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.”
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NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: nht92-1.45OpenDATE: 12/02/92 FROM: FRANK E. TIMMONS -- ASSISTANT VICE PRESIDENT, TIRE DIVISION, RUBBER MANUFACTURERS ASSOCIATION TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 2-11-93 FROM JOHN WOMACK TO FRANK E. TIMMONS (A40; STD. 109; STD. 119; PART 574); ALSO ATTACHED TO LETTER DATED 11-13-92 FROM PAUL JACKSON RICE TO UNDER SECRETARY, KUWAIT MINISTRY OF COMMERCE AND INDUSTRY; ALSO ATTACHED TO LETTER (DATE ILLEGIBLE) FROM UNDER SECRETARY, KUWAIT MINISTRY OF COMMERCE AND INDUSTRY. TEXT: Your November 13, 1992 letter to the Under Secretary, Ministry of Commerce Kuwait has just been brought to my attention (see attached). There are two statements in your letter that are incorrect. If the Kuwait government does not realize this, it is possible that US tire manufacturers could be adversely affected. In your third paragraph, starting on line 3, you state" . . .all new tires sold for use on other motor vehicles must be certified as complying with Standard No. 119 (49 CFR Part 571.119)." This is not true. Only those tires designed and offered for sale for use on highway vehicles, other than passenger cars, must be certified as being in compliance with FMVSS 119. The other misstatement in your letter is in your response to their question No. 1. "Must all tires manufactured and sold in the United States bear the 'DOT' mark?". Your answer - "Yes, assuming that the tires are intended for use on motor vehicles." is not correct. Only those tires intended for use on highway vehicles must be labeled with the DOT mark. NHTSA has stated in the past on more than one occasion that the DOT may not be labeled on tires that do not have an applicable Federal Motor Vehicle Safety Standard. It is requested that NHTSA send a follow-up letter to Kuwait clarifying that your response applied only to motor vehicles and their tires that are designed primarily for use on the highway. As mentioned to Walter Myers of your staff yesterday, I will ask Mr. Ed Wunder to discuss this with his contacts in Kuwait. Mr. Wunder is stationed in Saudi Arabia and is supported jointly by industry and the Department of Commerce (NIST) to help US manufacturers sell their products in the Gulf countries. |
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ID: nht88-2.68OpenTYPE: INTERPRETATION-NHTSA DATE: 07/12/88 FROM: WAYNE IVIE -- MANAGER, VEHICLE SUPPORT SERVICE SECTION, NHTSA TO: NHTSA, OFFICE OF SAFETY COMPLIANCE/ENFORCEMENT ATTACHMT: LETTER DATED DEC. 8, 1988 TO WAYNE IVIE, OREGON DEPT. OF TRANSPORTATION, FROM ERIKA Z. JONES, NHTSA TEXT: On June 16th of this year, Oregon enacted a mandatory helmet law. Anyone riding on a motorcycle or moped on our highways must wear "approved" protective headgear. Our agency adopted FMVSS 218, Motorcycle Helmets, as the minimum standard for helmets. Part S5.6.1 of the standard requires permanent and legible labeling of helmets, including the DOT symbol, to prove that a helmet meets that standard. Helmet manufactu rers apparently attach a sticker with the DOT symbol onto the back of the helmet. Our office is receiving inquiries from individuals and police officers, who advise that on many helmets, this DOT sticker has fallen off or been removed by someone in order to paint the helmet, etc. They add that often there is no other labeling in or o n the helmet, so they can not determine that it meets any standard. (Is considered "approved" for use in Oregon.) To complicate this further, there is no manufacturer or brand name anywhere on the helmet, so contacting a dealer or manufacturer for infor mation is not possible. Advising someone to dispose of such a helmet and get another with proper labeling doesn't seem an appropriate answer, and may be just an undue expense for the motorcycle rider. Are manufacturers allowed to use the DOT sticker only, with no other labeling, or is this being done in violation of FMVSS 218? (If the DOT sticker is now the only label used, we would definitely like to recommend that a permanently embossed DOT symbol somewhere in or on the helmet be also required.) Have you been advised of similar problems by other jurisdictions? Do you have suggestions on how we can resolve the situation of a helmet that appears to have been made in compliance with standard require ments, is in a good, undamaged condition, yet does not have any labeling? Thank you for your help in this matter. |
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ID: nht87-2.9OpenTYPE: INTERPRETATION-NHTSA DATE: 06/12/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Mr. Thomas D. Turner TITLE: FMVSS INTERPRETATION TEXT: Mr. Thomas D. Turner Manager Engineering Services Blue Bird Body Company P.O. Box 937 Dear Mr. Turner: Thank you for your letter concerning Standard No. 301, Fuel System Integrity. You stated that there is a conflict in the standard about the correct ground clearance of the contoured impact surface used in the school bus impact test of the standard. You s tated further that S7.5.1 of the standard refers to the dimension between the ground to the lower edge of the impact surface as 5.25 + 0.5 inches, while Figure 2 of the standard shows the ground clearance to be 12.25. As discussed below, and as Mr. Oesch of my staff discussed with you in a phone call earlier this year, the correct dimension is 5.25 + 0.5 inches. As you noted in your letter, the agency adopted the use of the contoured barrier in a final rule issued on April 16, 1975. The preamble to that final rule stated that "The contoured barrier would incorporate the moving barrier specifications of SAE Recom mended Practice J972a (March 1973). However, the impact surface of the barrier would be at a height 30 inches above the ground level, rather than 37 inches as specified in the SAE provision. Studies have shown that a 30-inch test height is more represent ative of actual collisions. This would be a typical engine height of vehicles that might impact a schoolbus." Thus, in S7.5.1 of the standard, the agency adopted the ground clearance as 5.25 inches + 0.5 inches to ensure that the top of the barrier would be 30 inches from the ground. In Figure 2, the agency apparently incorporated the barrier dimensions directly from the SAE Recommended Practice J972a, without changing the ground clearance dimension. We will publish an amendment to the standard that will correct the ground clearance dimension set out in Figure 2 of Standard No. 301. Thank you for bring this matter to the agency's attention. If you have any further questions, please let me know. Sincerely, Erika Z. Jones Chief Counsel November 20, 1986 Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590 Reference: 49 CFR Part 571; 3O1-75 Fuel System Integrity Section S7.5.1 of the standard specifies . . ." The contoured impact surface which is 24.75 inches high and 78 inches wide, conforms to the dimensions shown in Figure 2, and is attached to the carriage as shown in that figure. The ground clearance to the lower edge of the impact surface is 5.25 + 0.5 inches"... Figure 2 shows dimension D, ground clearance to the lower edge of the impact surface, is 12.25 inches while the text says it is 5.25 + 0.5 inches. In reviewing the history of Standard 301-75, I found the height of the impact surface was specifically discussed in Federal Register Volume 40, Number 74, Wednesday, April 16, 1975, with regard to school buses. The highlighted areas on the attached copy of this discussion indict the intention was to use the 5.25 inch dimension, making the overall height of the impact surface 30 inches, for school bus moving contoured barrier crash tests. Based on this history and recent discussions with NHTSA personnel, it is our understanding that the 5.25 + 0.5 inches is the correct dimension and dimension D in Figure 2 should be corrected to show this value. Please confirm that our understanding is co rrect. We are currently obtaining quotations from test laboratories for FMVSS 301 Certification testing and must have this issue resolved before finalizing testing plans. If written confirmation can be provided by December 11, 1986, it would be appreciat ed. If not, please have one of your staff verbally advise us by December 11, 1986, and then follow-up with a letter of confirmation. Thank you for a timely response to this request. Very truly yours, Thomas D. Turner Manager Engineering Services
fvc/1839 c: FHVSS 301-75 (SEE ATTACHMENT...) |
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ID: nht69-1.13OpenDATE: 02/26/69 FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA TO: Mr. T. Sudderth TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of January 22, 1969, concerning safety glazing in your motor home. We do not know what is meant by the description "Windows-Double Density - glass - set." Glasing materials in a motor home must be in accordance with Federal Standard No. 205. Glass in the windshield must be AS1, not AS2 as your letter states. The windows on either side of the driver's compartment may be AS2, and AS2 may be used in the balance of the windows when needed for driver visibility or AS3 may be used in the balance of the windows when not needed for driver visibility. The markings of glazing materials cited in your letter indicate that the materials used in your motor home are in accordance with Federal Standard No. 205, with the exception that you state that AS2 is marked on the windshield. Please advise me if AS1 is not installed in the windshield of your motor home. Sincerely, January 22, 1969. The National Highway Safety Bureau Department of Transportation Gentlemen: A few months ago I bought a new Dodge Motor Home (Travco) and it was ordered out from production with a number of option equipment items. One was identified as - "Windows - Double Density - glass - Set As of this date I am not too sure that this was included in the assembly and I have no way to identify the item and judge if I have paid a fair price. Will you please assist me - The glass in the windshield and two side of driver compartment are marked as Guardian Safety Glass As 2-67 Tempalite Solid Tint GG M 66 The glasses on the side walls are market's as follows - TWI-Lite Safety-Lite AS 3 M 21 The rear window is marked - AT Asorbing Safety Glass Solid Tempered M " 286 I am unable to see any identification on the two small glasses in the entrance doow assembly. Your prompt comments will be appreciated. Yours very truly T. Sudderth PO Box 757 - Laurens 29360 |
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ID: 77-4.25OpenTYPE: INTERPRETATION-NHTSA DATE: 10/31/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Oshkosh Truck Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of August 29, 1977, asking for confirmation of your interpretation of S4.5.4 of Motor Vehicle Safety Standard No. 108. Paragraph S4.5.4 requires that "The stop lamps on each vehicle shall be activated upon application of the service brakes." Oshkosh trucks are equipped with split air brake systems. This system incorporates a parking brake system on the rear axles. You indicated that there are three conditions under which the parking brakes will apply: Condition 1. - Parking Application. The spring brakes are driver applied through a hand operated parking control. Condition 2. - Rear Service Brake System Failure. The spring brakes can be driver applied through the service brake foot operated treadle valve control in the event of a failure in the rear service brake system. Condition 3. - Spring Brake Cavity Pressure Loss. A component failure which allows air pressure to exhaust from the spring cavity of the rear brake chambers will cause the spring brakes (parking brakes) to apply. This condition is not driver initiated." You have interpreted Condition 2 as the only "service brake" application since it is the only one of the three that is driver-initiated through the service brake control, and that stop lamp activation under the other two Conditions is not required by Standard No. 108. This will confirm your interpretation. With respect to Condition 1, we do not consider that driver application of the parking brake portion of the service brake system is "application of the service brakes" within the meaning of S4.5.4. Nor do we consider that activation of the parking brakes through component failure is "application of the service brakes", your Condition 3. SINCERELY, August 29, 1977 Chief Counsel NHTSA Subject: FMVSS 108 Stop Lamp Circuitry Interpretation Request Oshkosh Truck Corporation equips its trucks and truck tractors with split air brake systems. The Bendix-Westinghouse Corporation has a publication which very concisely explains the operation of a split air brake system like the one adopted by Oshkosh Truck. A copy of this publication "Bendix-Westinghouse Dual Air Brake System" is attached. As explained on page 5 of the Bendix publication, the spring brakes on the rear axles are the vehicle's parking brakes. There are, however, three conditions in which the spring brakes will apply. Condition 1. - Parking Application. The spring brakes are driver applied through a hand operated parking control. Refer to page 5 of the attachment. Condition 2. - Rear Service Brake System Failure. The spring brakes can be driver applied through the service brake foot operated treadle valve control in the event of a failure in the rear service brake system. Refer to page 6 of the attachment. Condition 3. - Spring Brake Cavity Pressure Loss. A component failure which allows air pressure to exhaust from the spring cavity of the rear brake chambers will cause the spring brakes (parking brakes) to apply. This condition is not driver initiated. FMVSS 108 requires that the stop lamps be activated upon application of the service brakes (para. 4.5.4) but does not require that the stop lamps be activated upon application of the parking brakes. Although all three of the above conditions are possible with the vehicle in motion, Oshkosh Truck Corporation interprets condition 2 as the only "service brake" application of the three described in that this spring brake application is the only one of the three that is driver initiated through the service brake control. In its interpretation of FMVSS 108 Oshkosh Truck Corporation has determined that stop lamp activation is not mandatory when the spring brakes are applied by conditions 1 or 3 described above (regardless of the vehicle's FMVSS 121 status). Oshkosh Truck requests written confirmation. Your immediate attention to this request will be greatly appreciated. Stephen C. Nimmer Senior Supervising Engineer [Publication Omitted.] |
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ID: 10574Open Mr. David O'Neil Dear Mr. O'Neil: This responds to your inquiry about Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, with respect to the labeling of glazing installed on transit buses. You stated that the passenger and driver side window glazing on certain transit buses will be a glass-plastic composite consisting of 1/4 inch tempered glass with DuPont Spallshield 307 plastic laminated to the interior surface. You asked whether this glazing must be certified and marked as Item 15B/16B glazing or whether it is possible to certify and mark the glazing as Item 2/3. You also asked whether taping the required cleaning instructions to the glazing satisfies the requirements of paragraph S5.1.2.10. Question One: Must the glazing be certified and marked as Item 15B/16B or is it possible to certify and mark the glazing as Item 2/3? The glazing described in your letter is tempered glass-plastic and therefore must be certified and marked as either Item 15B or 16B glazing. Item 2 and Item 3 glazing refers to glass, not glass-plastic glazing. It would be incorrect to certify and mark a glass-plastic item of glazing as glass. Question Two: Does a label containing all required instructions which is taped to the glazing satisfy the requirements of paragraph S5.1.2.10? Paragraph S5.1.2.10(a) states that Each manufacturer of glazing materials designed to meet the requirements of S5.1.2.1, S5.1.2.2, S5.1.2.3, S5.1.2.4, S5.1.2.5, S5.1.2.6, S5.1.2.7, or S5.1.2.8 shall affix a label, removable by hand without tools, to each item of such glazing material. The label shall identify the product involved, specify instructions and agents for cleaning the material that will minimize the loss of transparency, and instructions for removing frost and ice, and at the option of the manufacturer refer owners to the vehicle's Owners Manual for more specific cleaning and other instructions. S5.1.2.10(a) applies to your Item 15B/16B glazing since the glazing is required to comply with S5.1.2.6 or S5.1.2.8. S5.1.2.10(a) requires a manufacturer to "affix a label, removable by hand without tools..." Taping the instructions to the glazing is one way to affix a label to glazing that could be removed by hand without tools. Therefore, a manufacturer could comply with the requirements in S5.1.2.10(a) by taping the instructions to the glazing. I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely,
Philip R. Recht Chief Counsel ref:205 d:2/14/95
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1995 |
ID: 24099.ztvOpen Ms. Karen Benedix Dear Ms. Benedix: This is in reply to your letter of February 21, 2002, with reference to Federal stop lamp requirements. You have asked for specific requirements "for the number of brake lamps and also the amount of illumination required for each lamp" on passenger cars. Original and replacement equipment stop lamps must comply with Title 49, Code of Federal Regulations, Section 571.108 (Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Table III of Standard No. 108 requires a vehicle to be equipped with at least two stop lamps, one on each side of the vertical centerline, as far apart as practicable, and a center high-mounted stop lamp. The two lower-mounted stop lamps may be supplemented by additional stop lamps (which must be functionally and operationally similar to the required ones, and must not impair the effectiveness of the required stop lamps). The center high-mounted stop lamp must remain a single lamp and cannot be supplemented with an additional lamp. Table III requires that the lower-mounted stop lamps be designed to conform with SAE Standard J586 FEB84, which has been incorporated by reference into Standard No. 108 and contains photometric requirements for these lamps. Table III requires that the center high-mounted stop lamp be designed to conform with SAE Standard J186a, September 1977, except that the photometric requirements for the center lamp are those of Figure 10 of Standard No. 108. I hope that this answers your question. Sincerely, Jacqueline Glassman ref:108 |
2002 |
ID: 08-005240drnOpenGeorge Carl Pezold, Esq. Pezold, Smith, Hirschmann & Selvaggio, LLC 120 Main Street Huntington, NY 11743-6936 Dear Mr. Pezold: This responds to your request for an interpretation asking whether the COBUS 2700 is a motor vehicle subject to the Federal motor vehicle safety standards. As explained below, our answer is yes. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards. They must also ensure that their vehicles and equipment are free of safety-related defects. In your letter, you explained that your client, COBUS Industries, LP, would like to sell the COBUS 2700 Airport bus to the Denver Regional Transportation District (RTD) which intends to use it as a free shuttle bus for shoppers along the 16th Street Mall in downtown Denver. You state that the bus is virtually identical to the COBUS 3000 model, which this office had determined in 1999 was not subject to the FMVSSs as an airfield bus.[1] That is, the Cobus 3000 in that letter was built specifically for airfield use, to transport passengers between a remotely parked aircraft and the terminal or from terminal to terminal. Id. You believe that the substantial similarity in the use and application of the COBUS 2700 to the COBUS 3000 should justify a similar conclusion. In your letter, you describe the 16th Street Mall as follows: The Mall is a 1.3-mile-long portion of the 16th Street from Broadway to Wewatta Street. It has wide sidewalks with shops and restaurants lining both sides of the street. The center path was designed for the free mall shuttle bus fleet, which connects with the RTDs regional and express lines at either end of the Mall. You further write that the Mall is closed to all vehicular traffic except for the mall shuttle buses and authorized emergency and service vehicles. You note that the intersections with cross streets to the Mall are open to regular cross vehicular traffic and are controlled by traffic lights timed for the mall bus operating cycles.[2] You also state that from a stop at each intersection, the mall bus accelerates to about 15 miles per hour, then decelerates to a complete stop at the next intersection, opens all doors to discharge and board passengers, closes all doors and accelerates again to the next stop. The buses serve an average of over 50,000 commuters and tourists a day. You further state that each day, the vehicles will be driven on a regular city public street two miles to and from the RTDs bus storage and maintenance facility at a governed speed of 20 miles per hour. Agency Analysis We have considered the views you have expressed in your letter but disagree with the suggestion that the COBUS 2700 bus is not a motor vehicle. Motor vehicle is defined at 49 U.S.C. 30102(a)(6) in pertinent part as: a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways. The question to answer is whether the vehicle is manufactured primarily for use on the public streets, roads, and highways. Our answer is yes, for several reasons. First, your letter states that the COBUS 2700 would run daily on a regular city public street to and from RTDs bus storage and maintenance facility. This is a regular and expected use of the public roads by the COBUS 2700. Second, we do not agree that the closure of 16th Street to most vehicular traffic between Broadway and Wewatta Street renders 16th Street no longer a public road. Between Broadway and Wewatta Street, there are signal lights and numerous public roads crossing 16th Street. There is also a significant pedestrian presence in the shopping area. This close interface with motor vehicle and pedestrian traffic leads us to conclude that the bus will be operating on a public road. On a final note, NHTSA has previously considered pedestrian mall buses to be motor vehicles.[3] The COBUS 2700 differs from the airport bus that was the subject of the agencys 1999 letter on the COBUS 3000. Airfields on which the COBUS 3000 was designed to be used differ significantly from shopping areas in downtown Denver. Airfields are closed, isolated areas where vehicular traffic is restricted and pedestrian traffic nonexistent. In contrast, the 16th Street Mall is open to substantial vehicular cross-street and pedestrian traffic. It is important for the bus to meet the FMVSSs for crashworthiness and crash avoidance protection. Because it is intended to travel on public roads, the COBUS 2700 is a motor vehicle, more specifically, a bus. Therefore, before it is sold for use in the United States, the COBUS 2700 must be certified as meeting all applicable FMVSSs. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely yours, Stephen P. Wood Acting Chief Counsel ref:VSA102(4) d.2/3/09 [1] Letter to Ms. Debra Taylor from former Chief Counsel Frank Seales, Jr., September 9, 1999. [2] According to a web-based map, but not specifically mentioned in your letter, it appears that between Broadway and Wewatta, there are approximately 16 streets open to vehicular traffic, and a set of railroad tracks, crossing 16th St. [3] See letter to Mr. Keely Brunner, June 6, 1999. |
2009 |
ID: nht73-1.41OpenDATE: 06/28/73 FROM: Richard B. Dyson; NHTSA TO: Transportation Sash Co., Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of May 21, 1973, requesting that we clarify the certification and marking requirements for glazing materials. You indicate that you purchase block size glass and cut it to suit your customers. The requirements to which you refer are found in Federal Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR @571.205). They require each item of glazing material to be labeled with certain information, that specified in section [Illegible Number] of ANS @26.1-1966, which includes the manufacturer's trademark, the symbol AS or the words American Standard, a model number, and a reference, in the form of a number, that indicates the type of glazing material. All glazing materials for use in motor vehicles must be labeled with this information, which can be stencilled onto the material if it is removed during the cutting process. In addition to these identifying markings, each item of glazing material must be certified as conforming to the Federal standard. Prime glazing material manufacturers (those who fabricate, laminate, or temper the glazing material) certify glazing that is designed for use in any specific vehicle by including with the above markings the symbol DOT and a code number assigned to the manufacturer by this agency. Glazing that is not designed for a specific vehicle is certified pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), which includes, as you indicate, the use of a label or tag affixed to the glazing material that states that the material conforms to all applicable Federal motor vehicle safety standards. Manufacturers other than prime glazing material manufacturers, such as those, like yourself, who cut larger sheets to size, are required to certify in the same fashion; that is, in accordance with section 114, and may certify by labels or tags affixed to the material. I have enclosed a copy of the marking requirements of Standard No. 205 for your information. If you wish to obtain a copy of the American National Standard @@26.1-1966, you should write to the American National Standards Institute, 1430 Broadway, New York, New York 10018. |
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ID: nht80-1.27OpenDATE: 03/07/80 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Fiat Motors of North America TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of November 15, 1979, requesting that paragraph S8.1.9 of Safety Standard No. 208, Occupant Crash Protection, be corrected to change the phrase, "size 11EE shoe" to "size 11E shoe." I am sorry for the delay in this response. Size "11EE" shoes are specified in the standard to allow easy application of the shoes to the test dummy's feet. If the feet of the dummy are of the absolute maximum width allowed by the standard, some size "11E" shoes are very difficult to apply. However, the agency does not believe that use of either "11E" or "11EE" shoes will cause a variation in test results. Therefore, a manufacturer should be safe in using either size. Mr. Radovich was incorrect in his statement that size "11EE" shoes are not available on the market. Size "11EE" shoes can be obtained from the Freeman Shoe Company, the Bostonian Shoe Company and other companies by special order. For the reason stated above, we do not anticipate amending the standard to specify that shoe size should be "11E". However, if you have any data or other information indicating that test results can vary between use of size "11E" or size "11EE" shoes, we would certainly appreciate seeing the data. Sincerely, ATTACH. November 15, 1979 Frank Berndt -- Chief Council, NHTSA Dear Mr. Berndt, As per my conversation with Mr. Radovich of your staff, I am requesting NHTSA to please correct FMVSS 208 para 8.1.9 as follows: from: . . . with a size 11EE shoe . . . to: . . . with a size 11E shoe . . . Mr. Radovich agreed with me that this type of shoe is not available in the market and there is no explanation as to why NHTSA put 11EE in the standard.* (*) type 11E is available from Freeman Shoe Co. in Wisconsin. If you have any questions on the matter, please feel free to contact me, (313) 336-2400. My best regards, Aldo Fozzati -- FIAT RESEARCH & DEVELOPMENT, U.S.A. BRANCH |
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.