NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam5164OpenMr. Brett J. Higgins 10257 Slater Ave. #103 Fountain Valley, CA 92708; Mr. Brett J. Higgins 10257 Slater Ave. #103 Fountain Valley CA 92708; "Dear Mr. Higgins: This responds to your letter of March 25, 1993 t former Chief Counsel Paul Jackson Rice seeking information on how the laws and regulations administered by this agency would apply to an item of equipment you wish to sell. According to your letter, the item is a special clamp that is applied to the shoulder strap of a seatbelt as an after-market item. The purpose of this clamp is to allow for slack in the shoulder harness section of a seatbelt thus allowing it to be worn more comfortably. I am pleased to have this opportunity to explain our laws and regulations to you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act) authorizes this agency to issue motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 208, Occupant Crash Protection (49 CFR 571.208). This standard requires new motor vehicles to be equipped with safety belts and requires that those belts meet specified fit and comfort requirements, as set forth in S7 of the standard. However, Standard No. 208 does not apply to aftermarket items that seek to alter belt fit and/or comfort. Hence, you are not required to certify that this device complies with Standard No. 208 before offering the device for sale. In addition, you are not required to get some sort of 'approval' from this agency before offering this device for sale. NHTSA has no authority to 'approve' motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self- certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. As stated above, this device is not subject to any safety standard, so you do not have to make any certification. Although none of our safety standards directly apply to this device, there are several provisions in the Safety Act that are relevant. Manufacturers of motor vehicle equipment such as your belt positioning device are subject to the requirements in sections 151-159 of the Safety Act (15 U.S.C. 1411-1419) concerning the recall and remedy of products with defects related to motor vehicle safety. In addition, use of your product could be affected by section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits manufacturer, distributors, dealers, and repair shops from knowingly 'rendering inoperative,' in whole or in part, any device or element of design installed on or in a vehicle in compliance with an applicable safety standard. There are two elements of design in a vehicle that might be 'rendered inoperative' by the use of your belt positioning device. One is the occupant protection afforded by belts that meet the specified fit and comfort requirements. The other element of design that could be rendered inoperative by the use of your device is the burn resistance required by Standard No. 302, Flammability of Interior Materials (49 CFR 571.302). The materials used in the interior of vehicles, including the seat belts, seat backs and cushions, trim panels, and headliner must comply with the burn resistance requirements of Standard No. 302 to reduce deaths and injuries in the event of a fire in the vehicle's interior. If your device renders inoperative the belt fit and comfort requirements specified in Standard No. 208 or does not comply with burn resistance requirements, it could not be installed in a vehicle by any manufacturer, distributor, dealer, or repair shop. I note that NHTSA has received a number of inquiries about devices similar to the one you plan to sell. As we have advised others, this agency is concerned that a belted occupant could inadvertently use such products to introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of that belt. We encourage you to provide instructions with the product that warn users not to introduce excessive slack and provide detailed guidance for users on what is an excessive amount of slack. I have enclosed a general information sheet for new manufacturers that gives a thumbnail sketch of NHTSA's regulations and provides information on how to obtain copies of those regulations. 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, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam2987OpenMr. Moe Pare, Jr., Director of Design, Cars & Concepts, Inc., 12500 E. Grand River, Brighton, MI 48116; Mr. Moe Pare Jr. Director of Design Cars & Concepts Inc. 12500 E. Grand River Brighton MI 48116; Dear Mr. Pare: This responds to your March 2, 1979, letter concerning the definitio of the vehicle sub-classification, 'convertible.' Your letter included several Figures of various vehicle designs and asked whether each would be considered a 'convertible' by the National Highway Traffic Safety Administration.; While our regulations do not include a formal definition o 'convertible', the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed rigid structural member. Therefore, passenger cars equipped with a 'sun roof' or a 'Hurst hatch roof' do not qualify as convertibles, because they have a fixed, rigid structural member in the described location (April 21, 1976, letter of interpretation enclosed). This interpretation applies, moreover, whether the rigid structural member joining the 'A' and 'B' pillars is a hidden reinforcing component or whether the structural member is part of the exterior roof panel.; Given this interpretation, only the Fiat X-19 vehicle desig illustrated in your Figure 5 would qualify as a 'convertible.' Each vehicle design in your other illustrations (Figures 1, 2, 3, 4, 5, 6, 7, 8 and 9) include fixed, rigid structural components joining the 'A' and 'B' pillar sections of the vehicles and, therefore, would not be classified as convertibles. Likewise, the designs would not be considered 'open-body type vehicles' (49 CFR 571.3) for the same reason, the structural member, whether hidden or not, would be considered part of the vehicle top. Also, I would point out that the 'open-body vehicle' designation generally refers to multipurpose passenger vehicles such as 'Jeeps' or 'dune buggies.'; I hope this clarification is responsive to your inquiry. If you hav any further questions please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2988OpenMr. Moe Pare, Jr., Director of Design, Cars & Concepts, Inc., 12500 E. Grand River, Brighton, MI 48116; Mr. Moe Pare Jr. Director of Design Cars & Concepts Inc. 12500 E. Grand River Brighton MI 48116; Dear Mr. Pare: This responds to your March 2, 1979, letter concerning the definitio of the vehicle sub-classification, 'convertible.' Your letter included several Figures of various vehicle designs and asked whether each would be considered a 'convertible' by the National Highway Traffic Safety Administration.; While our regulations do not include a formal definition o 'convertible,' the agency has stated that it considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed rigid structural member. Therefore, passenger cars equipped with a 'sun roof' or a 'Hurst hatch roof' do not qualify as convertibles, because they have a fixed, rigid structural member in the described location (April 21, 1976, letter of interpretation enclosed). This interpretation applies, moreover, whether the rigid structural member joining the 'A' and 'B' pillars is a hidden reinforcing component or whether the structural member is part of the exterior roof panel.; Given this interpretation, only the Fiat X-19 vehicle desig illustrated in your Figure 5 would qualify as a 'convertible.' Each vehicle design in your other illustrations (Figures 1, 2, 3, 4, 6, 7, 8 and 9) include fixed, rigid structural components joining the 'A' and 'B' pillar sections of the vehicles and, therefore, would not be classified as convertibles. Likewise, the designs would not be considered 'open-body type vehicles' (49 CFR 571.3) for the same reason, the structural member, whether hidden or not, would be considered part of the vehicle top. also, I would point out that the 'open-body vehicle' designation generally refers to multi-purpose passenger vehicles such as 'Jeeps' or 'dune buggies.'; I hope this clarification is responsive to your inquiry. If you hav any further questions please contact Hugh Oates of my office (202-426-2992).; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: 10-005859 df samaniOpenMr. Nasser Zamani, Senior Manager Compliance and Regulatory Affairs Daimler Trucks North America LLC 4747 N. Channel Ave. Portland, OR 97217-7699 Dear Mr. Zamani: This responds to your request for assurance that we will apply a tolerance when measuring the width of flexible occupant seats, in testing school buses for compliance with Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School bus passenger seating and crash protection. We regret to inform you that this letter is unable to provide a tolerance. You ask about a flexible occupancy seat, which is defined in S4 of FMVSS No. 222 as: a bench seat equipped with Type 2 seat belts that can be reconfigured so that the number of seating positions on the seat can change. The seat has a minimum occupancy configuration and a maximum occupancy configuration, and the number of passengers capable of being carried in the minimum occupancy configuration must differ from the number of passengers capable of being carried in the maximum occupancy configuration. S4.1 of FMVSS No. 222 specifies how the National Highway Traffic Safety Administration (NHTSA) will determine the number of seating positions and seat belt positions on a bench seat, including flexible occupancy seats. S4.1(c) states: Except as provided in S4.1(d), the number of Type 2 seat belt positions on a flexible occupant seatis expressed by the symbol Y, and calculated as the seat bench width in millimeters [(mm)] divided by 380 and rounded to the next lowest whole number. See Table 1 [of the standard] for an illustration. S4.1(d) states: A flexible occupancy seat meeting the requirements of S4.1(c) may also have a maximum occupancy configuration with Y +1 Type 2 seat belt positions, if the minimum seat bench width for this configuration is Y +1 times 330 mm. See Table 1 [of the standard] for an illustration. (Emphasis added.) Request for Tolerances You indicate that your flexible occupancy seat has an occupancy configuration of two Type 2 seat belt positions large enough for mid-size adult males under S4.1(c) and an occupancy configuration of three seat belt positions for smaller passengers under S4.1(d). Under S4.1(d), the minimum seat width for the maximum occupancy configuration is 990 mm (3 x 330 mm). You would like the seat width to be permitted to be slightly less than 990 mm wide. You state that since it is difficult to control the tolerance of cushions, the average seat bench width would have to be greater than 990 mm in order to ensure the cushions produced never measured less than 990 mm. You are worried that if the seat bench width is greater than 990 mm, the bus aisle width would be less than 305 mm, which might not meet some State and local requirements. To avoid the difficulties of manufacturing soft goods, you ask if we apply tolerances to the measurement of seat bench width. You suggest that, Tolerances on soft good of this nature are typically +/- 13 mm. Response We regret to inform you that we cannot issue an interpretation along the line you suggest. NHTSA cannot provide variations from the explicit requirements of the FMVSSs through our interpretation letters. This is because under the National Traffic and Motor Vehicle Safety Act (49 U.S.C. Chapter 301; the Safety Act), NHTSA must establish by order appropriate safety standards. The Administrative Procedure Act (APA) applies to all orders establishing, amending, or revoking a safety standard. The APA generally requires agencies to publish a notice setting forth the proposed change to a safety standard, and allow the public to comment thereon, before the agency can adopt any change to the established safety standard. Our interpretation letters are not subject to the requirements for public notice and comment, because interpretations do not add, delete, or change any requirements established in a safety standard. Instead, our interpretations explain how the requirements established in safety standards or the Safety Act apply to particular vehicles or equipment, or otherwise clarify the meaning of the established requirements. In this case, S4.1s language is clear. Under S4.1(d), a flexible occupancy seat (bench seat) may have a maximum occupancy configuration with Y +1 Type 2 seat belt positions, if the minimum seat bench width for this configuration is Y +1 times 330 mm. Thus, under the standard, the minimum seat bench width for your flexible occupancy seat is 990 mm (3 x 330 mm=990 mm). We cannot interpret this language to include a tolerance of +/- 13 mm for the bench.[1] Your letter suggests a change to the requirements of FMVSS No. 222, not a clarification of those requirements. We cannot change those requirements without initiating rulemaking and giving the public notice of and the opportunity to comment on the change. We also note that interpreting the standard to include a tolerance would confuse the meaning of Table 1 of the standard. Table 1 illustrates the number of seating positions as a function of seat bench width. The table shows that a seat bench with a width of 990-1139 mm would have a minimum of two seating positions (fixed occupancy seats or flexible occupancy seats), and for flexible occupancy seats, a maximum occupancy configuration of three seating positions. The table also shows that a seat bench with a width of 760-989 mm would have a minimum of two seating positions (fixed occupancy seats or flexible occupancy seats), and a maximum occupancy configuration of two seating positions. If we applied a tolerance of +/- 13 mm as you suggest, a bench seat of 760-989 mm nominal width could have a maximum occupancy of two or three seating positions. An interpretation that 990 mm means some lesser value would render the values in Table 1 confusing. For the above reasons, we cannot interpret FMVSS No. 222 to provide the tolerance you seek. Sincerely, O. Kevin Vincent Chief Counsel Ref: Std. No. 222 8/17/2011 [1] We assume you meant +/- 13 mm for the entire 990 mm bench and not per 330 mm seating position, but it is unclear from your letter. |
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ID: aiam5590OpenMr. Jim Burgess Engineering Manager Independent Mobility Systems, Inc. 4100 West Piedras St. Farmington, NM 87401; Mr. Jim Burgess Engineering Manager Independent Mobility Systems Inc. 4100 West Piedras St. Farmington NM 87401; Dear Mr. Burgess: This responds to your letter of May 18, 1995 to thi office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system. You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no. FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states: S ide doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not conform to this standard. FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion. While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that 'lift' includes 'ramp.' In order to amend the standard to exclude wheelchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriate. I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures (2) 1985 final rule Part 552; |
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ID: aiam4879OpenMr. Danny J. Pugh Engineering Manager Special Service Vehicles Utilimaster Corporation 65266 State Road 19 P.O. Box 585 Wakarusa, IN 46573; Mr. Danny J. Pugh Engineering Manager Special Service Vehicles Utilimaster Corporation 65266 State Road 19 P.O. Box 585 Wakarusa IN 46573; Dear Mr. Pugh: This responds to your letter of April 15, 1991 regardin requirements for safety belts and door hardware in the prisoner area of police vehicles. Specifically, you asked if police vehicles are required to have seatbelts for prisoners, and if so, what type. You also asked if these vehicles are required to meet the door hardware requirements of Standard No. 206 for rear and side doors. All new vehicles, including police vehicles, are required to comply with all safety standards applicable to their type. Therefore, police vehicles, unless they are buses, are required to have safety belts at all designated seating positions when they are sold to the customer. Our December 13, 1990 letter to you regarding van conversions summarizes what type of safety belts are required depending on the seating position and vehicle type. In addition, police vehicles are required to comply with the requirements of Standard No. 206, if the vehicle is classified as a passenger car, a multipurpose passenger vehicle or a truck. You should note, however, that the requirements of Standard No. 206 do not apply to back doors, including car hatchbacks, van rear doors, and pickup truck tailgates. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: nht78-3.11OpenDATE: 10/06/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Southwest Research Institute TITLE: FMVSS INTERPRETATION TEXT: This responds to your June 27, 1978, letter concerning the requirements of Safety Standard No. 207 as they would apply to pedestal seat assemblies for use in van vehicles. You ask whether your test methodology is consistent with the requirements of the standard and whether the pedestal base is considered part of the seat assembly. As you know, the agency does not approve a manufacturer's test methods. A manufacturer must exercise due care to ascertain that his product is in compliance with all applicable motor vehicle safety standards and regulations. While your test methods appear to be reasonable, the agency will test seats in the vehicle rather than on a surrogate test frame. You must exercise due care to assure that your simulated test is a true determination whether the seats would comply with the standard when tested as provided in that standard. (The vehicle manufacturer is, of course, responsible for compliance with Standard 207.) Regarding your second question, the pedestal base would be considered part of the seat assembly for purposes of Standard 207. This means that the agency would test the entire assembly by applying a force of 20 times the combined weight of the seat and the pedestal, contrary to your simulated test procedure of using only the weight of the seat frame and adjuster, without the pedestal base attached. Finally, the force requirements of Safety Standard No. 210, Seat Belt Assembly Anchorages, (5,000 pounds) are applied simultaneously with the force requirements in Standard No. 207, if the anchorages are connected to the vehicle seat, to the pedestal, or to the pedestal base. Please contact this office if you have any further questions, and please excuse the delay in this response. SINCERELY, SOUTHWEST RESEARCH INSTITUTE DEPARTMENT OF STRUCTURAL SYSTEMS AND FIRE TECHNOLOGY June 27, 1978 National Highway Traffic Safety Administration Office of Chief Counsel Attention: Chief Counsel Subject: Interpretation of FMVSS 207/210 Load Application to Van Seating Assemblies Gentlemen: SwRI is currently performing qualification testing of van seating systems for commercial seat assembly manufacturers. The purpose of these tests has been to provide test data which demonstrates that the seat assembly appears to qualify to the requirements of FMVSS 207. These seat assemblies consist of a seat frame, seat adjuster tracks (if applicable), and pedestal base. Since this entire assembly is manufactured as a separate component for sale to van manufacturers, SwRI performs the tests and reports the results with the understanding that the portion of the assembly above the pedestal base does/does not appear to qualify to the load/time profile requirements of the Standard. In addition, SwRI insures that the test conditions which are not consistent with the requirements of FMVSS 207 are delineated, which are: 1. The assembly is tested on a rigid test frame (not in a vehicle). 2. SwRI utilizes available fasteners to secure the pedestal base to the test fixture (since OEM fasteners are not available). 3. Satisfactory test results are reported which indicate that only the seat structure and fasteners attaching the seat frame to the adjuster track and pedestal base appear to qualify to the requirements of FMVSS 207. 4. The fore/aft CG loads are calculated based on the seat frame and adjuster weight without the pedestal base attached. SwRI would like an interpretation to determine if this methodology is consistent with the requirements of FMVSS 207. SwRI has recently received a "barrel" van seat assembly which is constructed as illustrated in the attached sketch. This assembly has seat belt anchorage holes in the gussetted plate. The seat frame is attached to the gussetted plate which is secured to the pedestal base. SwRI would like an interpretation on the correct load application to this assembly by responding to the following: * Is the load applied as required in FMVSS 207 -- i.e. Forward CG load = 20 x seat assembly weight + 2500 lbs. for each anchorage? or * Is the FMVSS 210 load (5000 lbs.) applied separately? It appears the key question with these seat assemblies is, "Is the pedestal base considered a part of the seat assembly as it applies to the FMVSS 207 requirements?" Your prompt response to this request will be appreciated as SwRI has a sponsor awaiting test results. Charles J. Kerr Research Engineer cc: VINCE QUARLES SEAT STRUCTURE TUBING FIBERBOARD PEDESTAL BASE PEDESTAL ANCHORAGE POINTS GUSSETTED PLATE SEAT BELT ANCHORAGE POINTS "BARREL" VAN SEAT ASSEMBLY (Graphics omitted) |
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ID: aiam1471OpenMr. J. P. Koziatek, Director, Technical Services, Questor Juvenile Products Company, 771 N. Freedom Street, Ravenna, OH 44266; Mr. J. P. Koziatek Director Technical Services Questor Juvenile Products Company 771 N. Freedom Street Ravenna OH 44266; Dear Mr. Koziatek: This responds to your April 9, 1974, petition to substitute th proposed performance requirements for child harness testing under Standard No. 213, *Child seating systems*, for the performance requirements of Standard No. 209, *Seat belt assemblies*, to which Questor's Model 275 child harness is presently subject. As reasons for the substitution, you cite the inappropriateness of attachment hardware requirements (S4.3(c)) and the configuration of the test device (Figure 7) of Standard No. 209 as well as the desirability of testing to dynamic performance requirements which may become a part of Standard No. 213.; The Standard No. 213 dynamic test values which you recommend are onl proposals at this time. Interested parties have not had a full opportunity to comment on them and the NHTSA has not, of course, had the opportunity to fully evaluate them. For these reasons your petition to substitute these new dynamic tests for the Standard No. 209 static tests is denied.; You state that testing of the Model 275 to the assembly performanc requirements of Standard No. 209 (S4.4(c)) is complicated by the configuration of the test device for Type III harnesses, which is not suited to test a child harness such as the Questor NO. 275 that utilizes the adult front lap belts and the rear adult lap belt or the package shelf as attachment points.; Paragraph S5.3(c) (2) of Standard No. 209 directs that in such a cas 'attachment shall be. . .in accordance with the [manufacturer's] installation instructions'. As adherence to Model 275 installation instructions requires a front and rear adult belt installation (and in some cases a package shelf) the use of an actual vehicle bench seat in a passenger car would be an appropriate method to evaluate the assembly under S4.4(c) of Standard No. 209. Moreover, because the 12-inch extension requirement for an assembly tested under S4.4(c) is based on zero deflection of the test device, the actual vehicle seat should be modified to eliminate deflection.; The NHTSA has previously determined that the requirements of S4.3(c) o Standard No. 209 do not apply to bolts used to secure an adult upper torso restraint, other than the continuous loop type. Similarly, we interpret this provision not apply to the child harness upper torso restraint described in your letter. The bolts would be regulated with respect to strength only by the assembly performance requirements of S4.4(c).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: nht90-3.53OpenTYPE: Interpretation-NHTSA DATE: August 8, 1990 FROM: Hiroshi Ozeki -- Executive Vice President, Mazda Research & Development of North America, Inc. TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: Re Request for interpretation of FMVSS No. 214, "Side Door Strength" ATTACHMT: Attached to letter dated 3-12-91 from Paul Jackson Rice to Hiroshi Ozeki (A37; Std. 214) TEXT: The purpose of this letter is to request an interpretation of Federal Motor Vehicle Safety Standard No. 214, "Side Door Strength". Specifically, Mazda would like NHTSA's interpretation of the definition of the phrase, "...(t)he lowest point of the door;" . This phrase is found at S4(c)(2) under test procedures. One of Mazda's future models has a door design in which the door moulding extends below the door itself by approximately 15 mm (please see attached figure). Thus, in order that the loading device used for compliance testing is positioned properly, Mazda needs to know what position, A or B, is the "lowest point of the door". Should you have any questions regarding this request, please do not hesitate to contact either Mr. Rob Strassburger (313-930-2513) of my staff or Mr. Ted Kadoya (626-3263) at our Washington D.C. office. Attachment Drawing of side doors and moulding (Graphics omitted) |
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ID: aiam2965OpenMr. Paul Utans, Subaru of America, Inc., 7040 Central Highway, Pennesauken, (sic) NJ 08109; Mr. Paul Utans Subaru of America Inc. 7040 Central Highway Pennesauken (sic) NJ 08109; Dear Mr. Utans:#I regret the delay in responding to your September 12 1978, letter requesting interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. The responses to your specific questions regarding the compliance of your prototype monitor of vehicle systems are as follows:#1. When there is no problem with the vehicle systems included in the monitor, only the outline of a car is visible. The displays for items such as oil and electrical charge would not be illuminated. You asked if the monitor in its 'no problem' model would comply with FMVSS 101-80. The answer is yes. There is no requirement that the displays be continuously illuminated.#2. On the monitor, the high beam symbol would be oriented so that it pointed upward. You asked whether this complies with the standard even though the symbol appears in Table 2 of the standard pointing to the left. The answer is yes. The requirement is section 5.2.3 that the display symbol appear preceptually (sic) upright to the driver was not intended to apply to the situation in which the symbol is used in conjunction with a car diagram of the type in your monitor. In such situations, it would be more confusing to place the symbol in the upright position than to orient the symbol so that it bears the same relationship to the diagram as the symbolized equipment does to the actual vehicle.#Sincerely, Frank Berndt, Acting 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.