NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam2963OpenMr. Paul Utans, Subaru of America, Inc., 7040 Central Highway, Pennesauken, (sic) NJ 08109; Mr. Paul Utans Subaru of America Inc. 7040 Central Highway Pennesauken (sic) NJ 08109; Dear Mr. Utans:#I regret the delay in responding to your September 12 1978, letter requesting interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. The responses to your specific questions regarding the compliance of your prototype monitor of vehicle systems are as follows:#1. When there is no problem with the vehicle systems included in the monitor, only the outline of a car is visible. The displays for items such as oil and electrical charge would not be illuminated. You asked if the monitor in its 'no problem' model would comply with FMVSS 101-80. The answer is yes. There is no requirement that the displays be continuously illuminated.#2. On the monitor, the high beam symbol would be oriented so that it pointed upward. You asked whether this complies with the standard even though the symbol appears in Table 2 of the standard pointing to the left. The answer is yes. The requirement is section 5.2.3 that the display symbol appear preceptually (sic) upright to the driver was not intended to apply to the situation in which the symbol is used in conjunction with a car diagram of the type in your monitor. In such situations, it would be more confusing to place the symbol in the upright position than to orient the symbol so that it bears the same relationship to the diagram as the symbolized equipment does to the actual vehicle.#Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam2942OpenMr. D. K. Haenchen, Administrator, Vehicle Regulations, Volkswagen of America, 27621 Parkview, Boulevard, Warren, MI 48092; Mr. D. K. Haenchen Administrator Vehicle Regulations Volkswagen of America 27621 Parkview Boulevard Warren MI 48092; Dear Mr. Haenchen: This is in reply to your letter of January 3, 1979, asking fo confirmation of your interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to a braking system that Volkswagen proposes to use on its 1980 Dasher model.; Specifically, the Dasher will employ a single 'pressure switch on eac vehicle, meaning that the stop lamp will be activated by only one of the [two, split] service brake systems.' You asked whether this is consistent with S4.5.4 of Standard No. 108 which requires that 'the stop lamps on each vehicle shall be activated upon application of the service brakes.' You argued that it meets the standard because:; >>>'Neither FMVSS 571.105-75 nor 575.108 (sic) clearly specify th conditions under which the stop lights have to operate. Specifically, the regulations do not specify that the stop lamps must illuminate upon application of the service brake control if one of the circuits of a dual circuit hydraulic braking system failed.'<<<; We do not concur with your interpretation. S4.5.4 quite clearl specifies the conditions under which the stop lamps must operate--'upon application of the service brakes,' and it is immaterial which circuit of a dual circuit hydraulic braking system is braking the vehicle. Therefore, your proposed system would constitute an apparent noncompliance with Standard No. 108.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1591OpenMr. David E. Martin,Director, Automotive Safety Engineering,General Motors Corporation,General Motors Technical Center,Warren, Michigan 48090; Mr. David E. Martin Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center Warren Michigan 48090; Dear Mr. Martin:#This responds to your letter of August 14, 1974 requesting an interpretation of Motor Vehicle Safety Standard No. 106-74, *Brake Hoses* (Docket 1-5, Notice 11, published on June 28, 1974), regarding its applicability to specific hydraulic brake booster hoses used in General Motors products.#As indicated in notice11, it is the National Highway Traffic Safety Administration's (NHTSA) intention to exempt from the requirements of the standard hydraulic booster lines subject to a different working environment than brake hose, pending development of special performance requirements for such lines. General Motors' interpretation that the hydraulic booster hoses used in the systems described in your August 14 letter are exempted from the standard requirements is correct. The system described in your Attachment A is considered to incorporate an accumulator integral with the brake booster assembly. Hence all of the hoses run between the power steering pump and the accumulator (either directly or via the power steering gear) and are accordingly exempted per Notice 11 preamble. The hoses used in the system described in your Attachment B are exempted by virtue of the provision of redundant booster poser by the independent electro-hydraulic pump.#a future amendment to FMVSS 106 to eliminate ambiguity in respect to the standard's applicability to hydraulic booster hoses is currently under consideration. Any such amendment will be consistent with the present interpretation.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4965OpenMr. James G. White Head, Crash Avoidance Standards (ASFBE) Road Safety and Motor Vehicle Regulation Transport Canada; Mr. James G. White Head Crash Avoidance Standards (ASFBE) Road Safety and Motor Vehicle Regulation Transport Canada; FAX: 613-998-1965 Dear Mr. White: This responds to your FAX of Februar 18, 1992, to Richard Van Iderstine of this agency, who has asked this office to respond to your question 1.a. That question is: 'Is Koito correct in stating that FMVSS 108 does not require the 'O' point on IHAD (sic) indicators to be marked by the numeral '0''? In the letter from Koito that you furnished, Koito had remarked that the requirement in S7.7.5.2(a)(1) and (2) of Standard No. 108 'to have a zero mark' did 'not necessarily mean a mark of figure 'O', but may be just a reference mark.' Koito is incorrect. S7.7.5.2 On-vehicle aiming specifies requirements for Vehicle Headlamp Aiming Devices (VHADs). VHADs provide for headlamp aim inspection in both the vertical and horizontal axes. S7.7.5.2(a)(2) Horizontal aim states that 'An 'O' mark shall be used to indicate alignment of the headlamps relative to the longitudinal axis of the vehicle.' This clearly establishes the requirement for use of the figure '0' as the mark, and not use of a reference mark. You will note that S7.7.5.2(b) references setting the VHAD 'at 'O' vertical and 'O' horizontal.' This means at the 'O' mark. Both S7.7.5.2(a)(1) Vertical aim and (a)(2) reference the necessity to provide 'an equal number of graduations from the 'O' position representing angular changes in the axis.' These graduations are not required to be marked. The presence of the 'O' mark will assist the person aiming the headlamp to ensure that the VHAD is set at the junction of the horizontal and vertical axes, rather than at one of adjacent, unmarked graduations. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0369OpenMr. Keitaro Nakajima, General Manager, Toyota Motor Co., Ltd., Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, New Jersey 07071; Mr. Keitaro Nakajima General Manager Toyota Motor Co. Ltd. Lyndhurst Office Park 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: This is in reply to your letter of June 2, 1971, requestin clarification of S4.3 of FMVSS No. 110, which requires a placard containing specified information to be 'permanently affixed to the glove compartment door or an equally accessible location.' Your letter list seven locations on the vehicle (steering column, lower instrument panel pad or knee pad forward of the front seat occupants, sun visor, inside panel surface of the driver's door, door-latch post next to the driver's seat, door edge that meets the door-latch post next to the driver's seat, and door edge that meets the hinge pillar next to the driver's seat) and asks whether each would be considered an 'equally accessible location' under the standard.; The phrase 'glove compartment door or equally accessible location' i intended to require the placard to be affixed to a location where, like the glove compartment door, it can not only be easily referred to, but where it will also be relatively free from exposure to substances that may destroy it or render it illegible. With reference to your list of seven locations, we cannot determine without the specific configuration of the components involved whether placing the placard at any point on the component will meet the requirement. however, we believe the placard could be placed at some point on each of these components or locations so that the requirements of the standard would be met.; Please let us know if you have further questions. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3404OpenMr. John S. Miskowicz, Gateway Industries, Inc., 17512 Carriage Way Drive, Hazel Crest, IL 60429; Mr. John S. Miskowicz Gateway Industries Inc. 17512 Carriage Way Drive Hazel Crest IL 60429; Dear Mr. Miskowicz: This responds to your letter of March 2, 1981, to Vladislav Radovic concerning Standard No. 213, *Child Restraint Systems*. Your letter was forwarded to this office for reply.; You asked whether a child restraint belt buckle must meet the buckl force release requirements when tested in an unloaded condition. In addition, you asked whether section 4.3(a) and 4.3(b) of Standard No. 209, *Seat Belt Assemblies*, are the only requirements of that standard which apply to buckles in child restraint systems. The answer is yes.; Section 5.4.3.5 of Standard No. 213 provides that each child restrain belt buckle, when tested in accordance with S6.2, must not release when a force of not more than 12 pounds is applied before the dynamic sled specified in S6.1 is conducted. The buckle must release when a force of 20 pounds is applied after the dynamic sled test. Section 6.2 provides that in conducting the belt buckle release force test, the appropriate test dummy is placed in the restraint and either a pull force of 20 pounds is applied, in the case of 6-month-old test dummy, or a 45 pound pull force is applied, in the case of the three-year-old test dummy. Thus, the buckle is not tested in an unloaded state.; Section 5.4.2 of the standard provides that each belt buckle has t conform to the 'requirements of S4.3(a) and S4.3(b) of FMVSS No. 209.' No other provisions of Standard No. 209 apply to belt buckles used in child restraints.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5539OpenMr. Takashi Adachi Manager Ichikoh Industries, Ltd. North American Liaison Office 555 Briarwood Circle, Suite 190 Ann Arbor, MI 48108; Mr. Takashi Adachi Manager Ichikoh Industries Ltd. North American Liaison Office 555 Briarwood Circle Suite 190 Ann Arbor MI 48108; Dear Mr. Adachi: This is in reply to your letter of March 14, 1995, t Richard Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a reflex reflector design that you attached. This design shows a single reflector 2 inches in height mounted behind a clear outer lens which is bisected horizontally by an opaque strip 6mm (.25 in.) wide, giving the impression from the exterior of two reflectors, one .75 in. high above the divider, and one that is 1.00 in. in height, below the divider. You have asked whether the 'structure of the reflex reflector conforms to FMVSS 108,' and whether photometric conformance is judged with respect to the single reflector crossed by the opaque strip, or whether both the upper and lower portions of the bisected reflector must meet the photometric specification. Standard No. 108 is a performance standard, not a design standard. The standard does not specify any requirements concerning the structure of reflectors. The applicable requirements for reflex reflectors are those of SAE Standard J594f Reflex Reflectors January 1977, which Standard No. 108 incorporates by reference. Your reflector should be tested as a single reflector according to the procedures set forth in J594f. If the reflector does not meet the photometric performance requirements of that standard, you may add sufficient reflective elements to the reflector design until conformance is achieved. There is no need to test the upper and lower portions as separate reflectors. If you have any further questions, you may refer them to Taylor Vinson (202) 366-5263 of this Office. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam5311OpenMr. Richard A. Zander AlliedSignal Automotive Proving Grounds 32104 State Road 2 New Carlisle, IN 46552; Mr. Richard A. Zander AlliedSignal Automotive Proving Grounds 32104 State Road 2 New Carlisle IN 46552; "Dear Mr. Zander: This responds to your letter asking about the fad and recovery requirements of Federal Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems. I apologize for the delay in our response. You noted that the standard requires vehicles with a GVWR of 10,000 pounds or less to be capable of making a specified number of fade stops 'at a deceleration not lower than 15 fpsps for each stop.' You stated that you are aware of a number of different understandings within the industry of the quoted phrase, and requested an interpretation as to whether vehicles must be capable of maintaining an average deceleration of at least 15 fpsps or a minimum deceleration of at least 15 fpsps. As discussed below, vehicles must be capable of maintaining a minimum deceleration of at least 15 fpsps. By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, et seq.) authorizes the National Highway Safety Administration (NHTSA) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve motor vehicles or motor vehicle equipment. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. Manufacturers must have some independent basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. Whatever the basis for certification, however, the manufacturer must certify that the product complies with a standard as it is written, i.e., that the vehicle will pass all applicable requirements if it is tested exactly according to the standard's test conditions and other specifications. Standard No. 105's fade and recovery test requirements are set forth in S5.1.4. These requirements must be met under the conditions prescribed in S6, when tested according to the procedures set forth in S7. See S5.1. The purpose of the fade and recovery test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions cause by prolonged or severe use, such as long, downhill driving. The standard specifies two fade and recovery tests for vehicles with a GVWR of 10,000 pounds or less. Each of the fade and recovery tests consists of three parts: (1) baseline check stops, (2) fade stops, and (3) recovery stops. The requirements for the fade stops are set forth in S5.1.4.2(a), which states that: Each vehicle with a GVWR of 10,000 lbs or less shall be capable of making 5 fade stops (10 fade stops on the second test) from 60 mph at a deceleration not lower than 15 fpsps for each stop, followed by 5 fade stops at the maximum deceleration attainable from 5 to 15 fpsps.' As you noted, S5.1.4.2(a) must be read in conjunction with S7.11.2.1, which sets forth the procedure for conducting the fade stops. It reads, in relevant part, as follows: Make 5 stops from 60 mph at 15 fpsps followed by 5 stops at the maximum attainable deceleration between 5 and 15 fpsps for each stop. ... Attain the required deceleration within 1 second and, as a minimum, maintain it for the remainder of the stopping time. Control force readings may be terminated when the vehicle speed falls to 5 mph. (Emphasis added.) The words 'required deceleration' in S7.11.2.1 refer to 15 fpsps. (That value is set forth both in S5.1.4.2(a) and the first sentence of S7.11.2.1.) Thus, in conducting fade stops, within one second of beginning a stop, a deceleration of 15 fpsps must be attained. S7.11.2.1 then specifies that, 'as a minimum,' the required deceleration (15 fpsps) must be maintained for the remainder of the stopping time. (The word 'it' in the highlighted sentence refers back to the phrase 'required deceleration.') Thus, after a deceleration of 15 fpsps is attained (within one second of beginning the stop), the deceleration cannot drop below 15 fpsps even momentarily. You stated that you are aware of the following three understandings within the industry concerning the meaning of this requirement: 1. The average deceleration for the stop must be greater than 15 fpsps. The average deceleration is calculated from one second after the stop begins to a vehicle speed of 5 mph. 2. After 1 second the deceleration can not drop below 15 fpsps even for an instant. If the deceleration drops below 15 fpsps at any time it is considered a failure even if the average deceleration is greater than 15 fpsps. 3. The average deceleration for the stop must be greater than 15 fpsps and the deceleration must be greater than 15 fpsps for at least 75% of the stop excluding the first second of the stop. Of the three understandings, the first and third are inconsistent with the plain wording of S7.11.2.1 which specifies that, after the required 15 fpsps deceleration is attained (within one second of beginning the stop), it must, as a minimum, be maintained for the remainder of the stopping time. The first and third understandings would, among other things, replace S7.11.2.1's specification that the 15 fpsps deceleration be maintained as a 'minimum' with one that it be maintained as an 'average.' The second understanding is largely correct. It is correct to state that, in conducting a fade stop, after a 15 fpsps deceleration is attained (within one second of beginning the stop), the deceleration cannot drop below 15 fpsps even for an instant. However, if the deceleration did drop below 15 fpsps, that would not necessarily indicate a 'failure' but might simply be an invalid test. As you note in your letter, a deceleration might fall below 15 fpsps because the driver did not compensate for in-stop fade. However, if a vehicle was unable to pass Standard No. 105's fade stop test requirements at the specified deceleration rates, it would not comply with the standard, notwithstanding the fact that it might be able to pass the requirements at slightly lower deceleration rates. You stated in your letter that the second understanding appears to not consider the intent of the fade procedure, the intent being that a vehicle must be capable of making multiple high deceleration stops in a short period of time without drastic changes in effectiveness. As discussed above, the purpose of the fade and recovery test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions cause by prolonged or severe use, such as long, downhill driving. If a vehicle was unable to pass Standard No. 105's fade stop test requirements at the specified deceleration rates, it would indicate inadequate stopping capability during conditions caused by prolonged or severe use, such as long, downhill driving. You also stated that in the Laboratory Test Procedure for Standard No. 105, published by NHTSA's Office of Vehicle Safety Compliance (OVSC), the data sheet for the fade stops requests the following information for the deceleration: 'Average Sust Decel.' You stated that it therefore appears that NHTSA's interpretation of the phrase 'at a deceleration not lower than 15 fpsps for each stop' is 'the average sustained deceleration.' It is incorrect to interpret the OVSC Laboratory Test Procedures as limiting the requirements of the Federal motor vehicle safety standards. I call your attention to the following note which is set forth at the beginning of the Laboratory Test Procedure: The OVSC Laboratory Test Procedures, prepared for use by independent laboratories under contract to conduct compliance tests for the OVSC, are not intended to limit the requirements of the applicable FMVSS(s). In some cases, the OVSC Laboratory Test Procedures do not include all of the various FMVSS minimum performance requirements. Sometimes, recognizing applicable test tolerances, the Test Procedures specify test conditions which are less severe than the minimum requirements of the standards themselves. Therefore, compliance of a vehicle or item of motor vehicle equipment is not necessarily guaranteed if the manufacturer limits certification tests to those described in the OVSC Laboratory Test Procedures. I am enclosing a copy of the most recent version of the Laboratory Test Procedure for Standard No. 105, in response to your request. I hope this information is helpful. If you have any further questions, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366- 2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam4733OpenMr. Suichi Watanabe General Manager Automotive Lighting Engineering Control Department Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan; Mr. Suichi Watanabe General Manager Automotive Lighting Engineering Control Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Watanabe: This is in reply to your letter of March 19, 1990 asking whether a new combination rear lamp is permitted under Motor Vehicle Safety Standard No. 108. The lamp consists of three compartments. In its normal operating mode, when the taillamp and/or stop lamp are activated, all three compartments show a red light. Your question arises with respect to three different operating modes. The first occurs when the turn signal is activated, the red light in one of the compartments is replaced by an amber flashing one. The second occurs when the backup lamp is activated, the red light in another of the compartments is replaced by a white steady-burning one. The third occurs when both the backup lamp and turn signal are activated, in this event, the combination lamp would present an amber flashing light, a red steady-burning one, and a white steady-burning one. You have informed us that 'the requirement of photometric and lighted area for each lamp function comply to FMVSS No. 108 and related SAE Standards.' Further, as for the stop and taillamp functions, they comply with requirements for one and three compartment lamps when operating with one or three compartments (we assume that they would also meet the requirements for two compartment lamps). The lamp appears to be intended to fulfill the requirements of Standard No. 108 for turn signal, stop, tail, and backup lamps. Thus, your question appears to be whether Standard No. 108 requires separate lamps or compartments dedicated to a specific purpose, or whether your multiple purpose lamp is acceptable. Standard No. 108 does not prohibit a combination of the functions that any chamber of your lamp provides. When a specific function is activated, the lamp will perform that particular function in a manner that appears to meet the minimum standard established by Standard No. 108. Assuming that the CIE color definitions for white, amber, and red are met by the backup, turn, and stop/tail functions, the lamp appears to be permissible under Standard No. 108. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam2202OpenMr. Byron A. Crampton, 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This is in response to your letter of January 16, 1976, concerning cre cab doors for use on fire trucks, and the interpretation of Federal Motor Vehicle Safety Standard No. 206, *Door Locks and Door Retention Components*.; You asked two questions in your letter: >>>(1) Is it the intent of FMVSS 206 to actually address door hardwar for doors that are adjacent to a walkway and not a seat?<<<; Standard No. 206 is applicable to the type of vehicle that yo described. Paragraph S4 of the standard states that 'component on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard'. The standard does not require the door to be directly adjacent to a seat. The door on your vehicle leads directly 'into a compartment that contains one or more seating accommodations,' so the standard is applicable. The presence of a walkway is irrevelant. (sic); >>>(2) If the standard does apply would not the installation of a untested conventional door structure in place of a folding door result in a safer vehicle?<<<; The NHTSA hopes that manufacturers would install conventional hinge door structures instead of folding doors on fire trucks, if the hinged doors would result in producing safer vehicles. The cost of testing the components of hinged doors for purposes of Standard 206 should not be determinative of whether the manufacturer will install hinged doors or folding doors on the fire trucks. Rather, the safety of the firemen who must use the trucks should be the determinative factor.; You should be aware that the tests in Standard No. 206 are laborator tests of the components, and do not involve the vehicle as a whole. These component systems are generally available from suppliers and are already warranted as being in compliance with Federal standards. Therefore, the cost of using conventional hinged doors might not be as prohibitive as you had supposed.; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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.