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: aiam2859OpenMr. Richard H. Attenhofer, Manager, Tire Technical Relations, Dunlop Tire Company, Box 1109, Buffalo, New York 14240; Mr. Richard H. Attenhofer Manager Tire Technical Relations Dunlop Tire Company Box 1109 Buffalo New York 14240; Dear Mr. Attenhofer: This responds to your August 2, 1978, letter noting two standards o the National Highway Traffic Safety Administration that you consider to be in conflict with Standard No. 119, *new Pneumatic Tires for Vehicles Other Than Passenger Cars,* in their requirements for the size of the molding of the word 'regroovable'.; Standard No. 119 specifies all of the labeling of tires for moto vehicles other than passenger cars. The size of that required labeling is set at not less than .078 inches. This size provision applies generally to all of the various information required to be labeled on a tire. The information label on the tire includes that tire identification number and word 'regroovable' if appropriate. Both of these requirements, however, are subjects of their own regulations. The tire identification number is specifically regulated by Part 574 and regroovable tires are regulated by part 569. Each of these Parts further specifies the size designation of the information that it requires. For example, Part 569 specifically requires the word 'regroovable' to be in letters .38 to .50 inches in height.; The two standards do not conflict. The size requirement in Part 56 falls within the acceptable size levels of Standard No. 119. Part 569 merely further restricts the size of the word 'regroovable' beyond that specified in Standard No. 119. Accordingly, the two are consistent. To understand both requirements, apply the general size requirements of Standard No. 119 to all information that is not otherwise regulated elsewhere. For information specifically regulated elsewhere, apply the size criteria specified in the applicable regulation.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0864OpenMr. W. G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley, GA, 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of August 10, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to shower curtains in the motor homes you manufacture. You ask whether the NHTSA would consider it 'acceptable' for you not to supply a shower curtain with the motor homes you equip with showers.; You have the right, under the Vehicle Safety Act, to sell a motor hom with equipment omitted, as long as the equipment is not required by a safety standard or necessary for the safe functioning of the vehicle. Naturally, we would prefer that you fully equip the vehicle with a conforming curtain, but we cannot force you to do so.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4574OpenMr. Joseph F. Mikoll Vice President Transportation Equipment Corp. 712 North Van Buren Way Hopkins, MN 55343; Mr. Joseph F. Mikoll Vice President Transportation Equipment Corp. 712 North Van Buren Way Hopkins MN 55343; "Dear Mr. Mikoll: This responds to your letter asking for clarificatio of my November 3, 1988 letter to you. In a letter dated August 11, 1988, you requested my opinion concerning the acceptability of installing a new product you are developing (a 'safety bar') in school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less instead of installing safety belts in those vehicles. The 'safety bar' consists, in part, of two curved metal poles in planes that are parallel to the longitudinal centerline of the bus. The curved metal poles are attached to the outside of the seat in front of the seat whose occupants are to be protected by the 'safety bar.' These curved poles are joined by three cross or transverse members that are parallel to the seat and are covered with padding. The padded surface extends over the entire width of the seat whose occupants it is intended to protect. When an occupant wishes to be seated, he or she must lift the safety bar and then sit down and allow the safety bar to lower so that it rests on the occupant's thighs. Additionally, a special strap resembling a very long seat belt assembly must be fastened around the safety bar to hold it in position in the event of a crash. In my November 3, 1988 reply to your letter, I explained that the crash protection requirements for school buses with a GVWR of 10,000 pounds or less are set forth in S5(b) of Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222). That section requires that each designated seating position be equipped with either safety belts or a protection system that requires no action by vehicle occupants. Since the 'safety bar' is not a protection system that requires no action by vehicle occupants, my November 3 letter explained that the 'safety bar' could not be installed in place of safety belts in small school buses, i.e., school buses with a GVWR of 10,000 pounds or less. My November 3, 1988 letter also explained that safety bars could be installed in small school buses in addition to safety belts, if the safety bars do not destroy the ability of the required safety belts to comply with the requirements of our safety standards. I also stated that a manufacturer that installed these safety bars in small school buses would have to certify that the bus in which the safety bars were installed complied with the school bus emergency exit requirements of Standard No. 217, Bus Window Retention and Release (49 CFR /571.217) and with the impact zone requirements specified in S5.3 of Standard No. 222. You asked whether my November 3, 1988 letter addressed the situation for both large school buses (i.e., those with a GVWR of more than 10,000 pounds) and small school buses, or whether it addressed only small school buses. Your previous letter asked only about small school buses, so my November 3 letter addressed those vehicles only. Assuming this was the case, you asked for 'an opinion that the safety bar does not conflict with any standard for large school bus installation.' I am happy to have this chance to explain our regulations to you. Let me begin by noting that the National Traffic and Motor Vehicle Safety Act requires each manufacturer to certify that each of its motor vehicles or items of motor vehicle equipment complies with all applicable safety standards. Because of this statutory provision, NHTSA has no authority to approve, endorse, or offer assurances of compliance for your product. Instead, any manufacturer that installs your safety bar in its large school buses must itself certify that those large school buses comply with all applicable safety standards when the safety bars are installed. The occupant crash protection requirements for large school buses are set forth in Standard No. 222. No provision of Standard No. 222 expressly prohibits the installation of 'safety bars' in large school buses. Hence, 'safety bars' can be installed in a large school bus, provided that the manufacturer of the bus certifies that it complies with all applicable requirements set forth in the safety standards with the safety bars installed. These requirements include the emergency exit requirements specified in Standard No. 217, all of the requirements of Standard No. 222, and the flammability resistance requirements of Standard No. 302, Flammability of Interior Materials (49 CFR /571.302). Please let me know if you have any further questions or need additional information. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam1326OpenMr. W. G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA; Mr. W. G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA; Dear Mr. Milby: This is in reply to your letter of October 23, 1973, concerning th installation of seat belts and seat belt anchorages for passenger seats in school buses. The belts would be used to assist handicapped passengers in remaining seated while the bus is in motion.; Motor Vehicle Safety Standard No. 210, which regulates the strength o seat belt anchorages, applies only to the driver's seat in a bus. The passengers' seats are not covered by the standard. As a result, an anchorage provided at a passenger seat in a bus does not have to meet the requirements of Standard No. 210.; If you plan to acquire conventional automotive seat belts for use i the buses, you will find that all belts must be certified to Standard No. 209, *Seat belt assemblies*, by the belt manufacturer. Because of this the belt should not be a problem for you.; We would encourage you to construct the belt anchorages so that the have the capacity to protect the passengers in sudden stops or crashes, as well as to keep them in the seat during normal service. However, the anchorage standard does not have to be met for these seats and will not be an impediment to fulfilling your customers' orders for anchorage-equipped seats.; Yours truly, Richard B. Dyson, Assistant Chief Counsel. |
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ID: aiam4124OpenMr. Bob Carlson, 8305 29th Avenue, N.W., Seattle, WA 98117; Mr. Bob Carlson 8305 29th Avenue N.W. Seattle WA 98117; Dear Mr. Carlson: This responds to your January 23, 1986 letter inquiring about Federa motor vehicle safety standards applicable to your projected sale of aftermarket windshield wiper systems for trucks.; Under the National Traffic and Motor Vehicle Safety Act, this agenc has issued Federal Motor Vehicle Safety Standard No. 104, *Windshield Wiping and Washing Systems*, applicable to new motor vehicles. As you note, this standard applies to trucks, as well as other types of vehicles. In your letter, you ask which performance requirements apply to wiping systems for trucks.; Under S4. *Requirements*, new trucks are required to have power-driven windshield wiping system that meets the requirements of S4.1.1. The frequency requirements in S4.1.1 apply to trucks, but the wiped area requirements of S4.1.2 apply only to passenger cars. Trucks must also have a windshield washing system that meets the requirements of SAE Recommended Practice J942, November 1965, except that the 'effective wipe pattern' is considered to be 'the pattern designed by the manufacturer for the windshield wiping system on the exterior surface of the windshield glazing.' Therefore, the vehicle manufacturer establishes the wipe pattern of the system.; If a new truck equipped with your wiper system did not comply wit Standard No. 104 due to some aspect of that system, the sale of that truck to the public would be a violation of the prohibition in section 108(a)(1)(A) of the Act against the sale of noncomplying vehicles.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4333OpenMr. C.M. Mehta, Manager - Exports, Autolite (India) Limited, 469, Road No. 9, Vishwakarma Industrial Area, Jaipur, 302013 India; Mr. C.M. Mehta Manager - Exports Autolite (India) Limited 469 Road No. 9 Vishwakarma Industrial Area Jaipur 302013 India; Dear Mr. Mehta: This is in reply to your letter of February 23, 1987, to the Departmen of Transportation. You mentioned an earlier letter dated January 9, 1987, enclosing a copy of your product catalogue, but I regret to say that this Office has not received it.; As a producer of motor vehicle lighting equipment, you have asked fo answers to the following questions:; >>>'1. Details of DOT/SAE approval required in marketing our Headlam Units 7 inch, 5 3/4 inch (Round) and Rectangular small and large'.<<<; In the United States no 'approval' is required to import the headlamp that you mention. However, the manufacturer must assure itself that the headlamp comply with the requirements of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* (essentially those of the SAE for round and rectangular sealed beam headlamps), and certify each one as meeting all applicable Federal motor vehicle safety standards. This certification is a DOT symbol on the headlamp lens.; >>>2. Can we market those lamps as referred in Para. No. 1 fitted wit 9004, 9005 and 9006 Bulbs. If There is any specifications/technical details available with you, please send us a copy.'<<<; The headlamps discussed in paragraph 1 are sizes traditionall associated with sealed beam headlamps, rather than with replaceable bulbs such as the DOT HB1 (9004), HB3 (9005), and HB4 (9006). However, it is permissible to produce headlamps in these sizes, which incorporate replaceable light sources that are specified by Standard No. 108. However, such headlamps must meet all the requirements of the standard applicable to replaceable bulb headlamps. I enclose(sic) a copy of Standard No. 108 for your information.; >>>'3. We understand that the use 9004, 9005, 9006 bulbs are permitte on Headlamps with Lens and Reflectors made of Plastic. Kindly advise, if we can use these Reflectors made of metal?'<<<; Yes, a headlamp may have a reflector of either plastic or metal. >>>'4. Details of approval required for High Beam Driving Lamps to b use for off- road vehicle.'<<<; >>>'5. The details of specfications (sic) for Driving Lamps to be use on Cars, Trucks, etc.'<<<; Standard No. 108 does not require vehicles to be equipped with drivin lamps and it establishes no requirement for them. If there are any specifications or approvals required, they are those of the individual States in which these lamps would be sold and used. For further information on State requirements you should write: American Association of Motor Vehicle Administrators (AAMVA), 1201 connecticut Avenue, N.W., Washington, D.C.; It is the position of this Department that any headlamp unit which i capable of replacing a passenger car headlamp must meet the applicable requirements of Standard No. 108, even if it may also be used on off-road vehicles.; You have also asked for copies of 'SAE F-80 Front Fog Lamps' an SAE-J-79 Motor Cycle Headlamps'. We are not familiar with these materials and advise you to write: Society of Automotive Engineers Inc., 400 commonwealth Drive, Warrendale, Pa. 15096. As for 'Specification for Driving Lamps Using H3 Bulb', this appears to be a European specification unknown to us, as the H3 bulb is one that is not widely used in the United States.; The following is a listing of those requirements that must be complete before shipments begin. You must:; 1. Appoint an agent for service of process in accordance with Title 49 Code of Federal Regulations, Part 551 (49 CFR 551).; 2. Provide information as specified in 49 CFR 566, 'Manufacture Identification.'; If you determine in good faith that any lamp manufactured by you doe not conform with Standard No. 108 or contains a safety-related defect, section 151 (15 USC 1411) of the Act requires that you furnish notification to the Secretary and to owners in accordance with section 153 (15 USC 1413) and to remedy without cost the failure to conform or defect in accordance with 154 (15 USC 1414). Details are contained in 49 CFR 573, 576 and 579.; We are enclosing the following pertinent publications: 1. The Act 2. 19 CFR 12.80, 'Regulations for Motor Vehicle Importation' 3. 49 CFR 551, 'Procedure Rules' 4. 49 CFR 573, 'Defect and Noncompliance Reports' 5. 49 CFR 576, 'Record Retention' 6. 49 CFR 579, 'Defects and Noncompliance Responsibility' 7. Information for New Manufacturers of Motor Vehicle and Motor Vehicl Equipment; If we may be of further assistance, please let us know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1131OpenMr. Lawrence D. Beshore, Femco, Inc., P.O. Box 687, 500 North Bypass, McPherson, KS 67460; Mr. Lawrence D. Beshore Femco Inc. P.O. Box 687 500 North Bypass McPherson KS 67460; Dear Mr. Beshore: This is in reply to your letter of April 16, 1973, inquiring whethe any Federal laws apply to your building and installation of a man-lift (pictures of which you enclose) in a completed pick-up truck. You state you understand that if the man-lift is installed on a completed vehicle, you are not considered the final-stage manufacturer.; Based on the information you have provided us, we believe you interpretation to be correct. It does not appear that you have altered the pick-up truck in a way that would make your company responsible for conformity with Federal safety standards or regulations.; The NHTSA has proposed certain requirements for vehicle alterers (cop enclosed). These requirements would very likely apply to you, when effective, if the addition of the man-lift occurs before the purchase of the pick-up truck for a purpose other than resale.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4763OpenSusan Birenbaum, Esq. Acting General Counsel United States Consumer Product Safety Commission Washington, DC 20207; Susan Birenbaum Esq. Acting General Counsel United States Consumer Product Safety Commission Washington DC 20207; "Dear Ms. Birenbaum: This responds to your letter asking whether product would be considered an item of 'motor vehicle equipment,' within the meaning of the National Traffic and Motor Vehicle Safety Act (the Safety Act). I apologize for the delay in this response. The product in question is called 'kwik kool' and is intended to improve the performance of motor vehicles' air conditioning systems. The packaging and labeling for this product that were enclosed with your letter indicate that 'kwik kool' is intended exclusively for use with a motor vehicle and by ordinary users of motor vehicles. We conclude that this product is 'motor vehicle equipment.' As you are aware, section 102(4) of the Safety Act, 15 U.S.C. 1391(4), defines, in relevant part, the term 'motor vehicle equipment' as: any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle . . . 'Kwik kool' is an aerosol component that appears to be manufactured and sold for the improvement of motor vehicle air conditioning systems. As such, it is 'motor vehicle equipment' within the meaning of the Safety Act. You noted in your letter that the Consumer Product Safety Act excludes items of 'motor vehicle equipment' from those 'consumer products' subject to the authority of the Consumer Product Safety Commission under that Act. This agency, on the other hand, has express statutory authority to investigate allegations that an item of motor vehicle equipment contains a defect related to motor vehicle safety. Pursuant to the request in your letter, we have forwarded the complaint enclosed with your letter to our Office of Defects Investigation. If you have any questions or would like some additional information about this topic, please feel free to contact Mr. Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1561OpenGerhard P. Riechel, Esq.,Volkswagen of America, Inc.,Englewood Cliffs, New jersey 07632; Gerhard P. Riechel Esq. Volkswagen of America Inc. Englewood Cliffs New jersey 07632; Dear Mr. Riechel:#This responds to your July 1, 1974, letter concernin Volkswagen's petition to exempt its pre-bent vacuum hose from some requirements of STandard No. 106-74, *Brake hoses*. You requested that we confirm that an in-line vacuum check valve is not regulated under the standard, and that the standard's use of 'light duty' and 'heavy duty' vacuum hose terminology corresponds to the use of those terms in the SAE Standard J1403a. We respond to the Volkswagen petition in a letter of July 2, 1974, to Mr. J.W. Kennebeck of Volkswagen.#You are correct in your conclusion that an in-line check valve like the value in Volkswagen's pre- bent vacuum line is not a brake hose fitting subject to the requirements of Standard No. 106-74. #The National Highway Traffic Safety Administration tends to make the same distinction between light and heavy duty vacuum hose types as is made by the SAE Standard J1403a, which is based in the thickness of the hose wall. In addition to those sizes listed by the SAE we have added 9/32-inch hose.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam4299OpenMs. Paula J. Redford, Manager, Free Enterprise Company, 5417 Paseo, Kansas City, MO 64110; Ms. Paula J. Redford Manager Free Enterprise Company 5417 Paseo Kansas City MO 64110; Dear Ms. Redford: This responds to your March 12, 1976, request for a listing of Federa motor vehicle safety standards that apply to the manufacture of a fiberglass hardtop for installation on a Jeep. I am assuming that this top is an aftermarket item and is not incorporated by the Jeep Corporation as the vehicle roof of its product.; The only Federal motor vehicle safety standard applicable to this ite of aftermarket motor vehicle equipment is Standard No. 205, *Glazing Materials*, 49 CFR 571.205. Standard No. 205 specifies requirements for glazing materials used in motor vehicles and motor vehicle equipment, including a vehicle top such as you describe. Any glazing material used in the construction of your Jeep top must be certified as being in compliance with Standard No. 205, even though the top itself does not have to be certified. Generally, the prime glazing manufacturer or the glazing fabricator certifies the glazing, so your main concern as manufacturer of the Jeep top is to make certain that you use glazing that has been certified as being in compliance with the standard. If you obtain sheets of glazing from a prime glazing manufacturer and fabricate or mold the glazing yourself, you must mark and certify the glazing as specified in paragraphs S6.4 and S6.5 of Standard No. 205. A copy of the standard is enclosed for your information.; Sincerely, Stephen P. Wood, Assistant Chief Counsel |
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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.