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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| search results table | |
ID: aiam3225OpenMr. Ronald A. Irvine, Lombard, Gardner, Honsowetz & Brewer, 915 Oak Street, Suite 200, Eugene, Oregon 97401; Mr. Ronald A. Irvine Lombard Gardner Honsowetz & Brewer 915 Oak Street Suite 200 Eugene Oregon 97401; Dear Mr. Irvine: This responds to your letter of February 8, 1980, on behalf of you client, Ideal Welding and Machine Company. That company intends to market a one-piece unit coupling device for the connection of electrical and air-brake lines on tractor- trailers. You ask whether Safety Standard No. 106-74, *Brake Hoses* (49 CFR 571.106-74), would be applicable to this device.; The device described in your letter would not be considered a brak hose assembly or a brake hose end fitting. Rather, according to the drawings enclosed in your letter, a completed brake hose assembly with its own end fitting would be attached to the coupling device, similar to the attachment of a completed assembly to a manifold. Therefore, certification of compliance with Safety Standard No. 106-74 would not be required. This answer dispenses with your remaining questions concerning certification.; Although there are no Federal safety standards applicable to a devic such as you describe, it is a piece of motor vehicle equipment. Under the national traffic and motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381), a manufacturer of motor vehicles or motor vehicle equipment is responsible for any safety related defects that may exist in its products. The manufacturer would have to notify purchasers of any such safety related defects and remedy the defects at its own expense (15 U.S.C. 1411, *et seq.*). Therefore, your client should ascertain through testing or other means that there are no safety problems with its coupling device. Obviously, this is particularly important with any system involving vehicle braking.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2064OpenMr. John H. Elgin, Continental Hydraulic Hose Corp., State Route 182 East, P.O. Box 277, Upper Sandusky, Ohio 43351; Mr. John H. Elgin Continental Hydraulic Hose Corp. State Route 182 East P.O. Box 277 Upper Sandusky Ohio 43351; Dear Mr. Elgin: #This responds to your letter of August 28, 1975 concerning the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #Notice 18 (40 FR 38159, August 27, 1975) amended the standard to facilitate the depletion of inventories of brake hose, end fittings, and assemblies which do not meet certain labeling requirements. With regard to the assembly banding requirement, the amendment merely extends the period during which vehicle manufacturers may use unbanded assemblies which were manufactured before March 1, 1975. There is no change in the requirement that assemblies manufactured on and after that date (other than those assembled and installed by a vehicle manufacturer in vehicles manufactured by him) be labeled with a band as specified in S5.2.4 of the standard. #Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam0059OpenMr. Dick Romney, Sales Manager, Utility Body Company, 901 Gilman Street, Berkeley, CA 94710; Mr. Dick Romney Sales Manager Utility Body Company 901 Gilman Street Berkeley CA 94710; Dear Mr. Romney: This is in response to your letter of March 7, 1968 in which you aske if your company, a manufacturer of truck bodies and truck equipment that installs its product on a chassis furnished by a dealer or the ultimate user, its required to certify that 'the completed package, *including the chassis*, meets Standard 108?'; Under the National Traffic and Motor Vehicle Safety Act of 1966, yo are responsible for completing the vehicle so that it meets applicable standards. This means the vehicle should be assembled in a way that will not disturb existing compliance, and that portion of the vehicle you add must comply with any applicable standard.; This is a duty separate from certification. You are required to certif compliance under section 114 of the Act only if you deliver a completed vehicle to a distributor or dealer, and the certification would be as to all standards applicable to the vehicle, including Standard 108.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam4919OpenMr. Gene Byrd Legris Incorporated 244 Paul Rd. Rochester, N.Y. 14624; Mr. Gene Byrd Legris Incorporated 244 Paul Rd. Rochester N.Y. 14624; Dear Mr. Byrd: This responds to your September 23, 1991 letter askin about the air pressure requirement specified in S7.3.8 of Standard 106, Brake Hoses. Your letter has been referred to my office for reply. Paragraph S7.3.8 states that an air brake hose assembly shall contain air pressure of 200 psi for 5 minutes without loss of more than 5 psi. You ask whether Standard 106 specifies the length of the hose for an assembly tested to S7.3.8. The answer is no, the standard does not have a generic specification for hose length. Instead, each brake hose assembly is required to meet this requirement as manufactured and sold. For purposes of compliance testing, NHTSA obtains a brake hose assembly specimen by purchasing it on the market or directly from the manufacturer. The length of the hose might vary from assembly to assembly, depending on the particular configuration of an assembly. The assembly is tested as sold to obtain performance results that indicate the assembly's real world performance. While S7.3.8 is a performance requirement for assemblies, we understand that your company (an end fitting manufacturer) seeks to ensure that an assembly made with your fitting will not fail to meet S7.3.8 due to the fitting. Since an assembly is tested to S7.3.8 in the configuration in which it is sold, you could test to the requirement using the length of hose that will be used with your fitting. Legris might be able to avoid duplicative tests by conducting 'worst case' testing, such as tests using a fitting with a hose of a length most likely to exhibit an excessive loss of air pressure. Please contact us if you have further questions. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam2434OpenMr. David Gans, President, Gans Tire Co., Inc., 1003 Broadway, Chelsea, MA 02150; Mr. David Gans President Gans Tire Co. Inc. 1003 Broadway Chelsea MA 02150; Dear Mr. Gans: This responds to your October 12, 1976, question whether th manufacturer recordkeeping requirements of S 574.7 of NHTSA regulations (49 CFR Part 574) may be fulfilled by a tire importer by one or both of the following arrangements: the purchaser records of tires manufactured by company B abroad and imported by Gans would be maintained by company A, the purchaser records of tires manufactured by Company B abroad and imported by Gans would be compiled by Gans but maintained by company B.; Either of these arrangements is acceptable under the language of 574.7(b), which provides that '[e]ach tire manufacturer shall record and maintain or have recorded and maintained for him, the information specified. . . .' this language permits the designation of a person other than the tire manufacturer to maintain the required records. Despite this designation, of course, the ultimate responsibility for maintenance would lie with the importer that qualifies as the manufacturer in the situation you describe.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0409OpenDavid J. Humphreys, Esq., Recreational Vehicle Institute, Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; David J. Humphreys Esq. Recreational Vehicle Institute Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: By letter of May 26, 1971, you requested our interpretation of S7.2. of Standard No. 208, Occupant Crash Protection, as it affects motor homes and campers that have a forward control configuration. The section provides that forward control vehicles under 10,000 pounds GVWR manufactured after August 15, 1977, may continue to use seat belt assemblies and need not provide passive protection, but that motor homes and vehicles carrying chassis-mount campers must provide passive protection, at least in head-on impacts. Your question is whether a motor home or chassis-mount camper that is also a forward control vehicle must provide passive protection.; The exemption granted by S7.2.3 to forward control vehicles was base on the difficulties inherent in providing adequate passive protection for such vehicles, regardless of their anticipated use. If a forward control vehicle is manufactured in the form of a motor home or camper, the exemption continues to apply and such a vehicle would not be required to conform to the passive protection requirements of S4.1.2.2.; Please advise us if you have further questions on this subject. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0327OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co. Ltd., Liaison Office in U.S.A., 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 400 County Avenue Secaucus NJ 07094; Re: Interpretation of Motor Vehicle *Safety Standard No. 101*#Dear Mr Mizuno:#In your letter of April 27 you ask whether it is permissible to use the words 'emergency throttle' to identify the hand throttle which Standard No. 101 requires to be identified by the word 'throttle' alone.#In our opinion the use of identifying words or symbols in addition to those required or permitted by Standard No. 101 is permissible as long as the additional words or symbols do not conflict with those required or permitted. We see no such conflict in this instance and confirm your belief 'that this wording can be used.'#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam5125OpenMr. James L. Vasko 527 Old Canyon Road Fremont, CA 94536; Mr. James L. Vasko 527 Old Canyon Road Fremont CA 94536; Dear Mr. Vasko: This is in reply to your letter of January 13, 1993, t the agency in which you call our attention to your invention, the 'Front Brake Light System.' You have informed us that your invention utilizes 'the present turn signal lights . . . to notify the driver and or pedestrian in front of the vehicle that the vehicle is in a braking mode,' and that this is accomplished with only the present circuitry. You wish to 'open a dialogue' with us and will answer any questions we may have. We do have some questions about this invention. As you know, the individual front turn signal lamps also operate in tandem as hazard warning signal lamps, and flash simultaneously when the hazard warning switch is activated. We assume that your invention flashes both front signal lamps when the brake pedal is applied, and request confirmation of our assumption. We would also appreciate knowing how this is accomplished without 'necessity and expense of adding new, complicated apparatus' as you put it. If, on the other hand, the front signal lamps are activated in a steady-burning state, that would be of interest to us. Finally, we would appreciate your views as to how this device would enhance safety, as our concerns have been directed to warning those to the rear of the vehicle that it is about to stop, rather than those to the front. When we have this information, we shall be pleased to provide you with an interpretation as to the relationship of your invention to the statutes and regulations that this agency administers. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3858OpenMr. M. Iwase, Manager, Technical Administration Department, Koito Mfg. Co., Ltd., Shizuoka Works, 500, Kitawaki, Shimuzu-shi, Shitzuoka-ken, Japan; Mr. M. Iwase Manager Technical Administration Department Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimuzu-shi Shitzuoka-ken Japan; Dear Mr. Iwase: This is in reply to your letter of June 21, 1984, to Mr. Driver of thi agency asking for an interpretation of Motor Vehicle Safety Standard No. 108. Mr. Driver has not been an official of this agency for many years, and in the future, your request for interpretation should be addressed to the Chief Counsel, National Highway Traffic Safety Administration.; Your first question is whether Safety Standard No. 108 permits two-headlamp system on motorcycles. The answer is yes. Paragraph S4.1.1.34 specifies the lighting systems permissible on motorcycles. It allows two Type 2D1 or Type 2 (7 in.), or two Type 2B1 or Type 2B headlamps. Under Table IV, if two headlamps are used, they must be disposed symmetrically around the vertical center line. Two non-sealed headlamps meeting the requirements of SAE J584 may also be used, subject to the same mounting restriction. Therefore the system you propose appears acceptable under Standard No. 108.; You have also asked whether the two headlamps may be mounted one ato the other, rather than side by side. While Table IV specifies that a single headlamp must be mounted 'on the vertical centerline', it requires that two headlamps be disposed symmetrically around it. We do not interpret this language as allowing two headlamps to be mounted adjacent to each other on the vertical centerline.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1865OpenMr. A.F. Bleiweiss, P.Eng., Vice President, Dominion Auto, Accessories Limited, 420 Keele Street, Toronto 9, Canada; Mr. A.F. Bleiweiss P.Eng. Vice President Dominion Auto Accessories Limited 420 Keele Street Toronto 9 Canada; Dear Mr. Bleiweiss: This is in response to your letter of March 29, 1975, inquiring as t the permissibility of selling your 'Panamirror' in the United States as aftermarket equipment.; Motor Vehicle Safety Standard No. 111, *Rearview Mirrors*, Provide minimum performance requirements for rearview mirrors on passenger cars and multipurpose passenger vehicles. According to the standard, the inside rearview mirror must furnish the driver with a specified field of view to the rear of substantially unit magnification. Any vehicle manufactured for sale, sold, or introduced into interstate commerce must be equipped with an inside rearview mirror that meets the designated level of performance. It appears that the 'Panamirror' would not satisfy the requirements of the provision, because it is convex in structure and therefore would not provide a view of substantially unit magnification.; If the mirror were installed on a vehicle as aftermarket equipmen (after the vehicle's first purchase for purposes other than resale) in such a way as to render inoperative the inside rearview mirror, section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) as amended (Pub. L. 93-492) would apply where the installation was accomplished by a manufacturer, distributer, dealer, or motor vehicle repair business. The section prohibits the named parties from knowingly rendering inoperative a system installed in compliance with an applicable motor vehicle safety standard.; Yours truly, James C. Schultz, 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.