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 |
|---|---|
ID: aiam3374OpenMr. Clint Moye, Assistant Director, Motor Vehicle Division, State Revenue Department, Room 101, Trinity Washington Building, Atlanta, GA 30334; Mr. Clint Moye Assistant Director Motor Vehicle Division State Revenue Department Room 101 Trinity Washington Building Atlanta GA 30334; This is in response to your request on the adequacy of the Georgi certificate of title for use in lieu of a separate Federal odometer form.; As you know, the Federal odometer requirements that became effective a of January 1, 1978, have been substantially increased. We have made provision for those states that wish to include odometer information on their titles to use a shortened form that was adopted by the American Association of Motor Vehicle Administrators (AAMVA). We consider the AAMVA form to include the minimum amount of information ncessary for an adequate disclosure.; In addition to the information included on the sample title which yo submitted to our office, the buyer's signature is also required. If this signature is included, the title may be used in lieu of a separate Federal form.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2647OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body & Equipment Assoc., Inc., 5530 Wisconsin Ave., Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body & Equipment Assoc. Inc. 5530 Wisconsin Ave. Suite 1220 Washington DC 20015; Dear Mr. Crampton: This responds to your July 22, 1977, request for clarification of m July 21, 1977, letter to you stating that, in the case of brake and axle modifications to change the function of a used vehicle from that for which it was originally manufactured, it is the NHTSA's view that degradation of the brake system would only occur as prohibited by the National Traffic and Motor Vehicle Safety Act (S 108(a)(2)(A)) if portions of the brake system originally installed are removed, disconnected, or otherwise rendered inoperative. You asked whether a change in 'function' of a vehicle would include a modification that simply increases the load-carrying capacity or stability of a vehicle to carry out the same task for which it was originally manufactured.; The answer to your question is no. In the NHTSA's view, the changes yo describe would only increase the capabilities of the vehicle to perform its originally manufactured function. Thus, the 'element of design' that constitutes the original braking system of the vehicle could be knowingly degraded by the installation of an additional axle that does not provide the capability that would have been required for it if installed in the new vehicle.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: nht92-5.13OpenDATE: July 23, 1992 FROM: Takashi Odaira -- Chief Representative, Emissions & Safety, Isuzu Technical Center of America, Inc. TO: Paul Jackson Rice -- Chief Counsel, NHTSA COPYEE: Mr. Sakai TITLE: FMVSS 214 Side Impact Protection Quasi-static Door Strength Test ATTACHMT: Attached to letter dated 10/5/92 from Paul Jackson Rice to Takashi Odaira (Std. 214) TEXT: The side door strength test procedures specified in FMVSS 214 are not quite clear as they relate to pickup trucks. In the attached sheets, we have described three alternative procedures that Isuzu Motors Limited, Japan, plans to follow. Isuzu Motors requests your agency's view and/or comment on each of these procedures. I would appreciate receiving your prompt reply.
(Attachments omitted) |
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ID: nht90-4.43OpenTYPE: Interpretation-NHTSA DATE: October 12, 1990 FROM: A. Kling -- Hamadbik, Ltd. TO: U.S. Dept of Transport, NHTSA TITLE: Re: (FMVSS) No. 116 ATTACHMT: Attached to letter dated 3-8-91 from Paul Jackson Rice to A. Kling (A37; Std. 116) TEXT: We are enquiring about the abovementioned Safety Standard regarding DOT 3 and DOT 4 brake fluids. Clause S5.1.14 of the above standard refers to the color of the brake fluid being colorless to amber. We would much appreciate your sending us the color coding range of amber referred to in this clause. We would appreciate your sending us the color cod e and chart used by your department and as designated by the U.S. federal department We much appreciate your cooperation and thank you in advance |
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ID: nht93-2.38OpenDATE: March 30, 1993 FROM: Greg Hixson -- President, Hixson and Netherton Distributing TO: Office of the Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 4-16-93 from John Womack to Greg Hixson (A41; Std. 208) TEXT: Hixson and Netherton Distributing a corporation in Dallas, Texas wishes to import an "Aftermarket Airbag" for automobiles to be sold in the United States. We have been unable to obtain any specifications, standards or regulations regarding Airbags or importing of such an item. If your office has any of this information we would certainly appreciate you forwarding it to our office as soon as possible. We can be reached by phone or by mail at the following: Hixson and Netherton Distributing P.O. Box 28995 Dallas, Texas 75228 (214) 682-9836 A prompt reply would be very much appreciated. |
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ID: nht93-4.42OpenDATE: June 23, 1993 FROM: Gail Lindsey -- Hillsborough County Public Schools, Risk Management & Safety Department, Tampa, Florida TO: Ron Engles -- Safety Counter Measure Division TITLE: None ATTACHMT: Attached to letter dated 8/5/93 (est) from John Womack (signature by Kenneth N. Weinstein) to Gail Lindsey (A41; Part 571.3) TEXT: This correspondence is a reply to our recent phone conversation concerning the transporting of school children to and from special events in any vehicle other than school buses. In the past, it has been School Board policy to disallow the use of mini-vans on such events. I am requesting any information on the crash safety standards of such vehicles, or any recommendations that your office may give so that we can make a safe and fair determination on this current policy. Any assistance you can give will be greatly appreciated. |
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ID: nht72-3.25OpenDATE: 06/30/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Harold Schlintz & Associates TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of June 8, 1972, to Robert L. Carter, as to whether Federal Motor Vehicle Safety Standard No. 206 is applicable to a White "Freightliner" which was manufactured on or about December 1, 1970. The White Freightliner, as illustrated in the picture you enclosed, is a truck tractor, and is classified as a "truck" under the motor vehicle safety standards. Standard No. 206 became applicable to trucks on January 1, 1972, and would not therefore apply to this truck. No other standards are applicable to the doors or door latches of this vehicle. The standards do not apply to a vehicle after its first sale to a consumer (a used vehicle), and we exemption from the standards is necessary. |
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ID: nht92-5.18OpenDATE: July 14, 1992 FROM: Bill Traylor -- President, Waste Processing Equipment, Inc. TO: Office of Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 9/4/92 from Paul Jackson Rice to Bill Traylor (A39; Part 567) TEXT: Enclosed is a blueprint on a private motor coach we are constructing on a WCA Series Volvo GMC Class 8 truck chassis. Please advise in writing whether or not this vehicle will have to be certified by your administration. If certification is required, please advise as to how and what we do during the construction of the vehicle in order to assure certification. If you need to discuss this matter by phone, please call me at (205) 638-6355. A quick response will be appreciated since we are starting construction on or about August 1, 1992. |
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ID: nht75-1.5OpenDATE: 04/22/75 FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA TO: Kazuhiko Aoki TITLE: FMVSS INTERPRETATION TEXT: APR 22 1975 N40-30 TWH) Mr. Kazuhiko Aoki 2-3 Nihonbashi Koami-cho 1-chome Chuo-ku/ Toykyo, Japan 103 Dear Mr. Aoki: This responds to your January 30, 1975, question whether the test procedure of S7.7.1 in Standard No. 105-75, Hydraulic brake systems, refers to the parking brake in the next to the last sentence which states that it "may be necessary to reapply it if the vehicle moves slightly" (emphasis added). The word "it" refers to the service brake system, and not the parking brake system. This sentence permits application of the service brake only, which has the effect of taking up parking brake system slack due to rotation of the brake shoes and drum prior to bottoming against the anchor pin. Sincerely, James C. Schultz Chief Counsel |
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ID: nht89-3.13OpenTYPE: INTERPRETATION-NHTSA DATE: 10/12/89 FROM: GEORGE MILLER -- MEMBER OF CONGRESS TO: NANCY BRUCE -- DIRECTOR OFFICE OF CONGRESSIONAL AFFAIRS DEPARTMENT OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 12/1/89 FROM STEPHEN P. WOOD -- NHTSA TO U.S. CONGRESSMAN GEORGE MILLER; REDBOOK A34; STANDARD 125; LETTER DATED 10/17/89 FROM NANCY L. BRUCE -- D.O.T OFFICE OF CONGRESSIONAL AFFAIRS TO GEORGE MILLER, U.S. HOUSE OF REPR ESENTATIVES; LETTER DATED 10/4/89 FROM DELL RANDLE TO CONGRESSMAN GEORGE MILLER; LETTER DATED 9/8/89 FROM ELIZABETH M LUCAS -- NATIONAL SAFETY COUNCIL, PRODUCT DEVELOPMENT TO DELL RANDLE OF SHIKARI CONSULTANT FIRM LTD. TEXT: Dear Ms. Bruce: The enclosed correspondence from my constituent, Mr. Dell Randle, concerning the safety approval of his device, the Shi-Lite Holder, is being forwarded for your consideration. I would appreciate any assistance you may be able to provide in addressing the concerns presented in Mr. Randle's letter. Please direct your response to Jennifer Steneberg of my Richmond office at 3220 Blume Drive, Suite 281, Richmond, CA 94806, (415 ) 222-4212. Sincerely, |
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.