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As you correctly observed, S3. Accordingly, you stated that you are unsure whether you should use the latest version of SAE J rev. September or the earlier version rev. June As explained below, because a specific revision of that SAE standard is not cited or otherwise discussed in the rulemaking, the applicable version of SAE J for compliance purposes would be the version in effect at the time the comment period closed on the notice of proposed rulemaking NPRM proposing to incorporate SAE J into the standard i.
We further note that under 49 CFR Once approved, copies of such materials are kept on file by the Office of the Federal Register. June see 64 FR , Subsequently, a final rule was published in the Federal. June into the standard see 68 FR , No public comments were received on this issue. SAE a group comprised of technical experts, including ones from industry develops and maintains a system of standards which are constantly being revised and updated to reflect changing technologies and scientific understanding.
We note, however, that compliance with an SAE standard is voluntary, unless the standard is adopted by a government agency.
Furthermore, it is our understanding that, in light of that organizations procedures for regular updates of its standards, SAE decided not to cite specific revision dates for subreferenced standards, instead intending the most current revised version to be used.
In contrast, NHTSA adopts binding regulatory requirements, which may include all or parts of standards incorporated by reference from other sources. The agency adopts requirements only after an opportunity for public notice and comment. Consistent with the requirement of 49 CFR Otherwise, subsequent revisions to SAE standards or similar standards would impermissibly allow outside organizations to modify our FMVSSs through changes in their documents.
With that said, we now turn to the specific issue raised in your letter. In the case where a subreferenced SAE standard does not identify a specific, relevant version, we conclude that the correct version for compliance purposes would be the most recent version of that standard in effect at the close of the comment period of the NPRM proposing the incorporation by reference.
Our reasoning is as follows. In light of the ambiguity surrounding which version of a subreferenced SAE standard is to be used, it is logical to expect the agency and the public to have consulted the latest version of the subreferenced standard as they respectively develop and comment on the NPRM. This principle recognizes both SAEs intention for stakeholders to use the most recent version of its standards, and the agencys need to avoid incorporation of any subsequent version which would not have been available to receive the benefit of public comment e.
We note, however, that if public commenters did raise the issue of the revision date of any standard incorporated by reference e. As a related matter, we note that in analyzing the issues presented in your e-mail, we discovered an inconsistency in the version of SAE J incorporated by reference under S3. June and the version recited in the requirements of S5. November We understand that these two versions are substantively identical, with the latter version simply being a reaffirmation of the earlier standard pursuant to SAEs periodic review process.
The agency plans to issue a correcting amendment in the near future to resolve this discrepancy. If you have any further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at Skip to main content.
United States Department of Transportation. Report a Problem. Toggle navigation Homepage. Search Interpretations Cardinali1. Subsequently, a final rule was published in the Federal Register on July 25, , which included the amendment incorporating SAE J rev.
Sincerely, Anthony M. Cooke Chief Counsel ref d.
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Subscribers can view annotate, and download all of SAE's content. View Details. Motor Vehicle Dimensions. Elliptical eyellipse models in three dimensions are used to represent tangent cutoff percentiles of driver eye locations. Neck pivot P points are defined in Section 6 to establish specific left and right eye points for direct and indirect viewing tasks described in SAE J