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: aiam5594OpenMr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo, CA 93012; Mr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo CA 93012; "Dear Mr. Ponticelli: This replies to your letter of July 25, 1995 asking for an opinion 'on the use of Electro-Luminescent Strip Lighting on motor vehicles.' The device in question 'is an ornamental light which produces less than .05 candela/sq. inch.' You have enclosed a brochure which shows the strip in use as a license plate frame and to mark the sides or perimeter of a vehicle. We assume that you are not asking about the license plate frame but only the 'Lighted Pin Striping'. The 'Lighted Pin Striping' comes in 'basic white' but once applied, seven colors of overlay tape are available to change the color. The brochure shows it in shades of blue and pink. You would like our views 'on the installation of this product by regulated parties such as new car dealers and non-regulated entities such as aftermarket specialty shops and vehicle owners.' We are pleased to provide you with the interpretation you seek. The basic obligation of a new-car dealer is to deliver a new car that remains in compliance with all the applicable Federal motor vehicle safety standards for which its manufacturer has certified compliance. In other words, the dealer must ensure that none of its actions before the sale of a new vehicle create a noncompliance with a safety standard. Further, if a dealer alters a vehicle before sale other than by the addition, substitution, or removal of readily attachable components, or minor finishing operations such as painting, is required to certify that the altered vehicle continues to meet the standards. The Federal new vehicle standard that relates to your product is Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. This standard permits a new car dealer to add supplementary lighting equipment such as the luminescent strip if the supplementary equipment does not impair the effectiveness of the lighting equipment required by Standard No. 108. The most common cause of impairment is lighting equipment that creates confusion with, or distraction from, the purpose of any item of required lighting equipment. Under Standard No. 108's lighting scheme, the color of lamps on the front of a vehicle are restricted to white and amber. On the side of the vehicle, side marker lamps and reflectors must be only amber to the front and red to the rear. Rear lighting is red or amber, with the color white permitted for the backup lamp only. The Lighted Pin Striping comes in a variety of colors. Your brochure shows one that is pink or red in color mounted on the front of a vehicle. We believe it possible that a motorist seeing a color of light on the front of the vehicle generally used on the rear or on the side at the rear could be distracted from the driving task. There is also the possibility that the strip would be bright enough to mask and thereby reduce the effectiveness of an adjacent front or rear turn signal, or stop lamp. In general, the agency tries to discourage the use of novelty lighting devices because of the uncertain reaction an unfamiliar light or reflection may cause in other drivers on the roadway. However, the determination as to whether installation of the lighting strip would impair the efficiency of required lighting equipment is initially that of the new car dealer who must determine whether his modifications to a new vehicle might take it out of compliance. Unless that determination is clearly erroneous, NHTSA will not contest it. With respect to sales in the aftermarket, installation by a manufacturer, distributor, dealer, or motor vehicle repair business of the lighting strip would be prohibited if the use of the strip would, in the words of the statute, 'make inoperative' any of the required lighting equipment. We tend to equate 'make inoperative' and 'impair effectiveness' so that the same considerations would have to be taken into account in installing the lighting equipment on a used as well as a new car. However, this prohibition does not extend to the vehicle owner who, under Federal law, may install the lighting strip regardless of its effect upon compliance. Nevertheless, even if novelty lighting equipment does not violate Federal law, the ultimate decision of its acceptability is that of the State in which the lighting strip is to be used. It is our understanding that, for example, that California requires any emitted or reflected light from the front of vehicles to be white or yellow in color, which would appear to preclude installation of the lighting strip in colors other than these. For an opinion on the treatment of the lighting strip under State laws, we suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0796OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letters of July 25 and 28, 1972, on th subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.; The 'nominal design riding position' specified in Standard 208 an formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.; The term 'most upright position' used in Standard 210 was adopted i part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.; There have, however, been difficulties with the use of the 'mos upright position', in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the mannikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the *Federal Register*.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1884OpenMr. Jim Kielty, 1700 N. North Part - 3P, Chicago, IL 60614; Mr. Jim Kielty 1700 N. North Part - 3P Chicago IL 60614; Dear Mr. Kielty: This is in response to your letter of February 25, 1975, requestin information concerning the odometer disclosure requirements contained in Title IV of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513).; I have enclosed copies of the package that was sent to the Stat Attorneys General requesting their assistance in attacking the problem of odometer tampering and the report made by the agency pursuant to Section 413 of the Act.; You ask whether odometers are now tamper-proof and whether a Federa standard exists which requires their use. As far as we know, there is no item which could be called a 'tamper-proof' odometer currently in use on motor vehicles. Some vehicle manufacturers have tamper-resistant odometers, but, I do not know if these are installed as standard equipment on vehicles. The National Highway Traffic Safety Administration (NHTSA) has not promulgated a standard requiring the inclusion of tamper-resistant odometers in motor vehicles. The concept has been examined, but the problems inherent in specifying objective criteria for tamper-resistance appeared great. It became apparent that development of a 'tamper-proof' odometer specification was not possible, since we are uncertain if there is any way of making an odometer truly tamper-proof. We are open to suggestions as to how we might develop criteria that would ensure some level of tamper resistance.; Since the Federal odometer disclosure statement is mandatory throughou the United States, there is no pressure on States to make the Federal statement mandatory via State law. Some States have retained the odometer laws of disclosure that were in effect in their State prior to the enactment of the Cost Savings Act. In these States, the State law is not affected by the Federal requirements, as long as the Federal requirements are fulfilled. We do not know how many States have adopted disclosure requirements identical to the Federal ones. However, we support such a move, since it would then enable the State to enforce its provision and utilize any State remedies that might be available for noncompliance.; To date, the NHTSA has not prepared any model State odometer tamperin legislation. We do, however, intend to develop a model State law sometime in the near future. Any State that requests assistance in preparing odometer tampering legislation for presentation to the State legislature would be provided with the model law.; Based on a survey conducted by the NHTSA concerning the level o compliance with the disclosure requirements of the odometer law, it became apparent that a large number of used car dealers are not complying with the disclosure provisions. We have been attempting to solve this problem by enlisting the aid not only of the National Automobile Dealers Association but the Dealers Safety Mobility Council and the American Association of Motor Vehicle Administrators. In addition, a public information campaign has been initiated by the NHTSA that hopefully will ameliorate the current odometer disclosure problem.; Private civil actions have been brought under the Cost Savings Act Since they are private actions, it would be very difficult for us to monitor them. Thus, we must rely on individuals to report cases to us. For this reason, we do not know how many actions have been initiated, nor how they have been resolved.; We have received numerous reports alleging repeated violations of th Act by single dealers. However, since we have no investigative authority under the Act, we are unable to investigate the reports to obtain evidence necessary to bring an injunctive suit (the only Federal enforcement remedy under the Act). We were able to obtain sufficient evidence to bring such a suit in Florida. That case is currently in progress and had the advantage of two informants who were prior employees of the defendant and willing to testify against him.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0283OpenMr. A. Hammerstein, Robert Bosch GMBH, 7000 Stuttgart- Feuerbach, Postfach 400, Germany; Mr. A. Hammerstein Robert Bosch GMBH 7000 Stuttgart- Feuerbach Postfach 400 Germany; Dear Mr. Hammerstein: This is in reply to your letter of December 23, 1970, to the U. S Department of Transportation concerning the time when stop lamps will be required to meet Class A photometrics.; The conflict between the requirements of paragraphs S4.1.1.6 an S4.1.1.7 has already been called to our attention, and will be clarified in an amendment to Standard No. 108 scheduled to be published in the *Federal Register* in the near future.; It was not intended for the stop lamps to meet the Class A photometri values, nor are they required to, until January 1, 1973.; Sincerely, Roger H. Compton, Director, Office of Operating Systems Motor Vehicle Programs; |
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ID: aiam5081OpenMs. Shirley A. Stewart President SAS Electrical Service, Inc. 1601 Society Court Herndon, VA 22070; Ms. Shirley A. Stewart President SAS Electrical Service Inc. 1601 Society Court Herndon VA 22070; "Dear Ms. Stewart: This responds to your letter of October 16, 1992, t this office regarding the installation of a 'silent monitor' on school buses. You stated in your letter that you made a presentation to Mr. Maurice Hicks and Mr. Rich Van Iderstine of this agency at a meeting on October 2, 1992, and you asked how our standards apply to installation of this device on school buses. You described the silent monitor as a six-inch cube of welded steel designed to house a video camera to monitor the interior of school buses. You explained that the device is installed in the interior access panel above the bus windshield facing the passenger compartment. The box protrudes into the interior of the bus by three to four inches. The front of the box, which swings open for installation of a video camera, contains a reflective solar glass window to prevent glare on the inside of the box. By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable Federal safety standards. The following represents our opinion based on the facts provided in your letter. NHTSA does not have any safety standards specifically covering silent monitors. However, it is possible that the installation of a silent monitor could affect the compliance of a vehicle with some safety standards. All new motor vehicles manufactured for sale in the United States must be certified by their manufacturers as complying with the applicable Federal motor vehicle safety standards. If your silent monitor is installed in a new school bus prior to its first sale to a customer, the person making the installation would be considered a vehicle alterer. Under our certification regulation (49 CFR Part 567), a vehicle alterer must certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards. Manufacturers, distributors, dealers, or motor vehicle repair businesses modifying a used vehicle are prohibited by Section 108(a)(2)(A) of the Safety Act from knowingly rendering inoperative any safety device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Thus, if your silent monitor is installed in a used school bus, any businesses, including your own, making such installations cannot render inoperative the vehicle's compliance with any of our standards. We also note that manufacturers of motor vehicle equipment have responsibilities under the Safety Act regarding safety defects. Under Sections 151, et seq., of the Safety Act, such manufacturers must notify purchasers about safety-related defects and remedy the product free of charge. In order to determine how installation of your silent monitors could affect the compliance of school buses with applicable Federal safety standards, you should carefully review each standard, including but not limited to those addressing school bus body joint strength, crash protection, and windshield intrusion. In that regard, I am enclosing for your information a fact sheet entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and a booklet entitled Federal Motor Vehicle Safety Standards and Regulations. As indicated above, you stated that your silent monitor would be installed in the interior access panel above the bus windshield facing the passenger compartment. Given the added weight that would be on the panel, we suggest that you carefully evaluate whether additional securement of the panel is needed to ensure that the panel and silent monitor do not come loose during a crash. We also note that the silent monitor appears to have sharp edges. You may wish to consider adding padding to prevent injury to an occupant who comes in contact with the monitor. I hope this information is helpful. If you have any further questions, please feel free to contact Walter Myers of my staff at this address or at (202) 366- 2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0779OpenMr. Satoshi Nishibori, Engineering Representative, Liaison Office in U.S.A., 560 Sylvan Avenue, Englewood Cliffs, NJ, 07632; Mr. Satoshi Nishibori Engineering Representative Liaison Office in U.S.A. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letter of June 29, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to replacement parts for vehicles manufactured on or after September 1, 1972.; Standard No. 302 does not apply to replacement parts or aftermarke materials irrespective of the date of their manufacture. It applies only to new vehicles manufactured on or after September 1, 1972, and not to the replacement materials used in those vehicles.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2744OpenMr. Emil M. Mrak, 602 Cordova Place, Davis, CA 95616; Mr. Emil M. Mrak 602 Cordova Place Davis CA 95616; Dear Mr. Mrak: This is in reply to your letter of December 12, 1977, to Secretary o Transportation, Mr. Brock Adams, concerning the seat belts in your automobile.; Federal Motor Vehicle Safety Standard No. 208, Occupant Cras Protection, requires that the distance between the lap-shoulder belt intersection and the vertical center line of a 50th percentile (164 pounds, 5 feet 8 inches) adult male occupant must be at lease six inches when the seat is in its rearmost position. The purposes of this requirement is to reduce the risk of the occupant 'submarining' out from under the belt and to reduce the possibility of the shoulder belt pulling the lap belt up onto the abdomen where it could cause serious injury in a crash.; The possibility of submarining increases as the intersection of th lap-shoulder belt is moved toward the occupant's centerline and/or as seat cushion rigidity is reduced. In other words, the closer the intersection of the lap-shoulder belt is to the centerline of the occupant, and the softer the seat, the more the danger of 'submarining' in a crash. The standard does not limit the maximum distance from the occupant's centerline to the lap- shoulder belt intersection because of varying degrees of seat rigidity and installation configurations. Thus, contrary to what you may have been told, manufacturers who provide belt systems with distances greater than six inches do so by choice and not because they are required to do so by Federal standards.; Thank you for informing us of your problem. Sincerely, Elwood T. Driver, Acting Associate Administrator fo Rulemaking; |
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ID: aiam3856OpenWilliam Richard Alexander, Pupil Transportation Section, Maryland State Department of Education, 200 West Baltimore Street, Baltimore, MD 21201-2595; William Richard Alexander Pupil Transportation Section Maryland State Department of Education 200 West Baltimore Street Baltimore MD 21201-2595; Dear Mr. Alexander: This responds to your March 20, 1984, letter to the National Highwa Traffic Safety Administration (NHTSA), concerning the Federal school bus safety standards administered by this agency. You asked three questions regarding passenger seating in school buses and the classification of vehicles as school buses.; Specifically, your questions asked: >>>(a) There are 9 students plus the driver, for a total of 10 people in a school bus. For purposes of the definition of a school bus, is the driver a passenger?<<<; Section 571.3 of the Code of Federal Regulations defines a 'school bus as a bus that transports children to or from school or related events. Our regulations further define 'bus' as a vehicle designed for carrying more than 10 persons. The driver is considered a 'person' under our regulations. Thus, it may be useful to remember that any vehicle that carries more than 10 *persons* is a bus. Your vehicle which seats 9 students plus the driver, for a total of 10 persons, would not be considered a school bus.; >>>(b) If a van is originally designed for 11 passengers plus a drive and, because the definition of a school bus, the school system desires to alter the number of seat spaces by removing seats so that the van will accommodate 9 pupils plus the driver, will this alteration in any way conflict with the definition of vehicle capacity? (I would assume that any structural changes would place liability in the event of accident attributable to that alteration on the local school system making the change.) <<<; In asking whether the alteration will 'conflict with the definition o vehicle capacity,' we assume that you are asking whether removing the seats of the vehicle changes the classification of that vehicle as a bus. Your letter is not clear whether it is a dealer who will be modifying the vehicle prior to its sale to the school system, after its sale to the school system, or whether the school itself will be modifying the bus after purchasing the vehicle. We will address these situations in our answer.; Altering an 11-passenger van by removing some of its seats so that i would no longer be of a passenger capacity that would classify it as a bus is, in theory, permissible. If a dealer makes such a modification before the vehicle is sold to you, it must attach an alterer's label in accordance with Part 567.7, *Certification*, of our regulations. Since the dealer would be changing the vehicle type from a bus to a multipurpose passenger vehicle, it must make sure that the vehicle complies with all of the standards applicable to that new vehicle type. This might be difficult since some different standards apply to multipurpose passenger vehicles than apply to buses.; If the modifications to the vehicle are made by a business such as garage after you purchase the vehicle, the persons modifying the vehicle must not knowing (sic) render inoperative the compliance of your vehicle with any applicable safety standard. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibits motor vehicle manufacturers, distributors, dealers and repair businesses from rendering inoperative equipment or designs that are incorporated in motor vehicles in compliance with the Federal motor vehicle safety standards. This means that a person in any of the above categories would not be permitted to destroy the vehicle's compliance with any safety standard by the removal of the seat.; The prohibition against rendering inoperative does not apply to a owner, such as a school or a state, which modifies its own vehicles. A school modifying its own vehicles need not assure that the vehicles comply with the Federal school bus safety standards. However, you are correct in assuming that your school could incur substantial tort liability in the event of an accident involving a vehicle that was not in compliance with the appropriate safety standards. This matter should be discussed with your insurance company and attorney. You should further determine whether your State law would prohibit the use of these vehicles to transport school children.; >>>(c) On a 60-passenger school bus, all of the seats except the thre rows in the front are removed. Each seat is 39 inches in width and is used to accommodate two high school pupils. The vehicle color is something other than yellow. A floor-to-ceiling barrier, with an emergency opening, is installed behind the three rows of seats. Supplies, materials, tools, equipment, etc., are transported in the rear of the vehicle with up to 12 youngsters plus the driver in the front portion. Given that all these factors exist at one time, will this vehicle be in conflict with any federal standards? If so, which ones?<<<; There are several areas of school bus safety which could be affected b the proposed modification of the vehicle. Since the vehicle will be carrying more than 10 persons, it is categorized as a bus, and classified by its use as a school bus. A threshold issue related to the question you asked concerns, again, the possibility that removing the bus seats will render inoperative the vehicle's compliance with the Federal school bus safety standards. The issue depends on whether it is a garage-type business that will be altering the bus, or the school. Modification of a safety system so that it no longer complies with all applicable safety standards in effect on the date of the vehicle's manufacture would be a violation of Section 108(a)(2)(A). As discussed earlier, this prohibition does not apply to an owner, such as a school or a state, which modifies its own vehicles. A school may make any modification that it chooses to its buses. Such action does not violate the Vehicle Safety Act or render the school subject to any penalty under the Act.; However, as you know, private liability might occur if th modifications took the vehicle out of compliance with the safety standard and a student was subsequently injured in one of the buses. Accordingly, the modifications you make should not negatively affect the compliance of your vehicle with the safety standards.; The removal of the bus seats does not appear likely to affect adversel your vehicle's compliance with the Federal safety standards. Those standards do not require the installation of any specific seats or any specified number of seats in school buses. Instead, the standards specify that certain requirements must be met for any seat that is installed. Therefore, if the bus complied with the requirements of the Federal school bus safety standards before its alteration, the proper removal of the seats would not affect the vehicle's compliance.; You propose to install a floor-to-ceiling barrier in the vehicle behin the three rows of seats. Your letter does not describe this barrier in detail, but states that it contains an emergency opening. We are concerned that this barrier would render the vehicle in noncompliance with the requirements for emergency exits found in FMVSS No. 217, *Bus Window Retention and Release*.; Standard No. 217 regulates the number and size of school bus emergenc exits and requires that the release mechanisms of those exits be readily accessible. The purpose of these requirements is to provide an easily operable, unobstructed school bus emergency exit. In the past, the agency has preempted a State requirement for a safety chain that would have been placed across an exit, because we viewed the chain as providing an obstruction to the opening. We have also interpreted the Standard to prohibit a ramp used for transporting the handicapped when the ramp partially blocked the rear emergency exit when it folded into the bus. Your letter did not describe in detail the floor-to-ceiling barrier in your bus and we are unable to form an opinion as to the compliance of the altered vehicle with Standard No. 217. However, if the barrier provides an impediment to the emergency exit then the alteration might conflict with FMVSS No. 217. Further, if the barrier conflicted with Standard No. 217, then it could not be added as aftermarket equipment by any manufacturer, dealer, or repair business, without rendering inoperative the compliance of the bus with the safety standard.; Finally, you indicated that the school bus would be a color other tha yellow. Highway Safety Program Standard No. 17 formerly permitted school vehicles carrying 16 or less students to or from school (i.e., 'Type II' school vehicles) to be marked, painted, and lighted in one of two ways. The buses could be either marked, painted, and lighted as school buses, or marked painted, and lighted differently than school buses. However, all school buses now must have the lighting of a school bus required under Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*. since all school buses must have the lighting of a school bus, under Highway Safety Program Standard No. 17 they also must have the painting and marking of a school bus.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0329OpenMr. Yasunobu Mitoya, Project Manager, Designing Division, Toyo Kogyo Co. Ltd. 6047 Fuchu-Machi, Aki-Gum, Hiroshima, Japan; Mr. Yasunobu Mitoya Project Manager Designing Division Toyo Kogyo Co. Ltd. 6047 Fuchu-Machi Aki-Gum Hiroshima Japan; Dear Mr. Mitoya: This is in reply to your letter of April 6, 1971, requesting a interpretation of section S7 of Standard No. 208, Occupant Crash Protection.; Your question concerns the requirement of S7.1.2 that the intersectio of the upper torso belt with the lap belt shall be at least 6 inches from the occupant's front vertical centerline. As we understand your question, you have asked whether this 6-inch distance must be achieved by using an inboard belt segment of fixed length, or whether a manual adjusting device may be used that will permit lengthening of the inboard belt segment when the seat is moved forward.; It is the intent of section S.1.2 to require an intersection point tha cannot be adjusted so that it is less than 6 inches from a 50th percentile male occupant's centerline. We are considering a possible amendment to the standard to clarify this intent.; Please advise us if further explanation is needed. Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam2314OpenHonorable Philip A. Hart, United States Senate, Washington, DC 20510; Honorable Philip A. Hart United States Senate Washington DC 20510; Dear Senator Hart: This is in response to your letter of May 11, 1976, forwarding petition for reconsideration of the recently issued Part 581 bumper standard from Gulf + Western Manufacturing Company. You ask that the agency provide Gulf + Western with cost-benefit data upon which the bumper standard was based and also supply you with any available information justifying promulgation of the standard.; All of the data upon which the National Highway Traffic Safet Administration (NHTSA) based the Part 581 bumper standard, including several cost- benefit analyses, are in the public docket and available for public examination. A series of proposals preceded the issuance of the final rule, and information submitted in response to each of these proposals was closely reviewed and taken into account in reaching the finally adopted provisions.; Although we are prepared to provide you with the data that led to th issuance of the final rule, the volume of information is tremendous. Cost- benefit data are contained not only in several agency-prepared studies, but also in a large number of submissions from the automotive industry and other interested parties. I am therefore only enclosing the major agency studies on the costs and benefits of the bumper standard. You should note, however, that a considerable amount of additional information was considered. I am also enclosing copies of the *Federal Register* notices that preceded promulgation of the Part 581 standard. The preambles of these notices will give you an overview of the information upon which the agency based its bumper regulation.; It is the NHTSA's policy to issue a notice of action taken on petition for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. I assure you that Gulf + Western's comments and the information contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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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.