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: 77-2.32OpenTYPE: INTERPRETATION-NHTSA DATE: 05/11/77 FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA TO: Wayne Corporation TITLE: FMVSS INTERPRETATION TEXT: This responds to your April 1, 1977, letter asking whether the head protection zone requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection, extend to contactable surfaces 30 inches forward of the seating reference point of the front passenger seat behind the driver. The head protection zone requirements are outlined in S5.3.1.1 of the standard. This section requires that the zone extend 30 inches forward of the seating reference point. The fact that the requirement may extend the head protection zone into the driver occupant space and thus involve contactable surfaces does not diminish the applicability of the requirements to contactable surfaces within that space. Contactable surfaces within that 30-inch zone, as shown on your sketch, must meet the requriements of the standard. Sincerely, ATTACH. Wayne Corporation April 1, 1977 Frank R. Berndt -- Office of Chief Counsel, NHTSA Dear Mr. Berndt: This inquiry is in reference to FMVSS 222, School Bus Passenger Seating and Crash Protection. Apart from the 3.00 dimension, do the requirements of sections S5.3.1.2 and S5.3.1.3 apply to surfaces located in "Zone A" shown on the enclosed sketch? Your prompt attention to this matter and an early reply will be appreciated. Sincerely, Robert B. Kurre -- Director of Engineering Enclosure [Graphics omitted] |
|
ID: 11609.dfOpen James L. Miraldi, Esq. Dear Mr. Miraldi: This responds to your letter concerning paragraph S4.4 of Standard No. 207, Seating Systems. I regret the delay in replying. S4.4 provides that: Seats not designated for occupancy while the vehicle is in motion shall be conspicuously labeled to that effect. You ask whether that section requires the placement of a label on a rear bench seat in a conversion van which folds out into a bed. NHTSA has interpreted the requirement to apply only to positions that are not designated seating positions under 49 CFR 571.3. Presuming that the bench seat is a "designated seating position" under 49 CFR 571.3, a label is not required for the seat. I have enclosed a January 4, 1996, letter to Erika Z. Jones on this subject. We note that the bench seat in its unconverted mode must comply with all requirements for a "designated seating position," and would have to be equipped with seat belts. The label is not required for the position in the "bed" mode because S4.4 applies to "seats." An "occupant seat" is defined in S3 of Standard 207 as "a seat that provides at least one designated seating position." (Emphasis added.) Given the clear reference to "seat" in S4.4, we cannot interpret the labeling requirement to apply to a bed. In answer to your general inquiry about our interpretations, this office regularly responds to requests for interpretations of the safety standards. All of our interpretations are on file in the agency's public docket and are available for public inspection. The telephone number for our Docket Room is (202) 366-4949. In addition, interpretations that have been issued from 1988 to the present are now available on the Internet. I have enclosed information on how you can search these letters. Please contact Deirdre Fujita of my staff at (202) 366-2992 if you have any questions. Sincerely, Samuel J. Dubbin Chief Counsel Enclosures ref:207 d:8/12/96 |
1996 |
ID: 07-000136 two harnessesOpenMs. Desire Kootungal 12405 Alameda Trace Circle 1012 Austin, TX 78727 Dear Ms. Kootungal: This responds to your inquiry to the National Highway Traffic Safety Administration (NHTSA) asking whether it is permissible to provide two harnesses with the child restraint system you wish to produce. As explained below, Federal Motor Vehicle Safety Standard (FMVSS) No. 213, Child restraint systems, does not prohibit you from providing two harnesses. By way of background, NHTSA administers Federal safety requirements for the manufacture and sale of new motor vehicles and items of new motor vehicle equipment. We are authorized to issue Federal motor vehicle safety standards to reduce highway crashes and deaths and injuries resulting from crashes (49 U.S.C. 30101, et seq.). Under that authority, we issued FMVSS No. 213 (49 CFR 571.213), which sets forth requirements which must be met by any device designed for use in a motor vehicle to restrain, seat or position children who weigh 65 pounds or less. (We currently are considering a proposal to increase this weight limit to 80 pounds. Notice of proposed rulemaking, August 31, 2005, 70 FR 51720.) Child restraint manufacturers must certify that each of their child restraints satisfy all requirements of FMVSS No. 213. FMVSS No. 213 is frequently amended and manufacturers are responsible for keeping current on its requirements. For purposes of enforcement, this agency conducts validation checks of child restraints after they have been certified as complying with FMVSS No. 213, by purchasing and testing the child restraints according to the procedures specified in the standard. If the child restraints fail the test and are determined not to comply with FMVSS No. 213, the manufacturer of the child restraint is subject to the recall responsibilities of our statute (49 U.S.C. 30120). Manufacturers must also ensure that their products are free of safety-related defects. Discussion You ask about S5.4.3.1 of FMVSS No. 213, which states: Each belt that is part of a child restraint system and that is designed to restrain a child using the system shall be adjustable to snugly fit any child whose height and weight are within the ranges recommended in accordance with S5.5.2(f) [which requires the manufacturers recommendations for the maximum mass and height of children who can safety occupy the system] and who is positioned in the system in accordance with the instructions required by S5.6. You explain that you are working with a company that is designing a child restraint system (CRS) for physically handicapped children, for use only in the forward-facing position. The CRS would provide five-point restraint for children ranging in weight from 22 to 130 pounds (lb). You state that, to accommodate the broad range of occupants, the CRS must be sold with two harnesses, which together would encompass the weight and height ranges that the restraint is designed for. You ask: Is it permissible to have two harnesses, with the second (larger) harness designed and specified to be used only by children weighing more than 66 lb (or 81 lb when the new standard becomes effective)? FMVSS No. 213 does not prohibit manufacturers from providing more than one harness with child restraint systems. We interpret the requirement in S5.4.3.1 that each beltshall be adjustable to snugly fit any child of a height and weight recommended for the restraint as not to require that each belt (harness) alone must be adjustable to fit all the children recommended for the restraint. Rather, that section requires each child restraint to be sold with sufficient belts (harnesses) that provide the adjustability needed to snugly fit the child occupants recommended for the restraint. Of course, each belt (harness) sold with the restraint would each have to meet the requirements of FMVSS No. 213 for belts, belt buckles and belt webbing (S5.4), flammability resistance (S5.7), and all other applicable requirements.[1] There is an issue in your question as to whether child restraints recommended for children weighing more than the upper weight limit of the standard (65 lb, or in the future 80 lb assuming the standard were amended as currently proposed) may have features not permitted by the standard. For your information, our general view on this issue is that manufacturers are not permitted to avoid complying with FMVSS No. 213 simply by labeling their child restraint as not recommended for children within the weight range of Standard No. 213, if in fact the restraint is marketed toward or otherwise will likely be used by children weighing 65 lb (or in the future, 80 lb) or less. NHTSA would check whether the manufacturers assertion is bona fide. Moreover, restraint systems for children weighing 65 lb (or in the future, 80 lb) or more are motor vehicle equipment under our Safety Act, and as such must be free of safety-related defects. Finally, we note a procedural regulation that would apply to you if you begin manufacturing child restraints. 49 CFR Part 566, Manufacturer Identification, requires a manufacturer of child restraints to submit its name, address, and a brief description of the equipment it manufactures to this agency within 30 days of the date the child restraints are first manufactured. I have enclosed an information sheet that briefly describes the responsibilities of manufacturers of motor vehicles and motor vehicle equipment. If you have any further questions, please do not hesitate to contact Ms. Deirdre Fujita 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, Anthony M. Cooke Chief Counsel Enclosure Ref:213 d.6/18/07 [1] Note that NHTSA administers an Ease-of-Use (EOU) consumer information program that rates child restraints on their ease of use (49 CFR 575.201). This program started in 2002, when Congress directed us to establish a child restraint safety rating consumer information program to provide practicable, readily understandable, and timely information to consumers for use in making informed decisions in the purchase of child restraints. The EOU program encourages CRS manufacturers to produce child restraints with features that make it easier for consumers to use and install correctly. See final rule, November 5, 2002, 67 FR 67491, Docket 10052. The EOU program currently does not evaluate restraints targeted to handicapped children. We do not know the details of your design but broadly speaking, a child restraint sold to the general public with a design that required the owner to replace the harness when the child outgrew it would likely receive reduced marks in the EOU program. |
2007 |
ID: nht88-1.31OpenTYPE: INTERPRETATION-NHTSA DATE: 02/11/88 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: MTD Products Inc. TITLE: FMVSS INTERPRETATION TEXT: Mr. J.V. McFadden President MTD Products Inc. P.O. Box 36900 Cleveland, Ohio 44136 Dear Mr. McFadden: This responds to your letter concerning the applicability of Federal on State requirements to a hydraulic logsplitter mounted on a frame carriage equipped with highway high speed wheels and a trailer towing hitch. While we can not answer your question co ncerning applicable State requirements, we provide the following information on the applicability of Federal motor vehicle safety standards. By way of background information, our agency is authorized, under the National Traffic and Motor Vehicle Safety Act of 1966 (15 D.S.C. 1381 et seq.), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse commercial products. Instead, the Vehicle Safety Act establishes a "self-certification" process under which each manufacturer is required to certify that its p roducts meet all applicable safety standards. The Vehicle Safety Act prohibits the manufacture or sale of a noncomplying product unless, despite the exercise of due care, the manufacturer doesn't have reason to know that the noncompliance exists. Any vehicle that falls within the statutory definition of the term "motor vehicle" must comply with all applicable safety standards. Section 102(3) of the Vehicle Safety Act (15 D.S.C. 1391(3) defines a "motor vehicle" as any vehicle driven or drawn by m echanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. We have interpreted this language as follows. The definition does not include equipment which uses the highways only to move between job sites and which typically spends extended periods of time at a single job site. In this case, the on-highway use of t he vehicle is merely incidental, and is not the primary purpose for which the vehicle was manufactured. On the other hand, when a vehicle frequently uses the highway going to and from job sites, and stays at the job site for only a limited time, it is the agency's position that the vehicle in question is a "motor vehicle" in the statutory sense, since the on-highway use is more than "incidental". Notwithstanding the foregoing, a vehicle is not classified as a motor vehicle if it is of such an unusual configuration that it is easily distinguished from normal traffic and it has a top speed of not more than 20 miles per hour. A determination of whether or not a vehicle falls within the definition of motor vehicle is based upon a consideration of all of the above factors. Given the information that you have provided us, it appears that the hydraulic log-splitter is a motor veh icle. From the picture in the brochure, it is clear that the vehicle has an unusual configuration. This alone, however, is not adequate to prevent a determination that the vehicle is a motor vehicle within the meaning of the statute. More important is th e fact that the vehicle may make frequent use of the highway, staying at one particular job site a limited amount of time. The provision of highway speed tires indicates the manufacturer's intention to produce a vehicle which is suitable for driving at h ighway speeds. Because the tow-behind logsplitter is equipped with a trailer tow hitch, we would consider the vehicle a trailer, defined in the agency's regulations as: a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle.(See 49 CFR 571.3.) The safety standards which apply to all trailers are Standard No. 108, Lamps, reflective devices, and associated equipment: Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars: and Standard No. 115, Vehicle Identificati on Number--Basic Requirements. The content requirements for the vehicle identification number are found at Part 565. In addition, if the trailer is equipped with brakes, it must meet Standard No. 106, Brake hoses, Standard No. 116, Motor vehicle brake fl uids, and applicable requirements of Standard No. 121, Air brake systems. All of these standards are found in 49 CFR Part 571. We regret the delay in responding to your request. If you have further questions on this matter, please contact us. Sincerely, Erika Z. Jones Chief Counsel
Highway Traffic Safety Administration Office of Chief Counsel 400 7th Street S.W. Washington, DC 20590 RE: Applicability of Highway Rules - Tow Behind Logsplitter Gentlemen: Your advice is requested relative to whether there are any federal or state requirements which would pertain to a hydraulic log-splitter mounted on a frame carriage equipped with highway high speed wheels and a trailer towing hitch. We enclose product literature produced by Duerr Incorporated who inform us that this particular application does not fall within any regulations which would require lights, license plates, etc. Very truly yours, J.V. McFadden President JVM/djm Enclosure: Product brochure |
|
ID: nht89-1.35OpenTYPE: INTERPRETATION-NHTSA DATE: 03/10/89 FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA TO: JOSEPH F. MIKOLL -- VICE PRESIDENT TRANSPORTATION EQUIPMENT CORP. TITLE: NONE ATTACHMT: LETTER DATED 12/15/88 FROM JOSEPH F. MIKOLL TO ERIKA Z. JONES -- NHTSA, OCC 2812; LETTER DATED 12/03/88 FROM ERIKA Z. JONES -- NHTSA TO JOSEPH F. MIKOLL; LETTER DATED 08/11/88 FROM JOSEPH F. MIKOLL TO ERIKA Z. JONES TEXT: Dear Mr. Mikoll: This responds to your letter asking for clarification of my November 3, 1988 letter to you. In a letter dated August 11, 1988, you requested my opinion concerning the acceptability of installing a new product you are developing (a "safety bar") in schoo l buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less instead of installing safety belts in those vehicles. The "safety bar" consists, in part, of two curved metal poles in planes that are parallel to the longitudinal centerline of the bus. The curved metal poles are attached to the outside of the seat in front of the seat whose occupants are to be protected by the "safety bar." These curved poles are joined by three cross or transverse members that are parallel to the seat and ar e covered with padding. The padded surface extends over the entire width of the seat whose occupants it is intended to protect. When an occupant wishes to be seated, he or she must lift the safety bar and then sit down and allow the safety bar to lower so that it rests on the occupant's thighs. Additionally, a special strap resembling a very long seat belt assembly must be fastened around the safety bar to hold it in position in the event of a crash. In my November 3, 1988 reply to your letter, I explained that the crash protection requirements for school buses with a GVWR of 10,000 pounds or less are set forth in S5(b) of Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR @ 571.222). That section requires that each designated seating position be equipped with either safety belts or a protection system that requires no action by vehicle occupants. Since the "safety bar" is not a protection system that requires no action by vehicle occupants, my November 3 letter explained that the "safety bar" could not be installed in place of safety belts in small school buses; i.e., school buses with a GVWR of 10,000 pounds or less. My November 3, 1988 letter also explained that safety bars could be installed in small school buses in addition to safety belts, if the safety bars do not destroy the ability of the required safety belts to
comply with the requirements of our safety standards. I also stated that a manufacturer that installed these safety bars in small school buses would have to certify that the bus in which the safety bars were installed complied with the school bus emerge ncy exit requirements of Standard No. 217, Bus Window Retention and Release (49 CFR @ 571.217) and with the impact zone requirements specified in S5.3 of Standard No. 222. You asked whether my November 3, 1988 letter addressed the situation for both large school buses (i.e., those with a GVWR of more than 10,000 pounds) and small school buses, or whether it addressed only small school buses. Your previous letter asked onl y about small school buses, so my November 3 letter addressed those vehicles only. Assuming this was the case, you asked for "an opinion that [the safety bar] does not conflict with any standard for large school bus installation." I am happy to have thi s chance to explain our regulations to you. Let me begin by noting that the National Traffic and Motor Vehicle Safety Act requires each manufacturer to certify that each of its motor vehicles or items of motor vehicle equipment complies with all applicable safety standards. Because of this statuto ry provision, NHTSA has no authority to approve, endorse, or offer assurances of compliance for your product. Instead, any manufacturer that installs your safety bar in its large school buses must itself certify that those large school buses comply with all applicable safety standards when the safety bars are installed. The occupant crash protection requirements for large school buses are set forth in Standard No. 222. No provision of Standard No. 222 expressly prohibits the installation of "safety bars" in large school buses. Hence, "safety bars" can be installed in a large school bus, provided that the manufacturer of the bus certifies that it complies with all applicable requirements set forth in the safety standards with the safety bars installed. These requirements include the emergency exit requirements specif ied in Standard No. 217, all of the requirements of Standard No. 222, and the flammability resistance requirements of Standard No. 302, Flammability of Interior Materials (49 CFR @ 571.302). Please let me know if you have any further questions or need additional information. Sincerely, |
|
ID: 1736yOpen Mr. Joseph F. Mikoll Dear Mr. Mikoll: This responds to your letter asking for clarification of my November 3, 1988 letter to you. In a letter dated August 11, 1988, you requested my opinion concerning the acceptability of installing a new product you are developing (a "safety bar") in school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less instead of installing safety belts in those vehicles. The "safety bar" consists, in part, of two curved metal poles in planes that are parallel to the longitudinal centerline of the bus. The curved metal poles are attached to the outside of the seat in front of the seat whose occupants are to be protected by the "safety bar." These curved poles are joined by three cross or transverse members that are parallel to the seat and are covered with padding. The padded surface extends over the entire width of the seat whose occupants it is intended to protect. When an occupant wishes to be seated, he or she must lift the safety bar and then sit down and allow the safety bar to lower so that it rests on the occupant's thighs. Additionally, a special strap resembling a very long seat belt assembly must be fastened around the safety bar to hold it in position in the event of a crash. In my November 3, 1988 reply to your letter, I explained that the crash protection requirements for school buses with a GVWR of 10,000 pounds or less are set forth in S5(b) of Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222). That section requires that each designated seating position be equipped with either safety belts or a protection system that requires no action by vehicle occupants. Since the "safety bar" is not a protection system that requires no action by vehicle occupants, my November 3 letter explained that the "safety bar" could not be installed in place of safety belts in small school buses; i.e., school buses with a GVWR of 10,000 pounds or less. My November 3, 1988 letter also explained that safety bars could be installed in small school buses in addition to safety belts, if the safety bars do not destroy the ability of the required safety belts to comply with the requirements of our safety standards. I also stated that a manufacturer that installed these safety bars in small school buses would have to certify that the bus in which the safety bars were installed complied with the school bus emergency exit requirements of Standard No. 217, Bus Window Retention and Release (49 CFR /571.217) and with the impact zone requirements specified in S5.3 of Standard No. 222. You asked whether my November 3, 1988 letter addressed the situation for both large school buses (i.e., those with a GVWR of more than 10,000 pounds) and small school buses, or whether it addressed only small school buses. Your previous letter asked only about small school buses, so my November 3 letter addressed those vehicles only. Assuming this was the case, you asked for "an opinion that [the safety bar] does not conflict with any standard for large school bus installation." I am happy to have this chance to explain our regulations to you. Let me begin by noting that the National Traffic and Motor Vehicle Safety Act requires each manufacturer to certify that each of its motor vehicles or items of motor vehicle equipment complies with all applicable safety standards. Because of this statutory provision, NHTSA has no authority to approve, endorse, or offer assurances of compliance for your product. Instead, any manufacturer that installs your safety bar in its large school buses must itself certify that those large school buses comply with all applicable safety standards when the safety bars are installed. The occupant crash protection requirements for large school buses are set forth in Standard No. 222. No provision of Standard No. 222 expressly prohibits the installation of "safety bars" in large school buses. Hence, "safety bars" can be installed in a large school bus, provided that the manufacturer of the bus certifies that it complies with all applicable requirements set forth in the safety standards with the safety bars installed. These requirements include the emergency exit requirements specified in Standard No. 217, all of the requirements of Standard No. 222, and the flammability resistance requirements of Standard No. 302, Flammability of Interior Materials (49 CFR /571.302). Please let me know if you have any further questions or need additional information. Sincerely,
Erika Z. Jones Chief Counsel /ref:217#222#302#VSA d:3/l0/89 |
1970 |
ID: aiam4864OpenGary P. Toth, Esq. General Motors Corporation Legal Staff New Center One Building 3031 West Grand Blvd. P.O. Box 33122 Detroit, MI 48232; Gary P. Toth Esq. General Motors Corporation Legal Staff New Center One Building 3031 West Grand Blvd. P.O. Box 33122 Detroit MI 48232; "Dear Mr. Toth: This responds to your request for an interpretation o how the requirements of Standard No. 209, Seat Belt Assemblies (49 CFR 571.209) would affect some dual-spring retractor designs GM is considering. Your letter said that these dual-spring retractors are designed so that a spring with a lower retraction force is or can be engaged when the safety belt is being worn by an occupant. When the safety belt is removed, a spring with a higher retraction force is engaged to effectively stow the belt webbing. Your letter also said that the retractor for the shoulder belt portion of the lap/shoulder belts on which these designs would be used is an emergency locking retractor (ELR). The minimum and maximum retractor force requirements for ELRs are set forth in S4.3(j)(5) and (6) of Standard No. 209. Those sections specify minimum and maximum retractor force requirements when the retractors 'are tested in accordance with the procedures specified in paragraph S5.2(j).' S5.2(j) specifies that, for the purposes of measuring the retractor forces, the webbing shall be fully extended from the retractor and then retracting the webbing to 75 percent extension plus or minus 2 inches. Your letter stated that your dual-spring retractor designs will comply with the minimum retractor force requirements when tested under the conditions specified in S5.2(j). This is because the higher retraction force will always be engaged under those conditions. It appears that, when the higher retraction force is engaged in these dual-spring retractor designs, the retractors will comply with the minimum retractor force requirements. However, when the lower retraction force is engaged, the retractor force is less than the minimum retractor force requirement. Because these dual-spring retractors comply with the retractor force requirements when tested under the conditions specified in S5.2(j) of Standard No. 209, your company is ready to certify these designs as complying with Standard No. 209. You are, however, concerned with the implications of a February 16, 1984 NHTSA interpretation addressed to Mr. Frank Pepe. In that instance, Mr. Pepe stated that the ELR had two tension modes that were activated by the vehicle door. The subject retractor operated in a high tension mode when the vehicle door was open, and in a lower tension mode when the vehicle door was closed. The agency concluded that, because Standard No. 209 does not distinguish between tension modes, the subject retractors would have to comply with all the requirements of the standard, including the minimum and maximum retraction force requirements, in both tension modes. Your letter asked us to reevaluate the conclusions reached in our February 16, 1984 letter to Mr. Pepe. We believe that the facts presented in your letter are significantly different than those that were presented in the Pepe letter, so the conclusions reached in the Pepe letter are not the same we would reach for your company's dual-spring retractors. In the case of the Pepe letter, the starting point for our analysis of whether the retractors would comply with the minimum and maximum retractor force requirements was the language of S4.3(j) in Standard No. 209, which directed us to the test conditions set forth in S5.2(j) of Standard No. 209. However, the test conditions in S5.2(j) complete extension of the webbing, followed by subsequent retraction to 75 percent extension did not adjust the Pepe retractors to either the high or low tension mode. Some additional action beyond the conditions specified in S5.2(j) had to be taken to select either the high or low tension mode. Since the selection of the high or low tension mode was not specified in S5.2(j) or elsewhere in Standard No. 209, NHTSA concluded that the retractor would have to be certified as complying with the retractor force requirements when adjusted to either the high or low tension mode. The GM retractors present a significantly different situation. According to your letter, the conditions set forth in S5.2(j) will adjust the GM retractors in a way so that the higher retraction force will always be engaged. Assuming this to be the case, no adjustments beyond the conditions specified in S5.2(j) would be necessary to select a tension mode for the retractors. In these circumstances, compliance with the minimum retractor force requirements would be determined only under the conditions specified in S5.2(j). Sincerely, Paul Jackson Rice Chief Counsel"; |
|
ID: nht87-3.35OpenTYPE: INTERPRETATION-NHTSA DATE: 12/03/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Frank Miller -- Gerry Baby Products TITLE: FMVSS INTERPRETATION TEXT: Mr. Frank Miller Gerry Baby Products 12520 Grant Drive Denver, CO 80233 This responds to your September 25, 1987 letter to Mr. Val Radovich of NHTSA's Office of Vehicle Safety Standards and your October 19, 1987 letter to my office concerning paragraph S4.2.1 of Safety Standard No. 302, Flammability of Interior Materials. You ask whether the thread that is used in the manufacture of a seat cushion is tested as part of the component. The answer is yes. In a March 10, 1978 interpretation of Standard No. 302, NHTSA recognized that stitching that does not adhere at every poin t of contact should be tested separately under S4.2.1. However, the agency also determined that, from the standpoint of practicality, the stitching cannot be tested separately in the prescribed manner. NHTSA thus concluded that stitching will be tested a s part of the material itself. Please contact us if you have further questions. Sincerely, Erika Z. Jones Chief Counsel September 25, 1987 To: Mr. Val Radovich Office of Vehicle Safety Standards National Highway Traffic Safety Admin. 400 Seventh Street, S.W. Washington, D.C. 20590
From: Frank Miller Gerry Baby Products 12520 Grant Drive Denver, CO 80233 Dear Sir: This inquiry is in regards to the flame retardancy requirements of FMVSS 302, specifically S4.2.1. A question has been brought up about the thread that is used in the manufacture of the seat cushion. Is the thread considered to be part of the composite? Thank you for your time. Sincerely, Frank Miller Quality Engineer October 19, 1987 Office of Chief Counsel NHTSA 400 Seventh St. S.W. Washington, D.C. 20590 Dear Sir/Madam: To satisfy our specifications we need written legal interpretation of the term "composite" as used in FMVSS 302. Our feeling is that as long as the sewn seat meets the requirements, the thread and/or binding does not have to meet the requirements if tested separately. We feel this way because the thread and binding in the Gerry Guardian Car Seat adheres to the seat cushion at every point of contact. Your response to this matter will be greatly appreciated. Sincerely, Frank Miller Quality Engineer |
|
ID: nht72-3.33OpenDATE: 03/15/72 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Society of Automotive Engineers, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 7, 1972, to the Administrator, in which you requested "clarification" of two requirements of Standard 207 that impose forces on rearward facing seats. We do not believe that the requirements are unclear. S4.2(b) requires a rearward facing seat to withstand a force of 20 times its weight applied in a rearward direction, while S4.3.2.2 requires the restraining device not to release or fail under an acceleration of 20 g's in the direction opposite to that in which the seat folds. You suggest that these forces and accelerations are equivalent to those in a 30 mph barrier impact, and point out that none of the existing standards provides for a 30 mph rear impact. The intent of the cited sections is to require rear facing seats to withstand the force of rear and collisions, which occur frequently and are often of considerable severity. We have some doubt that the 20 g acceleration is equivalent to a 30 mph rear barrier impact; frontal 30 mph impacts typically produce accelerations of 30 to 40 g's. Whether it is not is irrelevant, however, to the validity of the standard. The standard is clear in its own terms, and in our judgement its requirements are appropriate and feasible. |
|
ID: 1983-3.6OpenTYPE: INTERPRETATION-NHTSA DATE: 09/15/83 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Potemkin TITLE: FMVSS INTERPRETATION TEXT:
NOA-30 Mr. Al Desarro Potemkin 21111 South Dixie Highway Miami, Florida 33189
Dear Mr. Desarro:
This is to follow up on your phone conversation with Stephen Oesch of my staff concerning the type of seat belts that must be used in a 1983 converted van that has a sofa.
Paragraph S4.2.2 of Safety Standard No. 208, Occupant Crash Protection, (copy enclosed) requires trucks and multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less to meet the same requirements as passenger cars. This would include the vans in question. Paragraph S4.1.2.3 of the standard specifies that passenger cars must be equipped with a Type 2 seat belt assembly (non-detachable lap and shoulder belt) at each front outboard designated seating position. At all other seating positions, either a Type 1 seat belt assembly (lap belt only) or a Type 2 seat belt assembly must be used. Thus, your vans must have Type 2 belts in the two front seats and either Type 2 or Type 1 belts in the rear seating positions, including the sofa. The agency's position regarding seat belts for sofa/beds used in van conversions is more fully explained in the enclosed interpretation letter of March 29, 1983, to Sherrod Vans, Inc.
If you have any further questions, please let me know. Sincerely,
Frank Berndt Chief Counsel
Enclosure |
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.