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: aiam1392OpenMr. George C. Nield, Engineering Advisor, Busby(sic) Rivkin(sic) Sherman(sic) Levy and Rehm, 816 Connecticut Avenue, N.W., Washington, DC 20006; Mr. George C. Nield Engineering Advisor Busby(sic) Rivkin(sic) Sherman(sic) Levy and Rehm 816 Connecticut Avenue N.W. Washington DC 20006; Dear Mr. Nield: This is in reply to your letter of December 13, 1973, asking whethe glazing in the rear quarter windows of the Datsun model HLB-210 may, consistently with Motor Vehicle Safety Standard No. 205, be manufactured of AS 3 glazing material. This depends, as you point out, on whether this glazing is used 'at levels requisite for driving visibility' under American National Standards Institute Standard ANS Z26.1-1966, incorporated into Standard No. 205. You refer in your letter to section 1017(a) of the California Vehicle Code which states:; >>>Side windows to the rear of the driver and the rear windows not use for vision directly to the rear are not considered areas requisite for driving visibility.<<<; The locations where the use of AS 3 glazing is permitted are set fort on page 12 of ANS Z26. AS 3 glazing may be used, 'anywhere in a motor vehicle except in passenger car windshields and in the following locations at levels requisite for driving visibility....(2) *Passenger automobiles and taxicabs*. Glazing of *all* windows including rear window, *all* interior partitions, and *all* apertures created for window purpose. (emphasis added); The only exclusion from the broad prohibition against the use of AS glazing in passenger cars is 'at levels not requisite for driving visibility.' We do not agree with the California Code provision. We consider the word 'levels' in Standard 205 to mean vertical heights in relation to the driver's eyes. We, therefore, cannot concur in the application of the 'levels requisite for driving visibility' concept as it appears in Standard No. 205 to complete windows or other glazing areas of passenger cars.; With respect to the Datsun model in question, there is no evidence i your letter that the windows in question are not at a level requisite for driving visibility. In fact, they appear to include levels of a driver's normal eye point.; The NHTSA presently hopes to publish a revised notice of propose rulemaking regarding direct fields of view in the fall of 1974. Previous proposals regarding this subject were withdrawn by notice published March 7, 1973 (38 FR 6194).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2478OpenMr. Joseph E. Papelian, Department of Police, Detroit, MI 48226; Mr. Joseph E. Papelian Department of Police Detroit MI 48226; Dear Mr. Papelian: This is in response to your letter of November 9, 1976, asking whethe Federal regulations permit manufacturers to equip police vehicles with 'push bumpers' and with bullet-proof shields located between the front and rear seating compartments.; Standard No. 215, *Exterior Protection*, establishes requirements fo the impact resistance and the configuration of front and rear vehicle surfaces of passenger cars. This standard does not prohibit 'push bumpers' and manufacturers are free to equip passenger cars with any bumper design they choose as long as the requirements of Standard No. 215 are met.; Standard No. 205, *Glazing Materials*, specifies requirements fo glazing for use in motor vehicles, including the permissible locations for the various types of glazing. The standard permits bullet-resistant glazing to be used anywhere in a motor vehicle, provided such glazing meets specified performance requirements. Therefore, vehicle manufacturers are permitted to equip vehicles with the bullet-proof shields mentioned in your letter if such shields are constructed with glazing that conforms to the requirements in Standard No. 205.; You also asked whether the police department or a business coul install the equipment in question. If the equipment is installed after the first sale of the vehicle for purposes other than resale, the Federal safety standards would no longer be applicable under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1397(b)(1). However, S 108(a)(2)(A) prohibits, with one exception, manufacturers, distributors, dealers, and motor vehicle repair businesses from knowingly rendering inoperative a safety device or element of design that has been installed in compliance with a motor vehicle safety standard.; Therefore, whether or not a business could install the equipmen depends on the nature of the business. If the business is a 'motor vehicle repair business', it can only install the 'push bumpers' and shields if such installation does not knowingly render inoperative devices or elements of design installed in the vehicle in compliance with applicable safety standards. Section 108(a)(2)(A) defines 'motor vehicle repair business' as any person who holds himself out to the public as in the business of repairing motor vehicles or motor vehicle equipment for compensation.; I have enclosed copies of Standard No. 205 and Standard No. 215. I hav underscored the pertinent sections of Standard No. 205 (and the ANS Z26 standard incorporated by reference in Standard No. 205) for your information.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4497OpenMr. James P. Nolan, Jr. President Nolan and Taylor-Howe Funeral Home, Inc. 5 Laurel Avenue Northport, NY 11768; Mr. James P. Nolan Jr. President Nolan and Taylor-Howe Funeral Home Inc. 5 Laurel Avenue Northport NY 11768; "Dear Mr. Nolan: This is in reply to your letter of March 24, 1988 enclosing a letter you have received from the Department of Motor Vehicles, New York State, advising you that your l987 Cadillac hearse requires a center high-mounted stop lamp. You have asked for the specifications of such a lamp. The center high-mounted stop lamp is required only on passenger cars. A passenger car is defined as a motor vehicle 'designed for carrying l0 persons or less.' A 'multipurpose passenger vehicle' is one 'designed for carrying l0 persons or less which is constructed either on a truck chassis or with special features for occasional off road operation.' A 'truck' is defined as a motor vehicle 'designed primarily for the transportation of property or special purpose equipment.' The agency recognizes chassis constructed for commercial use, such as a hearse, as the equivalent of a truck chassis. The determination of vehicle category is initially that of the manufacturer or final stage assembler who certifies compliance with all Federal motor vehicle safety standards applicable to the category of vehicle selected. In our opinion, a hearse could be properly certified as a either a 'multipurpose passenger vehicle,' or a 'truck.' In a conversation with Taylor Vinson of this Office on April 29, you informed us that the first six characters of the VIN of your hearse are 'lGED09', and that its final stage assembler, Superior, had certified it as an 'MPV' (multipurpose passenger vehicle). The 'G' in the VIN identifies it, according to internal documents of the initial stage manufacturer, General Motors, as 'Cadillac Incomplete Coaches' (meaning, it would appear, funeral coaches), and the '9' as 'Cadillac Commercial Body/Chassis.' This chassis does not form the basis of any passenger car completed by Cadillac. The letter from New York State states 'The manufacturer claims that funeral cars are classified as multipurpose vehicles and do not require the lights.' This is correct, as you have told us that Superior has classified it as an MPV, and certified its compliance to all standards applicable to that vehicle category. As the center high-mounted stop lamp standard is not one of those applicable to multipurpose passenger vehicles, there is no Federal requirement that your hearse be equipped with such a lamp. We appreciate your interest in safety, and trust that this answers your question. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam2477OpenMr. Joseph E. Papelian, Department of Police, Detroit, MI 48226; Mr. Joseph E. Papelian Department of Police Detroit MI 48226; Dear Mr. Papelian: This is in response to your letter of November 9, 1976, asking whethe Federal regulations permit manufacturers to equip police vehicles with 'push bumpers' and with bullet-proof shields located between the front and rear seating compartments.; Standard No. 215, *Exterior Protection*, establishes requirements fo the impact resistance and the configuration of front and rear vehicle surfaces of passenger cars. This standard does not prohibit 'push bumpers' and manufacturers are free to equip passenger cars with any bumper design they choose as long as the requirements of Standard No. 215 are met.; Standard No. 205, *Glazing Materials*, specifies requirements fo glazing for use in motor vehicles, including the permissible locations for the various types of glazing. The standard permits bullet-resistant glazing to be used anywhere in a motor vehicle, provided such glazing meets specified performance requirements. Therefore, vehicle manufacturers are permitted to equip vehicles with the bullet-proof shields mentioned in your letter if such shields are constructed with glazing that conforms to the requirements in Standard No. 205.; You also asked whether the police department or a business coul install the equipment in question. If the equipment is installed after the first sale of the vehicle for purposes other than resale, the Federal safety standards would no longer be applicable under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1397(b)(1). However, S 108(a)(2)(A) prohibits, with one exception, manufacturers, distributors, dealers, and motor vehicle repair businesses from knowingly rendering inoperative a safety device or element of design that has been installed in compliance with a motor vehicle safety standard.; Therefore, whether or not a business could install the equipmen depends on the nature of the business. If the business is a 'motor vehicle repair business', it can only install the 'push bumpers' and shields if such installation does not knowingly render inoperative devices or elements of design installed in the vehicle in compliance with applicable safety standards. Section 108(a)(2)(A) defines 'motor vehicle repair business' as any person who holds himself out to the public as in the business of repairing motor vehicles or motor vehicle equipment for compensation.; I have enclosed copies of Standard No. 205 and Standard No. 215. I hav underscored the pertinent sections of Standard No. 205 (and the ANS Z26 standard incorporated by reference in Standard No. 205) for your information.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1135OpenMr. J. C. Eckhold, Director, Automotive Safety Office, Ford Motor Company, Dearborn, MI 48121; Mr. J. C. Eckhold Director Automotive Safety Office Ford Motor Company Dearborn MI 48121; Dear Mr. Eckhold: By petition for rulemaking dated November 15, 1973, the Ford Moto Company requested an amendment of Motor Vehicle Safety Standard No. 210 with respect to the strength required of the anchorages for the pelvic portion of a Type 2 seat belt assembly. After considering the merits of the requested amendment, we have decided to deny your petition.; As stated in your petition, the anchorages for the pelvic portion of Type 2 assembly are presently subject to two strength requirements under Standard 210. Section S4.2.2 provides that, when tested in conjunction with the upper torso anchorage, the pelvic anchorages must withstand a force of 3,000 pounds applied through the seat belt assembly. Section S4.2.1 provides that, when tested separately from the upper torso anchorage, the pelvic anchorages must withstand a force of 5,000 pounds applied through the seat belt assembly.; It is Ford's position that the 5,000 pound requirement of S4.2.1 wa intended to be applicable to anchorages used with Type 2 assemblies having detachable shoulder belts, and that it was not intended for use with integral Type 2 assemblies. Although the NHTSA would agree that the most widely used Type 2 assembly at the time of the standard's adoption had a detachable shoulder belt, the agency does not agree that the 5,000 pound requirement should be limited to anchorages used with such belts.; The 1974 model year will be the first in which integral Type 2 belt are installed in all passenger cars. We anticipate that a measurable percentage of persons riding in cars with the new belts will somehow avoid using the shoulder belt, thereby placing the lap belt under the same potential stress as any other lap belt when used by itself. In light of this possibility, and in consideration of the fact that keeping the pelvic anchorage force at the currently required level of 5,000 pounds will not impose additional manufacturing costs on manufacturers, we do not consider it advisable to grant the requested amendment at this time.; The petition of Ford Motor Company for an amendment of S4.2.1 of Moto Vehicle Safety Standard No. 210 and for a complementary amendment to the test procedures of S5.1 of the standard is therefore denied.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs; |
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ID: aiam3895OpenMr. Giorgio Kirchner, Segreteria Generale, Federazione Italiana Fuoristrada, 20131 Milano, Via Capranica, 4, ITALY; Mr. Giorgio Kirchner Segreteria Generale Federazione Italiana Fuoristrada 20131 Milano Via Capranica 4 ITALY; Dear Mr. Kirchner: This responds to your letter asking for information about U.S. Federa laws covering tires. For your information, I have enclosed a copy of a letter I sent to a Brazilian tire manufacturer last year, explaining all of the requirements which must be satisfied by a foreign manufacturer selling tires in the United States and enclosing copies of the pertinent regulations.; You stated that you were particularly interested in knowing th meanings and the corresponding values of identification symbols required to appear on sidewalls of tires subject to Standard No. 119. You listed as examples of symbols you were interested in load range and 'P.R.'; The load range is a letter between 'A' and 'N', with an A being th lowest load range and N being the highest. Load ranges are assigned to tires for use on motor vehicles other than passenger cars because such tires may have identical physical dimensions and, therefore, identical size designations, but widely differing load-carrying capabilities. To ensure that these ties are used only in situations where their load-carrying capability is sufficient, section S6.5(j) of Standard No. 119 requires a letter designating the load range to appear on the sidewall of each tire for use on motor vehicles other than passenger cars. If you are interested in learning the load-carrying capability of the load ranges assigned to a particular tire size, you should contact one of the standardization organizations listed in section S5.1(b) of the enclosed copy of Standard No. 119.; I believe that the symbol 'P.R.' refers to the ply rating for a tire The ply rating is an older system which performed the same function now served by the load range. Under the ply rating system, tires were rated from 2 to 24 plies, with the lower numbers indicating a less load- carrying capability. Standard No. 119 does *not* require that a ply rating appear on the sidewall of tires. I have enclosed a copy of a page from the most recent yearbook published by the American standardization organization, the Tire & Rim Association, which shows how to convert a ply rating to the appropriate load range.; If you need further information or have any questions on the enclose materials, please feel free to contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: 07-000305asOpenMr. Russ Hunt Sr. Vice President Snider Tire Inc. P.O. Box 16046 Greensboro, NC 27416-6046 Dear Mr. Hunt: This responds to your letter asking several questions about the requirements of the National Highway Traffic Safety Administration (NHTSA) for sidewall markings for retreaded tires for buses. Your questions are answered below. It might be helpful to begin with background information. NHTSA is authorized to issue Federal Motor Vehicle Safety Standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipment (see 49 U.S.C. Chapter 301, National Traffic and Motor Vehicle Safety Act). NHTSA does not provide approval of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to self-certify that their products conform to all applicable safety standards that are in effect on the date of manufacture. NHTSA selects a sampling of new vehicles and equipment each year to determine their compliance with applicable FMVSSs. If our testing or examination reveals an apparent noncompliance, we may require the manufacturer to remedy the noncompliance, and may initiate an enforcement proceeding if necessary to ensure that the manufacturer takes appropriate action. There is no FMVSS applicable to retreaded tires for vehicles other than passenger cars. However, 49 CFR Part 574 (hereinafter Part 574) is applicable to retreaded tires for vehicles other than passenger vehicles, including buses. Part 574 was issued to facilitate notification of safety recalls to purchasers of defective or nonconforming tires, pursuant to Sections 30118 and 30119 of Title 49, United States Code. Part 574 requires each tire sold in the United States, including retreaded tires, to be labeled with a Tire Identification Number (TIN) in order to facilitate a recall in the event of a defect or noncompliance. Under section 574.5 paragraphs (a) through (d), each TIN consists of: (a) the manufacturers or retreaders identification mark, (b) the tire size symbol, (c) manufacturers optional code, and (d) the date code; i.e., the week and year of manufacture. With respect to your question about maximum load and inflation pressure, no regulation requires retreaded tires (other than those for passenger cars) to show this information. Furthermore, Part 574 requires that manufacturers shall record and maintain the name and address of the tire seller and the tire purchaser, as well as the TIN.[1] The collection of this information ensures that tire purchasers can be notified in the event that a tire they have purchased is recalled. This requirement applies to manufacturers and brand name owners of new and retreaded motor vehicle tires.[2] [emphasis added]. With that background in mind, I turn now to your specific questions. In instances where you have referred to tires, we have interpreted this to mean tires for use in vehicles other than passenger cars, as you stated these tires were for use in buses. (Pneumatic tires for use in passenger vehicles are regulated under FMVSS No. 117, Retreaded Pneumatic Tires, and the following answers are not applicable to those tires.) 1. In the bead to bead retreading process, using a carcass that was certified to FMVSS 119 when the tire was new, must the retreader replace all markings required by FMVSS No. 119 for the original new tire? Our answer is no. In the bead to bead retreading process, as you state, the entire exterior surface is mechanically buffed, which completely removes the surface layer of the tires and all tire markings and labelings. The retreaded tire is not subject to FMVSS No. 119, or to any other FMVSS. Accordingly, a retreader of tires for use other than in passenger cars is not required to mark the tire as specified by FMVSS No. 119. However, under 49 CFR 574.5, a retreader must mark the sidewall with a TIN. According to that section, each tire manufacturer[3] must conspicuously label on one sidewall of each tire it manufactures, by permanently molding into or onto the sidewall, a TIN containing the following four pieces of information, paraphrased from section 574.5 paragraphs (a) through (d): (a) Three symbols representing the retreaders assigned identification mark. (b) Two symbols identifying the retread matrix in which the tire was processed or a tire size code if a matrix was not used to process the retreaded tire. Each retreader shall maintain a record of each symbol used, with the corresponding matrix or tire size and shall provide such record to NHTSA upon written request. (c) At the option of the manufacturer, up to four symbols as a descriptive code for the purpose of identifying significant characteristics of the tire. Each retreader shall maintain a detailed record of any descriptive or brand name owner code used, which shall be provided to NHTSA upon written request. (d) Four symbols identifying the week and year of manufacture.[4] It should be noted that section 574.5 specifically anticipates the fact that tire sidewall information may be removed from the sidewall during the retreading process. Section 574.5 reads, in part: The DOT symbol shall not appear on tires to which no Federal Motor Vehicle Safety Standard is applicable, except that the DOT symbol on tires for use on motor vehicles other than passenger cars may, prior to retreading, be removed from the sidewall or allowed to remain on the sidewall, at the retreaders option. 2. When a tire has been retreaded using the bead to bead process, must all required marking be accurately reproduced onto the retreaded tire? Our answer is no. We do not require information to be reproduced on the retreaded tire. However, as discussed above, the retreader must mark the retreaded tire with an appropriate TIN. Questions 3 and 4 will be answered together. 3. Is there a safety issue if on a new tire the load values marked are incorrectly overstated and/or the pressure values are incorrectly understated as referenced by the manufacturer and in the standards of FMVSS 119?
4. Is there a safety issue on a tire retreaded by the bead to bead process if the load values are incorrectly overstated and/or the pressure values are incorrectly understated with reference to the tire standards of FMVSS 119? For both questions three and four, there are potential safety issues if the load values marked are incorrectly overstated and/or the pressure values are incorrectly understated. If the tire is loaded to the incorrectly marked level, it could result in the tire overheating, tread separation, or even a tire blowout. Maintaining proper tire pressure and not overloading tires are important measures for driving safety. 5. Is leaving the markings as is on correctly marked carcasses, as we do as normal process on all top cap retreads, legal under DOT/NHTSA laws and regulations? As there is no FMVSS regulating markings on retreaded tires (for vehicles other than passenger cars), it is legal to leave the markings as is. However, the tire retreader must still mark the retreaded tire with a TIN and keep all appropriate records, as discussed above. See also our answer to question 6. 6. Is leaving the markings as is on these incorrectly marked retreaded tires, as we do as normal process on all top cap retreads, legal under DOT/NHTSA laws and regulations? If not, please cite laws and regulations violated and recommend corrective action. Based on the circumstances you described, although it does not appear that Snider would be violating a Federal Motor Vehicle Safety Standard if it left the incorrect markings on the retreaded tires, we could use our defect authority to address safety problems resulting from the marked tires. The mislabeling you describe could result in serious safety issues. In your letter, you state that the markings on the tire indicate that the max tire loads are labeled substantially higher than this class of tire is actually rated to handle. As you stated, this tire is rated at 5,205 lbs at 110 PSI (single load application), and 4,805 lbs at 100 PSI (dual load application). The markings, however, indicate that the tire is rated at 6,045 lbs at 105 PSI single (840 lbs above the actual maximum rating) and 5,300 lbs at 95 PSI dual (495 lbs above the actual maximum rating). Using this tire under these conditions would both overload and underinflate the tire, leading to possible tire blowouts and severe accidents. Whether such a condition would constitute a safety-related defect would depend on a thorough review of its frequency and the risks involved. In view of the safety problems that could result from tires that are marked differently than their performance capability, you may not wish to leave unsafe markings on the tires, as these could cause consumers to use the tires in an unsafe manner. NHTSA could pursue unreasonable safety risks associated with the markings as part of our defect authority. Under the Vehicle Safety Act, manufacturers are responsible for notifying purchasers of defective equipment and remedying the problem free of charge. Any manufacturer which fails to provide notification of or remedy for a defect is also subject to substantial civil penalties (see 49 CFR 578.6). You may also be subject to liability under State tort law, so we suggest that you consult with a private attorney and/or insurance carrier. Questions 7-9 relate to issues of who is liable in the event of damage, injury, or death arising from incorrectly marked retreaded tires. As noted above, these questions fall outside the purview of NHTSA Chief Counsel, and should be discussed with your private attorney. 10. Should end users be concerned about being able to identify tires that have been retreaded in the Bead to Bead process in the event of a recall by the original manufacturer of the casing if the original casing was certified to FMVSS 119? (There is not enough information to identify the casing as a recall tire.) With regard to retreaded tires, you are concerned that an end-user may not be able to identify the tire as a recalled model because of the lack of identifying markings. End-users should always be aware of safety recalls, and should contact the tire manufacturer if there is a question about whether the end-users tires were recalled. In addition, the information collected pursuant to Part 574 should enable the manufacturer to contact the purchaser in the event that the end-users tires are recalled. We hope that we have answered your questions. If you require additional clarification, please contact Ari Scott of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel ref:119 d.10/29/07 [1] See 49 CFR 574.7(a)-(b). [2] Id. [3] A person who retreads tires is considered to be a manufacturer under the Vehicle Safety Act. The retreading process involves significant manufacturing operations, which do not differ substantially from those of manufacturing new tires. See letter to Frank S. Perkin, Esq., Jan 22, 1988. [4] Section 574.5 also provides the option of using a laser to etch the information is paragraph (d) rather than permanently molding the information onto the tire sidewall. |
2007 |
ID: nht91-7.3OpenDATE: November 7, 1991 FROM: Takashi Odaira -- Chief Representative, Emission & Safety, Isuzu TO: P. J. Rice -- Chief Counsel, NHTSA COPYEE: Mr. Sakai; Mr. Watanabe TITLE: Test Conditions - Side Impact (FMVSS 214) ATTACHMT: Attached to letter dated 1/14/92 from Paul Jackson Rice to Takashi Odaira (A39; Std. 214) TEXT: The purpose of this letter is to seek your agency's interpretation about the test conditions specified in FMVSS 214, Side Impact Protection. S3. (b), (c) and (d) of FMVSS 214 specify passenger cars whose rear seating areas are so small that the rear seat requirements do not apply. However, when such passenger cars are subjected to dynamic side impact test, is it necessary to place a test dummy on their rear seating positions? I would appreciate receiving your quick response to this question. |
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ID: nht90-2.37OpenTYPE: INTERPRETATION-NHTSA DATE: 05/01/90 FROM: BRAD MAGOR TO: DEPARTMENT OF TRANSPORTATION OFFICE OF VEHICLE SAFETY COMPLIANCE ENFORCEMENT TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/28/90 FROM PAUL JACKSON RICE -- NHTSA TO BRAD G. MAGOR; A35; PART 591 TEXT: We are moving back to the States (S.C.) from Canada in the near future. Ideally, we would like to buy a truck or van up here to help us with our move, though we don't want to get stuck with a vehicle that we can't use or eventually sell in the States. C ould you give us any information on what features cars or trucks require to meet U.S. safety standards. Do you know if Canada or Canadian cars generally have these items. Thank you very much for this information and your assistance. |
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ID: 08-006170as congressionalOpenThe Honorable Russell D. Feingold United States Senate Washington, DC 20510 Dear Senator Feingold: Thank you for your letter on behalf of your constituent, Bob Fraik, regarding his sons electric car. Information provided with your letter indicated that his son has developed an electric vehicle and would like the Federal regulation on low speed vehicles to be changed from 25 mph to 35 mph. We appreciate the opportunity to discuss this issue. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards (FMVSS) that set performance requirements for new motor vehicles and items of motor vehicle equipment (49 U.S.C. Chapter 301). Chapter 301 provides that a person may not "manufacture for sale, sell, offer for sale, introduce or deliver for introduction in interstate commerce, or import into the United States" any new motor vehicle or new item of motor vehicle equipment unless the vehicles or equipment are certified to comply with all applicable safety standards. NHTSA has used its authority to, among other things, establish a special category of motor vehicles called low speed vehicles (LSVs). This was done in part to accommodate the use of small golf cars as personal transportation vehicles in controlled, low-speed environments, such as retirement communities. In order to qualify as an LSV under the agencys definition,[1] a vehicle must, among other things, have a speed capability no higher than 25 mph and a gross vehicle weight rating of less than 3,000 pounds. LSVs are subject to a limited set of safety requirements, including ones related to the installation of lamps, mirrors, seat belts and a windshield. However, LSVs are not subject to most of the occupant protection standards with which other light vehicles such as passenger cars are required to comply, including many of our standards designed to protect occupants in the event of a crash. NHTSA recently considered and denied petitions requesting that the agency commence rulemaking to create a new class of motor vehicles known as medium speed vehicles, which would have a maximum speed capability of 35 mph. The petitioners contemplated Page 2 The Honorable Russell D. Feingold that these vehicles would be subject to a set of safety standards greater than those that apply to LSVs but substantially less than the full set of safety standards that apply to other light vehicles such as passenger cars. We denied the petitions (copy enclosed) because it is our belief the introduction of such a class of motor vehicles without the full complement of safety features required for other light vehicles would result in significantly greater risk of deaths and serious injuries. As we discussed in that notice, vehicles with a speed capability above 25 mph are more likely to be driven outside controlled, low speed environments, and the limited LSV safety requirements are not appropriate for such vehicle operation. Moreover, the traffic environment in which medium speed vehicles would likely travel, including, e.g., urban roads with a speed limit of 35 mph or 45 mph, is an environment for which the full set of the Federal motor vehicle safety standards is needed to prevent fatalities and serious injuries. I would like to note that there is intense work all over the world to develop and bring to market hybrid vehicles, battery-powered vehicles, and many other types of low-fuel consuming vehicles. Some are available now and other more advanced vehicles, according to the manufacturers, will be available by the 2010 model year. These vehicles, which are available to U.S. consumers, are certified to meet all the required safety standards. If you have any questions, please have your staff contact me or Stephen R. Kratzke, Associate Administrator for Rulemaking, at (202) 366-1810. Sincerely yours, James F. Ports, Jr. Enclosure ref:500 d.12/30/08 |
2008 |
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.