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NHTSA Interpretation File Search

Overview

NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.

Understanding NHTSA’s Online Interpretation Files

NHTSA makes its letters of interpretation available to the public on this webpage.

An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.

Reasons interpretation letters in this database may not be applicable 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.

More search options

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

Displaying 5641 - 5650 of 16514

Interpretations	Date
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ID: aiam2914 Open James P. Bally, Esq., Messrs. Brownfield, Kosydar, Bowen, Bally & Sturtz, 140 East Town Street, Columbus, OH 43215; James P. Bally Esq. Messrs. Brownfield Kosydar Bowen Bally & Sturtz 140 East Town Street Columbus OH 43215; Dear Mr. Bally: We understand that you are interested in an interpretation of th relationsip (sic) of a rear lighting system, developed by your client Mr. Leno Bevilacqua, to Federal motor vehicle lighting requirements. As you described this device in your letter of September 29, 1978, to the Nevada Department of Highways:; >>>'The device will project a green light for the vehicle which woul be in a constant or accelerated speed, a yellow light for the vehicle in a decelerated moving state and a red light for the vehicle which would be stopping.'<<<; Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflectiv Devices, and Associated Equipment, (49 CFR 571.108) neither requires nor expressly prohibits a lighting device of this nature as original equipment on motor vehicles. One section of the standard, however, S4.1.3, prohibits the installation of all original lighting equipment not mandated by the standard 'that impairs the effectiveness of lighting equipment required by this standard.' While we make no judgment with respect to Mr. Bevilacqua's 18-inch long 1 1/2 inch high rectangular device, I think it important to note that the agency's research into rear green signal lights indicate that there may be disadvantages rather than advantages to such a lighting system. One major disadvantage is the problem of confusing the unfamiliar colored rear lamps in urban environments having multicolored lights.; Standard No. 108 does not cover this device as an aftermarket item, an it would therefore be subject to regulation by the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3606 Open Mr. Shizuo Suzuki, Nissan Motor Co., Ltd., Suite 707, 1919 Pennsylvania Avenue, N.W., P.O. Box 57105, Washington, DC 20037; Mr. Shizuo Suzuki Nissan Motor Co. Ltd. Suite 707 1919 Pennsylvania Avenue N.W. P.O. Box 57105 Washington DC 20037; Dear Mr. Suzuki: This responds to your request for an interpretation concerning Standar No. 101, Controls and Displays. You asked several questions concerning informational readout displays. The answers to your questions are as follows.; >>>1. If one type of information is displayed by an electr illuminating device such as a light-emitting diode, can I define this as an IRD?<<<; The answer to this question is yes. Section S4 of Standard No. 10 defines informational readout display as 'a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information or message may be displayed.' [Emphasis added.] Thus, the type of system you describe comes within Standard No. 101's definition of informational readout display. In reference to the specific wording of your question, I would note that it is the definition in the standard, rather than a particular characterization by the manufacturer, that is determinative as to whether a display is an informational readout display.; >>>2. Do you think that the description 'other electro illuminatin device' includes normal electric bulbs?<<<; The answer to this question is no. The requirements applicable t informational readout displays are an exception to the usual requirements for displays, which ordinarily use normal electric bulbs. The preamble to the final rule establishing the requirements of the present Standard No. 101 explained that the reason for the exception was to 'permit the continued development of informational readout displays.' 43 FR 27541, June 26, 1978. This was necessary since current technology does not enable manufacturers to produce informational readout displays which can exhibit symbols (as opposed to words) or certain colors. Thus, while section S5.2.3 of Standard No. 101 makes the use of certain symbols and colors mandatory for traditional displays, the use of symbols and colors is optional for informational readout displays.; If 'other electro illuminating device' was interpreted to includ normal electric bulbs, traditional displays would come within the definition of informational readout display. Such an interpretation would render meaningless Standard No. 101's requirements for the mandatory use of certain symbols and colors for displays. It is thus clear that the term 'other electro illuminating device' does not include normal electric bulbs. Rather, the term was included within the definition of informational readout display, along with light-emitting diodes and liquid crystals, to avoid preventing the use of new electronic technology other than light-emitting diodes and liquid crystals.; Your third and fourth questions both contemplate that the answer t your second question is yes, rather than no. In reference to your question as to why the agency amended Standard No. 101 to permit the use of green as an alternative to blue or blue-green for the headlamp high beam telltale, the reason is that the agency does not interpret the standard's definition of informational readout display to include a mere colored light using light-emitting diode technology. To be an informational readout display, it must include information in the form of words or symbols. Since such a colored light is not an informational readout display, it must meet the color requirements of Standard No. 101. On February 1, 1982, the agency published a notice in the Federal Register (47 FR 4541) which proposed, among other things, an interpretive amendment to the definition of informational readout display to make that point clear. We have enclosed a copy of that notice for your convenience.; Your fourth question suggests that the definition of informationa readout display should be interpreted to include only displays providing more than one type of information. As explained in the answer to your first question, such an interpretation would be inconsistent with the wording of the standard's definition of informational readout display. The agency recognizes, however, that it is likely that most if not all informational readout displays will include more than one type of information, though it is possible that some manufacturers might use LED or similar technology for displays providing only one type. In any event, the agency is not aware of a need to revise the standard's requirements to exclude displays presenting only one type of information from the definition of informational readout display.; >>>5. According to the current regulation, is it possible to integrat telltales with other instrument displays in an informational readout display?<<<; The light intensity requirements of Standard No. 101 currently preven informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section specifies that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; We would note, however, that the notice of proposed rulemaking referre to above proposes an amendment to Standard No. 101 that would permit informational readout displays to be used as telltales. The agency is in the process of analyzing the comments received in response to that notice.; Our answer to your fifth question also covers your sixth question. hope this fully responds to your inquiry.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1115 Open Mr. Mel Turner, Manager, Heavy Duty Division, Automotive Service Industry Association, 230 North Michigan Avenue, Chicago, IL 60601; Mr. Mel Turner Manager Heavy Duty Division Automotive Service Industry Association 230 North Michigan Avenue Chicago IL 60601; Dear Mr. Turner: This is in reply to your letter of March 26, 1973, to Mr. Georg Shifflett of my staff, enclosing a letter from Mr. I. Warren Simpson of Standard Parts Corporation. Mr. Simpson's questions, as amplified in a phone conversation we had with him following your suggestion, are restated below, and followed by our responses.; 1. When 'glyder kits' are installed, is the installer considered to b a manufacturer and therefore responsible for certification? (We understand 'glyder kits' to mean a cab with chassis, less power train and rear axle.); Whether a vehicle must be certified depends upon whether it is 'completed vehicle', as that term is defined in 49 CFR S 568.3 (Vehicles Manufactured in Two or More Stages), copy enclosed. If the installation of a glyder kit produces a 'completed vehicle', the installer must certify the vehicle, as specified in 49 CFR Parts 567, 568, as conforming to all applicable Federal Motor Vehicle Safety Standards.; In cases involving the refurbishing of a used chassis, the NHTS considers the refurbished vehicle to be a used vehicle, for which no certification is necessary. However, the implication from your letter is that a glyder kit installation involves a new chassis (only the rear axle and power train are used) and consequently the completed vehicle will be a new vehicle which must be certified.; There is also the possibility that a glyder kit, when installed, wil be an 'incomplete vehicle' (also defined in 49 CFR 568.3). An incomplete vehicle is not certified. Rather, its manufacturer prepares, and ships with it pursuant to Part 568, a document containing information on steps that the final-stage manufacturer must take in order to bring the vehicle, as completed, into conformity with applicable Federal standards.; 2. Are we required to know the first purchaser for purposes other tha resale (users) of the vehicle when we complete the vehicle for a dealer?; Section 113(f) of the National Traffic and Motor Vehicle Safety Act (1 USC 1402(f)) requires each manufacturer of motor vehicles to maintain records of the names and addresses of the first purchaser (other than a dealer and distributor) of motor vehicles produced by that manufacturer. In completing a vehicle for a dealer, you are the final-stage manufacturer of the vehicle, and are responsible for maintaining the names and addresses of first purchasers. The information can be obtained from the dealers for whom you complete vehicles.; 3. If the vehicles are involved in a 'defect notification' campaign ar we, as final-stage manufacturer (we install fifth wheels), required to participate?; Under the National Traffic and Motor Vehicle Safety Act, a manufacture of motor vehicles is responsible for notifying owners of vehicles that he manufacturers (sic). Usually, for multi-stage vehicles, the incomplete vehicle manufacturer will issue notification for defects covering those vehicle parts or components which he assembled or manufactured. Final stage manufacturers, like yourself, would do likewise. Under the Defect Notification regulations (49 CFR Part 577), if any one manufacturer who participates in the manufacture of a multi-stage vehicle conducts a notification campaign, the other manufacturers will not be required to do so. You may, however, be called upon to furnish to the manufacturer conducting the campaign the names and addresses of purchasers for vehicles you have completed.; 4. 'How can a distributor safely attach a fifth wheel? (Any fram failure is our liability since the OEM is very specific about neither, welding, drilling, or cutting the frame.)'; This agency is not in a position to give advice in this regard. Th problem should be worked out between the incomplete and final-stage manufacturer.; We are enclosing the following pertinent publications: >>>1. The National Traffic and Motor Vehicle Safety Act 2. Part 567, 'Certification', and Part 568, 'Vehicles Manufactured i Two or More Stages.'; 3. Part 573, 'Defect Reports.' 4. Part 577, 'Defect Notification.'<<< If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs;
ID: aiam3128 Open Mr. Kei Matsui, Toyo Kogyo Co. Ltd., P.O. Box 18, Hiroshima, 730-91 Japan; Mr. Kei Matsui Toyo Kogyo Co. Ltd. P.O. Box 18 Hiroshima 730-91 Japan; Mr. Matsui: This is in response to your letter of May 11, 1979, requesting th National Highway Traffic Safety Administration's (NHTSA) views on whether the inclusion of optional equipment on certain Mazda models would be sufficient to create a number of different series within that model.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree on commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line', denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; Based in the facts presented, it is apparent that models equipped wit different optional equipment could each be designed a 'series' if Mazda desired. Nonetheless, the definition of a 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If the difference between the potential series are superficial and a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam4317 Open Ms. Robin Bender Stevens, Health Policy and Planning Consultant, ECRI, 5200 Butler Pike, Plymouth Meeting, PA 19462; Ms. Robin Bender Stevens Health Policy and Planning Consultant ECRI 5200 Butler Pike Plymouth Meeting PA 19462; Dear Ms. Stevens: Thank you for your letter of March 26, 1987, asking several question about how our regulations on safety belts would apply to side and rear-facing seats in emergency medical vehicles. I hope the following discussion answers your questions.; You explained in your letter that most emergency medical vehicles hav a rear-facing seat that is typically located behind the driver's seat. The photographs you sent with your letter show that in one of the two vehicle designs you photographed, the rear-facing seat appears to be a typical vehicle seat, referred to as a 'captain's chair,' often used in a van-type vehicle. In the other emergency vehicle design show in your photographs, there is a rearward-facing, bench-type seat with a padded seat pan and back installed directly behind the driver.; You further explained that, depending on the number of stretchers th vehicle is designed to carry, there may be another seating area in the vehicle. In single-stretcher vehicles, there is a squad bench, which your photographs show is a set of storage compartments with a padded top, located next to the stretcher. You explained that emergency personnel may sit on the squad bench to attend the the(sic) patient while the vehicle is in motion. You further explained that personnel in dual-stretcher vehicles sit on the empty stretcher to attend to the patient. You said that use of a safety belt in those positions is too restrictive to allow emergency personnel to provide acute care to patients during transports.; Standard No. 208, Occupant Crash Protection, sets requirements fo the installation of occupant restraints in motor vehicles. The emergency medical vehicles shown in your photographs would be classified as multipurpose passenger vehicles under our regulations since they are designed to carry 10 or fewer persons and are built on a truck chassis. Standard No. 208 requires manufacturer of new multipurpose passenger vehicles to install a safety belt for each designated seating position. Part 571.3 of our regulations defines, impart, a designated seating position as:; >>>any plan view location capable of accommodating a person at least a large as 5th percentile female, if the overall seat configuration and design and vehicle design is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats.<<<; The agency considers the two types of rearward-facing seats in th emergency medical vehicles you photographed to be designated seating positions. Those seats are designed and built in the same manner as conventional vehicle seats in that they have a padded seat pan and a high padded seat back. In fact, the one seat appears to be a conventional 'captain's chair' which has been mounted in a rearward-facing position. The two rearward-facing seats are also designed to be used on a routine basis by an emergency medical personnel as the vehicle travels to its destination.; In contrast, the agency does not consider as squad bench or a stretche to be a designed or built in the same manner as a conventional vehicle seat. Although they have the equivalent of a seat pan, they do not have a seat back. Most importantly, both the squad bench and stretcher are meant to be used on a temporary basis as auxiliary seating position by emergency medical personnel as they provide treatment to a patient. Thus, as an auxiliary seating area, they would not be considered a designated seating position and therefore not subject to the safety belt installation requirement of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam1545 Open Mr. R. W. Hilderbrandt, Heavy Vehicle Systems Group, Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hilderbrandt Heavy Vehicle Systems Group Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hilderbrandt: This responds to your May 10, 1974, request for interpetation (sic) o the volume requirements for service brake chambers in S5.2.1.2 and S5.1.2.1 of Standard No. 121, Air Brake Systems:; >>>S5.1.2.1 The combined volume of all service reservoirs and suppl reservoirs shall be at least twelve times the combined volume of all service brake chambers at maximum travel of the pistons or diaphragms.<<<; You also requested that reservoir volume be based on manufacture 'rated volume' based on the designed volume of the reservoir.; In testing for compliance with S5.1.2.1 and S5.2.1.2, the NHTSA wil accept a manufacturer's published 'rated volume' of the brake chamber with the piston or diaphragm at maximum travel. This means that the manufacturer may specify the full stroke of the piston or diaphragm and compute the 'rated volume' based on the designed volume of the chamber and the full stroke he has established. This volume may be somewhat larger than 'nominal brake chamber displacement' which does not necessarily account for the void ahead of the relaxed diaphragm or piston, the so-called 'pre-fill volume.' This volume must be included because it must be pressurized along with the displaced volume.; In the absence of manufacturer's published ratings, the NHTSA wil measure the brake chamber volume with the push rod at maximum stroke.; With regard to air reservoir volumes, the NHTSA will determine th volume of reservoirs by actual measurement. As a practical matter, air reservoirs are simple structures whose volumes are relatively easy to measure.; Sincerely yours, Robert L. Carter, Associate Administrator, Moto Vehicle Programs;
ID: aiam3578 Open Regal Tire Corporation, 4309 County Line Road, Chalfont, PA 18914; Regal Tire Corporation 4309 County Line Road Chalfont PA 18914; Dear Sir: At the request of the office of the Honorable Peter Peyser, M.C., w are writing this letter to you to explain the significance of certain items of information molded on the sidewall of new tires.; Part 574, Tire identification and recordkeeping (49 CFR 574) requires that each new tire to be sold in the United States have a serial number molded on one of its sidewalls. That number identifies the tire's manufacturer, date of manufacture, and size. This information is designed to ensure the proper identification of all tires subject to a recall by the manufacturer for correction of a safety-related defect or of a failure to comply with a safety standard. The serial number is not a guarantee of quality or of compliance with any safety standard.; Each new tire is also required by Federal Motor Vehicle Safet Standards Nos. 109, New pneumatic tires, and 119, New pneumatic tires for vehicles other than passenger cars (49 CFR 571.109 and 571.119), to have the symbol 'DOT' appear on one of its sidewalls. This symbol is a certification by the tire's manufacturer that the tire fully complies with all requirements of the applicable safety standard. The symbol does not guarantee the quality of a tire in areas of performance unregulated by the safety standards.; Neither the serial number nor the DOT symbol constitute representation that a tire is free from any safety- related defect.; If you have any questions regarding these matters, please contact me. Sincerely, Frank Berndt, Chief Counsel
ID: aiam4747 Open Mr. Raymond D. Strakosch President Safety Premiums 87 Broadway P. O. Box 1031 Newburgh, NY 12550; Mr. Raymond D. Strakosch President Safety Premiums 87 Broadway P. O. Box 1031 Newburgh NY 12550; "Dear Mr. Strakosch: Thank you for your letter to John Messera, of ou Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 125, Warning Devices (49 CFR 571.125). You indicated that you have for many years produced and sold a 'Signal Glo Car Door Mirror Clip On,' which you described as a 'dangling safety tag which attaches to the car mirror to alert passersby of emergency needs.' These warning devices are made of a reflective plastic material designed with a clip attachment, and come in eight different shapes, including a triangular configuration. These products are slightly more than four inches high. You also stated that, pursuant to a request from a customer, your company has developed a larger size warning triangle for mounting on a car mirror. You have provided a prototype of this new larger size 'Lite at Nite' Reflective Auto Triangle, that is approximately 6' at the base and 5 1/2' in height. You stated that, as your warning triangle gets larger, you 'wish to make sure it is not confused with the roadside truck version described in Standard No. 125.' Additionally, you stated that you wanted to be certain that the instructions for this larger size warning triangle 'in no way conflict with the standard.' I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. This agency has exercised this authority to establish Standard No. 125. Section S3 of Standard 125 states that the standard 'applies to devices, without self-contained energy sources, that are designed to be carried in motor vehicles, and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.' (Emphasis added.) This language in S3 of Standard No. 125 makes clear that the standard's requirements are not limited to devices used by large trucks, that is, Standard No. 125 does not apply only to a 'roadside truck version' of a warning device. Instead, the standard applies to all devices designed to be carried in any motor vehicle, from the smallest motorcycle to the largest truck, if the device satisfies the other conditions set forth in S3 of the standard. One of the conditions set forth in S3 is that the device must be designed to be used to 'warn approaching traffic of a stopped vehicle.' Devices that are not intended to warn approaching traffic of a stopped vehicle, but only to alert passing traffic of the stopped vehicle's need for assistance, are not subject to Standard No. 125. Examples of such devices include a rag tied on a radio antenna and a 'HELP' message printed on a folding cardboard sunshade. By the time approaching traffic sees one of these non-warning devices, the traffic would already be aware that the vehicle displaying such a device was stopped. Your 'Signal Glo Car Door Mirror Clip On' product appears to be designed and to function in the same way other non-warning devices do, i.e., it does not appear to be intended to warn approaching traffic of a stopped vehicle, but to alert passing traffic that the stopped vehicle needs assistance. If this is the case, the 'Signal Glo Car Door Mirror Clip On' would not be subject to Standard No. 125. However, the larger 'Lite at Nite' Reflective Auto Triangle may be designed to be used to 'warn approaching traffic of a stopped vehicle.' It appears from the promotional material enclosed in your letter that this larger triangle is intended to serve the same purpose as what you call 'truck warning triangles.' We assume that you are describing warning devices that are certified as complying with Standard No. 125. If your larger triangle is to serve this function, it would be subject to Standard No. 125 and would have to conform to all the requirements of the standard. From the enclosed copy of Standard No. 125, you will see that some of the specific requirements with which the larger triangle must conform include minimum size, durability, material, container, labeling, configuration, color, reflectivity, luminance, and stability. When the agency has issued an applicable safety standard, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) provides that no person shall 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any new motor vehicle or new item of motor vehicle equipment unless the vehicles or equipment are in conformity with the applicable standard. Further, the Safety Act provides that NHTSA has no authority to approve, certify, or otherwise endorse any commercial product. Instead, section 114 of the Safety Act (15 U.S.C 1403) establishes a self-certification process under which every manufacturer is required to certify that each of its products meet all applicable Federal safety standards. To comply with any applicable legal obligations, especially in connection with the manufacture of the larger size warning triangle, I suggest that you carefully examine the requirements of Standard 125 and consider the design, marketing, and intended use of the new larger warning triangle. You should also be aware that the Safety Act establishes a civil penalty of $1,000 for each violation of a safety standard and a maximum penalty of $800,000 for a series of violations. In addition, the Act requires manufacturers to notify purchasers and remedy any items of motor vehicle equipment, such as warning devices, that do not conform with any applicable safety standards. I have also enclosed an information sheet for new manufacturers of motor vehicles and motor vehicle equipment, that briefly summarizes our laws and regulations and explains how to get copies of those laws and regulations. If you have any further questions or need additional information on this subject, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures";
ID: aiam3082 Open Mr. D. Black, Alfa Romeo, 250 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. D. Black Alfa Romeo 250 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Black: This responds to your request for written confirmation of statement made by Mr. Ralph Hitchcock of the National Highway Traffic Safety Administration during a meeting with your representative, Mr. Bernstein. That meeting concerned the requirements of Safety Standard No. 208 and Safety Standard No. 216 as they apply to convertibles. The discussion below follows sections 'I' and 'V' of the transcript enclosed in your letter, which involve legal questions.; (I.) Convertibles, like all other passenger cars, must comply with th automatic restraint requirements of Safety Standard No. 208 beginning in 1981, 1982 or 1983, depending on vehicle wheelbase size. This means that convertibles will have to meet the frontal crash protection requirements of S5.1 by means that require no action by vehicle occupants and, either meet the lateral and roll-over requirements of S5.2 and S5.3 by means that require no action by vehicle occupants or, at the option of the manufacturer, have a Type I or Type II seat belt assembly at each front designated seating position (and meet the frontal requirements of S5.1 with these belts fastened around the test dummies).; In the second part of your first question, you asked whether convertible may meet the requirements of Safety Standard No. 216, Roof Crush Resistance, as an optional means of complying with the roll-over requirements of Standard No. 208. The answer to your question is yes. Convertibles are not required to meet the requirements of Standard No. 216 but may do so, at the option of the manufacturer, as an alternative to meeting the automatic roll-over requirements of Standard No. 208. Please note that compliance with Standard No. 216 would not excuse convertibles from compliance with the automatic lateral protection requirements of Standard No. 208. As stated above, however, installation of a lap belt at front designated seating positions would excuse all passenger cars from both the lateral and the roll-over requirements. Therefore, a convertible that meets the frontal crash protection requirements of the standard by means that require no action by vehicle occupants and that also has lap belts installed, does not have to meet the requirements of Standard No. 216. I am enclosing a letter of interpretation that was issued last year which discusses the relationship between Safety Standard No. 208 and Safety Standard No. 216, in light of the automatic restraint requirements.; In the final part of your first question, you asked whether you coul manufacture convertibles with fold-down tops, removable tops or removable hard-tops that would comply with Safety Standard No. 216, as an optional means of complying with the roll-over requirements of Safety Standard No. 208. The answer to this question is also yes. While our regulations do not include a formal definition of 'convertible,' the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) or by a fixed, rigid structural member. Therefore, if any of the vehicle designs you mentioned meet this criteria and also comply with Safety Standard No. 216, they would not be required to comply with the roll-over requirements of Safety Standard No. 208.; (V.) Section V of your transcript includes a discussion of the growin aftermarket convertible industry (removing hard-tops from vehicles) and the increasing number of kit-car convertibles. You asked about the legal requirements for these vehicles. Any new vehicle that is manufactured or assembled from a kit-car must comply with all applicable Federal motor vehicle safety standards and regulations. Likewise, a person who alters a new vehicle prior to its first purchase in good faith for purposes other than resale (by converting a hard-top vehicle to convertible, for example) is required to place an additional label on the vehicle certifying that, as altered, the vehicle remains in compliance with all applicable safety standards. This means that all of these vehicles would have to be in compliance with the automatic restraint requirements of Safety Standard No. 208 (after those requirements become effective).; Mr. Hitchcock's statement that removing the top of a vehicle that is i compliance with Safety Standard No. 216 would be prohibited by Federal law is incorrect. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (sic) 1974, does provide that no manufacturer, dealer, distributor or motor vehicle repair business may knowingly render inoperative any device or element of design installed in compliance with a Federal motor vehicle safety standard, and this is the law that Mr. Hitchcock referred to. The agency has stated in the past, however, that conversion of one vehicle type to another vehicle type (e.g., hard-top to convertible) does not violate this provision, as long as the converted vehicle complies with all safety standards that would have been applicable to it if it had originally been manufactured as the new type. Therefore, removal of a passenger car's hard-top does not render inoperative the vehicle's compliance with Standard No. 216 since a new convertible would not have been required to comply with that standard.; I hope this letter has responded fully to the legal questions raised i your discussions with Mr. Hitchcock. If you have any further questions, please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2739 Open Mr. Dick Rechlicz, Executive Secretary, Wisconsin School Bus Association, 2830 No. Brookfield Road, Box 403, Brookfield, WI 53005; Mr. Dick Rechlicz Executive Secretary Wisconsin School Bus Association 2830 No. Brookfield Road Box 403 Brookfield WI 53005; Dear Mr. Rechlicz: This responds to your October 16, 1977, letter requesting again tha the National Highway Traffic Safety Administration (NHTSA) reinterpret its 20-inch measurement of occupant seat spacing in Standard No. 222, School Bus Passenger Seating and Crash Protection.; Mr. Levin indicated in an earlier response to your letter that sea spacing is measured at the point of greatest distance separating the seats. This measurement is used to ensure that impact forces do not exceed the forces the seat is designed to sustain or absorb. To measure as you suggest would require redesigning school bus seats to ensure their ability to sustain or absorb increased impact loads.; The NHTSA has received a number of complaints on seat spacing in schoo buses manufactured in compliance with the subject regulations. We have met with most of the major school bus manufacturers discussing production seat spacings and the Federal requirements. The agency has found that manufacturers are producing buses with seat spacings which are, in some cases, 3 inches less than the maximum specified by the regulations. These large reductions in seat spacing result principally from manufacturers' choices in designing the seats. Such seat spacing reductions are not found in all seats designed to meet the regulations.; Through its monitoring of the standard's implementation, the NHTSA ha discovered that manufacturers are not achieving the maximum seat spacing that the agency had contemplated at the time the regulation was issued. The installation of seats in school buses cannot be done with the precision that the NHTSA had anticipated. Accordingly, manufacturers in their attempts to ensure that they do not violate the 20-inch space requirement must design seat spacing as much as an inch short of the 20-inch spacing allowance. The result is seat spacing which is less than the agency contemplated. The NHTSA has taken expeditious action to alleviate this problem.; On December 20, 1977, NHTSA issued an Interim Final Rule amendin Federal Motor Vehicle Safety Standard No. 222 by increasing the maximum allowable distance from the seating reference point to the seat back from 20 to 21 inches. The agency intended that the measurement be approximately 20 inches. A seat spacing specification of 21 inches permits 20- inch spacing by taking manufacturing tolerances into account. A Notice of Proposed Rulemaking (NPRM) proposing this change in the rule was also issued on December 20, 1977.; Sincerely, Joan Claybrook

Request an Interpretation

How do I submit a request for 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.

Interpretations	Date
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ID: aiam2914 Open James P. Bally, Esq., Messrs. Brownfield, Kosydar, Bowen, Bally & Sturtz, 140 East Town Street, Columbus, OH 43215; James P. Bally Esq. Messrs. Brownfield Kosydar Bowen Bally & Sturtz 140 East Town Street Columbus OH 43215; Dear Mr. Bally: We understand that you are interested in an interpretation of th relationsip (sic) of a rear lighting system, developed by your client Mr. Leno Bevilacqua, to Federal motor vehicle lighting requirements. As you described this device in your letter of September 29, 1978, to the Nevada Department of Highways:; >>>'The device will project a green light for the vehicle which woul be in a constant or accelerated speed, a yellow light for the vehicle in a decelerated moving state and a red light for the vehicle which would be stopping.'<<<; Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflectiv Devices, and Associated Equipment, (49 CFR 571.108) neither requires nor expressly prohibits a lighting device of this nature as original equipment on motor vehicles. One section of the standard, however, S4.1.3, prohibits the installation of all original lighting equipment not mandated by the standard 'that impairs the effectiveness of lighting equipment required by this standard.' While we make no judgment with respect to Mr. Bevilacqua's 18-inch long 1 1/2 inch high rectangular device, I think it important to note that the agency's research into rear green signal lights indicate that there may be disadvantages rather than advantages to such a lighting system. One major disadvantage is the problem of confusing the unfamiliar colored rear lamps in urban environments having multicolored lights.; Standard No. 108 does not cover this device as an aftermarket item, an it would therefore be subject to regulation by the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3606 Open Mr. Shizuo Suzuki, Nissan Motor Co., Ltd., Suite 707, 1919 Pennsylvania Avenue, N.W., P.O. Box 57105, Washington, DC 20037; Mr. Shizuo Suzuki Nissan Motor Co. Ltd. Suite 707 1919 Pennsylvania Avenue N.W. P.O. Box 57105 Washington DC 20037; Dear Mr. Suzuki: This responds to your request for an interpretation concerning Standar No. 101, Controls and Displays. You asked several questions concerning informational readout displays. The answers to your questions are as follows.; >>>1. If one type of information is displayed by an electr illuminating device such as a light-emitting diode, can I define this as an IRD?<<<; The answer to this question is yes. Section S4 of Standard No. 10 defines informational readout display as 'a display using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information or message may be displayed.' [Emphasis added.] Thus, the type of system you describe comes within Standard No. 101's definition of informational readout display. In reference to the specific wording of your question, I would note that it is the definition in the standard, rather than a particular characterization by the manufacturer, that is determinative as to whether a display is an informational readout display.; >>>2. Do you think that the description 'other electro illuminatin device' includes normal electric bulbs?<<<; The answer to this question is no. The requirements applicable t informational readout displays are an exception to the usual requirements for displays, which ordinarily use normal electric bulbs. The preamble to the final rule establishing the requirements of the present Standard No. 101 explained that the reason for the exception was to 'permit the continued development of informational readout displays.' 43 FR 27541, June 26, 1978. This was necessary since current technology does not enable manufacturers to produce informational readout displays which can exhibit symbols (as opposed to words) or certain colors. Thus, while section S5.2.3 of Standard No. 101 makes the use of certain symbols and colors mandatory for traditional displays, the use of symbols and colors is optional for informational readout displays.; If 'other electro illuminating device' was interpreted to includ normal electric bulbs, traditional displays would come within the definition of informational readout display. Such an interpretation would render meaningless Standard No. 101's requirements for the mandatory use of certain symbols and colors for displays. It is thus clear that the term 'other electro illuminating device' does not include normal electric bulbs. Rather, the term was included within the definition of informational readout display, along with light-emitting diodes and liquid crystals, to avoid preventing the use of new electronic technology other than light-emitting diodes and liquid crystals.; Your third and fourth questions both contemplate that the answer t your second question is yes, rather than no. In reference to your question as to why the agency amended Standard No. 101 to permit the use of green as an alternative to blue or blue-green for the headlamp high beam telltale, the reason is that the agency does not interpret the standard's definition of informational readout display to include a mere colored light using light-emitting diode technology. To be an informational readout display, it must include information in the form of words or symbols. Since such a colored light is not an informational readout display, it must meet the color requirements of Standard No. 101. On February 1, 1982, the agency published a notice in the Federal Register (47 FR 4541) which proposed, among other things, an interpretive amendment to the definition of informational readout display to make that point clear. We have enclosed a copy of that notice for your convenience.; Your fourth question suggests that the definition of informationa readout display should be interpreted to include only displays providing more than one type of information. As explained in the answer to your first question, such an interpretation would be inconsistent with the wording of the standard's definition of informational readout display. The agency recognizes, however, that it is likely that most if not all informational readout displays will include more than one type of information, though it is possible that some manufacturers might use LED or similar technology for displays providing only one type. In any event, the agency is not aware of a need to revise the standard's requirements to exclude displays presenting only one type of information from the definition of informational readout display.; >>>5. According to the current regulation, is it possible to integrat telltales with other instrument displays in an informational readout display?<<<; The light intensity requirements of Standard No. 101 currently preven informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section specifies that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; We would note, however, that the notice of proposed rulemaking referre to above proposes an amendment to Standard No. 101 that would permit informational readout displays to be used as telltales. The agency is in the process of analyzing the comments received in response to that notice.; Our answer to your fifth question also covers your sixth question. hope this fully responds to your inquiry.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1115 Open Mr. Mel Turner, Manager, Heavy Duty Division, Automotive Service Industry Association, 230 North Michigan Avenue, Chicago, IL 60601; Mr. Mel Turner Manager Heavy Duty Division Automotive Service Industry Association 230 North Michigan Avenue Chicago IL 60601; Dear Mr. Turner: This is in reply to your letter of March 26, 1973, to Mr. Georg Shifflett of my staff, enclosing a letter from Mr. I. Warren Simpson of Standard Parts Corporation. Mr. Simpson's questions, as amplified in a phone conversation we had with him following your suggestion, are restated below, and followed by our responses.; 1. When 'glyder kits' are installed, is the installer considered to b a manufacturer and therefore responsible for certification? (We understand 'glyder kits' to mean a cab with chassis, less power train and rear axle.); Whether a vehicle must be certified depends upon whether it is 'completed vehicle', as that term is defined in 49 CFR S 568.3 (Vehicles Manufactured in Two or More Stages), copy enclosed. If the installation of a glyder kit produces a 'completed vehicle', the installer must certify the vehicle, as specified in 49 CFR Parts 567, 568, as conforming to all applicable Federal Motor Vehicle Safety Standards.; In cases involving the refurbishing of a used chassis, the NHTS considers the refurbished vehicle to be a used vehicle, for which no certification is necessary. However, the implication from your letter is that a glyder kit installation involves a new chassis (only the rear axle and power train are used) and consequently the completed vehicle will be a new vehicle which must be certified.; There is also the possibility that a glyder kit, when installed, wil be an 'incomplete vehicle' (also defined in 49 CFR 568.3). An incomplete vehicle is not certified. Rather, its manufacturer prepares, and ships with it pursuant to Part 568, a document containing information on steps that the final-stage manufacturer must take in order to bring the vehicle, as completed, into conformity with applicable Federal standards.; 2. Are we required to know the first purchaser for purposes other tha resale (users) of the vehicle when we complete the vehicle for a dealer?; Section 113(f) of the National Traffic and Motor Vehicle Safety Act (1 USC 1402(f)) requires each manufacturer of motor vehicles to maintain records of the names and addresses of the first purchaser (other than a dealer and distributor) of motor vehicles produced by that manufacturer. In completing a vehicle for a dealer, you are the final-stage manufacturer of the vehicle, and are responsible for maintaining the names and addresses of first purchasers. The information can be obtained from the dealers for whom you complete vehicles.; 3. If the vehicles are involved in a 'defect notification' campaign ar we, as final-stage manufacturer (we install fifth wheels), required to participate?; Under the National Traffic and Motor Vehicle Safety Act, a manufacture of motor vehicles is responsible for notifying owners of vehicles that he manufacturers (sic). Usually, for multi-stage vehicles, the incomplete vehicle manufacturer will issue notification for defects covering those vehicle parts or components which he assembled or manufactured. Final stage manufacturers, like yourself, would do likewise. Under the Defect Notification regulations (49 CFR Part 577), if any one manufacturer who participates in the manufacture of a multi-stage vehicle conducts a notification campaign, the other manufacturers will not be required to do so. You may, however, be called upon to furnish to the manufacturer conducting the campaign the names and addresses of purchasers for vehicles you have completed.; 4. 'How can a distributor safely attach a fifth wheel? (Any fram failure is our liability since the OEM is very specific about neither, welding, drilling, or cutting the frame.)'; This agency is not in a position to give advice in this regard. Th problem should be worked out between the incomplete and final-stage manufacturer.; We are enclosing the following pertinent publications: >>>1. The National Traffic and Motor Vehicle Safety Act 2. Part 567, 'Certification', and Part 568, 'Vehicles Manufactured i Two or More Stages.'; 3. Part 573, 'Defect Reports.' 4. Part 577, 'Defect Notification.'<<< If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs;
ID: aiam3128 Open Mr. Kei Matsui, Toyo Kogyo Co. Ltd., P.O. Box 18, Hiroshima, 730-91 Japan; Mr. Kei Matsui Toyo Kogyo Co. Ltd. P.O. Box 18 Hiroshima 730-91 Japan; Mr. Matsui: This is in response to your letter of May 11, 1979, requesting th National Highway Traffic Safety Administration's (NHTSA) views on whether the inclusion of optional equipment on certain Mazda models would be sufficient to create a number of different series within that model.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree on commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line', denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; Based in the facts presented, it is apparent that models equipped wit different optional equipment could each be designed a 'series' if Mazda desired. Nonetheless, the definition of a 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If the difference between the potential series are superficial and a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam4317 Open Ms. Robin Bender Stevens, Health Policy and Planning Consultant, ECRI, 5200 Butler Pike, Plymouth Meeting, PA 19462; Ms. Robin Bender Stevens Health Policy and Planning Consultant ECRI 5200 Butler Pike Plymouth Meeting PA 19462; Dear Ms. Stevens: Thank you for your letter of March 26, 1987, asking several question about how our regulations on safety belts would apply to side and rear-facing seats in emergency medical vehicles. I hope the following discussion answers your questions.; You explained in your letter that most emergency medical vehicles hav a rear-facing seat that is typically located behind the driver's seat. The photographs you sent with your letter show that in one of the two vehicle designs you photographed, the rear-facing seat appears to be a typical vehicle seat, referred to as a 'captain's chair,' often used in a van-type vehicle. In the other emergency vehicle design show in your photographs, there is a rearward-facing, bench-type seat with a padded seat pan and back installed directly behind the driver.; You further explained that, depending on the number of stretchers th vehicle is designed to carry, there may be another seating area in the vehicle. In single-stretcher vehicles, there is a squad bench, which your photographs show is a set of storage compartments with a padded top, located next to the stretcher. You explained that emergency personnel may sit on the squad bench to attend the the(sic) patient while the vehicle is in motion. You further explained that personnel in dual-stretcher vehicles sit on the empty stretcher to attend to the patient. You said that use of a safety belt in those positions is too restrictive to allow emergency personnel to provide acute care to patients during transports.; Standard No. 208, Occupant Crash Protection, sets requirements fo the installation of occupant restraints in motor vehicles. The emergency medical vehicles shown in your photographs would be classified as multipurpose passenger vehicles under our regulations since they are designed to carry 10 or fewer persons and are built on a truck chassis. Standard No. 208 requires manufacturer of new multipurpose passenger vehicles to install a safety belt for each designated seating position. Part 571.3 of our regulations defines, impart, a designated seating position as:; >>>any plan view location capable of accommodating a person at least a large as 5th percentile female, if the overall seat configuration and design and vehicle design is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats.<<<; The agency considers the two types of rearward-facing seats in th emergency medical vehicles you photographed to be designated seating positions. Those seats are designed and built in the same manner as conventional vehicle seats in that they have a padded seat pan and a high padded seat back. In fact, the one seat appears to be a conventional 'captain's chair' which has been mounted in a rearward-facing position. The two rearward-facing seats are also designed to be used on a routine basis by an emergency medical personnel as the vehicle travels to its destination.; In contrast, the agency does not consider as squad bench or a stretche to be a designed or built in the same manner as a conventional vehicle seat. Although they have the equivalent of a seat pan, they do not have a seat back. Most importantly, both the squad bench and stretcher are meant to be used on a temporary basis as auxiliary seating position by emergency medical personnel as they provide treatment to a patient. Thus, as an auxiliary seating area, they would not be considered a designated seating position and therefore not subject to the safety belt installation requirement of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel
ID: aiam1545 Open Mr. R. W. Hilderbrandt, Heavy Vehicle Systems Group, Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hilderbrandt Heavy Vehicle Systems Group Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hilderbrandt: This responds to your May 10, 1974, request for interpetation (sic) o the volume requirements for service brake chambers in S5.2.1.2 and S5.1.2.1 of Standard No. 121, Air Brake Systems:; >>>S5.1.2.1 The combined volume of all service reservoirs and suppl reservoirs shall be at least twelve times the combined volume of all service brake chambers at maximum travel of the pistons or diaphragms.<<<; You also requested that reservoir volume be based on manufacture 'rated volume' based on the designed volume of the reservoir.; In testing for compliance with S5.1.2.1 and S5.2.1.2, the NHTSA wil accept a manufacturer's published 'rated volume' of the brake chamber with the piston or diaphragm at maximum travel. This means that the manufacturer may specify the full stroke of the piston or diaphragm and compute the 'rated volume' based on the designed volume of the chamber and the full stroke he has established. This volume may be somewhat larger than 'nominal brake chamber displacement' which does not necessarily account for the void ahead of the relaxed diaphragm or piston, the so-called 'pre-fill volume.' This volume must be included because it must be pressurized along with the displaced volume.; In the absence of manufacturer's published ratings, the NHTSA wil measure the brake chamber volume with the push rod at maximum stroke.; With regard to air reservoir volumes, the NHTSA will determine th volume of reservoirs by actual measurement. As a practical matter, air reservoirs are simple structures whose volumes are relatively easy to measure.; Sincerely yours, Robert L. Carter, Associate Administrator, Moto Vehicle Programs;
ID: aiam3578 Open Regal Tire Corporation, 4309 County Line Road, Chalfont, PA 18914; Regal Tire Corporation 4309 County Line Road Chalfont PA 18914; Dear Sir: At the request of the office of the Honorable Peter Peyser, M.C., w are writing this letter to you to explain the significance of certain items of information molded on the sidewall of new tires.; Part 574, Tire identification and recordkeeping (49 CFR 574) requires that each new tire to be sold in the United States have a serial number molded on one of its sidewalls. That number identifies the tire's manufacturer, date of manufacture, and size. This information is designed to ensure the proper identification of all tires subject to a recall by the manufacturer for correction of a safety-related defect or of a failure to comply with a safety standard. The serial number is not a guarantee of quality or of compliance with any safety standard.; Each new tire is also required by Federal Motor Vehicle Safet Standards Nos. 109, New pneumatic tires, and 119, New pneumatic tires for vehicles other than passenger cars (49 CFR 571.109 and 571.119), to have the symbol 'DOT' appear on one of its sidewalls. This symbol is a certification by the tire's manufacturer that the tire fully complies with all requirements of the applicable safety standard. The symbol does not guarantee the quality of a tire in areas of performance unregulated by the safety standards.; Neither the serial number nor the DOT symbol constitute representation that a tire is free from any safety- related defect.; If you have any questions regarding these matters, please contact me. Sincerely, Frank Berndt, Chief Counsel
ID: aiam4747 Open Mr. Raymond D. Strakosch President Safety Premiums 87 Broadway P. O. Box 1031 Newburgh, NY 12550; Mr. Raymond D. Strakosch President Safety Premiums 87 Broadway P. O. Box 1031 Newburgh NY 12550; "Dear Mr. Strakosch: Thank you for your letter to John Messera, of ou Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 125, Warning Devices (49 CFR 571.125). You indicated that you have for many years produced and sold a 'Signal Glo Car Door Mirror Clip On,' which you described as a 'dangling safety tag which attaches to the car mirror to alert passersby of emergency needs.' These warning devices are made of a reflective plastic material designed with a clip attachment, and come in eight different shapes, including a triangular configuration. These products are slightly more than four inches high. You also stated that, pursuant to a request from a customer, your company has developed a larger size warning triangle for mounting on a car mirror. You have provided a prototype of this new larger size 'Lite at Nite' Reflective Auto Triangle, that is approximately 6' at the base and 5 1/2' in height. You stated that, as your warning triangle gets larger, you 'wish to make sure it is not confused with the roadside truck version described in Standard No. 125.' Additionally, you stated that you wanted to be certain that the instructions for this larger size warning triangle 'in no way conflict with the standard.' I am pleased to have this opportunity to explain our law and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. This agency has exercised this authority to establish Standard No. 125. Section S3 of Standard 125 states that the standard 'applies to devices, without self-contained energy sources, that are designed to be carried in motor vehicles, and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.' (Emphasis added.) This language in S3 of Standard No. 125 makes clear that the standard's requirements are not limited to devices used by large trucks, that is, Standard No. 125 does not apply only to a 'roadside truck version' of a warning device. Instead, the standard applies to all devices designed to be carried in any motor vehicle, from the smallest motorcycle to the largest truck, if the device satisfies the other conditions set forth in S3 of the standard. One of the conditions set forth in S3 is that the device must be designed to be used to 'warn approaching traffic of a stopped vehicle.' Devices that are not intended to warn approaching traffic of a stopped vehicle, but only to alert passing traffic of the stopped vehicle's need for assistance, are not subject to Standard No. 125. Examples of such devices include a rag tied on a radio antenna and a 'HELP' message printed on a folding cardboard sunshade. By the time approaching traffic sees one of these non-warning devices, the traffic would already be aware that the vehicle displaying such a device was stopped. Your 'Signal Glo Car Door Mirror Clip On' product appears to be designed and to function in the same way other non-warning devices do, i.e., it does not appear to be intended to warn approaching traffic of a stopped vehicle, but to alert passing traffic that the stopped vehicle needs assistance. If this is the case, the 'Signal Glo Car Door Mirror Clip On' would not be subject to Standard No. 125. However, the larger 'Lite at Nite' Reflective Auto Triangle may be designed to be used to 'warn approaching traffic of a stopped vehicle.' It appears from the promotional material enclosed in your letter that this larger triangle is intended to serve the same purpose as what you call 'truck warning triangles.' We assume that you are describing warning devices that are certified as complying with Standard No. 125. If your larger triangle is to serve this function, it would be subject to Standard No. 125 and would have to conform to all the requirements of the standard. From the enclosed copy of Standard No. 125, you will see that some of the specific requirements with which the larger triangle must conform include minimum size, durability, material, container, labeling, configuration, color, reflectivity, luminance, and stability. When the agency has issued an applicable safety standard, section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) provides that no person shall 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any new motor vehicle or new item of motor vehicle equipment unless the vehicles or equipment are in conformity with the applicable standard. Further, the Safety Act provides that NHTSA has no authority to approve, certify, or otherwise endorse any commercial product. Instead, section 114 of the Safety Act (15 U.S.C 1403) establishes a self-certification process under which every manufacturer is required to certify that each of its products meet all applicable Federal safety standards. To comply with any applicable legal obligations, especially in connection with the manufacture of the larger size warning triangle, I suggest that you carefully examine the requirements of Standard 125 and consider the design, marketing, and intended use of the new larger warning triangle. You should also be aware that the Safety Act establishes a civil penalty of $1,000 for each violation of a safety standard and a maximum penalty of $800,000 for a series of violations. In addition, the Act requires manufacturers to notify purchasers and remedy any items of motor vehicle equipment, such as warning devices, that do not conform with any applicable safety standards. I have also enclosed an information sheet for new manufacturers of motor vehicles and motor vehicle equipment, that briefly summarizes our laws and regulations and explains how to get copies of those laws and regulations. If you have any further questions or need additional information on this subject, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures";
ID: aiam3082 Open Mr. D. Black, Alfa Romeo, 250 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. D. Black Alfa Romeo 250 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Black: This responds to your request for written confirmation of statement made by Mr. Ralph Hitchcock of the National Highway Traffic Safety Administration during a meeting with your representative, Mr. Bernstein. That meeting concerned the requirements of Safety Standard No. 208 and Safety Standard No. 216 as they apply to convertibles. The discussion below follows sections 'I' and 'V' of the transcript enclosed in your letter, which involve legal questions.; (I.) Convertibles, like all other passenger cars, must comply with th automatic restraint requirements of Safety Standard No. 208 beginning in 1981, 1982 or 1983, depending on vehicle wheelbase size. This means that convertibles will have to meet the frontal crash protection requirements of S5.1 by means that require no action by vehicle occupants and, either meet the lateral and roll-over requirements of S5.2 and S5.3 by means that require no action by vehicle occupants or, at the option of the manufacturer, have a Type I or Type II seat belt assembly at each front designated seating position (and meet the frontal requirements of S5.1 with these belts fastened around the test dummies).; In the second part of your first question, you asked whether convertible may meet the requirements of Safety Standard No. 216, Roof Crush Resistance, as an optional means of complying with the roll-over requirements of Standard No. 208. The answer to your question is yes. Convertibles are not required to meet the requirements of Standard No. 216 but may do so, at the option of the manufacturer, as an alternative to meeting the automatic roll-over requirements of Standard No. 208. Please note that compliance with Standard No. 216 would not excuse convertibles from compliance with the automatic lateral protection requirements of Standard No. 208. As stated above, however, installation of a lap belt at front designated seating positions would excuse all passenger cars from both the lateral and the roll-over requirements. Therefore, a convertible that meets the frontal crash protection requirements of the standard by means that require no action by vehicle occupants and that also has lap belts installed, does not have to meet the requirements of Standard No. 216. I am enclosing a letter of interpretation that was issued last year which discusses the relationship between Safety Standard No. 208 and Safety Standard No. 216, in light of the automatic restraint requirements.; In the final part of your first question, you asked whether you coul manufacture convertibles with fold-down tops, removable tops or removable hard-tops that would comply with Safety Standard No. 216, as an optional means of complying with the roll-over requirements of Safety Standard No. 208. The answer to this question is also yes. While our regulations do not include a formal definition of 'convertible,' the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) or by a fixed, rigid structural member. Therefore, if any of the vehicle designs you mentioned meet this criteria and also comply with Safety Standard No. 216, they would not be required to comply with the roll-over requirements of Safety Standard No. 208.; (V.) Section V of your transcript includes a discussion of the growin aftermarket convertible industry (removing hard-tops from vehicles) and the increasing number of kit-car convertibles. You asked about the legal requirements for these vehicles. Any new vehicle that is manufactured or assembled from a kit-car must comply with all applicable Federal motor vehicle safety standards and regulations. Likewise, a person who alters a new vehicle prior to its first purchase in good faith for purposes other than resale (by converting a hard-top vehicle to convertible, for example) is required to place an additional label on the vehicle certifying that, as altered, the vehicle remains in compliance with all applicable safety standards. This means that all of these vehicles would have to be in compliance with the automatic restraint requirements of Safety Standard No. 208 (after those requirements become effective).; Mr. Hitchcock's statement that removing the top of a vehicle that is i compliance with Safety Standard No. 216 would be prohibited by Federal law is incorrect. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (sic) 1974, does provide that no manufacturer, dealer, distributor or motor vehicle repair business may knowingly render inoperative any device or element of design installed in compliance with a Federal motor vehicle safety standard, and this is the law that Mr. Hitchcock referred to. The agency has stated in the past, however, that conversion of one vehicle type to another vehicle type (e.g., hard-top to convertible) does not violate this provision, as long as the converted vehicle complies with all safety standards that would have been applicable to it if it had originally been manufactured as the new type. Therefore, removal of a passenger car's hard-top does not render inoperative the vehicle's compliance with Standard No. 216 since a new convertible would not have been required to comply with that standard.; I hope this letter has responded fully to the legal questions raised i your discussions with Mr. Hitchcock. If you have any further questions, please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2739 Open Mr. Dick Rechlicz, Executive Secretary, Wisconsin School Bus Association, 2830 No. Brookfield Road, Box 403, Brookfield, WI 53005; Mr. Dick Rechlicz Executive Secretary Wisconsin School Bus Association 2830 No. Brookfield Road Box 403 Brookfield WI 53005; Dear Mr. Rechlicz: This responds to your October 16, 1977, letter requesting again tha the National Highway Traffic Safety Administration (NHTSA) reinterpret its 20-inch measurement of occupant seat spacing in Standard No. 222, School Bus Passenger Seating and Crash Protection.; Mr. Levin indicated in an earlier response to your letter that sea spacing is measured at the point of greatest distance separating the seats. This measurement is used to ensure that impact forces do not exceed the forces the seat is designed to sustain or absorb. To measure as you suggest would require redesigning school bus seats to ensure their ability to sustain or absorb increased impact loads.; The NHTSA has received a number of complaints on seat spacing in schoo buses manufactured in compliance with the subject regulations. We have met with most of the major school bus manufacturers discussing production seat spacings and the Federal requirements. The agency has found that manufacturers are producing buses with seat spacings which are, in some cases, 3 inches less than the maximum specified by the regulations. These large reductions in seat spacing result principally from manufacturers' choices in designing the seats. Such seat spacing reductions are not found in all seats designed to meet the regulations.; Through its monitoring of the standard's implementation, the NHTSA ha discovered that manufacturers are not achieving the maximum seat spacing that the agency had contemplated at the time the regulation was issued. The installation of seats in school buses cannot be done with the precision that the NHTSA had anticipated. Accordingly, manufacturers in their attempts to ensure that they do not violate the 20-inch space requirement must design seat spacing as much as an inch short of the 20-inch spacing allowance. The result is seat spacing which is less than the agency contemplated. The NHTSA has taken expeditious action to alleviate this problem.; On December 20, 1977, NHTSA issued an Interim Final Rule amendin Federal Motor Vehicle Safety Standard No. 222 by increasing the maximum allowable distance from the seating reference point to the seat back from 20 to 21 inches. The agency intended that the measurement be approximately 20 inches. A seat spacing specification of 21 inches permits 20- inch spacing by taking manufacturing tolerances into account. A Notice of Proposed Rulemaking (NPRM) proposing this change in the rule was also issued on December 20, 1977.; Sincerely, Joan Claybrook

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