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 |
|---|---|
ID: 0324Open Mr. Rishi Gupta Dear Mr. Gupta: This is in reply to your FAX of August 29, 1994, to Richard Van Iderstine of this agency. For future reference, requests for interpretations of U.S. Federal motor vehicle safety regulations should be addressed to the Office of Chief Counsel. You have asked whether the size and types of aiming pads you propose to place on headlamps manufactured by Autolite conform to DOT specifications. You describe these headlamps as "a 7" round and a 200 x 142 mm rectangular replaceable halogen sealed beams [which] use a replaceable halogen bulb (HB2)." You enclosed diagrams showing "aiming pad's position as per SAE J1383 - 1992" (Figures 1 and 3), and in the manner you wish to place them on the Autolite lamps (Figures 2 and 4). We understand that these replaceable bulb headlamps are intended to be sold as replacements for sealed beam headlamps of the same dimensions. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, is the DOT specification that applies to Autolite's headlamps. The aimability performance requirements for non-sealed beam headlamps are found in S7.8. of Standard No. 108. S7.8 allows any aiming pad pattern that will fit on the headlamp and that will allow any one of the available aiming adapters described in SAE J602 to be used on the headlamp. Specifically, S7.8.1 in pertinent part allows non- sealed beam headlamps to be equipped with aiming pads to be used with the photometric procedures of SAE J1383 APR85 (not "1992" as you wrote) when being tested for photometric compliance, and to serve for the aiming reference when the lamp is installed on a motor vehicle. S7.8.5 allows an installed headlamp system to be aimable with an externally applied aiming device. Under S7.8.5.1, this aiming device shall be the equipment specified in SAE Standard J602 OCT80 Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Units. You write that the aiming pad sizes and types you wish to use are identical to those on headlamps sold by Hella, and that ETL Testing Laboratories has told you that the aiming pad positions and types meet DOT specifications. This indicates that Autolite's headlamps would be mechanically aimable with SAE J602 equipment, and therefore permissible as meeting Standard No. 108. We recommend that Autolite verify mechanical aimability with SAE J602 equipment before certifying compliance with Standard No. 108. Our engineering staff has reviewed your letter and asks that we point out the following errors in Autolite's Figures Nos. 2 and 4. Under both Figures, there is a reference to "HB-2 (H4 P43t)." The HB2 light source is not the same as the H4 P43t light source. The HB2 is a light source permitted by Standard No. 108 while the H4 P43t is not permitted by the Standard for motor vehicles. Under the drawing, the dimension "68.5" should be "68.58 +/- 0.51" (see Figure 4-4 of Standard No. 108). The dimensions of "32" and "52.0" must be the sum of two dimension "A"s from Figure 4-4, thus the sum is 42.16 +/- 0.25 + 42.16 +/- 0.25 = 84.32 +/- 0.50, not 84 as nominally calculated. Finally, with respect to Figure 4 only, because this lamp is intended to replace a 200 x 142 mm sealed beam lamp, the position of the aiming pads are not, but should be identical to the 200 x 142 mm sealed beam to facilitate mechanical aim when only one headlamp is replaced. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:10/26/94
|
1994 |
ID: nht94-4.63OpenTYPE: INTERPRETATION-NHTSA DATE: October 26, 1994 FROM: Recht, Philip R. -- Chief Counsel, NHTSA TO: Gupta, Rishi -- Autolite (India) Limited TITLE: NONE ATTACHMT: Attached To 8/29/94 Letter From Rishi Gupta to Richard Van Iderstine (OCC 10324) TEXT: This is in reply to your FAX of August 29, 1994, to Richard Van Iderstine of this agency. For future reference, requests for interpretations of U.S. Federal motor vehicle safety regulations should be addressed to the Office of Chief Counsel. You have asked whether the size and types of aiming pads you propose to place on headlamps manufactured by Autolite conform to DOT specifications. You describe these headlamps as "a 7" round and a 200 x 142 mm rectangular replaceable halogen sealed beam s [which] use a replaceable halogen bulb (HB2)." You enclosed diagrams showing "aiming pad's position as per SAE J1383 - 1992" (Figures 1 and 3), and in the manner you wish to place them on the Autolite lamps (Figures 2 and 4). We understand that these replaceable bulb headlamps are intended to be sold as replacements for sealed beam headlamps of the same dimensions. Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, is the DOT specification that applies to Autolite's headlamps. The aimability performance requirements for non-sealed beam headlamps are found in S7.8. of Standard No. 108. S7.8 allows any aiming pad pattern that will fit on the headlamp and that will allow any one of the available aiming adapters described in SAE J602 to be used on the headlamp. Specifically, S7.8.1 in pertinent part allows non-sealed beam headlamps to be equipped with aiming pads to be used with the photometric procedures of SAE J1383 APR85 (not "1992" as you wrote) when being tested for photometric compliance, and to serve for the aiming reference when the lamp is installed on a motor vehicle. S7.8.5 allows an installed headlamp system to be aimable with an externally applied aiming device. Under S7.8.5.1, this aiming device shall be the equipment specified in SAE Standard J602 OCT80 Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Units. You write that the aiming pad sizes and types you wish to use are identical to those on headlamps sold by Hella, and that ETL Testing Laboratories has told you that the aiming pad positions and types meet DOT specifications. This indicates that Autolite 's headlamps would be mechanically aimable with SAE J602 equipment, and therefore permissible as meeting Standard No. 108. We recommend that Autolite verify mechanical aimability with SAE J602 equipment before certifying compliance with Standard No. 108 . Our engineering staff has reviewed your letter and asks that we point out the following errors in Autolite's Figures Nos. 2 and 4. Under both Figures, there is a reference to "HB-2 (H4 P43t)." The HB2 light source is not the same as the H4 P43t light so urce. The HB2 is a light source permitted by Standard No. 108 while the H4 P43t is not permitted by the Standard for motor vehicles. Under the drawing, the dimension "68.5" should be "68.58 +/- 0.51" (see Figure 4-4 of Standard No. 108). The dimensions of "32" and "52.0" must be the sum of two dimension "A"s from Figure 4-4, thus the sum is 42.16 +/- 0.25 + 42.16 +/- 0.25 = 84.32 +/- 0.50, not 84 as nominally calculated. Finally, with respect to Figure 4 only, because this lamp is intended to replace a 200 x 142 mm sealed beam lamp, the position of the aiming pads are not, but should be identical to the 200 x 142 mm sealed beam to facilitate mechanical aim when only one headlamp is replaced. |
|
ID: 07-002490drnOpenMs. Julie Laplante Les Entreprises Michel Corbeil, Inc. 830, 12 ime Avenue Saint-Lin-Laurentides (Qubec) J5M 2V9 CANADA Dear Ms. Laplante: This responds to your letter asking about Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window retention and release. You ask for guidance whether Corbeil should follow the school bus floor plan of a potential customer, and place a wheelchair securement position in front of an emergency exit window. We believe that school buses should not have a wheelchair anchorage position placed in a position that blocks an emergency exit. However, the exit you ask about is not a mandatory school bus emergency exit. Background In your letter, you state that a client wishes to purchase a new school bus with one emergency exit window on each side. A floor plan provided with your letter shows that the school bus is designed to have four wheelchair anchorage positions and two seat benches, both of which are 36 inches in length. You state that on the right hand side of the bus, there are only wheelchair positions (two wheelchair anchorage positions), so a wheelchair or wheelchair and passenger tiedowns must be placed in front of an emergency exit. You further state that neither FMVSS No. 217 nor State law requires the side emergency exit windows. You wish to know whether to agree with your clients request to place a wheelchair anchorage position in front of an emergency exit window, with the DO NOT BLOCK label. The Emergency Exit Windows Are Beyond What Is Required In response, I note that the seating capacity of the school bus at issue is fewer than 45 passengers because there are four wheelchair positions[1] plus two benches. Thus, no additional emergency exit beyond the rear emergency exit door is required. (See S5.2.3.1(a) and (b).) Any emergency exit windows provided on the school bus at issue would therefore be considered voluntarily provided.
Our longstanding interpretation of FMVSS No. 217 with regard to labeling requirements for voluntarily provided emergency exits in school buses can be found in an interpretation letter of July 6, 1979 to Mr. Robert B. Kurre (copy enclosed). In that letter, NHTSA stated that exits installed in school buses beyond those required by S5.2.3.1 need not comply with the exit requirements applicable to school bus exits. Instead, NHTSA interpreted the standard as requiring all additional exits to meet the requirement in the standard applicable to non-school buses. Thus, for the school bus you ask about, any side emergency exit window provided need not be marked DO NOT BLOCK. However, if side emergency exit windows are provided, they must be marked in accordance with S5.5.1 of FMVSS No. 217, which requires the designation Emergency Exit followed by concise operating instructions describing each motion necessary to unlatch and open the exit, located within 16 centimeters of the release mechanism. In addition, S5.5.1 states that when a release mechanism is not located within an occupant space of an adjacent seat, a label meeting the requirements of S5.5.2 that indicates the location of the nearest release mechanism shall be placed within the occupant space. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Please note that our address has changed. Our new address is: Office of the Chief Counsel, National Highway Traffic Safety Administration, 1200 New Jersey Avenue, SE, Mail Code: W41-227, Washington, DC 20590. Sincerely yours, Anthony M. Cooke Chief Counsel Enclosure ref:217 d.7/24/07 [1] Pursuant to the definition of designated seating position at 49 CFR Section 571.3, each wheelchair position in the school bus is regarded as four designated seating positions. Therefore, the four wheelchair positions in the school bus can be regarded as totalling 16 designated seating positions. Since the two benches at issue are both 36 inches long, each would represent 2 designated seating positions, or a total of 20 passengers. |
2007 |
ID: 10464traOpen Ms. Lois Castillo Dear Ms. Castillo: This responds to your letter to Mr. John Womack of my staff, asking about safety regulations for the "Travel Tray," a product you wish to manufacture. The brochure you enclosed with your letter states that the Travel Tray is a plastic tray that is designed to lay across the top of a child's car seat. The tray attaches to the car seat by the use of straps with "velcro" ends. Children would use the tray to "play on with their toys or to eat on." The National Highway Traffic Safety Administration (NHTSA) has the authority to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA has used its authority to issue Federal Motor Vehicle Safety Standard (FMVSS) No. 213, "Child Restraint Systems," to reduce the number of children killed or injured in motor vehicles. (This standard is found in volume 49 of the Code of Federal Regulations, section 571.213.) Each new child restraint system, which includes "car seats," must be certified as complying with the requirements of Standard No. 213. This means that, if the Travel Tray were marketed as part of a car seat, the car seat would be required to comply with all of the requirements of the standard, with the tray attached. Section S5.2.2.2 of Standard No. 213 prohibits any fixed or moveable surface in front of the child except for surfaces that adequately restrain a test dummy in a 20 mile per hour test. This requirement is to prevent items that could injure a child in a crash from being installed where they could be impacted by a child. Your tray is incapable of restraining a test dummy in a crash. Since the tray is unable to restrain the dummy, a car seat with the tray would not comply with Standard No. 213. In other words, a manufacturer of a car seat could not sell such a tray as a part of its child seating system. If your tray is manufactured and marketed separately to consumers who own child seats, the tray would not be required to comply with the requirements of Standard No. 213. The standard applies to new child restraint systems, or car seats, that are designed to restrain, seat or position children. Your tray sold by itself would not be designed to restrain, seat or position children and thus would not be subject to this standard. While no FMVSS applies to the Travel Tray, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. ''30118-30121 concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event 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. In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 49 U.S.C. section 30122, which states: "A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative ... any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard ...." It appears unlikely from the nature of your product that it would be placed in vehicles by commercial businesses instead of car seat owners. However, if your product were to be installed by persons in the categories listed in section 30122, that would constitute a potential violation of the "make inoperative" provision of section 30122. The prohibition of '30122 does not apply to individual owners who install equipment in their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages consumers not to degrade the safety of their vehicles or equipment. I hope this is helpful. If you have any other questions, please contact Ms. Deirdre Fujita of my staff at this address or by phone at (202) 366-2992. Sincerely,
Philip R. Recht Chief Counsel Enclosure ref:213 d:1/9/95
|
1995 |
ID: aiam3526OpenMr. William E. Lawler, Specifications Manager, Indiana Mills & Manufacturing, Inc., 120 West Main Street, Carmel, IN 46032; Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing Inc. 120 West Main Street Carmel IN 46032; Dear Mr. Lawler: This responds to your recent letter asking whether the requirements o paragraph S7.1.1.3 of Safety Standard No. 208, *Occupant Crash Protection*, apply to motor homes and school buses with a GVWR of 10,000 pounds or less. It is your assumption that only those vehicle applications which must have seat belt assemblies meeting S7.1 generally are required to have emergency locking retractors on lap belts.; Your interpretation is incorrect. It is true that belt assemblie installed pursuant to S4.2.1.2 are not required to comply with paragraph S7.1.1 of Standard No. 208, since that paragraph states that it is applicable to lap belts installed pursuant to S4.1.1 and S4.1.2. However, paragraph S7.1.1.3 is not so limited. It states that:; >>>A lap belt installed at any front outboard designated seatin position in a vehicle manufactured on or after September 1, 1982, shall meet the requirements of this section by means of an emergency-locking retractor that conforms to Standard No. 209.<<<; This means that S7.1.1.3 applies to all lap belts installed in an vehicle in compliance with the standard, including belts installed under S4.2.1.2. Therefore, both motor homes and school buses with a GVWR of 10,000 pounds or less would have to comply with the requirement.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: nht78-3.32OpenDATE: 05/01/78 EST FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA TO: Peabody Galion TITLE: FMVSR INTERPRETATION TEXT: This responds to your recent letter asking whether a stand-up, right-hand drive position in a truck with a mounted side loader would be considered a designated seating position under Federal safety regulations. The answer to your question is no. Under 49 CFR Part 571.3, "designated seating position" is defined as: "any plan view location intended by the manufacturer to provide seating accommodation while the vehicle is in motion, for a person at least as large as a fifth percentile adult female, except auxiliary seating accommodations such as temporary or folding jump seats." Since the driving position in question is a stand-up position in which no seat is provided, it obviously cannot be a location intended by the manufacturer to provide "seating accommodation." Feel free to contact this office if you have any further questions. Sincerely, ATTACH. March 14, 1978 Office of Chief Counsel -- National Highway Traffic Safety Administration Gentlemen: Peabody Solid Wastes Management is a division of Peabody International Corporation. Our division manufactures a complete line of Solid Waste Handling Equipment including truck mounted Front Loaders, Rear Loaders, Side Loaders, Stationary Compactors, Transfer Trailers and Transfer Stations. We are now designing a new truck mounted Side Loader. The concept of this Side Loader has been used on the West coast for a number of years. It is a very efficient, low labor cost system for collecting household refuse, since only one man is required. To make this system workable requires considerable modifications to a standard tilt cab chassis. One of the principle modifications is a stand up right hand drive position for the operator. This enables him to quickly exit and enter the cab as he picks up curb side refuse. The operator uses this drive position only when on his route, and usually at speeds of less than 10 miles per hour. When traveling over highways, he uses the normal left hand driving position. Enclosed is a sketch SK-7024-C which illustrates a typical cab conversion. Peabody wants to be certain that we can certify this converted cab to all N.H.T.S.A. regulations that apply. This conversion was discussed with the following on March 7, 1978. Martz Elliott - Office of Crash Avoidance Robert N. Williams - Office of Crash Worthiness Guy Hunter - Office of Crash Worthiness Roger Tilton - Office of Chief Counsel We are requesting a ruling from your office that the right hand drive position would not be construed as a designated seat. We would appreciate anything you could do to expedite your ruling since much of our program depends on this. Very truly yours, Glenn S. Park Vice President -- Director of Engineering, PEABODY GALION enc. 2 |
|
ID: 18897-2.wkmOpenPhillip A. Proger, Esq. Dear Mr. Proger: This refers to your meeting with Messrs. Daniel, Myers, and Woods of this agency on October 1, 1998 and to your letter of October 8 to Mr. Myers of my staff.(1) You asked two questions, as discussed below. Your first question concerned paragraph S5.3.3(b), Federal Motor Vehicle Safety Standard (Standard) No. 105, Hydraulic and electric brake systems, as amended (hereinafter referred to as "New 105").(2) You correctly stated that S5.3.3(b) of New 105 requires a message of malfunction to be stored in the antilock brake system (ABS) if it exists when the ignition is turned to the "off" position (ignition cycle No. 1) so that it again illuminates the malfunction indicator lamp (MIL) when the ignition is next turned to the "on" or "run" position (ignition cycle No. 2). You first asked how long the MIL must remain illuminated after being activated in ignition cycle No. 2. You stated that clarification of this point is essential since certain malfunctions, which you did not specify, can only be detected and confirmed when dynamically tested for at speed, but that S5.3.3(b) appears to require that the MIL remain illuminated indefinitely when a message of malfunction exists. You are correct that S5.3.3(b) so provides. Paragraph S5.3.3(a) of New 105 provides:
S5.3.3(b) then provides:
Thus, read together, S5.3.3(a) and (b) provide that the MIL must remain activated as long as the malfunction exists, whether in ignition cycle No. 1 or No. 2. Further, the malfunction message must be stored in the system so that the MIL automatically activates when the ignition is again turned to the "on" position. The MIL must also activate as a check of lamp function any time the ignition is turned to the "on" position, but must deactivate at the end of that check of lamp function, unless a malfunction message was previously stored in the system. Accordingly, whenever the ignition switch is on, regardless of the number of ignition cycles, once the MIL activates in response to a malfunction message, the lamp must remain illuminated until the malfunction no longer exists, however long that may be. Your second question also concerned illumination of the MIL. You stated that Lucas Varity Light Vehicle Brake Systems (LVBS) believes that once the MIL has been illuminated as the result of a message of malfunction, it would be desirable for the MIL to be deactivated when any vehicle motion is detected. You stated that this approach would provide advisories to drivers, relief drivers, and inspectors while avoiding false positive malfunction indications. You stated that certain malfunctions, again unspecified, cannot be verified until dynamic testing is completed at speeds ranging between 8 and 15 miles per hour (mph). Thus, LVBS prefers to deactivate the MIL once any vehicle motion is detected and illuminate it again only when the existence of a malfunction is confirmed through dynamic testing at speed. Then, as soon as a malfunction is so verified, the MIL will again illuminate. This question is answered by the answer to question 1 above, namely that the MIL, after momentary illumination for the bulb check function, must remain illuminated if either a malfunction is detected or a message of a malfunction was stored at the end of the previous ignition cycle. The MIL must remain illuminated until it is determined that a system malfunction is no longer present. Note that a message of malfunction stored at the end of an ignition cycle may be deleted from memory if repairs are performed to restore proper system functioning prior to initiation of the next ignition cycle. We note that the agency addressed the issue of the MIL being either illuminated or extinguished during low-speed driveaway after key-on in the final rule of March 10,1995, 60 FR at page 13246, wherein NHTSA stated:
In its petition for reconsideration of the final rule on this issue, Navistar suggested allowing the vehicle to be in motion at low speed during an ABS system check so that the sensor check could be included before the lamp extinguished. In denying that suggestion, the agency stated at 60 FR 63972:
In a further response to petitions for reconsideration dated March 16, 1998 (63 FR 12660), the agency again addressed the issue of the MIL remaining activated during a low-speed drive away. Kelsey-Hayes requested that the agency reconsider the activation protocol requirements for the MIL in the final rule of March 10, 1995. Kelsey-Hayes stated that allowing the MIL to remain illuminated during a low-speed drive away would serve to verify that the vehicle's wheel speed sensors were properly functioning. NHTSA denied that request, citing three reasons:
It is clear that NHTSA has repeatedly considered the issue of the continuous illumination of the MIL and has, on each occasion, reiterated its decision to require that the lamp remain illuminated when a malfunction message exists whenever the ignition switch is in the on position, in all ignition cycles, and be extinguished if no malfunction exists. Accordingly, the lamp may not remain illuminated (absent a detected malfunction on a stored malfunction message) pending a sensor check at speed, nor may it be extinguished pending "confirmation" of a malfunction at speed. I hope this information is helpful to you. Should you have any questions or need additional information, feel free to contact Mr. Myers or Mr. Woods at this address or by telephone at (202) 366-2992 and (202) 366-6206 respectively. Sincerely, 1. We note that you sent us three letters dated October 8, 1998, all relating to the October 1, 1998 meeting and all relating to the malfunction indicator lamp protocol of Standard No. 105. We are responding to the three letters separately. 2. The applicable amendments to Standard No. 105 were scheduled to become effective on March 1, 1999. That date was extended, however, until September 1, 1999 by Interim Final Rule; Request for Comments dated February 26, 1999 (64 FR 9446). |
1999 |
ID: nht78-3.16OpenDATE: 11/09/78 FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA TO: Hon. Bob Wilson - H.O.R. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of October 17, 1978, concerning a telephone call from your constituent, Mr. Stefan Dagrowski, urging standardization of the type of release on seat belts. Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, issued March 10, 1971 (36FR4600), required that effective January 1, 1972, passenger car seat belt assemblies would be released at a single point by push button action. To that extent, the type of release on seat belts is standardized since our standards are primarily performance oriented, and the manufacturers are free to design however they wish to meet those performance requirements. I hope this information is sufficient to satisfy Mr. Dagrowski's interest in standardized seat belt releases. SINCERELY, Congress of the United States House of Representatives October 17, 1978 Dear Ms. Claybrook: I recently received a telephone call from a constituent, Mr. Stefan Dagrowski, urging standardization of the type of release on seat belts. Your advice and counsel as to anything currently underway in this regard, which I can pass along to Mr. Dagrowski, will be greatly appreciated. Thank you for your attention to this matter and kind regards. Bob Wilson Member of Congress Honorable Joan Claybrook National Highway Traffic Safety Administration |
|
ID: nht91-6.39OpenDATE: October 24, 1991 FROM: Sue Ellen Russell -- Brand & Lowell TO: Paul Jackson Rice -- Chief Counsel, NHTSA COPYEE: Robert Hellmuth; Robert Krauss; Harry Thompson; Z Taylor Vinson TITLE: None ATTACHMT: Attached to letter dated 1/14/92 from Paul Jackson Rice to Sue Ellen Russell (A39; Std. 207; Std. 210) TEXT: This firm represents the Glaval Corporation, a company engaged in the business of van conversions. Glaval recently notified NHTSA of its intention to conduct a notification and remedy campaign to respond to an apparent noncompliance with the safety belt anchorage strength requirements as they apply to the rear bench set in Glaval vans. These seats contain three designated seating positions, and each seat belt anchorage is mounted on the seat, not the floor. In the course of evaluating potential remedies to ensure their compliance with the requirements of the standard, we became aware of a recent interpretation of FMVSS 210 (S4.2) issued to R.W. Schreyer of the Transportation Manufacturing Corporation (April 9, 1990). A copy is enclosed for your convenience. In this interpretation, the agency stated that ONLY FLOOR-MOUNTED anchorages common to a single seat and governing "adjacent seating positions" would be tested simultaneously for compliance with FMVSS 210. The letter reiterates that "Even those anchorages common to one occupant seat would be tested simultaneously only if the anchorages were floor-mounted." This interpretation raises several questions, because the Glaval bench seat in NHTSA's test was subjected to simultaneous loading of the anchorages for all three seating positions, although none of these anchorages is floor-mounted. Glaval's testing, conducted in accordance with the published test procedures in order to replicate the NHTSA test, also loaded the three seating positions simultaneously. Glaval's questions are: 1. Consistent with the Schreyer interpretation, should the seat-mounted anchorages of the Glaval bench seat have been loaded sequentially in NHTSA's test? If so, how does NHTSA's test on the Glaval bench seat, where the loads were applied simultaneously, affect NHTSA's tentative conclusion of noncompliance? 2. Since Standard 207 requires simultaneous loading of the forces required by Standard 207 along with those required by Standard 210, does the Schreyer interpretation mean that, for a bench seat with seat-mounted anchorages, the proper loading for a test pursuant to FMVSS 207 should be 20 times the seat weight, plus the proper load for one designated seating position on the bench seat? We look forward to Your early response to these questions, as they will affect Glaval's on going work on this issue. Attachment Letter dated 3/5/90 from R.W. Schreyer, of Transportation Manufacturing Corporation to Harry Thompson, of NHTSA. (Text omitted) |
|
ID: 86-5.32OpenTYPE: INTERPRETATION-NHTSA DATE: 10/16/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Terry Woodman -- Orthotist, Winkley Orthopedic Laboratory TITLE: FMVSS INTERPRETATION ATTACHMT: 9/6/88 letter from Erika Z. Jones to Robert Daugherty (Std. 213); 7/31/87 letter from Erika Z. Jones to Richard J. Maher; 2/5/88 letter from Robert Daugherty to Erika Z. Jones TEXT:
Mr. Terry Woodman Orthotist Winkley Orthopedic Laboratory 740 Douglas Drive North Golden Valley, MN 55422
Dear Mr. Woodman:
This responds to your recent letter to Mr. Steve Oesch of my staff, asking for an interpretation of Standard No. 213, Child Restraint System (49 CFR S571.213). Specifically, you asked whether car seats designed for use by severely physically handicapped children are required to comply with the requirements of Standard No. 213. The answer to your question is yes.
Section S4 of Standard No. 213 defines a child restraint system as "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh ?? pounds or less." No exception is made for restraints designed for use physically handicapped children who weigh 50 pound; or less. Further, section S6.1.2.1.1 of Standard No. 213 includes the following language. "A child harness, booster seat with a top anchorage strap, or a restraint designed for use by physically handicapped children shall be installed the center seating position of the standard seat assembly in accordance with the manufacturer's instructions provided with the system pursuant S5.6." This language makes clear that restraints designed for use by physically handicapped children are subject to the requirements of Standard No. 213.
We discussed this issue in some detail in a February 13, 1986, final to amending Standard No. 213 (51 FR 5335; copy enclosed). NHTSA had published a proposal that would have required all all child restraints except child harnesses to pass the 30 mile per hour (mph) frontal crash test of Standard No. 213 without attaching any tether strap. However, a number of commenters urged the agency to also exempt child restraints design for handicapped children from the proposed requirement to pass the 30 test without attaching any tether strap. These comments are discussed in 51 FR 5338. The National Highway Traffic Safety Administration (NHTSA) amended the final rule to provide that child restraints for use by physically handicapped children could attach tether straps during the mph test. As noted in the preamble to that final rule, "there is no alternative at present to the use of tether straps to provide the necessary upper torso support for physically handicapped children. Hence, any requirement to eliminate the use of tether straps on restraints for physically handicapped children would lessen the protection available for those children."
NHTSA knows of at least one manufacturer of child restraints for use by physically handicapped children that has incorporated a tether strap and certified that these restraints comply with all requirements of Standard No. 213. Since it is possible to offer these children the safe level of crash protection afforded to all other children, NHTSA believes there is no reason to permit physically handicapped children to be offered a lesser degree of safety protection in the event of a clash.
If you have any further questions or need more information on this topic, please contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosure
September 4, 1986
Office, Chief Council National Highway Traffic Safety Administration 400 7th Street S.W. Washington, D.C. 20590
Att: Steve Oesch NOA--32
Dear Mr. Oesch:
I have been told that I should contact your office regarding a ruling about wheel chair seating systems being used in cars as carseats for infants.
I have enclosed a picture of the system seat belted in the car and also a picture of it in a stroller. The system is designed to be used in a wheel chair or stroller on an independent base. As you can tell, this system is used with very handicapped children who need positioning support whenever sitting.
My question is this: Does adaptive equipment such as this system need to meet federal regulations regarding child seating systems for automobiles?
Could you please inform me of this. It would be greatly appreciated. Sincerely,
Terry Woodman Orthotist Winkley Orthopedic Laboratories |
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.