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
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ID: nht92-9.27OpenDATE: February 3, 1992 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Thomas A. Gerke, Esq. -- Smith, Gill, Fisher & Butts TITLE: None ATTACHMT: Attached to letter dated December 23, 1991 from Thomas A. Gerke to Paul Jackson Rice (OCC 6865) TEXT: This responds to your December 23, 1991 letter concerning Safety Standard 107, Reflectinq Surfaces. You asked us to confirm the interpretation of the standard set forth in my September 3, 1991 letter to Mr. Thomas Steinhagen. The interpretation is correct. My letter to Mr. Steinhagen was about the applicability of Standard 107 to a replacement windshield wiper arm and blade, a type of motor vehicle equipment that your client, Rally Manufacturing, seeks to sell. You state that Rally ceased producing certain windshield wiper arms and blades after NHTSA's Enforcement office notified Rally that it appeared the products did not meet the requirements of Standard 107. My letter to Mr. Steinhagen clarified the requirements of Standard 107 and the Vehicle Safety Act. I emphasized the following points in the letter: 1. Standard 107 applies to new motor vehicles, and not to items of motor vehicle equipment, such as a replacement wiper arm and blade. Replacement wiper arms and blades may be sold to consumers without violating Federal law, even if the component does not conform to the requirements of Standard 107. 2. Section 108(a)(2)(A) of the Safety Act prohibits any manufacturer, distributor, dealer or motor vehicle repair business from "rendering inoperative" any device or element of design installed in or on a vehicle in compliance with an applicable safety standard. If a person in the aforementioned categories installed a wiper arm and blade that did not conform to the requirements of Standard 107, the person would violate S108(a)(2)(A). 3. The prohibition of S108(a)(2)(A) does not apply to individual vehicle owners who alter their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to tamper with vehicle safety equipment if the modification would degrade the safety of the vehicle. 4. Regardless of whether Standard 107 applies to the replacement arm and blade, the device is subject to the requirements in SS151-159 of the Safety Act concerning the recall and remedy of products with safety defects. If the manufacturer or NHTSA determines that a safety-related defect exists either in an arm and blade that conforms to Standard 107 or in one that does not, the manufacturer must notify purchasers of the product and remedy the problem free of charge. In your letter, you specifically ask about the sale of a replacement wiper blade "by a wholesaler/distributor to retail stores and other similar customers without any installation service by the wholesaler/distributor." The sale is not prohibited by Standard 107 or S108(a)(2)(A). However, the retail store or "other similar customer" would be considered a dealer under S102(7) of the Safety Act, and thus subject to the "render inoperative" prohibition of S108(a)(2)(A). While the dealer may sell the replacement blade, the dealer would be prohibited from installing it on a motor vehicle. I regret any confusion resulting from NHTSA's letters to your client. If you have further questions, please do not hesitate to contact my office. |
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ID: nht94-2.28OpenTYPE: Interpretation-NHTSA DATE: April 8, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Derrick Barker -- John Martin Designs (Stourbridge, West Midlands) TITLE: None ATTACHMT: Attached to letter dated 12/22/93 from Derrick Barker to Mary Versilles (Versailles) TEXT: This responds to your letter concerning the buckle release requirement of Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding. You asked for the "tensile load requirements for the buckle and tongue." There is no specific requirement in Standard 213 for the tensile force that a child restraint buckle must withstand. Instead, the buckle must maintain its integrity when the chil d restraint is subjected to a simulated frontal impact at 30 mph with either a six-month-old (17 pounds (lbs.)) or three-year-old (33 lbs.) sized dummy restrained in the car seat. At the conclusion of the simulated impact, the force required to depress the latch button to release the buckle is measured and must be 16 lbs. or less. You also asked for a copy of Procedure D of the American Society for Testing and Materials Standard D756-78. Section S5.4.2 of FMVSS No. 213 sets forth those requirements by making reference to section S4.3(b) of FMVSS No. 209. which, in turn, leads to the reference to Procedure D of ASTM D756-78. The material you requested is enclosed. In addition, you asked for a list of laboratories that test child safety seats and buckles. NHTSA does not endorse particular test laboratories. However, I can provide you with a list of laboratories we are aware of that conduct child restraint complia nce tests. There may be other laboratories that can test child safety seats and buckles. Please contact Ms. Deirdre Fujita of my staff if you have further questions. LABORATORIES CONDUCTING CHILD RESTRAINT COMPLIANCE TESTS (Partial List - Addresses current as of Dec. 1993) CALSPAN CORPORATION (CAL) 4455 Genesee St. Buffalo, NY 14225 Phone: 716-632-7500 FAX: 716-631-6843 COMMERCIAL TESTING CO. (CTC) (Flammability testing) 1215 S. Hamilton Street Dalton, GA 30722-0985 Phone: 404-278-3935 FAX: 404-278-3936 DETROIT TESTING LABORATORY, INC (DTL) 7111 E. Eleven Mile Road Warren, Mi 48092-0869 Phone: 313-754-9000 FAX: 313-754-9045
MGA RESEARCH CORPORATION (MGA) 12790 Main Road P.O. Box 71 Akron, NY 14001-0071 Phone: 716-542-5515 FAX: 716-542-4437 MGA PROVING GROUNDS 5000 Warren Road Burlington, WI 53105 Phone: 414-763-2705 FAX: 414-763-0934 MOBILITY SYSTEMS & EQUIP. CO. (MSE) 19867 Cajon Blvd San Bernadino, CA 92407 Phone: 909-887-1938 FAX: 909-887-5937 MOBILITY SYSTEMS & EQUIP. CO. (MAIN OFFICE) 9920 LaCienega Blvd., Suite 708 Inglewood, CA 90301 Phone: 310-641-3606 FAX: 310-641 -1930 TRANSPORTATION RESEARCH CENTER OF OHIO (TRC) 10820 State Route 347 P.O. Box B67 East Liberty, OH 43319 Phone: 513-666-2011 FAX: 513-666-5066 UNITED STATES TESTING CO. (UST) - (Flammability testing) Engineering Services Division 291 Fairfield Avenue Fairfield, NJ 07004 Phone: 201-575-5252 FAX: 201-575-8271 UNITED STATES TESTING CO. (MAIN OFFICE) 1415 Park Avenue Hoboken, NJ 07030 Phone: 201-792-2400 FAX: 201-656-0636 UNIVERSITY OF MICHIGAN TRANSPORTATION RESEARCH INSTITUTE (UMTRI) 2901 Baxter Road Ann Arbor, MI 48109-2150 Phone: 313-936-1103 |
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ID: nht94-6.46OpenDATE: April 8, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Derrick Barker -- John Martin Designs (Stourbridge, West Midlands) TITLE: None ATTACHMT: Attached to letter dated 12/22/93 from Derrick Barker to Mary Versilles (Versailles) TEXT: This responds to your letter concerning the buckle release requirement of Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding. You asked for the "tensile load requirements for the buckle and tongue." There is no specific requirement in Standard 213 for the tensile force that a child restraint buckle must withstand. Instead, the buckle must maintain its integrity when the child restraint is subjected to a simulated frontal impact at 30 mph with either a six-month-old (17 pounds (lbs.)) or three-year-old (33 lbs.) sized dummy restrained in the car seat. At the conclusion of the simulated impact, the force required to depress the latch button to release the buckle is measured and must be 16 lbs. or less. You also asked for a copy of Procedure D of the American Society for Testing and Materials Standard D756-78. Section S5.4.2 of FMVSS No. 213 sets forth those requirements by making reference to section S4.3(b) of FMVSS No. 209. which, in turn, leads to the reference to Procedure D of ASTM D756-78. The material you requested is enclosed. In addition, you asked for a list of laboratories that test child safety seats and buckles. NHTSA does not endorse particular test laboratories. However, I can provide you with a list of laboratories we are aware of that conduct child restraint compliance tests. There may be other laboratories that can test child safety seats and buckles. Please contact Ms. Deirdre Fujita of my staff if you have further questions. LABORATORIES CONDUCTING CHILD RESTRAINT COMPLIANCE TESTS (Partial List - Addresses current as of Dec. 1993) CALSPAN CORPORATION (CAL) 4455 Genesee St. Buffalo, NY 14225 Phone: 716-632-7500 FAX: 716-631-6843 COMMERCIAL TESTING CO. (CTC) (Flammability testing) 1215 S. Hamilton Street Dalton, GA 30722-0985 Phone: 404-278-3935 FAX: 404-278-3936 DETROIT TESTING LABORATORY, INC (DTL) 7111 E. Eleven Mile Road Warren, Mi 48092-0869 Phone: 313-754-9000 FAX: 313-754-9045
MGA RESEARCH CORPORATION (MGA) 12790 Main Road P.O. Box 71 Akron, NY 14001-0071 Phone: 716-542-5515 FAX: 716-542-4437 MGA PROVING GROUNDS 5000 Warren Road Burlington, WI 53105 Phone: 414-763-2705 FAX: 414-763-0934 MOBILITY SYSTEMS & EQUIP. CO. (MSE) 19867 Cajon Blvd San Bernadino, CA 92407 Phone: 909-887-1938 FAX: 909-887-5937 MOBILITY SYSTEMS & EQUIP. CO. (MAIN OFFICE) 9920 LaCienega Blvd., Suite 708 Inglewood, CA 90301 Phone: 310-641-3606 FAX: 310-641 -1930 TRANSPORTATION RESEARCH CENTER OF OHIO (TRC) 10820 State Route 347 P.O. Box B67 East Liberty, OH 43319 Phone: 513-666-2011 FAX: 513-666-5066 UNITED STATES TESTING CO. (UST) - (Flammability testing) Engineering Services Division 291 Fairfield Avenue Fairfield, NJ 07004 Phone: 201-575-5252 FAX: 201-575-8271 UNITED STATES TESTING CO. (MAIN OFFICE) 1415 Park Avenue Hoboken, NJ 07030 Phone: 201-792-2400 FAX: 201-656-0636 UNIVERSITY OF MICHIGAN TRANSPORTATION RESEARCH INSTITUTE (UMTRI) 2901 Baxter Road Ann Arbor, MI 48109-2150 Phone: 313-936-1103 |
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ID: aiam0809OpenMr. Seymour M. Lewis, Legal Counsel, Automotive Trade Association, 110 South Dearborn, Chicago, IL 60602; Mr. Seymour M. Lewis Legal Counsel Automotive Trade Association 110 South Dearborn Chicago IL 60602; Dear Mr. Lewis: This is in reply to your letter of July 18, 1972, to Miss Nanc Brownell concerning the placement of additional seats in a 'van' by a dealer.; Section 108 of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. 1397) prohibits, among other things, the sale, offer for sale, or the introduction in interstate commerce of motor vehicles that do not conform to applicable motor vehicle safety standards in effect on the day of the vehicle's manufacture. This prohibition applies until after the sale of the vehicle to a purchaser for a purpose other than resale (15 U.S.C. 1397(b)(1)).; This provision prohibits all persons, including dealers, from alterin a new vehicle before its sale to a user in such a way that the vehicle no longer conforms to the standards. A person who performs such alterations would be required to ensure that the vehicle conformed to all applicable standards after the alterations have been made. It appears that merely adding seats to a van without making additional alterations would cause it to fail to conform to Motor Vehicle Safety Standard No. 208, 'Occupant Crash Protection', (49 CFR 571.208), and possibly other standards as well. The failure of the vehicle to conform could result in the imposition of civil penalties against the person making the alteration or selling the vehicle of up to $1,000 for each violation (15 U.S.C. 1398), and other sanctions (15 U.S.C. 1399).; You are right in your opinion that the vehicle may be modified withou regard to the standards after its first purchase for a purpose other than sale.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: nht71-3.22OpenDATE: 06/30/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Fiat Motor Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of February 19, 1971, in which you request an interpretation of the applicability of Federal Motor Vehicle Safety Standard No. 206 to the right side door of the Fiat City Taxi Car. I apologize for the delay in responding to your letter. Your questions and their answers are set forth below. Questions 1 and 2 have been reversed to facilitate discussion. "Can this door be classified as a sliding door?" Yes, if, as it appears, the mechanism attaching the right side door to the vehicle is a sliding device rather than a hinge system. "Can the outside door handle release control be inoperative and the door opened only from the inside." Yes, since the right side door is a sliding door, rather than a hinged door, it is not subject to the door lock requirements specified in S4.1.3 of the Standard. "Which are the loads, the direction and location of the load, and the test procedures to be followed to demonstrate that this door conforms to the Standard 206." The performance requirements and demonstration procedures which apply to sliding doors are specified in S4.3 and S5.3, respectively. S4.3 requires that the track and slide combination or other supporting means for the right side door not separate when a total transverse load of 4,000 pounds is applied, with the door in the closed position. Compliance of the right side door with S4.3 is required by S5.3 to be tested by applying an outward transverse load of 2,000 pounds to the load bearing members at the opposite edges of the door. The total force applied would be 4,000 pounds. S5.3 requires that the testing be done either in the vehicle or with the door retention components in a bench test fixture. "Can this door have only a fully latched position?" Yes. Standard No. 206 does not specify any requirements for latches on sliding doors. Please write if I can be of any further assistance. |
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ID: nht76-1.18OpenDATE: 11/10/76 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Nichirin Rubber Industrial Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in belated response to your May 14, 1976, letter concerning Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses. The National Highway Traffic Safety Administration (NHTSA) recognizes the designation "NCRN" as identifying Nichirin Rubber Industrial Co. on all brake hose and brake hose assemblies manufactured by Nichirin, regardless of whether these components are intended for use in hydraulic, air, or vacuum brake systems. The NHTSA does not issue approvals of motor vehicle equipment prior to sale. Under the National Traffic and Motor Vehicle Safety Act of 1966, as amended, certification of compliance with applicable safety standards is performed by the manufacturer. Standard No. 106-74 does not specify the testing which a manufacturer must do before certifying that his brake hose and assemblies comply; it does specify the performance levels which these products must meet when tested by the NHTSA for compliance. The manufacturer is required to exercise due care in assuring himself that his certification is neither false nor misleading. SINCERELY, NICHIRIN RUBBER INDUSTRIAL CO., LTD. NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION May 14, 1976 ATTENTION: Richard B. Dyson Acting Chief Counsel According to your letter on the 7th of Feb. in 1975, I understood that our designation "NCRN" had been entered in Office of Standards Enforcement. I want to ask your advice for following point. May I interpreted it that designation "NCRN" is able to apply to all head that is written in Federal Motor Vehicle Safety Standard No. 106-74? Namely these are S5 Hydraulic Brake Hose, S7 Air Brake Hose, S9 Vacuum Brake Hose. Now, we apply to the Hydraulic Brake Hose. In the future We Want to apply to the Air Brake Hose and Vacuum Brake Hose. Of course we think it is necessary that we complete regular process (AAMVA etc.) after test of TEST Laboratory in U.S.A. Will you please give me your advice that is necessary for me? Etsuo Yamazoe Factory Manager |
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ID: aiam0595OpenMr. Victor Wouk, Chairman, Technical Advisory Committee, Electric Vehicle Council, Edison Electric Institute, Petro- Electric Motors, Ltd., 342 Madison Avenue, New York, NY 10017; Mr. Victor Wouk Chairman Technical Advisory Committee Electric Vehicle Council Edison Electric Institute Petro- Electric Motors Ltd. 342 Madison Avenue New York NY 10017; Dear Mr. Wouk:#This is in further response to your letter of Decembe 16, 1971, requesting interpretations of several Federal motor vehicle safety standards as they apply to electric vehicles.#The engine retardation braking effect of Standard No. 102 applies only to vehicles equipped with automatic transmission, and not to an electric vehicle that has no transmission.#Standards Nos. 201 through 204 do not apply to trucks. You have stated that your electric vehicle is designed to that 'the rear . . . will normally be used for tools, service equipment, spare parts, etc., as would be required in a service vehicle as used by an electric utility company for going out and making repairs.' You have also stated that the back area could be converted to a seating area for two passengers, but that this would be 'unusual and occasional.' On the basis of this information we have concluded that you vehicle is a 'truck' and need not meet Standards Nos. 201-204.#Sincerely, Richard B. Dyson, Assistant Chief Counsel; |
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ID: nht95-2.47OpenTYPE: INTERPRETATION-NHTSA DATE: April 24, 1995 FROM: Philip R. Recht -- Acting Chief Counsel, NHTSA TO: Robert E. Fouts -- President, Earl's Performance Products TITLE: NONE ATTACHMT: ATTACHED TO 12/8/94 LETTER FROM ROBERT E. FOUTS TO PHILLIP RECHT (OCC 10555) TEXT: Dear Mr. Fouts: This responds to your question whether the whip test specified in Federal Motor Vehicle Safety Standard No. 106, Brake Hoses, can be interpreted to permit a modification to the test apparatus to facilitate your brake hose's meeting the whip test. As exp lained below, the answer is no. You describe your brake hose as made of "extruded teflon armored with stainless steel braid." You state your brake hose can meet all Standard No. 106 test specifications except for the whip test (See S6.3). The whip test specifies fastening the brake ho se on a test apparatus at two ends and cycling for 35 hours. You state because of "aggravated cyclic stress," your brake hoses fail before 35 hours. To prevent such failures, you wish to add a "whip dampener," a movable "spherical bearing enclosed in a machined housing", to the brake hose. In addition to the two ends, the whip test apparatus will mount the brake hose at the "whip dampener." You wish to know whether the whip test can be interpreted to permit mounting the brake hose at the "whip dampene r." In our opinion, S6.3 cannot be interpreted to permit mounting the brake hose at the "whip dampener." S6.3.1 Apparatus specifies a test apparatus that mounts the brake hose at "capped end fittings" on one end and "open end fittings" on the other, and spec ifies no mounting points in between. Thus, a test apparatus that mounts the brake hose at a "whip dampener," which is not an end fitting, would not meet Standard No. 106. However, the issues raised in your letter have led us to consider amending the whip test to permit the "whip dampener" when testing steel braided brake hoses. Accordingly, we will initiate rulemaking to further consider the issues. I hope this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. |
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ID: nht73-3.35OpenDATE: 03/01/73 FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA TO: E.T.R.T.O. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your submission No. 65/109 of January 23, 1973, petitioning that temporary exemption from Motor Vehicle Safety Standard No. 109 be provided for European tire manufacturers who manufacture high speed tires. Your petition points out that Standard No. 109 does not allow the manufacture of high speed tires designed to be inflated to relatively high inflation pressures, but which do not have commensurate load-carrying ability at those pressures. You indicate that such tires are commonly used in Europe for high speed passenger cars, and have not produced safety problems. The temporary exemption regulations (49 CFR 555, copy enclosed), in accordance with the statutory authority under which they were issued (P.L. 92-548), apply only to manufacturers of motor vehicles. They do not apply to manufacturers of motor vehicle equipment, and the relief which they provide is accordingly not available to tire manufacturers. The NHTSA is of the opinion that the requirements of Standard No. 109, emphasizing the load-carrying as well as the high speed capability of passenger car tires, should be suited to driving conditions which predominate in the United States. Despite the facts, as you mention, that it is possible for motorists to exceed posted speed limits, and that areas do exist where speed limits are not posted, the NHTSA believes the high speed requirements of Standard No. 109 are sufficient to guard against tire failures under these conditions. At the same time, the NHTSA will consider petitions to amend Standard No. 109, submitted pursuant to NHTSA procedural rules (49 CFR 553.31, .33), and E.T.R.T.O. is free to petition to amend the standard to include requirements for European-type high speed tires. Your petition should contain full supporting data for the amendments requested. We would expect you as well to include possible performance requirements for such tires. You refer briefly in your letter to the performance of these tires when tested pursuant to the planned Uniform Tire Quality Grading regulation. The NHTSA plans to publish in the very near future a revised notice of proposed rulemaking regarding this regulation, and we will be pleased to receive your comments to that proposal when it is published. |
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ID: 10555Open Mr. Robert E. Fouts Dear Mr. Fouts: This responds to your question whether the whip test specified in Federal Motor Vehicle Safety Standard No. 106, Brake Hoses, can be interpreted to permit a modification to the test apparatus to facilitate your brake hose's meeting the whip test. As explained below, the answer is no. You describe your brake hose as made of "extruded teflon armored with stainless steel braid." You state your brake hose can meet all Standard No. 106 test specifications except for the whip test (See S6.3). The whip test specifies fastening the brake hose on a test apparatus at two ends and cycling for 35 hours. You state because of "aggravated cyclic stress," your brake hoses fail before 35 hours. To prevent such failures, you wish to add a "whip dampener," a movable "spherical bearing enclosed in a machined housing", to the brake hose. In addition to the two ends, the whip test apparatus will mount the brake hose at the "whip dampener." You wish to know whether the whip test can be interpreted to permit mounting the brake hose at the "whip dampener." In our opinion, S6.3 cannot be interpreted to permit mounting the brake hose at the "whip dampener." S6.3.1 Apparatus specifies a test apparatus that mounts the brake hose at "capped end fittings" on one end and "open end fittings" on the other, and specifies no mounting points in between. Thus, a test apparatus that mounts the brake hose at a "whip dampener," which is not an end fitting, would not meet Standard No. 106. However, the issues raised in your letter have led us to consider amending the whip test to permit the "whip dampener" when testing steel braided brake hoses. Accordingly, we will initiate rulemaking to further consider the issues. I hope this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely,
Philip R. Recht Acting Chief Counsel ref:106 d:4/24/95
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1995 |
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.