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: aiam2682OpenMr. Donald H. Carter, 300 W. 11th Street, Reno, Nevada 89503; Mr. Donald H. Carter 300 W. 11th Street Reno Nevada 89503; Dear Mr. Carter: This is in response to your letters of August 24, 1977, and October 8 1977, concerning your Ford F-150 pickup truck.; The November 1976 date on your truck's certification label refers onl to the date of actual manufacture of the vehicle, not its model year. Virtually all manufacturers, including Ford, utilize a model year which does not correspond to the calender year. Typically, for American manufacturers, this model year begins on September 1 of the previous calender year, i.e., model year 1977 began on September 1, 1976. Manufacturers usually begin manufacture of their vehicles as early as July in order to have sufficient vehicles in their showroom by September start of the model year.; All Federal motor vehicle safety standards specify a date on whic their requirements become effective. Thus, the manufacturer must indicate by the certification label that its vehicles are in compliance with all Federal standards in effect on the date of the vehicles' manufacture. Whether a vehicle is marketed as a particular model year vehicle depends upon the manufacturer's own marketing practice. the certification date does not represent the model year date.; Finally, your first letter stated that your vehicle was ordered o November 4, 1976, with a 3 month delivery interval. Every manufacturer produced a large number of vehicles before there are orders for a specific vehicle, and maintains them in various storage locations around the country. When the manufacturer receives and order from a dealership for a specific vehicle, it will first determine whether it already has such a vehicle in stock, and if it does, it will ship that vehicle rather than specially manufacture a new vehicle.; However, if there is no identical vehicle in stock, it wil manufacturer one specifically for that order, which can take from a few days to several months to program into the assembly line and produce. As a dealership has no way to know in advance whether the vehicle it ordered is in stock or will have to be specially manufactured, it will often state a delivery date that anticipates the longest possible delay which would result from special manufacture. There is thus no reason for concern over the fact that your vehicle was manufactured in the same month it was ordered. Either Ford had such a vehicle in stock, or it was able to manufacture one with very little delay.; I hope that this letter has answered your concerns. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1807OpenMr. Thomas S. Pieratt, Jr., Executive Director, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Director Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This responds to the Truck Equipment and Body Distributors Associatio February 6, 1975, petition to amend Standard No. 121, *Air brake systems*, by exempting completed vehicles permanently from S5.3.1 of the standard (stopping distance) and until March 1, 1976, from S5.3.3 and S5.3.4 (actuation and release), if they have been 'certified' to these requirements as incomplete vehicles. You base this request on the commercial desirability of modifying the standard brake system on incomplete vehicles to accommodate additional axles, modification of the wheelbase, or installation of accessories. You conclude that testing of each modified vehicle would be involved in certification to the standard, and that such a burden is unreasonable.; We do not believe that a delay in the application of S5.3.1, S5.3.3 and S5.3.4 of Standard No. 121 to multi-stage vehicles would be advisable. As you know, the agency did consider postponing the standard in December, and decided against it based partly on information indicating that such a last-minute delay would be disruptive and wasteful. The conclusion would be even more valid today. Since the standard applies only to completed vehicles, it could not be suspended for completed vehicles as you suggest with the chassis still required to comply. Even if this were possible, it might cause anomalous and even hazardous results, since the final-stage manufacturers could disregard any design cautions of the chassis manufacturers, and could remove or disable portions of the chassis brake systems. Furthermore, even a complete delay in the standard with respect to the classes of vehicles with which you are concerned would probably not accomplish your purpose, since the chassis manufacturers could not be expected to produce chassis conforming to the standard with accompanying documentation, during the period of delay.; With regard to testing, your assumption that each vehicle must b road-tested following modification of the braking system may not be correct. For example, your members could establish categories of models which share a common brake system modification, and certify them all on the basis of tests on the most adverse configuration in the category. Alternatively, joint testing might be undertaken with a major supplier of brake and axle components. In the case of standard models, your members might be able to rely on the supplier's warranty of his products' capacities.; Neither of these methods would require road testing of each vehicl manufactured, nor would every model have to be road tested. A manufacturer must simply satisfy himself in the exercise of due care that the vehicle is capable of meeting the stopping performance requirements if it were tested by the NHTSA. What constitutes due care in a particular case depends on all relevant facts, including such things as the time to elapse before a new effective date, the availability of test equipment to small manufacturers, the limitations of current technology, and above all the diligence evidenced by the manufacturer.; Accordingly, your petition for delay of Standard No. 121 is denied. Yo and your members may be assured that, within the limits of the law, this agency will be understanding in its approach to problems experienced by intermediate and final-stage manufacturers as they bring their vehicles into conformity with the new standard.; Sincerely, James B. Gregory, Administrator |
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ID: aiam0715OpenMs. Hope C. Kocher, Secretary, International Houseing Incorporated, 32 West Penn Avenue, Cleona, PA 17042; Ms. Hope C. Kocher Secretary International Houseing Incorporated 32 West Penn Avenue Cleona PA 17042; Dear Ms. Kocher: This is to acknowledge your letter of May 19, 1972, regarding tir identification and recordkeeping.; Regulation Part 574 requires a vehicle manufacturer to maintain record of tires on each vehicle shipped to a dealer and requires that he maintain a record of the name and address of the first purchaser of the vehicle for a period of three years. The purpose, of course, is to enable him to locate tires in the event of a recall. The name and address of the purchaser is provided by the dealer. The manufacturer is not required by the regulation to record each identification number for each tire, but may do so by group or category. There is a strong possibility that all tires on one vehicle will be of the same brand and will have the same identification number. The manner in which a manufacturer chooses to maintain the tire records is optional and the dealer would be expected to cooperate in his system of recording data. It is primarily a matter of agreement between manufacturer and dealer.; In the event the original tires on a vehicle are changed by the deale prior to sale, he must report the new tire identification numbers and the purchaser's name and address to the manufacturer of the tires sold with the vehicle.; We note that your letter refers to registration of *serial* numbe rather than *identification* number. It is the latter that is subject to the regulation.; We trust this information answers your questions. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam2728OpenMr. Kenneth R. Brennan, Mobile Equipment Division, Hendrickson Mfg. Co., 8001 West Forty-Seventh Street, Lyons, IL 60534; Mr. Kenneth R. Brennan Mobile Equipment Division Hendrickson Mfg. Co. 8001 West Forty-Seventh Street Lyons IL 60534; Dear Mr. Brennan: This responds to your November 21, 1977, letter asking whether a schoo bus that is propelled by a propane-fueled engine is required to comply with Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity* (49 CFR 571.301-75).; Paragraph S3 of Safety Standard No.301-75 specifies that the standar applies to school buses that have gross vehicle weight ratings greater than 10,000 pounds and use fuel with a boiling point above 32 degrees F. Since the boiling point of propane is below 32 degrees F, Safety Standard No. 301-75 would not be applicable to a school bus propelled by a propane engine.; Please contact us if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5517OpenAllen F. Brauninger, Esq. Office of the General Counsel Consumer Product Safety Commission Washington, D.C. 20207-0001; Allen F. Brauninger Esq. Office of the General Counsel Consumer Product Safety Commission Washington D.C. 20207-0001; "Dear Mr. Brauninger: This responds to your letter asking whether window shade intended for use on an automobile is motor vehicle equipment. I apologize for the delay in sending this letter. From the materials you sent us, we assume that you are referring to the roll-down shades that suction onto the rear side window of vehicles, usually for the purpose of keeping the sun off the faces of children strapped into child safety seats. The answer to your question is yes. The window shades are an accessory (a type of motor vehicle equipment) under 49 U.S.C. 30102(a)(7). As explained in my September 16, 1994, letter from this office to Mr. Harleigh Ewell of your office, the National Highway Traffic Safety Administration (NHTSA) uses two criteria in determining whether a device is an 'accessory.' The two criteria are whether: (1) A substantial portion of its expected uses are related to the operation or maintenance of motor vehicles, and (2) it is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. Applying these criteria to the window shades, we conclude that they are accessories. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. We assume that the window shade you are referring to has packaging that shows that its purpose is to shield vehicle occupants from the sun while the vehicle is in operation. The shade would typically be acquired and used by ordinary users of motor vehicles (i.e., anyone using the vehicle). Since the shade satisfies both criteria, it is considered to be an 'accessory' and thus motor vehicle equipment. NHTSA has issued no safety standards that apply specifically to window shades that are sold separately from the vehicle. However, as you know, manufacturers of motor vehicle equipment are responsible under our statute for ensuring that their products are free of safety-related defects. If you will send us the information you have regarding the incidence of accidents caused by these window shades, we will forward it to the appropriate NHTSA office. I hope this information is helpful. If you have any further questions, please feel free to contact Mr. Paul Atelsek at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Acting Chief Counsel"; |
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ID: aiam5002OpenThe Honorable Phil Gramm United States Senate 2323 Bryan Street, #1500 Dallas, Texas 75201; The Honorable Phil Gramm United States Senate 2323 Bryan Street #1500 Dallas Texas 75201; "Dear Senator Gramm: Thank you for your letter on behalf of you constituent, Mr. Frank Sonzala, Senior Vice President of International Transquip Industries (ITI), regarding Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems. ITI is a manufacturer of air brake systems and is apparently having difficulty selling its product to vehicle manufacturers because of a compliance issue related to Standard No. 121. The National Highway Traffic Safety Administration's Chief Counsel, Paul Jackson Rice, reviewed Mr. Sonzala's concerns, and I am pleased to provide you the following information. By way of background information, NHTSA issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, the Safety Act requires manufacturers to certify that their vehicles or equipment comply with applicable safety standards. Standard No. 121 specifies braking requirements for vehicles equipped with air brake systems. The purpose of the standard is to ensure safe braking performance under normal and emergency conditions. The standard applies only to motor vehicles and not to motor vehicle equipment. Therefore, vehicle manufacturers are responsible for ensuring compliance with the standard, and not brake equipment manufacturers such as ITI. The dispute between ITI and the vehicle manufacturers (ITI uses the term 'original equipment manufacturers') relates to the standard's parking brake requirements. The specific requirement at issue, set forth at S5.6 of Standard No. 121, requires a vehicle's parking brake to meet certain grade holding requirements (or other equivalent requirements) with 'any single leakage-type failure' of certain parts, including service brake chamber diaphragms. The purpose of this requirement is to ensure that a driver can safely park his or her vehicle in the event of a leakage-type failure in the service brake system. Leakage- type failures include such things as ruptured or severed brake hoses and torn diaphragms. Since these types of failures are relatively common in air brake systems, NHTSA believes that it is important that drivers be able to safely secure heavy trucks and other vehicles with such failures, until the vehicles can be repaired. For the purpose of determining whether a vehicle can meet Standard No. 121's grade holding requirements with one particular leakage-type failure, a failed diaphragm, ITI would like the standard to be interpreted to cover only a very limited and specific type of failure, i.e., a hole 1/8 inch in size located in a particular place. ITI states that the vehicle manufacturers generally have a broader view of what constitutes a failed diaphragm, i.e., they believe that failures include holes larger than 1/8 inch. ITI argues that Standard No. 121 is ambiguous in this area and requests NHTSA to issue an interpretation supporting its position. After consulting with NHTSA's Chief Counsel, we can state that the vehicle manufacturers are correct in their understanding that a failed diaphragm is not limited to a diaphragm with a 1/8 inch hole. Therefore, if a vehicle cannot pass Standard No. 121's grade holding test with a larger hole in a failed diaphragm, the vehicle manufacturer cannot certify that the vehicle complies with the standard. Further, we disagree with ITI's contention that Standard No. 121 is ambiguous as to what constitutes a failed diaphragm. As indicated above, Standard No. 121 specifies that the grade holding requirements must be met with any single leakage-type failure of certain parts, including a failed diaphragm. The usage of the term 'any,' when used in connection with a set of items, is specifically defined at 49 CFR 571.4 as meaning the totality of that set of items, any one of which may be selected by the Administration for testing. Thus, a vehicle must meet the grade holding requirements regardless of the extent of the failure selected by NHTSA for testing. We note that leakage-type failures of many types and sizes can occur in vehicle brake systems. NHTSA intentionally did not limit the size or location of such failures in developing this requirement to ensure that a vehicle has adequate grade holding performance regardless of the specific nature of such a failure. ITI also asked whether other broken components, such as heavy parking springs, brake shoes, linings, and drums should be part of Standard No. 121's test requirements, since diaphragms are tested when torn. Although NHTSA's brake standards do not have any express test requirements for broken parking springs, brake shoes, linings or drums, those standards include a number of requirements to ensure adequate braking performance in the event of various failures in a vehicle's brake system. We hope that this information is helpful. Sincerely, Frederick H. Grubbe Enclosure: Constituents Correspondence cc: Washington Office"; |
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ID: aiam0200OpenMr. F. Michael Petler, Product Equipment Coordinator, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, CA 90607; Mr. F. Michael Petler Product Equipment Coordinator U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs CA 90607; >>>Re: Request for Interpretations by Suzuki<<< Dear Mr. Petler: This is in reply to your letter of October 13, 1969, requestin confirmation of your interpretation of certain Federal Motor Vehicle Safety Standards and regulations, and further asking whether or not certain other areas of (motor) vehicle performance are presently regulated under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1391 *et seq*.).; In your letter you state that your request results from the fact tha Suzuki is considering the production of a multipurpose passenger vehicle for export into the United States sometime in 1970, and attach a sketch of this vehicle. The vehicle represented by the sketch, however, appears to be a truck, and not a multipurpose passenger vehicle. 'Multipurpose passenger vehicle' is defined in the regulations (49 CFR 371.3(b)) as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' 'Truck' is defined to mean (49 CFR 371.3(b)) 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special equipment.' The distinction between a truck and multipurpose passenger vehicle, therefore, is whether the vehicle is designed primarily to carry persons or property. The sketch you enclose is of a vehicle designed to carry property, and for this reason I have answered your questions with reference only to trucks. Your questions are repeated below, with our replies following them:; *Subject No. 1* - Glazing Requirements - Rear Windows 1.>>>'We understand it would be permissible to use a fabric soft to with no rear window if an outside mirror was installed on the right side of the vehicle.'<<<; You are correct in saying you may use a fabric soft top with no rea window. Federal Motor Vehicle Safety Standard No. 205 specifies glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses. It does not require a rear window or the use of glazing material therein. If a rear window is installed, however, the referenced United States of America Standards Institute 'American Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' ASA Standard Z26.1-1966, July 15, 1966, specifies the types of material which must be used.; There are no National Highway Safety Bureau requirements for mirrors o trucks.; 2.>>>'We understand it would be permissible to use a fabric soft top with an open section in the back, utilizing no installation of glazing material, but just an open area which would permit viewing to the rear using the inside rear view mirror.'<<<; Your understanding is correct. As stated before, Standard No. 205 doe not require the use of glazing material.; 3.>>>'We understand it would be permissible to use a fabric soft top using a rear window such as found in the tops of convertible automobiles, in which the rear window's composition has utilized a ASA plastic material conforming to Z26.1-1966 regulations.(sic); 'If this is correct we would appreciate being informed which plasti materials can be utilized.'<<<; That is incorrect. The criterion for 'a rear window such as found i convertible automobiles' is inappropriate for trucks. The only plastics which may be used in trucks are AS4 and AS5, rigid plastics, and then only 'where other means to afford visibility of the highway' are provided.; 4.>>>'We understand it would be permissible to use a fabric soft top using a rear window such as found in the tops of convertible automobiles, in which the rear window's composition has utilized a ASA safety glass material conforming to Z26.1- 1966 regulations.(sic); 'If this is correct we would appreciate being informed which safet glass materials can be utilized.'<<<; As indicated in our comment to number 3 above, the criterion for rea window glizing (sic) used in convertible automobiles is inappropriate for trucks. ASA Standard Z26.1-1966 allows the use of Items 1, 2, 3, 8, 9, 10, and 11 glass in the rear window of trucks. Item 3 or 9 glass may only be used, however, 'where other means to afford visibility of the highway' are provided.; *Subject No. 2* - Gross Vehicle Weight >>>'It is our understanding that, at present, there is no requiremen that a manufacturer attach a label to the vehicle stating the gross vehicle weight of . . . [trucks] in the weight category of 2,000 lbs. or less.'<<<; Your understanding is correct. The National Highway Safety Bureau doe not presently have a requirement for gross vehicle weight labeling.; *Subject No. 3* - Fuel Tank Requirements >>>'It is our understanding again that there is no present Federa Motor Vehicle Safety Standard pertaining to gas tanks on . . . [trucks]. I understand that there may be future standards implemented in the near future regarding this subject.'<<<; Your understanding is correct. Federal Motor Vehicle Safety Standar No. 301, 'Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections - Passenger Cars', applies to only passenger cars at this time. Docket No. 3-2 (F.R. 14282), currently under consideration, contemplates extending the requirements of Standard No. 301 to multipurpose passenger vehicles, trucks, buses and motorcycles.; *Subject No. 4* - Vehicle Noise Level >>>'It is our understanding that, at the present time, there is n special noise level requirements pertaining to . . . (sic)trucks]. We would appreciate your comments as to any future standard presently under discussion regarding this subject.'<<<; Your understanding is correct. There are no Federal requirements o proposals at present concerning vehicle noise level, (sic) There are states and municipalities, however, that have requirements concerning this subject.; *Subject No. 5* - Speedometer Error >>>'There are several questions we have regarding this subject. 1. Is there a stipulation regarding allowance of percentage o speedometer error.; 2. Would it be considered the manufacturer's responsibility fo speedometer error in case the user or person was to change the tire size.'<<<; There are presently no Federal requirements concerning speedometers. substantial speedometer error resulting from a reasonable tire size change might be considered a safety related defect for which the manufacturer would be responsible.; *Subject No. 6* - Special Label for Non-Conforming Vehicle Entry Int The United States; >>>'I would like to confirm the following information regarding th placement of a special label to be placed on the inside of the vehicle's windshield so that it is readable from the outside of a vehicle being imported into the United States. This would be placed on a vehicle that does not have the required Federal Motor Vehicle Safety Standard items readily attached in their respective place on the vehicle.(sic); 'It is my understanding, for instance, that if the outside rear vie mirror was not attached to the vehicle, but packaged in a box to prevent damage or pilferage while in transit to the United States, that in such a case a label would be required to be attached to the vehicle stating essentially the following message.; THIS VEHICLE DOES NOT CONFORM TO FEDERAL MOTOR VEHICLE SAFETY STANDAR NO. 111 BECAUSE THE OUTSIDE REAR VIEW MIRROR HAS NOT BEEN ATTACHED FOR THE CONVENIENCE OF SHIPMENT. THIS VEHICLE WILL BE BROUGHT INTO CONFORMITY BY ATTACHMENT OF THE OUTSIDE REAR VIEW MIRROR BEFORE IT IS OFFERED FOR SALE TO THE FIRST PURCHASER FOR THE PURPOSE OF RESALE.(sic); 'If we have interpreted this requirement correctly would you pleas advise us of the full requirements for this label. It is also our understanding that at the time of importation of these vehicles the importer would be required to submit in duplicate the Federal Highway Administration Form Number HS-7.'<<<; Your interpretation of the above is correct. A label such as you hav described, used in conjunction with the certification label required in 49 CFR 367, would meet the requirements. Your understanding regarding the HS-7 form is also correct.; We trust this will clarify the situation for you. Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service; |
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ID: aiam2397OpenMr. Frank Tedesco, President, Lifetime Foam Products, Inc., 3001 Cullerton Drive, Franklin Park, IL 60131; Mr. Frank Tedesco President Lifetime Foam Products Inc. 3001 Cullerton Drive Franklin Park IL 60131; Dear Mr. Tedesco: This responds to your September 10, 1076, request for approval from th National Highway Traffic Safety Administration (NHTSA) for certification of 'consumer-installed seating accessories' to Standard No. 207, *Seating Systems*, by means of bench testing.; Standard No. 207 and the statute under which it is authorized (Th National Traffic and Motor Vehicle Safety Act (the Act), 15 U.S.C. S 1381, *et* seq.) do not permit the assistance you request. The Act requires 'self-certification' by manufacturers that their products comply with applicable standards (15 U.S.C. S 1403). The NHTSA does not 'approve' compliance tests for this reason.; Also, Standard No. 207 applies only to vehicles, and most of th requirements of the standard must be conducted with the seating as it is installed in the vehicle. For example, the application of force to the seat in the forward and rearward directions (S4.2) measures the seat's structural strength and its attachment to the vehicle. Your seating systems are subject to these requirements only if they are installed in a vehicle prior to its first sale for purposes other than resale.; While we are unable to provide the 'approval' you requested, we suppor your intention to ensure that the structure of your products conforms to existing requirements for motor vehicle seating as set forth in Standard No. 207. Although it appears that you are familiar with the requirements of Standard No. 207, I have enclosed an information sheet that explains where copies of the motor vehicle safety standards may be obtained.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5452OpenVictor Larson, P.E. Cryenco, Inc. 3811 Joliet Street Denver, CO 80238; Victor Larson P.E. Cryenco Inc. 3811 Joliet Street Denver CO 80238; "Dear Mr. Larson: This responds to your FAX of May 17, 1994, wit reference to the application of conspicuity material to the sides of cryogenic tank trailers. You point out that the only side mounting surface for striping that is perpendicular to the road is at the center of the tank, approximately 90 inches above the road surface. You ask for confirmation of your interpretation that conspicuity material can be placed at this location 'if that is the only available mounting area' and that it is not necessary to add additional structure for the sole purpose of providing a lower vertical mounting surface. We confirm your understanding. Standard No. 108 specified an original mounting height for conspicuity material as close as practicable to 1.25 m. However, in a notice published on October 6, 1993, NHTSA amended the requirement to 'as close as practicable to not less than 375 mm and not more than 1525 mm above the road surface.' The practicability qualification allows manufacturers to choose a location for conspicuity treatment that is outside the specified range to avoid body modifications that might otherwise be required to mount the material within the specified range. The manufacturers of conspicuity material certify its performance in a vertical plane. Trailer manufacturers should mount the material in a vertical plane or as close to a vertical plane as the trailer shape offers, in order to achieve the full conspicuity benefits of the material. In the case of your tank trailer without a suitable vertical surface below the belt line of the tank, reflective material at a belt line that is 90 inches above the road surface would be considered to have been mounted as close as practicable to the upper specification of the height range (1.525 m). As NHTSA observed when it adopted the original mounting height specification with its practicability provision, flexibility in the vertical location of conspicuity material is necessary for compliance of some tank trailers. However, it should not be overlooked that other types of tank trailers may have vertical surfaces on the frame, fenders, or other equipment well suited for conspicuity material. You inform us that some trailers have rear and midship cabinets that could be used, in conjunction with the belt line location, to provide a location for striping, although this would result in a non-aligned striping pattern. With respect to trailers equipped with cabinets, you asked whether compliance would be satisfied if only the belt-line location is used. The answer is yes, provided that the requirement of paragraph S5.7.1.4.2(a) is met, i.e., which provides that 'the strip need not be continuous as long as not less than half of the length of the trailer is covered and the spaces are distributed as evenly as practicable.' Since the strip need not be continuous, this would allow discontinuities in a strip mounted at 90 inches in which the cabinets were not used. Your final question is the required orientation of striping for conspicuity, some of your customers have requested placement of material at a downward angle of approximately 30 degrees to accommodate their graphics better. The standard does not explicitly address the issue of orientation. However, as noted in response to your first question, trailer manufacturers should mount conspicuity material in a vertical plane, or as nearly thereto as the trailer shape allows, so that the full conspicuity benefits of the material may be realized. If there is no available vertical surface on which the material can be mounted, we urge that a wider stripe of conspicuity material be used to provide the minimum required performance at the installed downward angle. The manufacturer of the conspicuity material which you use should be able to determine whether an increase in the width of the striping would allow the material mounted at or near the downward angle that your customer prefers to provide performance comparable to a narrower strip mounted in a vertical plane. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam1942OpenMr. Donald W. Segraves, Vice President, American Mutual Insurance Alliance, 20 North Wacker Drive, Chicago, IL 60606; Mr. Donald W. Segraves Vice President American Mutual Insurance Alliance 20 North Wacker Drive Chicago IL 60606; Dear Mr. Segraves: This is in response to your letter of May 9, 1975, expressing you opposition to any bumper requirement that would permit the elimination of the energy absorbers from motor vehicle bumper systems.; Your letter refers to a statement made by Mr. James Schultz in a May 7 1975, letter responding to your request for information concerning the cost-benefit trade-off involved in permitting damage to the bumper face bar components and associated fasteners. Mr. Schultz's comment that 'the proposed schedule for implementation of the surface damage criteria would not effect a lowering of the current level of bumper performance' was directed only at the exterior surface damage provisions which are proposed as part of a Part 581 damageability standard under the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513).; With regard to the provisions of Standard No. 215, *Exterio Protection*, the National Highway Traffic Safety Administration's action to reduce the number of required longitudinal pendulum impacts was taken to bring the test requirements more in line with real-world conditions. As was explained in the May 7 letter, the number of required pendulum impacts has been revised to conform to the average number of low-speed impacts a vehicle will encounter in its lifetime. The ability of a vehicle to comply with the pendulum test requirements will therefore assure its ability to withstand the number of low-speed collisions in which it is likely to be involved.; We are not able to predict whether the reduced number of impacts wil enable removal of the energy absorbing devices from the bumper system. Nissan has stated that they will not be able to eliminate the energy absorbers. However, it remains possible that some manufacturers could at least reduce the size of the components.; Yours truly, Richard B. Dyson, Assistant 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.