ID: 11187

Mr. Joseph J. Smith
Assistant Chief Maintenance Officer
New York City Transit Authority
25 Jamaica Avenue
Brooklyn, NY 11207

Dear Mr. Smith:

This responds to your inquiry about whether Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials (49 CFR ' 571.302), applies to air conditioning return air filters. You state that these filters are placed on top of the air conditioning evaporator coil and are separated from the bus interior by a louvered panel. You were concerned that the filters may be subject to Standard No. 302 because they may be considered located in the "occupant compartment air space." As explained below, Standard No. 302 does not apply to air conditioning return filters.

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. Since Standard No. 302 is a vehicle standard, the manufacturer of the vehicle, and not the manufacturer of the individual component, is responsible for certifying compliance with Standard No. 302. The agency periodically tests new vehicles and items of equipment for compliance with the standards.

Standard No. 302 specifies burn resistance requirements for materials used in the occupant compartment of new motor vehicles. Section S4.1 lists the components in vehicle occupant compartments that the vehicle manufacturer must certify as complying with the flammability resistance requirements of paragraph S4.3. The components listed include seat cushions, seat backs, seat belts headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, and any other interior materials, including padding and crash deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash. Section S4.1 represents a complete listing of all components in new vehicles that must comply with the flammability resistance requirements. Any component not identified in section S4.1 is not subject to those requirements. Therefore, an air conditioning return filter is not subject to those requirements.

Please note that there are other NHTSA requirements that could affect the manufacture and sale of products related to motor vehicles. A motor vehicle or equipment manufacturer incorporating air conditioning filters in its vehicles or equipment would be subject to 49 U.S.C. ''30118-30121 to ensure that its vehicles or equipment do not contain any safety related defect. If the manufacturer or NHTSA determines that a safety related defect exists, the manufacturer would be responsible for notifying purchasers of the defective vehicle or equipment and remedying the problem free of charge.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:302 d:9/29/95

ID: nht95-4.38

TYPE: INTERPRETATION-NHTSA

DATE: September 29, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Joseph J. Smith -- Assistant Chief Maintenance Officer, New York City Transit Authority

TITLE: NONE

ATTACHMT: ATTACHED TO 8/28/95 LETTER FROM JOSEPH J. SMITH TO JOHN WOMACK (OCC 11187)

TEXT: Dear Mr. Smith:

This responds to your inquiry about whether Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials (49 CFR @ 571.302), applies to air conditioning return air filters. You state that these filters are placed on top of the air c onditioning evaporator coil and are separated from the bus interior by a louvered panel. You were concerned that the filters may be subject to Standard No. 302 because they may be considered located in the "occupant compartment air space." As explained below, Standard No. 302 does not apply to air conditioning return filters.

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. Since Standard No. 302 is a vehicle standard, t he manufacturer of the vehicle, and not the manufacturer of the individual component, is responsible for certifying compliance with Standard No. 302. The agency periodically tests new vehicles and items of equipment for compliance with the standards.

Standard No. 302 specifies burn resistance requirements for materials used in the occupant compartment of new motor vehicles. Section S4.1 lists the components in vehicle occupant compartments that the vehicle manufacturer must certify as complying with the flammability resistance requirements of paragraph S4.3. The components listed include seat cushions, seat backs, seat belts headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, and any other interior materials, including padding and crash deployed elements, that are designed to absorb energy on contact by occupants i n the event of a crash. Section S4.1 represents a complete listing of all components in new vehicles that must comply with the flammability resistance requirements. Any component not identified in section S4.1 is not subject to those requirements. Ther efore, an air conditioning return filter is not subject to those requirements.

Please note that there are other NHTSA requirements that could affect the manufacture and sale of products related to motor vehicles. A motor vehicle or equipment manufacturer incorporating air conditioning filters in its vehicles or equipment would be subject to 49 U.S.C. @@ 30118-30121 to ensure that its vehicles or equipment do not contain any safety related defect. If the manufacturer or NHTSA determines that a safety related defect exists, the manufacturer would be responsible for notifying purch asers of the defective vehicle or equipment and remedying the problem free of charge.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: 77-3.11

TYPE: INTERPRETATION-NHTSA

DATE: 06/27/77

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

TO: American Seating Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 24, 1977, letter asking for an interpretation of the requirements for knee contact area in Standard No. 222, School Bus Passenger Seating and Crash Protection, which state that, when impacted, "the resisting force of the impacted material shall not exceed 600 pounds and the contact area on the knee form surface shall not be less than 3 square inches." You ask whether this requirement can be interpreted as meaning that, when impacted, the resisting force of the impacted material shall not exceed 200 pounds per square inch rather than 600 pounds over 3 square inches.

The 600 pound maximum force and the 3 square inch minimum contact area are two distinct requirements. The first specifies an upper bound on the load that will be applied to the upper leg while the latter specifies a lower bound on the knee area over which an impact load must be distributed. To combine the two requirements, as you suggest, tends to relax the contact area requirement for a load which is less than 600 pounds. Such an interpretation would not ensure the level of safety the agency demands for knee contact area. The suggested combination of the two requirements may not provide an adequate distribution of forces over the knee. Accordingly, the agency declines to accept the suggested interpretation of the standard.

SINCERELY,

March 24, 1977

National Highway Traffic Safety Administration

Att: Chief Counsel, Frank A. Berndt

Reference is made to Federal Standard 222, paragraph S5.3.2.2, "When any part on the rear surface of that part of a seat back or restraining barrier within any zone specified S5.3.2.1 is impacted from any direction at 16 feet per second by the knee form specified in S6.7, the resisting force of the impacted material shall not exceed 600 pounds and the contact area on the knee form surface shall not be less than 3 square inches".

We request an interpretation of the requirement for the knee form contact area. The knee recess area of the seat back is the most vulnerable part of the seat not only to vandalism but to hard use by the passenger. This is the area where feet are placed on the back and soles of shoes scuff and damage softer material. Also objects such as briefcases and lunchboxes add to the damage in this area. In fact, in city and inter-city buses this area is normally protected by heavy plastic or stainless steel panels. In the endeavor to provide a more practical surface than the soft vinyl we have been successful in adopting a thin plastic back panel. However, in some areas of the seat back, the resisting force, at 16 feet per second, is only 300 pounds and proportionately the contact area caused by the knee form is about 2 - 2 1/2 square inches.

We question whether the 3 square inches applies to the resisting force of the 600 pound magnitude or if it must extend to the lesser force. If we consider the distribution of the 600 pound force over the 3 square inch area, we are applying 200 pounds per square inch. When we measure the distribution of forces in this manner we meet the 200 pound maximum per square inch.

Under separate cover we are sending you copies of the actual contact areas indicated by the paint imprint. Because your interpretation will have a direct bearing on the construction of the seat as well as performance and economy of maintenance, we would appreciate a response at your earliest convenience.

Chester J. Barecki Vice President - Sales Engineering Transportation Products Division

[Attachments Omitted]

CC: T. HOYT; E. HENEVELD; J. OTT; T. CAMP

ID: 05-005888drn

Bryce Pfister, P.E.
Director of Operations
Collins Bus Corporation
P.O. Box 2946
Hutchinson, KS 67504-2946




Dear Mr. Pfister:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School bus passenger seating and crash protection. You ask whether you may equip school bus seats with Type 2 seat belt assemblies if the upper torso restraint is attached to the same structure required to meet FMVSS No. 222 forward displacement energy-absorbing performance criteria and if the application of force on that upper torso restraint causes the seat back to no longer meet FMVSS No. 222.

The answer is no. The issue you raise was addressed in our letters dated July 12, 2000, to Mr. Turner of the Blue Bird Body Company, and October 28, 1999, to Mr. Perea (copies enclosed). Please take particular note of our response to the first question in the letter to Blue Bird. We stated that Vehicle Safety Act provisions would prohibit Blue Bird from installing Type 2 belts if such a modification would cause a seating system not to comply with FMVSS No. 222, or any other applicable FMVSS.

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

Sincerely,

Stephen P. Wood
Assistant Chief Counsel
for Vehicle Safety Standards and Harmonization

Enclosures
ref:222
d.9/19/05

ID: aiam4587

"Dear Mr. Krewall: Thank you for your letter asking two questions abou how this agency's regulations apply to vehicles used as school buses. Before I answer your specific questions, it may be helpful to discuss some background information. Federal law regulates the manufacture and sale of new school buses. A 'school bus' is defined at 49 CFR /571.3 as 'a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.' The National Highway Traffic Safety Administration (NHTSA) has issued Federal motor vehicle safety standards applicable to all new school buses. It is a violation of Federal law for any person to manufacture for sale a new school bus that does not comply with these safety standards. It is also a violation of Federal law for any person to sell as a school bus any vehicle that does not comply with all school bus safety standards. On the other hand, without violating any provision of Federal law, a school district may purchase or use a vehicle to transport school children even if the vehicle does not comply with Federal school bus regulations. This is so because the individual States have authority over the activities of a retail purchaser or user of a school bus. (Note, however, that a dealer who sold a vehicle other than a school bus to a school district with knowledge that it is intended to be used to transport school children would violate the Federal law.) With this background, I will now address the specific questions raised in your letter. First, you asked whether a 'transit coach-type vehicle' that was manufactured prior to April 1, 1977 could be used to transport students to and from school. In a subsequent telephone conversation with Joan Tilghman of my staff, you explained that you used the term 'transit coach-type vehicle' to mean a bus with a gross vehicle weight rating (GVWR) of over 10,000 pounds. As explained above, Federal law does not regulate the use of vehicles as school buses. If there are any limitations on the use of vehicles as school buses in your State, those limitations arise from the laws or regulations of the State of Oklahoma. NHTSA has repeatedly advised the States of our position that the safest way to transport students is in a vehicle that is certified as complying with Federal school bus regulations. We have encouraged States and school districts to consider this fact carefully when deciding what vehicles should be used to transport students to and from school and school-related events. Your second question asked what must be done to bring a bus with a GVWR of more than 10,000 pounds 'into compliance as a standard Type 'D' school bus.' In your telephone conversation with Ms. Tilghman, you explained that Oklahoma refers to school buses with a GVWR of more than 10,000 pounds as 'Type D' school buses. Please note that Federal school bus standards apply only to new school buses. Accordingly, there is no Federal requirement under NHTSA regulations that any person retrofit a used bus to make it comply with our standards for new school buses. You may wish to know that the Federal Highway Administration (FHWA), a separate agency within the U.S. Department of Transportation, has proposed regulations to enhance highway safety by regulating operations of 'private motor carriers of passengers.' (54 Federal Register 7362, February 17, 1989, Private Carriage of Passengers.) FHWA is exploring whether it is appropriate to require retrofit of some buses owned by that category of operators to meet NHTSA vehicle safety standards. While the proposed rule does not address the operations of governmental entities, you may wish to consider the FHWA proposal or comment on it. I enclose a copy for your information, and direct your attention to the comment closing date of June 19, 1989. I hope you find this information helpful. If you have further questions, please contact Joan Tilghman of my staff at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel";

ID: aiam3693

Dear Mr. Stapp: This responds to your letter to Mr. Kratzke of my staff asking abou this agency's regulations applicable to regrooved tires. Specifically, you asked if a foreign casing must have a DOT symbol on the sidewall in order to be regrooved, what requirements apply to regrooved tires intended for a dealer's own use, and whether there are any restrictions on the use of regrooved tires in particular wheel locations.; 49 CFR Part 569 (copy enclosed) specifies the requirements which mus be met by all regrooved tires, except those intended solely for export and so tagged or labeled. The mechanics of importing casings for regrooving are explained in a previous letter of interpretation issued by the agency (copy enclosed). Once the casing is inside the customs territory of the United States, Part 569 specifies that the casing must be labeled 'regroovable' on both sidewalls. This marking cannot be added to the sidewall by a regroover before regrooving, but must have been placed there by the original manufacturer or a prior retreader. It seems unlikely that foreign manufacturers or retreaders would so label their tires. This means that few, if any, imported foreign casings may legally be regrooved. As explained in the enclosed letter, there is no requirement that the *DOT symbol* appear on the sidewall of casings in order for the casings to be regrooved.; The requirements of Part 569 apply to all tires regrooved in the Unite States, and apply equally to tires regrooved for sale to another party and to tires regrooved for the regroover's own use (Part 569.7). Each violation of those requirements could subject the offender to a $1,000 civil penalty. Each illegally regrooved tire would be treated as a separate violation.; With respect to your question about restrictions on the application an wheel position of a regrooved tire, this agency has no regulations. The bureau of Motor Carrier Safety of the Federal highway Administration has issued a regulation applicable to carriers used in interstate commerce. That regulation prohibits the use of regrooved tires above a certain load-carrying capacity on the front wheels of trucks and truck tractors. If you need further information concerning this subject, please contact Mr. Kenneth L. Pierson, Director, Bureau of Motor Carrier Safety, Federal Highway Administration, Washington, D.C. 20590.; Should you have any further questions regarding regrooved tires, pleas feel free to contact Mr. Kratzke at (202) 426-2292.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam4048

Dear Mr. Mitchell: This is in response to your letter of February 5, 1986, concernin Federal odometer disclosure requirements.; In 1972, Congress enacted Title IV of the Motor Vehicle Information an Cost Savings Act, 15 U.S.C. SS 1981-1991, seeking to eliminate odometer tampering and to establish certain safeguards for the protection of motor vehicle purchasers. This law is applicable in all fifty states, the District of Columbia, Puerto Rico, Guam, the Virgin Islands, the Canal Zone and American Samoa.; Section 1988(a) of the Act requires the Secretary of Transportation t prescribe rules relating to written odometer disclosures. These powers have been delegated to the National Highway Traffic Safety Administration (NHTSA). 49 C.F.R. S 1.50(f). To carry out the Congressional mandate, this Agency promulgated rules for the disclosure of odometer information, 49 C.F.R. S 580.4, and specified the form to be filled out by transferors of motor vehicles, 49 C.F.R. S 580.6. In addition, NHTSA exempted transferors of certain vehicles from the disclosure requirements. 49 C.F.R. S 580.5.; The portion of the regulation you question, 49 C.F.R. S 580.5(a)(1) exempts the transferors of motor vehicles having a gross vehicle weight rating (GVWR) of more than 16,000 pounds from the odometer disclosure requirements. The phrase 'gross vehicle weight rating' is defined as 'the value specified by the manufacturer as the loaded weight of a single vehicle.' 49 C.F.R. S 571.3.; In explaining the exemption for heavier vehicles, NHTSA stated: >>>A new section, 49 C.F.R. S 580.5, has been added in response to number of comments that objected to the application of the requirements to categories of vehicles for which the odometer is not used as a guide to value. Buses and large trucks, for example, are routinely driven hundreds of thousands of miles, and their maintenance records have traditionally been relied on by buyers as the principal guide to their condition. The NHTSA is in agreement with the position taken by Freightliner Corp. , White Motor Corp. , and the National Association of Motor Bus Operators, and has therefore created an exemption for larger vehicles. The exemption applies to vehicles having gross weight ratings of more than 16,000 pounds.<<<; 38 *Federal Register* 2978 (1973) While some courts have determined that NHTSA's authority to creat exemptions may be limited, we believe that NHTSA has the authority to create exemptions for transfers of vehicles for which the odometer reading is not relied upon as an indicator of vehicle mileage or condition. Consequently, the exemption remains a part of the odometer disclosure regulations.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law

ID: nht81-2.28

DATE: 05/21/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 21 1981

NOA-30

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032

Dear Mr. Lawler:

This responds to your recent letter concerning S6.2.4 of Standard No. 213, Child Restraint Systems. You asked whether section 5.2(d)(1) of Standard No. 209 is the relevant section to be used in testing the release force on buckles used on a child restraint system. The answer is yes.

Section 6.2 of Standard No. 213 sets out the test procedure for measuring the release force for buckles used in child restraint systems. Section 6.2.4 states that the buckle is to be operated in the manner described in section 5.2(d) of Standard No. 209, Seat Belt Assemblies. S5.2(d)(1) of Standard No. 209 sets out the procedure for measuring the buckle release force. You are correct that S5.2(d)(2) and (3) set out the procedures for conducting several other requirements of Standard No. 209 which do not apply to child restraints and thus are not relevant to the buckle release force test.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

April 2, 1981

Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W., Room 5219 Washington, D.C. 20590

Dear Sir:

Indiana Mills and Manufacturing, Inc. is a manufacturer of seat belt assemblies for use in motor vehicles. We make every effort to comply with the requirements of the motor vehicle safety standards set forth by the National Highway Traffic Safety Administration.

Standard No. 213 (49 CFR 571.213), Child Restraint Systems, refers in S6.2.4 to S5.2(d) of Standard No. 209 (49 CFR 571.209), Seat Belt Assemblies. The buckle release mechanism mentioned in S6.2.4 (213) is to be operated in the specific manner described in section 5.2(d) of Standard No. 209. We assume that only the portion of S5.2(d) of Standard No. 209 pertaining to the method of releasing the buckle mechanism is included by reference in Standard No. 213, and we believe that portion consists of paragraph (1) beginning with the words "The buckle release force shall be measured..." through the end of the paragraph. Because S5.2(d)(2) and S5.2(d)(3) deal with subjects other than the proper method of releasing the buckle mechanism, we interpret Standard No. 213 as excluding them while including only the portion of S5.2(d)(1) described above.

We would appreciate receiving from you an official written explanation of the intent of S6.2.4 of Standard No. 213.

Thank you for your assistance.

Yours very truly,

William E. Lawler Specifications Manager

WEL/jr

ID: 30102ad_aerial_work_platform

Mr. Mark A. Rangos
Manager, Product Support
Product Safety and Reliability Dept.
JLG Industries, Inc.
1 JLG Drive
McConnellsburg, PA 17233-9533

Dear Mr. Rangos:

This responds to your letter of December 8, 2003, concerning requirements for trailer-mounted aerial work platforms that are being developed by JLG Industries, Inc. (JLG), which are used primarily to lift personnel and materials to elevated work locations in industrial or construction environments.

You state that the aerial work platform structure is mounted upon a trailer chassis for the sole purpose of portability, to move the machine from one job site to another to perform its primary function as an aerial work platform. In a normal application, the machine is towed to a job site and set up for utilization. To be prepared for use, the machine must be maneuvered into position in proximity to the work location. Once in position, the stabilizers are deployed to stabilize and level the chassis. You also state that the machine may remain on the job site for "hours, days, months, or extended periods." Lastly, you claim that towing the machine upon the streets, roads, or highways is incidental to its use on job sites and performed only for the purpose of transfer to work locations. You asked us to confirm your interpretation that this machine would not be considered a "motor vehicle" as specified under the National Traffic and Motor Vehicle Safety Act. For the reasons that follow, we confirm your understanding.

By way of background, Chapter 301 of Title 49, U.S. Code (U.S.C.) (Safety Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to establish Federal motor vehicle safety standards (FMVSS) applicable to new motor vehicles and new items of motor vehicle equipment. The Safety Act defines a "motor vehicle" as:

a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways, but does not include a vehicle operated only on a rail line.

49 U.S.C. 30102(a)(6).

If a vehicle is a motor vehicle under the above definition, then it must comply with all applicable FMVSS. However, if a vehicle is not a motor vehicle under this definition, then it need not comply with the agencys safety standards.

Whether the agency will consider construction equipment, such as an aerial work platform structure that is mounted upon a trailer chassis, to be a motor vehicle depends upon its use. It is the agencys position that this statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between jobsites and which typically spend extended periods of time at a single jobsite. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured.

However, in those cases where certain types of construction equipment make more frequent use of the roadways, the agency has determined such equipment to be a motor vehicle under the Safety Act. For example, dump trucks have been determined to be motor vehicles because they regularly use the highways to travel between jobsites and stay on such jobsites for only a limited period of time, thereby rendering their on-highway use more than "incidental."

Your letter states that the aerial work platform structure is mounted upon a trailer chassis and may be towed from jobsite to jobsite. Your letter goes on to state that the duration of the aerial work platform structures use on jobsites is variable, ranging from "hours, days, months, or extended periods."

Based upon the information and literature you have provided, it does not appear that your aerial work platform structures are "motor vehicles" as that term is defined in the Safety Act. This conclusion is based upon the assumption that your equipment generally spends extended periods of time at a single construction site and only uses the public roads infrequently to travel between jobsites. Accordingly, your aerial work platform structures would not be subject to the FMVSS.

However, if the agency were to receive additional information indicating that the aerial work platform structures use the road more than on an incidental basis, then the agency would reassess this interpretation.

I hope this information is helpful. If you have any further questions regarding NHTSAs safety standards, please feel free to contact Edward Glancy of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:VSA
d.4/1/04

ID: nht75-4.35

DATE: 10/29/75

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Volkswagen of America's August 27, 1975, request for confirmation that a seat belt warning system that activates a 4- to 8-second warning light when the vehicle ignition is turned complies with the requirements of S4.5.3.3 of Standard No. 208, Occupant Crash Protection, although the warning system also activates the same warning light continuously when a separate circuit senses that the front seat belts are not fastened.

Volkswagen's understanding of S4.5.3.3 is correct. As we understand your description, the Volkswagen warning system does provide the automatic 4- to 8-second activation of a warning light called for in S4.5.3.3. This provision prohibits the use of an activation longer than the limits set forth in the standard.

The Volkswagen system provides a different and additional activation of the warning light when the seat belts are not fastened, using a separate circuit to monitor a set of conditions separate from those specified in the requirements of S4.5.3.3. The National Highway Traffic Safety Administration does not consider this activation (which can be longer than 8 seconds) to violate the limit on activation of the automatic reminder specified by the standard.