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.”
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NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: 11798.MLSOpen Mr. Michael J. Kroll Dear Mr. Kroll: This responds to your April 16, 1996 letter asking about the applicability of Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials (49 CFR '571.302), to various materials in the interior of a vehicle. You ask a number of questions about the standard which we have rephrased below, followed by our answers. Question: Are materials located under the dash (instrument panel) required to meet the FMVSS 302 requirements? Examples of materials located under the dash are: defrost ducts, air distribution ducting, demister tubes and hoses, insulation on wiring, sound deadening materials, electronic and/or electrical component enclosures. Many of these materials are not visible directly but are accessible via heater/defrost outlets and radio speaker grills. Answer: Section S4.1 of Standard No. 302 lists the components in the vehicle occupant compartment that must comply with the flammability resistance requirements of paragraph S4.3. The components listed are: seat cushions, seat backs, seat belts, headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, and any other interior materials, including padding and crash deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash. Under S4.1 and S4.2 of the standard, any portion of these components that is within 2 inch of the occupant compartment air space must meet the standard=s requirements. The materials you list are not included in S4.1. Thus, they do not have to comply with Standard No. 302. Question: Are materials located within the passenger compartment on or near the fire wall required to meet Standard 302? These include heating/ventilation/air conditioning (HVAC) ducting, carpeting, sound deadening materials, and electronic or electrical component enclosures. On many vehicles, the HVAC ducting material below the dash is clearly visible and intimately associated with other exposed materials such as carpeting and sound deadening material. Answer: Some materials located on or near the fire wall are subject to Standard 302. Among the items listed in S4.1 of the standard are floor coverings and engine compartment covers. The standard applies to HVAC ducting material that is part of carpeting used as a floor covering or part of the engine compartment cover. The standard also applies to foam directly under the dash coverings, since the agency considers such foam to be padding that is designed to absorb energy on contact by occupants in the event of a crash. This assumes that the HVAC and foam material is within 2 inch of the occupant compartment air space. Question: Section S4.2 states that AAny portion of a single or composite material which is in 2 inch of the occupant compartment air space shall meet the [flammability resistance] requirements of S4.3.@ Does S4.2 apply to all materials in the occupant compartment air space? Answer: No, S4.2 only specifies which portions of those components listed in S4.1 must meet the flammability resistance requirements. Question: Does S4.2 apply to: (i) materials located under the dash and exposed to the occupant compartment air space, (ii) on the fire wall near and/or on the floor of the occupant compartment, (iii) foams directly under vinyl or cloth coverings on seats, (iv) foam directly under dash coverings, and (v) foam used to line the interior of HVAC ducts? Answer: Standard No. 302 applies to materials on the fire wall near or on the occupant compartment=s floor, foams directly under vinyl or cloth coverings on seats, and foam directly under dash coverings. It does not apply to materials (other than padding) located under the dash and exposed to the occupant compartment space, assuming these materials are not listed in S4.1, or to foam used to line the interior of HVAC ducts. Question: Does S4.2 apply to composite materials, such as a foam backing on a vinyl headliner tested as a composite? Answer: Yes, and the composite vinyl headliner is subject to S4.2.2. That section specifies that AAny material that adheres to other material(s) at every point of contact shall meet the requirements of S4.3 when tested as a composite with other material(s). Question: Does S4.2 apply to a foam backing of a cloth headliner where the foam is not attached to the headliner? Answer: Yes, and the headliner would be tested subject to S4.2.1, which specifies that AAny material that does not adhere to other material(s) at every point of contact shall meet the requirements of S4.3 when tested separately.@ Question: Does S4.2 apply to any material underneath the carpeting where the total thickness of the carpeting and backing is less than 2 inch? Answer: Because S4.2 applies to any component in S4.1 that is within 2 inch of the occupant compartment air space, it applies to listed materials such as a floor covering, up to 2 inch. Question: Under what basis or criteria are some materials within the occupant compartment air space excluded? Answer: See answer to question one. Section S4.1 of Standard No. 302 provides a comprehensive list of materials subject to the standard. Any material not on this list is not subject to the standard. I hope this answers your questions. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely,
Samuel J. Dubbin Chief Counsel ref:302 d:5/16/96
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1996 |
ID: aiam3104OpenMr. Phillip L. Whitehorn, Messrs. Cannady & Whitehorn, 2150 Franklin Street, Suite 571, Oakland, California 94612; Mr. Phillip L. Whitehorn Messrs. Cannady & Whitehorn 2150 Franklin Street Suite 571 Oakland California 94612; Dear Mr. Whitehorn: This is in reply to your letter of August 31, 1979, following you discussion with Mr. Vinson of this office.; Your client, ZEMCO Inc., has developed a fuel saving device for th automobile aftermarket the operation of which you have described as follows:; >>>'...if a vehicle approached a read light requiring the driver t stop ... several seconds after the accelerator was released and the automobile stopped the device would automatically shut off the engine. To restart, the driver would press the accelerator pedal and the device would automatically trigger the ignition to start the engine.'<<<; "In your opinion two Federal Motor Vehicle Safety Standards appear t conflict with the ZEMCO device, Standards Nos. 102 and 124. Paragraph S3.1.3 of 49 CFR 571.102, Motor Vehicle Safety Standard No. 102 imposes a starter interlock requirements under which 'the engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive position.' You point out that ZEMCO's device 'has been designed to automatically restart the engine with the transmission in either forward or reverse.' Paragraph S5.1 of 49 CFR 571.124, Motor Vehicle Safety Standard No. 124 requires the throttle to return to the idle position within a specified time j period 'whenever the driver removes the opposing actuating force.' The ZEMCO device shuts off the engine several seconds after the(sic) driver's foot is removed from the accelerator."; You have cited Section 108(a)(1)(A) of the National Traffic and Moto Vehicle Safety Act which prohibits the manufacture of any item of motor vehicle equipment that does not conform to Federal motor vehicle safety standards, and Section 108(a)(1)(A) which forbids manufacturers, distributors, dealers and motor vehicle repair businesses from 'knowingly rendering inoperative ... any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.; You have asked whether the ZEMCO device is in conflict with the Act. The ZEMCO device does not violate Section 108(a)(1)(A) of the Act Although it is an item of 'motor vehicle equipment' as defined by Section 102(a) of the Act, there is no Federal motor vehicle safety standard applicable to a device of this nature, so that its manufacture and sale would not be a violation of Section 108(a)(1)(A).; With respect to Section 108(a)(2)(A) we do not see that the devic conflicts with Standard No. 124 as long as the device does not prevent the accelerator from returning to idle in the standard's specified time period before the engine is shut off. The ZEMCO device appears to come into play after the accelerator has returned to idle, a period of time outside the coverage of the standard.; You are correct, however, in your concern with Standard No. 102 as th activation of the starter in forward or reverse gear is diametrically opposed to the standard's requirement. Its installation would appear to 'render inoperative' the starter interlock that is required by Standard No. 102. Although ZEMCO's manufacture of the device would not violate Section 108(a)(2)(A), its installation by a person other than the vehicle owner would appear to.; You are also correct that this agency has not issued the regulatio authorized by Section 108(a)(2)(B) under which any person may be exempted from Section 108(a)(2)(A) upon a determination that the exemption is consistent with motor vehicle safety and the purposes of the Act.; If you wish to petition the agency to issue such a regulation or t amend Standard No. 102 in an appropriate manner you have, of course, the right to do so, and I enclose a copy of our petition procedures, 49 CFR Part 552, for your information.; I return your patent materials herewith. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3102OpenMr. Phillip L. Whitehorn, Messrs. Cannady & Whitehorn, 2150 Franklin Street, Suite 571, Oakland, CA 94612; Mr. Phillip L. Whitehorn Messrs. Cannady & Whitehorn 2150 Franklin Street Suite 571 Oakland CA 94612; Dear Mr. Whitehorn: This is in reply to your letter of August 31, 1979, following you discussion with Mr. Vinson of this office.; Your client, ZEMCO Inc., has developed a fuel saving device for th automobile aftermarket the operation of which you have described as follows:; >>>'...if a vehicle approached a red light requiring the driver t stop...several seconds after the accelerator was released and the automobile stopped the device would automatically shut off the engine. To restart, the driver would press the accelerator pedal and the device would automatically trigger the ignition to start the engine.'<<<; In your opinion two Federal Motor Vehicle Safety Standards appear t conflict with the ZEMCO device, Standards Nos. 102 and 124. Paragraph S3.1.3 of 49 CFR 571.102, Motor Vehicle Safety Standard No. 102 imposes a starter interlock requirement under which 'the engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive position.' You point out that ZEMCO's device 'has been designed to automatically restart the engine with the transmission in either forward or reverse.' Paragraph S5.1 of 49 CFR 571.124, Motor Vehicle Safety Standard No. 124 requires the throttle to return to the idle position within a specified time period 'whenever the driver removes the opposing actuating force.' The ZEMCO device shuts off the engine several seconds after driver's foot is removed from the accelerator.; You have cited Section 108(a)(1)(A) of the National Traffic and Moto Vehicle Safety Act which prohibits the manufacture of any item of motor vehicle equipment that does not conform to Federal motor vehicle safety standards, and Section 108(a)(2)(A) which forbids manufacturers, distributors, dealers and motor vehicle repair businesses from 'knowingly rendering inoperative...any device or element of design installed on or in a motor vehicle...in compliance with an applicable Federal motor vehicle safety standard'.; You have asked whether the ZEMCO device is in conflict with the act. The ZEMCO device does not violate Section 108(a)(1)(A) of the Act Although it is an item of 'motor vehicle equipment' as defined by Section 102(a) of the Act, there is no Federal motor vehicle safety standard applicable to a device of this nature, so that its manufacture and sale would not be a violation of Section 108(a)(1)(A).; With respect to Section 108(a)(2)(A) we do not see that the devic conflicts with Standard No. 124 as long as the device does not prevent the accelerator from returning to idle in the standard's specified time period before the engine is shut off. The ZEMCO device appears to come into play after the accelerator has return (sic) to idle, a period of time outside the coverage of the standard.; You are correct, however, in your concern with Standard No. 102 as th activation of the starter in forward or reverse gear is diametrically opposed to the standard's requirement. Its installation would appear to 'render inoperative' the starter interlock that is required by Standard No. 102. Although ZEMCO's manufacture of the device would not violate Section 108(a)(2)(A), its installation by a person other than the vehicle owner would appear to.; You are also correct that this agency has not issued the regulatio authorized by Section 108(a)(2)(B) under which any person may be exempted from Section 108(a)(2)(A) upon a determination that the exemption is consistent with motor vehicle safety and the purposes of the Act.; If you wish to petition the agency to issue such a regulation or t amend Standard No. 102 in an appropriate manner you have, of course, the right to do so, and I enclose a copy of our petition procedures, 49 CFR Part 552, for your information.; I return your patent materials herewith. Sincerely, Frank Berndt, Chief Counsel |
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ID: nht95-3.1OpenTYPE: INTERPRETATION-NHTSA DATE: June 6, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: C. Rufus Pennington, III -- Margol & Pennington, P.A. TITLE: NONE ATTACHMT: ATTACHED TO 4/5/95 LETTER FROM C. RUFUS PENNINGTON, III TO MARY VERSAILLES TEXT: Dear Mr. Pennington: This responds to your letter concerning the rear seats of a 1979 Porsche 911 SC, which were not equipped with any type of seat belt. You asked two questions relating to whether these seats should have been equipped with seat belts. Your questions are a ddressed below. 1. Did the manufacturer's designation of "two front" passenger seats eliminate any obligation on the part of the manufacturer to provide seat belts in the rear seats under Federal Motor Vehicle Safety Standard 208? As explained below, a manufacturer's designation that a vehicle has two front seats does not eliminate the obligation to provide seat belts at rear seats, if those positions are "designated seating positions." By way of background information, The National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards applicable to the manufacture and sale of new motor vehicles and items of motor vehicle equipment. NHTSA has exercised this authority to establish Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208), which specifies performance requirements for the protection of vehicle occupants in crashes. Standard No. 208 req uired passenger cars manufactured on or after September 1, 1973 and before September 1, 1986, to have either a Type 1 (lap) or Type 2 (lap/shoulder) seat belt assembly at each rear "designated seating position." The term "designated seating position" is defined at 49 CFR 571.3. For vehicles manufactured before September 1, 1980, the term "designated seating position" was defined as: any plan view location intended by the manufacturer to provide seating accommodation while the vehicle is in motion, for a person at least as large as a fifth percentile adult female, except auxiliary seating accommodations such as temporary or folding j ump seats. n1 n1 The definition was amended effective September 1, 1980. Copies of the September 28, 1978 notice of proposed rulemaking and April 19, 1979 final rule are enclosed. In a May 22, 1978, notification to vehicle manufacturers, the agency stated that manufacturers are responsible for determining the number of seating positions that are in the vehicle. The agency also stated: This does not mean, however, that the manufacturer's designation will be accepted by the agency if there are additional, obvious seating positions that are likely to be used by occupants while the vehicle is in motion. The agency unquestionably intends to require protection for all vehicle occupants. n2 Thus, a manufacturer's specification that a vehicle has two front seats did not eliminate Standard No. 208's requirement for a seat belt assembly at each rear seat, if those locations met the above definition. 2. Did the Porsche 911 SC comply with, or did it violate, the requirements of Federal Motor Vehicle Safety Standard 208? NHTSA cannot make a determination as to whether a vehicle complied with applicable safety standards outside a compliance proceeding. However, I can advise you of the factors the agency would look at to determine if the rear locations are designated seat ing positions. If those locations are designated seating positions, they should have been equipped with a seat belt assembly when originally manufactured. n2 43 FR 21893. A copy of this notice is enclosed. The May 22, 1978, notice provides a good summary of the agency's position. n3 That notice states: the agency will consider any position . . . capable of accommodating a person at least as large as a fifth percentile adult female to be a "designated seating position", if the overall seat configuration and design is such that the manufacturer knows the position is likely to be used as a seating position while the vehicle is in motion. I note that the hip breadth of a sitting fifth percentile female is approximately 13 inches, and the sitting height is approximately 31 inches. These are the measurements NHTSA would consider in determining whether a position is capable of accommodating a fifth percentile female. n3 While that notice was focused on front seats, the rationale would apply to any seat. I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. |
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ID: 06-007782jegOpenMr. Lance Tunick Vehicle Services Consulting, Inc. P.O. Box 23078 Santa Fe, NM 87502-3078 Dear Mr. Tunick: This responds to your letter asking several questions about Federal Motor Vehicle Safety Standards (FMVSS) No. 207, Seating Systems, No. 208, Occupant Crash Protection, and No. 210, Seat Belt Assembly Anchorages. Your questions are addressed below. Issues Related to FMVSS No. 210 and FMVSS No. 207
Background
Your first questions relate to S4.2.2 of FMVSS No. 210. That paragraph reads as follows: S4.2.2 Except as provided in S4.2.5, and except for side facing seats, the anchorages, attachment hardware, and attachment bolts for any of the following seat belt assemblies shall withstand a 3,000 pound force applied to the lap belt portion of the seat belt assembly simultaneously with a 3,000 pound force applied to the shoulder belt portion of the seat belt assembly, when tested in accordance with S5.2 of this standard: (a) Type 2 and automatic seat belt assemblies that are installed to comply with Standard No. 208 (49 CFR 571.208); and (b) Type 2 and automatic seat belt assemblies that are installed at a seating position required to have a Type 1 or Type 2 seat belt assembly by Standard No. 208 (49 CFR 571.208). S4.2.5, referenced at the beginning of S4.2.2, provides: S4.2.5 The attachment hardware of a seat belt assembly, which is subject to the requirements of S5.1 of Standard No. 208 (49 CFR 571.208) by virtue of any provision of Standard No. 208 other than S4.1.2.1(c)(2) of that standard, does not have to meet the requirements of S4.2.1 and S4.2.2 of this standard. Your Question 1
Your first question asks: When is S4.2.2 of FMVSS No. 210 not applicable by virtue of S4.2.5? You stated that a passenger car manufactured after September 1, 2006 must have a Type 2 seat belt assembly at each front outboard designated seating position by virtue of S4.1.5 of 49 CFR 571.208 and not by virtue of S4.1.2.1(c)(2). You asked whether it is correct that passenger cars manufactured after September 1, 2006 do not have to meet the strength requirements of S4.2.1 and S4.2.2 of FMVSS No. 210. In considering your question, we have reviewed the history of the provision at issue. On December 5, 1991, in a final rule relating to responses to petitions for reconsideration published in the Federal Register (56 FR 63676, 63677),[1] NHTSA decided to exclude from FMVSS No. 210 the attachment hardware of dynamically tested manual safety belt systems which are the only occupant restraint at a seating position. The agency believed that the FMVSS No. 210 tests were unnecessarily redundant for these dynamically tested systems. However, NHTSA also explained that it does not consider a manual belt installed at a seating position that is also equipped with an air bag to be dynamically tested, and therefore, the attachment hardware of these belts was subjected to the FMVSS No. 210 strength tests. To accomplish this, the agency included the provision in FMVSS No. 210 citing S4.1.2.1(c)(2) of FMVSS No. 208. Subsequent to this, the agency has not amended or proposed to amend this requirement of FMVSS No. 210. However, the agency did amend FMVSS No. 208 in a way that made the cross-reference in FMVSS No. 210 outdated, while not making conforming changes to FMVSS No. 210. Your Question 2 Your second question asks: In a case where S4.2.2 of FMVSS No. 210 is applicable, what is the force imposed on the seat under S4.2(c) of FMVSS No. 207? S4.2 of FMVSS No. 207 reads in relevant part as follows: S4.2 General performance requirements. When tested in accordance with S5., each occupant seat, other than a side-facing seat or a passenger seat on a bus, shall withstand the following forces, in newtons. . . . (c) For a seat belt assembly attached to the seatthe force specified in paragraph (a), if it is a forward facing seat, or paragraph (b), if it is a rearward facing seat, in each case applied simultaneously with the forces imposed on the seat by the seat belt assembly when it is loaded in accordance with S4.2 of 571.210 . . . In your letter, you state your belief that it is necessary to identify the force imposed on the seat by the seat belt to conduct testing under S4.2(c), and suggest ways of doing so. However, we disagree that it is necessary to identify or calculate these forces. Instead, the seat is loaded as specified in FMVSS No. 210 and the forces specified by FMVSS No. 207 applied simultaneously. Therefore, we do not agree with your suggested interpretation. You also asked about a reference in Laboratory Test Procedure TP-207-9 which states that the force imposed on the seat frame is 4,950 pounds independent of the seat configuration. This Laboratory Test Procedure refers to the 4,950 pound (force) load when testing a lap belt with the seat system (20 times the weight of the seat). We note that one of the loading conditions specified in FMVSS No. 210, which applies to lap belts, is a 5,000 pound force. See S4.2.1. The reference you ask about relates to that FMVSS No. 210 loading condition. For this particular compliance testing, we apply a load that is less severe than the 5,000 pounds specified in the standard.
We note, however, that manufacturers are required to certify their vehicles to the FMVSSs and not to the laboratory test procedures. TP-207-9 includes the following note on page 1: The OVSC Laboratory Test Procedures, prepared for use by independent laboratories under contract to conduct compliance tests for the OVSC, are not intended to limit the requirements of the applicable FMVSS(s). In some cases, the OVSC Laboratory Test Procedures do not include all of the various FMVSS minimum performance requirements. Sometimes, recognizing applicable test tolerances, the Test Procedures specify test conditions which are less severe than the minimum requirements of the standards themselves. Therefore, compliance of a vehicle or item of motor vehicle equipment is not necessarily guaranteed if the manufacturer limits certification tests to those described in the OVSC Laboratory Test Procedures. Issues related to S4.1.5 and S7.1.1 of FMVSS No. 208
Background You asked several questions related to S4.1.5 and S7.1 of FMVSS No. 208. These paragraphs read as follows: S4.1.5 Passenger cars manufactured on or after September 1, 1996. S4.1.5.1 Frontal/angular automatic protection system. (a) Each passenger car manufactured on or after September 1, 1996 shall: . . . (3) At each front designated seating position that is an outboard designated seating position, as that term is defined at 49 CFR 571.3, and at each forward-facing rear designated seating position that is a rear outboard designated seating positions, as that term is defined at S4.1.4.2(c) of this standard, have a Type 2 seat belt assembly that conforms to Standard No. 209 and S7.1 through S7.3 of this standard, and, in the case of the Type 2 seat belt assemblies installed at the front outboard designated seating positions, meet the frontal crash protection requirements with the appropriate anthropomorphic test dummy restrained by the Type 2 seat belt assembly in addition to the means that requires no action by the vehicle occupant. . . . S7.1 Adjustment. S7.1.1 Except as specified in S7.1.1.1 and S7.1.1.2, the lap belt of any seat belt assembly furnished in accordance with S4.1.2 shall adjust by means of any emergency-locking or automatic-locking retractor that conforms to 571.209 to fit persons whose dimensions range from those of a 50th percentile 6-year-old child to those of a 95th percentile adult male . . . Your Questions
You note in your letter that S7.1.1 specifies certain requirements for seat belt assemblies furnished in accordance with S4.1.2. You ask whether S7.1.1 applies to vehicles manufactured after September 1, 2006, in which the seat belt assemblies are furnished in accordance with S4.1.5. The answer is yes. The reason for this is that S4.1.5 itself specifies that these vehicles must have seat belt assemblies that conform to S7.1. See S4.1.5.1(2) and (3). We note that the version of S4.1.5 establishing requirements for vehicles manufactured on or after September 1, 1996 was established by NHTSA in the September 1993 final rule implementing the Congressional requirement for light vehicles to be equipped with an air bag and a manual lap/shoulder belt at both the drivers and right front passengers seating position. In the regulatory text specifying requirements for these vehicles, the agency included the adjustment requirements of S7.1. You also ask whether parts of S7.1 are outdated. The discussion provided above may provide the information you desire in this area. If not, we would need a more specific question from you. I hope this information is helpful. If you have further questions, please contact Edward Glancy of my staff at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel ref: 207#208#210#101#VSA102(4) d.6/22/07 [1] See also Final rule; delay of effective date and response to petitions for reconsideration; 57 FR 32902; July 24, 1992. |
2007 |
ID: 06-002617asOpenMr. Lance Tunick Vehicle Services Consulting, Inc. PO Box 23078 Santa Fe, NM 87502-3078 Dear Mr. Tunick: This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, with regard to the procedure for positioning the 5th percentile adult female dummy in the drivers seating position for the rigid barrier crash test. You ask five questions regarding the standards provisions for positioning of the test dummys foot. Your questions are phrased as though you were asking whether we would allow manufacturers to conduct Standard No. 208s compliance tests in a certain manner. While manufacturers are required to certify that their vehicles comply with the standard, they are not required to specifically perform the tests set forth in the FMVSSs. Manufacturers may base their certification upon procedures other than those specified in the FMVSSs, such as computer simulation, engineering studies, and mathematical calculations. The National Highway Traffic Safety Administration (NHTSA), however, will perform its own compliance testing in accordance with the procedures in the FMVSSs. In the event of a noncompliance, the reasonableness of the manufacturers basis for its certification will have a bearing on the enforcement action that the agency will pursue. Thus, in answering your questions, when you ask what a manufacturer is permitted to do in certain circumstances, we understood you to ask what actions NHTSA would take if we were testing your product under similar circumstances. 1) Your first question concerns S16.3.2.1.8 of FMVSS No. 208, which specifies the procedure for positioning the 5th percentile female dummys thighs, legs, and feet so that the torso can be properly positioned for the test. You ask if, during the S16.3.2.1.8 set up, the dummys left foot contacts the wheel-well while moving the seat forward, NHTSA would rotate the dummys left leg inward to avoid contact with the wheel-well. As explained below, our answer is no. However, we would not cease to move the seat forward because of the foot contact, as you suggest. The relevant portion of S16.3.2.1.8 reads, Proceed with moving the seat forward until either the leg contacts the vehicle interior or the seat reaches the full forward position. (The right foot may contact and depress the accelerator and/or change the angle of the foot with respect to the leg during seat movement.) If necessary to avoid contact with the vehicles brake or clutch pedal, rotate the test dummys left foot about the leg. If there is still interference, rotate the left thigh outboard about the hip the minimum distance necessary to avoid pedal interference. If a dummy leg contacts the vehicle interior before the full forward position is attained, position the seat at the next detent where there is no contact. In no portion of S16.3.2.1.8 does the standard state that the leg is rotated inward. According to S16.3.2.1.8, only the foot and thigh can be rotated and only for the purpose of avoiding pedal interference. Thus, we would not move the leg inward to avoid contact with the wheel-well. However, in the background portion of your letter, you indicate that you are stopping the forward movement of the dummy because, as you state, the driver dummys LEFT foot contacts the wheel-well and blocks the movement of the seat forward. We note that S16.3.2.1.8 states that one should [p]roceed with moving the seat forward until either the leg contacts the vehicle interior or the seat reaches the full forward position. [Emphasis added][1] The term leg is defined in S16.3.1.8 as the lower part of the entire leg, including the knee, as distinguished from the definition of foot given in S16.3.1.9, which is the foot, including the ankle. As long as only the foot, and not the leg, is in contact with the wheel-well, NHTSA would continue to move the seat forward until the seat reaches the full forward position. We are aware that, in certain situations such as where the foot strikes the wheel-well at an angle, continued forward motion may result in movement of the foot, leg, and/or hip, until the leg contacts the vehicle interior or the seat is in the full forward position. This resulting movement would be acceptable, but the leg should not be deliberately rotated inboard. We also note that our method is in accordance with the intent of the May 12, 2000 final rule on dummy positioning, which is to move the 5th percentile female dummy to the full frontal position. In that rulemaking, we stated that:
[T]his rule transforms unbelted rigid barrier testing under Standard No. 208 through the adoption of new and more stringent injury criteria, a new small adult female dummy seated far forward of where the existing mid-sized adult male dummy is placed in compliance testing.[2]
Therefore, we would follow the procedure outlined above, as it both conforms to the language of S16.3.2.1.8 and achieves the desired result, which is to position the dummy in the forward position. We would reposition the dummys feet in the proper position for the test later in the positioning process, using the procedures in paragraph S16.3.2.2, Driver foot positioning. 2) Your second question asks if the provisions for foot positioning set forth in S16.3.2.2.7 should be permitted under S16.3.2.1.8 in order to avoid a situation in which the dummy is so far rearward that it does not have its hands or feet on the controls. Our answer is two-fold. First, recall that as explained in our answer to question 1, we would continue to move the dummy forward until it reached the full forward position. In that position, the hands and feet would reach the vehicle controls. Therefore, we do not believe that there would be a situation where the dummy is so far rearward that its hands or feet do not reach the controls. Second, the provisions of S16.3.2.2.7 do not apply to S16.3.2.1.8. The movements described in S16.3.2.2.7 pertain to positioning the test dummy under S16.3.2.2.4, S16.3.2.2.5, and S16.3.2.2.6 of the standard, not to dummy positioning under S16.3.2.1.8. S16.3.2.1.8 describes a different part of the positioning process and is written to be performed before the procedures in paragraph S16.3.2.2, Driver foot positioning. 3) In your third question, you ask for confirmation that S16.3.2.2.7 sets the proper criteria for positioning of the dummys foot, as opposed to Item 34.2 of the Office of Vehicle Safety Compliance Laboratory Test Procedure for FMVSS 208, Appendix G (TP208-13). The answer is yes. We begin by noting that the procedures you refer to are currently listed as Item 31.2 of TP208-13. The Test Procedures are guidance for NHTSA contractors to perform compliance testing under the Federal standards. You are correct that there is a discrepancy between S16.3.2.2.7(c), which reads, rotate the left leg about the hip in either an outboard or inboard direction, [emphasis added] and TP208-13, Appendix G, Item 31.2, which reads, in relevant part, rotate the leg outboard about the hip. The procedure set forth in the FMVSS supersedes any discrepancy in TP208-13. 4) Your fourth question asks for confirmation of whether it would be permissible to have the dummys left foot rest on the foot rest if, after performing the procedures described in S16.3.2.2.7(a)-(c), the dummys foot still rests on the foot rest. The fifth sentence of S16.3.2.2.7 reads If it is not possible to avoid all prohibited foot contact, give priority to avoiding brake or clutch pedal contact. This sentence indicates that if, after the procedures in S16.3.2.2.7(a)-(c) are performed, there is contact between the left foot and the foot rest, then that contact is acceptable. 5) Finally, your fifth question asks if the agency could define the terms floor pan, foot rest, and toe-board. While we have not defined these terms, they are commonly used terms to describe portions of the area where the drivers feet are set while operating the vehicle. If you have a question as to whether some component of a specific design would be identified as any of these parts, NHTSA would be pleased to provide further clarification. I hope this information answers your questions satisfactorily. If you have any further questions, please contact Mr. Ari Scott of my staff at (202) 366-2992. Sincerely, Anthony M. Cooke Chief Counsel ref:208 d.1/18/07 [1] We also note that you claim there is a portion of paragraph S16.3.2.1.8 that permits movement of the dummys leg in an OUTBOARD direction. We were unable to find any such language. Perhaps you are referencing the sentence that says rotate the left thigh outboard about the hip, [emphasis added]. This sentence is inapplicable as it is prefaced with the statement [i]f necessary to avoid contact with the vehicles brake or clutch pedal, [emphasis added]. Here, the left foot comes in contact with the wheel-well only. [2] 55 FR 30684. |
2007 |
ID: aiam1984OpenMr. Samuel W. Alderson, President, Humanoid Systems, Division of Alderson Biotechnology Corporation, 5250 El Segundo Boulevard, Hawthorne, CA 90250; Mr. Samuel W. Alderson President Humanoid Systems Division of Alderson Biotechnology Corporation 5250 El Segundo Boulevard Hawthorne CA 90250; Dear Mr. Alderson: This is in response to your letter of June 27, 1975, criticisin certain aspects of the Part 572 dummy specifications in light of difficulties you have encountered in making test dummies.; You may have misunderstood the June 26 conversation with Dick Dyson o our Chief Counsel's Office that you mentioned. In his conversation with you, as Dick said at the time, he was simply paraphrasing the letter from Bob Carter that on that day was on its way to you in response to your letter of May 30. His (and the letter's) point was that dummies are not items of motor vehicle equipment, that there is therefore no Federal requirement for their certification, that any deviation from the Part 572 specifications is purely a matter of private negotiation between dummy manufacturers and their customers, and that no government approvals are possible or appropriate. This remains our position with respect to the legal status of the Part 572 dummy specification.; We will be glad to answer any questions of interpretation of Part 57 or other National Highway Traffic Safety Administration regulations. We will also give full consideration and a timely response to any petitions for changes in these regulations, in accordance with the statutory requirements of the 1974 Amendments to the Act. I invite you to submit any such questions or petitions on matters of interest to you.; Sincerely, James B. Gregory, Administrator |
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ID: nht68-2.33OpenDATE: 12/18/68 FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA TO: Consumers Union TITLE: FMVSS INTERPRETATION TEXT: I am writing in response to your several letters and the one from Mr. Posin in which an interest was expressed in learning about action planned by the National Highway Safety Bureau on a number of items which you have brought to our attention. Your letters included a request for information that four named imported passenger cars comply with Motor Vehicle Safety Standards 203 and 204, and your letter of September 13, 1963, and invited comment on several cases of alleged violation of the Standards that had been published in Consumer Reports. I am unable to comply with your request for information by model about conformance with specific standards. To do so might cause damage to the National Highway Safety Bureau's enforcement program. As Consumer Reports has noted on many occasione, the Burcau lacks the funds and facilition to test every model of every make of motor vehicle sold in the United States to determine whether all such vehicles comply with applicable Motor Vehicle Safety Standards. This deficiency has hampered both the speed and extensiveness of the compliance program. Consequently, we have been compelled, in our present enforcement program, to subject some makes and models to compliance testing and to omit others from the tests. Furthermore, the Bureau's resources do not permit it to test each vehicles selected for compliance testing to determine whether it complies with every Standard. The viability of this program of "spot checking" depends on secrecy as to which makes and models have been selected for testing and the exact tests each will undergo. The intentive for all manufacturers to comply with every Standard might be compromised if the manufacturers knew which vehicles(Illegible Line) must(illegible line). Therefore, we cannot comply with your request for disclosure of the results of the Bureau's tests of four imported cars for compliance with Standards 203 and 204. When our present testing cycle is completed, we may be able to release the information you seek, if you care to renew your request at that time. There are several specific points in your September 13 letter on which I am able to comment. My views on each of those points are as follows: 1. According to our information, the Dodge Polara mentioned in your letter was manufactured prior to January 1, 1968, the effective date of Standard No. 107. If you have information to the contrary, please supply it to us. 2. We are now studying the problem raised by the fact that, on some models of passenger care, the rear seat belts do not cross the "H" point at an angle(Illegible Word) near 45 degrees from the horizontal. Inquiries to one manufacturer and a limited amount of testing have indicated that the belt does make an angle close to 45 degrees when it is tested dynamically. From a safety viewpoint, of course, the important thing is that the proper angle exists during dynamic performance. For this reason, we are planning additional research with a view towards modification of Standard No. 210. 3. There of your comments deal with seat belts which are allegedly too long for snug adjustment. Standard No. 209 requires seat bolt assemblies to comply with the standards for seat belts promulgated by the National Bureau of Standards (31 F.R. 11528). Section 9.3(g) of the MBS standards requires each Type 1 or Type 2 seat belt assembly to be "capable of snug adjustment by the occupant..." It does not specify the anthropometric dimensions of the hypothetical occupant. The seat belt assembly in common use today cannot be manufactured so that it can be snugly adjusted to fit the entire range of human body types, from the small thin child to the large obese adult. We are, therefore, planning further research to enable us to specify(Illegible Word) adjustment range which will be practicable and at the same time will cover as many body sizes and types as possible. I will appreciate it if you will assist us by sending the Bureau(Illegible Words) the individuals on whom you tested the belts referred to in your letter. 4. Our investigation of both the Peugeot outside mirror and the outside mirror mount on the Datsun has indicated that both comply with Standard No. 111. If you have any data which show that the contrary is true, please send them to us so that, if warranted, we can reopen our investigatory file on each of these mirrors. 5. Since the Peugeot headlamp control is not mounted on the instrument panel, Standard No. 111 does not require that it be identified to permit recognition. 6. As you probably know, Toyota has initialed a defect motification campaign in reference to the throttle following publication of this item in the September 1968 issue of Consumer Reports. 7. Your letter also asks me to comment on a report that a dealer has refused to alter an original-equipment seat belt on the ground that to do so would subject him to a $1,000 fine. Although the National Traffic and Motor Vehicle Safety Act does not provide for fines, it does permit the imposition of civil penaltics of up to $1,000 for viclation on certain of its provisions. There are cases in which a dealer might be subject to civil penalty if he altered a motor vehicle or item of equipment so that it did not conform to applicable Standards. Whether, and in what circumstances, a dealer would run the risk of having a civil penalty imposed on him is a complex legal question. I cannot answer this question on the basis of the information you have supplied. The remaining matters mentioned in your September 13 letter are currently under investigation by the Bureau. Consequently, it would not be appropriate for me to comment on them at this time. The information which you supply to us and which you print in Consumer Reports is particularly valuable in that it suggests areas where we should consider concentrating our limited resources. Wherever there is an indication of a defect or violation of standards which is brought to our attention, such as the items you mention, we attempt to accomodate our testing and review planning to include consideration of these items. I think it might be valuable for us if you would be able to find the time to visit here with some of our staff and talk with Mr. H. M. Jacklin and his staff in the Motor Vehicle Safety Performance Service. I think it would be very valuable for them and perhaps out of this could come some ideas for areas in which information available to you and available to us can be made mutually beneficial. Thank you for your efforts to date. My apologies for the long delay in responding. |
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ID: 1691yOpen The Honorable Howard Wolpe Dear Mr. Wolpe: Thank you for your letter to former Secretary Burnley on behalf of your constituent, Mr. Dennis Furr of Lansing, Michigan. I've been asked to respond to your letter since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety. Mr. Furr is concerned about the potential safety problems that may result if school bus seats are being overloaded. In particular, Mr. Furr asks whether NHTSA's Highway Safety Program Guideline (HSPG) No. 17, Pupil Transportation Safety (23 CFR /1204.4), is consistent with Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222), with regard to seating specifications. Mr. Furr is particularly interested in how manufacturers are calculating the number of seating positions on a bench seat. I am pleased to address your constituent's concerns. Before I begin, I want to note that we have answered a number of similar inquiries from Mr. Furr in past years. We have two sets of "regulations" for school buses. The first, issued under the Vehicle Safety Act, includes our motor vehicle safety standards which apply to the manufacture and sale of new school buses. Compliance with these standards is mandatory for new vehicle manufacturers, and is enforced by this agency with civil penalties. FMVSS No. 222, with which your constituent is concerned, is one such safety standard. The second set of "regulations," or guidelines, for school buses was issued under the Highway Safety Act. Guidelines issued under this Act are not mandatory for the states; rather, they are recommended practices. Highway Safety Program Guideline No. 17, to which Mr. Furr frequently refers in his letter, consists of recommendations to the States for operating their school buses and pertains to Federal funding of State highway safety programs. Both FMVSS No. 222 and Guideline No. 17 contain specifications for school bus seating. Paragraph S4.1 of FMVSS No. 222 states: "The number of seating positions considered to be in a bench seat is expressed by the symbol W, and calculated as the bench width in inches divided by 15 and rounded to the nearest whole number." The guideline for seating accommodations in HSPG 17 states: Seating should be provided that will permit each occupant to sit in a seat in a plan view lateral location, intended by the manufacturers to provide seating accommodation for a person at least as large as a 5th percentile adult female, as defined in 49 CFR 571.3. Mr. Furr appears to see a conflict between the formula used in calculating the forces to be applied to the seats of large school buses under FMVSS No. 222, on the one hand, and the use by States and manufacturers of 13-inch seating positions for rating the capacity of a 39-inch seat, on the other hand. I believe that Mr. Furr's belief in the existence of a conflict rests on a misunderstanding. We view Standard No. 222 and HSPG 17 as complementary, not inconsistent. HSPG 17 reflects NHTSA's belief that all school bus passengers should be seated in the interest of safety. To that end, the guideline provides that there should be a seating position for each passenger and that the position should be at least large enough to accommodate a 5th percentile adult female. The hip width (sitting) of a 5th percentile adult female is 12.8 inches. The figure "15" in FMVSS No. 222's compliance formula is not a minimum requirement for the width of a seating position. It is the number which is used to establish the number of designated seating positions and ensures that the forces applied to the seat during compliance tests are reasonable reflections of the crash forces that would be involved in a real-world crash. It is also the number which ensures that the width of the smallest seat is approximately equal to the hip width of the 5th percentile female. That is consistent with HSPG 17 which provides that seating positions shall be at least large enough for a 5th percentile female. Use of the figure "15" in the FMVSS No. 222 formula results in a minimum seating position width of 12.67 inches (for a 38-inch wide seat.) That is only slightly smaller than the 12.8 inch hip width of the 5th percentile female. For a 39-inch wide seat, the single position width is 13 inches, which is slightly larger than the hip width of a 5th percentile female. It should be remembered, however, that the number of seating positions derived from the FMVSS No. 222 formula is not meant to be a measure of the absolute capacity of the bus for all size occupants. We recognize that, in practice, school buses transport a tremendously wide variety of student sizes. For example, a bus that may be capable of easily accommodating 65 preschool or elementary students may be capable of carrying only 43 high school students. When the bus is used to transport students of widely varying ages and sizes, reasonable accommodations may vary between those values. The decision on how many passengers may be comfortably and safely accommodated, therefore, is a decision that must be reached by the bus operator, in light of the ages and sizes of passengers involved. NHTSA does not have the authority under either the Highway Safety Act or Vehicle Safety Act to regulate how States use school buses. Therefore, NHTSA could not preclude a State from carrying more passengers on a bench seat than there are designated seating positions. However, this agency agrees with Mr. Furr that a student should not sit on a seat unless the student can sit fully on the seat instead of sitting only partially on the seat and thus only being partially protected by the compartmentalization. We believe that Mr. Furr's concerns as they apply to public schools would be best addressed by his working with the local school board and state officials. Mr. Furr is also concerned about a reference in our occupant crash protection standard (No. 208) to a 95th-percentile adult male occupant size. He asks why FMVSS No. 222 uses a 15-inch seat dimension, when FMVSS No. 208 references the 95th-percentile adult male occupant size in specifying occupant sizes which safety belts must adjust to fit. Both FMVSS No. 208 and FMVSS No. 222 are directed at providing occupant crash protection. Both of these standards set forth comprehensive requirements that are directed at protecting occupants likely to be inside a vehicle in a crash. With regard to school buses, the agency determined that the crash protection requirements should be developed taking into account the full size range of passengers typically riding on school buses. If we designed the force and deflection (energy-absorbing) characteristics of the seats for the 95th percentile males, the seats may be too stiff for a small child. Finally, Mr. Furr asks whether, when voluntarily installing safety belts on large school buses, States are violating Federal law by using S4.1 of FMVSS No. 222 in determining how many positions (and belts) there are on a bench seat. The answer is no. FMVSS No. 222 requires safety belts only for the passenger positions of small (10,000 pounds or less GVWR) school buses. Under S5 of the standard, belts on a small school bus bench seat are installed at "W" seating positions, as determined under S4.1. If a State wishes to order belts on its new large school bus and to use the same method for determining the number of belts to be installed, the State may do so. I hope this information is helpful. If you have any further questions, please do not hesitate to contact me. Sincerely,
Diane K. Steed /ref:VSA#222 d:2/23/89 |
1989 |
ID: 10839Open Mr. C. Rufus Pennington, III Dear Mr. Pennington: This responds to your letter concerning the rear seats of a 1979 Porsche 911 SC, which were not equipped with any type of seat belt. You asked two questions relating to whether these seats should have been equipped with seat belts. Your questions are addressed below. 1. Did the manufacturer's designation of "two front" passenger seats eliminate any obligation on the part of the manufacturer to provide seat belts in the rear seats under Federal Motor Vehicle Safety Standard 208? As explained below, a manufacturer's designation that a vehicle has two front seats does not eliminate the obligation to provide seat belts at rear seats, if those positions are "designated seating positions." By way of background information, The National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards applicable to the manufacture and sale of new motor vehicles and items of motor vehicle equipment. NHTSA has exercised this authority to establish Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208), which specifies performance requirements for the protection of vehicle occupants in crashes. Standard No. 208 required passenger cars manufactured on or after September 1, 1973 and before September 1, 1986, to have either a Type 1 (lap) or Type 2 (lap/shoulder) seat belt assembly at each rear "designated seating position." The term "designated seating position" is defined at 49 CFR 571.3. For vehicles manufactured before September 1, 1980, the term "designated seating position" was defined as: any plan view location intended by the manufacturer to provide seating accommodation while the vehicle is in motion, for a person at least as large as a fifth percentile adult female, except auxiliary seating accommodations such as temporary or folding jump seats. In a May 22, 1978, notification to vehicle manufacturers, the agency stated that manufacturers are responsible for determining the number of seating positions that are in the vehicle. The agency also stated: This does not mean, however, that the manufacturer's designation will be accepted by the agency if there are additional, obvious seating positions that are likely to be used by occupants while the vehicle is in motion. The agency unquestionably intends to require protection for all vehicle occupants. Thus, a manufacturer's specification that a vehicle has two front seats did not eliminate Standard No. 208's requirement for a seat belt assembly at each rear seat, if those locations met the above definition. 2. Did the Porsche 911 SC comply with, or did it violate, the requirements of Federal Motor Vehicle Safety Standard 208? NHTSA cannot make a determination as to whether a vehicle complied with applicable safety standards outside a compliance proceeding. However, I can advise you of the factors the agency would look at to determine if the rear locations are designated seating positions. If those locations are designated seating positions, they should have been equipped with a seat belt assembly when originally manufactured. The May 22, 1978, notice provides a good summary of the agency's position. That notice states: the agency will consider any position ... capable of accommodating a person at least as large as a fifth percentile adult female to be a "designated seating position", if the overall seat configuration and design is such that the manufacturer knows the position is likely to be used as a seating position while the vehicle is in motion. I note that the hip breadth of a sitting fifth percentile female is approximately 13 inches, and the sitting height is approximately 31 inches. These are the measurements NHTSA would consider in determining whether a position is capable of accommodating a fifth percentile female. I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel Enclosures ref:571#208 d:6/6/95 The definition was amended effective September 1, 1980. Copies of the September 28, 1978 notice of proposed rulemaking and April 19, 1979 final rule are enclosed. 43 FR 21893. A copy of this notice is enclosed. While that notice was focused on front seats, the rationale would apply to any seat.
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1995 |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.