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: aiam2053OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your letter of July 30, 1975, in which you aske whether the uniform tire quality grading requirements for furnishing information to prospective purchasers of vehicles apply to prospective purchasers of vehicles other than passenger cars that may be equipped with passenger car tires. This was asked in light of the fact that the tire quality grading rule itself applies to tires manufactured for use on passenger cars.; We do not consider that the requirements of S 575.6(a) and (c) regarding the furnishing of consumer information to motor vehicle buyers and prospective purchasers, apply to the sale of trucks or other non-passenger- car vehicles where uniform tire quality grading information is concerned.; We recognize that the language of the regulation may not be entirel clear in this regard, and are considering an interpretive amendment to clarify it.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0594OpenMr. Gerald E. Bowman, Chief Executive Officer, Winnebago Industries, Inc., P.O. Box 152, Forest City, IA 50436; Mr. Gerald E. Bowman Chief Executive Officer Winnebago Industries Inc. P.O. Box 152 Forest City IA 50436; Dear Mr. Bowman: We have received your quarterly report pursuant to section 573.5 of th Defect Reports regulations and note that you have marked 'confidential' data submitted concerning a notification campaign conducted on your Model 04 motor home.; The NHTSA does not consider information regarding notificatio campaigns to be confidential under sections 112 or 113 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. SS 1401, 1402), and is making this information public. The only information that we have agreed to keep confidential, if requested, are production figures submitted pursuant to section 573.5(b).; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3212OpenMr. David Shomberg, Bus Con Corporation, 19 South Main Street, Spring Valley, NY 10977; Mr. David Shomberg Bus Con Corporation 19 South Main Street Spring Valley NY 10977; Dear Mr. Shomberg: This responds to your January 22, 1980, letter asking two question about the use of your body conversion numbers on the certification labels of vehicles you produce.; First, you ask whether a final-stage manufacturer may substitute it body conversion number for the vehicle identification number (VIN) that comes with the incomplete vehicle. The answer to this question is no. The VIN must be continued from the incomplete vehicle certification label to the final-stage certification label. However, you may insert your body conversion number on the label in addition to the VIN. Your number should appear at the bottom of the label below the required information.; In your second question, you ask whether you may include your bod conversion number on the alterers' labels for previously certified vehicles that you alter. The answer to this question is yes. As indicated above the number should appear at the bottom of the label below the required information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2950OpenMr. Hisakazu Murakami, Nissan Motor Co., Ltd., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, New Jersey 07632; Mr. Hisakazu Murakami Nissan Motor Co. Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs New Jersey 07632; Dear Mr. Murakami: This is in response to your letter of September 29, 1978, and i confirmation of your conversation with Mr. Schwartz of my office. Since the agency was considering petitions for reconsideration when your letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of the amendments to the standard and a copy of the notice of proposed rulemaking to further amend the standard are enclosed.; Your letter raised a number of question concerning Federal Moto Vehicle Safety Standard No. 115. These questions will be answered in the order posed in your letter.; Q-1. The term 'line' is defined in S34 of the standard to mean 'a nam which a manufacturer applies to a family of vehicles within a make which have a degree of commonality in construction, such as body, chassis or cab type'. You are correct in saying that 'B210' is a Datsun 'line.'; Q-2. You ask whether it is necessary in designating a vehicle 'line' t distinguish between independent and rigid axle systems within the same model of vehicle. The answer to your question is no. It is not necessary to make this distinction. In your example, either Case 1 or Case 2 would be correct.; Q-3. You ask whether it is necessary in designating a vehicle 'line' t distinguish between different lengths of wheel base within the same family of vehicles. Again, the answer to your question is no. In your example, either Case 1 or Case 2 would be correct.; Q-4. You ask whether it is necessary in designating vehicle 'body type to distinguish between a 2-door vehicle and a 4-door vehicle. It is necessary to make this distinction.; Q-5. You also ask whether it is necessary in designating vehicle 'bod type' to distinguish between a sedan and a hardtop. It is not necessary to make this distinction.; Q-6 You ask whether it would be necessary in designating a vehicl 'series' to distinguish between a Datsun 810 with air conditioning and power steering and a Datsun 810 with these features. It is not necessary to make this distinction.; Q-7. You ask whether it would be necessary in designating a vehicl 'series' to distinguish between a Datsun B210 with a cigarette lighter and a Datsun B210 with out a cigarette lighter and with a less elegant interior. It is not necessary to make this distinction. A Datsun B210 with two doors would have a different 'body type' than a datsun B210 with four doors, however.; Q-8. You ask whether in designating vehicle 'engine type', you may us the same character (e.g., 'H') to designate different engines so long as they are within *different* 'lines', or whether you must use different characters for each engine type you manufacture.; The vehicle description section (VDS) of the VIN is used to describe group of vehicles with common characteristics. One of these characteristics is engine type. The VDS is a 'code word' which is translated as a whole into the appropriate specification. Each VDS is unique, and the use of a specific character in one VDS does not bar its use in another VDS, whether or not the meaning is the same or different. Consequently, 'HB210' can represent a Datsun B210 with an 85 CID displacement engine and 'HA100' can represent a DATSUM(sic) 510 with a 119 CID displacement engine. In your example, both Column 1 and column 2 would be permissible.; Q-9. you ask whether it is necessary to uniquely distinguish all engin types within a *make*, or whether it is sufficient to distinguish engine types within a line. As explained above, each vehicle descriptor section is unique. Consequently, you may use the same characters in more than one VDS provided the VDS can be translated into the specific engine type. In your example, either Column 1 or Column 2 would be permissible.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4187OpenThomas A. Hacker, Technical Services Bureau, New York Department of Motor Vehicles, The Governor Nelson A. Rockefeller Empire State Plaza, Albany, NY 12228; Thomas A. Hacker Technical Services Bureau New York Department of Motor Vehicles The Governor Nelson A. Rockefeller Empire State Plaza Albany NY 12228; Dear Mr. Hacker: This is in response to your letter dated May 15, 1986, to Edward Glanc concerning the conversion of the speedometer/odometer from kilometers to miles per hour.; In 1972, Congress enacted Title IV of the Motor Vehicle Information an Cost Savings Act (the 'Act'), 15 U.S.C. SS 1981-1991, to establish certain safeguards for the protection of motor vehicle purchasers. Pursuant to the Act, the National Highway Traffic Safety Administration promulgated rules for the disclosure of odometer information, 49 C.F.R. Part 580. Neither the Act nor the regulations prohibit the use of an odometer which records in kilometers.; In replacing an odometer that registers kilometers with one tha registers miles, you should be aware of Federal Motor Vehicle Safety Standard (FMVSS) 101, 49 CFR S 571.101, which requires that if the odometer indicates kilometers, then 'KILOMETERS' or 'km' shall appear, otherwise no identification is required. Furthermore, FMVSS 101 requires that if the speedometer is graduated in miles per hour and in kilometers per hour, the identifying words or abbreviations shall be 'MPH and km/h' in any combination of upper and lower case letters.; The Act does prohibit an individual from disconnecting, resetting altering or causing to be disconnected, reset or altered the odometer 'with intent to change the number of miles indicated thereon' 15 U.S.C. S 1984. Moreover, it permits the service, repair and replacement of odometers, provided the mileage remains the same 15 U.S.C. S 1987. The National Highway Traffic Safety Administration interprets mileage to mean actual distance travelled regardless of whether that mileage is calculated in terms of miles or kilometers. While it is clear that this section was intended to accommodate repairs of odometers that are malfunctioning, I have determined that it may also be relied upon to lawfully replace odometers which register kilometers travelled with those that register miles travelled. You may, therefore, convert the odometer reading from kilometers to miles by multiplying the kilometer reading by .62.; Additionally, the Federal regulations provide for the inclusion of tw sets of certifications on the odometer disclosure statements which must be completed at the time the vehicle is transferred. Transferors who convert the odometers from kilometers to miles should check the first box of the first set which reads:; >>>I hereby certify that to the best of my knowledge the odomete reading as stated above reflects the actual mileage of the vehicle described below.<<<; Furthermore, these transferors should check the second box in th second set of certifications which reads:; >>>I hereby certify that the odometer was altered for repair o replacement purposes while in my possession, and that the mileage registered on the repaired or replacement odometer was identical to that before such service.<<<; I hope this opinion is helpful to you in your attempt to assist dealer in complying with the Federal odometer laws. If you have any further questions, do not hesitate to contact me.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3642OpenMr. Mike M. Simovich, Champ Corporation, El Monte, CA 91733; Mr. Mike M. Simovich Champ Corporation El Monte CA 91733; Dear Mr. Simovich: This is in response to your March 23, 1983, letter to Roger Fairchil of this office, regarding the applicability of Federal Motor Vehicle Safety Standard No. 115 (Vehicle Identification Number) to construction type forklift trucks. As you state in your letter, these vehicles are principally designed to operate on a construction site, such as by lifting building materials to upper levels in a building project. The trucks would apparently remain at construction sites for two to twelve months, then move to the next job site. Some models of the trucks have special equipment to facilitate being towed between job sites. While all models presumably could be driven between job sites, none are capable of achieving open highway speeds.; Standard 115 applies only to vehicles manufactured 'primarily for us on the public streets, roads, and highways.' NHTSA has interpreted this language to exclude mobile construction equipment which use the highways only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental, not the primary purpose for which the vehicle was manufactured. Based on the information provided in your letter, your fork-lift trucks would therefore not be subject to Standard 115.; You should be aware that this interpretation applies only to Federa requirements, individual States may establish their own numbering requirements for vehicles outside this agency's jurisdiction (e.g., off-road vehicles). Thus, even though Federal requirements do not apply, it may be that State requirements do apply to your fork-lift trucks.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1385OpenMr. Gordon Needleman, Patent Attorney, Dow Corning Corp., Midland, Michigan 48640; Mr. Gordon Needleman Patent Attorney Dow Corning Corp. Midland Michigan 48640; Dear Mr. Needleman: This is in reply to your letter of January 10, 1974, to Mr. Schneider. It is uncertain whether 'some time in July of 1974 Federal standar will become effective relating to silicone brake fluids.' The proposed effective date for DOT 5 fluids is July 1, 1974, but the comments on this rulemaking action are still under consideration and the actual effective date, if the proposal is adopted, will probably be somewhat later.; It is true that S5.4.3 of Standard No. 105a does not require that al reservoir labeling be 'DOT 3.' The letters '*e.g.*' mean 'for example.' if DOT 4 is the recommended fluid then 'DOT 4' would be the appropriate insertion in the required statement.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0982OpenMr. Satoshi Nishibori, Nissan Motor Company, 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Nissan Motor Company 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letters of December 15, 1972, and January 3 1973, concerning paragraph S7.4.3 of Standard 208.; As I understand the question, you are positing a situation in which th occupants have correctly operated their belts, thereby permitting the engine starting system to operate, but in which the cranking of the engine by the starter motor does not start the engine and the key is returned to the 'on' position. Your question is whether the ignition can thereafter be turned from 'on' to 'start' in repeated efforts to start the engine, without interference from the interlock.; Our reply is that S7.4.3 permits a system in which the initial correc operation of the belts, followed by operation of the starting system, places the system in a 'free-start' mode so long as the ignition is not turned to 'off'. Repeated efforts to start the engine would therefore be permitted, regardless of the status of the belts.; If the ignition has been turned off and if the system is not in anothe of the 'free-start' modes allowed by S7.4.3, then the engine starting system will not be operable with an unbelted driver on the seat unless an engine compartment switch is operated pursuant to S7.4.4.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4168OpenMr. Robert H. Munson, Director, Automotive Safety Office, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. Robert H. Munson Director Automotive Safety Office Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. Munson: This is to follow-up on a phone conversation between Mr. William Kin of Ford Motor Company's Washington Office and Stephen Oesch of my staff concerning the initial knee spacing requirements of Standard No. 208, *Occupant Crash Protection*. Mr. King referred to a memorandum in the public docket on Standard No. 208 which summarizes a meeting held between representatives of General Motors Corporation (GM) and this agency on April 16, 1986, and asked when the agency plans to reinstate the 14.5 inch requirement for the initial spacing of the driver test dummy's knee's (sic).; As discussed in the memorandum summarizing the April 16, 1986 meeting the agency misinterpreted the comments made by GM and Honda Motor Company on the initial knee spacing requirement proposed in April 1985. As a result of that misinterpretation, the agency adopted a (sic) 11 3/4 requirement for the initial spacing of the driver test dummy's knees in the March 21, 1986 final rule on the test dummy positioning procedures, rather than the proposed 14 1/2 inch requirement. The memorandum said that the agency planned to publish a correction notice on the test dummy positioning procedure to reinstate the 14 1/2 dimension for the initial spacing of the driver test dummy's knees.; Subsequent to the April 16, 1986 meeting, Ford filed a petition fo reconsideration of many of the test dummy positioning and other requirement (sic) adopted in the March 1986 final rule. The agency will make the necessary correction to the initial knee spacing requirement for the test dummy at the time it responds to Ford's petition for reconsideration.; Manufacturers can rely on this letter, which will be placed in th public docket on Standard No. 208, as assurance that they can use the 14 1/2 inch initial knee spacing requirement for the driver test dummy in conducting compliance tests for Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1690OpenMr. L. E. Davis, Jr., General Manager, Vulcan Trailer Manufacturing Company, P. O. Box 5099, Pratt City Station, Birmingham, AL 35214; Mr. L. E. Davis Jr. General Manager Vulcan Trailer Manufacturing Company P. O. Box 5099 Pratt City Station Birmingham AL 35214; Dear Mr. Davis: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulation, Part 573.; The Defect Information Report involves: 114 trailers equipped wit Standard Forge axles which may have defective brake shoes.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74-0223*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject trailer does not entirely meet the requirements of Part 577(49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter states that the defect exists in a number of axles. In instances, however, where a vehicle manufacturer is conducting a campaign, Part 577.4(b) requires that the defect be described as existing in the vehicle itself. The reference in the regulation to motor vehicle equipment applies only to equipment campaigns where vehicles are not directly involved. Your statement that reduced braking power or lockup may result is not an adequate evaluation of the risk to traffic safety since Part 577.4(d) clearly states that if vehicle crash without prior warning is a potential occurrence the letter must state this. The letter also does not give an estimate of the time reasonably necessary to perform the required labor. Since it appears that the owner must bear the labor cost, this information is especially significant. A date by which parts will be available should also have been given.; It is therefore necessary that you send a revised letter to thos owners whose vehicles have not yet been corrected and who have not yet indicated their intention to do so. A copy should also be sent to this office.; We also wish to point out that the National Traffic and Motor Vehicl Safety Act of 1966 requires that defect notification letters be sent to all known retail purchasers. Notifications to dealers therefore do not satisfy this requirement and need not follow the format of Part 577. It is therefore recommended that dealers either forward to you the addresses of the retail purchasers or mail a notification letter to each purchaser directly. Addresses of owners, however, need not be submitted to this office unless requested.; A copy of Part 577 is enclosed. If you desire further information please contact Messrs. W. Reinhart or James Murray of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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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.