ID: aiam0146

Dear Mr. Folsom: This is in reply to your letter of January 18, 1969, to Dr. Willia Haddon, Jr., requesting information on Federal Motor Vehicle Safety Standards (FMVSS) applicable to ambulances.; If the ambulance is built on a passenger car chassis, all of the FMVS applicable to passenger cars would apply. However, if the ambulance is built on a truck chassis, the FMVSS applicable to multi-purpose passenger vehicles would apply. There have been no special exceptions granted for ambulances.; Enclosed for your information and guidance are copies of the Nationa Traffic and Motor Vehicle Safety Act of 1966 and the FMVSS established thereunder.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service;

ID: NCC-230816-001 Antolin Sun Visor

May 17, 2024

Dr. Enrique Curiel Sanz
Passive Safety Manager – Engineering Shared Services
Grupo Antolin
Enrique.curiel@grupoantolin.com 

Dr. Curiel Sanz, 

This responds to your email to the National Highway Traffic Safety Administration (NHTSA) concerning the standards that sun visors must meet under the Federal Motor Vehicle Safety Standards (FMVSS). Your question concerns evaluation of sun visors, specifically how NHTSA determines if the sun visor is covered in an energy absorbing material. Please note that our answer below is based on our understanding of the specific information provided in your email. 

Background 

NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue federal motor vehicle safety standards (FMVSS) that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety-related defects. 

In your July 19, 2023 message, you asked about the evaluation criteria for sun visors. Specifically, you asked whether sun visors are tested with a pendulum to determine if they are made of an energy absorbing material, and if so, which criteria are used to determine whether the sun visor passes or fails the test. On July 24, 2023, NHTSA responded to your message, indicating that the sun visor requirements in FMVSS No. 201 require that the visor be constructed of or covered with energy absorbing material and that each sun visor mounting present no rigid material edge radius of less than 3.2 mm that is statically contractable by a spherical 165 mm diameter head form. Thereafter, you requested clarification as to how a manufacturer may confirm that a visor’s material meets the definition of “energy-absorbing,” such as material composition or testing under impact conditions. 

Discussion 

As explained, under the Safety Act, each manufacturer of a motor vehicle or item of motor vehicle equipment is responsible for certifying that its products meet all applicable safety standards. Given
 

1 49 U.S.C. 30115. 

Page 2 

Dr. Enrique Curiel Sanz 

this “self-certification” regime, NHTSA does not certify or approve motor vehicles or motor vehicle equipment for compliance with the FMVSS. Manufacturers may not certify a vehicle or item of motor vehicle equipment if, “in exercising reasonable care, [they have] reason to know the certificate is false or misleading in a material respect.”
2 

FMVSS No. 201, “Occupant protection in interior impact,”3 establishes performance requirements designed to reduce the risk of injury in the event an occupant strikes the interior of a vehicle during a crash. Paragraph S5.4 of the standard requires that sun visors be “constructed of or covered with energy-absorbing material” and that the visor’s mounting must “present no rigid material edge radius of less than 3.2 mm that is statically contactable by a spherical 165 mm head form.” The purpose of this requirement is to reduce the injuries that occur when occupants strike the visor or visor mounting with their heads.  

The standard does not further define “energy-absorbing.” Moreover, neither the standard nor NHTSA’s own test procedure4 provides a performance-based or material definition of energy-absorbing, or a test for measuring the energy-absorption capability of sun visor material. Further, the laboratory test procedure for assuring compliance with the standard requires only that the sun visor be made of an energy-absorbing material; no further guidance is provided. Therefore, the responsibility is with the manufacturer to self-certify that the material from which sun visors are constructed or with which they are covered is energy-absorbing to meet the requirements of this standard. 

In so doing, please note that in addition to meeting the S5.4 requirements, S4.2 dictates that vehicles must also comply with the requirements of S6. S6.1.4.2 in turn requires that new vehicles meet the performance standards set forth in S7. Therefore, in addition to the requirement that sun visors be constructed of or covered in an energy absorbing material, manufacturers of sun visors must construct them in such a manner as to ensure compliance with the performance standard of S7 when installed in a vehicle. Compliance with S7 will ensure that the sun visors meet the performance standard, which is what NHTSA requires, along with ensuring that all components are free of safety defects. 

I hope this information is helpful. If you have any further questions, please feel free to contact Terrence Sommers of my staff at the address above or at (202) 366-7577. 

Sincerely,
Adam Raviv
Chief Counsel
 

2 Id.
3 Available at https://www.govinfo.gov/content/pkg/CFR-2022-title49-vol6/pdf/CFR-2022-title49-vol6-sec571-201.pdf (last accessed May 16, 2024).
4 Available at https://www.nhtsa.gov/sites/nhtsa.gov/files/documents/tp-201-02a_tag.pdf (last accessed May 16, 2024).

Dated: 5/17/24
Ref: Standard No. 201

ID: aiam5507

Dear Mr. Welch: This responds to your request for an interpretatio whether the Federal Motor Vehicle Safety Standards (FMVSS) specify 'the type of odometer' placed in a motor vehicle. As explained below, the FMVSS do not so specify. If an odometer is provided, its mileage may be stated in kilometers. Standard No. 101, Controls and displays, specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. Neither Standard No. 101 nor any other FMVSS specifies that an odometer be placed in a motor vehicle or that it register distance in miles, rather than kilometers. However, S5.3.1 (referencing Table 2 'Identification and Illumination of Displays') of Standard No. 101, specifies that if an odometer is provided and the odometer measures mileage in kilometers, the mileage must be stated as 'KILOMETERS' or 'km.' I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel;

ID: aiam3507

Dear Mr. Yokoi: The answers to the questions in your letter of January 20, 1982, ar 'yes' to both questions.; >>>1. The 'adjacent layers' referenced in Federal Motor Vehicle Safet Standard (FMVSS) No. 106, paragraph S7.3.7, are (a) the inner tube and braided layer and (b) the braided layer and outer tube.<<<; >>>2. The adhesion requirements are met if both the tensile strength measured between (a) the inner tube and braided layer and (b) that between the braided layer and the outer cover are equal to or greater than 8lbs/inch as determined using the FMVSS No. 106 procedure. It should be noted that the 8lbs/inch value is an absolute minimum value as indicated in paragraph S8.6.4(a) of the standard.<<<; A copy of FMVSS No. 106 is included for your information. Sincerely, Vernon G. Bloom, Safety Standards Engineer

ID: aiam5374

"Dear Mr. Rowe: This responds to your letter requesting informatio about Federal requirements applicable to your product, the Glad Grip. You stated that this product serves as a handle to help connect and disconnect truck tractor air brake hoses at the glad hand. I am pleased to have this opportunity to explain our regulations to you. By way of background, NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and new items of motor vehicle equipment, such as your product. However, NHTSA has not issued any FMVSS for your product. Our standard for brake hoses (FMVSS 106) applies to air brake hoses, end fittings and assemblies installed as original equipment and to those sold in the aftermarket. Standard 106 defines 'brake hose end fitting' as a coupler, other than a clamp, designed for attachment to the end of a brake hose. You describe the Glad Grip as a device which attaches to the end fitting of an air brake assembly and the glad hand. Since the brake hose that attaches to the Glad Grip is equipped with its own end fittings, the Glad Grip itself is not an end fitting. Therefore, Standard 106 is inapplicable. While it does not appear that you will market your device as original equipment on new vehicles, bear in mind that FMVSS No. 121, Air Brake Systems, applies to trucks and trailers. Any new truck or trailer that has your product as original equipment must meet the standard's requirements with your product installed. I note also that, while NHTSA has not issued any standards for a device such as yours, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall of products with defects related to motor vehicle safety. In the event that the manufacturer or NHTSA determines that the Glad Grip contains a safety related defect, you as the manufacturer of the product would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Further, the Glad Grip is also subject to the requirements of 49 CFR Part 393.45 and 393.46 (copy enclosed), which are regulations administered by the Federal Highway Administration (FHWA) for commercial vehicles. If you are interested in these FHWA requirements, you can write to that agency at the addressed provided in the enclosed information sheet. I hope this information is helpful. If you have any other questions about NHTSA's safety standards, please contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures";

ID: aiam2757

Dear Mr. Evans: This is in reply to your letter of February 3, 1978, to Mr. Guy Hunte of my staff, requesting assignment of a DOT' code number for purposes of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, *Glazing Materials*. You state that you supply vinyl plastic sheeting to your customer who, in turn, laminates and polishes this sheeting for use as glazing in the rear window opening of convertibles.; Under paragraph S6 of FMVSS No. 205 (a copy was previously mailed t you), the assignment of a code number is restricted to prime glazing material manufacturers. Prime glazing material manufacturers are those who either fabricate, laminate, or temper the glazing material. Since you merely supply the material to your customer who then laminates and polishes it for use as glazing, you are not considered the prime manufacturer and assignment of a code number to you is not appropriate. Your customer is the prime manufacturer in this case and it is his responsibility to certify that his glazing meets the requirements by the means specified in FMVSS No. 205.; If I can be of further help, do not hesitate to contact me. Sincerely, E. T. Driver, Acting Associate Administrator for Rulemaking

ID: aiam0983

Dear Mr. Murley: This is in response to your letter of January 31, 1973, in which yo asked us to confirm your 'understanding that FMVSS No. 121 will not apply to fire-fighting vehicles until 1 September 1976, two years from the effective date.' In general, you suggest that 'we would expect to comply with FMVSS for firefighting vehicles within two years after the effective date or two years from the date of publication of the FMVSS, whichever date occurs later'.; You have misread the relevant language of 49 CFR S 571.8. That sectio provides that the effective date of a standard as applied to firefighting vehicles is 'either 2 years after the date on which such standard or amendment is published in the Rules and Regulations section of the *Federal Register*, or the effective date specified in the notice, whichever is later', except as otherwise specified in the standard with reference to those vehicles. The alternatives are thus (a) 2 years after the publication date, or (b) the effective date, whichever is later -- *not* 2 years after the effective date, as you have read it.; Your reading would not be reasonable, since the effective date canno be before the publication date, there would be no point to the alternative phrasing.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam5434

"Dear Ms. O'Cordan: This responds to your question about whether an Federal motor vehicle safety standard (FMVSS) applies to glass used in a travel trailer. You stated that your law office was investigating an accident in which an individual was injured by glass of such a vehicle. Please be aware that no FMVSS applies to the glazing (the term the agency uses for glass) in trailers. The agency has issued one standard, FMVSS No. 205, Glazing Materials, (49 CFR 571.205), which applies to glazing in some motor vehicles. However, this standard does not apply to glazing in trailers, which our regulations define as 'a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle' (49 CFR 571.3). You may wish to contact the State of Wisconsin about the regulation of glass in trailers. The State has the authority to regulate the operation and modification of vehicles by their owners. Wisconsin may have used this authority to issue regulations about glazing in travel trailers. I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, John Womack Acting Chief Counsel";

ID: aiam5642

Dear Mr. Fisher: This is in reply to your letter of October 11, 1995 asking for our comments on the relationship of your lighting invention, 'The Enlightener,' to Federal Motor Vehicle Safety Standard (FMVSS) No. 108. The Enlightener is intended to replace the center highmounted stop lamp. The lens has two colors, divided between amber at the top and red at the bottom. The amber portion is lit in a steady burning mode when both the accelerator and brake are not depressed, and in a flashing mode when the transmission lever is in Reverse. The red portion is lit when the brake pedal is depressed and amber is extinguished. This device would not be permissible under FMVSS No. 108. The center highmounted stop lamp must stand alone, the lamp cannot serve another function, and paragraph S5.4(a) prohibits combining it with any other lamp. In addition, the backup function on motor vehicles is furnished by a steady burning white lamp, required by FMVSS No. 108. The presence of a flashing amber lamp operating simultaneously would impair the effectiveness of the backup lamp by sending a conflicting signal. I am sorry that we cannot provide you a more positive response. If you have any questions, you may refer them to Taylor Vinson of this office by calling (202) 366-5263. Sincerely, Samuel J. Dubbin Chief Counsel;

ID: aiam2939

Dear Mr. Miyazawa, This is in reply to your letter of June 14, 1978, to Mr. E. T. Driver requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, *Lamps, Reflective Devices and Associated Equipment*. Your letter depicted the use of two headlamps, both round and rectangular, mounted side by side, and also one above the other.; Table IV of FMVSS No. 108 requires that if two headlamps are mounted o a motorcycle they must be symmetrically disposed about the vertical centerline. The same requirement applies to taillamps, stoplamps, and reflex reflectors. This has been interpreted previously, in the case of reflex reflectors, to mean that if two are used they may be mounted only side by side. Four headlamp systems are now permitted on motorcycles. These are specified in the new paragraph S4.1.1.34 in the amendment published in the *Federal Register* July 27, 1978. A copy of the new amendment is enclosed, along with copies of previous notices that constitute FMVSS No. 108. However, if two headlamps are mounted on a motorcycle, they still must be mounted side by side and equidistant from a vertical centerline of the body of the motorcycle.; This agency is currently considering an amendment to the standard tha will, if approved, permit the positioning of headlamps and reflectors one above the other when two are mounted on a motorcycle. The necessary rulemaking procedures, if initiated, would take several months and there is no certainty that the contemplated amendment would be issued.; We welcome your further comments and questions, Sincerely, Michael M. Finkelstein, Associate Administrator fo Rulemaking;