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: malone.ztvOpenDaniel P. Malone Dear Mr. Malone: This is in reply to your e-mail of June 20, 2003, to Taylor Vinson of this Office, asking about the early warning reporting (EWR) responsibilities of seat manufacturers that supply integrated child seat systems. Your question arises from a statement in the preamble to the EWR final rule, which remarked:
You have asked whether "this comment regarding integrated child seat systems eliminates any responsibility of seat manufacturers [under] EWR as a child restraint system manufacturer for those products." The answer is no. This comment relates to the reporting responsibilities of manufacturers of light vehicles. The proposed rule would have had these manufacturers reporting separately for integrated child restraint systems (Code 08) and for seats (Code 17) (see 66 FR at 66222). In the final rule, as the preamble indicated, reports of light vehicle manufacturers involving integrated child seat systems are to be included as a report for seats (Code 22). As a manufacturer of original equipment, a manufacturer of seats with integrated child seat systems remains subject to the reporting requirements of 49 CFR 579.27, which oblige it to report to NHTSA any claims or notices involving death that relate to its product. Your second question was "for purposes of EWR, does that comment clarify that integrated child seat systems are to be considered as 'seats' and not child restraint systems."The answer is yes. If you have further questions, you may phone Taylor Vinson at 202-366-5263. Sincerely, Jacqueline Glassman ref:579 |
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ID: malone_new.ztvOpenDaniel P. Malone Dear Mr. Malone: This is in reply to your e-mail of June 20, 2003, to Taylor Vinson of this Office, asking about the early warning reporting (EWR) responsibilities of seat manufacturers that supply integrated child seat systems. Your question arises from a statement in the preamble to the EWR final rule, which remarked:
You have asked whether "this comment regarding integrated child seat systems eliminates any responsibility of seat manufacturers [under] EWR as a child restraint system manufacturer for those products." The answer is no. This comment relates to the reporting responsibilities of manufacturers of light vehicles. The proposed rule would have had these manufacturers reporting separately for integrated child restraint systems (Code 08) and for seats (Code 17) (see 66 FR at 66222). In the final rule, as the preamble indicated, reports of light vehicle manufacturers involving integrated child seat systems are to be included as a report for seats (Code 22). As a manufacturer of original equipment, a manufacturer of seats with integrated child seat systems remains subject to the reporting requirements of 49 CFR 579.27, which oblige it to report to NHTSA any claims or notices involving death that relate to its product. Your second question was "for purposes of EWR, does that comment clarify that integrated child seat systems are to be considered as 'seats' and not child restraint systems."The answer is yes. If you have further questions, you may phone Taylor Vinson at 202-366-5263. Sincerely, Chief Counsel |
2003 |
ID: mansfieldOpen
Via Federal Express
Mr. Christopher C. Mansfield General Counsel Liberty Mutual Group 175 Berkeley Street Boston, MA 02117
Dear Mr. Mansfield:
We have received reports that certain insurance companies may be engaging in transactions that violate Federal odometer disclosure law with respect to vehicles damaged in Hurricane Sandy. Although we are not asserting that your company is engaging in such practices, we are writing to a number of auto insurance companies to remind them of the Federal odometer disclosure law requirements and ask them to review their practices regarding odometer disclosures. These letters do not accuse your company, or any other company, of violating the law.
We understand that when a flood-damaged vehicle is declared a total loss, the insurance company pays the insured the value of the vehicle, becomes the owner, and acquires control over the vehicle from the insured. However the reports we have received indicate that instead of completing the required odometer disclosure, some companies ask the insured to complete the odometer disclosure statement without listing the insurance company as the transferee. According to these reports, the insurance company will not sign the title, make an odometer disclosure, or transfer title. The insurance company then sells the vehicle at auction, keeps the proceeds from the auction, and provides the title with the odometer disclosure statement as signed by the insured to the auction buyer. The next person in the chain of title of the vehicle will be the buyer at auction. The insurance company will essentially be omitted from the chain of title.
In the circumstance described above, an insurance company is considered a transferee when it pays the insureds claim (in return it obtains ownership of the vehicle), and a transferor when it sells the vehicle at auction. See 49 C.F.R. 580.3. As a transferor, the insurance company is required to make certain disclosures.
Under federal odometer disclosure law, 49 U.S.C. 32705, a person transferring ownership of a motor vehicle shall give the transferee written disclosure of the cumulative mileage registered on the odometer. More specifically, under 49 C.F.R. 580.5, each transferor shall disclose the mileage to the transferee in writing on the title or on the document being used to reassign the title [t]his written disclosure must be signed by the transferor, including the printed name. The transferee must sign the disclosure statement, print his name, and return a copy to his transferor.
If you have any questions, please do not hesitate to contact Marie Choi of my staff at (202) 366-1738 or via email at marie.choi@dot.gov.
Sincerely,
O. Kevin Vincent Chief Counsel
d: 12/20/12
Identical letters sent to:
Mr. Dana Proulx General Counsel GEICO Corporation One Geico Plaza Washington, DC 20076
Mr. Charles E. Jarrett Chief Legal Officer The Progressive Corporation 300 North Commons Blvd., OHF 11 Mayfield Village, OH 44143
Mr. Christopher C. Mansfield General Counsel Liberty Mutual Group 175 Berkeley Street Boston, MA 02117
Ms. Patricia R. Hatler Chief Legal and Governance Officer Nationwide One Nationwide Plaza Columbus, OH 43215
Ms. Susan L. Lees General Counsel Allstate Insurance Company 3075 Sanders Road Northbrook, IL 60062
Mr. Garrett Paddor General Counsel Farmers New World Life Insurance Company 4680 Wilshire Blvd, 2nd Fl. Los Angeles, CA 90010 Mr. Steven A. Bennett General Counsel United Services Automobile Association (USAA) 9800 Fredericksburg Road San Antonio, TX 78288
Mr. Jeffrey W. Jackson General Counsel State Farm Mutual Automobile Insurance Company One State Farm Plaza Bloomington, IL 61710
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ID: markowskiOpenMr. Norbert P. Markowski Dear Mr. Markowski: This responds to your recent letter requesting the National Highway Traffic Safety Administration's assistance to enable you to seek alteration of your Model Year 2000 Buick LeSabre to accommodate your needs. You explain that you need a left side foot accelerator in order to assist your driving. You cannot drive safely with a right foot accelerator because your right leg is fused at the knee and ankle. You state that your right foot rests on the right accelerator and that, while driving, you do not dare move your right leg lest you unintentionally press on the right accelerator. In a telephone conversation with Dorothy Nakama of my staff, you stated that your LeSabre has already been modified to include a left side foot accelerator pedal. You ask us for written permission that would permit you to go to a dealership or other business to remove the right accelerator pedal. This letter should provide the relief you seek. We do not prohibit modifiers from removing the pedal, as long as the work is done without negating the safety of a required component or element of design. Section 30122(b) of Title 49 of the United States Code (the title under which Standard No. 124 was issued) provides in part that--
Our safety standards do not require that an accelerator pedal be provided on a motor vehicle, or that the accelerator pedal be placed to the right of the brake pedal. Since our standards do not require the accelerator pedal to be on the right, moving the pedal position from the right to the left would not "make inoperative" the compliance of your vehicle with Standard No. 124. However, Standard No. 124, Accelerator Control Systems, requires that a vehicle's throttle must return to the idle position when the driver removes the actuating force from the accelerator control or in the event of a severance or disconnection in the accelerator control system. Your LeSabre must meet this safety requirement with the accelerator pedal on the left. Further, after the right accelerator pedal has been removed from your LeSabre, I would strongly urge you to inform all potential drivers of your LeSabre that the accelerator pedal and the brake pedal in your vehicle are reversed from their usual positions. In addition, if you should decide to sell your LeSabre in the future, I would suggest that the right foot accelerator pedal is replaced before the vehicle is sold. Showing this letter to your dealer or repair business when you take your car to have the right accelerator pedal removed should provide the assurance they seek to perform the modification. If the dealer or repair business wishes to verify the authenticity of this letter, they may call the telephone number below. If you have any other questions, please contact Dorothy Nakama at this address or by phone at (202) 366-2992. Sincerely, |
1999 |
ID: matsumoto-2.ztvOpenMr. Todd Matsumoto Dear Mr. Matsumoto: This responds to your letter concerning your 1964 and 1968 "dune buggy" kit cars. You informed us that the "local government" requires you "to provide the state with a design plan certified by a professional engineer that meets all federal safety standards in order for my car to be legally registered." Subsequently, you faxed us a copy of a letter to you, dated June 30, 2003, from the State of Hawaiis Department of Transportation, which indicates that your vehicles are considered "reconstructed vehicles" under Hawaii law. You asked whether your cars have to meet any specific Federal motor vehicle safety standards (FMVSS or standards) or other regulations. I will address the applicability of Federal law, 49 U.S.C. Chapter 301, to this issue. This law authorizes the National Highway Traffic Safety Administration to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment. All new motor vehicles and items of motor vehicle equipment must meet the FMVSSs in effect on the date of manufacture. We have previously provided the following explanation [1] how our regulations apply to kit cars:
In order to be registered for use, a kit car must meet the requirements of the State of licensing. Assuming that the construction of a kit car does not involve the use of so many new parts as to make it a new motor vehicle, we do not consider it to be a new motor vehicle subject to the FMVSSs in effect on the date of completion of the kit car. Based on the information you provided with your letter and in telephone conversations with Taylor Vinson of my staff, it appears that this is the case with your 1964 and 1968 dune buggy kit cars. However, the States may regulate the reconstruction of vehicles. The letter you provided to us from the State of Hawaiis Department of Transportation indicates that it considers your vehicles to be "reconstructed vehicles" under Hawaii law, and subject to its requirements for the approval of reconstructed vehicles. If you have any questions, you may call Taylor Vinson again (202-366-5263). Sincerely, Jacqueline Glassman ref:571 |
2002 |
ID: Maxon9759OpenS.Lafferty, Manager, Engineering Dear Mr.Lafferty: This responds to your letter in which you raised several questions regarding Federal motor vehicle safety standard (FMVSS) No.403, Platform lift systems for motor vehicles.Your letter raised issues with the control illumination, attachment hardware, and interlock requirements of the standard.I have addressed each issue below. By way of background, the agency established FMVSS Nos.403 in order to protect individuals that are aided by canes, walkers, wheelchairs, scooters, and other mobility devices and rely on platform lifts to enter/exit a motor vehicle.FMVSS No.403 is an equipment standard that specifies minimum performance requirements for platform lifts designed for installation on motor vehicles.The agency also established the companion standard FMVSS No.404, Platform lift installations in motor vehicles, which specifies requirements for vehicles equipped with platform lifts. Illumination of Lift Controls S6.7.6.2 of FMVSS No.403 requires that platform lift controls on a public use lift must be illuminated according S5.3 of FMVSS No.101, Controls and displays.In part FMVSS No.101 requires that the illumination of controls must be adjustable to provide at least two levels of brightness, one of which is barely discernible to a driver who has adapted to dark ambient roadway conditions.The low level of illumination is to minimize the impact of the illumination on a drivers night vision. In your letter, you stated that the controls on the lifts manufactured by your company, Maxon, are not located in the driver compartment.As such, you stated that there is no need for a dual level of illumination as specified in FMVSS No.101. The illumination requirement in FMVSS No.403 is applicable to all controls, regardless of location.An amendment to this requirement would have to be accomplished through the agencys rulemaking procedure. Attachment Hardware S6.3.1 of FMVSS No.403 requires that a lift manufacturer provide all of the attachment hardware necessary to install a lift on a vehicle.In your letter you stated that some installations may require longer bolts than that provided or that bolts may be lost during installation.You asked if Maxon would be permitted to specify attachment hardware by "grade, size, plating etc and allow substitute hardware" in those instances. S6.13.1 requires a lift manufacturer to specify, either by make and model or by design elements, the vehicles on which the lift is designed to be installed.The attachment hardware provided must permit the installation of a lift on these vehicles.If a vehicle is listed under S6.13.1 that requires a longer bolt, then a longer bolt must be provided. With regard to hardware lost during the installation process, we recognize that lift installers may need to obtain replacement hardware.Nothing in the standard prohibits a lift manufacturer from providing the hardware specifications in conjunction with the actual hardware. Interlock requirements Your letter correctly states that under S6.10.2.2 of FMVSS No.403, an interlock must prevent operation of a platform lift from a stowed position until forward and rearward motion of a vehicle is inhibited.You then asked what is required if during lift operation there is a failure of the interlock: should lift operation cease or continue in the event of such a failure? FMVSS No.403 does not specify how a lift must operate in the event of an interlock failure.Therefore, it is up to the individual manufacturer to determine an appropriate default status. I hope you find this helpful.If you have any additional questions, please contact Mr.Chris Calamita of my staff at (202) 366-2992. Sincerely, Jacqueline Glassman ref:403#404 |
2005 |
ID: maxon_threshold7346OpenS. Lafferty, Manager, Engineering Dear Ms. Lafferty: This responds to you letter in which you asked about the threshold warning requirements under Federal Motor Vehicle Safety Standard (FMVSS) No. 403, Platform lift systems for motor vehicles. You stated that there is an apparent discrepancy between the threshold warning system requirement and the associated test procedure, and asked which takes precedent. As explained below, the specified test procedure for the threshold warning system requirement is consistent with that requirement. As part of FMVSS No. 403, the agency established a threshold warning signal requirement for platform lifts in part to minimize the risk of a lift user backing off a vehicle before a lift is properly positioned. S6.1 of FMVSS No. 403 requires an appropriate threshold warning signal to be activated when any portion of a passengers body or mobility aid occupies the platform threshold area defined in S4 of that standard, and the platform is more than 25 mm (1 inch) below the vehicle floor reference plane. A platform lift must meet this requirement when tested in accordance with S7.4 of the standard. In your letter you stated that it is possible to design a threshold warning system that "will pass a test that is performed as described in S7.4 and not completely fulfill the requirements of S6.1.3". You described a threshold warning system designed with an optical sensor at the interior boundary of the platform threshold area. You stated that such a system would activate the warning signal only when a passenger is crossing the boundary of the threshold at the same time as the platform is lower than 25 mm from the vehicle floor. You further stated that such a system would not activate a signal if a passenger were completely within the threshold area when the platform reached the specified distance from the vehicle floor. Your letter indicated that you believe that such a system would "pass" the test procedure, but not comply fully with the requirement. A system as you described would not comply with the requirements of S6.1.3 when tested as specified in S7.4. As stated above, S6.1 requires the appropriate warning signal to activate when tested in accordance with S7.4. S7.4.2 specifies that, with the platform lift at the vehicle floor loading position:
Thus, S7.4.2 specifies placing the front wheel of the test device on any portion of the threshold area. As explained in 49 CFR 571.4, the use of the term "any" in connection with a range of values or set of items means generally, "the totality of the items or values, any one of which may be selected by the [agency] for testing". Accordingly, the procedure specified in S7.4.2 includes placement of the front wheel that could result in the entire test device being within the threshold area prior to the platform being lowered. This also includes placement that results in a portion of the test device being on the platform. Given the discussion above, a system such as you described would not comply when tested under S7.4.2. As such, there is no discrepancy between the requirement of S6.1.3 and the test procedure specified in S7.4. If you have any additional questions, please contact Mr. Chris Calamita of my staff at (202) 366-0536. Sincerely, Stephen P. Wood ref:403#404 |
2005 |
ID: 86-5.25OpenTYPE: INTERPRETATION-NHTSA DATE: 09/29/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Mr. Rohit Vaidya TITLE: FMVSS INTERPRETATION TEXT: This responds to your April 30, 1986 letter concerning Safety Standard No. 213, Child Restraint Systems, and your planned built-in child seat. You asked for information concerning all safety standards that would be applicable to the seat and concerning a pending petition for amending Standard No. 213 to permit the installation of built-in child seats in new motor vehicles. I regret the delay in our response. Standard No. 213 is the only standard which this agency has issued concerning child restraint systems. It was drafted at a time when add-on or portable systems were the only type of child restraint systems. Accordingly, the requirements of the standard are oriented toward that type of system. However, the agency has granted a petition to broaden the standard to permit the installation of built-in child restraint systems. We expect to issue a proposal regarding this matter later this year. Copies of the standard and the petition are enclosed. As a new manufacturer of motor vehicle equipment, you should know that a manufacturer has a variety of responsibilities in addition to certifying compliance with all applicable safety standards. Manufacturers have the responsibility to conduct notification and remedy campaigns for safety-related defects or noncompliances with standards in their products. If a child restraint system fails to comply with Standard No. 213 or contains a safety-related defect, the manufacturer may elect to either (1) repair the child restraint so that the defect or noncompliance is removed; or (2) replace the child restraint with an identical or reasonably equivalent restraint which does not have the defect or noncompliance. Whichever of these options is chosen, the child restraint manufacturer must bear the expense for the remedy. Installation of your product in a used vehicle would also be affected by the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) of the Motor Vehicle Safety Act prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from "rendering inoperative" in whole or in part, any device or element of design installed in a motor vehicle in compliance with an applicable safety standard. Such a rendering inoperative could occur, for example, if the installer of a built-in child safety seat removed the original vehicle seat, installed a replacement vehicle seat containing the built-in child safety seat, but did not ensure that the seat belt anchorages for adult seating positions in the replacement rear seat continued to meet the location and strength requirements of Standard No. 210, Seat Belt Assembly Anchorages. A rendering inoperative could also occur if the installer did not ensure that a replacement vehicle seat continued to meet the strength requirements of Standard No. 207, Seating Systems, to minimize the possibility of failure by forces acting on that seat as a result of vehicle impact. Section 108(a)(2)(A) does not establish any limitations on an individual vehicle owner's ability to alter his or her own vehicle. Under Federal law, individual vehicle owners can themselves install any product they want on their vehicles, regardless of whether that product would render inoperative the compliance of the vehicle's seats or seat belt assembly anchorages with the requirements of Standards Nos. 207 or 210. However, the agency encourages vehicle owners not to install products which could lessen the occupant protection afforded by the original seats or safety belt assembly anchorages and thus adversely affect safety. For further information concerning these responsibilities, please consult the enclosed information sheet for new manufacturers. ENCLS(3) OCC 0617 Erika Jones Chief Counsel National Highway Traffic Safety Administration April 30, 1986 Dear Madam, This letter is in reference to the Federal Regulations regarding automobile child safety-seats - the Federal Motor Vehicle Safety Standard # 213. I am an inventor and I expect to be receiving a Letters Patent from the US Patent & Trademark Office for a child safety seat that is designed to be an integral part of a vehicle. I would be very grateful if you could send me a list of all current applicable test standards for automobile child safety-seats (including FMVSS #213, above). Furthermore, I understand the above referenced standard #213 is under review because of a petition that has been submitted to your office to broaden the scope of the regulation. I also would like to request: (1) information on the status of this review; and (2) a copy of the petition. Thank you very much. Rohit Vaidya cc: DR. C. CLARK, NHTSA MR. W. FONTAINE |
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ID: 86-5.26OpenTYPE: INTERPRETATION-NHTSA DATE: 09/29/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Mr. William C. Fisher TITLE: FMVSS INTERPRETATION TEXT:
Mr. William C. Fisher Product Engineer Parker Hannifin Corporation Parflex Division 1300 North Freedom Street Ravenna, OH 44266
Dear Mr. Fisher:
Thank you for your letter and enclosure regarding the labeling requirements for air brake hose assemblies set forth in Standard No. 106, Brake Hoses. I regret the delay in our response. We have referred the matter to our enforcement division to obtain more information about the assemblies you enclosed. We will return the samples of brake hose assemblies you sent, as you requested, when our examination is completed.
Sincerely,
Erika Z. Jones Chief Counsel
National Highway Traffic Safety Admin. Department of Transportation Office of Chief Council, NOA32 Room 5219 400 Seventh Street, S.W. Washington,D.C. 20590
Attention : Ms. Deirdre Hom, Attorney Advisor
Subject: D.O.T. Safety Standard 106 Section 7.2.3, Parts a and b - Identification of brake tubing assemblies by banding; Section 7.2.3.1 - End fitting marking to D.O.T. regulations.
Dear Deirdre:
Per our recent conversation, I have enclosed samples of the air brake end fittings which we contend are not in compliance with DOT 106 regulations. These assemblies were permanently ". . attached by crimping or swaging. ." a brass collar to the nylon tubing. This would, in our opinion, constitute a permanently attached fitting which is not reusable. In addition, no identification band was found on the coil assembly, and all end fittings lack D.O.T. identification markings.
I request that you review these samples and render a decision on the following questions:
1) Do these samples constitute permanently attached fittings under Section 7.2.3?
2) Is the attachment of a D.O.T. identification band required on brake hose assemblies made with this type of end fitting? 3) Is the end fitting identification marking in compliance with DOT 106 regulations?
I have enclosed for review, a current production sample of a Parker brake coil assembly that complies with DOT 106 regulations. I request that these samples be returned to me at the Parker Parflex Division upon completion of your study.
Ms. Deirdre Hom Page 2
Your swift attention to this matter will be appreciated. If you have any additional questions, please contact me at (216) 296-2871, ext. 259.
Very truly yours,
William C. Fisher Product Engineer
WCF:dm
Enclosures
1) Unidentified brake hose end fitting (Section Out) 2) Unidentified brake hose end fitting 3) Parker brake coil assembly
cc: William Hertel, Corporate Staff Engineer, Parker Hannifin Corp. Mark Kugelman, General Marketing Mgr., Parker Hannifin Corp. Robert Wiseman, Plant Mgr., Parker Hannifin Corp. |
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ID: 86-5.27OpenTYPE: INTERPRETATION-NHTSA DATE: 09/29/86 FROM: DALE T. FANZO TO: DIANE STEED -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 09/02/88 FROM ERIKA Z JONES TO GERALD PETERSON; REDBOOK A32, STANDARD 202; LETTER DATED 05/17/88 FROM GERALD PETERSON TO ERIKA JONES, OCC - 2052; LETTER DATED 08/28/87 FROM CARL C CLARK TO JERRY PETERSON TEXT: Dear Ms. Steed, "I hereby petition the National Highway Traffic Safety Administration to change the requirements of Standard #202 to include head restraints on vehicles other than passenger cars. I feel that the listing of these mini vans as multi purpose evades the issue of safety. I am enclosing this copy of my letter to Lee Iacocca and Chrysler's response. A brief summary of my accident follows: "On February 11, 1986 I was sitting at a red light on Route 22. A welding truck was in back of me and was struck by a milk tanker. The driver of the tanker dozed off at 50 mph, pusing the welding truck into me with me ending up 211 ft. from point of contact. "The result from the accident was I had 0 degree head movement for 9 weeks and a A/C separation of the left shoulder. After seeing 4 doctors and 6 therapists I am able to move my head to the left, however, only 60 degree to the right. It is 7 months now and I may have permanent damage to my ligaments in my neck. I have been told that a normal whiplash is caused when your head goes back and it bounces off the head restraint. However, my 3 seated Voyager SE had no head rest which caused my head to snap over the seat causing my injury. "Ms. Steed, my van is listed with the State as a station wagon and also with my insurance company. If you check to see how many SE Voyager and Caravans were purchased since 1984 you would find, I'm sure, 80%-90% with families. My purpose for this petition is to make sure that no other innocent party will have to go through what I have been going through. To make matters worse, I am a self employed individual who relys on sales by way of 40,000 miles a year to support my family." In summary, I would appreciate your time and consideration towards this petition. I can be reached at the above address, or by calling (412) 831-8514. ENCLS |
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.