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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

Displaying 1701 - 1710 of 16490

Interpretations	Date

ID: aiam3876 Open Mr. John S. Cucheran, Vice President, Design and Engineering, Jac Products, Inc., 1901 E. Ellsworth, Ann Arbor, MI 48104; Mr. John S. Cucheran Vice President Design and Engineering Jac Products Inc. 1901 E. Ellsworth Ann Arbor MI 48104; Dear Mr. Cucheran: This is in reply to your letter of November 30, 1984, to Mr. Vinson o this office asking for an interpretation of Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment.; Figure 10 of Standard No. 108 establishes the minimum desig photometrics for center high mounted stoplamps. The test procedure for this particular part of Standard No. 108 which is specified in SAE J186a, stipulates that the 'lamp axis shall be taken as the horizontal line through the light source.' However, I believe that you have misinterpreted the light cone that is involved. The pertinent light cone in this case has its vertex at the photometer and a cross section at the plane of the lamp which encompasses the lens areas. From Drawing A that you have provided, it appears that your rail would interfere with this light cone.; In order to determine if your rack interferes with the photometri requirements, the vehicle must be tested with the rack in position as installed on the vehicle. As the agency has noted before, the photometric requirements do not specify that the entire lens must be visible from each 5 degree down test point. Instead, they specify the intensity of light that must be visible from those points. Therefore, the requirement can be met with a lamp whose lens is partially obscured by a portion of the vehicle when viewed from some of the test points.; We hope that his interpretation is helpful to you. Sincerely, Frank Berndt, Chief Counsel
ID: aiam2866 Open Mr. Robert B. Kurre, Director of Engineering, Wayne Corporation, P. O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director of Engineering Wayne Corporation P. O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your recent letter asking whether Safety Standard No 208, Occupant Crash Protection, does require side- facing seats in multipurpose passenger vehicles to comply with one of the options under paragraph S4.2.2, since the side-facing seats in question would be considered designated seating positions. If a manufacturer chooses to install seat belts under one of the options of that paragraph, the seat belt assemblies must comply with Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages.; Safety Standard No. 210 does exempt side-facing seats from its strengt requirements, but all other requirements of the standard would be applicable. However, we strongly recommend that belt anchorages for side-facing seats be of at least equivalent strength to anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements. Side-facing seats were excepted from the strength requirements specified in the standard because the forces acting on side-facing seats are different from those acting on forward or rearward facing seats and the requirements and procedures were specifically developed for these latter seats.; Please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam2371 Open William K. Rosenberry, Esq., Attorney at Law, Parkway Central Plaza, 611 Ryan Plaza Dr., Suite 713, Arlington, TX 76011; William K. Rosenberry Esq. Attorney at Law Parkway Central Plaza 611 Ryan Plaza Dr. Suite 713 Arlington TX 76011; Dear Mr. Rosenberry: This is in reply to your letter of July 14, 1976, to George Shifflet of the Office of Standards Enforcement, on behalf of a client who intends to install a different type of seat, carpeting, and headliner in a pick-up truck, which would then be sold to the general public. You asked whether a fabric supplier must test each fabric lot for flammability before certification to Motor Vehicle Safety Standard No. 302 can be given, and whether your client 'may rely on the warranty of a fabric manufacturer that the fabric sold meets the requirements ' of Standard No. 302.; You are correct in your understanding that the provisions of th National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq) apply to your client. His basic responsibility is to ensure that the vehicles he modifies are in compliance with the Federal standards when delivered to dealers for sale to the public. (15 U.S.C. 1397(a)(1)(A)) A temporary noncompliance during modifications is permissible if the vehicle is not used on the public roads while noncompliant (15 U.S.C. 1397(a)(2)(A)). Standards which would appear to be affected by your client's modifications include: Standard No. 207 Seating Systems, No. 208 Occupant Crash Protection, No. 210 Seat Belt Assembly Anchorages and No. 302 Flammability of Interior Materials.; As a person who alters a certified vehicle other than by the additio of readily detachable (sic) components, your client is also required to attach his own certification of compliance to each modified truck (49 CFR 567.7). Should a noncompliance be discovered as a result of an alterer's modification, the alterer would be liable for a civil penalty unless he could establish that he did not have actual knowledge of the noncompliance, and that he did not have reason to know in the exercise of due care that the vehicle did not comply (15 U.S.C. 1397(b)(2)).; With respect to Standard No. 302, there is no requirement that a fabri supplier 'test each fabric lot for flammability before certification.' In point of fact, 49 CFR 571.302 Motor Vehicle Safety Standard No. 302 does not apply to suppliers but only to vehicle manufacturers (or alterers) and it is they who are required to certify compliance with Standard No. 302. Generally, at a minimum, a vehicle manufacturer will require by contract with the supplier that the fabric meets Standard No. 302. In the exercise of 'due care' the manufacturer may wish to examine the basis for the supplier's assurance of compliance, and to require periodic testing of the fabric being supplied him. Since there is no requirement that each fabric lot be tested, such testing as is conducted should be sufficient to demonstrate in the event of a noncompliance that the vehicle manufacturer has exercised due care. As to whether your client may rely on the 'warranty' of his supplier, it has been our experience that simple reliance is insufficient to establish a 'due care' defense. That manufacturer should examine the supplier's test results to insure that the margin of compliance of the test fabric is great enough that production variables do not result in noncompliance. Some manufacturers even conduct their own test independent of the supplier.; Your client would also be responsible for conducting a notification an remedy campaign (15 U.S.C. 1411 et seq) if a noncompliance or safety-related defect occurs in the truck as a result of the alterations.; I enclose copies of the Act, 49 CFR Part 567, and Standards Nos. 207 208, 210, and 302 for your information.; Yours truly, Frank Berndt, Acting Chief Counsel
ID: aiam2369 Open AIRMAIL, William K. Rosenberry, Esq., Attorney at Law, Parkway Central Plaza, 611 Ryan Plaza Dr., Suite 713, Arlington, TX, 76011; AIRMAIL William K. Rosenberry Esq. Attorney at Law Parkway Central Plaza 611 Ryan Plaza Dr. Suite 713 Arlington TX 76011; Dear Mr. Rosenberry: This is in reply to your letter of July 14, 1976, to George Shifflet of the Office of Standards Enforcement, on behalf of a client who intends to install a different type of seat, carpeting, and headliner in a pick-up truck, which would then be sold to the general public. You asked whether a fabric supplier must test each fabric lot for flammability before certification to Motor Vehicle Safety Standard No. 302 can be given, and whether your client 'may rely on the warranty of a fabric manufacturer that the fabric sold meets the requirements' of Standard No. 302.; You are correct in your understanding that the provisions of th National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq) apply to your client. His basic responsibility is to ensure that the vehicles he modifies are in compliance with the Federal standards when delivered to dealers for sale to the public. (15 U.S.C. 1397(a)(1)(A)) A temporary noncompliance during modifications is permissible if the vehicle is not used on the public roads while noncompliant (15 U.S.C. 1397 (a)(2)(A)). Standards which would appear to be affected by your client's modifications include: Standard No. 207 Seating Systems, No. 208 Occupant Crash Protection, No. 210 Seat Belt Assembly Anchorages and No. 302 Flammability of Interior Materials.; As a person who alters a certified vehicle other than by the additio of readily detachable components, your client is also required to attach his own certification of compliance to each modified truck (49 CFR 567.7). Should a noncompliance be discovered as a result of an alterer's modification, the alterer would be liable for a civil penalty unless he could establish that he did not have actual knowledge of the noncompliance, and that he did not have reason to know in the exercise of due care that the vehicle did not comply (15 U.S.C. 1397(b)(2)).; With respect to Standard No. 302, there is no requirement that a fabri supplies 'test each fabric lot for flammability before certification.' In point of fact, 49 CFR 571.302 Motor Vehicle Safety Standard No. 302 does not apply to suppliers but only to vehicle manufacturers (or alterers) and it is they who are required to certify compliance with Standard No. 302. Generally, at a minimum, a vehicle manufacturer will require by contract with the supplier that the fabric meets Standard No. 302. In the exercise of 'due care' the manufacturer may wish to examine the basis for the supplier's assurance of compliance, and to require periodic testing of the fabric being supplied him. Since there is no requirement that each fabric lot be tested, such testing as is conducted should be sufficient to demonstrate in the event of a noncompliance that the vehicle manufacturer has exercised due care. As to whether your client may rely on the 'warranty' of his supplier, it has been our experience that simple reliance is insufficient to establish a 'due care' defense. That manufacturer should examine the supplier's test results to insure that the margin of compliance of the test fabric is great enough that production variables do not result in noncompliance. Some manufacturers even conduct their own tests independent of the supplier.; Your client would also be responsible for conducting a notification an remedy campaign (15 U.S.C. 1411 et seq) if a noncompliance of safety-related defect occurs in the truck as a result of the alterations.; I enclose copies of the Act, 49 CFR Part 567, and Standards Nos. 207 208, 210, and 302 for your information.; Yours truly, Frank Berndt, Acting Chief Counsel
ID: aiam0532 Open Mr. Rozie M. Turner, Engineering Department, Hackney Bros. Body Company, P. O. Box 920, Wilson, NC 27893; Mr. Rozie M. Turner Engineering Department Hackney Bros. Body Company P. O. Box 920 Wilson NC 27893; Dear Mr. Turner: This is in reply to your letter of December 6, 1971, in which yo requested our opinion on the application of Standard No. 207 to swivel type pedestal seats.; Your problem arises from the method specified in S5.1.1 for th application of the force required by S4.2(a) of 20 times the weight of the seat. Although your letter does not state the problem directly, it appears that when a forward force is applied from behind the seat, as shown in the figures accompanying S5.1.1, the seat will tend to swivel. Your solution is to attach a T-shaped structure to the seat and to apply the force to the leg of the T forward of the swivel point.; The initial question raised by your letter is whether a seat tha swivels under the application of a force through its back as shown in Figure 1, will be considered to fail to withstand the force and thereby fail the standard.; On the basis of our present information, we cannot say that such swiveling action would result in a failure of the standard. The engineering staff has expressed uncertainty as to the effects on the occupant if the seat swivels in a side or angular crash, but they are not prepared to say that it would present a hazard. Since the swiveling itself is not a failure, the remaining question is one of test procedure. Our opinion is that the procedure you describe, using a T shaped structure, appears to be an acceptable means of applying the test force to the seat.; Sincerely, Richard B. Dyson, Assistant Chief Counsel
ID: aiam3845 Open Mr. Donald M. Schwentker, Schnader, Harrison, Segal & Lewis, Suite 1100, 900 Seventeenth Street, N.W., Washington, D.C. 20006; Mr. Donald M. Schwentker Schnader Harrison Segal & Lewis Suite 1100 900 Seventeenth Street N.W. Washington D.C. 20006; Dear Mr. Schwentker: This responds to your letter of May 9, 1984, concerning the applicatio of Standard No. 208, Occupant Crash Protection, and Standard No. 209, Seat Belt Assemblies, to an emergency locking retractor designed by one of your clients. The following discussion addresses the application of those standards to the retractor.; You explained that the purpose of the new emergency locking retracto (ELR) is to facilitate the securing of a child restraint in a vehicle. The ELR would only be installed in forward-facing passenger seating positions. The new ELR is designed so if the belt is pulled all the way out of the retractor, the ELR will convert into an automatic locking retractor (ALR). Once all but 1393-1493 mm of the belt retracts, the retractor will revert automatically to the ELR mode.; You further explained that the continuous loop lap and upper torso bel used with this retractor is 380 mm longer than the belt system provided for the driver's seating position. You explained that the extra 380 mm of belt webbing is meant 'to permit normal occupant movement without inadvertent actuation of the ALR mode while still rendering it convenient for manual extension when the ALR mode is desired for child restraint use.'; You specifically asked whether the retractor designed by your clien would be considered an ELR for the purposes of S7.1.1 of Standard No. 208. In addition, you asked about the retractor durability tests of S5.2(k) of Standard No. 209. As a part of that test, a retractor is subjected to '45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension.' You asked whether, for the purposes of the section 5.2(k) test, the length of the driver's belt, which is 380 mm shorter than the passenger's belt, could be used to determine what constitutes 100 percent extension of the belt. You alternatively asked whether the test could be stopped before complete extension of the passenger belt.; As we understand your client's seat belt assembly, the amount o webbing in the driver's side assembly complies to the adjustment requirements of section 4.1(kg) of Standard No. 209. The 380 mm's of extra webbing that is included in the passenger's seat belt assembly has been voluntarily added as a precaution to reduce the possibility of an occupant inadvertently actuating the ALR mode of the retractor. Based on the information you have provided, it appears that in normal operation by occupants covered by the adjustment requirements of Standard No. 209 the retractor functions exclusively as an ELR and thus can be used to meet the requirements of S7.1.1 of Standard No. 208. The agency views the 380 mm's of extra webbing as a voluntary addition not required by the standard. Therefore, for the purpose of section 5.2(k) of Standard No. 209, the agency will use the length of the driver's belt to determine what constitutes full extension of the webbing.; Sincerely, Frank Berndt, Chief Counsel.
ID: aiam3716 Open Mr. Binichi Doi, NSK Representative Office, 5400 S. State Street, Ann Arbor, MI 48104; Mr. Binichi Doi NSK Representative Office 5400 S. State Street Ann Arbor MI 48104; Dear Mr. Doi: This responds to your letter asking whether a continuous loop seat bel system with a tension reliever ('window-shade device') on the upper torso section of the belt must have a one-way locking tongue.; Continuous seat belt systems are permissible under Safety Standard No 208 if certain conditions are met. Paragraph S7.1.1 of that standard requires adjustment of the lap belt portion of Type 2 belts 'by means of an emergency locking or automatic-locking retractor' and adjustment in most cases of the upper torso portion 'by means of an emergency-locking retractor.' The language permits single retractor, continuous loop systems if the single retractor does 'automatically adjust' the tension of the lap belt portion to prevent excessive slack. Because of the danger of submarining due to a slack lap belt, the agency has restricted the acceptability of continuous loop systems under S7.1.1 in two areas.; First, to conform to the requirements, the buckle of the assembly mus be designed by the manufacturer with a sufficiently low level of friction to qualify the lap portion as automatically adjusting. This means that when the belt is buckled by the vehicle occupant, the retractor must be capable of cinching the lap belt tightly around the occupant's pelvic area (regardless of where the buckle tongue is located along the belt webbing when the belt is fastened). The friction in the buckle tongue cannot be so high that the occupant must manually pull the belt webbing through the tongue to tighten the lap belt. Based on our viewing of your proposed belt system (presented by your representative in a May 25th meeting), it is our opinion that your system does not have a sufficiently low level of friction that it would automatically adjust the lap belt portion. It is impossible for us to judge how this system would perform when installed in a vehicle, however, since the angle of the buckle tongue at the time of fastening does affect its friction level. It is the manufacturer's responsibility to determine whether or not its belt design complies with the standard. The agency does not offer advance approval of any motor vehicle or piece of motor vehicle equipment. Further, the agency does not make determinations of compliance of a vehicle or item of equipment prior to the manufacturer's certification of that vehicle or equipment.; The second restriction in regard to continuous loop systems concern the use of manual and automatic tension relieving devices on the upper torso portion of the continuous loop. In past letters of interpretation, the agency has limited the use of tension relieving devices to the upper torso section of seat belts that have an individually adjustable lap belt. A system does not have an individually adjustable lap belt if slack which is introduced into the continuous loop by a 'window shade' device or 'comfort clip' is directly transferred to the lap belt. Thus, in answer to your specific question, yes, a continuous loop seat belt system with a tension reliever on the upper torso portion of the belt should have a one-way locking tongue or some other method of preventing slack from returning to the lap belt. The high friction in the buckle tongue of your belt design would likely prevent the return of belt slack to the lap belt. However, as pointed out above, this high friction would also likely prevent the lap belt from adjusting automatically. Granted, these are somewhat conflicting concerns and they do present a tremendous design challenge. However, the agency believes these are necessary requirements if manufacturers include tension-relieving devices in their continuous loop systems.; I hope this clarification will be of help to you in your design plans. Sincerely, Frank Berndt, Chief Counsel
ID: aiam2111 Open Mr. W.G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W.G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in response to your letter of September 23, 1975, in which yo inquire whether the emergency exit decal installations shown in photographs enclosed with your letter comply with paragraphs S5.5.1 and S5.5.2 of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Window Retention and Release.'; It appears from the photographs you provided that some of the emergenc exit markings may not comply with some of the requirements specified in FMVSS No. 217. Our specific comments are listed below:; 1. Figure 1 - The emergency exit marking for the rear door appears t meet the requirements. It is to be noted, however, that revised requirements for emergency exits on school buses have been proposed which may differ from the current requirements.; 2. Figures 2 and 3 - The emergency exit marking for the side push-ou windows does not appear to meet the requirements of S5.5.2. Both the seat back and the adjacent seated occupant partially obstruct the marking so it is not legible from the adjoining seat or the aisle location.; 3. Figure 4 - The emergency exit marking for the side door appears t meet the requirements.; 4. Figure 5 - The marking for the rear window emergency exit that i adjacent to a davenport type seat with unknown seating capacity appears to contain two release mechanisms (laterally spaced at each edge) and an identical marking for each latch mechanism. We cannot determine if occupants would obstruct these markings from standees if all positions in the davenport type seat were occupied.; We also question whether the instructions are complete because i cannot be determined if both latches must be released before the window can be pushed out.; 5. Figure 6 - The emergency exit marking for the transit sliding typ window appears to meet the requirements.; 6. Figure 7 - The center rear emergency door which contain instructions for unlatching the opening of the door in the form of an arrow only per the proposed amendment to FMVSS No. 217, Docket 75-3: Notice 1 does not meet the present requirements for emergency exit identification. The specific content of the emergency exit marking for school buses has not yet been finalized by this agency and we, therefore, cannot comment until a final rule on the proposal has been published in the Federal Register; 7. Figures 8 and 9 - The emergency exit marking for another transi sliding type window appears to meet the requirements.; It is emphasized that these comments are for your information only an are based on the contents of your photographs. This agency cannot make a final judgement concerning compliance of a bus from photographs of components. The determination of compliance or noncompliance with FMVSS No. 217 can be made only by the actual inspection and test of a complete vehicle.; I trust this information will be of assistance to you in regard to you inquiries.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam1352 Open Mr. W. G. Milby, Project Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your November 8, 1973, request for a interpretation of the warning signal requirements of Standard No. 121, Air brake systems.; S5.1.5 of that standard states: >>>A signal, other than a pressure gauge, that gives a continuou warning to a person in the normal driving position when the ignition is in the 'on' or 'run' position and the air pressure in the service reservoir system is below 60 psi. The signal shall be either visible within the driver's forward field of view, or both audible and visible.<<<; A warning that 'the air pressure in the service reservoir system i below 60 psi' is intended to mean that a warning device's sensor could be located in the system you described in your letter between the source of air pressure and the check valve(s) required by S5.2.1.5. As you pointed out, this location would sense pressure below 60 psi anywhere from the compressor through the entire service reservoir system. A single warning installed before the check valves in a split service brake system would fulfill the requirements of S5.1.5 as long as it is positioned to sense pressure below 60 psi in any part of the split service reservoir system.; Your interpretation of the signal requirements is correct. The signa must be both audible and visible, or it must be visible within the driver's forward field of view. A simple audible signal is insufficient, as is a simple visible signal which is not within the driver's forward field of view.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1919 Open Mr. Sumner Meiselman, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Sumner Meiselman Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Meiselman: This responds to the Truck Trailer Manufacturers Association March 28 1975, request that the National Highway Traffic Safety Administration (NHTSA) review its position that building a trailer from new materials in combination with the running rear of an existing trailer constitutes the manufacture of a new vehicle subject to applicable safety standards. You also request confirmation that modification of the barrel of a tank trailer to replace compartments or to add to its volume does not constitute manufacture of a new vehicle.; NHTSA has already reconsidered its interpretation of what constitute the manufacture of a new truck in cases where components from an existing vehicle are used. Based on the high value of the drive train components found in powered vehicles, NHTSA has proposed an amendment of Part 571 that would supplant its earlier interpretation that, to constitute repair, the chassis of the existing vehicle must as a minimum be used in the new vehicle. The proposed amendment would establish that, in the assembly of a truck, a new vehicle is manufactured for purposes of compliance with and certification to applicable safety standards, unless the engine, transmission, and rear drive axles (as a minimum) of the rebuilt vehicle are not new, and at least two of these components were taken from an existing vehicle whose identity is continued in the rebuilt vehicle with respect to model year, vehicle identification number, and any other documentation incident to the vehicle's remanufacture and registration.; Our interpretation of what constitutes manufacture of a new traile (when use of components from an existing vehicle is involved) parallels our present interpretation of truck rebuilding in this area. We regret any confusion in our use of the term 'chassis', but we have made clear that the running gear and main frame of an existing vehicle, must, as a minimum, be used in the rebuilding of a vehicle to be considered a repair. I enclose copies of two letters which establish this point.; NHTSA does not view the manufacture of trucks and trailers a sufficiently similar to justify attempting to apply our newly-proposed position on truck rebuilding to trailer manufacture. The primary consideration of extremely high value of drive train components found in powered vehicles is not applicable to trailer manufacture. NHTSA also concludes that the economic considerations which discourage avoidance of Standard No. 121, Air brake systems, in truck manufacture do not operate in trailer manufacture.; In regard to tank trailer modifications where the tank serves th purpose of and replaces the frame rails, we would not consider replacement of compartments in the tank to be manufacture of a new vehicle. Similarly, the addition of volume in response to the new weight limits would not constitute manufacture of a new vehicle.; Sincerely, James C. Schultz, Chief Counsel

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.

Interpretations	Date

ID: aiam3876 Open Mr. John S. Cucheran, Vice President, Design and Engineering, Jac Products, Inc., 1901 E. Ellsworth, Ann Arbor, MI 48104; Mr. John S. Cucheran Vice President Design and Engineering Jac Products Inc. 1901 E. Ellsworth Ann Arbor MI 48104; Dear Mr. Cucheran: This is in reply to your letter of November 30, 1984, to Mr. Vinson o this office asking for an interpretation of Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment.; Figure 10 of Standard No. 108 establishes the minimum desig photometrics for center high mounted stoplamps. The test procedure for this particular part of Standard No. 108 which is specified in SAE J186a, stipulates that the 'lamp axis shall be taken as the horizontal line through the light source.' However, I believe that you have misinterpreted the light cone that is involved. The pertinent light cone in this case has its vertex at the photometer and a cross section at the plane of the lamp which encompasses the lens areas. From Drawing A that you have provided, it appears that your rail would interfere with this light cone.; In order to determine if your rack interferes with the photometri requirements, the vehicle must be tested with the rack in position as installed on the vehicle. As the agency has noted before, the photometric requirements do not specify that the entire lens must be visible from each 5 degree down test point. Instead, they specify the intensity of light that must be visible from those points. Therefore, the requirement can be met with a lamp whose lens is partially obscured by a portion of the vehicle when viewed from some of the test points.; We hope that his interpretation is helpful to you. Sincerely, Frank Berndt, Chief Counsel
ID: aiam2866 Open Mr. Robert B. Kurre, Director of Engineering, Wayne Corporation, P. O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director of Engineering Wayne Corporation P. O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your recent letter asking whether Safety Standard No 208, Occupant Crash Protection, does require side- facing seats in multipurpose passenger vehicles to comply with one of the options under paragraph S4.2.2, since the side-facing seats in question would be considered designated seating positions. If a manufacturer chooses to install seat belts under one of the options of that paragraph, the seat belt assemblies must comply with Safety Standard No. 209, Seat Belt Assemblies, and Safety Standard No. 210, Seat Belt Anchorages.; Safety Standard No. 210 does exempt side-facing seats from its strengt requirements, but all other requirements of the standard would be applicable. However, we strongly recommend that belt anchorages for side-facing seats be of at least equivalent strength to anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements. Side-facing seats were excepted from the strength requirements specified in the standard because the forces acting on side-facing seats are different from those acting on forward or rearward facing seats and the requirements and procedures were specifically developed for these latter seats.; Please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam2371 Open William K. Rosenberry, Esq., Attorney at Law, Parkway Central Plaza, 611 Ryan Plaza Dr., Suite 713, Arlington, TX 76011; William K. Rosenberry Esq. Attorney at Law Parkway Central Plaza 611 Ryan Plaza Dr. Suite 713 Arlington TX 76011; Dear Mr. Rosenberry: This is in reply to your letter of July 14, 1976, to George Shifflet of the Office of Standards Enforcement, on behalf of a client who intends to install a different type of seat, carpeting, and headliner in a pick-up truck, which would then be sold to the general public. You asked whether a fabric supplier must test each fabric lot for flammability before certification to Motor Vehicle Safety Standard No. 302 can be given, and whether your client 'may rely on the warranty of a fabric manufacturer that the fabric sold meets the requirements ' of Standard No. 302.; You are correct in your understanding that the provisions of th National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq) apply to your client. His basic responsibility is to ensure that the vehicles he modifies are in compliance with the Federal standards when delivered to dealers for sale to the public. (15 U.S.C. 1397(a)(1)(A)) A temporary noncompliance during modifications is permissible if the vehicle is not used on the public roads while noncompliant (15 U.S.C. 1397(a)(2)(A)). Standards which would appear to be affected by your client's modifications include: Standard No. 207 Seating Systems, No. 208 Occupant Crash Protection, No. 210 Seat Belt Assembly Anchorages and No. 302 Flammability of Interior Materials.; As a person who alters a certified vehicle other than by the additio of readily detachable (sic) components, your client is also required to attach his own certification of compliance to each modified truck (49 CFR 567.7). Should a noncompliance be discovered as a result of an alterer's modification, the alterer would be liable for a civil penalty unless he could establish that he did not have actual knowledge of the noncompliance, and that he did not have reason to know in the exercise of due care that the vehicle did not comply (15 U.S.C. 1397(b)(2)).; With respect to Standard No. 302, there is no requirement that a fabri supplier 'test each fabric lot for flammability before certification.' In point of fact, 49 CFR 571.302 Motor Vehicle Safety Standard No. 302 does not apply to suppliers but only to vehicle manufacturers (or alterers) and it is they who are required to certify compliance with Standard No. 302. Generally, at a minimum, a vehicle manufacturer will require by contract with the supplier that the fabric meets Standard No. 302. In the exercise of 'due care' the manufacturer may wish to examine the basis for the supplier's assurance of compliance, and to require periodic testing of the fabric being supplied him. Since there is no requirement that each fabric lot be tested, such testing as is conducted should be sufficient to demonstrate in the event of a noncompliance that the vehicle manufacturer has exercised due care. As to whether your client may rely on the 'warranty' of his supplier, it has been our experience that simple reliance is insufficient to establish a 'due care' defense. That manufacturer should examine the supplier's test results to insure that the margin of compliance of the test fabric is great enough that production variables do not result in noncompliance. Some manufacturers even conduct their own test independent of the supplier.; Your client would also be responsible for conducting a notification an remedy campaign (15 U.S.C. 1411 et seq) if a noncompliance or safety-related defect occurs in the truck as a result of the alterations.; I enclose copies of the Act, 49 CFR Part 567, and Standards Nos. 207 208, 210, and 302 for your information.; Yours truly, Frank Berndt, Acting Chief Counsel
ID: aiam2369 Open AIRMAIL, William K. Rosenberry, Esq., Attorney at Law, Parkway Central Plaza, 611 Ryan Plaza Dr., Suite 713, Arlington, TX, 76011; AIRMAIL William K. Rosenberry Esq. Attorney at Law Parkway Central Plaza 611 Ryan Plaza Dr. Suite 713 Arlington TX 76011; Dear Mr. Rosenberry: This is in reply to your letter of July 14, 1976, to George Shifflet of the Office of Standards Enforcement, on behalf of a client who intends to install a different type of seat, carpeting, and headliner in a pick-up truck, which would then be sold to the general public. You asked whether a fabric supplier must test each fabric lot for flammability before certification to Motor Vehicle Safety Standard No. 302 can be given, and whether your client 'may rely on the warranty of a fabric manufacturer that the fabric sold meets the requirements' of Standard No. 302.; You are correct in your understanding that the provisions of th National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq) apply to your client. His basic responsibility is to ensure that the vehicles he modifies are in compliance with the Federal standards when delivered to dealers for sale to the public. (15 U.S.C. 1397(a)(1)(A)) A temporary noncompliance during modifications is permissible if the vehicle is not used on the public roads while noncompliant (15 U.S.C. 1397 (a)(2)(A)). Standards which would appear to be affected by your client's modifications include: Standard No. 207 Seating Systems, No. 208 Occupant Crash Protection, No. 210 Seat Belt Assembly Anchorages and No. 302 Flammability of Interior Materials.; As a person who alters a certified vehicle other than by the additio of readily detachable components, your client is also required to attach his own certification of compliance to each modified truck (49 CFR 567.7). Should a noncompliance be discovered as a result of an alterer's modification, the alterer would be liable for a civil penalty unless he could establish that he did not have actual knowledge of the noncompliance, and that he did not have reason to know in the exercise of due care that the vehicle did not comply (15 U.S.C. 1397(b)(2)).; With respect to Standard No. 302, there is no requirement that a fabri supplies 'test each fabric lot for flammability before certification.' In point of fact, 49 CFR 571.302 Motor Vehicle Safety Standard No. 302 does not apply to suppliers but only to vehicle manufacturers (or alterers) and it is they who are required to certify compliance with Standard No. 302. Generally, at a minimum, a vehicle manufacturer will require by contract with the supplier that the fabric meets Standard No. 302. In the exercise of 'due care' the manufacturer may wish to examine the basis for the supplier's assurance of compliance, and to require periodic testing of the fabric being supplied him. Since there is no requirement that each fabric lot be tested, such testing as is conducted should be sufficient to demonstrate in the event of a noncompliance that the vehicle manufacturer has exercised due care. As to whether your client may rely on the 'warranty' of his supplier, it has been our experience that simple reliance is insufficient to establish a 'due care' defense. That manufacturer should examine the supplier's test results to insure that the margin of compliance of the test fabric is great enough that production variables do not result in noncompliance. Some manufacturers even conduct their own tests independent of the supplier.; Your client would also be responsible for conducting a notification an remedy campaign (15 U.S.C. 1411 et seq) if a noncompliance of safety-related defect occurs in the truck as a result of the alterations.; I enclose copies of the Act, 49 CFR Part 567, and Standards Nos. 207 208, 210, and 302 for your information.; Yours truly, Frank Berndt, Acting Chief Counsel
ID: aiam0532 Open Mr. Rozie M. Turner, Engineering Department, Hackney Bros. Body Company, P. O. Box 920, Wilson, NC 27893; Mr. Rozie M. Turner Engineering Department Hackney Bros. Body Company P. O. Box 920 Wilson NC 27893; Dear Mr. Turner: This is in reply to your letter of December 6, 1971, in which yo requested our opinion on the application of Standard No. 207 to swivel type pedestal seats.; Your problem arises from the method specified in S5.1.1 for th application of the force required by S4.2(a) of 20 times the weight of the seat. Although your letter does not state the problem directly, it appears that when a forward force is applied from behind the seat, as shown in the figures accompanying S5.1.1, the seat will tend to swivel. Your solution is to attach a T-shaped structure to the seat and to apply the force to the leg of the T forward of the swivel point.; The initial question raised by your letter is whether a seat tha swivels under the application of a force through its back as shown in Figure 1, will be considered to fail to withstand the force and thereby fail the standard.; On the basis of our present information, we cannot say that such swiveling action would result in a failure of the standard. The engineering staff has expressed uncertainty as to the effects on the occupant if the seat swivels in a side or angular crash, but they are not prepared to say that it would present a hazard. Since the swiveling itself is not a failure, the remaining question is one of test procedure. Our opinion is that the procedure you describe, using a T shaped structure, appears to be an acceptable means of applying the test force to the seat.; Sincerely, Richard B. Dyson, Assistant Chief Counsel
ID: aiam3845 Open Mr. Donald M. Schwentker, Schnader, Harrison, Segal & Lewis, Suite 1100, 900 Seventeenth Street, N.W., Washington, D.C. 20006; Mr. Donald M. Schwentker Schnader Harrison Segal & Lewis Suite 1100 900 Seventeenth Street N.W. Washington D.C. 20006; Dear Mr. Schwentker: This responds to your letter of May 9, 1984, concerning the applicatio of Standard No. 208, Occupant Crash Protection, and Standard No. 209, Seat Belt Assemblies, to an emergency locking retractor designed by one of your clients. The following discussion addresses the application of those standards to the retractor.; You explained that the purpose of the new emergency locking retracto (ELR) is to facilitate the securing of a child restraint in a vehicle. The ELR would only be installed in forward-facing passenger seating positions. The new ELR is designed so if the belt is pulled all the way out of the retractor, the ELR will convert into an automatic locking retractor (ALR). Once all but 1393-1493 mm of the belt retracts, the retractor will revert automatically to the ELR mode.; You further explained that the continuous loop lap and upper torso bel used with this retractor is 380 mm longer than the belt system provided for the driver's seating position. You explained that the extra 380 mm of belt webbing is meant 'to permit normal occupant movement without inadvertent actuation of the ALR mode while still rendering it convenient for manual extension when the ALR mode is desired for child restraint use.'; You specifically asked whether the retractor designed by your clien would be considered an ELR for the purposes of S7.1.1 of Standard No. 208. In addition, you asked about the retractor durability tests of S5.2(k) of Standard No. 209. As a part of that test, a retractor is subjected to '45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension.' You asked whether, for the purposes of the section 5.2(k) test, the length of the driver's belt, which is 380 mm shorter than the passenger's belt, could be used to determine what constitutes 100 percent extension of the belt. You alternatively asked whether the test could be stopped before complete extension of the passenger belt.; As we understand your client's seat belt assembly, the amount o webbing in the driver's side assembly complies to the adjustment requirements of section 4.1(kg) of Standard No. 209. The 380 mm's of extra webbing that is included in the passenger's seat belt assembly has been voluntarily added as a precaution to reduce the possibility of an occupant inadvertently actuating the ALR mode of the retractor. Based on the information you have provided, it appears that in normal operation by occupants covered by the adjustment requirements of Standard No. 209 the retractor functions exclusively as an ELR and thus can be used to meet the requirements of S7.1.1 of Standard No. 208. The agency views the 380 mm's of extra webbing as a voluntary addition not required by the standard. Therefore, for the purpose of section 5.2(k) of Standard No. 209, the agency will use the length of the driver's belt to determine what constitutes full extension of the webbing.; Sincerely, Frank Berndt, Chief Counsel.
ID: aiam3716 Open Mr. Binichi Doi, NSK Representative Office, 5400 S. State Street, Ann Arbor, MI 48104; Mr. Binichi Doi NSK Representative Office 5400 S. State Street Ann Arbor MI 48104; Dear Mr. Doi: This responds to your letter asking whether a continuous loop seat bel system with a tension reliever ('window-shade device') on the upper torso section of the belt must have a one-way locking tongue.; Continuous seat belt systems are permissible under Safety Standard No 208 if certain conditions are met. Paragraph S7.1.1 of that standard requires adjustment of the lap belt portion of Type 2 belts 'by means of an emergency locking or automatic-locking retractor' and adjustment in most cases of the upper torso portion 'by means of an emergency-locking retractor.' The language permits single retractor, continuous loop systems if the single retractor does 'automatically adjust' the tension of the lap belt portion to prevent excessive slack. Because of the danger of submarining due to a slack lap belt, the agency has restricted the acceptability of continuous loop systems under S7.1.1 in two areas.; First, to conform to the requirements, the buckle of the assembly mus be designed by the manufacturer with a sufficiently low level of friction to qualify the lap portion as automatically adjusting. This means that when the belt is buckled by the vehicle occupant, the retractor must be capable of cinching the lap belt tightly around the occupant's pelvic area (regardless of where the buckle tongue is located along the belt webbing when the belt is fastened). The friction in the buckle tongue cannot be so high that the occupant must manually pull the belt webbing through the tongue to tighten the lap belt. Based on our viewing of your proposed belt system (presented by your representative in a May 25th meeting), it is our opinion that your system does not have a sufficiently low level of friction that it would automatically adjust the lap belt portion. It is impossible for us to judge how this system would perform when installed in a vehicle, however, since the angle of the buckle tongue at the time of fastening does affect its friction level. It is the manufacturer's responsibility to determine whether or not its belt design complies with the standard. The agency does not offer advance approval of any motor vehicle or piece of motor vehicle equipment. Further, the agency does not make determinations of compliance of a vehicle or item of equipment prior to the manufacturer's certification of that vehicle or equipment.; The second restriction in regard to continuous loop systems concern the use of manual and automatic tension relieving devices on the upper torso portion of the continuous loop. In past letters of interpretation, the agency has limited the use of tension relieving devices to the upper torso section of seat belts that have an individually adjustable lap belt. A system does not have an individually adjustable lap belt if slack which is introduced into the continuous loop by a 'window shade' device or 'comfort clip' is directly transferred to the lap belt. Thus, in answer to your specific question, yes, a continuous loop seat belt system with a tension reliever on the upper torso portion of the belt should have a one-way locking tongue or some other method of preventing slack from returning to the lap belt. The high friction in the buckle tongue of your belt design would likely prevent the return of belt slack to the lap belt. However, as pointed out above, this high friction would also likely prevent the lap belt from adjusting automatically. Granted, these are somewhat conflicting concerns and they do present a tremendous design challenge. However, the agency believes these are necessary requirements if manufacturers include tension-relieving devices in their continuous loop systems.; I hope this clarification will be of help to you in your design plans. Sincerely, Frank Berndt, Chief Counsel
ID: aiam2111 Open Mr. W.G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W.G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in response to your letter of September 23, 1975, in which yo inquire whether the emergency exit decal installations shown in photographs enclosed with your letter comply with paragraphs S5.5.1 and S5.5.2 of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Window Retention and Release.'; It appears from the photographs you provided that some of the emergenc exit markings may not comply with some of the requirements specified in FMVSS No. 217. Our specific comments are listed below:; 1. Figure 1 - The emergency exit marking for the rear door appears t meet the requirements. It is to be noted, however, that revised requirements for emergency exits on school buses have been proposed which may differ from the current requirements.; 2. Figures 2 and 3 - The emergency exit marking for the side push-ou windows does not appear to meet the requirements of S5.5.2. Both the seat back and the adjacent seated occupant partially obstruct the marking so it is not legible from the adjoining seat or the aisle location.; 3. Figure 4 - The emergency exit marking for the side door appears t meet the requirements.; 4. Figure 5 - The marking for the rear window emergency exit that i adjacent to a davenport type seat with unknown seating capacity appears to contain two release mechanisms (laterally spaced at each edge) and an identical marking for each latch mechanism. We cannot determine if occupants would obstruct these markings from standees if all positions in the davenport type seat were occupied.; We also question whether the instructions are complete because i cannot be determined if both latches must be released before the window can be pushed out.; 5. Figure 6 - The emergency exit marking for the transit sliding typ window appears to meet the requirements.; 6. Figure 7 - The center rear emergency door which contain instructions for unlatching the opening of the door in the form of an arrow only per the proposed amendment to FMVSS No. 217, Docket 75-3: Notice 1 does not meet the present requirements for emergency exit identification. The specific content of the emergency exit marking for school buses has not yet been finalized by this agency and we, therefore, cannot comment until a final rule on the proposal has been published in the Federal Register; 7. Figures 8 and 9 - The emergency exit marking for another transi sliding type window appears to meet the requirements.; It is emphasized that these comments are for your information only an are based on the contents of your photographs. This agency cannot make a final judgement concerning compliance of a bus from photographs of components. The determination of compliance or noncompliance with FMVSS No. 217 can be made only by the actual inspection and test of a complete vehicle.; I trust this information will be of assistance to you in regard to you inquiries.; Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam1352 Open Mr. W. G. Milby, Project Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your November 8, 1973, request for a interpretation of the warning signal requirements of Standard No. 121, Air brake systems.; S5.1.5 of that standard states: >>>A signal, other than a pressure gauge, that gives a continuou warning to a person in the normal driving position when the ignition is in the 'on' or 'run' position and the air pressure in the service reservoir system is below 60 psi. The signal shall be either visible within the driver's forward field of view, or both audible and visible.<<<; A warning that 'the air pressure in the service reservoir system i below 60 psi' is intended to mean that a warning device's sensor could be located in the system you described in your letter between the source of air pressure and the check valve(s) required by S5.2.1.5. As you pointed out, this location would sense pressure below 60 psi anywhere from the compressor through the entire service reservoir system. A single warning installed before the check valves in a split service brake system would fulfill the requirements of S5.1.5 as long as it is positioned to sense pressure below 60 psi in any part of the split service reservoir system.; Your interpretation of the signal requirements is correct. The signa must be both audible and visible, or it must be visible within the driver's forward field of view. A simple audible signal is insufficient, as is a simple visible signal which is not within the driver's forward field of view.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1919 Open Mr. Sumner Meiselman, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Sumner Meiselman Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Meiselman: This responds to the Truck Trailer Manufacturers Association March 28 1975, request that the National Highway Traffic Safety Administration (NHTSA) review its position that building a trailer from new materials in combination with the running rear of an existing trailer constitutes the manufacture of a new vehicle subject to applicable safety standards. You also request confirmation that modification of the barrel of a tank trailer to replace compartments or to add to its volume does not constitute manufacture of a new vehicle.; NHTSA has already reconsidered its interpretation of what constitute the manufacture of a new truck in cases where components from an existing vehicle are used. Based on the high value of the drive train components found in powered vehicles, NHTSA has proposed an amendment of Part 571 that would supplant its earlier interpretation that, to constitute repair, the chassis of the existing vehicle must as a minimum be used in the new vehicle. The proposed amendment would establish that, in the assembly of a truck, a new vehicle is manufactured for purposes of compliance with and certification to applicable safety standards, unless the engine, transmission, and rear drive axles (as a minimum) of the rebuilt vehicle are not new, and at least two of these components were taken from an existing vehicle whose identity is continued in the rebuilt vehicle with respect to model year, vehicle identification number, and any other documentation incident to the vehicle's remanufacture and registration.; Our interpretation of what constitutes manufacture of a new traile (when use of components from an existing vehicle is involved) parallels our present interpretation of truck rebuilding in this area. We regret any confusion in our use of the term 'chassis', but we have made clear that the running gear and main frame of an existing vehicle, must, as a minimum, be used in the rebuilding of a vehicle to be considered a repair. I enclose copies of two letters which establish this point.; NHTSA does not view the manufacture of trucks and trailers a sufficiently similar to justify attempting to apply our newly-proposed position on truck rebuilding to trailer manufacture. The primary consideration of extremely high value of drive train components found in powered vehicles is not applicable to trailer manufacture. NHTSA also concludes that the economic considerations which discourage avoidance of Standard No. 121, Air brake systems, in truck manufacture do not operate in trailer manufacture.; In regard to tank trailer modifications where the tank serves th purpose of and replaces the frame rails, we would not consider replacement of compartments in the tank to be manufacture of a new vehicle. Similarly, the addition of volume in response to the new weight limits would not constitute manufacture of a new vehicle.; Sincerely, James C. Schultz, Chief Counsel

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