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 |
|---|---|
ID: aiam0164OpenMr. W.J. Sears, Vice President, Rubber Manufacturers Association, 1346 ConnecticutAvenue(sic), N.W., Washington, D.C. 20036; Mr. W.J. Sears Vice President Rubber Manufacturers Association 1346 ConnecticutAvenue(sic) N.W. Washington D.C. 20036; Dear Mr. Sears: This will acknowledge your letter of May 14, 1969, to the Nationa Highway Safety Bureau requesting the addition of the 6JJ alternative rim size for the E78-14 tire size designation to Table I of Appendix A of Federal Motor Vehicle Safety Standard No. 110.; On the basis of the data submitted indicating compliance with th requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the *Federal Register*, Volume 33, No. 195, Page 14964, dated October 5, 1968, the 6JJ alternative rim size for the E78-14 tire size designation will be listed within Table I of Appendix A of Standard No. 110. This change will be published in the *Federal Register* in the near future.; The addition of new alternative rim size designations to the table i accomplished through an abbreviated procedure consisting of the publication in the Federal Register of petitioned alternative rim size. If no comments are received, the amendment becomes effective 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.; Sincerely, H.M. Jacklin, Jr., Acting Director, Motor Vehicle Safet Performance Service; |
|
ID: aiam5366OpenMr. Fred Benford 100+ Motoring Accessories 2220 East Orangewood Avenue Anaheim, CA 92806-61100; Mr. Fred Benford 100+ Motoring Accessories 2220 East Orangewood Avenue Anaheim CA 92806-61100; "Dear Mr. Benford: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard (FMVSS) No. 211, Wheel nuts, wheel discs and hub caps. You wrote that your company manufactures aluminum wheel covers without 'protruding objects.' You requested confirmation that the wheel covers do not violate any FMVSS. Our response is provided below. By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles, or of motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), it is the responsibility of the manufacturers of motor vehicle equipment to ensure that its equipment meet applicable requirements. The following represents our opinion based on the facts provided in your letter. Standard No. 211 regulates wheel nuts, wheel discs, and hub caps. Since 'wheel discs' encompasses wheel covers, your company's wheel covers are subject to Standard No. 211. S4. Requirements of Standard No. 211 states in part: As installed on any physically compatible combination of axle and wheel rim, wheel nuts, wheel discs, and hub caps for use on passenger cars and multipurpose passenger vehicles shall not incorporate winged projections ... In your letter, you stated that your wheel covers do not have any 'protruding objects.' Since Standard No. 211 prohibits wheel discs (covers) with 'winged projections,' if your company's wheel covers do not incorporate 'winged projections,' the wheel covers would satisfy Standard No. 211. 'Winged projection' is defined at S3.2 of Standard No. 211 as an exposed cantilevered appendage that projects radially from a wheel disc and that typically has front, edge, and/or rear surfaces which are not in contact with the wheel when the wheel disc is installed on the axle. You also asked whether wheel covers made of aluminum violate any FMVSS. The answer is no, because Standard No. 211 does not specify materials for use in wheel covers. However, since wheel covers are 'motor vehicle equipment,' your company must ensure that the wheel covers are free of safety-related defects under the Safety Act. Sections 151-159 of the Safety Act concern the recall and remedy of products with defects related to motor vehicle safety. In the event that your company or NHTSA determines that the wheel covers have a safety-related defect, your company would be responsible for notifying purchasers of the defective wheel covers and remedying the problem free of charge. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
|
ID: aiam2509OpenMr. Steven Katz, Silver Thread Studios, 413 A Sixth Avenue, Brooklyn, NY 11215; Mr. Steven Katz Silver Thread Studios 413 A Sixth Avenue Brooklyn NY 11215; Dear Mr. Katz: This responds to your February 1, 1977, letter requesting informatio concerning the Federal regulations that would be applicable to glazing for use in van-type vehicles. Your assumption that the glazing regulation is not applicable to plastic material used for porthole windows and sun-roofs in vans is incorrect.; Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*, 4 CFR 571.205, specifies requirements for all glazing materials for use in motor vehicles and motor vehicle equipment. The standard specifies the types of glazing that may be used in various locations in vehicles and, in addition, specifies performance requirements for each type of glazing. Although the standard does permit the use of plastic glazing in side windows and sun-roofs of van-type vehicles, the plastic glazing must meet specified performance requirements.; I am enclosing a copy of Standard No. 205 (and the ANS Z26 standar that is incorporated by reference in Standard No. 205) for your information. From the standard you will be able to determine the various types of glazing that may be used for side windows and sun-roofs in vans.; Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam0534OpenMr. Paul G. Scully, Vice President, The Grote Manufacturing Company, Post Office Box 766, Madison, IN 47250; Mr. Paul G. Scully Vice President The Grote Manufacturing Company Post Office Box 766 Madison IN 47250; Dear Mr. Scully: This is in reply to your letter of October 18, 1972, to Mr. Schneide asking for an interpretation of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108. You have enclosed photographs of boat trailers marked to show your understanding of the language 'as far forward as practicable' and ask for our views.; Table II and Table IV of Standard No. 108 require that front sid reflex reflectors and lamps on trailers, including boat trailers, be located as far to the front as practicable. Recognizing that a literal interpretation of the standard would require that these devices be installed on the trailer tongue and that in many instances it would be impracticable to do so, the NHTSA added paragraph S4.3.1.3 to allow a location as far forward as practicable exclusive of the trailer tongue.' The intent of the regulation is that the device be mounted as far to the front of the vehicle as the manufacturer determines is practicable, and a definition of 'trailer tongue' is immaterial for this purpose. If the angled portion of the frame is deemed 'practicable', and the device is located there, it must be mounted, as you suggested, in a position such that it meets the photometric requirements at the specified angles with respect to the vehicle.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam4824OpenMr. Walter E. Gundaker Acting Director Center for Devices and Radiological Health Food and Drug Administration 12720 Twinbrook Parkway Rockville, MD 20857; Mr. Walter E. Gundaker Acting Director Center for Devices and Radiological Health Food and Drug Administration 12720 Twinbrook Parkway Rockville MD 20857; "Dear Mr. Gundaker: This responds to your December 26, 1990 lette concerning mechanical hand and foot driving controls. These controls are intended to enable persons who have limited use of their arms or legs to drive a motor vehicle. In your letter you stated that, because these controls raise questions regarding motor vehicle safety, your agency would like to revoke their present classification as a class II medical device. However, before you do this, you would 'need assurances that these driving controls for handicapped persons do fall in the jurisdiction of NHTSA and that significant complaints of malfunction would be investigated by NHTSA.' The following is a summary of our statutory authority in this area. Section 103 of the National Traffic and Motor Vehicle Safety Act (the Safety Act, 15 U.S.C. 1392) authorizes NHTSA to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. The driving controls that are the subject of your letter would be considered items of motor vehicle equipment, within the meaning of the Safety Act. However, this agency has not issued any standards setting forth performance requirements for controls for disabled drivers. Obviously, these controls could not be determined to be in noncompliance with a safety standard if there is no applicable safety standard. Another possible source of authority for NHTSA would be 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)), which specifies that, 'no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard.' This statutory prohibition would be violated if a manufacturer, distributor, dealer, or repair business installed a mechanical hand or foot driving control so as to 'render inoperative' any of the elements of design installed in the original vehicle in compliance with one of our safety standards. However, when NHTSA has been asked about this in the past, the agency has generally stated that it would not institute enforcement proceedings under section 108(a)(2)(A) of the Safety Act against dealers or repair shops when a particular vehicle must be modified to accommodate the needs of a particular disability. Finally, the agency has authority to investigate allegations that items of motor vehicle equipment, such as these controls, contain defects related to motor vehicle safety, and to order the equipment manufacturer to notify owners and to remedy without charge any items of equipment determined to contain a defect related to motor vehicle safety, as provided in sections 151-160 of the Safety Act (15 U.S.C. 1411-1420). If there were indications that these controls contained a defect related to motor vehicle safety, the agency would investigate and take appropriate actions. Of course, as with any investigation of alleged safety-related defects, the outcome would depend on the facts of the specific investigation. I hope you find this information helpful. If you have further questions or need some additional information in this area, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
|
ID: aiam5223OpenMr. Howard Schecter P. O. Box 61353 Honolulu, HI 96839; Mr. Howard Schecter P. O. Box 61353 Honolulu HI 96839; "Dear Mr. Schecter: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number - basic requirements (49 CFR 571.115). In a telephone conversation with Dorothy Nakama of my staff, you explained that you own a three-wheel motorcycle built with all used parts. The engine and other parts are from a used Corvair passenger car, and additional parts are from used motorcycles. Your letter asks whether your motorcycle must be assigned a vehicle identification number (VIN). The answer is no. Standard No. 115 applies to new motor vehicles, including motorcycles. NHTSA does not consider your motorcycle as new, since it was built entirely out of used parts. Since Standard No. 115 applies only to new motor vehicles, and NHTSA does not consider your motorcycle to be new, the motorcycle's rebuilder need not, under NHTSA's regulations, assign a VIN to the motorcycle. Your letter stated that the State of Hawaii's Reconstructed Vehicle Department (RVD) would not register your motorcycle since it has no VIN. Registration procedures for motor vehicles are set by each State, not NHTSA. However, we suggest that you show this letter to the RVD officials to explain that your motorcycle need not be assigned a VIN under NHTSA's regulations. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
|
ID: aiam0021OpenMr. E. L. Koepenick, Secretary-Treasurer, Fire Apparatus Manufacturers Association, Inc., 7979 Old Georgetown Road, Washington, DC 20014; Mr. E. L. Koepenick Secretary-Treasurer Fire Apparatus Manufacturers Association Inc. 7979 Old Georgetown Road Washington DC 20014; Dear Mr. Koepenick: Your March 7, 1967, letter to Dr. William Haddon, Jr., requested tha you be advised regarding the applicability of lighting requirements, as specified in the Initial Motor Vehicle Safety Standards, to fire apparatus.; With exceptions as noted in Section 255.7, page 2409 of the *Federa Register*, Volume 32, Number 23, dated February 3, 1967 (copy enclosed), the lighting requirements will be applicable to fire apparatus. Initial Standard No. 108 covers lighting requirements for vehicles (as specified therein) that are 80 or more inches wide overall and becomes effective January 1, 1968. A Notice of Proposed Rule Making (see page 2418) of enclosed *Federal Register* includes a Proposed Amendment to Standard No. 108 and a Proposed Initial Standard No. 112, covering vehicles (as specified therein) that are less than 80 inches wide overall. It is anticipated that the proposed Amendment and Initial Standard No. 112 will also become effective on January 1, 1968.; Thank you for your interest in the Motor Vehicle Safety Standards. Sincerely, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
|
ID: aiam4961OpenMarc C. Gravino, Esq. Williams & McCarthy P.O. Box 219 Rockford, Ill. 61105-0219; Marc C. Gravino Esq. Williams & McCarthy P.O. Box 219 Rockford Ill. 61105-0219; Dear Mr. Gravino: This responds to your letter of February 7, 1992 asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Specifically, you ask whether the standard contains any requirement that the parking lamps, taillamps, and side marker lamps operate independently of the ignition switch so that when they are activated they will remain activated regardless of whether or not the ignition switch is in the on or off position. You have reviewed Standard No. 108, and reference paragraphs S5.5.3, S5.5.4, S5.5.5, and S5.5.7, copies of which you have enclosed. The answer is no. Under paragraph S5.5.5, the vehicular hazard warning signal operating unit is required to operate independently of the ignition switch, but no other lamp is required by the standard to do so. Sincerely, Paul Jackson Rice Chief Counsel; |
|
ID: aiam5389Open"Mr. S. Greiff PARS Passive R ckhaltesysteme GmbH Borsigstrabe 2 63/55 Alzenau Germany"; "Mr. S. Greiff PARS Passive R ckhaltesysteme GmbH Borsigstrabe 2 63/55 Alzenau Germany"; Dear Mr. Greiff: This responds to your letter of April 19, 1994 requesting an interpretation of the 500 foot minimum runway length in the Laboratory Test Procedure for Federal motor vehicle safety standards Nos. 208, 212, 219, and 301. Laboratory Test Procedures are provided to contracted laboratories as guidelines for conducting compliance tests. The Laboratory Test Procedures do not limit the requirements of the applicable Federal motor vehicle safety standards. None of the standards referenced in your letter include any requirement for minimum runway length. Instead, the standards specify that the collision into the fixed barrier will occur at any speed up to and including 30 mph. 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; |
|
ID: aiam0471OpenMr. Charles O. Verrill, Jr., Patton, Blow, Verrill, Brand & Boggs, 1200 Seventeenth Street, N.W., Washington, DC 20036; Mr. Charles O. Verrill Jr. Patton Blow Verrill Brand & Boggs 1200 Seventeenth Street N.W. Washington DC 20036; Dear Mr. Verrill: This is in reply to your letter of October 12, 1971, in which you mad several requests with respect to the Tire Identification and Record Keeping (49 CFR Part 574) and Certification (49 CFR Part 567) regulations.; >>>1. You suggested that the Tire Identification and Record Keepin regulation be amended to provide that where tires are not shipped on or in a vehicle, the vehicle manufacturer's record keeping obligation be limited to three years from the date of sale. We will take this request into consideration, and let you know when a decision is made. It appears that since the minimum time would apply to all vehicle manufacturers, such a requirement should appear in a regulation other than Part 574.; 2. You requested the deletion of the requirement that information o the certification label be placed 'in the order shown.' We have previously denied petitions relating to the order of information on the label (36 F.R. 19593), and this request is also denied. The requirement that the label information be placed in a definite order has been in effect for over two years, and has been found to enhance the readability and hence the usefulness of the label. Now that further numerical information is to be required on the label, we consider that it will be even more important that this requirement be maintained.; 3. You requested 'an interpretation that a multi-column label or label in two parts each with an information column, will meet the requirements of [Part] 567,' because of the space limitations on some trailers. As long as the information appears in the order specified in the regulation, the NHTSA has no objection to a multi-column label or a label in two parts.; 4. Finally, you requested that a trailer manufacturer be allowed to us up his existing supply of labels, by affixing a supplementary label with the additional required information. As stated above, we have decided to adhere to the requirement that the information on the label be in the order specified, although it may be in more than one column or part. To the extent that the action requested would allow a manufacturer not to conform to that requirement, the request is denied. Although the deviation might appear small, it would seriously detract from the integrity and enforceability of the regulation to allow incidental nonconformity without amending the requirement. The other vehicle manufacturers have undoubtedly already incurred costs similar to those cited by your client, and it would be distinctly unfair not to enforce the regulation evenhandedly as to all parties.<<<; Sincerely, Robert L. Carter, Acting Associate Administrator |
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.