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: aiam3801OpenMr. Daniel J. Roberson, Comfort-Tour Cycle Products, 8724 116th Avenue, N. E., Kirkland, WA 98033; Mr. Daniel J. Roberson Comfort-Tour Cycle Products 8724 116th Avenue N. E. Kirkland WA 98033; Dear Mr. Roberson: This responds to your letter of November 29, 1983, to the Office o Vehicle Safety Compliance, which was forwarded to this office for reply, concerning the legal requirements regulating the manufacture of motorcycle windshields. You requested information on how you as a manufacturer may obtain certification of your product under the National Traffic and Motor Vehicle Safety Act.; The National Highway Traffic Safety Administration (NHTSA) has th authority to govern the manufacture of new motor vehicles and motor vehicle equipment, and pursuant to the National Traffic and Motor Vehicle Safety Act we have promulgated Federal Motor Vehicle Safety Standard No. 205 (FMVSS No. 205), *Glazing Materials*. FMVSS No. 205 incorporates by reference the American National Standard 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' Z26.6-1966 (ANS Z26). These requirements for glazing used in vehicles and motorcycles, such as minimum levels of light transmittance and abrasion resistance. Copies of FMVSS No. 205 and ANS Z26 have been enclosed in the letter sent to you by the Office of Vehicle Safety Compliance dated January 10, 1984.; You should be aware that the NHTSA does not pass approval on th compliance of any vehicle or equipment with a safety standard before the actual events that underlie certification. Under the Vehicle Safety Act, it is your responsibility as a manufacturer to determine whether your windshields comply with all applicable safety standards and regulations, and to certify your products in accordance with that determination.; There are other regulations and standards affecting manufacturers o motor vehicle equipment of which you should be aware. For instance, manufacturers of motor vehicle equipment have specific responsibilities under the National Traffic and Motor Vehicle Safety Act regarding safety- related defects in their products. Sections 151 *et* *seq.* of the Act a copy of which is enclosed, requires manufacturers to notify purchasers about safety-related defects in their product and to remedy such defects without charge. In addition, Part 556 requires vehicle and equipment manufacturers to provide the agency with certain information concerning themselves and the products they manufacture. I am enclosing an information sheet explaining how you can obtain copies of the agency's regulations. You should refer to the Act and its implementing regulations in order to understand the extent of your responsibilities as a manufacturer of motor vehicle equipment.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1216OpenMr. T. Hiramine, Director, Overseas Department, Takata Kojyo Company, Ltd., No. 10 Mori Bldg. 28, Sakuragawa-Cho Nishikubo Shiba, Minato-Ku, Tokyo, Japan 105; Mr. T. Hiramine Director Overseas Department Takata Kojyo Company Ltd. No. 10 Mori Bldg. 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan 105; Dear Mr. Hiramine: This is in reply to your letter of July 31, 1973, concerning th meaning of the term 75 percent extension' as used in S5.2(j) of Motor Vehicle Safety Standard No. 209.; The 75 percent extension point used in S5.2(j) is intended to represen the belt's extension during its use in a vehicle. The measurement of extension is therefore begun with the webbing retracted as fully as the design of hardware and the size of the retractor permit. It may be that when the belt is retracted to this point a considerable amount of webbing remains outside the retractor, as shown in Figure 2 of your letter. The measurement of extension nonetheless begins at this point, so that 75 percent extension' is 75 percent of the incremental webbing length between this point and the point of fullest extension.; To refer to the figures accompanying your letter, the measuremen technique shown in Figure 2 is correct. That shown in Figure 1, which is based on 75 percent of the total length of the belt, is incorrect.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4014OpenMr. Richard A. Gomes, Supervisor, Technical Support, Room 28, New York City Transit Authority, 25 Jamaica Avenue, Brooklyn, NY 11207; Mr. Richard A. Gomes Supervisor Technical Support Room 28 New York City Transit Authority 25 Jamaica Avenue Brooklyn NY 11207; Dear Mr. Gomes: This responds to your June 21, 1985 letter to this office concernin our requirements for emergency exits under Federal Motor Vehicle Safety Standard No. 217, *Bus Window Retention and Release*. I apologize for the delay in our response.; In a July 15 telephone conversation with Ms. Hom of my staff, yo explained that your question concerns the side rear door on transit buses which is used to unload passengers. The door in question is not intended as an emergency exit, and the buses have the requisite emergency exits in compliance with Standard No. 217 without the need to count the rear exit door. Typically, passengers can exit the bus by pushing handles which open the door, after the driver activates a mechanism located in the driver's compartment. The Transit Authority would like to place another activating mechanism near the rear exit door that can be operated 'in an emergency.' You propose to place the second mechanism in a 'break-away' plastic case and ask whether we have standards specifying requirements for materials used for that purpose.; There are no safety standards setting requirements for the material yo wish to use to cover the secondary release mechanism. Your questions, however, raises the issue of the applicability of Standard No. 217's emergency exit requirements to the rear exit door. This question arises in cases where a label is attached to a door indicating that it is to be used in an emergency.; From your description, it appears that a label would be attached to th mechanism at the rear door instructing passengers how to open the door in an emergency.; We have stated in the past that a door that is not labeled or intende as an emergency exit need not comply with the emergency exit requirements of Standard No. 217. However, if a door were labeled with instructions on how to open the door in case of an emergency, such as 'To Open Door In Emergency Pull Down,' then the label indicates that the door is intended for use as an emergency exit. Such a door must comply with the requirements applicable to emergency doors in Standard No. 217, since the label indicates to the occupants that the door is suitable for use in an emergency and it is likely that riders would use the door as an emergency exit. The National Highway Traffic Safety Administration has uniformly required this of all doors labeled with instructions for use in emergencies.; One purpose of Standard No. 217 is to provide a means of readil accessible emergency egress. While the standard does not explicitly prohibit a plastic case around an emergency exit release mechanism, it is obvious that any type of design or device which would inhibit the release of the mechanism would not be allowed. We urge you to ensure that the release mechanism is easily accessible to bus occupants and that the plastic case does not unnecessarily impede its operation.; Under the National Traffic and Motor Vehicle Safety Act of 1966 (1 U.S.C. 1381 *et seq.), manufacturers of new motor vehicles and motor vehicle equipment must certify that their products conform to all applicable Federal motor vehicle safety standards. Any person selling you a new bus with the rear exit door marked as an emergency exit must ensure that the door meets Standard No. 217's requirements for emergency exits. The Transit Authority may modify its buses by labeling the rear exit door with instructions for use in an emergency after it receives delivery of the vehicles without regard to our safety standards, since our authority under the Vehicle Safety Act does not extend to the use of vehicles by their owners. However, we would urge the Transit Authority to carefully consider the benefits of assuring continued compliance with all applicable motor vehicle safety standards.; I hope this information is helpful. Please contact this office if yo have further questions.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2969OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your February 1, 1979, letter asking whether any la or regulation prohibits the remanufacture of a school bus with an old chassis and a new body when the completed vehicle does not comply with the new safety standards.; As you are aware, the agency has stated many times that such remanufactured vehicle need only comply with the standards in effect on the date of manufacture of the chassis as long as the remanufacturing process conforms to the guidelines established in Part 571.7(e) of our regulations. The agency does not view the remanufacturing problem as significant, because a vehicle's chassis normally wears out before its body. The recycling of noncomplying buses will cease when the supply of used chassis manufactured prior to April 1, 1977, disappears.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0954OpenJohn M. Carter, Esquire, messrs. Carter and Carter, 229 John Street, Clayton, NY 13624; John M. Carter Esquire messrs. Carter and Carter 229 John Street Clayton NY 13624; Dear Mr. Carter: This is in reply to your letter of December 14, 1972, to the Federa Highway Administration on behalf of your client, a snow plow dealer. You ask for verification 'that the addition of a snow plow to a completed truck is considered the addition of a readily attached component and does not require recertification.'; We confirm that a person adding a snow plow to a completed truck is no a final-stage manufacturer who is required by 49 CFR Part 568 to certify compliance of the vehicle with Federal motor vehicle safety standards. He is, however, responsible for insuring that the modified vehicle complies with Standard No. 108 before delivering it to its purchaser.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1646OpenMr. Reno Laforest, After Sales Service Manager, Alouette Recreational Products, Ltd., 3700 St. Patrick Street, Montreal 205, Quebec, Canada; Mr. Reno Laforest After Sales Service Manager Alouette Recreational Products Ltd. 3700 St. Patrick Street Montreal 205 Quebec Canada; Dear Mr. Laforest: This is in reference to your defect notification campaign involvin 1973 and 1974 Alouette AX-125 motorcycles.; Since four different defects are involved, it has been found necessar to assign four different National Highway Traffic Safety Administration (NHTSA) identification numbers. Please refer to these numbers in all future correspondence concerning these campaigns.; Campaign numbers have been assigned as follows: >>>74-0178 - Rear brake pedal lever problem 74-0179 - Kick stand problem 74-0180 - Fuel leakage problem 74-0181 - Rear brake back plate holder lock nut problem<<< Although NHTSA will consider this matter as four campaigns, you ma still combine them in one owner notification letter and in communications with dealers.; The letter which you have sent to the owners of the vehicles which wer sold in the United States of America does not entirely meet the requirements of Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter does not contain the precise wording that is required by Part 577.4(b). Use of the words 'potential' and 'may' also imply that possibly a defect does not exist and should therefore be deleted from this sentence.; Your letter also fails to adequately evaluate the risk to traffi safety as required by Part 577.4(d). If vehicle crash can occur, the letter must state this. Your letter also does not make clear if the repairs will be performed free of charge and also does not give an estimate of the time needed to perform the labor necessary to correct the defect, as required by Part 577.4(e).; It is therefore necessary that you revise the owner notificatio letters and send a copy of the revised letter to this office and all known owners of the affected vehicles. Since you have stated that owners will receive a second notice at the time that parts have become available, the revised notification letter can be sent to owners at that time.; It is also necessary that you submit a Defect Report in accordance wit Part 573 of the regulations. The first Quarterly Reports, as required by Part 573.5, should be submitted before February 5, 1975, for the period ending December 31, 1974.; Copies of Part 573 and Part 577 are enclosed. If you desire furthe information, please contact Messrs. W. Reinhart or James Murray at this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam4444OpenFrank S. Perkin, Esq. Assistant General Counsel The Budd Company Law Department 3l55 West Big Beaver Road Box 260l Troy, Michigan 48084; Frank S. Perkin Esq. Assistant General Counsel The Budd Company Law Department 3l55 West Big Beaver Road Box 260l Troy Michigan 48084; "Dear Mr. Perkin: This responds to your letter expressing concern abou a statement in one of our interpretation letters, which you believe could be read as condoning the practice of rebuilding wheels by processes which include heating and welding. As discussed below, our letter's reference to remanufacturing wheels was made only to serve as an illustrative example and was not intended to address either the safety of such processes or the relevant regulations of other Federal agencies. The interpretation letter in question is one that we sent on September 22, l986, to Steven R. Taylor, responding to a request concerning regulations that apply to manufacturers of reconditioned brake drums. The letter included the following paragraph: NHTSA has in the past considered the issue of what types of operations make a person a manufacturer with respect to retreaded tires and remanufactured wheels. A person who retreads tires is considered to be a manufacturer under the Vehicle Safety Act. The retreading process involves significant manufacturing operations, which do not differ substantially from those of manufacturing new tires. By contrast, a person who remanufactures wheels is not considered to be a manufacturer under the Vehicle Safety Act. The process of remanufacturing wheels consists of such things as straightening, re-welding parts, and repairing cracks by welding. These types of actions are not significant manufacturing operations, but instead are the type of operations commonly performed in repair shops. You stated that all of the things mentioned in our letter, i.e., straightening, re-welding parts and repairing cracks by welding, are specifically prohibited by the OSHA standard applicable to truck wheels, both multi and single piece. You also stated that the 'out of service' criteria adopted by the Bureau of Motor Carrier Safety mandate that a vehicle be placed out of service if welded repairs are found on certain disc wheels. According to your letter, any significant changes made after the manufacture of a steel truck wheel, especially involving bending, heating or welding, carry a significant risk of rendering the wheel unsafe. As is indicated from the context of our September 22, l986 interpretation letter, the reference to remanufacturing wheels was made solely for the purpose of providing an illustrative example and was not intended to address either the safety of such processes or their permissibility or impermissibility under the relevant regulations of other Federal agencies. I would note that NHTSA has long taken the position that remanufactured wheels are considered to be used wheels instead of new wheels for purposes of Federal motor vehicle safety standards. See, for example, our November 28, l973 letter addressed to Mr. L. Clinton Rich and February 7, l983 letter to Mr. H. J. Lindekugel (copies enclosed). Again, however, these letters do not purport to address the safety of remanufacturing wheels or the relevant regulations of other Federal agencies. We appreciate your bringing to our attention your concern about the safety of remanufactured wheels. Copies of this correspondence are being placed in the public docket. Sincerely, Erika Z. Jones Chief Counsel Enclosures"; |
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ID: aiam3381OpenMr. J. Federsel, Product Manager, Teleflex Industrial Inc. 1816 57th Street, Sarasota, FL 33580; Mr. J. Federsel Product Manager Teleflex Industrial Inc. 1816 57th Street Sarasota FL 33580; Dear Mr. Federsel: This responds to your letter of October 8, 1980, in which you requeste an interpretation of Safety Standard No. 127, *Speedometers and Odometers*. You asked us to confirm that your speedometer/odometer meets all the requirements of the rule.; The National Highway Traffic Safety Administration (NHTSA) does no offer prior approval of compliance of any vehicle or equipment design with any safety standard before the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) to determine whether its vehicle or equipment complies with all applicable safety standards and regulations and to certify its vehicle in accordance with that determination.; However, the agency is willing to give an informal opinion concernin whether a vehicle or motor vehicle equipment complies with a particular rule. The speedometer/odometer you sent to us does not comply with the speedometer requirements of Standard No. 127. Section S4.1.4 of that rule requires speedometers to include the number '55' in the mph scale, and to highlight that number in some fashion. There is no '55' on the speedometer you enclose with your letter.; It is not possible to determine upon brief examination whether th odometer meets all the requirements of S4.2.5.2, the encapsulation option. The type of examination necessary to make such a determination is not performed by this agency prior to the manufacturer's certification. It is readily apparent, however, that the odometer you sent to us is in violation of section S4.2.3, as you stated in your letter. The odometer would have to have a sixth wheel or other mechanism to indicate when the number of whole miles or whole kilometers travelled exceeds either 89,999 or 99,999, if the device were to comply with the standard. Note that the effective date of the odometer provisions (sections S4.2 through S5.2) is September 1, 1981. Thus, any odometer that you manufacture prior to that date does not have to comply with the odometer requirements. NHTSA encourages manufacturers to meet these provisions voluntarily, however. The speedometer requirements (section S4.1) of Standard No. 127 are presently in effect, and thus all speedometers you manufacture must currently be in compliance.; We emphasize that the above statements are only the agency's opinio based on the information you have supplied, and that opinion is not binding on you or the agency. It is your duty as the manufacturer to determine whether in fact your product meets the requirements of the standard and to certify that compliance. We hope you find this information helpful. Please contact this office if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0407OpenMr. Louis C. Lundstrom, Director, Automotive Safety Engineering, General Motors Environmental Staff, General Motors Technical Center, Warren, MI, 48090; Mr. Louis C. Lundstrom Director Automotive Safety Engineering General Motors Environmental Staff General Motors Technical Center Warren MI 48090; Dear Mr. Lundstrom: This is in reply to your letter of July 12, 1971, to Mr. Douglas W Toms, Acting Administrator, concerning replacement equipment covered in FMVSS No. 108, effective January 1, 1972.; The requirements for original and replacement equipment in FMVSS No 108 cover those items listed in Tables I and III, namely:>>>; Headlamps, Tail lamps, Stop lamps, License plate lamps, Refle reflectors, Parking lamps, Side marker lamps, Backup lamps, Turn signal lamps,; Turn signal operating units, Turn signal flashers, Vehicular hazar warning signal operating units, Vehicular hazard warning signal flashers, Identification lamps, Clearance lamps, Intermediate side marker lamps, Intermediate reflex reflectors<<<; In addition the requirements cover the following items specified in th text of the standard:>>>; School bus warning lamps, Headlamp beam switching devices, Headlam upper beam indicator lamps, Turn signal pilot indicator lamps, Hazard warning signal pilot indicator lamps, Plastic lenses.<<<; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0226OpenMr. J. C. Eckhold, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold Ford Motor Company The American Road Dearborn MI 48121; This is in reply to your letter of March 19, 1970 with which yo submitted for our examination a sample format for consumer information produced by a computer.; The sample that you submitted does deviate from the requirements of th consumer information regulations in that the required warnings and explanations are placed on a sheet that is separate from the numerical data. The regulations generally require that the information be presented in the form illustrated by the published figures, with the explanatory matter in proximity to the numerical data. I believe that computer printing is flexible enough to allow you to accomplish this.; Sincerely, Douglas W. Toms, Director |
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.