NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam3503OpenMr. Michael M. Packard, Commissioner, Indiana Bureau of Motor Vehicles, State Office Building, Indianapolis, IN 46204; Mr. Michael M. Packard Commissioner Indiana Bureau of Motor Vehicles State Office Building Indianapolis IN 46204; Dear Mr. Packard: This is in response to your letter of November 23, 1981, asking fo suggestions that would enable the citizens of Indiana to do away with the necessity of using and retaining the federal odometer disclosure statement.; In my previous correspondence I indicated that the Indiana Certificat of Title could not be used in lieu of a separate Federal odometer disclosure statement unless additional information was incorporated. In your recent letter you asked whether the title application could be utilized to meet the Federal disclosure requirements. For your information, I have enclosed several notices that have appeared in the *Federal Register* that deal directly with this issue. The first is an August 1977 notice which allows states that wish to utilize their Certificates of Title as disclosure statements to include a shortened odometer disclosure statement, but requires other State documents to contain the longer form. In January 1980 the latter requirement was amended (see enclosed *Federal Register* notice) to allow the shortened form to be used in lieu of a separate Federal disclosure statement on *any* State document which evidences ownership of the vehicle. The effect of this change is to permit the State of Indiana to use the shorter form on its application for title and still have the application satisfy the Federal odometer disclosure requirements.; With respect to your comment that Indiana would like to enable citizen to do away with the necessity of retaining disclosure statements, I am enclosing a copy of a January 1980 *Federal Register* notice which discusses the retention requirements. As you will note, the retention requirements apply only to dealers and distributors (persons who buy or sell five or more motor vehicles within any 12 month period), and not to the average consumer. If Indiana incorporates an acceptable disclosure statement onto its title application, all dealers and distributors will, nevertheless, be required to maintain copies of these documents at their primary place of business. This requirement facilitates enforcement efforts and should not be too great a burden on businesses that already have storage facilities for the other documents.; I hope that I have satisfactorily responded to your concerns. I woul welcome the opportunity to work further with Indiana in the effort to curtail odometer fraud.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5087OpenMr. Kevin Mitchell Goodyear Tire & Rubber Co. Sun Prairie, WI 53590; Mr. Kevin Mitchell Goodyear Tire & Rubber Co. Sun Prairie WI 53590; "Dear Mr. Mitchell: This responds to your letter asking about th hydraulic brake hose labeling requirements (S5.2) of FMVSS 106, Brake Hoses. You indicated that your current brake hoses have two stripes, on opposite sides of the hose. Each of the stripes is interrupted by a line of information. One line, which you call the 'DOT print line,' contains the information required by FMVSS 106. The other line, which you call the 'SAE print line,' contains certain information not required by FMVSS 106, including 'batch and shift' information. You asked whether it is permissible to place the batch and shift information (consisting of a mark such as 'AA') on the DOT print line. You stated that moving the batch and shift mark to the DOT print line would improve the legibility of the SAE print line. This is because better print materials could be used in the SAE print line if that legend did not contain a mark that must be updated on a daily or more frequent basis, such as the batch and shift mark. As discussed below, the batch and shift information may not be placed on the same line as the required information. NHTSA's longstanding position, stated in past rulemaking notice preambles (e.g., 39 FR 7425, February 26, 1974, 39 FR 24012, June 28, 1974), is that the DOT print line may only contain the required information. The striping requirement (S5.2.1) of FMVSS 106 states that one of the requisite stripes on a brake hose 'may be interrupted by the information required by S5.2.2, and the other stripe may be interrupted by additional information at the manufacturer's option.' We interpret this to mean that the stripe that is interrupted by the required information may not be interrupted by information voluntarily provided by the manufacturer. This conclusion is consistent with the preamble for the final rule establishing S5.2.1 (38 FR 31302, November 13, 1973), which refers to optional additional information as not being permitted in the legend that interrupts the first stripe. (That rule modified the labeling requirements to permit interruption of the second stripe with the optional information.) NHTSA did not permit optional information to be mixed with the required information because the mixture of optional and required labeling could obscure or confuse the meaning of the required information, or interfere with the appearance of complete labeling on some hose assemblies. For your information, we have enclosed the Federal Register documents cited above. Please contact Ms. Fujita of my staff at (202) 366-2992 if you have any further questions. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam2742OpenMr. John Bonita, Jerome Avenue Dealers Association, 217 Broadway, Bronx, NY 10007; Mr. John Bonita Jerome Avenue Dealers Association 217 Broadway Bronx NY 10007; Dear Mr. Bonita: This is in response to your letter of December 1, 1977, requestin information on the Federal odometer disclosure law.; You asked whether an employee has the authority to sign an odomete disclosure statement relating to the purchase of vehicles sold dealer to dealer. Section 580.4 of Title 49, Code of Federal Regulations, requires each transferor of a motor vehicle to furnish to the transferee a written statement of the mileage traveled by the vehicle. 'Transferor' is defined as 'any person who transfers his ownership in a motor vehicle by sale, gift, or any means other than by creation of a security interest.' In a dealer-to-dealer transaction, as in all other transactions, the owner of the vehicle is responsible for signing the disclosure statement. He may assign that responsibility to an employee or representative. The transferor, however, as the owner of the vehicle, nevertheless remains liable for the actions of his employee.; You also raised the question in your telephone call of January 18, wit Kathy DeMeter of my staff, whether in a wholesale transaction all vehicles could be listed on one invoice as long as separate disclosure statements are issued for each. The National Highway Traffic Safety Administration is concerned with the issuance of correct mileage statements for each vehicle and does not have any objection to all the vehicles being listed in one invoice.; The sample 'Odometer Statement' which you enclosed with your lette meets all of the requirements of the Federal regulation. Thank you for your cooperation in preparing the revised statements.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam3850OpenMr. David A. White, Senior Safety Engineer, Grumman Olson, 70180 Centerville Road, Sturgis, Michigan 49091; Mr. David A. White Senior Safety Engineer Grumman Olson 70180 Centerville Road Sturgis Michigan 49091; Dear Mr. White: This responds to your letter of May 3, 1984, asking about Standard No 101, *Controls and Displays*. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listing in that table. You asked whether the symbols are required to be illuminated or whether its is permissible instead to illuminate the identifying words without illuminating the symbol. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.; By way of background information, I would note that the Nationa Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic an Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.; Section S5.2.1 of Standard No. 101 generally requires that 'an hand-operated control listed in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol.' The section states further that '(s)uch a control may, in addition, be identified by the word or abbreviation shown in column 2.' The three controls noted above, heating fan, windshield wiper and washer and defroster system, are all listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.; Section S5.3.1 of Standard No. 101 states: >>>Except for foot-operated controls or hand-operated controls mounte upon the floor, floor console, or steering column, or in the windshield header area, the *identification required by S5.2.1* or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield...[Emphasis added.]<<<; As discussed above, the identification required by section S5.2.1 fo the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word 'yes' in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated It is thus not permissible to illuminate the identifying words without also illuminating the symbols.; I would note that your letter does not provide sufficient informatio to determine whether the controls in you proposed design could come within any of Standard o. 101's exceptions to the illumination requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0285OpenMr. Charles W. Dietrich, Head, Traffic Sciences, Bolt Beranek and Newman, Inc. 50 Moulton Street, Cambridge, MA 02138; Mr. Charles W. Dietrich Head Traffic Sciences Bolt Beranek and Newman Inc. 50 Moulton Street Cambridge MA 02138; Dear Mr. Dietrich: This is in reply to your letters, both dated December 16, 1970 concerning Motor Vehicle Safety Standard No. 213, 'Child Seating Systems.' One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as 'not a safety harness,' and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.; Your second letter requests that a study conducted by the University o Michigan Highway Safety Research Institute (Contract No. FH- 11-6962), entitled 'Integrated Seat - Restraint and Child Systems,' be placed in the public docket, and further request that the 'data films of the dynamic sled test be made available through the Docket.' The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled 'Child Seat and Restraint Systems Test Program' but bears the same contract number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2312OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50 -- 100 W. Alondra Blvd., Gardena, CA 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 -- 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill: This is in response to your May 6, 1976, request for confirmation tha the Honda 'MPV' qualifies as a multipurpose passenger vehicle although it is constructed on a 'modified' truck chassis.; In our letter to you of April 30, 1976, we concluded that the Hond 'MPV' would be classified as a multipurpose passenger vehicle, based upon the assumption that the 'MPV' is constructed on a truck chassis. You responded that the 'MPV' is constructed on a 'modified' truck chassis, and questioned whether the National Highway Traffic Safety Administration considered this fact in its previous interpretation.; The reference to 'truck chassis' in the definition of multipurpos passenger vehicle, 49 CFR Part 571.3(b), is intended to include chassis that were designed and developed for trucks, but which have been produced in a version for use in passenger carrying vehicles. According to your letter and drawings of March 1, 1976, the Honda 'MPV' is a passenger version of the Honda TN 500 light truck. Since the modification of the chassis in the production of the 'MPV' does not appear to be so great that the major characteristics of the truck chassis are destroyed, we confirm our previous determination that the Honda 'MPV' qualifies as a multipurpose passenger vehicle.; Sincerely, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam0905OpenMr. James L. Burgess, 1414 Home Savings Building, 1006 Grand Avenue, Kansas City, MO 64106; Mr. James L. Burgess 1414 Home Savings Building 1006 Grand Avenue Kansas City MO 64106; Dear Mr. Burgess: This is in reply to your request of November 8, 1972, for informatio concerning the effects of governmental regulation on a decorative bumper that your client proposes to manufacture for sale in the automotive 'after-market.'; As far as Federal standards are concerned, your client's product is no a regulated item of equipment as long as it is installed after the vehicle has been sold to a customer for purposes other than resale. Although we have issued a standard to regulate the safety of bumpers on passenger cars (Federal Motor Vehicle Safety Standard No. 215, 49 CFR 571.215, effective September 1, 1972), the standard does not apply to the bumper as a separate item of equipment. Thus, a new car manufactured after the effective date of the standard must conform to the standard, but a bumper manufactured after the effective date and sold separately from the vehicle as a replacement part or add on, does not have to conform.; We strongly recommend, however, that any bumper system developed fo sale in the after-market be designed to conform to the performance requirements of Standard No. 215. If it should happen that significant problems are caused by the sale of inadequate bumpers, it may be necessary to expand the application of the standard to regulate the bumper as a separate item of equipment.; For your added information, state statutes with which we are familia also apply to new vehicles and would presumably not affect the installation of your client's product. However, you might find it advisable to ask the opinion of responsible state officials on this question.; If we can be of further assistance, please let us know. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2938OpenMr. James R. Randolph, 765 Malley Drive, Northglenn, CO 80233; Mr. James R. Randolph 765 Malley Drive Northglenn CO 80233; Dear Mr. Randolph: This responds to your December 28, 1978, letter concerning an auxiliar fuel tank installed by the dealer on a 1978 Ford van that you purchased. You are concerned that the auxiliary tank represents a safety hazard due to the location of the tank's filler cap in the left rear wheel-well.; Federal Motor Vehicle Safety Standard No. 301-75, *Fuel Syste Integrity* specifies performance requirements for fuel systems on motor vehicles. Although the standard applies to completed vehicles rather than to fuel tanks or other fuel system components, your dealer had to assure that your van complied with the standard. A person who mounts an auxiliary fuel tank on a new motor vehicle before the vehicle's first purchase in good faith for purposes other than resale is a vehicle alterer under National Highway Traffic Safety Administration regulations. That person is required by 49 CFR 567.7 to affix a label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards--including Safety Standard No. 301-75. Therefore, there should be an 'alterer' label on your van in addition to the certification label placed on the vehicle by the original manufacturer.; Even if the vehicle complies with Safety Standard No. 301-75, th location and design of the auxiliary fuel tank could constitute a safety-related defect for which the manufacturer would also be responsible. I am, therefore, forwarding a copy of your letter to the agency's Office of Defects Investigation. That office will examine this situation and may be in touch with you at a later date.; Thank you for your letter and for bringing this matter to ou attention.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1617OpenMr. Robert S. Podlewski, Brake Engineer, Diamond Reo Trucks, Inc., 1331 S. Washington, Lansing, MI 48920; Mr. Robert S. Podlewski Brake Engineer Diamond Reo Trucks Inc. 1331 S. Washington Lansing MI 48920; Dear Mr. Podlewski: This responds to your August 13, 1974, question whether building motor vehicle from a used power train (rear axle, suspension, drive line, and engine) and a new 'glider kit' constitutes the manufacture of a new motor vehicle, subject to Federal motor vehicle safety standards, including Standard No. 121 after March 1, 1975. Typically, a 'glider kit' is a truck chassis on which a cab and front axle system are mounted, which is purchased to permit the re-utilization of a power train from another vehicle.; Re-use of components from an existing vehicle in the construction o another vehicle may or may not result in the manufacture of a new vehicle. The NHTSA has established that the addition of new components (such as a truck body) to the chassis of a used vehicle does not constitute the manufacture of a new vehicle. Conversely, the addition of used components to a new chassis which has never been certified in a vehicle constitutes the manufacture of a new vehicle, subject to the safety standards in effect for that vehicle class on the date of manufacture. This criterion has been relied on in the area of chassis-cab multistage manufacture.; Since a glider kit typically incorporates a new chassis (as well as new cab and front suspension), the NHTSA finds that the use of such a glider kit in the construction of a motor vehicle constitutes the manufacture of a new motor vehicle. To conclude otherwise would mean that a vehicle composed entirely of brand new components except the rear axle and perhaps the engine and transmission, would qualify as a used vehicle.; You noted that our decision could eliminate the use of glider kit because Standard No. 121 certification would prevent re-use of rear axles which do not meet 121-level performance requirements. We believe that our determination will contribute to motor vehicle safety by introducing more 121-type vehicles on the highway and will not interfere with the use of glider kits in the long term. Glider kits can be made to meet Standard No. 121 as soon as 121-type rear axles become available on the used market. Until that time, the rear axles of present vehicles may be utilized as replacement parts in used vehicles which are not required to meet Standard No. 121.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4415OpenMr. Frank Miller, Gerry Baby Products, 12520 Grant Drive, Denver, Co 80233; Mr. Frank Miller Gerry Baby Products 12520 Grant Drive Denver Co 80233; Dear Mr. Miller: This responds to your September 25, 1987, letter to Mr. Val Radovich o NHTSA's Office of Vehicle Safety Standards and your October 19, 1987 letter to my office concerning paragraph S4.2.1 of Safety Standard No. 302, *Flammability of Interior Materials*.; You ask whether the thread that is used in the manufacture of a sea cushion is tested as part of the component. The answer is yes. In a March 10, 1978 interpretation of Standard No. 302, NHTSA recognized that stitching that does not adhere at every point of contact should be tested separately under S4.2.1. However, the agency also determined that, from the standpoint of practicality, the stitching cannot be tested separately in the prescribed manner. NHTSA thus concluded that stitching will be tested as part of the material itself.; Please contact us if you have further questions. Sincerely, Erika Z. Jones, Chief Counsel |
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.