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 |
|---|---|
ID: 07-005970--28 Feb 08--saOpenMs. Marine Jacotot Regulation Department Heuliez Cerizay 7. rue Louis Heuiliez BP 70209 79142 CERIZAY Cedex France Dear Ms. Jacotot: This is in response to your e-mail regarding free motion headform (FMH) impact test requirements for upper interior components in Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant Protection in Interior Impact (S6.3), as they relate to your companys retractable hardtop (RHT) roof system. Specifically, you seek confirmation of your interpretation that by excluding any target located on a convertible roof frame or on a convertible roof linkage mechanism, S6.3(a) also excludes any target on a decorative trim located such that during a FMH test, the trim would be between the forehead of the headform and the roof linkage mechanism or convertible roof frame. Based on the information you provided in emails on October 17, 2007 and December 13, 2007, and the analysis below, the National Highway Traffic Safety Administration (NHTSA) disagrees with your interpretation as it applies to the Peugeot 206 CCs RHT roof system. S6.3(a) of FMVSS No. 201 provides that a vehicle need not meet the requirements of S6.1 through S6.2 (the FMH impact requirements) for any target located on a convertible roof frame or a convertible roof linkage mechanism. Convertible roof frame is defined in S3 as the frame of a convertible roof. Convertible roof linkage mechanism is defined in S3 as any anchorage, fastener, or device necessary to deploy a convertible roof frame. In an April 5, 2002 letter we sent your company, we interpreted the S6.3 exclusion as it applies to RHT roof systems and hardtops for convertibles. NHTSA determined that with the exception of those components required to raise and lower the top or to latch it into position, RHT roof systems and detachable hardtops for convertibles must meet the FMH impact requirements of FMVSS No. 201. Previously addressing the application of the FMH impact test requirements to convertible roof systems, in an April 1998 Federal Register notice denying petitions for reconsideration, NHTSA rejected a request to modify the definition of convertible roof frame to include RHTs. We explained that the S6.3 exclusion of convertible roof frames and linkage mechanisms from the FMH impact requirements existed because the presence of a countermeasure such as padding would interfere with the frame and linkage mechanisms movement. We further reiterated that rigid convertible tops could produce head injuries and that the agency believed that protection should be provided for all the hard areas inside a vehicle unless it is not practicable to do so. 63 Fed. Reg. 19839, 19840. NHTSA noted that the petitioner did not submit any data indicating that convertible hardtops cannot be made as flexible as a conventional roof structure. The agency determined that since convertible roof frames and linkage mechanisms are excluded from FMH impact tests, the design of the remainder of the convertible hardtop roof should not present additional compliance difficulties. Id. The photographs and information you sent us was for the Peugeot 206 CCs RHT roof system. This vehicles RHT roof system consists of two moving, rigid panel sections. This RHT roof system retracts and deploys by the movement of two metal arms along the length of both panels of the roof on both sides, in the longitudinal direction. The two panels are connected by the movable metal arms, and by two joints located at the outer edges of the rigid panels. In your photographs, you have denoted these two joint areas, which consist of a metal side of the joint (facing the exterior of the vehicle) and a plastic side of the joint (facing the interior of the vehicle), as the roof joint mechanisms. The user secures the RHT to the vehicle frame by manually locking two front latch mechanisms, which each consist of a fixed striker on the A-pillar, a hook on the RHT, and a handle. The edges of the roof closest to the movable metal arms have a plastic trim that runs along the length of both sides of the rigid roof panels. The trims purpose is to cover the movable metal arms when the roof is deployed in the coupe configuration. Since the trim is linked to the roof, the trim moves when the roof moves, and thus is stowed with the roof when the RHT is in the convertible configuration. The two front latch mechanisms and the two roof joint mechanisms appear to be components necessary to raise and lower the top or to latch it into position. Thus, under S6.3, the vehicle need not meet the FMH impact requirements for any target located on these components. Because the trim moves and stows with the roof panels (and not with the movable arms), it appears that the trim is more a part of the roof than a part of the components necessary to raise and lower the roof or to latch it into position. It does not appear to us that the presence of a countermeasure such as padding would interfere with the trims movement, or that the trim cannot be made as flexible as the rest of the roof structure. Accordingly, while the roof joint mechanisms and front latch mechanisms are excluded from being targets for the FMH impact tests, the plastic trim on the Peugeot 206 CCs RHT roof system that covers the metal bars would not be excluded as a target in the FMH impact tests. This trim covering the movable metal arms is distinguished from any plastic pieces on the front latch mechanisms or roof joint mechanisms, which we do consider excluded from being a target in the FMH impact tests, because we consider those plastic pieces to be parts of the front latch mechanisms and roof joint mechanisms. We hope this answers your questions. If you have any further questions, please do not hesitate to contact Sarah Alves of my staff at (202) 366-2992. Sincerely yours, Anthony M. Cooke Chief Counsel ref:108 d.4/29/08 |
2008 |
ID: nht95-4.52OpenTYPE: INTERPRETATION-NHTSA DATE: October 11, 1995 FROM: Gerald R. Stewart -- Office of Safety Performance Standards, Crash Avoidance Division, NHTSA TO: Office of the Chief Counsel, NHTSA TITLE: Request for Interpretation for Safety Grooves ATTACHMT: Attached to 11/13/95 letter from Samuel J. Dubbin to Borje Kukka (A43; Std. 104; Std. 205) TEXT: MEMORANDUM: At a recent meeting I received a video tape and brochures on safety grooves which are used in Finland and other countries to help keep windshields and wiper blades clean in adverse weather. Mr. Borje Kukka from Helsinki Finland asked for help with regar d to which vehicle safety standards, if any, would be applicable to safety grooves. I have sent Mr. Kukka a letter with most of the information he needs; however Mr. Felrice suggested that I request an interpretation from Chief Counsel to be sent to Mr. Kukka so that he has a complete understanding of whether safety grooves are consider ed an item of vehicle equipment or not. I am submitting the video tape, brochures, and a copy of my letter to Mr. Kukka. Please prepare an interpretation letter for Mr. Kukka. If you have questions contact me at 366-5268 or Mr. Kukka at the following: Borje Kukka Humalistonkatu 5 00250 Helsinki Finland Phones: 011 358 0 493 013 private 011 358 02 419 820 Fax 011 358 0 407 315 cellular 011 358 49 414 727 Attachment Mr. Borje Kukka Humalistonkatu 5 00250 Helsinki Finland Dear Mr. Kukka, Thank you for inviting me to your meeting with Mr. Nitze to review the safety groove principles and video tape. I was impressed with the simplicity of the process for grinding the grooves into a vehicle windshield and also with the performance of the gr ooves on keeping the windshield and wiper blades clean during adverse conditions. I contacted the Office of Chief Counsel and a search of interpretations produced an example for a device which cleans windshield wipers. A copy is attached along with some general information which will help you. As I said in the meeting, it is importa nt for you to understand the term "render inoperative" as it refers to our Federal Motor Vehicle Safety Standards 205 and 104. Copies of these are attached. At the meeting I gave you a copy of the ANS 226 document which is referenced by Standard 205. At this point, it is important for you to know whether the safety grooves would be considered by our agency as an item of motor vehicle equipment or not. I have provided your video tape and brochures to the Chief Counsel Office with a request for an int erpretation of the question of which vehicle safety standards, if any, are applicable to your safety grooves. An answer should be available within 60 days. Thank you again for giving me an opportunity to learn about a simple process that can improve a driver's ability to drive safely. I hope this information is helpful to you. If you have questions or need more information please do not hesitate to call m e at 202-366-5268. |
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ID: nht95-7.18OpenTYPE: INTERPRETATION-NHTSA DATE: October 11, 1995 FROM: Gerald R. Stewart -- Office of Safety Performance Standards, Crash Avoidance Division, NHTSA TO: Office of the Chief Counsel, NHTSA TITLE: Request for Interpretation for Safety Grooves ATTACHMT: Attached to 11/13/95 letter from Samuel J. Dubbin to Borje Kukka (A43; Std. 104; Std. 205) TEXT: MEMORANDUM: At a recent meeting I received a video tape and brochures on safety grooves which are used in Finland and other countries to help keep windshields and wiper blades clean in adverse weather. Mr. Borje Kukka from Helsinki Finland asked for help with regard to which vehicle safety standards, if any, would be applicable to safety grooves. I have sent Mr. Kukka a letter with most of the information he needs; however Mr. Felrice suggested that I request an interpretation from Chief Counsel to be sent to Mr. Kukka so that he has a complete understanding of whether safety grooves are considered an item of vehicle equipment or not. I am submitting the video tape, brochures, and a copy of my letter to Mr. Kukka. Please prepare an interpretation letter for Mr. Kukka. If you have questions contact me at 366-5268 or Mr. Kukka at the following: Borje Kukka Humalistonkatu 5 00250 Helsinki Finland Phones: 011 358 0 493 013 private 011 358 02 419 820 Fax 011 358 0 407 315 cellular 011 358 49 414 727 Attachment Mr. Borje Kukka Humalistonkatu 5 00250 Helsinki Finland Dear Mr. Kukka, Thank you for inviting me to your meeting with Mr. Nitze to review the safety groove principles and video tape. I was impressed with the simplicity of the process for grinding the grooves into a vehicle windshield and also with the performance of the grooves on keeping the windshield and wiper blades clean during adverse conditions. I contacted the Office of Chief Counsel and a search of interpretations produced an example for a device which cleans windshield wipers. A copy is attached along with some general information which will help you. As I said in the meeting, it is important for you to understand the term "render inoperative" as it refers to our Federal Motor Vehicle Safety Standards 205 and 104. Copies of these are attached. At the meeting I gave you a copy of the ANS 226 document which is referenced by Standard 205. At this point, it is important for you to know whether the safety grooves would be considered by our agency as an item of motor vehicle equipment or not. I have provided your video tape and brochures to the Chief Counsel Office with a request for an interpretation of the question of which vehicle safety standards, if any, are applicable to your safety grooves. An answer should be available within 60 days. Thank you again for giving me an opportunity to learn about a simple process that can improve a driver's ability to drive safely. I hope this information is helpful to you. If you have questions or need more information please do not hesitate to call me at 202-366-5268. |
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ID: aiam2275OpenHonorable Delbert L. Latta, House of Representatives, Washington, DC 20515; Honorable Delbert L. Latta House of Representatives Washington DC 20515; Dear Mr. Latta: Thank you for your March 23, 1976, request for consideration of th views of a constituent that provision of air cushion restraint systems in passenger cars would be too costly, and that motor vehicle regulation should concentrate on used vehicles because they are equipped with fewer safety and emission features.; As you are aware, the National Traffic and Motor Vehicle Safety Ac (the Act) (15 U.S.C. S 1391 *et seq*.) directs the Secretary of Transportation to issue motor vehicle standards that will reduce the number of accidents and deaths, and the severity of injuries, that occur on our nation's highways. The National Highway Traffic Safety Administration (NHTSA) of the Department of Transportation evaluates the available means to meet this goal. Restraining vehicle occupants to protect them against impact with the vehicle interior in a crash offers one of the greatest opportunities for improving motor vehicle safety. Reliance on existing seatbelt systems has prevented only a small portion of the death and injuries that occur from impact with the vehicle interior. For this reason, other means of providing restraint are under consideration. I can assure you that the issues of purchase cost, replacement cost, and the alternatives to air cushions are being included in this consideration.; The safe operation of motor vehicles has traditionally been regulate by the individual States and not the Federal Government. While the Act does not authorize the retrofit of safety devices to vehicles in use, the NHTSA has issued a highway safety program standard for State periodic motor vehicle inspection programs (23 CFR S 1204.4). Part 570, *Vehicle in Use Standards* (49 CFR Part 570), sets forth a procedure for inspection of older vehicles for use by the States in implementing the program standard. Also, the NHTSA has established demonstration diagnostic inspection projects that include emission as well as safety inspection of vehicles in use.; I have no basis for comment on the reported decision by Allstat Insurance Company not to consider the effects of bumper modification in establishing its premium structure.; I trust that this response will answer your constituent's questions. Sincerely, William T. Coleman, Jr. |
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ID: aiam2276OpenHonorable Delbert L. Latta, House of Representatives, Washington, DC 20515; Honorable Delbert L. Latta House of Representatives Washington DC 20515; Dear Mr. Latta: Thank you for your March 23, 1976, request for consideration of th views of a constituent that provision of air cushion restraint systems in passenger cars would be too costly, and that motor vehicle regulation should concentrate on used vehicles because they are equipped with fewer safety and emission features.; As you are aware, the National Traffic and Motor Vehicle Safety Ac (the Act) (15 U.S.C. S 1391 *et seq*.) directs the Secretary of Transportation to issue motor vehicle standards that will reduce the number of accidents and deaths, and the severity of injuries, that occur on our nation's highways. The National Highway Traffic Safety Administration (NHTSA) of the Department of Transportation evaluates the available means to meet this goal. Restraining vehicle occupants to protect them against impact with the vehicle interior in a crash offers one of the greatest opportunities for improving motor vehicle safety. Reliance on existing seatbelt systems has prevented only a small portion of the death and injuries that occur from impact with the vehicle interior. For this reason, other means of providing restraint are under consideration. I can assure you that the issues of purchase cost, replacement cost, and the alternatives to air cushions are being included in this consideration.; The safe operation of motor vehicles has traditionally been regulate by the individual States and not the Federal Government. While the Act does not authorize the retrofit of safety devices to vehicles in use, the NHTSA has issued a highway safety program standard for State periodic motor vehicle inspection programs (23 CFR S 1204.4). Part 570, *Vehicle in Use Standards* (49 CFR Part 570), sets forth a procedure for inspection of older vehicles for use by the States in implementing the program standard. Also, the NHTSA has established demonstration diagnostic inspection projects that include emission as well as safety inspection of vehicles in use.; I have no basis for comment on the reported decision by Allstat Insurance Company not to consider the effects of bumper modification in establishing its premium structure.; I trust that this response will answer your constituent's questions. Sincerely, William T. Coleman, Jr. |
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ID: 20747.ztvOpenMr. George Manset Dear Mr. Manset: This is in reply to your letter of September 14, 1999, to Rich Van Iderstine, with respect to whether your prospective location of taillamps on utility trailers complies with Federal Motor Vehicle Safety Standard No. 108. Your current practice is to locate taillamps "on the very rear of the trailer (which have total lengths of 96" and 132")." You are considering locating these lamps in the fenders "which are 12" and 30" from the rear on the respective trailers." You observe that for many trailer designs, with tilt features and loading ramps, "it isn't always practical to be located directly on the rear." Mr. Van Iderstine tells us that these designs may also affect the location of other rear lighting equipment such as stop and turn signal lamps, and perhaps license plate lamps and clearance lamps as well. Paragraph S5.3.1 of Standard No. 108 requires motor vehicle lighting equipment to be mounted in the location specified in Table II or Table IV of Standard No. 108. Each Table requires stop, turn signal, clearance, and taillamps to be mounted "on the rear." Further, S5.3.2 requires each lamp to be located "so that it meets the visibility requirements specified in any applicable SAE Standard." The applicable SAE Standards are indicated in Table I and Table III. As you know, lamps must be designed to meet minimum candlepower specifications measured at various test points. In general, the visibility of lamps must not be obstructed by any part of the vehicle throughout the photometric test angles for the lamp, unless the lamp is designed to comply with all photometric and visibility requirements with the obstructions considered. Further, the signal from lamps on both sides of the vehicle must be visible through a horizontal angle from 45 deg. to the left to 45 deg. to the right. To be considered visible, the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding reflex at least 2 sq. in (12.5 sq. cm.) in extent, measured at 45 deg. to the longitudinal axis of the vehicle. Enclosed are three letters which address issues raised by your question. You will see from our letter of January 29, 1996, to Tommy Reeder, that it is not necessary to locate lamps literally on the extreme end of a tilt bed trailer provided that the photometric and visibility requirements of Standard No. 108 are met in the location chosen. We informed Jack Rademacher on August 22, 1990, that we interpret "on the rear" as meaning the trailing edge of the rear fender, providing the visibility requirements were met. If your taillamps meet all the visibility requirements when mounted in the trailing edge of a rear fender 12 inches from the extreme end of the trailer, we would consider the lamps as mounted "on the rear." However, our letter of January 8, 1990, to Howard Kossover stated that lamps mounted 27 inches from the rear edge of the vehicle were not mounted "on the rear" as the standard specifies; further, we had reservations whether the visibility requirements could be met in that location. This means that your contemplated location of 30 inches would not comply with Standard No. 108 as we have interpreted it. If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263). Sincerely, |
1999 |
ID: nht78-1.33OpenDATE: 03/22/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Blue Bird Body Company TITLE: FMVSS INTERPRETATION TEXT: This responds to your January 11, 1978, letter asking whether several joints in your school bus must comply with Standard No. 221, School Bus Body Joint Strength. The terms which establish the applicability of the requirements of the standard to a particular section of a school bus body are defined in S4 of the standard. Read together they establish the following test. If the edge of a surface component (made of homogeneous material) that encloses occupant space in a bus comes into contact or close proximity with any other body component, the requirements of S5 apply, unless the area in question is designed for ventilation or another functional purpose, or is a door, window, or maintenance access panel. Applying this test to the several joints to which you refer, it appears that they do not need to comply with the requirements since they connect panels which are considered to be maintenance access panels. The National Highway Traffic Safety Administration (NHTSA) notes that maintenance access panels are granted this exception from the requirements because of their need for removal for routine service to underlying components. The NHTSA will not consider all bus walls as maintenance access panels simply because wiring may be present behind them since routine maintenance would not be required on such wiring. Further, should any of the panels to which you refer in your letter not have wiring or other serviceable components requiring routine maintenance behind them, they will not be treated as maintenance access panels. SINCERELY, January 11, 1978 Joseph J, Levin, Jr. Chief Counsel National Highway Traffic Safety Administration Dear Mr. Levin: SUBJECT: 571.221 Standard Number 221, School Bus Body Joint Strength Section S4 defines a body panel joint as follows: ""Body panel joint" means the area of contact or close proximity between the edges of a body panel and another body component, excluding spaces designed for ventilation or another functional purpose, and excluding doors, windows, and maintenance access panels." Blue Bird has initially set up the following panels to meet 60% joint strength per S5. Front Upper Inner Panel Rear Upper Inner Panel Rear Vision Panel Inside Right Hand Rear Vision Panel Inside Left Hand Rear Inner Panel Right Hand Rear Inner Panel Left Hand Post Cap Rear Emergency Door Access Right Hand Post Cap Rear Emergency Door Access Left Hand We have had field and production line complaints regarding wiring access with the many rivets in these panels and propose to designate these panels as maintenance access panels per section S4 and install them with screws as shown in the enclosed pictures. Sheets 1 through 5 show the lamp wiring which is serviced by the appropriate inside panels. We understand that competitive make buses are already using similar designs and we are being pressured by the marketplace from both the cost and serviceability points of view to adopt the proposals which appear in this letter. We look forward to receiving your confirmation that these proposals fully comply with the requirements of FMVSS 221. W. G. Milby Manager, Engineering Services [ENCLS. OMITTED] |
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ID: 9045Open Ms. Jane L. Dawson Dear Ms. Dawson: This responds to your questions about a December 2, 1992, rule that amended Standard No. 111, Rear-view mirrors, by establishing field-of-view requirements around school buses (57 FR 57000). The rule amended Standard No. 111 to require a bus driver to be able to see, either directly or through mirrors, certain specified areas in front of and along both sides of school buses. I apologize for the delay in responding. Your first question asks: Are we required to certify that the mirror system has the ability to be adjusted for viewing of the cylinders by a 25th percentile female or to certify that the mirror system has been adjusted? Under the National Traffic and Motor Vehicle Safety Act, each new vehicle manufacturer must certify that its vehicle complies with the Federal motor vehicle safety standards (FMVSS's). NHTSA evaluates a vehicle's compliance with the safety standards using the test procedures and conditions specified in the FMVSS's. Standard 111 requires that specified areas must be visible when viewed from the eye location of a 25th percentile adult female (S9, S13). The test procedures of S13 state that, when testing a school bus, NHTSA will adjust an adjustable mirror to the eye location of a 25th percentile adult female before the test, in accordance with the manufacturer's recommendations (S13.3). Of course, to comply with Standard 111, the mirror will have to be able to be adjusted to the required location at the time NHTSA tests the vehicle. Your second question asks: Are the outside rearview mirrors required to view the area straight down from the mirrors and 200 feet rearward? In an October 21, 1993, telephone conversation with Marvin Shaw of my staff, you explained that you ask whether S9.2 of Standard 111 requires measurement beginning at the ground below the System A mirror (and extending at least 200 feet behind that plane). The answer is yes, the mirror must provide a view of the area straight down from that mirror and extending 200 feet rearward. Section S9.2 states that each school bus must have two outside rearview mirror systems: A System A driving mirror and a System B convex cross view mirror. The System A mirror on the left side of the bus is required by S9.2(b)(2) to provide a view of "the entire top surface of cylinder M in Figure 2, and of that area of the ground which extends rearward from the mirror surface not less than 60.93 meters (200 feet)" (emphasis added). Please note that the agency is currently reviewing a rulemaking petition in which Blue Bird Body Company has requested that the agency amend Standard No. 111, with respect to System A driving mirrors. I hope this information is helpful. Please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely,
John Womack Acting Chief Counsel ref:111 d:2/14/94 |
1994 |
ID: aiam0485OpenMr. E. M. Ryan, Chief Design Engineer, Ward School Bus Mfg., Inc., P. O. Box 849, Conway, AR, 72032; Mr. E. M. Ryan Chief Design Engineer Ward School Bus Mfg. Inc. P. O. Box 849 Conway AR 72032; Dear Mr. Ryan: Your letter of October 28, 1971, to Mr. Stan Haranski, Truck Body an Equipment Association, Inc., concerning switching arrangements for school bus red signal lamps, has been forwarded to this Office for reply.; Paragraph S4.1.4(a) of Federal Motor Vehicle Safety Standard No. 10 requires that the four red signal lamps be controlled by a manually actuated switch. A two-way switch, whereby all four lamps are activated when the switch is in one position, and the two rear lamps only are activated when the switch is in the opposite position, would not be in violation of this requirement of Standard No. 108.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: 1984-1.39OpenTYPE: INTERPRETATION-NHTSA DATE: 04/11/84 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Mazda (North America) Inc. TITLE: FMVSS INTERPRETATION TEXT:
Mr. Stephen Underwood Mazda (North America), Inc. 23777 Greenfield Road Suite 462 Southfield, Michigan 48075
Dear Mr. Underwood:
This is to follow up on your phone conversation with Stephen Oesch of my staff on Standard No. 203, Impact Protection for the Driver From the Steering Control System. You asked how the steering wheel should be positioned when it is tested in accordance with the standard. As explained below, the steering wheel should be positioned at its design angle, as specified by the manufacturer. Standard No. 203 incorporates by reference Society of Automotive Engineers Recommended Practice J944, Steering Wheel Assembly Laboratory Test Procedure, December 1965. Section 6.2 of SAE J944 provides that the steering wheel is to be mounted "at the proper angle as determined by the package drawing." Therefore, the agency would mount the column at the design angle specified by the manufacturer.
If you have any further questions, please let me know. Sincerely,
Frank Berndt 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.