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: aiam2878OpenMr. J. Kawano, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., One Harmon Plaza, Secaucus, NJ 97094; Mr. J. Kawano Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. One Harmon Plaza Secaucus NJ 97094; Dear Mr. Kawano: This is in reply to your letter of September 6, 1978, requesting a interpretation of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*. You referred to the Society of Automotive Engineers (SAE) Standard J571d, referenced in Standard No. 108, which specifies dimensions for rectangular headlamp retaining rings in its Figure 8(B). The table of dimensions in Figure 8 specifies a maximum of 1.52 mm for the 'K' dimension on the drawing, the distance of the forward portion of the retaining ring from the lens surface. You stated that Toyota plans to increase that dimension by an unspecified amount for ornamental purposes.; You further advised that the proposed design would not interfere wit the ability of the headlamps to meet the performance requirements of SAE J580a and b and of the mechanical aiming requirements of SAE J602c.; Since Figure 8(B) of SAE J571d shows that the 'K' dimension shall no exceed 1.52 mm, any greater dimension would not meet the specifications of the standard. However, you may petition for rulemaking to appropriately amend Standard No. 108. We cannot, however, offer any assurance that the standard would be changed in response to your petition.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0845OpenMr. S.G. Jonas, Attorney and Counselor, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. S.G. Jonas Attorney and Counselor American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Jonas: This is in reply to your letter of May 24, 1972, concerning the tes procedures applicable to a passenger car headlamp after the impacts required by Motor Vehicle Safety Standard No. 215.; Your question is whether the requirements of SAE Standard J580a, whic are incorporated in the lighting systems standard, Standard No. 108, are meant to be incorporated into Standard No. 215, and, if so, whether the 'Aiming Adjustment Tests' of SAE J580a are to be performed in a laboratory fixture or on the vehicle.; Our answer is that Standard No. 215, in adopting the headlam adjustment requirements of Standard No. 108, incorporates the requirements of SAE J580. Contrary to your impression, SAE J580 can be conducted either as a bench test or as an on-vehicle test, and as incorporated into Standard No. 215 its aiming adjustment test will be applied as an on-vehicle test. The use of the bench test procedure by our Office of Standards Enforcement in its laboratory procedures manual for Standard No. 108 should not be understood to mean that we consider the bench test to be the only test method under SAE J580a.; Sincerely, Richard B.DDyson (sic), Assistant Chief Counsel |
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ID: aiam4555OpenGeorge F. Ball, Esq. Office of the General Counsel General Motors Corporation New Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit, MI 48232; George F. Ball Esq. Office of the General Counsel General Motors Corporation New Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit MI 48232; "Dear Mr. Ball: This responds to your letter seeking our opinion as t whether a new minivan GM plans to introduce (referred to as the GM 200 minivans in your letter) could be classified as a 'multipurpose passenger vehicle' for the purposes of the Federal Motor Vehicle Safety Standards. In your letter, you indicated GM's belief that this new minivan should be classified as a multipurpose passenger vehicle, because it will be constructed on a truck chassis. Your company has concluded that this minivan will be constructed on a truck chassis for several reasons. First, you state that this chassis has 'truck attributes' that make it more suitable for commercial use than a passenger car chassis would be. The examples of such truck attributes set forth in your letter were an integrated ladder-type frame with full-length longitudinal rails and supporting cross-members, an extended width rear axle, a powertrain certified as complying with the light-duty truck emissions standards, and a flat load floor. Second, you state the chassis is a truck chassis because a cargo van version of this vehicle will be marketed and sold for commercial use. Third, you provided an analysis showing that this minivan will have certain chassis and body characteristics similar to those characteristics of minivans that are now produced and classified as multipurpose passenger vehicles. At the outset, I would like to make clear that the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) places the responsibility for classifying a particular vehicle in the first instance on its manufacturer. For this reason, NHTSA does not approve or endorse any vehicle classifications before the manufacturer itself has classified a particular vehicle. NHTSA may reexamine the manufacturer's classification in the course of any enforcement actions. We will, however, tentatively state how we believe we would classify this vehicle for the purposes of the safety standards. It is important for GM to be aware that these tentative statements of classification are based entirely on the information presented to the agency by GM, and the tentative classifications may change after NHTSA has had an opportunity to examine the vehicle itself or otherwise acquire additional information about the vehicle. With those caveats, we believe that the GM 200 minivan family could be classified as a multipurpose passenger vehicle for the purposes of the safety standards, because it will be constructed on a truck chassis. The fact that a cargo van version of the GM 200 will be marketed and sold for commercial use is evidence that the common chassis is a truck chassis. Additionally, the front to rear longitudinal side rails and supporting cross-members that are not present on the A-car chassis shows the GM 200 minivan chassis design is more suitable for heavy duty, commercial operations than the A-car chassis. Finally, the characteristics of the GM 200 chassis appear to be similar to the characteristics of other chassis that have been identified as 'truck chassis' by their manufacturers. Accordingly, assuming that your description of the GM 200 chassis is accurate, it appears to us that this minivan is constructed on a truck chassis. The version of your letter to me that has been placed in the public docket has all the information for which you requested confidential treatment deleted from it. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam3290OpenMr. Donald E. Boyd, Donald Boyd & Associates, Inc., 5617 W. 6th Street, Stillwater, OK 74074; Mr. Donald E. Boyd Donald Boyd & Associates Inc. 5617 W. 6th Street Stillwater OK 74074; Dear Mr. Boyd: This responds to your recent letter requesting confirmation that larg commercial truck tractors do not have to comply with Federal Motor Vehicle Safety Standard No. 216, *Roof Crush Resistance*. You also asked whether large trucks should be designed to comply with the 'belt system' option under Safety Standard No. 208, *Occupant Crash Protection*.; You are correct in your assumption that large commercial trucks woul not have to comply with Safety Standard No. 216 since that standard only applies to passenger cars. You are also correct in stating that trucks with a GVWR greater than 10,000 pounds may meet the seat belt option of Safety Standard No. 208 found in paragraph S4.3.2 Under S4.3.1, manufacturers do have the option of meeting the crash protection requirements of S5 by means that require no action by vehicle occupants (with current technology this means air cushion restraints or automatic seat belts). Further, vehicles manufactured prior to August 15, 1977, were permitted to comply with Safety Standard No. 216 in lieu of the 'rollover' requirements of Standard No. 208, and for large trucks this would have been a simple test to meet. However, since the vehicle would also have been required to meet the 'frontal' and 'lateral' requirements by automatic means if option S4.3.1 were taken, no truck manufacturer chose to comply with the 'rollover' requirements of Standard No. 208 via the Standard No. 216 option. Rather, seat belts were installed on all large trucks.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1307OpenMr. Gerald Ahronheim, 807 Demerius, #J-1, Durham, NC 27701; Mr. Gerald Ahronheim 807 Demerius #J-1 Durham NC 27701; Dear Mr. Ahronheim: This is in response to your request for a statement of your odomete disclosure obligations under the Motor Vehicle Information and Cost Savings Act, Public Law 92- 513.; Under the Act, all transferors must make a 'mileage statement' to th transferee. 'Transferor' means any person who transfers his ownership in a motor vehicle by sale, gift, or any means other than by creation of a security interest. This includes a dealer transfering (sic) a new or used vehicle. The only exceptions to the requirement are for vehicles over 16,000 pounds gross weight rating, non-self-propelled vehicles, vehicles 25 years old or older, and new vehicles sold by a dealer to another dealer for resale.; The statement must contain (1) the odometer reading, (2) date o transfer, (3) transferor's name and current address, (4) vehicle identification or serial number, make, model, year, body-type, last plate number, (5) a statement that actual mileage differs from recorded mileage if such is the case and the transferor knows it, and (6) reference to the Motor Vehicle Information and Cost Savings Act with the statement that incorrect information may result in civil liability under it. An example of an adequate statement and format is enclosed for your information.; The federal government does not print these forms but severa commercial printers have prepared Federal disclosure forms for the convenience of dealers. Alternatively, the statement may be included in the bill of sale, or other transfer document. In any case, it must be completed and signed prior to the transfer. Either the original or carbon copy may go to the transferee. You can see that the transferor must make a statement about actual mileage only if he knows that it differs from recorded mileage. A person like yourself who has no knowledge of odometer accuracy would only state the recorded mileage.; A copy of the Act is also enclosed for your information. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4105OpenMr. Don Black, Director, U.S. Engineering Office, Alfa Romeo, Inc., 250 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Don Black Director U.S. Engineering Office Alfa Romeo Inc. 250 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Black: This responds to your letter to Mr. Barry Felrice, our Associat Administrator for Rulemaking, requesting an interpretation of Part 541, *Federal Motor Vehicle Theft Prevention Standard*. Specifically, you stated that Alfa Romeo plans to label its front and rear bumpers in the following locations. The front bumper would have a label attached to the bumper assembly in the area where it would not be visible if a front license plate was attached to the bumper. The rear bumper would have a label attached to the rear bumper in an area that will be covered by a plastic snap-in molding. This molding must be removed to remove the rear bumper from the vehicle. You asked whether these planned locations would satisfy the requirement of S541.5(d)(1)(iii) that the labels be 'visible without further disassembly once the part has been removed from the vehicle.' It is NHTSA's opinion that the locations specified for marking bumpers in your letter would satisfy the requirement of S541.5(d)(1)(iii).; Your planned location for labeling the front bumpers is in an are where those labels will be visible at the time the cars arrive at the dealer and will remain visible unless and until a front license plate is installed on the car. NHTSA must thus determine whether the possible need to remove a front license plate would result in labels in this location failing to satisfy the requirement that labels be placed so that they will be 'visible without further disassembly once the part has been removed from the vehicle.' It appears not to be necessary to remove the front license plate in order to remove the front bumper from your vehicles. Hence, one might conclude that such location would not satisfy this requirement.; However, the intent underlying this requirement was clearly set fort in the rulemaking proceeding that established Part 541. The preamble to the notice of proposed rulemaking contained the following sentence: 'Both commenters agreed, however, that NHTSA's regulations should ensure that investigators will not have to conduct any *additional* dismantling (over and above what chop shops, parts dealers, or thieves have ordinarily done) to locate the identifier on parts removed from a vehicle.' (Emphasis in original) 50 FR 19731, May 10, 1985. NHTSA believes that license plates are routinely removed from front bumpers by legitimate parts dealers prior to reselling the bumper. Law enforcement groups have assured us that license plates are removed from stolen bumpers, so that the stolen part cannot be traced to its rightful owner. In these circumstances, the agency has no reason to believe that labels for front bumpers that are covered by the front license plate will require investigators to conduct additional dismantling of the front bumpers. Accordingly, we conclude that labels on front bumpers that are clearly visible when the front license plate is removed satisfy the requirement that those labels be 'visible without further disassembly once the part has been removed from the vehicle.'; With respect to the rear bumpers, the situation is simpler. Accordin to your letter, the plastic molding covering the labels *must* be removed to remove the bumper from the vehicle. Thus, the label would be visible without further disassembly once the bumper has been removed from the vehicle. As such, it would satisfy the requirement of S541.5(d)(1)(iii).; If you have any further questions or need more information on thi subject, please do not hesitate to contact me.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4410OpenWilliam J. Maloney, Esq., Rode & Qualey, 295 Madison Avenue, New York, NY 10017; William J. Maloney Esq. Rode & Qualey 295 Madison Avenue New York NY 10017; Dear Mr. Maloney: This responds to your letter seeking an interpretation of Standard No 211, *Wheel Nuts, Wheel Discs, and Hub Caps* (49 CFR S571.211). Section S3 of this standard states, 'Wheel nuts, hub caps, and wheel discs for use on passenger cars and multipurpose passenger vehicles shall not incorporate winged projections.' You asked whether these components are permitted to incorporate winged projections if the winged projections do not extend beyond the wheel rim when mounted. As we have stated several times in the past, winged projects are prohibited on wheel nuts, hub caps, and wheel discs, *regardless* of whether the winged projections are recessed below the level of the wheel rim.; This issue was first raised in response to the notice of propose rulemaking for the initial Federal motor vehicle safety standards, published on December 3, 1966 (31 FR 15212). That notice proposed language for Standard No. 211 that was identical with that which was adopted. In response to this proposal, a manufacture commented that it did not consider its winged wheel nuts a hazard to pedestrians or cyclists, because the winged wheel nuts did not extend beyond the outermost projection of the wheel rim. The final rule published on February 3, 1967 (32 FR 2408) did not make any change to the proposed language in response to this comment.; In a report issued on March 17, 1967 on the development of the initia Federal motor vehicle safety standards, the agency summarized the comments on the proposed standards and its response to those comments. I have enclosed a copy of the summary of Standard No. 211 for your information. As you will see, this summary recited the manufacturer's comments on winged projections that were located inside the outermost projection of the wheel rim and tire. The summary goes on to say, 'The Agency did not agree, and retained the prohibition of even such recess winged structures lest the clothes of child pedestrians and others be caught.' Hence, arguments about the unobjectionability of *recessed* winged projections were considered and rejected by the agency more than twenty years ago.; We have repeated this position in our subsequent interpretations o Standard No. 211. I have enclosed copies of an August 26, 1970 letter to Mr. James S. Campbell ('...any winged projection is prohibited, even if recessed.'), a November 25, 1975 letter to Mr. James J. Schardt ('Our interpretation of Standard No. 211 is that S3 prohibits winged projections that do not extend beyond the outer edge of the tire or rim, as well as those that do.'), and a January 31, 1980 letter to Mr. Doug Smith ('...the standard prohibits the use of all winged projections regardless of the extent to which they extend from a rim.').; After examining the history of this requirement, we have concluded tha the language of the standard itself draws no distinction between winged projections that do not extend beyond the outer edge of the rim and those that do. Instead, section S3 provides that the identified components 'shall *not* incorporate winged projections.' We reaffirm our previous interpretations, which concluded that this language prohibits *all* winged projections on the identified components, not just those that extend beyond the outer edge of the rim.; You concluded by asking me to state that recessed winged projection may by imported, offered for sale, and sold in the United States. I cannot make such a statement. Since those winged projections are prohibited by Standard No. 211, section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1397(a)(1)(A)) makes it illegal to 'manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States' any wheel discs, wheel nuts, or hub caps that incorporate winged projections. Section 109 of the Safety Act (15 U.S.C. 1398) specifies a civil penalty of up to $1000 for each violation of section 108(a), and we would consider each sale of wheel discs, wheel nuts, or hub caps with winged projections to be a separate violation of section 108(a).; If you have any further questions on this matter, please feel free t contact Mr. Kratzke at this address or by telephone at (202) 366-2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1612OpenMr. Mike A. Read,Design Engineer, Spring Division,Borg-Warner Corporation,700 South 25th Avenue,Bellwood, Illinois 60104; Mr. Mike A. Read Design Engineer Spring Division Borg-Warner Corporation 700 South 25th Avenue Bellwood Illinois 60104; Dear Mr. Read:#This is in reply to your letter of September 13, 1974 pointing out discrepancies between our two standards covering motor vehicle hydraulic brake systems, Nos. 105-75 and 122.#We intend to amend Standard No. 122 in the near future to be consistent with Standard No. 105-75.This will clarify that the same interpretation will be given master cylinder reservoir and capacity requirements.#Thank you for pointing this out to us. #Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam0900OpenMr. Robert I. Yeoman, Plaskolite, Inc., P.O. Box 1497, 1770 Joyce Avenue, Columbus, OH 43216; Mr. Robert I. Yeoman Plaskolite Inc. P.O. Box 1497 1770 Joyce Avenue Columbus OH 43216; Dear Mr. Yeoman: This is in reply to your letter of October 16, 1972, requesting a DO number for safety glazing materials. You indicate that your understanding is that such a number is required in order to obtain approval under ANS Z26.1-1966.; Under Federal Standards applicable to motor vehicle glazing material (Motor Vehicle Safety Standard No. 205, 49 CFR 571.205) the manufacturer of the material is responsible for certifying the conformity of the material to the standard. The NHTSA does not provide prior approvals, but tests materials it purchases on the open market. Motor Vehicle Safety Standard 205 incorporates by reference, with some exceptions, ANS Standard Z26.1-1966. The DOT number to which you refer has been an optional method by which prime glazing material manufacturers certify their materials. Beginning April 1, 1973, prime glazing material manufacturers will be required to use the symbol DOT and a code number in certifying their materials. Plaskolite Incorporated is hereby assigned code number 98. The method for certifying is more fully explained in the Standard.; While the NHTSA does not require prior approvals of glazing materials such approvals are required by certain States. You may obtain information regarding these approvals from the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3785OpenMr. Richard McCarl, American Isuzu Motors Inc., Whittier, CA 90601; Mr. Richard McCarl American Isuzu Motors Inc. Whittier CA 90601; Dear Mr. McCarl: This responds to your November 23, 1983 letter regarding th applicability of motor vehicle certification requirements to a new vehicle to be imported by Isuzu Motors. This small utility vehicle would be certified as a truck. Isuzu dealers will offer for the vehicle an optional rear seat which can be installed by simply bolting it to the vehicle. The basic vehicle already has the necessary mountings for the seat, so the seat installation can apparently be readily accomplished. You have asked whether installation of these seats constitutes 'alteration' of the vehicle by the dealer, requiring the addition of an alterer's label in accordance with 49 CFR 567.7.; Based on your description of the seat installation process, it appear that dealers installing the seats would be subject to 49 CFR 567.6, 'Requirements for persons who do not alter certified vehicles or do so with readily attachable components.' Since the seats appear to be 'readily attachable components,' section 567.6 requires dealers to leave the manufacturer's certification label in place and requires no alterer's label to be added.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, 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.