NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam1973OpenDonald J. Gobeille, Jr., Product Safety Engineer, Volvo of America Corporation, Rockleigh, New Jersey 07647; Donald J. Gobeille Jr. Product Safety Engineer Volvo of America Corporation Rockleigh New Jersey 07647; Dear Mr. Gobeille: This is in reply to your letter of June 19, 1975, seeking a interpretation of Standard No. 124, *Accelerator Control Systems*, with regard to an accelerator control system which contains either elements in parallel or a complete parallel system.; The requirements of S5.2 of Standard No. 124 are met if, after severance or disconnection of any component of the accelerator control system, the throttle returns to the idle position within the time specified in S5.3, measured from the first removal of the opposing actuating force by the driver, *or* from the disconnection or severance. You are correct in your interpretation that Standard No. 124 is intended to protect against a single severance, and that there are no requirements in Standard No. 124 concerning the severance or disconnection of the remaining one(s) of two or more parallel elements in an accelerator control system.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam5033OpenMr. William E. Lawler Manager, Specifications Indiana Mills & Manufacturing, Inc. 18881 U.S. 31 North P.O. Box 408 Westfield, Indiana 46074-0408; Mr. William E. Lawler Manager Specifications Indiana Mills & Manufacturing Inc. 18881 U.S. 31 North P.O. Box 408 Westfield Indiana 46074-0408; Dear Mr. Lawler: This responds to your letter of May 18, 1992 concerning the test requirements of Standard No. 210, Seat Belt Assembly Anchorages. Your questions concern a final rule published on December 5, 1991 (56 FR 63682) clarifying the definition of 'seat belt anchorage.' That final rule had the effect of requiring seat belt attachment hardware, which previously was not included within the definition of 'seat belt anchorage,' to comply with the requirements of Standard No. 210. Your five questions are addressed below. The first three questions refer to a safety belt design which incorporates a retractor. l. If a test harness is used, can one end of the harness be attached to the attachment hardware (retractor frame), or must it be attached to the retractor spool? The use of test harnesses for Standard No. 210 testing was permitted in a final rule published April 30, 1990, and effective September 1, 1992. More specifically, the final rule specified that 'material whose breaking strength is equal to or greater than the breaking strength of the webbing for the seat belt assembly installed as original equipment' be used to transfer the test loads from the body block to the anchorages during the Standard No. 210 compliance tests. The amended standard also specifies that the attachment of this material should 'duplicate the geometry' of the original webbing. The amended definition of 'seat belt anchorage' explicitly states that the seat belt anchorage is any component, other than the webbing or straps, involved in transferring seat belt loads to the vehicle structure, including, but not limited to, the attachment hardware, seat frames, seat pedestals, the vehicle structure itself, and any part of the vehicle whose failure causes separation of the belt from the vehicle structure. If the retractor spool breaks during a crash, the safety belt will not remain attached to the vehicle. Therefore, the retractor spool is a part of the vehicle whose failure causes separation of the belt from the vehicle structure, and, under the definition set forth above, is part of the seat belt anchorage. If a test harness is used, it must be attached such that the retractor spool is tested as part of the seat belt anchorage. The harness may not be attached directly to the retractor frame, since the retractor spool would not be tested in that instance. 2. If the harness must be attached to the spool, may it be attached around the spool as opposed to being inserted into the spool? As stated previously, Standard No. 210 specifies use of 'material whose breaking strength is equal to or greater than the breaking strength of the webbing for the seat belt assembly installed as original equipment' for Standard No. 210 tests. For compliance tests, NHTSA's preference is to use the original safety belt webbing whenever possible. When this cannot be done, due to elongation or breakage of the original webbing, NHTSA's first choice is to attach substitute webbing or other material to the original webbing near the anchorage. If the substitute material cannot be attached to the original webbing, NHTSA would attach the substitute webbing directly to the retractor spool. If the substitute webbing cannot be inserted into the spool in the same manner as the original webbing, attaching the substitute webbing around the spool would most closely duplicate the geometry of the original webbing. 3. We assume it is the intent of the agency to test only the strength of the attachment hardware--not the locking mechanism of the retractor built in accordance with FMVSS 209. The strength requirement in S4.2 of Standard No. 210 specifies that anchorages must withstand certain forces when tested under specified conditions. Under S4.2.3, permanent deformation or rupture of a seat belt anchorage or its surrounding area is not considered to be a failure, if the required force is sustained for the specified time. If breakage of the locking mechanism (a part of the anchorage because it is 'involved in transferring seat belt loads to the vehicle structure') caused separation of the belt from the vehicle structure, such breakage would be a failure of the Standard No. 210 test, as the anchorage would not have withstood the test forces. However, if the locking mechanism broke or released during the test without allowing the webbing to separate from the vehicle structure, the agency would not consider it a failure of the strength requirement test, since the belt would still be anchored to the vehicle structure. 4. A commonly used design is the 'cable buckle'. The buckle assembly is positioned in convenient reach of the seat occupant by attaching the buckle to a cable by a method called swaging. The attachment hardware consists of a flat end containing a hole for an attaching bolt and a ferrule which is swaged to the cable. The ferrule and the flat end are made in one piece. Please confirm that the attachment ferrule bolted to the seat/vehicle is what is required to withstand the forces dictated by FMVSS 210, separation of the cable from the ferrule would not constitute malfunction of the test harness and not non-compliance to FMVSS 210. In the December 5, 1991 final rule, the agency stated that 'the definition of seat belt anchorage included only the attachment points of the seat belt, and not the webbing, straps, or similar device, or the buckles which comprise the seat belt itself.' For this design, the cable is a 'similar device' to seat belt webbing, and would be considered part of the seat belt, not the anchorage. If the cable broke, the agency would consider that an incomplete test, just like breakage of webbing. However, it would be a failure of the Standard No. 210 test if the cable pulled out of the ferrule, since such pulling out would result from a failure of the ferrule rather than a broken cable. 5. Please confirm that the test harness could delete the buckle mechanism and attach directly to the upper end of the cable in the cable/ferrule assembly. The answer to this question is yes. As stated previously, buckles are part of the seat belt, not the anchorage, and therefore, are not subject to the strength requirement of Standard No. 210. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0231OpenMr. Henry C. Hudson, Clements, McClellan and Hawley, 401 Main Street, Mt. Vernon, Indiana 47620; Mr. Henry C. Hudson Clements McClellan and Hawley 401 Main Street Mt. Vernon Indiana 47620; Dear Mr. Hudson: This is in reply to your letter of April 3, 1970, to the Director National Highway Safety Bureau, that has been referred to this office.; The type of information requested under items 1 and 2 of your lette can be extracted, within the limitations of the tests conducted, from the enclosed test result summaries. However, it should be recognized that the scope of the Bureau's testing program is such that valid statistical inferences relating to industry-wide rates for tire defects or failures are not possible with the limited data available.; Prior to the adoption of the labeling requirements in Federal Moto Vehicle Safety Standard No. 109, tires could be identified by manufacturer. This was an industry practice, involving the use of serial number systems and was not required by Government regulation nor war the coding used readily available to the general public.; We trust this and the enclosed publication will answer your questions We will be pleased to answer any additional questions.; Thanks you for your interest in the programs of the National Highwa Safety Bureau.; Sincerely, Francis Armstrong, Director, Office of Compliance, Moto Vehicle Programs; |
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ID: aiam4272OpenMr. Dwight R. Koehler, Product Management, Parker Industries P. O. Box 337589, Omaha, NE 68137; Mr. Dwight R. Koehler Product Management Parker Industries P. O. Box 337589 Omaha NE 68137; Dear Mr. Koehler: This is in reply to your letter of December 9, 1986, with respect t agricultural (grain) transportation vehicles which you manufacture, known in the industry as 'grain buggies.' You have asked whether there are any DOT lighting requirements for these vehicles, and if so, what are they and how might you meet them.; You have described the grain buggies as designed to be towed b agricultural tractors, with a top road speed of 25 to 30 mph. You have also told us that 'the primary use for these trailers will be 'off road' in nature,' although ' there are times when these units will be used on gravel roads and occasionally, highways.'; The requirements of Federal Motor Vehicle Safety Standard No. 10 *Lamps, Reflective Devices, an Associated Equipment apply to various categories of 'motor vehicles.' A 'motor vehicle' is defined as a vehicle driven or drawn by mechanical power and manufactured primarily for use on the public streets, roads, and highways. The manufacturer of a vehicle determines whether his product is a 'motor vehicle' and therefore a vehicle that must comply with all applicable Federal motor vehicle safety standards including Standard No. 108. The National Highway Traffic Safety Administration reserves the right to challenge any determination that appears clearly erroneous. On the basis of the information you have presented us, the grain buggies will be primarily used off the public roads, and use of the public roads will be only incidental (in our experience agricultural equipment uses public road for such limited purposes as crossing from one field to another, and delivery of produce to processing plants). Under these circumstances, we would not consider the grain buggies as 'motor vehicles,' and no Federal requirements would apply to them. They would, however, remain subject to any appropriate requirements of the State in which they are used.; I hope that this answers your questions. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4788OpenSatoshi Nishibori, Vice President Industry-Government Affairs Nissan Research & Development, Inc. 750 17th Street NW Suite 902 Washington, DC 20006; Satoshi Nishibori Vice President Industry-Government Affairs Nissan Research & Development Inc. 750 17th Street NW Suite 902 Washington DC 20006; "Dear Mr. Nishibori: This responds to your letter dated June 28, 199 requesting an interpretation of how the requirements of FMVSS 101, Controls and Displays, would apply to two vehicle systems Nissan is considering using. By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter and during a discussion between Kazuo Iwasaki of your staff and Mary Versailles of my staff in our offices on July 13th. I. Car Phone Nissan is considering introducing a car phone in certain passenger cars which has five illuminated displays. The first display shows the number being dialed. The display is illuminated whether or not the phone is in use, and the number dialed continues to be displayed while the phone is in use. The second display illuminates the push buttons. The display becomes illuminated when the first button is pushed, and remains illuminated for 10 seconds. The remainder of the car phone displays are LED indicators. The first indicator (IU) is illuminated when the phone is 'in use'. The second indicator (NS) is illuminated when cellular phone service is not available. The third indicator (RM) is illuminated when outside the system's local operating area if the system is able to lock onto an available phone line. It is our understanding that there will be times when none of these three LED's will be illuminated and times when more than one of the LEDs could be illuminated (for example, both the IU and RM indicators). None of the car phone displays can be turned off while the ignition switch is in the 'ON' position. The illumination is not variable in any display. You asked whether the car phone displays are 'telltales' or other 'sources of illumination,' within the meaning of section S5.3.5, and whether the system is consistent with the requirements of FMVSS 101. Based upon our understanding of their functioning, the three LED indicators (IU, NS, and RM) would appear to be telltales. Both the IU and RM displays 'indicate the actuation of a device', while the NS display indicates 'a failure to function'. Because the displays are not listed in the standard, and because they are exempt from the requirements of section S5.3.5 because they are telltales, they are not subject to any illumination requirements. The other displays are not telltales. The functions of both the first display ('number dialed') and the second display ('push button') are not among those listed in the definition of a telltale. The 'number dialed' display provides information in much the same way as a fuel gauge. The illumination of the push buttons functions to facilitate dialing. Because these displays are not among those listed in Standard No. 101, and because they are not telltales, they are subject to the requirements of section S5.3.5. Therefore, these displays must 'have either (1) light intensity which is manually or automatically adjustable to provide at least two levels of brightness, (2) a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or (3) a means of being turned off.' Based upon your description, none of these requirements are currently met. II. Air-conditioning Indicator Light In certain vehicles, Nissan uses an indicator light that is illuminated only if both the air-conditioning operating switch and the ignition switch are in the 'ON' position. You indicate that you believe the indicator is a telltale, and that if it is a telltale 'it would appear to meet the requirements of section 5.3.4, since the display is bright enough to be visible in all ambient lighting conditions.' Because the indicator light indicates actuation of a device, i.e., the air conditioner, you are correct that it is a telltale. NHTSA would like to clarify that, with the exception of the requirements of section S5.3.5, FMVSS 101 regulates only controls and displays listed in the standard. Since the air-conditioning indicator light you describe is not listed in the standard, and because telltales are exempt from the requirements of section S5.3.5, there are no illumination requirements. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1070OpenMr. R. K. Ferwerda, President, Great Southern Equipment Company of Tampa, 1023 South 50th Street, Tampa, FL 33619; Mr. R. K. Ferwerda President Great Southern Equipment Company of Tampa 1023 South 50th Street Tampa FL 33619; Dear Mr. Ferwerda: This is in reply to your letter of January 31, 1973, requesting 'a application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks'.; Under NHTSA regulations, the operations you perform appear to make yo a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, 'Manufacturer Identification'.; Copies of NHTSA regulations may be obtained as indicated on th enclosed. 'Where to Obtain Motor Vehicle Safety Standards and Regulations'. We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4622OpenRobert Knauff, President Applied Research & Design, Inc. Markethouse Suite 405 289 E. 5th St St. Paul, MN 55l0l; Robert Knauff President Applied Research & Design Inc. Markethouse Suite 405 289 E. 5th St St. Paul MN 55l0l; "Dear Mr. Knauff: On April 21, l989, you wrote the agency with respec to the acceptability of your collision avoidance lighting system, as both original and aftermarket lighting equipment, under Federal laws and regulations. Because the patent application you enclosed was stamped 'Confidential', Ms Kathy DeMeter, the Assistant Chief Counsel for General Law, wrote you on May 26 for a clarification of your intent regarding confidential treatment of the material you submitted. We have received your letter of June 8 to Ms DeMeter containing your 'permission to use' the confidential information in responding to you. As Ms DeMeter explained, the issue is not whether we may 'use' the information, but whether it may be made available to the public, for the agency cannot provide non-public interpretations. Your statement is not a clear waiver of a claim of confidentiality, however, Ms DeMeter states that you told her that you were no longer requesting confidential treatment as the patent application has been filed, and we regard that as a sufficient oral waiver of your request. Your invention is intended as an advance warning of braking, and consists of 'a single pulse of light lasting approximately 40 millionths of a second.' You wish to know of the acceptability of this device as both original and aftermarket lighting equipment in six different configurations. First, let me observe that the agency has not performed research with respect to a device such as yours. However, it is concerned with the effects of glare, whether disabling or discomforting in nature. It would be concerned if the after-image left by the pulse of light from your device created a momentary distraction in drivers from their immediate driving task, in this instance, causing them to hesitate rather than to apply the brake pedal. We note the concern expressed by the State of Minnesota in its l987 and l988 letters to you. Under the assumption that a pulse of 40 millionths of a second does not produce this effect, I shall proceed to a discussion of your device with respect to the situations you envision. The first configuration is as 'a high-mount stop light system.' A center high-mounted stop lamp has been required for all passenger cars manufactured on and after September l, l985, by Federal Motor Vehicle Safety Standard No. l08 Lamps, Reflective Devices, and Associated Equipment. Paragraph S5.4 of Standard No. l08 states that the center stop lamp 'shall not be combined with any other lamp or reflective device.' This is the only flat prohibition in Standard No. l08 against physical combinations of lighting equipment, and as such, we read it as forbidding use of the collision avoidance pulse. Thus, your device would not be acceptable as original equipment for passenger cars. As for its suitability as original equipment on other types of motor vehicles, it is permissible as long as it does not impair the effectiveness of other lamps that Standard No. l08 requires (paragraph S5.1.3). With respect to the aftermarket, the pulse could not be incorporated in a center high-mounted stop lamp intended to replace original equipment high-mounted stop lamps, because replacement equipment must conform with original equipment requirements. However, the lamp would be permissible for installation on passenger cars manufactured before September l, l985, and on any other vehicle as well. Whether or not subject to a standard, all aftermarket equipment is subject to the Federal requirement that its installation not lead to a rendering inoperative (wholly or partially) of equipment installed in accordance with any Federal safety standard. For example, if your light utilized the wiring of stop lamps and somehow diminished the light output, we would regard its installation as rendering the stop lamps partially inoperative within the meaning of the prohibition. This prohibition applies to motor vehicle manufacturers, distributors, dealers and repair shops. It does not, however, apply to changes made by a person to his or her own vehicle. Because the agency has no standards for your device, a State may set its own standard for it, or even prohibit it altogether even though it is not prohibited under Federal Law. This is implied by the State of Minnesota to you in its letter of August l6, l988. We are unable to advise you on State law, and suggest that you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Your second configuration is as 'an enhancement for existing vehicular brake lights.' We interpret this as meaning a combination of the pulse lamp with a stop lamp. This is not a forbidden equipment combination for original equipment, but it is subject to the same restriction (paragraph S5.1.3) as all supplementary lighting equipment: that it not impair the effectiveness of required lighting equipment. Similarly, its installation as an aftermarket device is permissible if it does not violate the rendering inoperative prohibition mentioned above. Your third configuration involves 'use in motorcycle taillights'. Taillamps are steady burning in nature, activated when the headlamps are on. Today, most motorcycle headlamps are activated when the ignition is turned on, meaning that the taillamp operates at all times that the motorcycle is in motion. Your letter does not indicate the frequency of the pulse, but we must raise the possibility that a pulse from the taillamp might impair the effectiveness of signals from the stop lamp, or from the turn signal lamps. If this possibility occurs, the device could not be incorporated into original equipment or replacement motorcycle taillamps for the reasons discussed in the preceding paragraph. The fourth configuration you envision involves 'use for 8-way lights in school bus systems.' This would appear to mean incorporation in the red warning lamps of the red and amber warning lamp system. This system operates automatically when the bus door is opened (paragraph S5.1.4). This appears to enhance the warning purpose of the lamps, and not impair their effectiveness. Nor does it appear to 'render inoperative', within the meaning of the aftermarket prohibition. We must advise you, however, that States are particularly sensitive to issues of school bus safety and lighting. 'Ambulance lighting' is your fifth concern. The agency has no specific requirements for warning light systems on ambulances. Such systems, of course, must not impair the effectiveness of original equipment lighting installed in accordance with Standard No. l08. Strobe-type warning lamps on the vehicle top, at front and rear, have been considered permissible. Finally, you ask about 'off-road type vehicles, i.e., snowmobiles, boats, etc.' The agency has no jurisdiction over vehicles that are not manufactured primarily for use on the public roads, and thus we cannot answer this question. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1420OpenBert W. Rein, Esq., Kirkland, Ellis & Rowe, 1776 K Street, N.W., Washington, DC 20207; Bert W. Rein Esq. Kirkland Ellis & Rowe 1776 K Street N.W. Washington DC 20207; Dear Mr. Rein: We have reviewed the revised defect notification letters i International Harvester campaigns numbers 73505, 73503, 73511, 73513, G-73520 and G-73521 which you forwarded to us. We believe these revised letters conform to 49 CFR Part 577. However, we believe the letters in campaigns 73505, 73513, and 73521, which involve an accelerator problem, should, in response to the requirements of S 577.4(c)(4), include some guidance as to how the driver can stop the vehicle.; While we find the letters you submit to conform to the requirements, w are of the opinion that, in general, the format you use to describe the defect (577.4(c)) goes little further than meeting the regulation's literal requirements. We suggest you review the letters we have received from other companies in order to obtain an indication of other, more complete approaches to meeting the requirements. While we had indicated that we might furnish you specific letters as examples, we prefer not to recommend any specific letter as a model or to imply that it is preferable to others.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3108OpenMr. Hisakazu Murakami, Nissan Motor Co., Ltd., Suite No. 1012, 1028 Connecticut Avenue, N.W., Washington, DC 20036; Mr. Hisakazu Murakami Nissan Motor Co. Ltd. Suite No. 1012 1028 Connecticut Avenue N.W. Washington DC 20036; Dear Mr. Murakami: This responds to your recent letter requesting an interpretatio concerning the proper 'designated seating capacity' for three hypothetical seat designs. You ask whether each of the designs would be permitted to have only two 'designated seating positions.'; The amended definition of 'designated seating position' provides, i part, that any bench or split-bench seat having greater than 50 inches of hip room shall have not less than three designated seating positions, unless the seat design or vehicle design is such that the center position cannot be used for seating.; Your three hypothetical designs are derived from a basic seat desig having 52 inches of hip room (Figure 1 in your letter). This basic design would be required to have three designated seating positions since it has greater than 50 inches of hip room, unless the center position cannot be used because of some obstruction or other impediment. You ask whether the agency would consider the three hypothetical designs illustrated in your letter to adequately establish impediments to use of the center position.; Your 'Figure 2' illustrates an unpadded depression at the cente position of the bench seat. Since this center depression is unpadded, 3.1 inches deep and 6.7 inches wide, it is the agency's opinion that the center position lacks an essential attribute of a seating position and would not likely be used for seating (even though there might be some unorthodox use of the position from time to time). If a seat of this design is equipped with seat belt assemblies, location of assembly hardware in the center depression would further clarify that the area is not a seating position. It must be emphasized, however, that designs of this type would be required to have three designated seating positions if the depth and width of the depression is so minimal that a person could easily straddle the depression and use the center position. Also, stiffness of seat belt assembly hardware located in the center depression becomes a more determinative factor the more narrow the width of such a depression.; The seat design illustrated in 'Figure 3' of your letter includes 'partition pipe' at the center of the seat cushion. Whether such a design would preclude the use of the center position would depend greatly on the physical dimensions and characteristics of the 'pipe' that is used and whether it is removable. If the 'pipe' were made of soft, pliable padding similar to the other portions of the seat, for example, the 'pipe' might not be sufficient to discourage use of the center position. Since your letter provides no information on the nature of the 'partition pipe' that is illustrated, the agency cannot offer an opinion concerning this design.; In 'Figure 4,' there is a padded 'swelling' in the center sea position. Although the Figure specifies a height of 3.9 inches at the front of the 'swelling,' it appears that the 'swelling' slants down toward the seat back so that it is only about one-half inch high where it joins the seat back. The illustration also does not describe whether the 'swelling' is made of soft padding or of some rigid material. Without this information, the agency cannot offer an opinion concerning this design. I would point out, however, that if the 'swelling' is made of soft, flexible padding, it would not likely discourage use of the center position. In fact, if as it appears the 'swelling' slants down to the seat back to create a 'saddle effect,' young children might be encouraged to use this center position.; To summarize, it is the agency's opinion that 'Figure 2' in your lette illustrates a seat design that could qualify as having two designated seating positions. Regarding Figures 3 and 4, your letter did not include sufficient information for the agency to provide an opinion. On the basis of the information that was provided, however, I would say that these two designs are very dubious and do not indicate an adequate attempt on the part of the manufacturer to clarify that the center position is not to be used. It does not behoove a manufacturer to attempt to come narrowly within the meaning of the amended definition of 'designated seating position.' It would be much wiser to make sure that there is no question that the center position is not to be used. In the design illustrated in your 'Figure 4,' for example, you could easily design the 'swelling' to be 4 or more inches tall from front to rear and made of a rigid material, and there would be no question concerning your compliance.; Finally, I would emphasize that this letter only represents th agency's opinion based on the information supplied in your letter. The NHTSA does not pass approval on any vehicle design, for any safety standards, prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles comply with all applicable safety standards and regulations, and to certify its vehicles in accordance with that determination.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1135OpenMr. J. C. Eckhold, Director, Automotive Safety Office, Ford Motor Company, Dearborn, MI 48121; Mr. J. C. Eckhold Director Automotive Safety Office Ford Motor Company Dearborn MI 48121; Dear Mr. Eckhold: By petition for rulemaking dated November 15, 1973, the Ford Moto Company requested an amendment of Motor Vehicle Safety Standard No. 210 with respect to the strength required of the anchorages for the pelvic portion of a Type 2 seat belt assembly. After considering the merits of the requested amendment, we have decided to deny your petition.; As stated in your petition, the anchorages for the pelvic portion of Type 2 assembly are presently subject to two strength requirements under Standard 210. Section S4.2.2 provides that, when tested in conjunction with the upper torso anchorage, the pelvic anchorages must withstand a force of 3,000 pounds applied through the seat belt assembly. Section S4.2.1 provides that, when tested separately from the upper torso anchorage, the pelvic anchorages must withstand a force of 5,000 pounds applied through the seat belt assembly.; It is Ford's position that the 5,000 pound requirement of S4.2.1 wa intended to be applicable to anchorages used with Type 2 assemblies having detachable shoulder belts, and that it was not intended for use with integral Type 2 assemblies. Although the NHTSA would agree that the most widely used Type 2 assembly at the time of the standard's adoption had a detachable shoulder belt, the agency does not agree that the 5,000 pound requirement should be limited to anchorages used with such belts.; The 1974 model year will be the first in which integral Type 2 belt are installed in all passenger cars. We anticipate that a measurable percentage of persons riding in cars with the new belts will somehow avoid using the shoulder belt, thereby placing the lap belt under the same potential stress as any other lap belt when used by itself. In light of this possibility, and in consideration of the fact that keeping the pelvic anchorage force at the currently required level of 5,000 pounds will not impose additional manufacturing costs on manufacturers, we do not consider it advisable to grant the requested amendment at this time.; The petition of Ford Motor Company for an amendment of S4.2.1 of Moto Vehicle Safety Standard No. 210 and for a complementary amendment to the test procedures of S5.1 of the standard is therefore denied.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs; |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.