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: Hopkins.1OpenMr. Bruce A. Hopkins Dear Mr. Hopkins: This is in response to your letter of October 21, 2003, in which you requested clarification of several issues under Federal Motor Vehicle Safety Standard (FMVSS) No. 110, Tire Selection and Rims, as amended by a final rule published on November 18, 2002, (67 FR 69600). Your questions involved actions that your final stage manufacturer members must take to meet the requirements of the regulation, once the revisions become effective on September 1, 2004. [1] Specifically, you asked about the content and placement of vehicle placards, listing of information related to spare tires, and reporting of seating capacity. As you are aware, the National Highway Traffic Safety Administration (NHTSA) is in the process of responding to petitions for reconsideration of the November 18, 2002, final rule, and we expect to issue our response shortly. We note that RVIA itself submitted a petition to the agency on this rulemaking. Our review suggests that the issues raised in your most recent letter are already before the agency in the context of the petitions for reconsideration, and we believe that the response will clarify these matters and will allow manufacturers sufficient time to assure compliance with applicable requirements. Should you have any remaining or additional questions once the response to the petitions for reconsideration is published, please feel free to submit them to the agency. If you have further questions in the interim, you may contact Mr. George Feygin of my staff at (202) 366-2992. Sincerely, Jacqueline Glassman ref:110 [1] 68 FR 33655 (June 5, 2003,) (final rule; response in part to petitions for reconsideration; delay of effective date). |
2004 |
ID: nht81-2.42OpenDATE: 07/01/81 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Airstream TITLE: FMVSR INTERPRETATION TEXT: This responds to your March 26, 1981, letter asking for a clarification of the certification requirements applicable to vehicles that you manufacture. The units frequently are completed by you, but in some instances, they are shipped to a final manufacturer for completion of the interior work. Your first question asks whether you should label the vehicle as a final-stage manufacturer since your vehicle is road worthy and needs only the addition of an interior finish prior to sale. In order to certify the vehicle as a final-stage manufacturer, the vehicle that you produce must be a completed vehicle (49 CFR Part 568). A completed vehicle is one that is finished and requires no further manufacturing operations to perform its intended functions with the exceptions of minor finishing operations or readily attachable components. If your vehicle is completed in a manner that it can perform its intended functions, you may label the vehicle as a final-stage manufacturer. The person performing alterations on your vehicle may then be required to add an alterer's label. If the finishing operation that will be made to your vehicle is more than the attachment of readily attachable components or minor finish work, the person doing the finishing work may label the vehicle as a final-stage manufacturer. In determining whether the installation of a bathroom, kitchen, furniture, beds, appliances, or seats is an installation of readily attachable components, you should consider whether it requires special expertise or tools. If it requires either, it is not the installation of readily attachable components. Your second question asks whether your vehicle would be considered a chassis-cab in those instances where another manufacturer might be attaching a final-stage label. The answer to this question is no. The definition of chassis-cab in part 567, Certification, states that it is a vehicle with a completed occupant compartment that needs only the addition of work performing or load carrying components to complete its function. It appears that your vehicle does not have a completed occupant compartment and, therefore, would not be considered a chassis-cab. Finally, you ask what will happen if you label the vehicle as a final-stage manufacturer and a subsequent manufacturer significantly alters the vehicle. You ask whether you could treat the vehicle as an incomplete vehicle and furnish the documentation required by Part 568. If you label the vehicle as a final-stage vehicle, you cannot treat it as an incomplete vehicle. However, you may convey information similar to that conveyed in an incomplete vehicle document to the subsequent manufacturer to ensure that it can comply with all of the standards. In fact, that manufacturer may require such information in order to be able to make the necessary modifications. |
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ID: 19518.wkmOpenMr. Roger C. Anderson Dear Mr. Anderson: This refers to your letter addressed to Walter Myers of my staff and to your telephone conversations with Jim Gilkey of this agency. You asked whether a dash-mounted pneumatic valve attached to the vehicle's air brake circuit to control various non-brake related chassis functions would be subject to Federal Motor Vehicle Safety Standard (Standard) No. 106, Brake hoses. The answer is a qualified yes. You enclosed schematics of the valve in question with your letter and sent a further drawing to Mr. Gilkey by telefax on May 24, 1999. You stated that the valve is to be used in an unprotected accessory air brake circuit to control various non-brake-related chassis functions. You stated that the plastic-bodied toggle valves incorporate Legris push-to-connect (PTC) 1/4-inch cartridges for connection to the B reservoir in the vehicle's air system. The B reservoir and lines supply air to the vehicle's front brakes. You stated that the PTC cartridges are assembled as an integral element to the dash valve in the manufacturing process, and that original equipment manufacturers insert their accessory lines into these cartridges. You stated that it is your understanding that application of the Legris cartridge integral to your dash valve does not constitute a brake hose end fitting and therefore is not subject to Standard No. 106. You asked us to confirm that understanding. Brake hose end fitting is defined in S4 of Standard No. 106 as "[A] coupler, other than a clamp, designed for attachment to the end of a brake hose." "Brake hose" is defined, also in S4, as:
Although your dash valve does not directly supply air to the vehicle's brake system, if the hoses attached to the dash valve transmit or contain brake air pressure from the vehicle's air system, that is, if failure of any such hose would result in a loss of air pressure in the brake system, then such hoses must comply with Standard No. 106. Moreover, your dash valve to which such hoses were attached would also be required to comply with Standard No. 106. However, if you added a check valve to the non-brake-related circuit so that loss of pressure in the circuit did not affect air brake system pressure, the hose would not be considered brake hose subject to Standard No. 106. I hope this information is helpful to you. Should you have any questions or need additional information, feel free to contact Mr. Myers or Mr. Gilkey at this address or by telephone at (202) 366-2992 or (202) 366-5295. Sincerely, |
1999 |
ID: nht74-2.30OpenDATE: 05/02/74 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Maxi-Cab Enterprises TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 18, 1974, asking which Federal requirements apply to the Maxi-Cab, pictures of which you enclose. You describe the Maxi-Cab as a fiberglass shell that fits in the back of compact pickups, and indicate that it has been designed to be used to transport children. Based on the pictures you have furnished, we have concluded that the Maxi-Cab is a "pickup cover", which is defined in S4 of Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR 571.205), as "a camper having a roof and sides but without a floor, designed to be mounted on and removable from the cargo area of a truck by the user." Since you describe the Maxi-Cab as designed to transport persons, the glazing material used in its construction must conform to Motor Vehicle Safety Standard No. 205. No other Federal requirements administered by this agency apply to it. Yours truly, ATTACH. March 18, 1974 Chief Counsel -- National Highway Traffic Safety Adm. Dear Sir: Several months ago we first put a product on the market called the Maxi-Cab. The Maxi-Cab has two parts: The first part is a fibreglass shell that fits on the back of compact pickups. After the first installation the shell can be taken off or put on again in about five minutes. The rear window of the truck cab is removed and there is a waterproof boot between the cab and the shell. The second part is a utility box which slides in under the front part of the shell. This box is then locked in both by sliding bolts and by a clete in the tonneau which holds it in place when the tonneau cover is shut. There are two shelves on the sides and cushions are placed on the shelves either for storage for gear, or if the driver chooses, as seats for children. We put this product out after checking first with the California State Department of Motor Vehicles who informed us that in their opinion the unit did not come under any existing regulations since it was completely removable. We then talked also with the California Highway Patrol which in turn referred us to the NHTSA. I have had a series of phone conversations with a Mr. Buckley in NHTSA and after discussions with legal people in your office he informed us that pending a ruling from your office it was his opinion that with the exception of certain glazing standards (with which we already comply) there were no federal regulations governing this product. Both for our own peace of mind, and to answer questions from our dealers, we would like to receive some documentation of this opinion. Mr. Buckley indicated that the appropriate method for receiving a written opinion on this matter was to send a written request to your Office requesting a written opinion on this matter. I am enclosing two photographs which will give you some idea of the appearance and mechanisms involved. I hope they will be sufficient. Thank you for your attention to this matter. Sincerely, James L. Creighton -- MAXI-CAB ENTERPRISES (Graphics omitted) (Graphics omitted) |
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ID: nht94-3.28OpenTYPE: INTERPRETATION-NHTSA DATE: June 8, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Mr. and Mrs. Hal Sullivan TITLE: None ATTACHMT: Attached To Letter Dated 8/30/93 From Hal Sullivan To NHTSA Chief Counsel TEXT: Dear Mr. and Mrs. Sullivan: This responds to your letter to David Elias, formerly of this office, requesting an interpretation of the term "rated cargo load" used in 49 CFR @ 567.5. I apologize for the delay in responding. You state in your letter that you purchased a 1992 Pace Arrow motor home from Fleetwood Motor Homes of California, Inc. You state that, if this motor home is equipped with "the identical factory optional HWH hydraulic jacks," it will exceed its gross ve hicle weight rating (GVWR) when the available water tanks are filled to capacity. You characterize this as "seriously inadequate carrying capacity," and ask if this violates NHTSA's regulations. As explained below, if a vehicle exceeds its GVWR when lo aded with its intended cargo, the manufacturer may be subject to civil penalties. By way of background, @ 114 of the National Traffic and Motor Vehicle Safety Act requires each motor vehicle manufacturer to certify the compliance of its new vehicles with all applicable Federal motor vehicle safety standards. NHTSA issued its vehicle certification regulation (49 CFR Part 567) to implement @ 114. Section 108(a)(1)(E) of the Safety Act prohibits any person from failing to comply with any regulation issued under @ 114. Under @ 109 of the Safety Act, violations of @ 108(a)(1)(E) are su bject to a civil penalty of up to $ 1,000 for each violation. NHTSA's certification regulation specifies the content of the certification label, and requires manufacturers to assign a GVWR to its new vehicles. The term GVWR is defined in 49 CFR @ 571.3 as "the value specified by the manufacturer as the loaded weig ht of a single vehicle." The GVWR informs vehicle owners how heavily the vehicle may safely be loaded. It also affects the vehicle's loading and other test conditions for the performance tests to ascertain whether the vehicle complies with applicable sa fety standards. The only express regulatory limitation on the GVWR that manufacturers may assign to their vehicles is set forth in 49 CFR @ 567.4(g)(3), which provides that the assigned GVWR 2 "shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity." (Emphasis added.) There is no express definition for the term "rated cargo load" in Part 567 or elsewhere in NHTSA's regulations. However, NHTSA expects the GVWR (which includes rated cargo load) to reflect a manufacturer's good-faith evaluation of the vehicle's size, we ight, load-carrying capacity and intended use. NHTSA is concerned about the potentially adverse effects on safety that might result from assigning too low a GVWR to a vehicle. NHTSA recognizes that vehicle overloading may create a serious safety proble m and will take appropriate action against any manufacturer whose vehicle, when operated in its intended manner, exceeds the assigned GVWR. Thank you for bringing this matter about the Pace Arrow to our attention. NHTSA's Office of Vehicle Safety Compliance will be contacting you for more information about your experience with the vehicle. Meanwhile, if you have further questions, please co ntact Deirdre Fujita of my staff at (202) 366-2992. Sincerely, |
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ID: 9064Open Mr. and Mrs. Hal Sullivan Dear Mr. and Mrs. Sullivan: This responds to your letter to David Elias, formerly of this office, requesting an interpretation of the term "rated cargo load" used in 49 CFR '567.5. I apologize for the delay in responding. You state in your letter that you purchased a 1992 Pace Arrow motor home from Fleetwood Motor Homes of California, Inc. You state that, if this motor home is equipped with "the identical factory optional HWH hydraulic jacks," it will exceed its gross vehicle weight rating (GVWR) when the available water tanks are filled to capacity. You characterize this as "seriously inadequate carrying capacity," and ask if this violates NHTSA's regulations. As explained below, if a vehicle exceeds its GVWR when loaded with its intended cargo, the manufacturer may be subject to civil penalties. By way of background, '114 of the National Traffic and Motor Vehicle Safety Act requires each motor vehicle manufacturer to certify the compliance of its new vehicles with all applicable Federal motor vehicle safety standards. NHTSA issued its vehicle certification regulation (49 CFR Part 567) to implement '114. Section 108(a)(1)(E) of the Safety Act prohibits any person from failing to comply with any regulation issued under '114. Under '109 of the Safety Act, violations of '108(a)(1)(E) are subject to a civil penalty of up to $1,000 for each violation. NHTSA's certification regulation specifies the content of the certification label, and requires manufacturers to assign a GVWR to its new vehicles. The term GVWR is defined in 49 CFR '571.3 as "the value specified by the manufacturer as the loaded weight of a single vehicle." The GVWR informs vehicle owners how heavily the vehicle may safely be loaded. It also affects the vehicle's loading and other test conditions for the performance tests to ascertain whether the vehicle complies with applicable safety standards. The only express regulatory limitation on the GVWR that manufacturers may assign to their vehicles is set forth in 49 CFR '567.4(g)(3), which provides that the assigned GVWR "shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity." (Emphasis added.) There is no express definition for the term "rated cargo load" in Part 567 or elsewhere in NHTSA's regulations. However, NHTSA expects the GVWR (which includes rated cargo load) to reflect a manufacturer's good-faith evaluation of the vehicle's size, weight, load-carrying capacity and intended use. NHTSA is concerned about the potentially adverse effects on safety that might result from assigning too low a GVWR to a vehicle. NHTSA recognizes that vehicle overloading may create a serious safety problem and will take appropriate action against any manufacturer whose vehicle, when operated in its intended manner, exceeds the assigned GVWR. Thank you for bringing this matter about the Pace Arrow to our attention. NHTSA's Office of Vehicle Safety Compliance will be contacting you for more information about your experience with the vehicle. Meanwhile, if you have further questions, please contact Deirdre Fujita of my staff at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:567#VSA d:6/8/94
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1994 |
ID: 1985-01.47OpenTYPE: INTERPRETATION-NHTSA DATE: 03/11/85 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Ms. Janet M. Goodrich TITLE: FMVSS INTERPRETATION TEXT: Ms. Janet M. Goodrich 870 W. Versailles Ct. Baton Rouge, LA 70819
This responds to your letter asking about regulations for automobile ignition systems and steering wheel locking systems. You asked for information concerning requirements for vehicles with automatic transmissions for the removal of the ignition key while the vehicle is in drive or any gear other than park. You specifically asked whether a driver should be able to remove the key from the ignition while the car is in drive even if the engine is no longer running. Requirements relating to steering wheel locking systems are set forth in Federal Motor Vehicle Safety Standard No. 114, Theft Protection. Section S4.2 of the standard requires (among other things) that vehicles have a key-locking system that, whenever the key is removed, will prevent either steering or forward self-mobility of the vehicle, or both. Section S4.3 of the standard requires that the prime means for deactivating the vehicle's engine shall not activate the deterrent that prevents steering or forward self-mobility of the vehicle. Thus, the driver of an automobile may turn off the engine while the car is in motion without activating the steering column lock or impeding forward self-mobility. Neither Standard No. 114 nor any other standard specifically requires that vehicles be designed so that drivers are unable to remove the key from the ignition while the vehicle is in drive. I would note that the agency has conducted rulemaking addressing the issue of inadvertent activation of the steering column lock in moving vehicles. While the National Highway Traffic Safety Administration issued a notice of proposed rulemaking on this subject in May 1978 and a final rule in December 1980, the agency deleted the relevant requirements in a final rule and response to petitions for reconsideration, published in June 1981. In that latter notice, the agency stated that it had determined that the problem of inadvertent activation is not significant enough to require vehicles to be equipped with key-locking systems that provide more protection against inadvertent activation. Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect, also includes a requirement relevant to your question. Section S3.7.3 requires that the engine starter for automatic transmission vehicles be inoperative when the transmission shift lever is in a forward or reverse drive position.
Copies of Standards Nos. 102 and 114 and the three Federal Register notices discussed above are enclosed for your convenience. Sincerely,
Jeffrey R. Miller Chief Counsel
Enclosures
870 W. Versailles Ct. Baton Rouge, La. 70819 (504) 275-0666 November 8, 1984
U. S. Department of Transportation National Highway Safety Administration Office of Standard Enforcement 400 7th Street SW Washington, D. C. 20590
Dear Sir or Madam:
I need information concerning the legal regulations for automobile ignition systems and steering wheel locking systems. Specifically I would like for the information to cover what the requirements are for the manufacturers of vehicles with automatic transmissions for the removal of the ignition key while the vehicle is in drive or any gear other than park. Should the driver be able to remove the key from the ignition while the car is in drive even if the engine is no longer running.
Your immediate attention to this matter would be very much appreciated as I need the information to complete my research. Thank you. Sincerely, Janet M. Goodrich jmg |
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ID: 9697Open Mr. Jeffrey D. Shetler Dear Mr. Shetler: This is in reply to your letter of February 7, 1994, to the Associate Administrator for Enforcement requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108. So that we may serve you better in the future, please note that the Office of Chief Counsel is the one to which requests for interpretations should be addressed. You have asked whether the "proposed application of a projector beam headlamp to a motorcycle" will meet the requirements of Standard No. 108. In this headlamp "the projector beam (lower beam) is located on the left side and the high beam is on the right side." You continue by saying that "the outer lens of the headlamp assembly is symmetrically positioned about the vertical centerline," and you ask whether the headlamp complies with the requirements of Table IV of Standard No. 108. Table III of Standard No. 108 requires a motorcycle to have at least one headlamp. Table IV requires the headlamp to be located "on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline." The device you describe contains the upper and lower beams in one housing and hence is a single headlamp. Although your projector beam headlamp would be mounted literally on the vertical centerline, the beams provided by the headlamp are located on either side of the centerline and are therefore asymmetrical in relation to the centerline of the motorcycle when either beam is activated. A redesign of the lamp so that its vertical centerline becomes its horizontal centerline and Line A becomes the vertical centerline would be a configuration that meets Table IV since both beams of the single headlamp would then be located on the vertical centerline. SAE J584 does not specify the location of one beam in relation to the other for dual beam motorcycle headlamps, i.e. whether one beam is to be mounted above or below the other. Your second question concerns an interpretation of S5.1.1.23. This paragraph provides an alternative for motorcycles to the headlamps specified by Table III, and allows a motorcycle to be equipped with "one half of any headlighting system specified in S7 which provides both a full upper beam and full lower beam, and where more than one lamp must be used, the lamps shall be mounted vertically, with the lower beam as high as practicable." You have asked whether this means that your proposed headlamp "shall be mounted on the upper half and the high beam shall be on the lower half when using one half of any headlighting system specified in S7," or "is our proposed layout in the attachment acceptable?" As I have explained, your proposed layout in the attachment is not acceptable under Table IV without reorientation. The headlighting systems specified in S7 are those intended for four-wheeled motor vehicles (other than trailers). As we understand it, your proposed headlamp has been developed as a headlamp system for motorcycles and not as half of a headlamp system for vehicles other than motorcycles. Because motorcycle photometrics differ from those for vehicle other than motorcycles, your proposed headlamp could not be half of a system specified in S7 which may be used on motorcycles as an alternative to the headlamps specified by Table III. Sincerely,
John Womack Acting Chief Counsel ref:108 d:5/6/94 |
1994 |
ID: nht94-5.47OpenDATE: May 6, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Jeffrey D. Shetler -- Manager of Government Relations, Kawasaki Motors Corp. U.S.A. TITLE: None ATTACHMT: Attached to letter dated 2/7/94 from Jeffrey D. Shetler to the Associate Administrator for Enforcement, NHTSA (OCC-9697) TEXT: This is in reply to your letter of February 7, 1994, to the Associate Administrator for Enforcement requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108. So that we may serve you better in the future, please note that the Office of Chief Counsel is the one to which requests for interpretations should be addressed. You have asked whether the "proposed application of a projector beam headlamp to a motorcycle" will meet the requirements of Standard No. 108. In this headlamp "the projector beam (lower beam) is located on the left side and the high beam is on the right side." You continue by saying that "the outer lens of the headlamp assembly is symmetrically positioned about the vertical centerline," and you ask whether the headlamp complies with the requirements of Table IV of Standard No. 108. Table III of Standard No. 108 requires a motorcycle to have at least one headlamp. Table IV requires the headlamp to be located "on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline." The device you describe contains the upper and lower beams in one housing and hence is a single headlamp. Although your projector beam headlamp would be mounted literally on the vertical centerline, the beams provided by the headlamp are located on either side of the centerline and are therefore asymmetrical in relation to the centerline of the motorcycle when either beam is activated. A redesign of the lamp so that its vertical centerline becomes its horizontal centerline and Line A becomes the vertical centerline would be a configuration that meets Table IV since both beams of the single headlamp would then be located on the vertical centerline. SAE J584 does not specify the location of one beam in relation to the other for dual beam motorcycle headlamps, i.e., whether one beam is to be mounted above or below the other. Your second question concerns an interpretation of S5.1.1.23. This paragraph provides an alternative for motorcycles to the headlamps specified by Table III, and allows a motorcycle to be equipped with "one half of any headlighting system specified in S7 which provides both a full upper beam and full lower beam, and where more than one lamp must be used, the lamps shall be mounted vertically, with the lower beam as high as practicable." You have asked whether this means that your proposed headlamp "shall be mounted on the upper half and the high beam shall be on the lower half when using one half of any headlighting system specified in S7," or "is our proposed layout in the attachment acceptable?" As I have explained, your proposed layout in the attachment is not acceptable under Table IV without reorientation. The headlighting systems specified in S7 are those intended for four-wheeled motor vehicles (other than trailers). As we understand it, your proposed headlamp has been developed as a headlamp system for motorcycles and not as half of a headlamp system for vehicles other than motorcycles. Because motorcycle photometrics differ from those for vehicle other than motorcycles, your proposed headlamp could not be half of a system specified in S7 which may be used on motorcycles as an alternative to the headlamps specified by Table III. |
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ID: nht79-2.33OpenDATE: 12/07/79 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Ward Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: DEC 7 1979 Mr. E. M. Ryan Ward Industries, Inc. P.O. Box 849 Highway 65 South Conway, Arkansas 72032 Dear Mr. Ryan: This responds to your October 8, 1979, letter asking whether your new bus design will comply with Standard No. 217, Bus Window Retention and Release. The window exit that you plan to install in the bus would slide open rather than push out and would be operated by a squeeze-type force application that is parallel to the horizontal centerline of the bus. Standard No. 217 requires buses to be equipped with emergency exits that comply with a variety of requirements. In the case of window exits, the force application for opening them depends upon the location of the release mechanism. For example, the required force application in the high force access region, according to the standard (S5.3.2), is straight and perpendicular to the exit surface. In applying the above requirement to your vehicle, it appears that your bus would not comply with the standard. From the pictures that you enclosed with your letter, it appears that your release mechanism falls in the high force access region. If so, the force application for opening the exit is in the incorrect direction as specified by the standard. Further, your bus would use window exits that slide open rather than push out. Although, sliding emergency exits are not prohibited by the standard, they must comply with all of the standard's requirements. Also, they must be capable of complying when the non-exit half of the window is either open or closed. The agency prefers the use of push-out emergency exits, because they are less likely to "bind up" during a side impact than sliding emergency exits.
The standard was written in its present form to provide uniformity of emergency exits in buses. A uniform exit system can help prevent confusion during accidents and facilitate emergency exit of vehicles. The vehicle that you plan to build would be unlike other buses now in operation with respect to emergency exits. The NHTSA does not think that this would be desirable or in the interest of safety. Sincerely, Frank Berndt Chief Counsel October 8, 1979 Office of Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admn. 400 Seventh Street, S.W. Washington, D.C. 20590 Ref: FMVSS 217 "Bus Window Retention and Release" Paragraph S5.3 and S5.4 Dear Sir: Ward Industries proposes to incorporate in a new bus design an emergency exit described as a horizontal sliding type. The window consists of two sliding sections, one of which opens large enough to admit unobstructed passage of an ellipsoid as required and described in Paragraph S5.4.1. The sliding section of this window slides fore and aft and parallel to the longitudinal center line of the bus. The window is not hinged at the top and does not swing out or "push out." It appears that the suggested type of emergency exit would comply with the requirements of FMVSS 217, Paragraph S5.4.1. Will this type of action be acceptable? The latching mechanism consists of a single latch which holds the sliding section in position. (See enclosed photos.) The release mechanism requires for release a squeeze type application to open. The force application for release is aft and parallel to the horizontal centerline of the bus. Will this type of release mechanism be acceptable? We would appreciate very much an early reply. Thank you in advance for your consideration. Sincerely, E. M. Ryan, Specifications Engineering Mgr. EMR/ws Enclosures |
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.