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: aiam1481OpenMr. William J. Cicero, Supt. of Maintenance, Triboro Coach Corporation, 85-01 24th Avenue, Jackson Heights, NY 11369; Mr. William J. Cicero Supt. of Maintenance Triboro Coach Corporation 85-01 24th Avenue Jackson Heights NY 11369; Dear Mr. Cicero: This is in reply to your letter of April 4, 1974, concerning you request for an exemption from the roof emergency exit requirements (S5.2.1) of Motor Vehicle Safety Standard No. 217 (49 CFR 571.217). We had denied an earlier request on March 27, 1974 following your letter to us of February 13, 1974.; We must again deny your request. The Federal motor vehicle safet standards which apply to motor vehicles (some apply to equipment only) specify safety requirements which apply to vehicle types generally (passenger cars, trucks, buses, etc.) and must of necessity be based on the use to which such vehicle types are generally put. The NHTSA has determined through the administrative rulemaking process that buses, including buses for use in urban environments, must have a roof emergency exit when a rear exit can not be installed due to the configuration of the bus. In most cases, including many urban situations, the roof exit can be an important safety feature, particularly when the bus is overturned on a side. While we do not dispute the facts you present, we view the situation as unusual, and not a suitable basis for modifying a requirement applicable to every urban bus. Our regulations do not permit exemptions from requirements for buses sold to one party.; However, under the National Traffic and Motor Vehicle Safety Act (1 U.S.C. SS1391 *et seq.*) under which Standard No. 217 is issued, a vehicle need not conform to a Federal motor vehicle safety standard after its sale to its ultimate user. Consequently there is no Federal prohibition to your modifying or eliminating the roof exits in these buses if you wish, after you receive them from the manufacturer.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3146OpenMr. Robert C. Schultz, 5115 N. Mulligan, Chicago, IL 60630; Mr. Robert C. Schultz 5115 N. Mulligan Chicago IL 60630; Dear Mr. Schultz: This is in response to your letter to the Secretary of Transportatio regarding the transportation of diesel fuel in the trunk of an automobile in plastic auxiliary tanks. You asked whether it is permissible to permanently install a plastic auxiliary diesel fuel tank in the trunk of a four door passenger car. You also noted the availability of 5.5 gallon plastic utility containers that can be used as auxiliary tanks. From your description I gather that these types of containers are not attached to the vehicle's fuel system.; From your letter I got the impression that you are asking whether an law administered by this agency would prohibit an individual from using either of these types of tanks in his private automobile. With respect to small tanks that are not connected to the automobile's fuel system, this agency administers no law that would prevent an individual from carrying such a tank in his automobile. However, please note that this is a very dangerous practice that can lead to fires and explosions potentially harmful or fatal not only to the driver and passengers of the vehicle carrying such a tank but also occupants of other nearby vehicles. I have enclosed a copy of a press release that the Department of Transportation issued this Spring, which describes the dangers associated with carrying gasoline, but which is also applicable to carrying diesel fuel. As noted in the press release this agency strongly discourages the use of portable fuel containers.; There is no law administered by this agency which would bar a individual from installing a plastic auxiliary fuel tank in his or her own automobile or from using such a tank once installed by the individual of by a commercial installer. However, there are legal obligations imposed by the statutes and regulations under which we operate that would apply to the manufacturers and installers of such tanks. Since I am unsure as the exact scope of your inquiry I will summarize these below.; The National Traffic and Motor Vehicle Safety Act, as amended 1974 (the Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue motor vehicle safety standards applicable either to entire vehicles or to equipment for installation in vehicles. Safety Standard No. 301-75, *Fuel System Integrity*, is a vehicle standard which applies to certain vehicles, including passenger cars, that use fuel with a boiling point above 32 degrees F. Under the standard's requirements, no part of a vehicle's entire fuel system can have fuel spillage beyond certain specified amounts during barrier crash tests. Specific performance requirements for individual components of the fuel system, such as the fuel tank, are not currently included in the standard. With the advent of high density polyethylene (plastic) fuel tanks, however, the current 'system' performance requirements might not be sufficient to ensure the integrity of vehicle fuel systems. For this reason, the agency has published an Advance Notice of Proposed Rulemaking concerning the advisability of establishing performance standards for plastic tanks (44 FR 33441, June 11, 1979, copy enclosed).; Despite the inapplicability of Safety Standard No. 301-75 to thei manufacture, auxiliary fuel tanks must be designed and manufactured for safety. A manufacturer of auxiliary fuel tanks, is subject to the defects responsibility provisions of the Act (sections 151 *et seq*.). Upon discovery of a safety-related defect by the Secretary of Transportation, the NHTSA Administrator, or the manufacturer itself, the manufacturer would be required to notify vehicle owners, purchasers, and dealers and remedy the defect.; If a manufacturer, distributor, dealer, or motor vehicle repai business installed an auxiliary fuel tank in a new vehicle, prior to its first purchase in good faith for purposes other than resale, that person or entity would be a vehicle alterer under NHTSA regulations. As an alterer, that person or entity would be required by 49 CFR 567.7 to affix an additional label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards--including Safety Standard No. 301-75. Should a noncompliance or safety- related defect be discovered in such a vehicle, as a result of the modification, the alterer would be required to notify vehicle owners, purchasers, and dealers and to remedy the defect.; If a manufacturer, distributor, dealer, or motor vehicle repai business installed an auxiliary gasoline tank in a used passenger vehicle, that person or entity would not be required to attach an alterer's label. However, section 108(a)(2)(A) of the Act would apply. Section 108(a)(2)(A) provides in relevant part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . .<<<; Thus, if one of the named entities added an auxiliary tank to a use passenger vehicle manufactured in compliance with Safety Standard No. 301-75 and other standards, and in the process knowingly rendered inoperative the compliance of the fuel system or another system, that person or entity would be in violation of section 108(a)(2)(A).; I hope that you will find this response helpful and have not bee inconvenienced by our delay in sending it to you. If you have any further questions please feel free to address them to Ms. Debra Weiner of my office (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4683OpenTracey Powell Legislative Coordinator Government Relations American Motorcyclist Association P.O. Box 6114 Westerville, OH 43081-6114; Tracey Powell Legislative Coordinator Government Relations American Motorcyclist Association P.O. Box 6114 Westerville OH 43081-6114; Dear Tracey Powell: This is in reply to your letter of November l4 l989, with respect to existing prohibitions in some States against the use of modulating headlamps on motorcycles. The apparent basis of the prohibition is that flashing lamps are generally reserved for emergency vehicles. You point out the distinction that Standard No. 108 makes between the two types of headlamps, and ask our 'assistance in attaining uniform recognition of the legal use of modulating headlights through the United States . . . .' As you note, there is a legal distinction in Standard No. 108 between a modulating headlamp (one that goes from a higher to a lower intensity within either the upper or lower beam) and a flashing one (one that goes from either the upper or lower beam to off). Further, section S5.6.1 of Standard No. 108 provides that 'A headlamp on a motorcycle may be wired to modulate.' The authority of States to regulate this aspect of motorcycle lighting is constrained by section l03(d) of the National Traffic and Motor Vehicle Safety Act (l5 U.S.C. 1392(d)). This section provides in pertinent part that: w henever a Federal motor vehicle safety standard . . . is in effect, no State. . . shall have any authority either to extablish, or to continue in effect, with respect to any motor vehicle. . . any safety standard applicable to the same aspect of performance of such vehicle. . . which is not identical to the Federal standard.' The effect of this provision of the Safety Act with respect to lighting is to expressly prohibit a State from enacting a law that forbids a manufacturer from installing headlamp modulators on motorcycles. I hope that this responds to your concerns. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam5138OpenMr. Robert A. Ernst Research Coordinator I-Car Tech Center 4 Systems Drive, Suite C Appleton, WI 54914; Mr. Robert A. Ernst Research Coordinator I-Car Tech Center 4 Systems Drive Suite C Appleton WI 54914; "Dear Mr. Ernst: This responds to your February 4, 1993, lette concerning possible legal obligations to repair an air bag system following a collision. You stated that your organization produces technical training for the automotive collision repair industry and has received a number of inquiries concerning this issue. Your specific questions are addressed below. Where two questions concern a common issue, they are addressed by a single response. 1. Are there Federal regulations which specifically direct the collision repair facility to restore the supplemental restraint system to an operable condition following a deployment on vehicles the facility repairs? 4. Can the vehicle be sold if the owner knows that the supplemental restraint is inoperable because of a previous deployment? I am enclosing a copy of a January 19, 1990, letter to Ms. Linda L. Conrad which addresses the issue of possible legal obligations to repair a deployed air bag following a collision. As explained in that letter, Federal law does not require replacement of a deployed air bag in a used vehicle. In addition, there is no Federal law that prohibits selling a used vehicle with a supplemental restraint that is inoperable because of a previous deployment. However, our agency strongly encourages dealers and repair businesses to replace deployed air bags whenever vehicles are repaired or resold, to ensure that the vehicles will continue to provide maximum crash protection for occupants. Moreover, a dealer or repair business may be required by state law to replace a deployed air bag, or be liable for failure to do so. 2. If repairs are deliberately made to mask the fact that the air bag system is inoperative, has the repair facility violated any applicable laws? Section S4.5.2 of Standard No. 208 requires a readiness indicator for an air bag system which is clearly visible from the driver's seating position. After an air bag is deployed, this indicator would show that the air bag system is not operative. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard. As explained in the Conrad letter enclosed, this provision does not impose an affirmative duty on a repair business to replace an air bag that was damaged in a crash. However, this section would prohibit the repair business from removing, disabling, or otherwise 'rendering inoperative' the readiness indicator. Any violations of this 'render inoperative' prohibition in the Safety Act would subject the violator to a potential civil penalty of up to $1,000 for each violation. 3. If the owner of the vehicle requests that the supplemental restraint not be restored to operational condition, is the owner of the repair facility or the vehicle liable for later injuries? Liability risk is a question of state law, not of Federal law. Therefore, a repair business should consult an attorney in its state about this question. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam2307OpenHonorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your recent letter forwarding a petition fro Gulf + Western Manufacturing Company for reconsideration of the bumper standard recently issued as Part 581 of Title 49 Code of Federal Regulations.; A number of requests for our view on the Gulf + Western petition hav been forwarded by members of Congress who have received copies of the Gulf + Western petition accompanied by a letter from Mr. James A. Graham.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Gulf + Western.; I assure you that Gulf + Western's comments and the informatio contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5568OpenRobert Charles Maltzahn, Esq. 418 Northwest Midland Building 401 Second Avenue South Minneapolis, MN 55401; Robert Charles Maltzahn Esq. 418 Northwest Midland Building 401 Second Avenue South Minneapolis MN 55401; "Dear Mr. Maltzahn: This responds to your request for an interpretatio whether Standard No. 115, Vehicle identification number - basic requirements or any other Federal Motor Vehicle Safety Standard (FMVSS) applies to your client's high pressure 'waterjet cutting and cleaning equipment' manufactured as a mobile trailer. As explained below, the answer is no. Your letter describe your client's product as 'manufactured for use in the construction industry for hydrodemolition and cleaning and for industrial use.' The letter states the equipment is mobile to facilitate towing from site to site, but is 'not used primarily on the roadways and highways of the United States.' In a telephone conversation with Dorothy Nakama of my staff, you explained that the length of time the equipment is at a job site depends on the task. The equipment could be at a ship cleaning site for over a year, or at a hydrodemolition site for five days. You stated that the equipment very rarely stays at a job site for less than a week. The FMVSS's apply only to 'motor vehicles,' within the meaning of 49 U.S.C. 30102(a)(6). That section defines 'motor vehicle' as: a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways, but does not include a vehicle operated only on a rail line. Whether the agency considers your trailer to be a motor vehicle depends on its use. It is the agency's position that this statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. In contrast are instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time. Such vehicles are considered motor vehicles for purposes of the Safety Act, since the on-highway use is more than 'incidental.' Based on your description, it appears that your client's equipment is not a motor vehicle. This is because the equipment appears to stay on job sites for extended periods of time (ranging from a week to over a year). Therefore, your client's equipment need not meet Standard No. 115, or any other FMVSS. I note that, if the agency were to receive additional information indicating that your trailer used the roads more than on an incidental basis, then the agency would reassess this interpretation. I hope this information is helpful. If you have any questions, please contact Dorothy Nakama at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0290OpenMr. Howard R. Moore, Jr., Kelly Springfield Tire Company, Cumberland, MD 21502; Mr. Howard R. Moore Jr. Kelly Springfield Tire Company Cumberland MD 21502; Dear Mr. Moore: This is in reply to your letter of February 2, 1971, concerning Par 574 - Tire Identification and Record Keeping regulations and to confirm that the date code may be placed at the end of the tire identification number by means of a screw as depicted in the sketch attached to your letter.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5092OpenMr. Mike Love Manager, Compliance Porsche Cars North America, Inc. P. O. Box 30911 Reno, Nevada 89520-3911; Mr. Mike Love Manager Compliance Porsche Cars North America Inc. P. O. Box 30911 Reno Nevada 89520-3911; "Dear Mr. Love: This responds to your request that NHTSA determine tha a proposed modification to a previously approved antitheft device on the Porsche 911 car line constitutes a de minimis change to the device. The change is proposed to be made on only one model in the 911 line and to be effective beginning with the 1994 model year (MY). As explained below, the agency concludes that the proposed change to the antitheft device is not a de minimis change. As you are aware, in a Federal Register notice of June 2, 1989 (54 FR 23727), NHTSA determined that the antitheft device, to be placed as standard equipment on the MY 1990 Porsche 911 car line, was likely to be as effective as parts marking. Subsequently, by letter dated May 31, 1990, the agency concluded that proposed changes to the antitheft device in the MY 1991 Porsche 911 car line were de minimis changes. The primary change for the 1991 model year was that the interior light control units were to be integrated with the alarm control unit and central locking system. The latter two components were already integrated. For the following reasons, NHTSA concludes that the proposed change to the antitheft device for the 1994 model year is not de minimis. In reaching this conclusion, we looked primarily at the anti-theft system on which the exemption was originally based. Under the original system, locking one door would automatically lock all doors, as well as arm the alarm system. Under the proposed change, locking one door with the key would no longer automatically lock all doors, but would still arm the alarm system. This is not an insignificant change like the substitution of new components for old components, each serving the same function. Nor does the change involve adding a feature making an exempted antitheft device even more effective. The change in question lessens the likelihood that all doors of a car will be locked, thus easing a thief's access to the passenger compartment. A thief may easily open the unlocked door, providing an opportunity to attempt to shut off the alarm system (since both the alarm control unit and the power lines from the battery to the alarm system are inside the vehicle) and to circumvent the engine disabling system. If the thief successfully overcomes these systems, theft of the entire vehicle or its parts is facilitated. Once inside the vehicle, a thief may open the hood by a release in the vehicle interior, thereby gaining access to the storage space under the hood. Since the battery for the Porsche 911 is also located in the front hood compartment of the vehicle, access to the battery also makes it easier for a thief to attempt to shut off the alarm system and engine disabling system, again facilitating theft of the entire vehicle or its parts. Because the same aspects of performance (i.e., the central door locking system that automatically locked all doors, making access to the vehicle interior and hood release more difficult), are not provided in the proposed device, resulting in the possibility of the vehicle's increased vulnerability to being stolen in whole, or to have its parts stolen, this agency concludes that Porsche's proposed modification to the antitheft device in one model in the MY 1994 911 car line is not a de minimis change. If Porsche wishes to place its proposed antitheft device on the 911 car line, it must formally file a petition with NHTSA pursuant to 49 CFR 543.9(c)(2). Please note that the petition for a modification must provide the same information for the modified device as is required under 543.6 for a new device. This includes the statement in 543.6(a)(1) that the antitheft device will be installed as standard equipment on all cars in the line for which an exemption is sought. Since the modification planned by Porsche would result in one model within the car line lacking a feature found on the anti-theft systems of other models, the agency would determine in the following manner whether the car line continued to merit exemption. It would regard the system of the one model as the system of the car line as a whole and assess whether that system would be as effective in preventing theft as parts marking. The additional feature on the other models within the car line, i.e., the central locking system, would be regarded as an addition to the standard equipment system and would not have any bearing upon the exemptability of the car line. NHTSA notes that this same approach would not be taken if the system to be installed on a single model within a car line could not be regarded as a stripped down version of the system on the other models. In that case, there would be no standard equipment version of the system and the car line would not be eligible for an exemption. If you have any questions, please contact Ms. Barbara A. Gray, Chief, Motor Vehicle Theft Division, Office of Market Incentives, Office of Rulemaking, NHTSA, at this address or by telephone at (202) 366-1740. Sincerely, Barry Felrice Associate Administrator for Rulemaking"; |
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ID: aiam2757OpenMr. R. C. Evans, Vice President, O Sullivan Corporation, P.O. Box 603, Winchester, VA 22601; Mr. R. C. Evans Vice President O Sullivan Corporation P.O. Box 603 Winchester VA 22601; Dear Mr. Evans: This is in reply to your letter of February 3, 1978, to Mr. Guy Hunte of my staff, requesting assignment of a DOT' code number for purposes of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, *Glazing Materials*. You state that you supply vinyl plastic sheeting to your customer who, in turn, laminates and polishes this sheeting for use as glazing in the rear window opening of convertibles.; Under paragraph S6 of FMVSS No. 205 (a copy was previously mailed t you), the assignment of a code number is restricted to prime glazing material manufacturers. Prime glazing material manufacturers are those who either fabricate, laminate, or temper the glazing material. Since you merely supply the material to your customer who then laminates and polishes it for use as glazing, you are not considered the prime manufacturer and assignment of a code number to you is not appropriate. Your customer is the prime manufacturer in this case and it is his responsibility to certify that his glazing meets the requirements by the means specified in FMVSS No. 205.; If I can be of further help, do not hesitate to contact me. Sincerely, E. T. Driver, Acting Associate Administrator for Rulemaking |
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ID: aiam3845OpenMr. Donald M. Schwentker, Schnader, Harrison, Segal & Lewis, Suite 1100, 900 Seventeenth Street, N.W., Washington, D.C. 20006; Mr. Donald M. Schwentker Schnader Harrison Segal & Lewis Suite 1100 900 Seventeenth Street N.W. Washington D.C. 20006; Dear Mr. Schwentker: This responds to your letter of May 9, 1984, concerning the applicatio of Standard No. 208, *Occupant Crash Protection*, and Standard No. 209, *Seat Belt Assemblies*, to an emergency locking retractor designed by one of your clients. The following discussion addresses the application of those standards to the retractor.; You explained that the purpose of the new emergency locking retracto (ELR) is to facilitate the securing of a child restraint in a vehicle. The ELR would only be installed in forward-facing passenger seating positions. The new ELR is designed so if the belt is pulled all the way out of the retractor, the ELR will convert into an automatic locking retractor (ALR). Once all but 1393-1493 mm of the belt retracts, the retractor will revert automatically to the ELR mode.; You further explained that the continuous loop lap and upper torso bel used with this retractor is 380 mm longer than the belt system provided for the driver's seating position. You explained that the extra 380 mm of belt webbing is meant 'to permit normal occupant movement without inadvertent actuation of the ALR mode while still rendering it convenient for manual extension when the ALR mode is desired for child restraint use.'; You specifically asked whether the retractor designed by your clien would be considered an ELR for the purposes of S7.1.1 of Standard No. 208. In addition, you asked about the retractor durability tests of S5.2(k) of Standard No. 209. As a part of that test, a retractor is subjected to '45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension.' You asked whether, for the purposes of the section 5.2(k) test, the length of the driver's belt, which is 380 mm shorter than the passenger's belt, could be used to determine what constitutes 100 percent extension of the belt. You alternatively asked whether the test could be stopped before complete extension of the passenger belt.; As we understand your client's seat belt assembly, the amount o webbing in the driver's side assembly complies to the adjustment requirements of section 4.1(kg) of Standard No. 209. The 380 mm's of extra webbing that is included in the passenger's seat belt assembly has been voluntarily added as a precaution to reduce the possibility of an occupant inadvertently actuating the ALR mode of the retractor. Based on the information you have provided, it appears that in normal operation by occupants covered by the adjustment requirements of Standard No. 209 the retractor functions exclusively as an ELR and thus can be used to meet the requirements of S7.1.1 of Standard No. 208. The agency views the 380 mm's of extra webbing as a voluntary addition not required by the standard. Therefore, for the purpose of section 5.2(k) of Standard No. 209, the agency will use the length of the driver's belt to determine what constitutes full extension of the webbing.; Sincerely, Frank Berndt, Chief Counsel. |
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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.