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: aiam2611OpenHonorable Joseph L. Fisher, 19 East Market Street, Leesburg, VA 22075; Honorable Joseph L. Fisher 19 East Market Street Leesburg VA 22075; Dear Mr. Fisher: This responds to your February 16, 1977, letter asking whether day car centers are required to purchase buses manufactured in conformance with the school bus safety standards.; The National Highway Traffic Safety Administration has decided that th inclusion of day care centers within the definition of 'school', for purposes of applying the school bus safety standards, would be inappropriate at this time. After careful deliberation, the agency has concluded that since the school bus safety standards do not specifically refer to day care centers, cay care center operators may not have been aware of the possibility that vehicles they use might be subject to school bus safety requirements. Therefore, persons interested in that issue may not have fully participated in our earlier rulemaking on the subject.; In accordance with accepted rulemaking procedures, the agency intend to issue a proposal to extend the coverage of the school bus standards to buses purchased by day care centers. This proposal will provide an opportunity for persons interested in the operation of these facilities to comment upon the advisability of extending the school bus safety standards to their vehicles.; I appreciate your interest in this issue and apologize for an inconvenience caused to your constituent by the length of time required to make this decision.; Sincerely, Joan Claybrook |
|
ID: aiam0339OpenMarion C. Denton, Marden Manufacturing Company, 205 Denton Avenue, Auburndale, FL 33823; Marion C. Denton Marden Manufacturing Company 205 Denton Avenue Auburndale FL 33823; Dear Mr. Denton: This is in reply to your letter of May 3, 1971, requesting a interpretation of the Tire Identification and Record Keeping Regulation. You indicated in your letter that you are a trailer manufacturer. As such, you are considered a motor vehicle manufacturer under both the regulation and section 102(3) and (5) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et seq*.) (copies enclosed).; As a manufacturer, you are required, by section 113(f) of the Act, t record the name and address of the first purchaser for purposes other than resale. Section 574.10 of the regulation requires that you maintain a record of the tires shipped on or in vehicles which you manufacture. In the event of a defect notification concerning either the vehicle or its tires, your responsibilities are enumerated in section 111 and 113 of the Act.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam2304OpenHonorable James L. Buckley, United States Senate, Washington, DC 20510; Honorable James L. Buckley United States Senate Washington DC 20510; Dear Senator Buckley: This is in response to your letter of May 11, 1976, forwarding petition from Gulf + Western Manufacturing Company for reconsideration of the bumper standard recently issued as Part 581 of Title 49 Code of Federal Regulations.; A number of requests for our view on the Gulf + Western petition hav been forwarded by members of Congress who have received copies of the Gulf + Western petition accompanied by a letter from Mr. James A. Graham.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Gulf + Western.; I assure you that Gulf + Western's comments and the informatio contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam0293OpenMr. Y. Takami, Engineer, Toyo Tire (U.S.A.) Corporation, 3136 East Victoria Street, Compton, CA 90221; Mr. Y. Takami Engineer Toyo Tire (U.S.A.) Corporation 3136 East Victoria Street Compton CA 90221; Dear Mr. Takami: This is in reply to your letter of February 2, 1971, to Mr. Casanov concerning Part 574 - Tire Identification and Record Keeping.; Adding a group of numbers consisting of three-digits to the tir identification number is not permitted under the regulation because the additional numbers would be too easily confused with the tire identification number.; You are not prohibited, however, from placing the additiona three-digit number elsewhere on the tire in an area where it would not be confused with the required tire identification number. Anywhere further than six inches would be far enough to avoid confusion.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam3846OpenMr. Masakatsu Kano, Executive Vice President, MMC Services Inc., Suite 1960, 3000 Town Center, Southfield Michigan 4805; Mr. Masakatsu Kano Executive Vice President MMC Services Inc. Suite 1960 3000 Town Center Southfield Michigan 4805; Dear Mr. Kano: This responds to your letter of April 13, 1984, addressed to Mr. Roma Brooks of NHTSA's Office of Enforcement. You stated that you were submitting the letter 'to assure that the Agency and Mitsubishi agree in writing as we did verbally' concerning the compliance of a proposed electronic odometer design with Standard No. 101, *Controls and Displays.* You also stated that lead time dictates an imminent decision on design plans, that the agency's early approval/response' to your selected solution is greatly appreciated, and that if you do not hear to the contrary within 30 days, you will assume the agency's concurrence. As discussed below, your letter indicates a serious misunderstanding of both Federal statutory requirements and NHTSA policies and procedures. Moreover, your apparent interpretation of Standard No. 101 is incorrect.; First, NHTSA does not grant approval of motor vehicle or motor vehicl equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements.; NHTSA is willing to provide interpretations and opinions in response t reasonable requests. However, such interpretations and opinions are only provided in writing and only by NHTSA's Chief Counsel. The agency does not consider itself bound by verbal statements made by agency employees or by interpretations made by persons other than the Chief Counsel.; Moreover, NHTSA does not offer interpretations by remaining silent i response to letters which assert that such silence is assumed to be concurrence. The agency considers the inclusion of such purported conditions to be inappropriate and does not consider itself bound by them.; The agency regrets if Mr. Brooks' conversation contributed to th misunderstandings apparent in your letter. In the future, questions of interpretations should be addressed in writing to the Chief Counsel.; Your question of interpretation concerns a proposed design for a electronic odometer which would display either miles or kilometers. The following represents our opinion based on the facts provided in your letter.; According to your letter, the vehicle's speedometer would display, a the option of the driver, in either miles per hour or kilometers per hour. The selected unit of measure would be identified by a lighted display reading either 'MPH' or 'Km/h'. The digits of the odometer would correspond to the units of measure selected for the speedometer, but the odometer itself would not identify its units of measure. As discussed below, such a design would not meet the requirements of Standard No. 101, since that standard requires an odometer that indicates kilometers to be identified by 'KILOMETERS' or 'km'.; Section S5 of Standard No. 101 requires that 'each passenger car multi-purpose passenger vehicle and truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.' Odometers are one of the display listed in column 1 of Table 2.; Section S5.2.3 references the requirements of Table 2. Footnote 3 o Table 2 specifies the following requirements for odometers:; >>>If the odometer indicates kilometers, then 'KILOMETERS' [or] 'km shall appear, otherwise no identifications is required.<<<; Section S5.2.3 further provides that '[t]he identification required o permitted by this section shall be placed on or adjacent to the display that it identifies.; Standard No. 101 thus requires odometers indicating kilometers to b identified by 'KILOMETERS' or 'km', and such identification must be placed on or adjacent to the odometer. Since your proposed design would indicate kilometers, it would be necessary to identify its units of measure according to these requirements.; I would note that these requirements cannot be met merely by placin the odometer adjacent to the speedometer. While the identification of the selected units of measure for the speedometer could be placed adjacent to both the speedometer and odometer, the identification requirements are different for the two displays. Table 2 requires that a speedometer graduated in miles per hour and kilometers per hour be identified by 'MPH and km/h' in any combination of upper or lower case letters. As discussed above, the requirement for odometers is 'KILOMETER' or 'km'. A single identification of units of measure cannot meet these requirements simultaneously.; Please note that this opinion is limited to the specific issue raise by your letter and does not consider whether the proposed design would otherwise meet the requirements of Standard No. 101.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam5091OpenMr. Chester I. Nielsen, III Vice President Sales Wesbar Corporation P.O. Box 577 West Bend, WI 53095; Mr. Chester I. Nielsen III Vice President Sales Wesbar Corporation P.O. Box 577 West Bend WI 53095; Dear Mr. Nielsen: This responds to your letter of October 21, 1992, t Walter B. McCormick, Jr. (the General Counsel of this Department). You have written for 'further explanation of S5.3.1.1.1 in FMVSS 108.' You have heard that there is an additional interpretation with respect to the location of clearance lamps on boat trailers whose overall width is 80 inches or more, which would allow mounting of these lamps in accordance with a sketch that you enclosed, and you ask for confirmation of this interpretation. We are unaware of any interpretation of this nature. The requirements for the provision and location of clearance lamps on wide boat trailers remain those set forth in Tables I and II of Standard No. 108, with the exceptions set forth in paragraphs S5.1.1.9, S5.3.1.1.1, and S5.3.1.4. Sincerely, Paul Jackson Rice Chief Counsel; |
|
ID: aiam0769OpenMr. D. P. Peck, The Standard-Triumph Motor Co., Ltd., Coventry, England; Mr. D. P. Peck The Standard-Triumph Motor Co. Ltd. Coventry England; Dear Mr. Peck: This is in reply to your letter of June 28, 1972, in which yo requested formal confirmation of the interpretation of S4.3(c) of Motor Vehicle Safety Standard No. 209 given you informally on June 22.; The requirements of S4.3(c) apply to bolts used to secure the pelvi restraint of a seat belt assembly. They do not apply to bolts used to secure the upper torso restraint. Bolts for the upper torso restraint are therefore regulated with respect to their strength only by the assembly performance requirements of S4.4(b).; The reference to shoulder bolts' in S4.3(c) relates to the design o the bolt and not to the manner of its use. Pelvic restraints are often attached to the vehicle by such bolts, hence the reference to them.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2754OpenMr. B. Henderson, Legislative Engineer, NVT Motorcycles Limited, Lynn Lane, Shenstone, Lichfield, Staffordshire WS14 OEA, England; Mr. B. Henderson Legislative Engineer NVT Motorcycles Limited Lynn Lane Shenstone Lichfield Staffordshire WS14 OEA England; Dear Mr. Henderson: This is in reply to your letter of December 15, 1977, asking for a interpretation of S5.1 of Federal Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*. You have asked whether a switch on the right handlebar of moped exported by NVT to the United States may be viewed as the 'supplement engine stop control' that the standard requires.; You have noted that the switch is 'identified as required in Table 3 and that the engine can be stopped by the clutch that is part of the starter arrangement. To answer your question it is necessary to make several assumptions as your letter is not complete enough to allow a definitive response. If the normal or recommended method of stopping the vehicle is through the clutch then the switch may serve as the supplemental engine stop control. If, however, turning the switch to off is the normal or recommended method of stopping the vehicle, it cannot be viewed as a supplemental control.; We assume that the switch is identified as 'engine stop' and no 'ignition' since you refer to it as a means of stopping the vehicle and imply that the clutch arrangement is the only method of starting it. If our assumptions are not correct, please inform us of the correct facts so that we may advise you accordingly.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam3515OpenMr. James S. Nasby, Director of Engineering, Pathfinder Auto Lamp Company, 6201 W. Howard Street, Niles, IL 60648; Mr. James S. Nasby Director of Engineering Pathfinder Auto Lamp Company 6201 W. Howard Street Niles IL 60648; Dear Mr. Nasby: This responds to your November 25, 1981, letter to Roger Tilton of thi Office regarding the applicability of vehicle identification number (VIN) requirements to trailer kits manufactured by your company.; It is our view that these trailer kits must comply with the VI requirements of FMVSS 115. Your kits contain all components necessary to assembly a complete trailer, and are advertised as capable of being readily assembled with simple tools such as screwdrivers and wrenches. We see no relevant basis for distinguishing between such kits and completed trailers for purposes of determining the applicability of FMVSS 115.; While the VIN requirements do provide anti-theft benefits, they als are important to this agency in administering the defect recall program as well as to State motor vehicle departments and insurance companies. Further, even if this agency exempted trailer kits from VIN requirements, purchasers of your kits would likely face difficulties when they attempt to register their trailers with the States. We expect most states to soon begin checking VIN's as part of the vehicle registration process, and vehicles without a VIN or with a nonconforming identification number might face rejection by the state motor vehicle departments notwithstanding a technical exemption from NHTSA. We feel that in the long run, the best and simplest solution is for vehicle manufacturers to assign a VIN which meets the requirements of FMVSS 115.; Should you still wish to seek an exemption from the standard procedures for obtaining exemptions are set forth in Title 49 of the Code of Federal Regulations, Part 555, a copy of which is enclosed. Such exemptions are available for not more than three years.; You should also be aware that certification labels must contain bot the month and year of a vehicle's manufacture. See 49 CFR 567.5(b)(5). The copy of the label you sent us contains only the year of manufacture.; If you have further questions on this matter, feel free to contact u again.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam1528OpenMr. J.M. Craig, President, Gator Trailer Corp., 1925 E. Beaver, Jacksonville, FL, 32206; Mr. J.M. Craig President Gator Trailer Corp. 1925 E. Beaver Jacksonville FL 32206; Dear Mr. Craig: This is in reply to your letter of May 30, 1974, describing you pontoon boat trailer and asking if it is permissible to offer a '. . . clamp on light bar at the rear along with front side marker amber lighting for installation forward on the pontoon boat itself?' As you point out 'This would mean that the user would have to install the lighting each time a rig is put on the highway.'; Your proposed installation arrangement does not appear to be i conformance with paragraph S4.3.1 of Federal Motor Vehicle Safety Standard No. 108, which requires that lighting and reflective devices be *securely* mounted on a rigid part of the *vehicle*. If the cargo partially obscures the visibility of the required lighting devices on the trailer, State regulations would govern any additional, temporarily attached lighting devices on the cargo.; We trust this answers your question. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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.