not be so readily adaptable to Jeep vehicles resulting in major vehicle modifications which may compromise the safety performance of the original vehicle. Marketing of these engineered accessories may not be possible, however, if the dynamic testing procedures of Standard No. 301, Fuel System Integrity, differ from the test procedures specified for other standard such as Standard No. 219, Windshield Zone Intrusion, and require multi-purpose vehicles to be tested with a myriad of special equipment accessories. Programs to assure compliance to any Federal Safety Standard specifying barrier testing with all possible equipment combinations would create a testing and financial burden which Jeep Corporation could not bear. The end result would be the withdrawal from the marketplace of certain original equipment, manufacturer-installed accessories or dealer-installed, manufacturer-approved accessories which may not be in the best interest of public safety. Summary In recognition of the above arguments, Jeep Corporation petitions the Administrator to amend Section 7.1.6(b) of Motor Vehicle Safety Standard No. 301, Fuel System Integrity, by adding the sentence underlined here: ". . . same. Each dummy shall be restrained only by means that are installed in the vehicle for protection at its seating position. For the purposes of this section, unloaded vehicle weight does not include the weight of work-performing accessories." Jeep Corporation submits that such rulemaking is both in the public interest and in the best interest of vehicle safety. |
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ID: nht95-4.36OpenTYPE: INTERPRETATION-NHTSA DATE: September 25, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Winston Sharples -- President, Cantab Motors, Ltd. TITLE: NONE ATTACHMT: NONE TEXT: Dear Mr. Sharples I enclose a copy of an order of the Administrator granting the petition by Cantab Motors for temporary exemption from Motor Vehicle Safety Standards Nos. 208 and 214. The exemption from Standard No. 208 will expire on September 1, 1997, and that for Sta ndard No. 214 on September 1, 1998. In accordance with agency regulations on the subject, within 30 days after your receipt of this letter please provide the Director, Office of Vehicle Safety Compliance, with a copy of the certification label reflecting the exemption that will be used on Cantab's vehicles (49 CFR 555.9(a)). We have received your letter of August 17, 1995, which admits that Cantab manufactured and sold nine vehicles manufactured after the expiration of its previous exemption that did not conform with Standard No. 208, and which enclosed a petition for a dete rmination of inconsequentiality on this matter. This is currently under review. If you have any questions, you may discuss them with Taylor Vinson of this Office (202-366-5263). Enclosure ACTION: Issuance of Federal Register Notice Granting Cantab's Petition for Temporary Exemption From Standards Nos. 208 and 214 John Womack (K. WEINSTEIN) Acting Chief Counsel Barry Felrice Associate Administrator for Safety Performance Standards Attached for your signature is a Federal Register notice granting the petition by Cantab Motors for a temporary exemption from the automatic restraint requirements of Standard No. 208, and the side impact protection requirements of Standard No. 214. The basis of the grant is that compliance would cause substantial economic hardship to a manufacturer that has tried in good faith to meet the standards. Cantab imports shells of Morgan sports cars from England, and installs propane engines and drive trains in the US; for this reason, we consider Cantab rather than Morgan as the manufacturer. In the year preceding the filing of its exemption petition it produced only 9 such cars. It has cumulative net losses approaching $ 93,000 for the last three fiscal years. It has been working with Morgan to develop vehicles that will be equipped with airbags meeting Standard No. 208, and provide side impact prote ction meeting Standard No. 214. Because the components that must be modified for conformance are under the control of Morgan rather than Cantab, the company is dependent upon Morgan's efforts. Cantab asked for only a 2-year exemption from Standard No. 208, indicating that it is optimi stic that its cars will conform in less than the 3 years it could have asked for. However, it appears to require the full 3 years for Standard No. 214. Any threat to safety that would be presented by an exempted vehicle would be minimal because they are few in number, and are represented as conforming to earlier versions of the two standards. No comments were received on the application. Attachment DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration Docket No. 95-53; Notice 2 Cantab Motors, Ltd. Grant of Application for Temporary Exemption From Federal Motor Vehicle Safety Standards No. 208 and 214 Cantab Motors, Ltd., of Round Hill, Va., applied for a temporary exemption of two years from paragraph S4.1.4 of Federal Motor Vehicle Safety Standard No. 208 Occupant Crash Protection, and for three years from Federal Motor Vehicle Safety Standard No . 214 Side Impact Protection. The basis of the application was that compliance will cause substantial economic hardship to a manufacturer that has tried to comply with the standard in good faith. Notice of receipt of the application was published on July 14, 1995, and an opportunity afforded for comment (60 FR 36328). The make and type of passenger car for which exemption was requested is the Morgan open car or convertible. Morgan Motor Company ("Morgan"), the British manufacturer of the Morgan, has not offered its vehicle for sale in the United States since the e arly days of the Federal motor vehicle safety standards. In the nine years it has been in business, the applicant has bought 35 incomplete Morgan cars from the British manufacturer, and imported them as motor vehicle equipment, completing manufacture by the addition of engine and fuel system components. They differ from their British counterparts, not only in equipment items and modifications necessary for compliance with the Federal motor vehicle safety standards, but also in their fuel system compon ents and engines, which are propane fueled. As the party completing manufacture of the vehicle, Cantab certifies its conformance to all applicable Federal safety and bumper standards. The vehicle completed by Cantab in the U.S. is deemed sufficiently di fferent from the one produced in Britain that NHTSA considers Cantab the manufacturer, not a converter, even though the brand names are the same. Morgan itself produced 478 cars in 1994, while in the year preceding the filing of its petition in June 1995, the applicant produced 9 cars for sale in the United States. Since the granting of its original exemption in 1990, Cantab has invested $ 38, 244 in research and development related to compliance with Federal safety and emissions standards. The applicant has experienced a net loss in each of its last three fiscal (calendar) years, with a cumulative net loss for this period of $ 92,594. Application for Exemption from Standard No. 208 Cantab received NHTSA Exemption No. 90-3 from S4.1.2.1 and S4.1.2.2 of Standard No. 208, which expired May 1, 1993 (55 FR 21141). When this exemption was granted in 1990, the applicant had concluded that the most feasible way for it to conform to the automatic restraint requirements of Standard No. 208 was by means of an automatically deploying belt. In the period following the granting of the exemption, Morgan and the applicant created a mock-up of the Morgan passenger compartment with seat belt h ardware and motor drive assemblies. In time, it was determined that the belt track was likely to deform, making it inoperable. The program was abandoned, and Morgan and Cantab embarked upon research leading to a dual airbag system. According to the applicant, Morgan tried without success to obtain a suitable airbag system from Mazda, Jaguar, Rolls-Royce and Lotus. As a result, Morgan is now developing its own system for its cars, and "[as] many as twelve different sensors, of b oth the impact and deceleration (sic) type, have been tested and the system currently utilizes a steering wheel from a Jaguar and the Land Rover Discovery steering column." Redesign of the passenger compartment is underway, involving knee bolstering, a s upplementary seat belt system, antisubmarining devices, and the seats themselves. Morgan informed the applicant on May 2, 1995, that it had thus far completed 10 tests on the mechanical components involved "and are now carrying out a detailed assessment of air bag operating systems and columns before we will be in a position to undertake the full set of appropriate tests to approve the installation in our vehicles." Application for Exemption from Standard No. 214 Concurrently, Morgan and the applicant have been working towards meeting the dynamic test and performance requirements for side impact protection, for which Standard No. 214 has established a phase-in schedule. Although Morgan fits its car with a dua l roll bar system specified by Cantab, and Cantab installs door bars and strengthens the door latch receptacle and striker plate, the system does not yet conform to the new requirements of Standard No. 214, and the applicant has asked for an exemption of three years. It does, however, meet the previous side door strength requirements of the standard. Were the phase-in requirement of S8 applied to it, calculated on the basis of its limited production, only very few cars would be required to meet the st andard. Safety and Public Interest Arguments Because of the small number of vehicles that the applicant produces and its belief that they are used for pleasure rather than daily for business commuting or on long trips, and because of the three-point restraints and side impact protection currentl y offered, the applicant argued that an exemption would be in the public interest and consistent with safety. It brought to the agency's attention two recent oblique front impact accidents at estimated speeds of 30 mph and 65 mph respectively in which t he restrained occupants "emerged unscathed." Further, the availability "of this unique vehicle . . . will help maintain the existing diversity of motor vehicles available to the U.S. consumer." Finally, "the distribution of [this] propane-fueled vehicle has contributed to the national interest b y promoting the development of motor systems by using alternate fuels." No comments were received on the application. In adding only engine and fuel system components to incomplete vehicles, the applicant is not a manufacturer of motor vehicles in the conventional sense. It does not produce the front end structural components, instrument panel, or steering wheel, ar eas of the motor vehicle whose design is critical for compliance with the airbag requirements of Standard No. 208. These are manufactured by Morgan, and the applicant is necessarily dependent upon Morgan to devise designs that will enable conformance wi th Standard No. 208. The applicant has been monitoring Morgan's progress, and that company is engaging in testing and design activities necessary for eventual conformance. The fact that the applicant is requesting only a two-year exemption, rather than three, indicates its belief that complying operator and passenger airbags will at last be fitted to its cars by the end of this period. Similarly, the applicant is dependent upon the structural design of its vehicle for compliance with Standard No. 214. As with Standard No. 208, Morgan and the applicant are working towards conformance, though apparently it will not be achieved within two years. In both instances, however, the applicant is conscious of the need to conform and has been taking steps to accomplish it. Although the company's total expenditure of $ 38,244 in the last five years to meet emission and safety requirements is low, the small number of cars produced for sale in the United States in the last year, nine, would not make available substantial funds to the company, and its cumulative net losses of $ 92,594 indicate an operation whose financial existence is precario us. Applicant's cars are equipped with manual three-point restraint systems and comply with previous side impact intrusion requirements. Because applicant produces only one line of vehicles, it cannot take advantage of the phase-in requirement. Given th e existing level of safety of the vehicles and the comparatively small exposure of the small number of them that would be produced under an exemption, there would appear to be an insignificant risk to traffic safety by providing an exemption. The public interest is served by maintaining the existence of small businesses and by creating awareness of alternative power sources. In consideration of the foregoing, it is hereby found that to require immediate compliance with Standards Nos. 208 and 214 would cause substantial economic hardship to a manufacturer that has in good faith attempted to meet the standards, and that an exemption would be in the public interest and consistent with the objectives of traffic safety. Accordingly, the applicant is hereby granted NHTSA Exemption No. 95-2, from paragraph S4.1.4 of 49 CFR 571.208 Motor Vehicle Safety Standard No. 208 Occupant Crash Protection, expiring September 1, 1997, and from 49 CFR 571.214 Motor Vehicle Safety St andard No. 214 Side Impact Protection, expiring September 1, 1998. (49 U.S.C. 30113; delegation of authority at 49 CFR 1.50) Issued on SEP 7 1995 Ricardo Martinez, M.D. Administrator BILLING CODE: 4910-59-P |
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ID: nht68-1.10OpenDATE: 04/11/68 FROM: AUTHOR UNAVAILABLE; William Hadden, Jr.; NHTSA TO: House of Representatives TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of March 16, 1968, in reference to an inquiry from Mitts and Merrill, Incorporated, concerning the application of the Federal Motor Vehicle Safety Standards to their brush chipper. The brush chippers as shown in the brochures you enclosed are less than 80 inches in width; therefore, Motor Vehicle Safety Standard No. 108 does not apply at present. However, after January 1, 1968, Table No. III of Motor Vehicle Safety Standard No. 108, will apply to passenger cars, multi-purpose passenger vehicles, trucks, buses, trailers and motorcycles. We are enclosing a copy of the Federal Motor Vehicle Safety Standards as per your request and trust they assist you in this matter. Sincerely, mitts & merrill, inc. March 14, 1968 Honorable James Harvey, M. C. Sir: REFERENCE: Your Letter of March 6 and Wire of March 11 1968 We have studied the Motor Vehicle Safety Act of 1966 and also reviewed your wire. With regard to the above Act, the Federal Safety Standards were not sent with it. The establishment of these standards is stated in the Act under Title I, Section 103, paragraph (h) concerning issuance of Federal Safety Standards and subsequent revised standards. Please have copies of these standards sent(Illegible Word) immediately or advise at once where we may obtain same. We must know if our Brush Chipper falls under this Act. Concerning your wire, enclosed are two copies each of our specification sheets and outline drawings of our Brush Chipper. You will note that no models are over 80" wide which will not bring them under the trailer lighting standards. Our units do require license plates. Thank you for your efforts in our behalf. Very truly yours, Norman E. Hess -- Chief Engineer enclosures MITTS & MERRILL CHIPPER SPECIFICATIONS MODELS -- M7, M8, M9 TRAILER UNITS -- SERIES 160 (16 INCHES) TRAILER: Frame All tubular steel, welded construction. Draw Bar Pintle eye-standard. Ball and socket-optional. Axle Coil spring torsion type, 2" O.D., tubular construction - 61-1/2" track. Wheels Two (2) - Semi-drop center. Tires Two (2) - 15" 8-ply rated - commercial Fenders Two (2) Safety Chains Standard. Parking Wheel Screw action to raise and lower. Rear Stand Folding type. Combination tail light and license plate holder furnished. CHIPPING UNIT: Housing Steel Plate, welded construction. Feed Opening 10" x 16" Cutting Bar 7/8" x 2-7/8" x 16-1/2" - Special steel and heat-treated. Dia. of Cylinder 16" Length of Cylinder 16" Cylinder Material Flame cut steel plate. Dia. of Shaft 3" Bearings Two (2) 2-15/16" Dia., single row, piloted and flange mounted. R.P.M. of Cylinder 3000 Number of Knives Twelve (12) Knife Dimensions 4-1/4" x 2-3/8" x 1/2" Type of Knife Double-edged, special knife steel, heat- treated, and with positive lock arrangement. Cylinder is dynamically and statically balanced. Flywheel and auxiliary blower not required. POWER UNIT: Ford Industrial Engines-Standard. Available in the following models: Model "300", 6-cylinder. 149 B.H.P. with either torque converter, or heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM. Model "330", 8-cylinder, 155 B.H.P. with heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM. EQUIPMENT-STANDARD WITH ALL MODELS: Swing-away Feed Chute. Telescoping discharge chute with deflector bonnet, adjustable for height, with 360 degrees rotation for complete control for discharging right, left, or into a truck. Hinged Cover for easy access to cylinder. Matched set of high capacity "V"-Belts. Covered Battery Box. Tool box containing Knife Wrench, Sharpening Stone, Grease Gun and Operating Manual. Mechanical Governor. Paint - Color (customer option) either highway yellow Kem-Lustral F65YQ317, orange Kem-Lustral F65E1, or green Kem-Lustral F65G7. WEIGHTS - (APPROXIMATED): M & M MODEL NO. POWER UNIT & DRIVE WEIGHT M-7 "300" with Clutch 3675 lbs. M-8 "300" with Torque 3725 lbs. M-9 "330" with Clutch 3825 lbs. OPTIONAL EQUIPMENT: Tachometer Directional Signals Brakes Solenoid Throttle Control Engine Hour Meter Flashing Warning Light Engine Side Panels Fuel Gauge WARRANTY Machine & Parts -- 1 year Service -- Ninety Days Purchased Parts -- Subject to Original Manufacturer's Warranty. The Company reserves the right to change the list price of its products without notice. It shall have the right to discontinue the manufacture of any model or type of product, and change design or add improvements at any time without incurring any obligation to install the same on M & M products previously purchased. For further information, contact your nearest M & M Chipper Dealer, or contact the factory direct. MITTS & MERRILL will engineer units to suit your needs and requirements. 168 BC-12 MITTS & MERRILL CHIPPER SPECIFICATIONS MODELS M2, M3, M4, M11, M12, M13 TRAILER UNITS -- SERIES 120 (12 INCHES) TRAILER: Frame All tubular steel, welded construction. Draw Bar Pintle eye-standard. Ball and socket-optional. Axle Coil spring torsion type, 2" O.D., tubular construction - 61-1/2" track. Wheels Two (2) - Semi-drop center. Tires Two (2) - 15" 8-ply rated - commercial Fenders Two (2) Safety Chains Standard. Parking Wheel Screw action to raise and lower. Rear Stand Folding type. Combination tail light and license plate holder furnished. CHIPPING UNIT: Housing Steel plate, welded construction. Feed Opening 10" x 12" Cutting Bar 7/8" x 2-7/8" x 12-1/2" -- Special steel and heat-treated. Dia. of Cylinder 16" Length of Cylinder 12" Cylinder Material Flame cut steel plate. Dia. of Shaft 3" Bearings Two (2) 2-11/16" Dia., single row, piloted and flange mounted. R.P.M. of Cylinder 3000 Number of Knives Nine (9) Knife Dimensions 4-1/4" x 2-3/8" x 1/2" Type of Knife Double-edged, special knife steel, heat- treated, and with positive lock arrangement. Cylinder is dynamically and statically balanced. Flywheel and auxiliary blower not required. POWER UNIT: Ford Industrial Engines-Standard. Available in the following models: Model "172", 4-cylinder, 59 B.H.P. with torque converter. Engine is calibrated at 2500 RPM. Model "240", 6-cylinder, 124 B.H.P. with either torque converter, or heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM. Model "300", 6-cylinder, 149 B.H.P. with either torque converter, or heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM. Model "330", 8-cylinder, 155 B.H.P. with heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM. (Graphics omitted) Mitts & Merrill Brush Chipper engineered for years of maintenance-free service improved to do all jobs(Illegible Words) [] telescoping discharge chute The new telescoping discharge chute gives the operator maximum flexibility in getting jobs done easier and in less time. The chute is adjustable to various heights, and rotatable . . . a combination that means dump boxes can be filled quickly from corner to corner with minimum spill. An adjustable bonnet at the end of the chute also permits discharge to either side, or forward, providing complete freedom in cases such as road right-of-way maintenance where chips may be left on the ground. [] swing-away feed chute Knife removal and throat bar adjustments are made relatively easy by the swing-away feed chute. The cutting cylinder is completely exposed when the chute is moved to the side and the hinged cover is lifted. These two features are exclusive with Mitts & Merrill Brush Chippers. [] staggered knife pattern The staggered knife pattern, found only on Mitts & Merrill Brush Chippers, provides more cuts per revolution. This results in smoother, more efficient cutting action that reduces material by shaving action rather than the conventional chopping motion. The double-edged knives are securely held in place by a wedge-lock which can be easily disengaged for knife reversal. [] More outstanding features Safety-lock pin The double-edged knives have a positive safety locking pin between the wedge block and the special tool steel knife. This safety feature prevents throw-out of knives not properly tightened. Easy loading The feed chute is low to the ground and designed to permit wide-angle loading of brush and free limbs. No pushing is required . . . the cylinder draws the material into the cutting chamber quickly and safely. All-steel cylinder The solid steel plate cylinder is supported by a heavy-duty flange mounted ball bearing assembly. The cylinder, rotating in an all-steel welded cutting chamber, has a built-in flywheel and blower arrangement, eliminating the need for any optional equipment for blowing material into the discharge chute. Excellent roadability The low profile, strong tubular frame and torsion spring axle assure better roadability over any type of terrain. The certified 100-pound weight at the trailer hitch reduces wear and tear on towing vehicle and adds to the over-all strength and rigidity of the equipment. Over 70 years of experience . . . Mitts & Merrill has over 70 years of experience in producing and improving wood reduction machinery. The equipment offered today by Mitts & Merrill is the highest quality, best performing . . . first choice of municipalities, public utilities, highway departments, tree surgeons and others who seek economy in equipment operation through many years of maintenance-free service. The Mitts & Merrill Brush Chipper is the standard by which all brush chippers are judged. You buy it with confidence. TRAILER UNITS -- SERIES 120 (12 INCH) Total Approximate Pounds Shipping Model Engine Drive Chipping Capacity Weight M-2 Ford "172" Torque Converter Up to 6" Dia. Logs 3350 M-3 Ford "240" Clutch Up to 6" Dia. Logs 3480 M-4 Ford "240" Torque Converter Up to 6" Dia. Logs 3530 M-11 Ford "300" Clutch Up to 8" Dia. Logs 3500 M-12 Ford "300" Torque Converter Up to 8" Dia. Logs 3550 M-13 Ford "330" V8 Clutch Up to 8" Dia. Logs 3675 TRAILER UNITS -- SERIES 160 (16 INCH) Total Approximate Pounds Shipping Model Engine Drive Chipping Capacity Weight M-6 Ford "240" Torque Converter Up to 6" Dia. Logs 3700 M-7 Ford "300" Clutch Up to 8" Dia. Logs 3675 M-8 Ford "300" Torque Converter Up to 8" Dia. Logs 3725 M-9 Ford "330" V8 Clutch Up to 8" Dia. Logs 3825 All trailers are equipped with tires, fenders, taillight, license plate holder, rear support jack, covered tool box, covered battery box, choice of ball or pintle eye hitch on telescopic draw bar, and adjustable front landing wheel. Machines are painted with prime coating plus hi-gloss enamel with color choice optional. WARRANTY Parts -- One year; Service Adjustments -- 90 days: Purchased parts are subject to original manufacturers guarantees. Mitts & Merrill reserves the right to discontinue the manufacturer of any model, to redesign and to add improvements to existing models without incurring any obligation to install same on products previously furnished. . . . then note how many features are exclusive with Mitts & Merrill Brush Chippers Mitts & Merrill General Brush Chipper Specifications Specifications Trailer frame All tubular steel, welded construction Suspension * Coil spring, torsion type Feed chute * Swing-away type Cutting chamber cover Hinged type Cylinder * 16-inch diameter, dynamically balanced with staggered knife design Cylinder material Flame cut steel plate RPM of cylinder 2,800 to 3,000 Type of knife * Self-adjusting, double-edged, positive-lock type Diameter of shaft 3 inches Feed opening * 10-inch by 12-inch, or 10-inch by 16-inch Bearings 2-15/16 inch diameter, single row, piloted and flange mounted Flywheel * Unnecessary Power Ford 172, 240, 300 or 330 cubic-inch displacement Drive * Torque converter or clutch Blower Standard equipment |
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ID: ConductorsAlliancedrnOpen
Mr. Robert Strassburger Dear Mr. Strassburger: This responds to your letter (Docket 15712-9) asking us to reevaluate the November 26, 2002, and July 23, 2003, interpretation letters that we issued to Mr. Larry Costa of Costa Industries, concerning whether Federal Motor Vehicle Safety Standard (FMVSS) No. 205, as amended on July 25, 2003 (68 FR 43964)(Docket No. 15712), further amended September 26, 2003 (68 FR 55544), January 5, 2004 (69 FR 279), August 18, 2004 (69 FR 51188), and July 12, 2005 (70 FR 39959), requires glazing fracture testing to be conducted with conductors or any other components attached. We have developed the enclosed paper, "The Definition of Conductor in Fracture, Test 7 of ANSI/SAE Z26.1-1996, Incorporated by Reference into FMVSS No. 205". This paper clarifies the meaning of "conductors" and "terminals" and distinguishes between the terms. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Enclosure The Definition of "Conductor" in "Fracture, Test 7" of ANSI/SAE Z26.1-1996,
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2006 |
ID: ConductorsDaimlerChryslerdrnOpen
Stephan P. Speth, Director Dear Mr. Speth: This responds to your letter (Docket 15712-3) asking us to reevaluate the November 26, 2002 and July 23, 2003 interpretation letters that we issued to Mr. Larry Costa of Costa Industries, concerning whether Federal Motor Vehicle Safety Standard (FMVSS) No. 205, as amended on July 25, 2003 (68 FR 43964)(Docket No. 15712), further amended September 26, 2003 (68 FR 55544), January 5, 2004 (69 FR 279), August 18, 2004 (69 FR 51188), and July 12, 2005 (70 FR 39959), requires glazing fracture testing to be conducted with conductors or any other components attached. We have developed the enclosed paper, "The Definition of Conductor in Fracture, Test 7 of ANSI/SAE Z26.1-1996, Incorporated by Reference into FMVSS No. 205". This paper clarifies the meaning of "conductors" and "terminals" and distinguishes between the terms. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Enclosure The Definition of "Conductor" in "Fracture, Test 7" of ANSI/SAE Z26.1-1996,
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2006 |
ID: ConductorsGeneralMotorsdrnOpen
Lou Carlin, Director Dear Mr. Carlin: This responds to your letter (Docket 15712-5) asking us to reevaluate the November 26, 2002 and July 23, 2003, interpretation letters that we issued to Mr. Larry Costa of Costa Industries, concerning whether Federal Motor Vehicle Safety Standard (FMVSS) No. 205, as amended on July 25, 2003 (68 FR 43964)(Docket No. 15712), further amended September 26, 2003 (68 FR 55544), January 5, 2004 (69 FR 279), August 18, 2004 (69 FR 51188), and July 12, 2005 (70 FR 39959), requires glazing fracture testing to be conducted with conductors or any other components attached. We have developed the enclosed paper, "The Definition of Conductor in Fracture, Test 7 of ANSI/SAE Z26.1-1996, Incorporated by Reference into FMVSS No. 205". This paper clarifies the meaning of "conductors" and "terminals" and distinguishes between the terms. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Enclosure The Definition of "Conductor" in "Fracture, Test 7" of ANSI/SAE Z26.1-1996,
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2006 |
ID: ConductorsPilkingtondrnOpen
Joseph E. Poley, Senior Research Associate Dear Mr. Poley: This responds to your letter (Docket 15712-4) asking us to reevaluate the November 26, 2002 and July 23, 2003 interpretation letters that we issued to Mr. Larry Costa of Costa Industries, concerning whether Federal Motor Vehicle Safety Standard (FMVSS) No. 205, as amended on July 25, 2003 (68 FR 43964)(Docket No. 15712), further amended September 26, 2003 (68 FR 55544), January 5, 2004 (69 FR 279), August 18, 2004 (69 FR 51188), and July 12, 2005 (70 FR 39959), requires glazing fracture testing to be conducted with conductors or any other components attached. We have developed the enclosed paper, "The Definition of Conductor in Fracture, Test 7 of ANSI/SAE Z26.1-1996, Incorporated by Reference into FMVSS No. 205". This paper clarifies the meaning of conductors and terminals and distinguishes between the terms. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Enclosure The Definition of "Conductor" in "Fracture, Test 7" of ANSI/SAE Z26.1-1996,
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2006 |
ID: ConductorsPPGdrnOpen
John P. Banks, Director Dear Mr. Banks: This responds to your letter (Docket 15712-6) asking us to reevaluate the November 26, 2002 and July 23, 2003 interpretation letters that we issued to Mr. Larry Costa of Costa Industries, concerning whether Federal Motor Vehicle Safety Standard (FMVSS) No. 205, as amended on July 25, 2003 (68 FR 43964)(Docket No. 15712), further amended September 26, 2003 (68 FR 55544), January 5, 2004 (69 FR 279), August 18, 2004 (69 FR 51188), and July 12, 2005 (70 FR 39959), requires glazing fracture testing to be conducted with conductors or any other components attached. We have developed the enclosed paper, "The Definition of Conductor in Fracture, Test 7 of ANSI/SAE Z26.1-1996, Incorporated by Reference into FMVSS No. 205."This paper clarifies the meaning of "conductors" and "terminals" and distinguishes between the terms. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Stephen P. Wood Enclosure The Definition of "Conductor" in "Fracture, Test 7" of ANSI/SAE Z26.1-1996,
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2006 |
ID: nht95-7.3OpenTYPE: INTERPRETATION-NHTSA DATE: September 25, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Winston Sharples -- President, Cantab Motors, Ltd. TITLE: NONE ATTACHMT: NONE TEXT: Dear Mr. Sharples I enclose a copy of an order of the Administrator granting the petition by Cantab Motors for temporary exemption from Motor Vehicle Safety Standards Nos. 208 and 214. The exemption from Standard No. 208 will expire on September 1, 1997, and that for Standard No. 214 on September 1, 1998. In accordance with agency regulations on the subject, within 30 days after your receipt of this letter please provide the Director, Office of Vehicle Safety Compliance, with a copy of the certification label reflecting the exemption that will be used on Cantab's vehicles (49 CFR 555.9(a)). We have received your letter of August 17, 1995, which admits that Cantab manufactured and sold nine vehicles manufactured after the expiration of its previous exemption that did not conform with Standard No. 208, and which enclosed a petition for a determination of inconsequentiality on this matter. This is currently under review. If you have any questions, you may discuss them with Taylor Vinson of this Office (202-366-5263). Enclosure ACTION: Issuance of Federal Register Notice Granting Cantab's Petition for Temporary Exemption From Standards Nos. 208 and 214 John Womack (K. WEINSTEIN) Acting Chief Counsel Barry Felrice Associate Administrator for Safety Performance Standards Attached for your signature is a Federal Register notice granting the petition by Cantab Motors for a temporary exemption from the automatic restraint requirements of Standard No. 208, and the side impact protection requirements of Standard No. 214. The basis of the grant is that compliance would cause substantial economic hardship to a manufacturer that has tried in good faith to meet the standards. Cantab imports shells of Morgan sports cars from England, and installs propane engines and drive trains in the US; for this reason, we consider Cantab rather than Morgan as the manufacturer. In the year preceding the filing of its exemption petition it produced only 9 such cars. It has cumulative net losses approaching $ 93,000 for the last three fiscal years. It has been working with Morgan to develop vehicles that will be equipped with airbags meeting Standard No. 208, and provide side impact protection meeting Standard No. 214. Because the components that must be modified for conformance are under the control of Morgan rather than Cantab, the company is dependent upon Morgan's efforts. Cantab asked for only a 2-year exemption from Standard No. 208, indicating that it is optimistic that its cars will conform in less than the 3 years it could have asked for. However, it appears to require the full 3 years for Standard No. 214. Any threat to safety that would be presented by an exempted vehicle would be minimal because they are few in number, and are represented as conforming to earlier versions of the two standards. No comments were received on the application. Attachment DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration Docket No. 95-53; Notice 2 Cantab Motors, Ltd. Grant of Application for Temporary Exemption From Federal Motor Vehicle Safety Standards No. 208 and 214 Cantab Motors, Ltd., of Round Hill, Va., applied for a temporary exemption of two years from paragraph S4.1.4 of Federal Motor Vehicle Safety Standard No. 208 Occupant Crash Protection, and for three years from Federal Motor Vehicle Safety Standard No. 214 Side Impact Protection. The basis of the application was that compliance will cause substantial economic hardship to a manufacturer that has tried to comply with the standard in good faith. Notice of receipt of the application was published on July 14, 1995, and an opportunity afforded for comment (60 FR 36328). The make and type of passenger car for which exemption was requested is the Morgan open car or convertible. Morgan Motor Company ("Morgan"), the British manufacturer of the Morgan, has not offered its vehicle for sale in the United States since the early days of the Federal motor vehicle safety standards. In the nine years it has been in business, the applicant has bought 35 incomplete Morgan cars from the British manufacturer, and imported them as motor vehicle equipment, completing manufacture by the addition of engine and fuel system components. They differ from their British counterparts, not only in equipment items and modifications necessary for compliance with the Federal motor vehicle safety standards, but also in their fuel system components and engines, which are propane fueled. As the party completing manufacture of the vehicle, Cantab certifies its conformance to all applicable Federal safety and bumper standards. The vehicle completed by Cantab in the U.S. is deemed sufficiently different from the one produced in Britain that NHTSA considers Cantab the manufacturer, not a converter, even though the brand names are the same. Morgan itself produced 478 cars in 1994, while in the year preceding the filing of its petition in June 1995, the applicant produced 9 cars for sale in the United States. Since the granting of its original exemption in 1990, Cantab has invested $ 38,244 in research and development related to compliance with Federal safety and emissions standards. The applicant has experienced a net loss in each of its last three fiscal (calendar) years, with a cumulative net loss for this period of $ 92,594. Application for Exemption from Standard No. 208 Cantab received NHTSA Exemption No. 90-3 from S4.1.2.1 and S4.1.2.2 of Standard No. 208, which expired May 1, 1993 (55 FR 21141). When this exemption was granted in 1990, the applicant had concluded that the most feasible way for it to conform to the automatic restraint requirements of Standard No. 208 was by means of an automatically deploying belt. In the period following the granting of the exemption, Morgan and the applicant created a mock-up of the Morgan passenger compartment with seat belt hardware and motor drive assemblies. In time, it was determined that the belt track was likely to deform, making it inoperable. The program was abandoned, and Morgan and Cantab embarked upon research leading to a dual airbag system. According to the applicant, Morgan tried without success to obtain a suitable airbag system from Mazda, Jaguar, Rolls-Royce and Lotus. As a result, Morgan is now developing its own system for its cars, and "[as] many as twelve different sensors, of both the impact and deceleration (sic) type, have been tested and the system currently utilizes a steering wheel from a Jaguar and the Land Rover Discovery steering column." Redesign of the passenger compartment is underway, involving knee bolstering, a supplementary seat belt system, antisubmarining devices, and the seats themselves. Morgan informed the applicant on May 2, 1995, that it had thus far completed 10 tests on the mechanical components involved "and are now carrying out a detailed assessment of air bag operating systems and columns before we will be in a position to undertake the full set of appropriate tests to approve the installation in our vehicles." Application for Exemption from Standard No. 214 Concurrently, Morgan and the applicant have been working towards meeting the dynamic test and performance requirements for side impact protection, for which Standard No. 214 has established a phase-in schedule. Although Morgan fits its car with a dual roll bar system specified by Cantab, and Cantab installs door bars and strengthens the door latch receptacle and striker plate, the system does not yet conform to the new requirements of Standard No. 214, and the applicant has asked for an exemption of three years. It does, however, meet the previous side door strength requirements of the standard. Were the phase-in requirement of S8 applied to it, calculated on the basis of its limited production, only very few cars would be required to meet the standard. Safety and Public Interest Arguments Because of the small number of vehicles that the applicant produces and its belief that they are used for pleasure rather than daily for business commuting or on long trips, and because of the three-point restraints and side impact protection currently offered, the applicant argued that an exemption would be in the public interest and consistent with safety. It brought to the agency's attention two recent oblique front impact accidents at estimated speeds of 30 mph and 65 mph respectively in which the restrained occupants "emerged unscathed." Further, the availability "of this unique vehicle . . . will help maintain the existing diversity of motor vehicles available to the U.S. consumer." Finally, "the distribution of [this] propane-fueled vehicle has contributed to the national interest by promoting the development of motor systems by using alternate fuels." No comments were received on the application. In adding only engine and fuel system components to incomplete vehicles, the applicant is not a manufacturer of motor vehicles in the conventional sense. It does not produce the front end structural components, instrument panel, or steering wheel, areas of the motor vehicle whose design is critical for compliance with the airbag requirements of Standard No. 208. These are manufactured by Morgan, and the applicant is necessarily dependent upon Morgan to devise designs that will enable conformance with Standard No. 208. The applicant has been monitoring Morgan's progress, and that company is engaging in testing and design activities necessary for eventual conformance. The fact that the applicant is requesting only a two-year exemption, rather than three, indicates its belief that complying operator and passenger airbags will at last be fitted to its cars by the end of this period. Similarly, the applicant is dependent upon the structural design of its vehicle for compliance with Standard No. 214. As with Standard No. 208, Morgan and the applicant are working towards conformance, though apparently it will not be achieved within two years. In both instances, however, the applicant is conscious of the need to conform and has been taking steps to accomplish it. Although the company's total expenditure of $ 38,244 in the last five years to meet emission and safety requirements is low, the small number of cars produced for sale in the United States in the last year, nine, would not make available substantial funds to the company, and its cumulative net losses of $ 92,594 indicate an operation whose financial existence is precarious. Applicant's cars are equipped with manual three-point restraint systems and comply with previous side impact intrusion requirements. Because applicant produces only one line of vehicles, it cannot take advantage of the phase-in requirement. Given the existing level of safety of the vehicles and the comparatively small exposure of the small number of them that would be produced under an exemption, there would appear to be an insignificant risk to traffic safety by providing an exemption. The public interest is served by maintaining the existence of small businesses and by creating awareness of alternative power sources. In consideration of the foregoing, it is hereby found that to require immediate compliance with Standards Nos. 208 and 214 would cause substantial economic hardship to a manufacturer that has in good faith attempted to meet the standards, and that an exemption would be in the public interest and consistent with the objectives of traffic safety.
Accordingly, the applicant is hereby granted NHTSA Exemption No. 95-2, from paragraph S4.1.4 of 49 CFR 571.208 Motor Vehicle Safety Standard No. 208 Occupant Crash Protection, expiring September 1, 1997, and from 49 CFR 571.214 Motor Vehicle Safety Standard No. 214 Side Impact Protection, expiring September 1, 1998. (49 U.S.C. 30113; delegation of authority at 49 CFR 1.50) Issued on SEP 7 1995 Ricardo Martinez, M.D. Administrator BILLING CODE: 4910-59-P |
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ID: 571.108--NCC-230201-001 LED Headlights_ M. BakerOpenFebruary 13, 2024 Mr. Mark Baker, B.S.E.E. Soft Lights 9450 SW Gemini Drive PMB 44671 Beaverton, OR 97008 mbaker@softlights.org Dear Mr. Baker: This responds to your letter and email dated June 27, 2021 and October 31, 2021, respectively, regarding the legal status and safety of motor vehicle headlamps that use light-emitting diode (LED) technology as the light source. Please note that our answer below is based on our understanding of the specific information provided in your letter and email. You ask about the “legality of LED headlights.” You state your belief that Federal Motor Vehicle Safety Standard (FMVSS) No. 108 does not regulate “peak luminance, absolute spectral power distribution or flicker” and that the standard “only applies to spherical emitters such as tungsten- filament and gas-discharge and is not applicable to non-uniform luminance flat-source emitters such as LED chips.” You ask whether it is “NHTSA’s position that FMVSS No. 108 is only applicable to uniform luminance emitters which can be regulated by setting maximums for luminous intensity without the need of setting peak luminance maximums” and whether “NHTSA [has] approved the use of spatially heterogeneous visible radiation for use as the light source used in vehicle headlights.” You state your concerns about adverse health impacts due to the performance characteristics of LEDs, such as high peak luminance, high-color temperature, high-energy blue wavelength light, and flicker. You request NHTSA’s opinion about the “sufficiency” of FMVSS No. 108 regarding these health concerns. We understand you to use “uniform luminance emitters” to refer to filament (halogen/tungsten) and high-intensity discharge (HID) light sources, and “non-uniform” or “heterogenous emitter” to refer to LED light sources. We therefore understand you to be asking whether LEDs are legal as a light source in motor vehicle headlamps under FMVSS No. 108, and, if they are legal, what is NHTSA’s position on the safety of LED light sources in headlamps with respect to “eye safety, mental safety, and visual performance.” Background NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue FMVSS that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety-related defects. FMVSS No. 108, “Lamps, reflective devices, and associated equipment,” applies to “[p]assenger cars, multipurpose passenger vehicles, trucks, buses, trailers (except pole trailers and trailer converter dollies), and motorcycles” and covers, among other things, “original and replacement lamps, reflective devices, and associated equipment” for motor vehicles. The standard specifies performance requirements for headlamps. The most common types of headlamps are integral beam (S10.14) and replaceable bulb (S10.15, S11) headlamps. NHTSA has stated that LED light sources are permitted as part of an integral beam headlamp if they are wired in series such that a failure of one LED would cause all the LEDs to cease functioning, and they otherwise comply with all relevant FMVSS.1 Paragraph S4 of FMVSS No. 108 defines an integral beam headlamp as “a headlamp … comprising an integral and indivisible optical assembly including lens, reflector, and light source, except that a headlamp conforming to paragraph S10.18.8 or paragraph S10.18.9 may have a lens designed to be replaceable.” The standard does not contain performance requirements for a light source that is part of an integral beam headlamp, but instead specifies performance requirements for the complete headlamp. These include (among other things) photometry, through minimum and maximum candela at specified test points,2 color, which must remain within specified boundaries,3 and that the headlamp be steady burning.4 While LED light sources that are part of an integral beam headlamp are permitted as noted above, no LED light source is currently permitted to be used in a replaceable bulb headlamp. FMVSS No. 108 contains specific requirements for the replaceable light sources (i.e., bulbs) used in replaceable bulb headlamps. These requirements are intended to support light source interchangeability. Paragraph S11 of the standard requires that “[e]ach replaceable light source must be designed to conform to the dimensions and electrical specifications furnished with respect to it pursuant to part 564 of this chapter[.]”5 Part 564 requires that replaceable bulb manufacturers submit to NHTSA for review and acceptance various design specifications for the bulb. If accepted, this design information is then placed in a publicly available docket to facilitate the manufacture and use of those light sources. As of the date of this letter, no submission that includes LEDs as the light source for a replaceable bulb headlamp has been listed in the docket. Therefore, no LED replaceable light source may be used in a replaceable bulb headlamp. Discussion Pursuant to FMVSS No. 108, paragraphs S4 and S10.14, LEDs are allowed to be used as a light source in integral beam headlamps as long as the headlamp conforms to all applicable headlamp requirements in FMVSS No. 108. However, LEDs are not currently permitted in a replaceable bulb headlamp. Nevertheless, illegal LED headlamp replaceable light sources may be available for purchase on the internet, and although these lights do not conform to the requirements of FMVSS No. 108, some consumers purchase and install these LED light sources in their replaceable bulb headlamps. While NHTSA regulates the manufacture and sale of light sources, it generally does not regulate the modifications individuals make to their own vehicles. It is therefore left to State law to address installation of an LED replaceable light source in a headlamp. FMVSS No. 108 does not directly regulate what you describe as peak luminance as measured in nits or the spectral power distribution of the headlamp light source. However, this is indirectly regulated through the headlamp performance requirements, such as the photometry and chromaticity requirements. Additionally, flicker is regulated through the requirement that lower beam headlamps be steady burning. We also note that, although FMVSS No. 108 requires that the light emitted by headlamps be white, the permissible boundary of white includes colors that may be perceived by the human eye as white with a yellow tint and white with a blue tint.6 In your communications, you raise concerns about the health impacts of LED headlamps. We are aware of concerns raised about possible adverse effects of certain LED devices, particularly as used in street lighting that emits excess blue light.7 NHTSA’s focus is on automotive safety, but the agency recognizes that separate expertise resides in sister agencies that are health-focused, such as the Food and Drug Administration. I hope this information is helpful. If you have any further questions, please feel free to contact Eli Wachtel of my staff at this address or at (202) 366-2992. Sincerely, John Donaldson
2 Photometry requirements for headlamp systems can be found in FMVSS No. 108, Tables XVIII and XIX. 3 See FMVSS No. 108, Table I-a (headlamp color). Chromaticity requirements are pursuant to FMVSS No. 108 S14.4. 4See FMVSS No. 108 Tables I-(a and c). NHTSA has stated that “steady burning” means “light that is essentially unvarying in intensity.” See Letter from Frank Berndt, Chief Counsel, NHTSA, to United Sidecar Association, Inc. (Feb. 9, 1982). A device may fail to meet this requirement where the driver “would not see a signal that was consistent or reliable in its meaning.” See Letter from Paul Jackson Rice, Chief Counsel, NHTSA, to Bob Abernathy, Idea’s Inc. (Sept. 7, 1990) (applying steady burning in a taillamps context). In the context of a modulating motorcycle headlamp, we have stated that “there is no failure to conform if the modulating light from the lamp is perceived to be a steady beam.” Letter from John Womack, Acting Chief Counsel, NHTSA, to Joe De Sousa (March 10, 1994). 5 See Letter from John Womack, Acting Chief Counsel, NHTSA, to Nancy Tavarez, Beitrix Industries (Aug. 30, 1995) (clarifying application of Part 564 to replaceable headlamp bulbs). 6 Letter from Frank Seales, Jr., Chief Counsel, NHTSA, to Richard Hodson, (July 4, 2000) (stating that “SAE J578c defines white by blue, yellow, green, red, and purple boundaries within a chromaticity diagram. Thus, it is possible to design a headlamp that emits a light that approaches the blue boundary and is perceived as having a blue tint but which nevertheless remains within the boundaries that define "white." These headlamps would comply with the color requirements of Standard No. 108.”). 7 See “AMA adopts guidance to reduce harm from high intensity street lights,” American Medical Association, June 14, 2016, available at https://www.ama-assn.org/press-center/press-releases/ama-adopts-guidance-reduce-harm-high- intensity-street-lights. |
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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.