NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: 77-3.9OpenTYPE: INTERPRETATION-NHTSA DATE: 06/27/77 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Truck Body and Equipment Association, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your April 6, 1977, letter asking whether two proposed labels satisfy the requirements for certification and information labels found in 49 CFR Part 567. Certification, and Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The National Highway Traffic Safety Administration (NHTSA) does not issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with NHTSA regulations. From the illustrations you present, it appears that you have closely followed the format suggested in our regulations, and therefore, the labels seem to comply with the agency's requirements. Section S5.3(b) of Standard No. 120 permits the use of both labels when affixed in accordance with Part 567.4(b)-(f). |
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ID: 1982-2.20OpenDATE: 07/21/82 FROM: Frank Berndt; NHTSA TO: Arnold P. Fuchs TITLE: FMVSS INTERPRETATION TEXT: This letter is to confirm your view, expressed in a telephone call with Edward Glancy of this office, that the requirements of Standard No. 206, Door Locks and Door Retention Components, are not applicable to a replacement latch for a truck built in l969. The requirements of Standard No. 206 are applicable to passenger cars, multipurpose passenger vehicles and trucks. See S2 of that Standard. However, its requirements are not applicable to replacement parts for installation in used vehicles of these types. Further, the "render inoperative" provisions of the National Traffic and Motor Vehicle Safety Act are not relevant to the installation of such a latch. Under section 108(a)(2)(A) of that Act, a business such as a garage must make sure that it does not knowingly render inoperative the compliance of a vehicle with any applicable safety standard. With respect to a 1969 truck and Standard No. 206, there is no compliance which could be rendered inoperative since the Standard was never applicable to that truck. That Standard applies only to trucks manufactured on or after January 1, 1972. I would note that even in the absence of an applicable safety standard, the defect provisions of the Act may be applicable. Sections 151 et seq. of the Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge. |
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ID: nht68-3.24OpenDATE: 04/16/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: R.J. Townsly TITLE: FMVSR INTERPRETATION TEXT: Thank you for your letter of February 23, 1968, to the Department of Transportation, in regard to information pertaining to importation into the United States of a right hand drive Canadian manufactured vehicle. If your vehicle was manufactured prior to January 1, 1968, the Federal Motor Vehicle Safety Standards would not apply, however, if built after January 1, 1968, full compliance to Federal Safety Standards is necessary. While it is not clear from your letter, the status of your visa, or how long you wish to have the car in the United States a solution to your problem may be provided by the regulations governing the importation of motor vehicles subject to the Federal Standards which became effective January 10, 1968. You will see from 19 CFR Section 12.80 (b) (v) of the regulations enclosed that a non-resident of the United States may import a non-confirming motor vehicle for personal use for a period of not more than one year, and that it may not be resold in the United States. The National Highway Safety Bureau has not been informed of the manner in which vehicles of Canadian manufacture, including those with right hand drive, do not comply with the Federal Standards. It would be best to communicate directly with the Canadian manufacturer as to the extent of modification necessary should you not come with the 12.80 (b) (v) exception. If we can be of further assistance, please let us hear from you. |
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ID: 9142Open Mr. Terry Karas FAX 514-688-6968 Dear Mr. Karas: This responds to the concern your expressed by telephone to Taylor Vinson of this Office that a phrase in our letter of October 18, 1993, may be misinterpreted by the U.S. Customs Service. The final sentence of the paragraph that begins page 2 of that letter reads: "If this examination indicates that the vehicle is Canadian, and if it is being imported for commercial purposes, then the vehicle is subject to the registered importer process." In the context of the letter, we assumed that it was clear that the Canadian vehicle in question was one that did not comply with the U.S. Federal motor vehicle safety standards. You believe that Customs may interpret the word "Canadian" to mean any vehicle of Canadian manufacture, whether or not complying with the U.S. safety standards. We are pleased to provide the following clarification. With reference to the examination of the Canadian-manufactured vehicle in question, if it indicates that the speedometer does not have mph markings, this will demonstrate that the certification is to Canadian standards. Consequently, the Canadian-manufactured vehicle is one that does not comply, and is not certified as complying, with the U.S. standards, and, if it is being imported for commercial purposes, is subject to entry under bond and the registered importer process. Sincerely,
John Womack Acting Chief Counsel ref:567 d:10/18/93 |
1993 |
ID: nht91-3.31OpenDATE: April 29, 1991 FROM: George D. Powley -- Project Engineer, Truck-Lite Co., Inc. TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: Re FMVSS NO. 108 (Lamp, reflective devices, and associated equipment) Interpretation and/or petition for Orientation of electrical contact blades on sealed beam headlamps ATTACHMT: Attached to letter dated 5-22-91 from Paul Jackson Rice to George D. Powley (A37; Std. 108) TEXT: We would like your advice regarding the orientation of electrical contact blades on sealed beam headlamps. We are contemplating the future production of a 2A1 type sealed beam with a contact blade orientation differing from that shown in SAE Standard J571, fig. 6 "type 2A sealed beam headlamp unit 4 x 6 1/2 in. (100 x 165 mm) rectangular unit" (Attachment A), which establishes a blade orientation that we will describe as being rotated 148 degrees 54' in the clockwise direction from the orientation established for a "type 2B sealed beam headlamp 142 x 200 mm" as shown in fig. 1 of SAE Standard J1132 (Attachment B). We would like to produce both a large rectangular 2B1 and a small rectangular 2A1 using the same blade orientation. Specifically, we would propose to use the 2B1 orientation on the 2A1 unit. We wish to stress that the electrical function of each terminal in all cases would conform to the appropriate specification, and all the dimensional requirements, other than the "31 degrees 06' " orientation for the 2A1, would be adhered to on both products. We do not feel that this proposed electrical contact orientation will in any way adversely effect the lamps performance or its ability to interchange with existing lamps in motor vehicles presently in the field. We have observed that Koito Manufacturing Co., Ltd., of Japan is apparently presently marketing a 2A1 glass sealed beam unit with a non-standard blade orientation, and it is worthy of note that our proposed orientation differs from theirs only in that our terminal pattern would be rotated 180 degrees from theirs with respect to the top of the lamp. We thank you for your prompt consideration of this matter. Should you have any questions, please contact the writer at (716) 665-6214 Extension 231.
Attachments Attachment A Figure 6 Type 2A Sealed Beam Headlamp Unit 4 x 6 1/2 in (100 x 165 mm) Rectangular Unit (Text and graphics omitted) Attachment B SAE Recommended Practice 142 x 200 mm Sealed Beam Headlamp Unit -- SAE J1132 Figure 1 Type 2B Sealed Beam Headlamp 142 x 200 mm (5.6 x 7.9 in) Rectangular Unit (Text and graphics omitted) |
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ID: 1985-04.3OpenTYPE: INTERPRETATION-NHTSA DATE: 10/22/85 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Kenneth E. Deane -- Application Engineer, Mallory Timers Company TITLE: FMVSS INTERPRETATION TEXT: Mr. Kenneth E. Deane Application Engineer Mallory Timers Company P.O. Box 986 Indianapolis, IN 46206
This is in reply to your letter of July 25, 1985, to Mr. Vinson of this office asking for an interpretation of Motor Vehicle Safety Standard No. 108.
With reference to the center high-mounted stop lamp and the acceptability of a switch you have designed, you have asked whether the new lamp and the vehicle's primary stop lamps "must be energized simultaneously, or that the low mount light must come on first, followed by the high mount light within 35 milliseconds." You have designed a switch which would energize these lamps within 80 milliseconds of each other.
Paragraph S4.5.4 requires that the stop lamps on a vehicle be activated upon application of the service brakes, and, further, that the center high-mounted stop lamp shall only be activated upon application of the service brakes. We interpret this as meaning that all stop lamps on a vehicle must be activated simultaneously. Lawrence J. Fogel's "Human Information Processing" (Prentice-Hall, Inc. (1967), p. 101) indicates that the eye cannot discern delays of 50 milliseconds or less. Therefore, we believe that an observer would not be able to detect a 35 millisecond delay but would be able to detect an 80 millisecond delay. Accordingly, a 35 millisecond delay would be considered to be "simultaneous," but an 80 millisecond delay would not.
You have also asked whether "slow 'teasing' of the brake pedal must not cause intermittent 'blip' flashing of the high mount light when the hazard warning signal is employed." A center high-mounted stop lamp is allowed to flash with the hazard warning system on passenger cars manufactured before September 1, 1986, but it must be steady burning at all times on passenger cars manufactured on or after that date.
I hope that this answers your questions. Sincerely, Jeffrey R. Miller Chief Counsel
July 25, 1985 Mr. Taylor Vinson SMVSS108 NHTSA Room 5219 U.S. Department of Transportation 400 7th Street, SW Washington, DC 20024
Dear Mr. Vinson:
I have been referred to you by Mr. Kevin Cavey of the NHTSA for a clarification of one of the requirements for the High Mounted Brake Light on passenger cars.
We have designed and tooled a brake switch for this application in which the low mount brake lights and the high mount brake lights are energized within 80 milliseconds of each other. (This is at a brake lever actuation speed of 5mm/second.) To further clarify, either light could come on first, followed by the other light within 80 milliseconds.
Recent inputs from our customer, B-O-C Detroit, indicate that both lights must be energized simultaneously or that the low mount light must come on first, followed by the high mount light within 35 milliseconds. Also that slow "teasing" of the brake pedal must not cause any intermittent "blip" flashing of the high mount light when the hazard warning system is employed. In conversation with B-O-C engineering they indicated that they "think" this is the NHTSA requirement.
A complete redesign of our already tooled product would be necessary to meet these new requirements at considerable cost and subsequent program delay. For this reason, we request your input and interpretation of the NHTSA's intentions in this area. Thank you for your early consideration. Respectfully, Kenneth E. Deane Application Engineer KED/s cc: Messrs. E. Eaton P. Johnson J. Smith R. Stafford J. Wiser |
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ID: Legg1OpenMs. Kerry Legg Safety & Compliance Manager New Flyer 25 DeBaets Street Winnipeg, Manitoba R2J 4G5 Canada Dear Ms. Legg: This responds to your letter regarding permissible colors for illuminated destination signs on the front of new transit buses, under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. You state that a customer has requested installation of signs capable of illuminating route designations and other messages in a variety of colors, including red, green, and blue. You believe that lighting equipment on the front of the vehicle must illuminate within the color spectrum from white to amber, adding that you have seen specific limitations to this effect under California State law. You ask whether such red, green, and blue lighted signs are prohibited under FMVSS No. 108. As explained below, given only the description you offer of the subject lighting system, the answer to your question is yes. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. 30111 and 49 CFR Part 571). It is the responsibility of manufacturers to certify that their products conform to all applicable safety standards before they can be offered for sale (see 49 U.S.C. 30115 and 49 CFR Part 567). FMVSS No. 108 sets forth the requirements for both new and replacement motor vehicle lighting equipment. We note that the agency addressed the issue of color of vehicle lighting equipment in a July 29, 2002 letter of interpretation to Trooper Lawrence Richardson (Richardson letter, copy enclosed). Our interpretation of FMVSS No. 108 has not changed from the opinion of the Richardson letter. Under Federal law (i.e., FMVSS No. 108), the only permissible colors of light that may be emitted by original required equipment lighting on new vehicles are red, amber, or white. Furthermore, the standard requires items of replacement equipment to emit the same color light as the original equipment that they are designed to replace. Accessory equipment (i.e., lighting equipment not required under the standard) is permissible on new vehicles, provided that it does not impair the effectiveness of lighting equipment required by Standard No. 108 (see S5.1.3). We interpret this as a general prohibition on lamps of colors different than red, amber, or white, because of the possibility that non-standard colors could cause confusion in other drivers, thereby diverting their attention from lamps that signal driver intention, such as stop lamps or turn signal lamps. Turning to the specifics of the issue presented in your letter, we first note that permissible colors for lamps on the front of a bus are limited to amber or white. Use of supplemental red lamps on the front of a vehicle, such as the destination signs to which you refer, could cause confusion with brake or stop lamps. The color green typically conveys the message that one may proceed, so it could cause confusion with other red or yellow lamps that seek to warn or caution. Finally, blue is a color that some States reserve for use on emergency vehicles, so drivers unexpectedly encountering blue lamps on other types of vehicles could take potentially inappropriate actions. Generally, if certain accessory lighting is not permissible on new vehicles, commercial entities will not be permitted to install the lighting as an aftermarket accessory for vehicles in use. The legal consideration is whether the accessory makes inoperative in any way a lamp required under and installed in accordance with Standard No. 108 (see 49 U.S.C. 30122). Usually, we equate impairing the effectiveness of a required item of lighting equipment with making inoperative such equipment in part, a violation of 30122. Federal law does not prohibit a vehicle owner personally from making any safety equipment inoperative on his or her own vehicle, although the agency strongly discourages disabling any safety system. However, whether non-standard lighting equipment is allowable on vehicles in use is a matter of State law. Based upon the above analysis and the description offered by you of the subject lighting system, under FMVSS No. 108, a manufacturer of new transit buses would not be permitted to install destination signs on the front of a vehicle that illuminate in red, green, or blue, because the lighting devices in those colors could impair the effectiveness of other frontal lighting equipment required under FMVSS No. 108. If you have further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel Enclosure ref.108 d.10/19/06 |
2006 |
ID: nht68-4.16OpenDATE: 09/16/68 FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA TO: Messrs. O'Donohue and O'Connor TITLE: FMVSR INTERPRETATION TEXT: In your letter of August 15 you ask for a copy of regulations issued under the National Traffic and Motor Vehicle Safety Act of 1966 which might apply to "a small refuse-carrying three-wheeled vehicle" which is being designed by one of your clients. I enclose a copy of all Federal Motor Vehicle Safety Standards which have been issued to date. You will note in 23 C.F.R. @ 255.3(b) that the definitions of "truck" and "motorcycle" or "motor driven cycle" appear to apply to the vehicle you have described. In order to make a definite classification we need more information such as 'a photograph of the vehicle and a technical specification sheet'. However, if the vehicle is classified as a "truck", 23 C.F.R. @ 255.7(a) provides that the Federal Standards will not apply if its curb weight is 1,000 pounds or less. If the vehicle is classified as a "motorcycle" or "motor driven cycle", Federal Standard No. 108 effective January 1, 1969, will be the only Standard applicable to this category of vehicle. If there is any further assistance I can give you I shall be happy to do so. O'DONOHOE AND O'CONNOR August 15, 1968 National Highway Safety Bureau It is our understanding that under the President's Executive Order of June 6, 1967, your Bureau is charged with the carrying out of the principles of the Highway Safety Act. This firm represents a small local corporation which is engaged in the design for marketing of a small refuse-carrying three-wheeled vehicle, to be primarily used in combination with a larger packer truck. Could you please forward to the undersigned copies of such bulletins or regulations as you have promulgaged with reference to required safety features in this particular type of vehicle. The vehicle will be three wheeled, operate with hydrostatic drive, and will have a dump box at the front. As stated above, it's main purpose will be to pick up from trash cans in alley ways and up driveways and then to deposit its load when full in the larger packer truck. We will be glad to supply added details for your use in determining what regulations would be applicable;but frankly, right now, having just read the bare bones of the statute, I am at a loss to know what you will need to proceed. We would appreciate it if you would send us such materials as you have on hand. James E. O'Donohoe |
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ID: 86-2.12OpenTYPE: INTERPRETATION-NHTSA DATE: 04/03/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: The Honorable Quentin N. Burdick TITLE: FMVSS INTERPRETATION TEXT:
The Honorable Quentin N. Burdick United States Senate Washington, D.C. 20510
Dear Senator Burdick:
Thank You for Your letter enclosing correspondence from your constituent, Ms. Lorraine Holgerson concerning requirements for identifying school buses. Your letter has been referred to my office for reply since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.
Ms. Holgerson is concerned that yellow school buses in North Dakota lack identifying features which notify following motorists that the bus is a school bus. Your constituent suggests Federal law address this problem by setting school bus identification requirements for features such as "School Bus" signs, or distinctive lights. I appreciate this opportunity to respond to Ms. Holgerson's concern. would like to begin by explaining that NHTSA has two sets of regulations for school buses that contain special requirements facilitating the recognition of those vehicles by motorists. The first set, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966, includes the motor vehicle safety standards applying to the manufacture and sale of new school buses. The second set of regulations, issued under the Highway Safety Act of 1966, are the highway safety program standards applicable to Federal funding of states' highway safety programs. One of the motor vehicle safety standards applying to school buses issued under the Vehicle Safety Act is Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. This standard requires school bus warning lamps on the rear of all new school buses. The presence of the lighting system alerts other motorists that the vehicle is a school bus, and activation of the lights warns motorists around the vehicle that school children are boarding or leaving the bus. Each school bus manufactured in or imported to this country must be equipped with the distinctive warning lamp system.
The additional identifying features that your constituent recommends for school buses have been included in the highway safety program standard we issued for pupil transportation safety (Highway Safety Program Standard No. 17). I have enclosed a copy of this standard for your information.
Standard No. 17 recommends that states require additional features for school buses such as prominent "School Bus" signs and the familiar yellow paint and black trim for the bus body, to distinguish them from other types of vehicles. Requirements for school bus identification are regularly included in states' highway safety programs to facilitate safe transportation of school children, and some or all of the recommendations of Standard No. 17 have been adopted by most of the states.
While we urge states to adopt a strong pupil transportation program consistent with Standard No. 17's guidelines, the effect of the standard on school buses operating in North Dakota is a matter for the State to decide. State officials are given discretion in adopting Standard No. 17 and may specify requirements for school bus operation that are appropriate for their particular highway safety needs. Ms. Holgerson might want to express her concerns and suggestions to North Dakota state officials, since they have the authority to set requirements for "School Bus" signs and other identifying features of school buses.
We appreciate Ms. Holgerson's concern for school bus safety. If you or your constituent have any further questions, please do not hesitate to contact us.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosure
The Honorable Quentin N. Burdick United States Senate Washington, D.C. 20510
Dear Senator Burdick:
Thank you for your letter forwarding correspondence from your constituent, Ms. Lorraine Holgerson..
I have transmitted your inquiry to the appropriate Departmental officials who are familiar with this matter and they will respond to you directly.
I appreciate your contacting me and hope you will not hesitate to call if I can be of any further assistance.
Sincerely,
David P. Sloane Director, Office of Congressional Affairs February 27, 1986
Mr. David Sloane Director Office of Congressional Relations Department of Transportation 400 - 7th Street S. W. Washington, D. C. 20590
Dear Mr. Sloane:
Enclosed is a letter I have recently received from Lorraine Holgerson regarding her concern about the lack of appropriate reflectors on the back of North Dakota school buses. I would appreciate your Looking into the matter Ms. Holgerson has described and responding to my office with your findings. Thank you for your attention to this matter.
With kind regards, I am
Sincerely,
Quentin N. Burdick QNB:mvj Honorable Senator Burdick:
Dear Mr. Burdick,
Could it be possible that a bill be passed to make North Dakota school buses more visible from the back?
School buses now have two directional lights back there, and a row of small lights across the top. This is really not very much on that large background of yellow. Even the words "School bus" in black or reflective letterings should help.
Some truckers that drive the big rigs have lights all around the top of their cabs, and even a row of lights around the trailer. Anything that could be done to make the school buses safer would be greatly appreciated.
Thank you
Lorraine Holgerson |
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ID: 13193.drnOpen Mr. Jir Misk Dear Mr. Misk: This responds to your request for an interpretation of Area "A" to be wiped on motor vehicle windshields, as specified in Federal Motor Vehicle Safety Standards (FMVSS) 103, Windshield defrosting and defogging systems, and 104, Windshield wiping and washing systems. Your question is answered below. Your letter states your understanding of two ways in which Area A is to be measured, and asks which of the two is correct:
Statement One is correct. Area A is that portion of the total area bounded by the angles in Tables I through IV of Standard No. 104 that is also within a perimeter 25 mm within the daylight opening of the windshield frame. It is not necessary that the windshield be large enough to contain the whole area bounded by the angles (of which 16 to 18 is the left border) as indicated by Statement Two. S.4.1.2 of Standard No. 104 states the following:
Area A of the windshield is described at S3.1 of SAE Standard J903a. S3.1 states:
S3.1's description means that Area A is not a fixed, predetermined area for all windshields, but is an area that varies from windshield to windshield. The variables are the angle of measurement and the width of the car. S4.1.2 of Standard No. 104 adds another variable by describing Area A as within the area bounded by a perimeter line on the glazing surface 25 millimeters from the edge of the daylight opening. Furthermore, not all of Area A must be wiped. In Standard No. 104, Tables I, II, III, and IV all specify that after the test is conducted, a minimum of 80% of Area A must be wiped. Please note that since Standard No. 103 references Standard No. 104 in specifying Area A as the applicable cleared area, the above description of Area A also applies to Standard No. 103. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Our FAX number is (202) 366-3820. Sincerely, |
1997 |
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.