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: aiam3712OpenWilliam Shapiro, P.E., Manager, Regulatory Affairs, North American Car Operations, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; William Shapiro P.E. Manager Regulatory Affairs North American Car Operations Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro: This responds to your letter of May 24, 1983, requesting a interpretation concerning the retraction force requirements of Safety Standard No. 209, *Seat Belt Assemblies*. You are considering a Type 2 seat belt design which includes an emergency locking retractor for continuous loop webbing and an emergency locking retractor for additional webbing at the inboard buckle portion of the system. You state that this inboard webbing is extended only if the belt is used by an extremely large occupant. You ask whether the retraction force requirements of the standard allow testing with the webbing of the *entire system* extended 75%, i.e., even if this means that no webbing is extended from the inboard retractor, so that the retraction force is actually only measured from the retractor for the continuous loop portion of the belt.; Paragraph S4.3(j) of Safety Standard No. 209 specifies that a emergency locking retractor of a Type 1 or Type 2 seat belt assembly, when tested in accordance with the procedures specified in paragraph S5.2(j) shall:; >>>***** (4) exert a retractive force of at least 0.6 pound under zer acceleration when attached only to the pelvic restraint,; (5) exert a retractive force of not less than 0.2 pound and not mor than 1.1 pounds under zero acceleration when attached only to an upper torso restraint,; (6) exert a retractive force of not less than 0.2 pound and not mor than 1.5 pounds under zero acceleration when attached to a strap or webbing that restrains both the upper torso and pelvis.<<<; The test procedures of paragraph S5.2(j) specify that these retractio forces are to be measured with the belt webbing extended from the retractor to 75% of its length.; The requirements of S4.3(j) apply to *each* retractor on a Type 1 o Type 2 belt system. There is no exception in the standard for a system which includes two or more retractors which exert force on the same belt webbing. Thus, both retractors on your proposed system would have to comply with the requirements of the standard independently of one another. Under the test procedure you suggest, the retraction force of the inboard retractor would not be measured. This is contrary to the explicit language of the standard.; Both retractors on your proposed system would have to comply with th force requirements of paragraph S4.3(j)(6). This is true because both retractors are attached 'to a strap or webbing that restrains both the upper torso and the pelvis.' Therefore, the retraction force on your inboard retractor must be not less than 0.2 pound and not greater than 1.5 pounds when the webbing on that retractor is extended to 75% of its length. The same is true for the retractor on the continuous loop portion of the system.; I hope this has clarified any misunderstanding you might have ha concerning these requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3342OpenMr. Samuel W. Halper, Bartman, Braun & Halper, Suite 1015, 1880 Century Park East, Los Angeles, CA 90067; Mr. Samuel W. Halper Bartman Braun & Halper Suite 1015 1880 Century Park East Los Angeles CA 90067; Dear Mr. Halper: This responds to your letter of May 28, 1980, on behalf of Californi Strolee, Inc. (Strolee), to Stephen Oesch of my office and to the questions you asked during your meeting of August 7 with members of the agency's staff. Both your letter and your meeting concerned Standard No. 213, *Child Restraint Systems*. You asked whether Strolee's prototype child restraint, described in your letter and demonstrated at the meeting, must be tested in accordance with section 6.1.2.1.2 of the standard and, if so, whether the agency will attach the harness system of the child restraint during that testing. The answers are that the child restraint must be tested in accordance with section 6.1.2.1.2 and the agency will attach the harness during that testing.; Your May 29, 1980, letter, describing Strolee's future product plans requested confidentiality for Strolee's request for interpretation and the agency's response. At your August 7, 1980, meeting, you informed Mr. Oesch that Strolee had decided to withdraw its request for confidentiality.; The child restraint described in your letter and demonstrated to th agency has a movable shield. The shield is attached to each side of the restraint by a pivot mechanism, which has a spring that lifts the shield. Because the movable shield is spring-loaded, it must be mechanically held down or it will automatically raise the shield above the child's head. Attached to the lower part of the child restraint is a crotch strap with a buckle on one end. The crotch strap is intended to be manually passed through a loop mounted on the bottom of the movable shield and attached to the other portions of the five point harness system within the restraint.; The other portions of the harness system consist of two straps, eac strap serves as an upper and lower torso restraint. Each strap has a movable metal latchplate which is inserted into the buckle attached to the crotch strap.; Once the crotch strap is passed through the loop mounted on the shiel and attached to the harness system, the shield is held in place in front of the child. The five point harness system provides the primary restraint of the child, but the movable shield, which will be designed to comply with the shape and radius of curvature requirements of section 5.2.2.1(c) of the standard, also provides restraint in a crash.; Your first question was whether the child restraint must be tested i accordance with test configuration II specified in Section 6.1.2.1.2 of the standard. More specifically, the issue is whether the Strolee shield is the sort of restraining surface described in section 5.2.2.2. As explained below, the answer is yes. The Strolee child restraint will be tested in accordance with test configuration II. When tested in that configuration, it will not have its top tether attached.; Section 5.2.2.2 of the standard requires that: >>>Each forward facing child restraint system shall have no fixed o movable surface directly forward of the dummy and intersected by a horizontal line parallel to the SORL and passing through any portion of the dummy, except for surfaces which restrain the dummy when the system is tested in accordance with S6.1.2.1.2 so that the child restraint system shall conform to the requirements of S5.1.2 and S5.1.3.1.<<<; When the Strolee child restraint is used in accordance with th manufacturer's instructions, the crotch strap is passed through the loop on the movable shield and attached to the harness system. Once that action is taken, the movable shield is positioned in front of the test dummy. Although the five point harness system provides the primary restraint in the Strolee system, the shield also provides restraint. Therefore, the child restraint must be tested in accordance with section 6.1.2.1.2.; Your second question, raised during your meeting, was whether th agency would attach the crotch strap of the Strolee child restraint if the restraint must be tested in accordance with section 6.1.2.1.2. The answer is yes.; Section 6.1.2.3.1.(c) of the standard provides that in the 20 mph tes of forward facing child restraints with fixed or movable surfaces that restrain the child, the restraint system's belts are not to be attached 'unless they are an integral part of the fixed or movable surface.'; The crotch strap used in the Strolee child restraint is not an integra part of the movable shield. The movable shield is a complete unit by itself. The crotch strap is a separate device that must be manually passed through a loop mounted on the shield every time the unit is used.; The rationale for the integral belt requirement involves the principa misuse of child restraints, which is the failure to attach buckles. This failure is often associated with child restraints having movable surfaces that can be positioned in front of the child. Parents mistakenly assume that such surfaces by themselves would provide sufficient protection and thus do not buckle the harness system in the restraint. To reduce that misuse, the agency established the requirement that belts may be attached during the testing of restraints equipped with movable shields only if they are integral parts of the shield. Attachment of belts that are integral parts is permitted since they remain attached to the restraining shield whether or not the restraint is in use. In addition, the need to buckle those belts is more readily apparent than in the case of belts that are not integral parts of the shield. Thus, the integral belts are not subject to the type of misuse described above.; This rationale applies to belts on a child restraint having a movabl restraining shield that is not spring-loaded. It does not, however, apply to a nonintegral belt on a restraint having a spring-loaded movable shield, if that shield can be held in place only by attaching the nonintegral belt so as to fully and properly restrain the child. The Strolee spring-loaded movable shield will not stay in place in front of the child unless the crotch strap is attached. If the crotch strap is not fastened to the remaining portions of the Strolee child restraint, the movable shield automatically rises above the child's head to signal that the buckle is unfastened and the child is unrestrained. Requiring the crotch strap to be an integral part of the movable restraining shield is unnecessary if the movable shield can only be positioned in front of the child when the child is properly restrained.; The agency originally had several concerns about whether the movabl shield in the Strolee child restraint could be positioned in front of the child without fully and properly restraining the child. One concern was whether the crotch strap and buckle could be passed through the loop mounted on the shield without attaching it to the remaining portion of the harness and the weight of the buckle would hold the shield in place in front of the child. At the meeting, you explained that the large buckle used on the prototype was for demonstration purposes only. Strolee demonstrated a smaller, lighter push-button buckle which would be used on production models and which could not hold down the movable shield by its own weight.; Another concern was whether the crotch strap and buckle could be passe through the loop on the movable shield and attached to only one of the two remaining straps of the harness system. Thus, the shield could be in front of the child, but the child would not be fully and properly restrained because a portion of the five-point harness system would not be connected. An examination of current restraint systems should show that one child restraint is already using a similar type of five-point harness as used in the Strolee system. The agency has not received any reports that parents are connecting only one half of that harness system. In addition, the need to connect both straps is readily apparent, since the buckle on the crotch strap has a separate receptacle for the latchplate on each belt.; The agency is still concerned about the durability of a spring-loade system such as Strolee's. To properly perform its function, the spring must have sufficient force to slowly but repeatedly, raise the movable shield. Further, child restraints are traditionally handed down from child to child and family to family. We, therefore, urge Strolee to design the spring so that it will have sufficient durability to withstand at least several years of repeated use.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4487OpenMr. L. T. Mitchell Specification Engineer Thomas Built Buses, L.P. P.O. Box 2450 1408 Courtesy Road High Point, NC 27261; Mr. L. T. Mitchell Specification Engineer Thomas Built Buses L.P. P.O. Box 2450 1408 Courtesy Road High Point NC 27261; "Dear Mr. Mitchell: This is a response to your letter asking whether i is permissible to install only two seat belts on a 39-inch bench-seat in a school bus with a gross vehicle weight rating (GVWR) of 10,000 pounds or less (small school bus). I apologize for the delay in this response. The answer is no. You stated that Thomas Built Buses (Thomas) would like to accommodate certain customers who wish to have two designated seating positions on each 39-inch bench-seat installed in a small school bus 'for passenger comfort reasons.' Your letter sets forth a suggested rationale as to why Thomas believes such a configuration would be permissible in small school buses. First, you argued that a May 11, 1978 interpretation of Standard 217, Bus Window Retention and Release, states that Federal motor vehicle safety regulations do not prohibit having only two-passenger seating positions on a 39-inch bench-seat in a bus designed for adult transportation. In these circumstances, we said, a manufacturer has some discretion to decide the number of designated seating positions in its vehicles, but must make a good faith determination of the vehicle's passenger capacity to discourage vehicle overloading. You reason that because the term 'designated seating position' is in the Definitions section of the Federal safety standards (49 CFR 571.3), the definition applies to all safety standards. You apparently conclude that our earlier interpretation of Standard 217 and the definition of 'designated seating position' in 571.3 permit a manufacturer to make a good faith determination respecting the number of seating positions on a school bus. Based on this conclusion, you posited two situations in which this reasoning might be applied. Situation 1 was described as follows in your letter: Thomas Built Buses interprets (the May, 1978, interpretation) to be applicable for a school bus sold to carry only high school students. We consider the use of two seat belts on a 39 inch seat to be reasonable and justified due to passenger size making three passengers on one 39' seat impossible. We would honor a purchaser's request to equip these 39' seats with two belts each. Is this interpretation correct? This interpretation is incorrect for several reasons. First, the earlier interpretation did not apply to school buses, by its own terms, it is clearly limited to buses other than school buses. Second, there is not a separate set of standards that specify differing requirements for school buses designed to carry high school students. In determining whether school bus standards apply to a vehicle designed to carry 11 or more persons, the proper inquiry is whether the bus is sold to carry 'primary, preprimary, or secondary school students' to or from school or school-related events. Any vehicle that meets this definition of the term 'school bus' must comply with all applicable school bus standards, regardless of whether it is designed to carry small children to kindergarten or teenagers to high school. Third, the definition of 'designated seating position' and our interpretations of that term, are not relevant in determining whether a school bus bench-seat in a small school bus complies with the requirements of Standard 222. Paragraph S4.1 of Standard 222 sets out a specific procedure for calculating the number of seating positions in a bench seat. That paragraph explains that the number of seating positions on a bench seat in school buses is calculated by (1) measuring the width of the bench seat in inches, (2) dividing by 15, and (3) rounding to the nearest whole number. The value which results from this calculation (expressed by the term 'W') is the basis for determining whether the seat complies with the requirements of Standard 222. For a 39-inch bench-seat, the procedure in S4.1 shows that this seat has three seating positions. Paragraph S5(b) of Standard 222 therefore requires that this bench-seat have three seat belt assemblies installed. Therefore, if your company were to install only two seat belt assemblies on a 39-inch wide bench-seat in a small school bus, you could not certify that the vehicle complies with Standard 222. For these same reasons, your interpretation set forth in your 'Situation 2' is also incorrect. Even if a customer specifically asks that only two seat belt assemblies be installed on 39-inch bench seats, Standard 222 requires your company to equip these seats with three seat belt assemblies. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam0997OpenMr. Stan Haransky, Associate Director, Truck Body and Equipment Assoc., 5530 Wisconsin Avenue, Suite 1220, Washington, D.C. 20015; Mr. Stan Haransky Associate Director Truck Body and Equipment Assoc. 5530 Wisconsin Avenue Suite 1220 Washington D.C. 20015; Dear Stan: This is in reply to your letter of January 8, 1973, concerning th application of Standard No. 124, 'Accelerator Control Systems', to auxiliary throttles mounted inside or outside of the cab and used exclusively while the vehicle is in a stationary position to insure proper engine speed for the operation of pumps, elevating platforms, and similar equipment. Since the definition of 'idle position' was amended to provide for the use of throttle positioners in 37 F.R. 20035 (September 23, 1972), the auxiliary throttles described are not subject to the requirements of the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1685OpenMr. Donald L. Gibson, Supervising Inspector, Commander, Enforcement Services Division, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Mr. Donald L. Gibson Supervising Inspector Commander Enforcement Services Division Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Mr. Gibson: This is in response to your letter of October 21, 1974, inquiring as t the effect of Federal Motor Vehicle Safety Standard No. 121 on State laws relating to air brake performance. You ask whether California can impose requirements pertaining to parking brake release (on trucks and buses) and trailer emergency braking capability which differ from provisions contained in the Federal standard.; Section 103(d) of the National Traffic and Motor Vehicle Safety Act o 1966 (15 U.S.C. 1392(d)) provides that no State or political subdivision of a State may promulgate or continue in effect standards applicable to an aspect of motor vehicle or motor vehicle equipment performance which is covered by a Federal motor vehicle safety standard, unless the standards are identical.; Standard 121 includes provisions relating to truck and bus parkin brake performance and specifies requirements for an emergency braking capability on trailers. Promulgation by a State of a more restrictive parking brake requirement providing for the installation of a release not specified in the Federal standard is prohibited by S 103(d) since the Federal standard is intended to cover all aspects of parking brake performance. A State requirement specifying application of trailer service brakes on breakaway would also be preempted by Standard 121 since Section S5.8 of the Federal standard addresses the subject of emergency trailer braking capability.; The Federal requirements must be regarded as conclusive with regard t parking brake performance and emergency braking capability in order to maintain the uniformity necessary in a Federal regulatory scheme. If States were permitted to impose additional requirements in an area regulated by a Federal safety standard manufacturers would be confronted with an impossible task of compliance. This reasoning formed the basis of a recent decision rendered in a case brought by the Motorcycle Industry Council, Inc. against the State of California in the United States District Court for the Eastern District of California concerning the preemption of a California State requirement that motorcycle headlamps be wired to operate when the engine is running. The Court held that the California requirement is preempted by the Federal Motor Vehicle Safety Standard No. 108 since the NHTSA intended to cover all aspects of performance directly involving motorcycle headlamps.; Therefore, requirements such as those described in your letter would b preempted by Standard 121 since the aspects of performance that would be affected are covered by the Federal standard.; You also ask if your interpretation of Standard No. 121 t International Harvester is correct. In answer, I would like to set out a comprehensive explanation of the standard's requirements for parking brakes (S5.6) in relation to the requirements for emergency braking capability (S5.7, S5.8). I have separated the requirements for trailers from those for trucks, and further separated the truck requirements into the 'automatically-applied parking brake' systems (S5.7.1) and the 'modulated' systems (S5.7.2).; *Trailer brake requirements (other than trailer converter dollies)*. I addition to the requirement for a trailer service brake system (S5.3, S5.4), Standard No. 121 specifies that each air-braked trailer be equipped with an emergency capability (S5.8) and a parking brake (S5.6). The emergency braking capability calls for an automatic application of the parking brake system in the event the air pressure in the supply line is lost. This requirement ensures a back-up braking system in cases of service brake failure and brakes on the trailer in the event of a trailer break away.; The parking brake requirements for trailers specify that the brakes b applied by an energy source that is not affected by loss of air pressure in the service brake system and that, once applied, the parking brakes be held in the applied position solely by mechanical means. The common method to meet this requirement is, of course, to use springs to apply and hold the friction elements of the service brake system. The requirements are intended to ensure that a parked vehicle will not lose its brakes if air is lost from the system by leakage.; The NHTSA recognizes that automatic application of the 'spring brakes (as an emergency capability) could cause a safety problem if they could not be released to move the disabled vehicle from the roadway. For this reason, S5.2.1.1 specifies that each trailer be equipped with a protected reservoir that is capable of releasing the vehicle's parking brakes at least once.; Your interpretation that Standard No. 121 requires control of this tan from the driver's position after an automatic application of the parking brakes is incorrect. The parking brake requirements of S5.6 specify a system for holding stationary a vehicle (or combination) which has a totally functioning brake system. Therefore, S5.6.4 does not establish requirements for application and release of the parking system of the towed vehicle in an emergency when, for example, a supply line to the towed vehicle has burst. The requirement of S5.7.2.2 that parking brakes remain operable is not addressed to trailers.; You pointed out in your July 11, 1973, comments to the docket that th standard should be amended to require that the trailer's protected tank be equipped with a manual valve that releases the parking brakes to permit moving a disabled trailer from the roadway. We are preparing a proposal on parking brake systems in response to an American Trucking Associations petition, which may be responsive to your suggestions.; *Truck (and bus) requirements*. In addition to the requirement for service brake system (S5.3, S5.4), Standard No. 121 specifies that each air-braked truck (and bus) be equipped with an emergency braking capability (S5.7) and a parking brake system (S5.6).; The parking brake requirements of S5.6, as noted above, specify system for holding stationary a vehicle (or combination) which as a totally functioning brake system. S5.6.4 does not therefore establish control requirements in the event of a failure in the system. Only the brake control requirements listed in S5.7 are required during and after a stop which follows a failure in the service brake system.; Section S5.7 permits the manufacturer to provide the emergency brak capability and associated controls in one of two ways: automatically-applied parking brakes (S5.7.1) or a modulated braking capability (S5.7.2). To our knowledge few if any manufacturers have chosen to build an emergency system which conforms to S5.7.1. Because the International Harvester (IH) system and those of other manufacturers conform to S5.7.2, the following discussion addresses only that option.; S5.7.2 specifies an emergency braking capability which can stop th truck or bus within a certain distance in the event of a failure of the service brake system other than a failure of a common valve, manifold, brake fluid housing, or brake chamber housing (S5.7.2.3). When a failure of this type occurs in the truck, S5.7.2.1 specifies that the towing vehicle emergency brake system control be capable of controlling service or parking brakes on any towed vehicle equipped with air brakes. This does not mean that control must be exercised over the trailer brakes if a failure occurs in the supply line or control line to the trailer.; S5.7.2.2 specifies a dynamic braking capability in the parking brak system (subject to manual application) in the event of a total failure of the service- emergency braking capability.; From a study of the brake system schematics for the IH split syste (with spring brakes), it appears that the system would comply with Standard No. 121. In your letter to IH you conclude that their system does not comply 'since the spring brake [on the truck] can not be released when the service air is lost.' You base your interpretation on language of S5.7.2.2 that 'loss of air [due to failure in both service and emergency modes] shall not cause the parking brake to be inoperable'. Your concern is that a failure of this nature would prevent a disabled vehicle from being moved from the roadway if the parking brake is not releasable.; As earlier noted, S5.7.2.2 specifies a dynamic parking brake capabilit in the event of catastrophic failure. This section is not a requirement that the parking brake operate as it would in a totally functioning and stationary vehicle. Such a requirement in S5.7.2 for release of the parking brakes to move the vehicle is impractical with some of the specified failures. Moreover, it is also unnecessary, because a modulated emergency system provides a driver with several applications and releases of the emergency brake system to move the disabled vehicle off the road after the signal from the warning system (S5.1.6) that the vehicle has lost its service brake system. These applications are the equivalent of the California requirement that the spring brake system be capable of being applied, released, and reapplied by the driver, following notice of the service brake system failure, as indicated by an automatic brake application.; You make the statement that IH must meet the requirements of S5.7.1. because its parking brakes apply automatically after both the service system fails and the emergency system is depleted. In fact IH has chosen to meet S5.7.2 and is not required to meet any of the specifications of S5.7.1.; Because these differences exist between the present Californi regulations and the soon-to-be-implemented Federal requirements, manufacturers like International Harvester will have difficulty in effecting an orderly transition to the new systems. We have encouraged manufacturers to introduce the new systems in small numbers before the effective date to gain some experience with them, and we feel that it would be unfortunate if these manufacturers were penalized by the States for their early introductions.; I invite comments from the State of California on our upcoming parkin brake system proposal.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2103OpenMr. Claud Riggs, Mountain States Tire Dealers Association, 1230 Pontiac Street, Denver, Colorado 80220; Mr. Claud Riggs Mountain States Tire Dealers Association 1230 Pontiac Street Denver Colorado 80220; Dear Mr. Riggs: Please forgive the delay in responding to your letter of May 1, 1975 which included a list of information items you believe are required to appear on retreaded tires pursuant to Federal Motor Vehicle Safety Standard No. 117, *Retreaded Pneumatic Tires*.; With the following qualifications, you list is correct: >>>1. The tire must be labeled with the symbol 'DOT' followed by th letter 'R', and other information required by 49 CFR Part 574.5, *Tire Identification and Recordkeeping*, as a certification that the tire complies with Standard No. 117. This requirement is distinct from and in addition to the requirement that the casing retain the 'DOT' symbol from its original manufacturer.; 2. The words 'bias/belted' are not required, because the actual numbe of plies in the sidewall and, if different, in the tread area, are now required to appear.; 3. Tube-type and tubeless tires must be labeled with the specific wor 'tube-type' and 'tubeless', respectively.; 4. The items listed in your third group may appear in a paper labe only if that label is not easily removable.<<<; For your convenience, I have enclosed a copy of Standard No. 117. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5296OpenMr. Don Vierimaa Truck Trailer Manufacturers Association 1020 Princess Street Alexandria, VA 22314; Mr. Don Vierimaa Truck Trailer Manufacturers Association 1020 Princess Street Alexandria VA 22314; Dear Mr. Vierimaa: This responds to your FAX of January 11, 1994, t Pat Boyd of this agency requesting an interpretation of the trailer conspicuity requirements of Standard No. 108. In the future, please address your requests for interpretations to the Chief Counsel. You have asked 'may a manufacturer install a 4 inch (100 mm) wide retrofrelective sheeting instead of 2 inch (50 mm) sheeting on the side of new trailers?' Paragraph S5.7.1.3(d) of Standard No. 108 states that retroreflective sheeting shall have a width of 50 mm (Grade DOT-C2), 75 mm (Grade DOT-C3), or 100 mm (Grade DOT-C4). Paragraph S5.7.1.4.2(a), as amended on October 6, 1993 (58 FR 52021 at 52026), sets forth the requirements for application of retroreflective sheeting to the side of trailers. Without elaboration, it simply identifies it as 'a strip of sheeting.' This means that the manufacturer of the trailer is permitted his choice of Grade DOT-C2, -C3, or -C4 material. Therefore, a manufacturer may install sheeting that has a width of 100 mm on the side of a trailer. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2553OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of March 29, 1977, asking two question about the use of strobe lamps on school buses.; Your first question is whether it is 'legal to install strobe typ warning lamps on school buses?' The answer is yes provided such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887 'School Bus Red Signal Lamps.'; You also reference 'certification from our vendor. . . that his syste meets FMVSS if installed according to his instructions.' You have asked if this letter from your vendor is 'adequate documentation upon which we could certify that a bus with such a system meets FMVSS 108?' In an earlier opinion letter on this subject (to Yankee Metal Products Corporation of April 12, 1976) we opined opinion by a professional engineer indicating compliance of a strobe lamp design with SAE J887 provided a basis upon which Yankee could certify that its system meets Standard No. 108. Since you did not enclose the letter from your vendor we cannot comment upon it. However the National Traffic and Motor Vehicle Safety Act requires that a manufacturer exercise due care in insuring that its certification is not false and misleading in a material respect, and you should exercise the same care in this instance that you do with respect to insuring compliance of other items of lighting devices with which your buses are equipped.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0094OpenMr.. Francesco Palazzi, 11 Direttore, Associazione Nazionale Fra, Industrie Automobilistiche, 10128 - Torino, Italy; Mr.. Francesco Palazzi 11 Direttore Associazione Nazionale Fra Industrie Automobilistiche 10128 - Torino Italy; Dear mr. Palazzi: Thank you for your letter of June 3 to the National Highway Safet Bureau asking 'whether the solution given in the enclosed drawing N. 591-1559 of Ferrari is in line with the requirements' of Federal motor vehicle safety standard No. 211.; This standard states that 'wheel nuts, hub caps, and wheel discs fo use on passenger cars...shall not incorporate winged projections'. The Ferrari plan appears to incorporate such a projection, even though it is recessed. Accordingly the proposed solution by Ferrari does not meet the requirements of Federal standard No. 211.; Sincerely, Joseph R. O'Gorman, Acting Director |
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ID: aiam0581OpenMr. J. Frank Brasher, Salt lake Auto Auction, 460 Orange Street (1900 West), Salt Lake City, Utah 84104; Mr. J. Frank Brasher Salt lake Auto Auction 460 Orange Street (1900 West) Salt Lake City Utah 84104; Dear Mr. Brasher: This is in reply to your letter of January 5, 1972, inquiring whethe you may inlay whitewall rings in black tires. You state that in the process a narrow strip of black rubber around the tire is buffed or ground off and replaced with a strip of whitewall which is bounded or vulcanized to the tire in its place.; Assuming that you are discussing applying this process to new passenge car tires, whether the process is permissible depends upon whether or not it adversely affects the tire's compliance with Motor Vehicle Safety Standard No. 109, 'New Pneumatic Tires,' which prescribed performance requirements for all passenger car tires sold in the United States. A copy of the standard is enclosed.; If after using the process the tire will not comply with Standard No 109, the use of the process is prohibited, and its use can result in the imposition of civil penalties of up to $1,000 per tire and of other sanctions as well (15 U.S.C. 1397(a)(1), 1398, 1399). In addition, it is the responsibility of the one who wishes to use the process to determine whether it will cause the tires to fail the standard.; 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.