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: aiam4785OpenMr. William T. Mullen Undersheriff of McHenry County, Illinois 2200 N. Seminary Ave. Woodstock, IL 60098; Mr. William T. Mullen Undersheriff of McHenry County Illinois 2200 N. Seminary Ave. Woodstock IL 60098; "Dear Mr. Mullen: This responds to your letter asking about Federa requirements for safety belts in police cars. Specifically, you asked if your police department could legally remove the automatic belts that are installed and replace them with manual lap/shoulder safety belts. You stated that the reasons for making such a substitution would be to alleviate two problems your police officers have experienced with the automatic belts that were not present in older models that had manual lap/shoulder belts at the front seating positions. First, you said that the automatic belts result in a blind spot on the driver's left side. Second, you said that the automatic belts 'prevent left arm movements' of your taller officers. I appreciate this opportunity to respond to your concerns. I have enclosed copies of two previous letters we have written on the subject of removing or replacing occupant protection features from police cars. The first of these is a July 29, 1985 letter to Corporal Frank Browne and the other is a May 25, 1989 letter to Senator Harry Reid. These letters explain that new vehicles purchased by police departments must be certified as complying with the occupant crash protection standard (Federal Motor Vehicle Safety Standard No. 208). All cars manufactured on or after September 1, 1989 must provide automatic crash protection for front seat occupants. To date, manufacturers have provided automatic crash protection either by installing air bags or automatic safety belts. General Motors, the manufacturer of the police cars in question, has chosen to comply with the requirement for automatic crash protection by installing automatic safety belts in these cars. Federal law prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from replacing the automatic belts in these police cars with manual lap/shoulder belts. Thus, none of these commercial entities could make such a replacement on behalf of the County without violating Federal law. However, Federal law does not prohibit individual vehicle owners from removing safety features from their own vehicles. Thus, McHenry County itself can replace the automatic belts in its own cars without violating any Federal law, just as any resident of McHenry County can remove any safety equipment they like from their own vehicles without violating any Federal laws. Such actions may, however, violate the laws of the State of Illinois. I recommend that you carefully consider the effects of replacing the automatic belts in your police cars, even though Federal law does not prohibit the County itself from making these modifications to its own vehicles. The automatic belts in these cars help to assure safety belt use by police officers on the job. Particularly since the McHenry County police officers face the possibility of becoming involved in high speed pursuit situations, we believe it is important that they use safety belts for effective protection in case of a crash. If you decide to replace the automatic belts in these vehicles with manual lap/shoulder belts, we would urge you to take some actions to assure that the police officers will use the manual lap/shoulder belts every time they ride in the police cars. I hope this information is helpful. If you have any further questions or need some additional information on this subject, please let me know. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam3040OpenMr. Maurice H. Allmacher, Project Engineer, Vehicle Regulations, Volkswagen of America, Inc., 7111 East Eleven Mile Road, Warren, MI 48090; Mr. Maurice H. Allmacher Project Engineer Vehicle Regulations Volkswagen of America Inc. 7111 East Eleven Mile Road Warren MI 48090; Dear Mr. Allmacher: This is in response to your letter of June 1, 1979, regarding th provision of Uniform Tire Quality Grading (UTQG) information to vehicle first purchasers (49 CFR 575.104(d)(1)(iii)). You ask whether UTQG information must be provided to first purchasers of vehicles manufactured after the UTQG sidewall molding effective date for the type of tire used on the vehicle, if the vehicle is equipped with tires manufactured prior to the effective date.; Section 575.104(d)(1)(iii) requires that tire grading information b furnished, in the case of bias- ply tires,; >>>'...to the first purchaser of a new motor vehicle, other than motor vehicle equipped with bias-ply tires manufactured prior to October 1, 1979, ...'<<<; Thus, UTQG first purchaser information is not required for vehicle manufactured after the bias-ply sidewall molding effective date of October 1, 1979, but equipped with tires manufactured prior to that date. The regulation applies in the same manner to vehicles equipped with bias-belted and radial tires manufactured prior to April 1, 1980, and October 1, 1980, respectively.; In order to avoid confusion regarding the date of manufacture of tire installed on particular vehicles, manufacturers may choose to supply UTQG information to all first purchasers of vehicles manufactured after the effective date for sidewall molding for the tire type used as standard equipment on the vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1587OpenMr. Richard D. Henderson, Private Truck Council of America, Inc., 1101 Seventeenth Street, N.W., Washington, D.C. 20036; Mr. Richard D. Henderson Private Truck Council of America Inc. 1101 Seventeenth Street N.W. Washington D.C. 20036; Dear Mr. Henderson: This is in reply to your letters of July 25 and August 26, 1974 requesting information on NHTSA regulations applicable to regrooved tires.; You ask whether companies leasing trucks to other companies may equi the trucks with regrooved tires, and what tire standards apply.; The recent court decision regarding regrooved tires (*NAMBO* v *Volpe*, 483 F. 2d 1294 (D.C. Cir. 1973), *Cert.* *denied*,-- U.S.--(1974)) held that under the National Traffic and Motor Vehicle Safety Act the NHTSA could permit only the sale of regrooved tires. Consequently, the leasing of regrooved tires is now prohibited, as is any other introduction of them into interstate commerce other than by a sale. The NHTSA recently amended its regrooved tire regulations to conform to this Court opinion.; We do not construe the opinion to prohibit the leasing of truck equipped with regrooved tires. The regulation applies only to the manner in which the tires themselves are obtained.; The standards applicable to regrooved tires are fund in the Regroove Tire regulations (49 CFR Prt 569). Regroovable tires manufactured after March 1, 1975, must also conform to Motor Vehicle Safety Standard No. 119.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2201OpenMr. Earl C. Sievers, Finance Manager, Layton Paving Equipment Specialists, 4725 Turner Road, Salem, Oregon 97302; Mr. Earl C. Sievers Finance Manager Layton Paving Equipment Specialists 4725 Turner Road Salem Oregon 97302; Dear Mr. Sievers: This is in response to your letter of January 14, 1976, asking whethe your company's paver product must comply with the requirements of Federal motor vehicle safety standards and regulations, particularly Standards No. 119 and 120.; The National Highway Traffic Safety Administration (NHTSA) issue safety standards and regulations for 'motor vehicles.' Section 102(3) of the National Traffic and Motor Vehicle Safety Act defines a motor vehicle as a vehicle 'manufactured primarily for use on the public streets, roads, and highways.' Thus, a motor vehicle is a vehicle which the manufacturer expects will use public highways as part of its intended function. The primary Function of some vehicles is of a mobile, work-performing nature, and, as such, their manufacturer contemplates a primary use of the highway. Mobile cranes, rigs, and towed equipment such as chippers and pull-type street sweepers that travel at a normal highway speed are examples in this area. These motor vehicles qualify as trucks or trailers. As such they are subject to the Federal motor vehicle safety standards and regulations. On the basis of the information you have sent us your company's towed paver appears to be in this category of vehicles, and would therefore be considered a 'motor vehicle.'; There are some vehicles which are excepted from the motor vehicl classification despite their use on the highway. Highway maintenance and construction equipment, lane strippers, *self-propelled* asphalt pavers, and other vehicles whose maximum speed does not exceed 20 mph and whose abnormal configuration distinguished them from the traffic flow are not considered motor vehicles. Your company's paver would not appear to qualify in this category of vehicles since, as a towed paver, it would travel at a speed greater than 20 mph, at least when moving between job sites.; Consequently, your product must comply with the requirements of th Federal standards and regulations. Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*, does not directly impose any duty on you, because it applies to tires rather than vehicles. However, the NHTSA has recently issued Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars* (copy enclosed). This standard does require, effective September 1, 1976, that your vehicles be equipped with tires that conform to Standard No. 119 and are of sufficient load rating.; In addition to compliance with the safety standards and regulations you must ensure that your product does not contain a defect relating to motor vehicle safety. Vehicles containing such defects are subject to the notification, remedy, and civil penalty provisions of the National Traffic and Motor Vehicle Safety Act. For example, a vehicle equipped with tires that are designed for speed-restricted use would probably be considered to contain a safety-related defect if the vehicle is expected to travel at higher speeds.; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2651OpenMs. Jill M. Zick, BURLEY, SMIERTKA, SWANK AND MISKO, Attorneys and Counselors at Law, 2525 West Jefferson, Trenton, MI 48183; Ms. Jill M. Zick BURLEY SMIERTKA SWANK AND MISKO Attorneys and Counselors at Law 2525 West Jefferson Trenton MI 48183; Dear Ms. Zick: This is in reference to your September 6 letter, regarding modificatio of motor vehicles for the handicapped, which was forwarded to this office by the Lansing, Michigan, office of the Federal Highway Administration.; Your letter has been forwarded to the Office of Chief Counsel, Nationa Highway Traffic Safety Administration, Washington, DC. I'm sure you may expect to hear from that office shortly.; Sincerely, Ardella J. Pitts, Highway Safety, Management Specialist |
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ID: aiam5194OpenDr. Thomas L Luckemeyer Dept. VER/LB SWF Auto Electric GmH; Dr. Thomas L Luckemeyer Dept. VER/LB SWF Auto Electric GmH; "FAX 07142/73 28 95 Dear Dr. L ckemeyer: As you have requested, we ar responding by FAX to your FAX letter of June 25, 1993, to Taylor Vinson of this Office. Our FAX letter to you of May 28, 1993, provided an interpretation of SAE J588 NOV84, incorporated by reference in Federal Motor Vehicle Safety Standard No. 108. You mention the l990 SAE Ground Vehicle Lighting Manual which refers to SAE J588 September l970, and ask which is the correct SAE reference. Standard No. 108 was amended with an effective date of December 1, 1990, to substitute 'SAE J588 NOV84' for 'SAE J588 September 1970' as the U.S. Federal requirement for turn signal lamps used as original equipment on passenger cars and other motor vehicles with an overall width of less than 80 inches overall width. Turn signal lamps may still be manufactured to the requirements of 'SAE J588 September 1970' if they are intended to replace original equipment turn signal lamps that were manufactured in accordance with 'SAE J588 September 1970.' We understand that your earlier letter asked for an interpretation of Standard No. 108 as it related to the design of lamps for future production, and trust that this answers your question. As you have requested, we are also FAXing a copy of Table III. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3943OpenMr. Ralph Walker, 5517 Cleon Avenue, North Hollywood, CA 91605; Mr. Ralph Walker 5517 Cleon Avenue North Hollywood CA 91605; Dear Mr. Walker: This responds to your letter of April 8, 1985, and follows up on you telephone conversation with Stephen Oesch of my staff concerning safety regulations applying to sun roof windows for recreational vehicles. The National Highway Traffic Safety Administration has issued Standard No. 205, *Glazing Materials*, which sets requirements for the glazing used in motor vehicles, including the glazing for a sun roof in a recreational vehicle. A copy of the standard is enclosed.; You were particularly interested in the certification requirements fo sun roofs. Paragraphs S6.1 and S6.3 of Safety Standard No. 205 specify that prime glazing material manufacturers shall certify each piece of glazing for use in motor vehicles. The certification must be in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act and with section 6 of the ANS Z-26 standard. These requirements would be applicable to the company from which you buy your glazing, since that company would qualify as a prime glazing material manufacturer.; As a manufacturer or distributor who cuts a section of glazing for us in a motor vehicle, your company would be required to certify its product in accordance with paragraphs S6.4 and S6.5 of Standard No. 205. S.6.4 requires your company to mark any section of glazing that it cuts with the same AS number, manufacturer model number and manufacturer trademark or designation as the piece of glazing from which it was cut.; S6.5 requires your company to certify your product in accordance wit section 114 of the National Traffic and Motor Vehicle Safety Act. Section 114 provides that an item of motor vehicle equipment (including glazing) may be certified by means of a label or tag on the item of equipment or on the outside of a container in which the equipment is delivered. The label or tag must certify that the item of motor vehicle equipment complies with all applicable motor vehicle safety standards, Standard No. 205 in this case.; Please let me know if you have any further questions. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0396OpenKendall M. Barnes, Esq., General Counsel, Department of the Army, Headquarters United States Army Material Command, Washington, D.C. 20315; Kendall M. Barnes Esq. General Counsel Department of the Army Headquarters United States Army Material Command Washington D.C. 20315; Dear Mr. Barnes: This is in reply to your letter of June 29 with its enclosures from th Staff Judge Advocate, Aberdeen Proving Ground. The Judge Advocate requests an 'interpretation of the applicability of the [military] exception to recent motor vehicle brake fluid legislation,' stating his specific interest in 'the use of MIL-P-46046' brake fluid.; We are unaware of any 'legislation' that affects the manufacture an use of MIL-P-46046 brake fluid. The NHTSA issued an amended brake fluid standard on June 24 but this does not affect the exception provided in 49 CFR S 571.7(c) that 'No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specification.' Thus continued use of MIL-P-46046 brake fluid by military personnel appears permissible as far as this agency is concerned.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0683OpenMr. J. W. Kennebeck, Manager, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This is in reply to your letter of April 10, 1972, on the subject o the label required by Standard 207 to be affixed to a seat that is not intended for use while the vehicle is in motion.; Although S4.4 of Standard 207 does not require the warning to b verbal, it is our impression that the concept is difficult to convey by nonverbal symbols. A quick review of personnel in the NHTSA revealed that most of them were familiar enough with the international sign system to know that something was being forbidden, but were unsure as to what the forbidden act was. Of the two symbols, the one showing the vehicle in motion appeared to be more understandable, but not by much.; It is our conclusion that neither of the symbols is adequate to giv the warning intended by S4.4. This is not to say that the symbols would not be adequate in other countries whose citizens are more familiar with symbolic labeling. I might add that the label need not contain the exact words of the standard. It would be acceptable, for example, to say 'Do not ride in this seat,' if you find that shortening the phrase would make the label less cumbersome.; Sincerely, Richard B. Dyson |
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ID: aiam1991OpenMr. E. Cooper Lipshield, Manager Research and Development, Orscheln Lever Sales Company, 1177 N. Morley Street, Moberly, MO 65270; Mr. E. Cooper Lipshield Manager Research and Development Orscheln Lever Sales Company 1177 N. Morley Street Moberly MO 65270; Dear Mr. Lipshield: This is in response to your letter of July 10, 1975, in which yo request a copy of the proposed rule dealing with tilt cab vehicle latch systems (Docket No. 69-27), which was referred to this office by the Docket Section.; Notice 1 of Docket 69-27 was published as an advance notice of propose rulemaking on October 22, 1969 (34 FR 17115). On January 25, 1972, a notice was published suspending rulemaking on 69-27 and proving that no regulation would be issued without additional notice and opportunity for comment (37 FR 1120). There has been no further action taken on tilt cab vehicle latch systems since that date.; If we can be of any further assistance, please let us know. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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.