ID: 001389Klasing.drn

Tony Klasing, Manager
Vehicle Inspection Unit
Division of Traffic Safety
Illinois Department of Transportation
3215 Executive Park Drive
P. O. Box 19212
Springfield, IL 62794-9212

Dear Mr. Klasing:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 217, Bus emergency exits and window retention and release. Specifically, you wish to know whether in test procedures for school buses specified at S5.4.2.1(a)(1) of the standard, a parallelepiped is used or a template. The answer is the agency uses a parallelepiped, as specified in the standard, rather than simply measuring from the rear of the seat back to the exit door.

As specified at S5.4.2.1(a), the rear emergency exit door must be manually extendable by a single person to a position that permits "an opening large enough to permit unobstructed passage of a rectangular parallelepiped 114 centimeters high, 61 centimeters wide, and 30 centimeters deep" when "keeping the 114 centimeter dimension vertical, the 61 centimeter dimension parallel to the opening, and the lower surface in contact with the floor of the bus at all times."[1]Contrary to what may be your understanding, the agency has not "approved" the use of a template that tapers at the top.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:217
d.2/6/03





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[1] In some school buses, the rear of the bus may curve inward, towards the passenger compartment. In such cases, in testing, although the bottom of the parallelepiped is in contact with the floor of the bus at all times, the top part of the parallelepiped may extend outside of the bus. When it conducts its school bus compliance testing for the rear emergency exit door, NHTSA would deem the school bus to meet S5.4.2.1(a)(1) of Standard No. 217 as long as the bottom of the specified parallelepiped is in contact with the floor of the bus at all times.

ID: 3039yy

Mr. Michael L. Harmon
President
Classic Interiors
30244-2 County Road 12 West
Elkhart, IN 46514

Dear Mr. Harmon:

This responds to your letter asking whether Standard No. 213, Child Restraint Systems, permits the installation of a built-in child restraint system (i.e., a child restraint system that is an integral part of the vehicle) in a multipurpose passenger vehicle (MPV), and if so, what requirements apply.

As discussed below, a child restraint system built into an MPV would fall within the definition of "child restraint system" in Standard No. 213 and would therefore have to comply with all the provisions of the standard that are generally applicable to child restraint systems. Since such a restraint would not be portable, it would not have to meet any requirement that is, by its own terms, or those of the compliance test procedure for that requirement, specifically applicable to "add-on child restraint systems" only. Since it would be built into an MPV instead of a passenger car, it would not have to meet any requirement that is, for the same reasons, specifically applicable to "built-in child restraint systems" only.

The following sections of Standard No. 213 contain requirements that would apply to a child restraint built into an MPV: S5.2.1 (head support surface), S5.2.2 (torso impact protection), S5.2.4 (protrusion limitation), S5.4 (belts, buckles and webbing), and S5.7 (flammability). The principle requirements of the standard that would not apply are those in S5.l.l relating to dynamic performance.

In view of the importance of the dynamic performance requirements for ensuring the safety of child restraint systems, we intend to begin rulemaking to apply those requirements to all built-in systems, not just to those installed in passenger cars. In the meantime, we suggest that manufacturers of such systems for MPVs carefully consider whether the systems provide protection comparable to that provided by built-in child restraint systems in passenger cars. You should also be aware that the National Traffic and Motor Vehicle Safety Act (l5 U.S.C. 1381-l431) imposes responsibilities on manufacturers of motor vehicles and motor vehicle equipment regarding safety-related defects. Manufacturers are responsible for ensuring that the vehicles and equipment they manufacture are free from safety-related defects and can perform their intended function safely. If the manufacturer or the agency determines that a safety-related defect (or noncompliance with an FMVSS) exists, the manufacturer is obligated under 151 et seq. of the Act to notify purchasers of its product and remedy the problem without charge. Manufacturers who fail to provide notification of or remedy for a defect or noncompliance may be subject to a civil penalty of up to $1,000 per violation.

Legal Analysis

Standard No. 2l3 applies to child restraint systems for use in motor vehicles and aircraft. See section S3. The term "child restraint system" is defined as "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." See section S4. A child restraint system that is an integral part of an MPV would come within this definition.

Some of Standard No. 2l3's requirements apply generally to "child restraint systems," i.e., without regard to whether a child restraint system is built-in or add-on or whether, if it is built-in, it is installed in a car or other type of vehicle. Since a child restraint system which is an integral part of an MPV comes within the definition of "child restraint system," it is required to meet all such requirements unless excepted. The following sections of Standard 213 contain requirements which apply generally to "child restraint systems": S5.2.1 (head support surface), S5.2.2 (torso impact protection), S5.2.4 (protrusion limitation), S5.4 (belts, buckles and webbing), and S5.7 (flammability).

In a number of instances, however, particularly with respect to dynamic performance, Standard No. 2l3 either specifies separate requirements for "add-on child restraint systems" and "built-in child restraint systems," or provides a test procedure for these two types of child restraint systems only. The standard defines "add-on child restraint system" without respect to the type of vehicle to which it might be added, i.e., as "any portable child restraint system." The term "built-in child restraint system" is defined more restrictively, as "any child restraint system which is an integral part of a passenger car." (Emphasis added.) A child restraint system which is an integral part of an MPV does not come within either of these definitions, since such a restraint is neither portable nor a part of a passenger car. Therefore, Standard No. 2l3's requirements for "add-on child restraint systems" and "built-in child restraint systems," do not apply to a child restraint system which is an integral part of an MPV. Similarly, those requirements for which the standard specifies a test procedure for "add-on child restraint systems" and "built-in child restraint systems" only do not apply to a child restraint system which is an integral part of an MPV.

I hope this information is helpful. Please contact us if you have further questions.

Sincerely,

Paul Jackson Rice Chief Counsel /ref:213 d:6/l2/9l

ID: nht91-4.19

DATE: June 12, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Michael L. Harmon -- President, Classic Interiors

TITLE: None

ATTACHMT: Attached to letter dated 2-14-91 from Michael L. Harmon to Paul J. Rice (OCC 5721)

TEXT:

This responds to your letter asking whether Standard No. 213, Child Restraint Systems, permits the installation of a built-in child restraint system (i.e., a child restraint system that is an integral part of the vehicle) in a multipurpose passenger vehicle (MPV), and if so, what requirements apply.

As discussed below, a child restraint system built into an MPV would fall within the definition of "child restraint system" in Standard No. 213 and would therefore have to comply with all the provisions of the standard that are generally applicable to child restraint systems. Since such a restraint would not be portable, it would not have to meet any requirement that is, by its own terms, or those of the compliance test procedure for that requirement, specifically applicable to "add-on child restraint systems" only. Since it would be built into an MPV instead of a passenger car, it would not have to meet any requirement that is, for the same reasons, specifically applicable to "built-in child restraint systems" only.

The following sections of Standard No. 213 contain requirements that would apply to a child restraint built into an MPV: S5.2.1 (head support surface), S5.2.2 (torso impact protection), S5.2.4 (protrusion limitation), S5.4 (belts, buckles and webbing), and S5.7 (flammability). The principle requirements of the standard that would not apply are those in S5.1.1 relating to dynamic performance. In view of the importance of the dynamic performance requirements for ensuring the safety of child restraint systems, we intend to begin rulemaking to apply those requirements to all built-in systems, not just to those installed in passenger cars. In the meantime, we suggest that manufacturers of such systems for MPVs carefully consider whether the systems provide protection comparable to that provided by built-in child restraint systems in passenger cars.

You should also be aware that the National Traffic and Motor Vehicle Safety Act (15 U.S-C- 1381-1431) imposes responsibilities on manufacturers of motor vehicles and motor vehicle equipment regarding safety-related defects. Manufacturers are responsible for ensuring that the vehicles and equipment they manufacture are free from safety-related defects and can perform their intended function safely. If the manufacturer or the agency determines that a safety-related defect (or noncompliance with an FMVSS) exists, the manufacturer is obligated under S151 et seq. of the Act to notify purchasers of its product and remedy the problem without charge. Manufacturers who fail to provide notification of or remedy for a defect

or noncompliance may be subject to a civil penalty of up to $1,000 per violation.

LEGAL ANALYSIS

Standard No. 213 applies to child restraint systems for use in motor vehicles and aircraft. See section S3. The term "child restraint system" is defined as "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." See section S4. A child restraint system that is an integral part of an MPV would come within this definition.

Some of Standard No. 213's requirements apply generally to "child restraint systems," i.e., without regard to whether a child restraint system is built-in or add-on or whether, if it is built-in, it is installed in a car or other type of vehicle. Since a child restraint system which is an integral part of an MPV comes within the definition of "child restraint system," it is required to meet all such requirements unless excepted. The following sections of Standard 213 contain requirements which apply generally to "child restraint systems": S5.2.1 (head support surface), S5.2.2 (torso impact protection), S5.2.4 (protrusion limitation), S5.4 (belts, buckles and webbing), and S5.7 (flammability).

In a number of instances, however, particularly with respect to dynamic performance, Standard No. 213 either specifies separate requirements for "add-on child restraint systems" and "built-in child restraint systems," or provides a test procedure for these two types of child restraint systems only. The standard defines "add-on child restraint system" without respect to the type of vehicle to which it might be added, i.e., as "any portable child restraint system." The term "built-in child restraint system" is defined more restrictively, as "any child restraint system which is an integral part of a passenger car." (Emphasis added.) A child restraint system which is an integral part of an MPV does not come within either of these definitions, since such a restraint is neither portable nor a part of a passenger car. Therefore, Standard No. 213's requirements for "add-on child restraint systems" and "built-in child restraint systems," do not apply to a child restraint system which is an integral part of an MPV. Similarly, those requirements for which the standard specifies a test procedure for "add-on child restraint systems" and "built-in child restraint systems" only do not apply to a child restraint system which is an integral part of an MPV.

I hope this information is helpful. Please contact us if you have further questions.

ID: aiam3073

Dear Mr. Tydings: This responds to your July 20, 1979, letter asking a questio concerning Standard No. 217, *Bus Window Retention*. You ask whether paragraph S5.4.2.1(a) permits the parallelepiped device to compress the seat cushion when it is inserted in a school bus emergency exit in accordance with the test procedures of the standard. The answer to your question is no.; Paragraph S5.4.2.1(a) states that each rear emergency exit must provid 'an opening large enough to permit unobstructed passage of a rectangular parallelepiped device...' If the parallelepiped device compresses the seat cushion while being inserted in the bus, its passage is not unobstructed as required by the standard. Accordingly, the National Highway Traffic Safety Administration concludes that the device must enter the vehicle without compressing the seat cushion.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam5046

"Dear Mr. Allison: This responds to your letter of August 20, 199 requesting an interpretation of Standard No. 216, Roof Crush Resistance. Specifically, you requested 'an interpretation of 1) the proper application and orientation of the test device (S6.2 of this standard) and 2) the distance the test device is allowed to travel (paragraph S4 of this standard), when testing vehicles equipped with roof mounted accessories, such as roof racks (luggage racks).' You believe that there are three possible test conditions. The first condition would conduct the test either without the roof rack installed or with the roof rack removed, and with the test device positioned in accordance with S6.2. The second condition would conduct the test with the roof rack installed, and with the test device positioned using the point of contact established under test condition 1. The third condition would conduct the test with the roof rack installed, and with the test device positioned in accordance with S6.2 to the roof rack. You requested our interpretation as to which is the correct test condition. In addition, you asked if we determined that either test condition 2 or 3 was correct, could the amount of distance traveled before contact with the roof be added to the allowable distance of test device travel under S4. We would conduct our compliance testing for Standard No. 216 with roof mounted accessories such as roof racks removed (your test condition 1). We would do so because the purpose of the test is to measure the strength of the roof, not the strength of roof mounted accessories. Further, as you have noted, conducting the test with roof mounted accessories in place could influence the positioning of the test device. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam5047

"Dear Mr. Allison: This responds to your letter of August 20, 199 requesting an interpretation of Standard No. 216, Roof Crush Resistance. Specifically, you requested 'an interpretation of 1) the proper application and orientation of the test device (S6.2 of this standard) and 2) the distance the test device is allowed to travel (paragraph S4 of this standard), when testing vehicles equipped with roof mounted accessories, such as roof racks (luggage racks).' You believe that there are three possible test conditions. The first condition would conduct the test either without the roof rack installed or with the roof rack removed, and with the test device positioned in accordance with S6.2. The second condition would conduct the test with the roof rack installed, and with the test device positioned using the point of contact established under test condition 1. The third condition would conduct the test with the roof rack installed, and with the test device positioned in accordance with S6.2 to the roof rack. You requested our interpretation as to which is the correct test condition. In addition, you asked if we determined that either test condition 2 or 3 was correct, could the amount of distance traveled before contact with the roof be added to the allowable distance of test device travel under S4. We would conduct our compliance testing for Standard No. 216 with roof mounted accessories such as roof racks removed (your test condition 1). We would do so because the purpose of the test is to measure the strength of the roof, not the strength of roof mounted accessories. Further, as you have noted, conducting the test with roof mounted accessories in place could influence the positioning of the test device. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam5304

"Dear Ms. Caron: This responds to your letter asking about the safet of aftermarket belt positioning devices. The devices you ask about alter the positioning of vehicle lap and shoulder belts, for the advertised purposes of improving the fit of the belts on children and small adults. Although NHTSA understands your view that safety belts should be comfortable for the wearer, we have significant concerns about aftermarket belt positioning devices. The following discussion explains those concerns and the effect of our regulations on such products. By way of background information, the National Traffic and Motor Vehicle Safety Act (the Safety Act) gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. This agency does not have a safety standard that directly applies to belt positioning devices. Our safety standards for 'Occupant Crash Protection,' (Standard No. 208) and 'Seat Belt Assembly Anchorages' (Standard No. 210) apply to new, completed vehicles. In addition, our safety standard for 'Seat Belt Assemblies' (Standard No. 209) applies to new seat belt assemblies. Because a belt positioning device is neither installed as part of a completed vehicle nor as part of a seat belt assembly, none of these regulations apply to belt positioning devices. While none of these standards applies to a belt positioning device, the manufacturer of the product is subject to the requirements of the Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. To date, there have been no defect proceedings concerning these products. In addition, while it is unlikely that a belt positioning device would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, the Safety Act prohibits those businesses from installing the device if the installation 'rendered inoperative' compliance with any safety standard. Belt positioning devices raise safety concerns you should consider in deciding whether to use these products. These devices could be used in a way that significantly affects crash forces on the occupant. Standard No. 208 includes requirements that have the effect of ensuring that the lap and shoulder belts distribute the crash forces to the occupant's skeletal structure, a part of the body that can better withstand the forces. For example, Standard No. 208 requires the shoulder belt and the lap belt to intersect off of the abdominal area. A device that moved that intersection from the side to the middle of the abdomen could greatly increase the loading on the occupant's abdomen. An increase in abdominal loading could have serious safety implications for the wearer of the belt. There are other concerns about these devices. The realigning of the shoulder belt could increase the likelihood that the wearer would twist toward the middle of the vehicle in a crash, so that the person could be partially or completely unrestrained by the shoulder belt. In addition, if the device introduced excessive slack into the belt system, the occupant's head would be more likely to contact the vehicle interior. Also, slack in the belt system generally introduces higher crash forces, which increase the risk of injury. We urge you to consider these factors when deciding whether to use a belt positioning device, or the manner in which to use one. You also asked whether a 'travel vest' can be used with your two and a half year old son, in place of a child seat. The travel vest is a 'child restraint system' and is thus subject to our safety standard for child restraints (Standard No. 213). The manufacturer of the travel vest (which the standard refers to as a 'harness') is responsible for determining the conformance of the vest to the requirements of Standard No. 213, and certifying that the vest so conforms. This agency periodically tests products for compliance with Standard No. 213. When properly used, harnesses that comply with Standard No. 213 provide good protection in a crash, similar to that provided by child seats. You should always follow the manufacturer's instructions for using the child restraint system, including the specifications for the weight of the child for whom the restraint is recommended. I hope this information is helpful. If you have further questions, please feel free to contact Mary Versailles of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: 77-4.33

TYPE: INTERPRETATION-NHTSA

DATE: 11/10/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Satterlee, Mestayer & Freeman

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of August 31, 1977, to our Fort Worth, Texas office and October 7, 1977, telephone conversation with Robert Churella of my staff concerning the existence of any Federal motor vehicle standard that would require doors on garbage trucks.

There are no Federal motor vehicle safety standards that require vehicles to be equipped with doors. In fact, Motor Vehicle Safety Standard No. 206 (49 CFR 571.206), which regulates door locks and door retention components, specifically exempts from its application those motor vehicles manufactured for operation without doors.

The National Highway Traffic Safety Administration has, however, promulgated a standard requiring trucks manufactured after July 1, 1971, to be equipped with seat belts. This requirement would provide protection for an individual riding in a vehicle without a side door.

SINCERELY,

Request for Ruling on Rights of Accident Victim Described in Attached Letter

September 16, 1977

Regional Administrator National Highway Traffic Safety Administration

Joseph J. Levin, NOA-30 National Highway Traffic Safety Administration

The regional office has received the attached request for a DOT position statement concerning the described accident. I am therefore forwarding the attached request to your office for consideration.

E. Robert Anderson

ATTACH.

SATTERLEE, MESTAYER & FREEMAN

August 31, 1977

Dept. of Transportation National Highway Transportation Safety RE: Mary Johnson vs. Continental Insurance Company, et als Civil Action No. 77-2583 Our File #77-506

I represent Mary Johnson, concerning an accident which her son was involved in on or about June, 1977. Mrs. Johnson's son, Herman Johnson, was driving a garbage truck on a Louisiana highway, and was involved in an automobile accident, whereby he was ejected from the vehicle. The vehicle did not have any doors whatsoever on it.

I have written the United States Department of Labor, Occupational Safety and Health Administration, and have been informed by this agency, that the above occurance is not under OSHA jurisdiction. Since the accident occurred on a Louisiana highway, I am of the opinion that the Department of Transportation would have jurisdiction over any complaint which my client has.

I am requesting that you furnish to my office a Department of Transportation complaint pertaining to the above.

Thanking you for your time and cooperation, I remain

Charlotte A. Hayes

ID: nht72-3.38

DATE: 09/25/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 12, 1972, concerning the automatic adjustment of seat belts required by S7.1.1 of Standard No. 208.

The belt system that Renault is considering for use after August 15, 1973, employs a continuous length of webbing that runs from a floor-mounted emergency-locking retractor up through a metal ring mounted high on the B-pillar, then downward across the occupant's chest to the buckle, where it passes around a knurl bar and back across the occupant's lap to an outboard floor anchorage. Your question concerns the amount of friction that may be produced by the knurl bar before the lap belt would be considered to have lost the automatic adjustment capacity required by S7.1.1.

After examining the buckle enclosed with your letter, we have concluded that in its present (Illegible Word) the (Illegible Word) produced by the knurl bar is such that the belt would probably not adjust automatically as required by S7.1.1.

In evaluating belts of similar design, we have not attempted to quantify the amount of allowable buckle friction. The characteristic to be avoided is the tendency of the buckle to trap an excessive amount of webbing on the lap belt side of the buckle. This tendency is overcome if the friction in the buckle is low enough that the normal motion of the occupant against the shoulder belt cinches up the lap belt, or if the buckle slides down of its own weight while the assembly is stored on the B-pillar so that the next occupant must lengthen the lap belt as he fastens the buckle.

In the case of the Renault buckle, a person using the assembly after its use by a larger person would find the buckle in the position appropriate for the larger occupant. After buckling it, he would have a slack lap belt. It appears that the friction in the buckle is great enough that the occupant's normal motion would not tighten the lap belt and that he would have to adjust it manually in order to have it fit him properly. We do not consider this to be satisfactory.

If you have further questions, please advise us.

ID: aiam5083

"Dear Mr. McGuigan: This responds to your letter of September 29, 199 concerning certain new requirements of Federal Motor Vehicle Safety Standard No. 114, Theft Protection, which became effective on September 1, 1992. Your questions relate to S4.2.1 of the standard, which states: S4.2.1 Except as provided in S4.2.2(a) and (b), the key-locking system required by S4.2 in each vehicle which has an automatic transmission with a 'park' position shall prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. You argued that this provision should be interpreted to prevent key removal only when the transmission shift lever is in one of the available gear selector positioning detents other than 'park,' i.e., reverse, neutral, drive, first, second, and not when the lever is at various points between those detents. You stated that a compliance test involving positioning of the shift lever between gear positions would be 'inappropriate,' because you believe that it would be premised on an assumption that a substantive purpose of the amendment is to prevent shifting errors. You therefore argue that vehicles in which the key can be removed while the shift lever is between gear positions would not fail to comply with the amended standard. We cannot agree with your suggested interpretation, as it is inconsistent with the express language of S4.2.1. That section states that, with certain exceptions not at issue, the key-locking system must prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. Stated more simply, key removal must be prevented in all circumstances save those specified in S4.2.1. Neither the transmission nor the transmission shift lever is locked in 'park' when the lever is between the gear selector positioning detents. Therefore, under section S4.2.1, key removal must be prevented in that situation, unless the transmission/ transmission shift lever becomes locked in 'park' as a direct result of removing the key. Our interpretation is consistent with the agency's intent in promulgating S4.2.1. As discussed in several rulemaking notices, NHTSA amended Standard No. 114 to prevent vehicle rollaway caused by unattended children shifting the transmission lever in automatic transmission vehicles. If a driver were able to remove the key while the transmission or transmission shift lever was not locked in park, and if the transmission or transmission shift lever did not become locked in 'park' as a result of removing the key, a child might later shift the transmission lever, thereby causing a vehicle rollaway. For this reason, we continue to believe that this amendment to Standard No. 114 meets the need for motor vehicle safety. I note that while it may be true that NHTSA would not commence a rulemaking proceeding focused solely on preventing inadvertent vehicle movement arising out of transmission shift lever mispositioning, as reflected in the agency's June 1990 denial of the Barr petition, this does not mean that Standard No. 114, as construed above, does not achieve a valid and appropriate safety benefit. You asked about Standard No. 114 in connection with the key-locking systems of 1993 Escorts and Tracers. You stated that if attempts are made to remove the ignition key with the transmission shift lever in each of the available gear selector positioning detents, the key-locking systems of these vehicles prevent removal of the key except when the transmission shift lever is locked in the 'park' detent. You also stated, however, that if attempts are made to remove the ignition key with the transmission shift lever at various points between reverse and park, the key can be removed, for at least a large proportion of these vehicles, at certain points where the selector lever is 'held short of engaging the Park positioning detent.' We recognize that you believe that the chances of a vehicle rollaway occurring with your system would be very small. While you have made a number of arguments to support your contention, we note that we cannot consider that type of argument in interpreting Standard No. 114. As you know, under the National Traffic and Motor Vehicle Safety Act, NHTSA is required to issue safety standards that provide objective criteria. In interpreting a standard, we must follow those objective requirements, notwithstanding arguments regarding the safety significance of a particular vehicle design. If you believe that those arguments have merit, you may present them to the agency in other contexts, such as in a petition for determination of inconsequential noncompliance. I hope this information is helpful. Sincerely, Paul Jackson Rice Chief Counsel";