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: nht81-2.15OpenDATE: 04/16/81 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Rivkin, Sherman and Levy TITLE: FMVSR INTERPRETATION TEXT: APR 16 1981 NOA-30 Donald M. Schwentker, Esq. Rivkin, Sherman and Levy 900 17th Street, N.W. Suite 1100 Washington, D.C. 20006 Dear Mr. Schwentker: This letter is in reference to our March 20, 1981, meeting with you and your client, Jaguar. The meeting was held at your request and concerned whether future product plans of Jaguar are consistent with existing Federal motor vehicle safety standards. As we indicated to you at the beginning of the meeting, the agency does not give oral interpretations. The agency holds such meetings with industry representatives in order to help those representatives identify questions which should be submitted in writing to the Office of Chief Counsel for interpretation, and to familiarize agency personnel with the specific nature of products at issue. One concern expressed by Jaguar in that meeting was the confidentiality of its future product plans. In issuing letters of interpretation, the agency ordinarily will provide confidential treatment for future product plans. A request for confidential treatment should accompany the request for interpretation. The agency published a final rule concerning confidential business information in the Federal Register (46 FR 2049) on January 8, 1981. While that rule is not yet effective, we suggest that its procedures for requesting confidential treatment be followed. We would note that even where the agency provides confidential treatment for future product plans, letters of interpretation issued by the agency are made available to the public for inspection. In drafting a letter of interpretation, only the information necessary for that interpretation would be stated. The agency does not issue private letters of interpretation, however. During the March 20 meeting, you indicated that Jaguar might find it preferable not to request an interpretation in light of its concerns about confidentiality. We would like to remind you that informal discussions with agency personnel should not be relied on as evidence that the agency approves of stated product plans or that those plans comply with Federal motor vehicle safety standards. Moreover, the fact that particular issues concerning compliance with Federal motor vehicle safety standards were not raised at the March 20 meeting should not be taken to mean that such issues do not exist. Sincerely, Frank Berndt Chief Counsel |
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ID: nht88-1.91OpenTYPE: INTERPRETATION-NHTSA DATE: APRIL 8, 1988 FROM: M. IWASE -- MANAGER, TECHNICAL ADMINISTRATION DEPT., KOITO MFG. CO., LTD. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA TITLE: Headlamp Aimability (Docket No. 85-15; Notice 5) ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO M. IWASE FROM STEPHEN P. WOOD; (A35; STD. 108). ALSO ATTACHED TO LETTER DATED 10-18-89 TO ERIKA Z. JONES FROM M. IWASE AND LETTER 9-12-88 TO M. IWASE FROM ERIKA Z. JONES. TEXT: We would ask you to provide us with your confirmation of interpretation of proposed rulemaking; Headlamp Aimability as cited in Docket No. 85-15; Notice 5 of Federal Register dated Dec. 29, 1987. We are now in the stage of studying and developing a new technology of on-vehicle aiming (Vehicle Headlamp Aiming Device) in conformity with the said NHTSA proposal so that we can adopt it into our headlamps as soon as possible in case that the proposal is put into effect as a rule. Upon our careful review to this proposal and also through our talk with Mr. Richard Van Iderstine / Rulemaking Office of NHTSA, our ideas for headlamp aiming configuration as shown in the attached sheet are fully consistent with NHTSA's intention for hea dlamp aimability proposed therein, we believe. Please refer to the attached sheet in which our specific questions are shown. We would greatly appreciate it if you would kindly treat Structure-2 of attached as "Confidential" because it involves our own idea for development of on-vehicle aiming which has something related with our patent application intended hereafter. Upon your kind review to this matter, your prompt reply would be greatly appreciated. Attachment Question: Whether the following structure of on-vehicle aiming could be accepted in case that the proposed requirements of S7.7.5.2 "On-Vehicle aiming" would be regulated in the FMVSS No. 108 as they are. Structure-2: Built-in Reflector System [GRAPHICS OMITTED]1) Lens and Housing are bonded together. 2) Built-in reflector is mounted with aiming mechanism onto Housing. 3) Aiming is made by adjusting faced direction of built-in reflector. 4) Spirit level is mounted on built-in reflector and can be seen through lens for the vertical aiming. 5) Headlamp assembly can comply with the applicable requirements of FMVSS No. 108. |
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ID: 07-007338drn Sept 16 cleanOpenHugo De Roo, Area Export Manager B & C Export USA Van Hool NV Bernard Van Hoolstraat 58 B-2500 Lier Koningshooikt BELGIUM Dear Mr. De Roo: This responds to your letter asking about Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release, in connection with a double decker bus, the TD925 Series, that Van Hool intends to sell in the United States. From the information you provided, we understand that the upper deck of the TD925 bus is fully enclosed. You provided blueprints and photographs of the bus, and a technical note discussing how you plan to meet the emergency exit requirements in FMVSS 217 and the counterpart European regulations. You did not ask any particular question about those plans. Accordingly, as your bus exceeds 10,000 lb., gross vehicle weight rating (GVWR), we focused on paragraph S5.2.2 of the standard, which sets for the requirements for the amount of unobstructed emergency opening in those buses. As explained below, the standard does not contemplate your particular kind of bus and, therefore, does not presently specify any requirements concerning a means by which lower deck occupants can gain access to a roof exit in the upper deck of such a bus. I wish to emphasize that under the National Traffic and Motor Vehicle Safety Act, it is your responsibility as a manufacturer of motor vehicles to ensure compliance with the Federal motor vehicle safety standards. The National Highway Traffic Safety Administration (NHTSA) provides interpretations of the Safety Act and the requirements of the safety standards issued under the Safety Act, but our interpretations are based on the information provided in interpretation requests. The standard at S5.2.1 provides manufacturers with some options as to how they provide emergency exits. It appears that you intend to provide the exits by way of meeting S5.2.2. As noted above, S5.2.2 specifies requirements for the amount of unobstructed opening for buses with a GVWR of more than 10,000 pounds. Since the materials you provided state that the GVWR of the TD925 is 56,500 lbs, S5.2.2.2 would apply. S5.2.2.2 states: S5.2.2.2 Buses with GVWR of more than 10,000 pounds. Buses with a GVWR of more than 10,000 pounds shall meet the unobstructed openings requirements in S5.2.2.1 by providing side exits and at least one rear exit that conforms to S5.3 through S5.5. The rear exit shall meet the requirements of S5.3 through S5.5 when the bus is upright and when the bus is overturned on either side, with the occupant standing facing the exit. When the bus configuration precludes installation of an accessible rear exit, a roof exit that meets the requirements of S5.3 through S5.5 when the bus is overturned on either side, with the occupant standing facing the exit, shall be provided in the rear half of the bus. You state that the lower deck has two emergency exit windows on the left side, two emergency exits on the right side, and two emergency doors on the right side. On the upper deck, there are four emergency exit windows on the left side, four emergency exit windows on the right side, and two roof emergency exits. Judging from photographs of the rear of the TD925 and the schematic, there is no rear exit (door or window) on the bus. Accordingly, a roof exit must be provided. The question is whether two exits in the roof satisfy that requirement, given that access to the upper deck is provided by two stairways on the right side of the bus. We note that these staircases might be difficult for lower deck occupants to use in order to reach the roof exits if the bus overturned on its left side. After careful consideration of the standard and its history, our conclusion is that S5.2.2.2 does not contemplate this particular kind of bus (a double decker bus whose upper deck is enclosed) and, therefore, does not presently specify any requirements concerning a means by which lower deck occupants can gain access to the roof exit of such a bus if it falls on either side. However, we note that the overall purpose of FMVSS 217 is to provide a means of readily accessible emergency egress. To the extent that manufacturers design their buses to ensure that lower deck occupants have adequate access in all situations, there is no need for changed regulatory language to implement the expressed purpose of the standard. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel ref:217 d.9/18/08 |
2008 |
ID: 11064Open Mr. Curt Stiede Dear Mr. Stiede: This responds to your letter to Walter Myers of my staff, and to subsequent telephone conversations with Mr. Myers, about this agency's standards for the product you manufacture. At Mr. Myers' request, you provided detailed schematics of your product and several pictures of it connected to various types of towed vehicles. It appears from these that the product is a trailer converter dolly. You stated that your product is intended as a towing device for a variety of trailers, such as "gooseneck flatbed, equipment, utility, farm equipment, horse trailers, along with 5th wheel recreational vehicles." You further stated that it has a combined load range of 3,500 to 15,000 pounds, depending on the trailer weight and engine power of the towing vehicle. You stated that there may be some state restrictions applicable to your trailer dolly, and suggested that some Federal regulations may have to be amended to address such a vehicle. By way of background information, this agency has the authority under Federal law to issue Federal motor vehicle safety standards (FMVSS) and related regulations applicable to new motor vehicles and new items of motor vehicle equipment. Vehicle and equipment manufacturers are responsible for "self- certifying" that their products comply with all applicable FMVSSs. They must also ensure that their products are free of safety-related defects. Once the vehicle or equipment is sold to the first retail customer, the product is no longer subject to the FMVSSs. The first question you raise is whether your trailer dolly is a "motor vehicle." The answer is yes. "Motor vehicle" is defined in 49 U.S. Code (U.S.C.) '30102 as: [A] vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways, but does not include a vehicle operated only on a rail line. Your trailer dolly clearly meets the definition of a motor vehicle since the dolly is designed to be drawn by mechanical power on the streets, roads, and highways. It is referred to in NHTSA regulations (49 Code of Federal Regulations (CFR), section 571.3) as a "trailer converter dolly," which is defined as "a trailer chassis equipped with one or more axles, a lower half of a fifth wheel and a drawbar." We note that a trailer converter dolly, although fabricated on a trailer chassis, is not a trailer. It is a motor vehicle designed to tow another vehicle rather than carry persons or property itself. The following standards and regulations apply to your manufacture of the trailer converter dolly. As a manufacturer of a motor vehicle, you must submit certain identifying information to NHTSA in accordance with 49 CFR Part 566, Manufacturer Identification (copy enclosed). You must also ensure that a dolly with a hydraulic braking system must meet FMVSS No. 116, Motor vehicle brake fluids (49 CFR 571.116). You must also comply with the requirements of 49 CFR Parts 567, Certification. In addition, in the event that you or NHTSA determines that your product contains a safety- related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. The enclosed information sheet briefly describes those responsibilities. As Mr. Myers discussed with you, since your trailer dolly is designed and intended for interstate marketing and transport, the Federal Highway Administration (FHWA) may have requirements applicable to your product. Accordingly, I will forward a copy of your letter to Mr. James Scapellato, Director, Office of Motor Carrier Research and Standards, FHWA, this address, for further response. In the alternative, you may contact Mr. Larry Minor of Mr. Scapellato's staff at this address or at (202) 366-4012 to discuss pertinent FHWA regulations. Finally, you mentioned in your letter that some states may have certain restrictions or requirements for your trailer dolly. NHTSA does not have information on those state requirements. However, you may be able to obtain such information from: American Association of Motor Vehicle Administrators 4200 Wilson Boulevard, Suite 1000 Arlington, VA 22203 (703) 522-4200 I hope this information is helpful to you. Should you have any further questions or seek additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992, or by fax at (202) 366-3820. Sincerely,
John Womack Acting Chief Counsel Enclosures
ref:116#571#566#567 d:10/16/95
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1995 |
ID: knapheide.ztvOpenMr. John D. Evans Dear Mr. Evans: We are responding to your letter of October 10, 2002, asking five questions with respect to interpretations of the "early warning reporting" final rule (49 CFR Part 579, Subpart C). Your first question was:
In adopting a definition of "structure," we observed that "we believe it is important to obtain information about problems with a vehicles structure, since many other systems and components attach to the structure" (67 FR at 45861). Section 579.22(b)(2) establishes reporting codes for 22 systems and components of medium heavy trucks and buses. Only "structure" is appropriate for reporting issues directly related to the body of a vehicle, so all reports regarding the body should be filed in the "structure" category. See also, response to final question below. Your second question was:
The purpose of the early warning reporting rule is to provide NHTSA with an earlier indication of potential safety problems in part through submission of the number of warranty claims relating to specified components and systems. These problems generally have their origin in the design or manufacture of a motor vehicle. They do not have their origin in events that occur after a vehicle has left the direct control of a manufacturer, such as dings in shipping, damage from leaking water (although "paint failure" cited by the commenter could indicate a deficiency in manufacturing), and the like, or, as Knapheide put it, warranty issues that have "nothing to do with the vehicle as manufactured by the OEM." Your third question was:
Generally, accessories that are installed inside of a service body would appear to have little potential for creating a motor vehicle safety-related defect. We therefore do not expect warranty claims on "these types of accessories" to be reported to NHTSA unless they do affect safety, such as a problem that creates the risk of a fire. Your fourth question was:
Ancillary pieces of equipment added to the exterior of a truck body can be defective in themselves and they have the potential for creating a safety-related defect, and warranty claims involving them must be reported. Since there is no code under Section 579.22(b)(1) for reporting systems and components other than the 22 specified, "structure" is the appropriate reporting category. You prefaced your final question with the explanation that Knapheide is a manufacturer of original and replacement truck body equipment that it sells through distributors. One of the distributors is Knapheides wholly-owned subsidiary while four others "have common shareholders" with Knapheide. These five entities are all final stage manufacturers (as well as distributors). You asked:
We interpret this question as based on the assumption that each of the five manufacturing corporations will report to NHTSA separately. If Knapheide itself were not a final stage manufacturer, it would be considered a manufacturer of motor vehicle equipment other than child restraint systems and tires, and subject to the less extensive requirements of Section 579.27. Its wholly owned subsidiary would have to report as a vehicle manufacturer, and if it manufactured 500 or more vehicles per year of any specified category, it would have to file comprehensive reports as under Section 579.21 and/or Section 579.22. If you have any questions, you may call Taylor Vinson of this Office (202-366-5263). Sincerely, Jacqueline Glassman ref:579 |
2003 |
ID: nht90-4.93OpenTYPE: Interpretation-NHTSA DATE: December 24, 1990 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Mitch L. Williams -- President, Hella Inc. TITLE: None ATTACHMT: Attached to letter dated 11-1-90 from Mitch L. Williams to Richard Van Iderstine (OCC 5441); Also attached to letter dated 11-8-90 from Mitch L. Williams to Richard Van Iderstine TEXT: This is in reply to your letters of November 1 and 8 to Richard Van Iderstine of this agency. In your letter of November 1 you ask "How would NHTSA view the addition of a rear spoiler with integrated third rear brake light to a vehicle already originally equipped with a third rear brake light?" There are two relevant provisions of Standard No. 108 that deal with your question. The first is relevant if installation of the spoiler prevents the original lamp from meeting the photometric or visibility requirements of Standard No. 108. If this occ urs, compliance may be maintained by installing another center high-mounted lamp that meets all requirements of Standard No. 108. See S5.3.1.1. Presumably, the lamp in the spoiler is designed, or could be designed, to comply to all applicable requireme nts. A further question is whether two center high-mounted stop lamps are permissible. An auxiliary lamp is prohibited by S5.1.3 if it impairs the effectiveness of the lighting equipment required by Standard No. 108. One example of impairment is when the au xiliary lamp creates confusion as to the function of the original lamp. The motoring public is used to seeing only one center lamp in operation. Although we cannot reach a definitive conclusion that an auxiliary center stop lamp would impair the effect iveness of the original center stop lamp, it would probably be prudent to ensure that there is only one center stop lamp in operation. Thus, if the spoiler lamp complies with Standard No. 108, the original lamp may be disconnected. If the spoiler lamp d oes not comply with Standard No. 108 and the original lamp remains in compliance with Standard No. 108, the question of impairment arises. On balance, it would appear unlikely that impairment would result from this configuration. In your letter of November 8 you ask several questions with respect to the installation of center high-mounted stop lamps on pickup trucks. On May 31, 1990, NHTSA proposed that the lamp be installed on pickup trucks and some other types of vehicles as w ell. We anticipate publishing a final rule on this issue in the Federal Register in the near future. The preamble to the rule will address your questions on location of the lamp. |
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ID: nht91-6.46OpenDATE: November 1, 1991 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Ronald Van Campenhout -- US Liaison Officer, ABC Coach/Van Hool TITLE: None TEXT: This responds to your letter of August 29, 1991, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a situation you recently encountered in Florida. You state that "one of our client's coaches was stopped by a DOT-inspector and a compliance-audit with FMVSS-standards was performed." According to the DOT inspector, "the third, centrally mounted, rear stoplight needs to be illuminated, not only when the brake pedal gets activated, but also whenever the coach is parked with the engine running at high idle speed . . . ." It is your interpretation that the center light "should only come on when pressure is applied to the brake pedal." Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, is the Federal motor vehicle safety standard (FMVSS) that applies to the center highmounted stop lamp. Standard No. 108 does not require that the center highmounted stop lamp be activated when a vehicle is parked with the engine running at idle. In fact, S5.5.4 of Standard No. 108 specifies that the center lamp shall be activated only upon application of the service brakes. Thus, your interpretation is the correct one. There are other anomalies reported in your letter that I would like to address. First, Standard No. 108 does not require buses manufactured before September 1, 1993, to be equipped with a center highmounted stop lamp (and, after that date, only buses with a GVWR less than 10,000 pounds and less than 80 inches in overall width must be so equipped). Apparently, the inspector was not informed that the requirement for certain buses to be equipped with center highmounted stop lamps does not take effect for nearly two more years. Second, this agency has no inspectors performing compliance audits of vehicles in service. We surmise that your coach may have been inspected by either the Florida State DOT, or the U.S. DOT's Federal Highway Administration (FHWA) for compliance with the Motor Carrier Safety Regulations. The FHWA, which concurs in this letter, does not require in its Motor Carrier Safety Regulations or elsewhere that stop lamps on a bus be illuminated when the service brakes are not being applied, even if the vehicle is idling. |
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ID: 12328.ztvOpen Julius Fisher, Esq. Re: U.S. Patent No. 5,389,913 Warning System for Vehicles Your file Jodee P-8A Dear Mr. Fisher: This is in reply to your letter of August 6, 1996, to the former Chief Counsel, Samuel Dubbin, with respect to whether a warning system for motor vehicles which you describe would be permitted by paragraph S5.1.3 of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment (49 CFR 571.108). As you describe it, the system "provides a visual indication of a warning situation through use of the parking lamps, high beam headlamps, and back-up lamps." The system operates as follows: "when the horn is sounded, electrical circuits are energized . . . which cause the high beam of the headlamps to flash on and off, in synchronism with the flasher. If the high beams or back-up lamps are already in their 'on' state, they will change to a 'flashing' state." In addition, the parking lamps are activated in a steady-burning state when the horn is sounded (no change takes place if the parking lamps are already on). If the lower beams are on when the horn is sounded, there is no change either; only the upper beams begin to flash. We note from reading the patent that the system incorporates an "off relay delay" which "is set for a predetermined time during which it stays in its on state after being energized. This predetermined time might be for five seconds." We note also that the system may be extended to other lamps but that the inventors have not chosen to do so because "such might produce confusion and/or an inappropriate response." Finally, we note that the flash rate is unspecified but can be changed. A range of from a quarter of a second to a second is mentioned. Standard No. 108 establishes lighting requirements that a motor vehicle must meet up to the time it is first purchased in good faith other than for resale. When a vehicle has been manufactured to conform with Standard No. 108, a dealer must not add optional equipment that creates a noncompliance. The principal provision of Standard No. 108 that affects the warning system is paragraph S5.5.10 which prescribes wiring requirements for lighting equipment in use. Under paragraph S5.5.10(b) "Headlamps and side marker lamps may be wired to flash for signaling purposes". However, under paragraph S5.5.10(d), "All other lamps shall be wired to be steady-burning." This means that it is permissible under paragraph S5.5.10(b) for the upper beam headlamps to flash, but the warning system would create a noncompliance with paragraph S5.5.10(d) when the back-up lamps flashed. The acceptability of optional lighting equipment is also dependent upon paragraph S5.1.3 which forbids the addition of any equipment "that impairs the effectiveness of lighting equipment required by this standard." The warning system's activation of the parking lamps would not appear to have an impairing effect on the front lighting equipment required by Standard No. 108. Nor can we conclude that a flashing of the upper beam when the lower beam is on would have an impairing effect. Under Federal law, the acceptability of the warning system as an item of equipment sold in the aftermarket is determinable by 49 U.S.C. 30122. This section prohibits manufacturers, distributors, dealers, and motor vehicle repair businesses from "making inoperative" any device or element of design installed in accordance with a Federal safety standard. As we have discussed, the system would create a noncompliance in the operation of the back-up lamp, which, in our opinion, is the same as making it inoperative. However, this prohibition does not apply to an owner who installs the warning system. Nevertheless, the warning system would remain subject to acceptability under local laws. We are unable to advise you on these and suggest that you consult local officials in areas where the inventors would like to sell their warning system. We appreciate the concern shown in the patent that the system not create confusion and/or an inappropriate response from other drivers. But we believe it more likely than not that a driver ahead of a vehicle equipped with the warning system will indeed be confused when confronted with the sounding of a horn and the sudden presence of flashing upper beam headlamps in the rear view mirrors, and will not understand the "message" that is being conveyed. How this might impact safety is speculative. But with the increasing trend towards aggressive drivers on the roads, a system of this nature could be subject to abuse, even if its flash rate and duration were standardized and immutable. If you have further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack ref:108#VSA |
1996 |
ID: nht88-3.95OpenTYPE: INTERPRETATION-NHTSA DATE: 11/03/88 EST FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA TO: AL CUNNINGHAM -- CHIEF ENGINEER, WESBAR CORPORATION ATTACHMT: 9/14/88 letter from Al Cunningham to Erika Jones (Std. 108; OCC 2564) TEXT: This is in reply to your letter of September 14, 1988, attaching two lamps, and asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to each. Specifically, you wish clarifications of SAE J588e, "the definition . . . 2.2 'Mu ltiple Compartment Lamp' and the term used in 3.1 'Single Compartment Lamp'". SAE Standard J588e Turn Signal Lamps, incorporated by reference in Standard No. 108, defines a multiple compartment lamp as "a device which gives its indication by two or more separately lighted areas which are joined by one or more common parts such as a housing or lens." The term "single compartment lamp" is not used in section 3.1, though the term "single compartment photometric requirements" is used in referencing the values for one "lighted section" given in Table 1 of J588e. For purposes of this discussion we shall define a "single compartment lamp" as one that gives its indication by one lighted area. You have described your first lamp as "a housing with back and four sides containing a two filament bulb with a single lens covering face of housing." The lamp photometrically complies to the basic requirements of a Class A tail, stop and turn signal lam p. You have asked if this lamp is a single compartment lamp. The answer is yes; your model 3504 Exp. contains a single light source and has a single lighted area. Your second lamp is described as "a housing with a back, two sides and one end, containing one #57 bulb and one #1157 (2 filament) bulb. This housing is closed with two red lenses, one on the end and one on the face with an additional clear lens on bott om side. This lamp also complies to all standards of a class A tail, stop and turn lamp plus side marker clearance, license plate illuminator and class a reflex reflector side and rear". You ask if this also is a single compartment lamp. The answer is yes. The term "separately lighted area" in the definition of a multiple compartment lamp is understood to mean an area that is 2 illuminated by a separate light source. In your model 3504 the turn signal light is provided by the #1157 bulb alone, and not in tandem with the #57 bulb. I hope that this provides the clarification you seek. We are returning your lamps under separate cover. |
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ID: 3135oOpen Mr. Al Cunningham Dear Mr. Cunningham: This is in reply to your letter of September l4, l988, attaching two lamps, and asking for an interpretation of Motor Vehicle Safety Standard No. l08 with respect to each. Specifically, you wish clarifications of SAE J588e, "the definition...2.2 'Multiple Compartment Lamp' and the term used in 3.1 'Single Compartment Lamp'". SAE Standard J588e Turn Signal Lamps, incorporated by reference in Standard No. l08, defines a multiple compartment lamp as "a device which gives its indication by two or more separately lighted areas which are joined by one or more common parts such as a housing or lens." The term "single compartment lamp" is not used in section 3.1, though the term "single compartment photometric requirements" is used in referencing the values for one "lighted section" given in Table 1 of J588e. For purposes of this discussion we shall define a "single compartment lamp" as one that gives its indication by one lighted area. You have described your first lamp as "a housing with back and four sides containing a two filament bulb with a single lens covering face of housing." The lamp photometrically complies to the basic requirements of a Class A tail, stop and turn signal lamp. You have asked if this lamp is a single compartment lamp. The answer is yes; your model 3504 Exp. contains a single light source and has a single lighted area. Your second lamp is described as "a housing with a back, two sides and one end, containing one #57 bulb and one #ll57 (2 filament) bulb. This housing is closed with two red lenses, one on the end and one on the face with an additional clear lens on bottom side. This lamp also complies to all standards of a class A tail, stop and turn lamp plus side marker clearance, license plate illuminator and class a reflex reflector side and rear". You ask if this also is a single compartment lamp. The answer is yes. The term "separately lighted area" in the definition of a multiple compartment lamp is understood to mean an area that is illuminated by a separate light source. In your model 3504 the turn signal light is provided by the #ll57 bulb alone, and not in tandem with the #57 bulb. I hope that this provides the clarification you seek. We are returning your lamps under separate cover. Sincerely,
Erika Z. Jones Chief Counsel /ref:108 d:ll/3/88 |
1970 |
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.