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: aiam2094OpenMr. J. W. Kennebeck, Manager, Emissions, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Emissions Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This responds to Volkswagen of America's August 27, 1975, request fo confirmation that a seat belt warning system that activates a 4- to 8-second warning light when the vehicle ignitions turned complies with the requirements of S4.5.3.3 of Standard No. 208, *Occupant Crash Protection*, although the warning system also activates the same warning light continuously when a separate circuit senses that the front seat belts are not fastened.; Volkswagen's understanding of S4.5.3.3 is correct. As we understan your description, the Volkswagen warning system does provide the automatic 4- to 8-second activation of a warning light called for in S4.5.3.3. This provision prohibits the use of an activation longer than the limits set forth in the standard.; The Volkswagen system provides a different and additional activation o the warning light when the seat belts are not fastened, using a separate circuit to monitor a set of conditions separate from those specified in the requirements of S4.5.3.3. The National Highway Traffic Safety Administration does not consider this activation (which can be longer than 8 seconds) to violate the limit on activation of the automatic reminder specified by the standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam4843OpenMr. Delbert N. Pier Legislation and Compliance Coordinator Hyundai America Technical Center, Inc. 5075 Venture Drive Ann Arbor, MI 48108; Mr. Delbert N. Pier Legislation and Compliance Coordinator Hyundai America Technical Center Inc. 5075 Venture Drive Ann Arbor MI 48108; Dear Mr. Pier: This is in reply to your letter of February 11, l99l asking for an interpretation of Motor Vehicle Safety Standard No. 108. With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked 'whether the bulb fixture can be rotated approximately 11 degrees', and have informed us that this will not change the 'constants . . . or the relationship of the terminals to the constants.' Standard No. 108 does not specify the orientation of replaceable light sources in headlamps, the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector) of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0553OpenMr. Thomas E. Toney, III, Fordyce, Wayne, Hartman, Renard & Stribling, Attorneys and Counselors, 818 Olive Street, Saint Louis, MO 63101; Mr. Thomas E. Toney III Fordyce Wayne Hartman Renard & Stribling Attorneys and Counselors 818 Olive Street Saint Louis MO 63101; Dear Mr. Toney: This is in reply to your letter of October 10, 1972, requestin information on requirements applicable to the trucking industry regarding the reporting of numbers of vehicles produced. You also ask whether a person who adds a fifth wheel to complete a truck is a manufacturer who is subject to the requirements.; Section 573.5(5) of NHTSA 'Defects Reports' regulation (49 CFR Par 573) requires manufacturers of motor vehicles to report, on a quarterly basis, the total number of the manufacturer's vehicles by make, model, and model year, if appropriate, produced or imported during that quarter. This requirement applies to all manufacturers of complete or incomplete motor vehicles, including manufacturers of trucks. A person who adds a fifth wheel to an incomplete vehicle and completes the vehicle is considered to be a manufacturer under section 573.3 of the regulation, and is required to report production figures as part of his quarterly reports.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4510OpenMr. Donald Friedman President Liability Research, Inc. 4448 Via Esperanza Santa Barbara, CA 93110; Mr. Donald Friedman President Liability Research Inc. 4448 Via Esperanza Santa Barbara CA 93110; "Dear Mr. Friedman: This is a response to your letter dated Novembe 17, 1987, asking whether two child restraint systems you have designed comply with certain requirements of Federal motor vehicle safety standard 213, Child Restraint Systems. You call one system 'Cradle Safe,' and describe it as an inclined, rear-facing, deformable, vinyl-covered woodfiber board carrier designed to restrain new-born infants from 4.5 to 14 lbs. The second system you call 'Premie Cradle,' and describe it as a recumbent, rear-facing, deformable, vinyl-covered woodfiber board carrier designed for premature infants from 4 to 6 lbs. Your letter assesses the performance attributes of these systems as follows: 'In an accident the baby is oriented and cushioned to avoid injury and ejection by a deformable, energy absorbing 'bed' and 'shell' without harnessing the infant. The bed and its crushable extensions (wings) cause the infant to rotate and take acceleration forces through its back and limit those applied to the head. After rotation, the infant is cushioned by the collapsing bed.' You state your belief that both systems comply with applicable provisions of Standard 213, but ask for our comment because 'the designs are innovative and make the applicability and interpretation of certain paragraphs of the standard not entirely obvious.' To help the agency better understand your products and the methods you used to test performance, you requested that agency staff meet with you, and your colleague, Mr. David Shinn. On April 12, 1988, a meeting was held with you, Mr. Shinn, and agency staff from the following offices: Chief Counsel, Enforcement, Plans and Policy, Research and Development, Rulemaking, and Traffic Safety Programs. At that meeting, you and Mr. Shinn presented a video-film showing two sled-tests of your cradle-safe restraint system, one with a NHTSA-specified, 17 pound dummy, and one with an EEC eight pound dummy. In the video film, your child restraint system broke apart in the 30 mph test with the 17 pound dummy, but appeared to maintain its structural integrity when tested with the eight pound dummy. You did not show a sled-test with your 'Premie Cradle' product. By a letter dated June 8, 1988, you informed this agency that you had performed tests of a 'modified' Cradle-Safe restraint system, and that this system will contain the NHTSA-specified 17 pound dummy in simulated barrier-impact testing under Standard 213. You state further that a restraint system you call 'One-ride' also will contain a 17 pound dummy in Standard 213 testing. (You did not address the 'One-ride' restraint in your November 17, 1987, correspondence, nor did you present it during the April 12, 1988 meeting.) Your June 8 letter also references a letter of July 22, 1987, addressed to Mr. Val Radovich of this agency, a June 3, 1988 video tape showing a simulated barrier impact test of your Cradle-Safe seat with a 17 pound dummy, and submissions of patent documents in support of a patent application for your products. As NHTSA staff understood from your November 17, 1987 letter, and the April 12, 1988 meeting, your principal question was whether you could test a Standard 213 child restraint system with an eight or 14 pound dummy (rather than the specified 17 pound dummy), if you intended to label the restraint as appropriate for children from 4.5 to 10 pounds. You briefly addressed the other matters raised in your November 17, letter, clarifying a reference to an 'unspecified belt provided for use outside the vehicle and not required in (Standard 213) testing.' You explained that the 'belt' to which you refer is a two-piece, cloth wrap that anchors at either side of the restraint, and fastens over the child with a velcro attachment. I shall respond to your comments in the order that you present them in your letter, also discussing new matters raised in the meeting, in the June 8, 1988 letter, and in your other submissions where appropriate. I will not discuss the patent materials because they are not relevant to a determination of whether your restraint systems comply with Standard 213. In responding to your comments, I assume that we are discussing only those child restraint systems designed for children weighing less than 20 pounds (infant restraints). Your First Comment. Paragraph 5.1.1.a dealing with Child Restraint System Integrity specifies 'no complete...and no partial separation' of surfaces. Our design is deformable and involves materials of 1/4' thickness which in deforming, tear slightly. However when torn these materials are not lacerating and not likely to come into contact with the infant. Response. Paragraph S5.1.1(a) states that when a child restraint is tested as specified in the Standard, the system shall: Exhibit no complete separation of any load bearing structural element and no partial separation exposing either surfaces with a radius of less than 1/4 inch or surfaces with protrusions greater than 3/8 inch above the immediate adjacent surrounding contactable surface of any structural element of the system. If the system failure you describe as tearing of materials at the system surface does not result in a failure of the load-bearing structure of the system, then paragraph S5.1.1(a) is inapplicable. In 1978, NHTSA proposed adding this language to 213 as one of a number of amendments to the Standard that would upgrade performance requirements, improve performance criteria, and require dynamic testing of child restraint systems using anthropomorphic test dummies. (43 FR 21470, 21473, May 18, 1978.) In the preamble of that document, we stated that our objectives in promulgating the system integrity requirements were to prevent a child's excessive excursion or ejection from the system, and to ensure that the system does not fracture or separate in such a way as to harm the child. (43 FR 21470, 21473.) To accomplish this objective, Standard 213 requires that in dynamic testing, any load-bearing, structural element of a child restraint system must not separate completely, and that any partial separation must not expose surfaces with sharp edges that may contact the child. Id. Your letter states that some materials at the surface of your system may tear during an impact. In promulgating S5.1.1(a), the agency intended to minimize dangers resulting from failures in the structural integrity of the system, rather than failures in the materials. The agency did not intend to preclude a manufacturer from designing some deformation into a child restraint system to improve the system's energy absorption performance. Your Second Comment. Paragraph 5.2.3.2.b The system surface in contact with the infant's head shall be covered with slow recovery, energy absorbing material. Although our system surfaces are not covered, they are fabricated out of such material. The system surface in contact with the infants head (the bed) is 3/16' woodfiber separated by air from a similar material in the shell. The system complies with the requirement and when dynamically tested exhibits deformation much better than a 25% compression-deflection, but there is no appropriate ASTM Test Standard such as for open or closed cell foam. Response. As I read your comment, you raise three issues which I shall address separately. The first is whether the material from which you fabricate your system can meet the S5.2.3.2(b) requirement that a child restraint system must be 'covered' with slow recovery, energy absorbing material. The agency's long-standing position is that a given type of surface material is an acceptable 'covering' if it is a flexible material that would meet the thickness and performance requirements for energy-absorbing padding set out in paragraphs (a) and (b) of S5.2.3.2. The surface needn't have a separate layer of energy-absorbing padding. The second issue is whether 3/16 inch woodfiber is a sufficient thickness for a system surface. This thickness would not comply with S5.2.3.2(b) of Standard 213. That subparagraph requires thicknesses of at least 1/2 or 3/4 inch, depending on the material's compression-deflection performance as measured in the static testing specified in S6.3 of Standard 213. You assert that the 3/16 inch thickness material used in your systems exceeds a 25% compression-deflection measurement in dynamic testing. In the preamble to the final rule amending Standard 213, NHTSA responded to commenters who suggested that specifying a minimum thickness for the infant restraint surface was design-restrictive. (44 FR 72131, 72135, December 13, 1979.) We explained in that document that we set these minimum thickness requirements because there was no available test device to measure the energy absorption properties of either the surface or underlying structure of an infant restraint in dynamic testing. Consequently, the agency specified 'long-established static tests' of the surface material, and established minimum thickness requirements based on the results of those static tests. Therefore, a compression-deflection measurement derived from dynamic testing is not an acceptable test of compliance with paragraph S5.2.3.2. The third issue is whether the compression-deflection measurement for this system must be derived from tests under one of the ASTM standards in S6.3, even though none of the ASTM titles expressly states that the test is for woodfiber, and all three procedures are for static tests. Paragraph S5.2.3.2(b) requires that when one tests the energy absorption properties of child restraint materials, those tests must be conducted under one of three ASTM static test procedures set out in paragraph S6.3 of Standard 213. Your restraint systems are made of woodfiber. Woodfiber - or any material that meets the Standard's requirements - can be an acceptable substance out of which to fabricate a child restraint. As NHTSA stated in the final rule preamble cited earlier, the agency wishes to allow restraint manufacturers to use a wide range of materials, provided that the material exhibits acceptable energy absorption properties. You may use any ASTM title specified in paragraph S6.3 to test your surface material, and the material is acceptable if it displays the required energy absorption properties when tested under one of those titles. Your Third Comment. Paragraph 5.4.3.1 'Each belt that is part of a child restraint system and that is designed to restrain a child using the system...' is interpreted to mean that a soft unspecified belt provided for use outside the vehicle and not required in testing, need not conform to this paragraph. Response. As you explained in the April 12, meeting, the 'belt' to which you refer is the cloth device described in the beginning of this letter. By its express terms, paragraph S5.4.3.1 is inapplicable to belts that are (1) not part of the child restraint system and (2) not designed to restrain a child using the system. On the other hand, I note that in the June 8, video tape, the narrative refers to a belt within the Cradle-Safe system as a belt for restraining the child. If you do intend any belt in the system to be used for restraining the child, then various provisions of paragraph S5.4.3, Belt Restraint, will apply, depending on the design configuration of the belt assembly. In the preamble to the May 1978 proposal cited earlier in this letter, the agency expressed its continuing concern that child restraint system designs minimize the prospect of system misuse. (43 FR 21470, 21471.) If there are belts in any of your child restraint systems that you do not intend as restraints for the child, then I hope you will consider whether these additional belts unreasonably increase the risk that some users will mistake the additional belt assembly as a Standard 213 belt intended for use in restraining a child. Your Fourth Comment. Paragraph 6. This paragraph requires the CRADLE SAFE to be tested with a paragraph 7 dummy (17 lb.) for which it was not designed and which cannot be physically accommodated. We would prefer to use available 7.8 lb. and/or 14 lb. non-specified dummies. The PREMIE CRADLE falls in the car bed 'travel crib' category and does not require dynamic testing. Response. Paragraph S7.1 of Standard 213 requires testing an infant restraint system with the 6-month-old dummy specified in 49 CFR 572.25. (An infant restraint system is one that is recommended 'for use by children in a weight range that includes children weighing not more than 20 pounds.') That test device is 17.4 pounds. Because your child safety system meets the definition of infant restraint, it must be capable of meeting Standard 213 performance requirements when tested with the specified 17.4 pound dummy. If an infant restraint can not accommodate this test device, then it can not be certified as complying with Standard 213. I understand from your June 8, 1988, letter that the Cradle-Safe and One-Ride systems will accommodate the specified 17.4 pound dummy in Standard 213 testing. Further, your restraint systems must meet head excursions limits with the 17.4 pound dummy under paragraph S5.1.3.2, Rear-facing Child Restraint Systems. The dummy specified in Part 572 is based on a simple design that represents a 6-month-old infant in dimensional, mass distribution, and dynamic response characteristics. NHTSA chose to use this test dummy after conducting extensive testing and evaluation of the dummy's responses. The testing, conducted by NHTSA and the Federal Aviation Administration (FAA), showed that the specified dummy provided a consistent and repeatable measure of the structural integrity and confinement properties of a child restraint system, and was superior to a previous test version. (43 FR 21490, May 18, 1978, 44 FR 76527, December 27, 1979.) Before we can sanction use of another device to test an infant restraint system, the agency would have to determine that the dummy is a reliable surrogate for measuring a system's performance in an actual crash. NHTSA can not now make that statement with respect to any unspecified dummy, instrumented or non-instrumented. The agency can make this kind of finding only through a rulemaking process. Further, contrary to what you believe, infant car beds are subject to dynamic testing to ensure that the test dummy stays within the confines of the restraint system during impact. (Standard 213, S6.1.2.3.3.) While you believe you have identified some potential problems with Standard 213, I am sure that you can appreciate the need to follow established procedures when considering any change to a safety standard. Following established practices helps ensure that child restraint systems which comply with Federal standards continue to offer satisfactory crash protection for children. The agency has scheduled two public meetings this summer in order to explore the need for changes to Standard 213. I enclose a copy of the notice announcing these meetings, and invite you to participate in the forum. Based on the information you provided, it appears that you would have to modify your systems, or the agency would have to amend Standard 213 in order for you to be able to certify your child restraint system as satisfying all the applicable requirements of that Standard. Title 49 CFR Part 552, Petitions for Rulemaking, Defect, and Noncompliance Orders (copy enclosed) sets out a procedure for petitioning the agency to amend a safety standard, and you have a right to file such a petition. If NHTSA grants your petition, the agency would follow its normal rulemaking procedures to amend Standard 213. If you have some further questions or need further information on this subject, please contact Joan Tilghman of my staff at our address, or telephone (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosures"; |
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ID: aiam1712OpenMr. William D. Stokes, Laurence, Stokes & Neilan, Suite 805, Crystal Plaza 1, 2001 Jefferson Davis Highway, Arlington, VA 22202; Mr. William D. Stokes Laurence Stokes & Neilan Suite 805 Crystal Plaza 1 2001 Jefferson Davis Highway Arlington VA 22202; Dear Mr. Stokes: This is in reply to your letter of November 8, 1974, asking whethe manufacturers of pickup caps are required to certify these equipment items under the National Traffic and Motor Vehicle Safety Act.; There is no requirement at present that pickup caps be certified. Th certification label is a manufacturer's representation that a motor vehicle or item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards, and there are no standards that presently apply to pickup caps.; Your client should be aware of a related requirement. Motor Vehicl Safety Standard No. 205, 'Glazing materials' (49 CFR S 571.205), specifies requirements for glazing materials (glass and plastics for windows, doors, and interior partitions) used in motor vehicles and motor vehicle equipment, including pickup covers (essentially pickup caps as you describe them). Although applicable to the glazing material, the standard's effect under the National Traffic and Motor Vehicle Safety Act is that pickup caps must contain only glazing materials that meet the requirements of the standard.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0800OpenMr. Keitaro Nakajima, Director/General Manager, Toyota Motor Sales, U.S.A., Inc., Factory Representative Office, Lyndhurst Office Park, 1099 Wall Street, West, Lyndhurst, NJ, 07071; Mr. Keitaro Nakajima Director/General Manager Toyota Motor Sales U.S.A. Inc. Factory Representative Office Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of June 27, 1972, asking whether th temporary covers which you intend to use to protect a vehicle's upholstery during shipment and storage in a dealer's yard are permitted despite their nonconformity with Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You indicate that you plan to take four steps to ensure that the covers are removed by the dealer before delivery to a customer.; While you may follow the procedure you have specified, your first ste (the attachment of a statement to the windshield pursuant to 12.80(b)(2)(iv) of each car stating that the vehicle does not conform to FMVSS No. 302, but will be brought into conformity when the covers are removed by the dealer) appears unnecessary. The NHTSA has determined that such covers will not be subject to the standard and may be installed without affecting the vehicle's conformity, if the manufacturer takes appropriate steps to ensure that the covers are removed before the car is put into use.; Two steps which should be taken to manifest this intent are: (1 placing the covers in the vehicle in such a way that their use after purchase is unlikely, and (2) making adequate provision that the covers are removed before sale to the purchaser. Although you appear to deal adequately with the second step, you should also place the covers in the vehicle in such a way that their use after purchase is unlikely. If Toyota does take these steps, then the temporary covers would not be required to conform to Standard No. 302.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4140OpenMr. Toshio Maeda, Executive Vice President & Chief Operating Officer, Nissan Research & Development, Inc., P.O. Box 8650, Ann Arbor, MI 48104; Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Maeda: Thank you for your letter of April 11, 1986, requesting a interpretation of the comfort and convenience requirements of Standard No. 208, *Occupant Crash Protection*. Your specific question is whether the retraction requirements of S7.4.5 of the standard apply only to the front outboard seating positions. As explained below, the answer is yes.; The April 12, 1985 notice proposed changes to the comfort an convenience requirements in response to petitions for reconsideration. In the case of the retraction requirements, the proposed language of S7.4.5 said that the requirement would only apply to a safety belt system installed at the 'front outboard designated seating position.' In the November 6, 1985 final rule adopting the retraction requirement, the agency dropped the reference to the 'front outboard seating position.' However, S7.4.5 still referred to conducting a compliance test on a test dummy which has been positioned 'in accordance with S10.' S10, in turn, references the test dummy positioning requirements of S8.1.11. S8.1.11.1 and S8.1.11.2 provide for positioning test dummies in the front outboard seating positions. Thus, the minor change in the language of the requirements did not change the applicability of the requirement. However, to eliminate any possible ambiguity about the application of the retraction requirement, the agency is planning to amend S7.4.5 to provide explicitly that it only applies to the front outboard designated seating positions.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3685OpenThe Honorable Charles H. Percy, United States Senate, Washington, DC 20510; The Honorable Charles H. Percy United States Senate Washington DC 20510; Dear Senator Percy: This responds to your letter of April 11, 1983 (Ref. 3098500010 requesting information on behalf of your constituent, Mrs. D. Parutti. Mrs. Parutti is concerned about the growing practice of persons installing darkly tinted film on passenger car windows. She believes this is a dangerous practice because it prevents other drivers from seeing inside the vehicles. Following is a discussion of the implications under Federal law of installing these tinting films.; A Federal regulation already exists which, under certain circumstances precludes the practice referred to by Mrs. Parutti. The National Highway Traffic Safety Administration has the authority to govern the manufacture of new motor vehicles and motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, we have promulgated Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance. This specification for light transmittance precludes darkly-tinted windows in new automobiles.; The agency has stated in past interpretations that solar films such a the type referred to in Mrs. Parutti's letter are not glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, that manufacturer or dealer has to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Section 108(a)(1) prohibits any person from offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards.; After a new vehicle has been sold to the consumer, he may alter hi vehicle as he pleases, so long as he adheres to all State requirements. Under Federal law, the owner could install the tinting film on glazing in his vehicle whether or not such installation adversely affected the light transmittance and abrasion resistance of his vehicle's glazing. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. Render inoperative' means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the Federal safety standards. Thus, none of those persons may knowingly install a solar film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.; The individual States must govern the operational use of vehicles b their owners since the agency does not have authority in this area. Thus, it would be up to the States to preclude owners from applying films or one-way glass on their own vehicles. Mrs. Parutti may wish to contact the National Committee on Uniform Traffic Laws (555 Clark Street, Evanston, Illinois 60204) to find out which States have laws that would preclude owners from placing solar film on their automobile windows.; Please contact Hugh Oates of my staff if you have any further question (202- 426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2997OpenMr. Paul Utans, Product Compliance, Subaru of America, Inc., 7040 Central Highway, Pennsauken, NJ 08109; Mr. Paul Utans Product Compliance Subaru of America Inc. 7040 Central Highway Pennsauken NJ 08109; Dear Mr. Utans:#This is in response to your letter of March 26, 1979 requesting our interpretation of whether the turn signal identification symbol which you propose meets the requirements of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The answer is yes. As long as the turn signal symbol is displayed in the horizontal mode, as shown in Table 1, it will comply with the standard. Small additional arrows that will not be confused with the turn signal symbol may be incorporated to indicate movement of the control. Your thin vertical arrows do not appear to pose any possibility of causing such confusion.#Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam1342OpenSheller Globe Corporation, Lima, OH; Sheller Globe Corporation Lima OH; In response to your telegram of December 6 NHTSA would consider the us of a roof emergency exit as appropriate to meet the requirements to S5.2.1 of standard No. 217 if it were impracticable to use a rear exit because, as you state, retooling an existing configuration would be excessively expensive.; Richard B. Dyson, Assistant Chief Counsel, N40-30, National Highwa Traffic Safety Administration, Department of Transportation; |
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.