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
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ID: aiam5387OpenMr. Ivan L. Bost Director of Engineering Comm-Trans 792 S. Cooper St. Memphis, TN 38104; Mr. Ivan L. Bost Director of Engineering Comm-Trans 792 S. Cooper St. Memphis TN 38104; Dear Mr. Bost: This responds to your letter of April 6, 1994 requesting information on the type of seat belt required at the rear outboard seating positions in passenger vans with a gross vehicle weight rating (GVWR) greater than 8,500 pounds but less than 10,000 pounds. Your letter states that these vehicle have a capacity for 10 to 15 persons, including the driver. Before explaining the safety belt installation requirements for these vehicles, I would like to clarify two of the terms that I will be using. A 'rear designated seating position' is any seating position to the rear of the front seat(s). An 'outboard designated seating position' is a designated seating position within 12 inches of the side of the vehicle. However, the latter term does not include any designated seating position adjacent to a walkway that is located between the seat and the side of the vehicle and is designed to allow access to more rearward seating positions. Thus, with respect to a passenger van having a two person bench seat behind the front seats, the latter term typically does not include the rightmost of those two positions. The safety belt installation requirements for all vehicle types are set forth in Standard No. 208. Passenger vans with a seating capacity of 10 persons or less would be considered multipurpose passenger vehicles (MPVs) under NHTSA's regulations. Section S4.2.4 of Standard No. 208 requires the installation of an integral Type 2 (lap/shoulder) seat belt assembly at each forward-facing rear outboard designated seating position in an MPV, other than a motor home, manufactured on or after September 1, 1991, with a GVWR of 10,000 pounds or less. A Type 1 (lap) or a Type 2 seat belt assembly is required at all other rear designated seating positions. Sections S4.2.4.2 and S4.2.4.3 of Standard No. 208 allow the Type 2 seat belt assembly to have a detachable upper torso portion if the seating position can be adjusted to a direction other than forward-facing or if the seat is designed to be easily removed and replaced. Vans with a seating capacity of more than 10 persons would be considered buses under NHTSA's regulations. Section S4.4.3.2 of Standard No. 208 requires the installation of an integral Type 2 seat belt assembly at each forward-facing rear outboard designated seating position in a bus, other than a school bus, manufactured on or after September 1, 1991, with a GVWR of 10,000 pounds or less. A Type 1 or a Type 2 seat belt assembly is required at all other rear designated seating positions. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2442OpenMr. Charles V. Mulhern, Supervisor, School Bus Inspection, The Commonwealth of Massachusetts, Registry of Motor Vehicle, 100 Nashua Street, Boston, MA 02114; Mr. Charles V. Mulhern Supervisor School Bus Inspection The Commonwealth of Massachusetts Registry of Motor Vehicle 100 Nashua Street Boston MA 02114; Dear Mr. Mulhern: This responds to your June 29, 1976, question whether specific aspect of Massachusett's (sic) requirements for the construction, location, and size of fuel tanks in school buses would be preempted by the Federal requirements for school bus fuel system integrity that become effective April 1, 1977 (Standard No. 301-75, *Fuel System Integrity*). I regret that we have not responded to your questions sooner.; Section 103(d) of the National Traffic and Motor Vehicle Safety Ac (the Act) 15 U.S.C. S1392(d) does preempt State motor vehicle safety requirements of general applicability that are not identical to a Federal standard applicable to the same aspect of performance. In the cases you cite, it appears that the fuel tank seams and the location of the tank are items of design that are identical to the aspects of performance (integrity of the fuel system) regulated by the barrier impact test of Standard No. 301-75. It is the opinion of the NHTSA that these aspects of fuel system construction are preempted by Standard No. 301-75, effective April 1, 1977. In developing the performance requirements of the standard, the agency did not intend to regulate fuel tank size.; The second sentence of S103(d) clarifies that the limitation of safet regulations of general applicability does not prevent governmental entities from specifying additional safety features in vehicles purchased for their own use. Thus the Commonwealth of Massachusetts or its political subdivisions could specify additional fuel system features in the case of public school buses. The second sentence does not, however, permit those governmental entities to specify safety features that prevent the vehicle or equipment from complying with the applicable safety standards. A school bus manufacturer must continue to comply with all applicable standards.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0185OpenMr. Frank Stewart, Sales Representative, La France, Precision Casting Company, 1462 South Velacco Street, Los Angeles, CA 90023; Mr. Frank Stewart Sales Representative La France Precision Casting Company 1462 South Velacco Street Los Angeles CA 90023; Dear Mr. Stewart: This is in reply to your letter of February 11, 1969, to Mr. Lowell K Bredwell. Your letter was misplaced and did not reach me until now. I apologize for the delay.; You submitted a label, asking whether it would comply with th Certification Regulations for motor vehicles, with particular reference to campers, trailers and motor homes. The current Certification regulations for motor vehicles, published July 9, 1969 (34 F.R. 11360, copy enclosed), require that the vehicle label contain, in the order listed:; >>>1. name of manufacturer, 2. month and year during which manufacture of the vehicle is completed, 3. the following statement-- 'THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFET STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE,'; 4. vehicle identification number, 5. (for multipurpose passenger vehicles only, as defined in 49 CFR S 371.3) the words 'TYPE MULTIPURPOSE PASSENGER VEHICLE.'<<<; You should note that the above requirements only apply to complet vehicles, which include motor homes and trailers, and not to items of equipment, such as campers, which will be only part of a vehicle. No regulations have been issued as yet for the certification of equipment. Under the National Traffic and Motor Vehicle Safety Act, equipment that either is covered by a standard or, as in the case of most campers, contains other equipment such as glazing that is covered by a standard, must carry a label or tag certifying that the equipment conforms to applicable Federal motor vehicle safety standards.; The label that you submitted differs from the above requirements i several respects. If you or your customers have further questions concerning the certification requirements, we will be please to answer them.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor vehicle Safety Performance Service; |
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ID: aiam2012OpenMr. Leon C. Huneke, Power Controls Division, Midland-Ross Corporation, 490 S. Chestnut Street, Owosso, Michigan 48867; Mr. Leon C. Huneke Power Controls Division Midland-Ross Corporation 490 S. Chestnut Street Owosso Michigan 48867; Dear Mr. Huneke: #Please forgive the delay in responding to your lette of March 24, 1975, to Mr. Schwimmer of this office concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to new brake hose assemblies whose end fittings are partially disassembled by vehicle manufacturers. #You have described brake hose assemblies equipped with permanent end fittings containing sacrificial sleeves. Although the assemblies are complete when delivered by you to a vehicle manufacturer, they must be partially disassembled by him (because they lack swivel fittings) to facilitate installation in vehicles. At this point the vehicle manufacturer does not, as you have suggested, become the hose assembler, assuming responsibility for the assemblies' compliance with the standard and relieving you of responsibility for their continued compliance. He is not, however, required to remove the assembler's band which you have installed pursuant to S5.2..4 (as incorporated by reference in S7.2 and S9.1), although he is free to do so, nor is he required to install his own band, because of the exception in S5.2.2 for assemblies which are assembled and installed by a vehicle manufacturer in his own vehicles. Furthermore, he is not required to replace the sacrificial sleeve in the end fittings, because that sleeve has not been used. #An aftermarket purchaser who disassembles and then reassembles one of your assemblies also relieves you of responsibility for its continued compliance with the standard. He is not required to remove your assembler's band, nor is he required to replace the sacrificial sleeve. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam3253OpenMr. Don Gerken, Product Engineer, Cosco Home Products, 2525 State Street, Columbus, IN 47201; Mr. Don Gerken Product Engineer Cosco Home Products 2525 State Street Columbus IN 47201; Dear Mr. Gerken: This responds to your letter of March 27, 1980, to Mr. Stephen Oesch o my staff concerning Standard No. 213, *Child Restraint Systems*. You asked whether the labels and installation diagrams required by the standard must comply with Standard No. 302, *Flammability of Interior Materials*. In addition, you asked whether an upholstery tag, required by State law, attached to the seat must comply with Standard No. 302.; Section 5.7 of Standard No. 213 requires 'each material used in a chil restraint system' to conform to the performance requirements of Standard No. 302. Because the label, installation diagram and tag materials are affixed to the child restraint, they would have to comply with Standard No. 302.; Section 4.2.2 of Standard No. 302 provides that 'any material tha adheres to other materials at every point of contact' shall meet the performance requirements of the standard 'when tested as a composite with the other materials.' Thus, if the label, diagram and tag are affixed to the plastic shell of the restraint so that they adhere to the shell at every point of contact, they would be tested with the shell. If the label, diagram and tag do not adhere at every point of contact, section 4.2.1 requires them to meet the performance requirement of the standard when tested separately.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4596OpenRobert C. Craig Quality Control Manager Cosco, Inc. 2525 State Street Columbus, IN 47201; Robert C. Craig Quality Control Manager Cosco Inc. 2525 State Street Columbus IN 47201; "Dear Mr. Craig: This responds to your February 3, 1989 letter to Mr George Parker, our Associate Administrator for Enforcement, seeking an interpretation of Standard 213, Child Restraint Systems (49 CFR /571.213). Specifically, paragraph S5.5 of that standard requires each child restraint system to be permanently labeled with certain specified information. One of the items of information required to be permanently labeled on the child restraint is the manufacturer's recommendations for the maximum weight and height of children who can safely occupy the system, and those weight and height recommendations must be expressed in English units (pounds and inches). Your letter stated that your company would like to express its maximum weight and height recommendations in both English units and equivalent metric units (kilograms and meters), and asked whether this would be permitted by Standard 213. As long as the information is presented in a manner that is not likely to cause confusion, Standard 213 does not prohibit manufacturers from expressing required information in equivalent English and metric units. For each of the labeling requirements set forth in NHTSA's regulations, this agency has consistently taken the position that manufacturers may present information in addition to the required information, provided that the additional information is presented in a manner that is not likely to confuse the user. Moreover, the agency has already concluded that passenger car tires may be labeled with required information expressed in equivalent English and metric units. See the enclosed April 5, 1979 letter to Mr. Michael Petler. We would apply the same reasoning in interpreting the labeling requirements of Standard 213. That is, Standard 213 permits manufacturers to present the required information in both English and metric units, provided that the information is presented in a manner that is not likely to confuse persons using the child restraint system. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam1794OpenMr. Gerhard P. Riechel, Attorney, Volkswagen of America, Inc., Englewood Cliffs, N.J. 07632; Mr. Gerhard P. Riechel Attorney Volkswagen of America Inc. Englewood Cliffs N.J. 07632; Dear Mr. Riechel: This responds to Volkswagen's December 11, 1974, request for determination that a brake system indicator lamp which activates only upon application of the brake pedal with a control force if 50 pounds or more to signal a 'gross loss of pressure' would meet the requirements of S5.3.3 of Standard no. 105-75, *Hydraulic brake systems*:; >>>S5.3.3 Each indicator lamp activated due to a condition specified i S5.3.1 shall remain activated as long as the condition exists, whenever the ignition (start) switch is in the 'on' ('run') position, whether or not the engine is running.<<<; Your question arises as to the meaning of the phrase in S5.3.3. whic requires that the lamp 'remain activated as long as the condition exists', with reference to the condition described in S5.3.1(a) as 'gross loss of pressure (such as caused by rupture of a brake line but not by a structural failure if a housing that is common to two or more subsystems)'. You point out that a condition involving loss if pressure cannot exist in the absence of pressure, that is, after control force is remove from the brake pedal.; While the NHTSA has always believed that the requirement in questio can best be satisfied by an indicator lamp which remains activated after the loss of pressure has occurred, we agree that the language in question could be more clearly drafted to express this intent.Accordingly, we plan to propose an amendment to the standard to eliminate this ambiguity. The proposed effective date of the amendment will be far enough in the future so that any new design changes required to comply may be effected without undue burden on affected manufacturers.; Because we conclude that the reliance Volkswagen has placed on it alternative reading if S5.3.3 can be justified in this case, we would accept the limited warning offered by the system you describe as satisfying the current requirement in S5.3.3 with regard to S5.3.1(a).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0886OpenMr. Patt Mann, Purchasing and Production, Dalman Enterprises Ltd., P.O. Box 340, Killarney, Manitoba, Canada ROK 1G0; Mr. Patt Mann Purchasing and Production Dalman Enterprises Ltd. P.O. Box 340 Killarney Manitoba Canada ROK 1G0; Dear Mr. Mann: This is in reply to your letter of September 20, 1972, in which yo enclose a brochure describing your feed mover as requested by Mr. Andrew Moss, of my staff.; An examination of the material submitted would seem to indicate tha your classification of the feed mover as farm machinery is valid. We would not, therefore, consider it to be a 'motor vehicle' within the meaning of the National Traffic and Motor Vehicle Safety Act (the Act) based on the information furnished.; In addition to the Act (PL 89-563) and 19 C.F.R. 12.80, that you hav requested, we are also enclosing Part 571 (formerly Part 371) of Title 49 of the Code of Federal Regulations. Of particular interest to you would be the interpretations on mini- bikes that set forth criteria to assist manufacturers in classifying their products insofar as off-road use is concerned.; If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam3603OpenThe Honorable Bob McEwen, House of Representatives, Washington, DC 20515; The Honorable Bob McEwen House of Representatives Washington DC 20515; Dear Mr. McEwen: This responds to your July 8, 1982, letter to Mr. William Dabaghi o the Department enclosing correspondence from your constituent Mr. Donald M. Robinson. Mr. Robinson would like to know whether Federal regulations prohibit him from purchasing a pickup cab and chassis without the body attached. The answer to his question is no.; The National Highway Traffic Safety Administration only requires tha all vehicles be manufactured in compliance with the applicable motor vehicle safety standards. We have no requirement, nor do we know of any other Federal regulation, that would prevent Mr. Robinson from purchasing just the cab and chassis of a vehicle that he desires. When he adds his own utility body to the cab and chassis, he would become the final-stage vehicle manufacturer and would be required to certify that the completed vehicle complies with all applicable Federal safety standards. I am enclosing copies of the regulations pertinent to such an operation.; If I can be of further assistance to you or Mr. Robinson, pleas contact me.; Sincerely, Diane K. Steed, Administrator |
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ID: aiam2911OpenMr. O.R. Schmidt, Conco Inc., Mendota, Illinois 61342; Mr. O.R. Schmidt Conco Inc. Mendota Illinois 61342; Dear Mr. Schmidt: This is in response to your letter of October 27, 1978, concerning th application of Motor Vehicle Safety Standard No. 115 to final stage manufacturers and in confirmation of your telephone conversation with Mr. Schwartz of my office.; The National Highway Traffic Safety Administration has amended Standar No. 115 to shift the responsibility for assigning the vehicle identification number for vehicles manufactured in more than one stage from the final stage manufacturer to the incomplete vehicle manufacturer (copy enclosed). We appreciate your desire to comply fully with the standard but, with this recent amendment, compliance will not be required by final stage manufacturers.; In response to your question concerning the 'model year' to be used fo trailers, the calendar year is acceptable as the 'model year.' Should you have any other questions concerning your responsibility for assigning VINs to the trailers you manufacture, please do not hesitate to contact me.; Sincerely, Joseph J. Levin, Jr., 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.