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: aiam3525OpenMr. Leon W. Steenbock, Project Engineer, FWD Corporation, Clintonville, WI 52929; Mr. Leon W. Steenbock Project Engineer FWD Corporation Clintonville WI 52929; Dear Mr. Steenbock: This responds to your recent letter asking whether Safety Standard No 205, *Glazing Materials*, permits the use of Items 4 and 5 rigid plastics in rear windows on fire trucks. You were confused because the 'ANS Z26' standard permits rigid plastics in these locations, yet Standard 205 is silent on the issue.; The fact that Standard No. 205 does not specifically state that Items and 5 rigid plastics may be used in rear windows in trucks does not mean that such use is not permitted. The 'ANS Z26' standard is incorporated by reference in Standard No. 205 (paragraph S5.1.1). Therefore, glazing materials that conform with 'ANS Z26' may be used in the locations specified in that standard. In addition to the requirements and specified locations in 'ANS Z26,' Standard 205 includes other locations and requirements for additional types of glazing, as well as other locations for the Items of glazing that are specified in 'ANS Z26.'; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3030OpenMr. Donald I. Reed, Director of Engineering, Trailer Manufacturer Association, 401 North Michigan Avenue, Chicago, IL 60611; Mr. Donald I. Reed Director of Engineering Trailer Manufacturer Association 401 North Michigan Avenue Chicago IL 60611; Dear Mr. Reed: This letter corrects an interpretation provided you on June 1, 1979. In our letter, we answered in the negative to your question whether: >>>'whether (sic) it is permissible to combine a clearance lam function in a tail lamp fixture if a second bulb is installed in the tail lamp which, when lit alone, satisfies the photometric requirements of the clearance lamp shown through the tail lamp lens ... and further assuming that all tail lamp photometric requirements are met when the tail lamp bulb alone is lit and when both lamps are lit.'<<<; We commented that such a lamp would appear to create the optica combination prohibited by S4.4.1 when both lamps are lit.; It has been brought to our attention that this conflicts wit interpretations provided on March 4, 1977, to Dennis Moore of Livermore, California, and B.R. Weber of West Bend, Wisconsin, both manufacturers of boat trailer lighting equipment. In our letter to Mr. Weber, for example, we interpreted 'optically combined' to mean a situation in which 'the same light source (i.e., bulb) and the same lens area fulfill two or more functions (i.e., tail lamp, and stop lamp, clearance lamp and turn signal lamp)'. The phrase is not intended to prohibit the installation of two separate bulbs in a single housing and covered by a common lens.; Upon review, we believe that the interpretation of March 4, 1977, i the correct one, and that the conflicting interpretation of June 1, 1979, should be with error. We are sorry for any confusion this may have caused your members.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3460OpenMr. Charles Schamblin, Flag-It Signaling Device Co., P.O. Box 1709, Bakersfield, CA 93302; Mr. Charles Schamblin Flag-It Signaling Device Co. P.O. Box 1709 Bakersfield CA 93302; Dear Mr. Schamblin: The National Transportation Safety Board has forwarded for reply you letter of June 10, 1981, asking whether the 'Flag-It Automobile Signaling Device' would be legal to use according to your new regulations . . . .'; Requirements for equipment use are not established by the Federa government but by the individual State in which a vehicle is registered.; Our agency within the Department of Transportation establishes th Federal motor vehicle safety standards which apply to vehicle and equipment manufacturers. Your device consists of reflectors which hang beneath the front and rear bumper. They are not covered by our standard on reflectors (Standard No. 108 *Lamps, Reflective Devices and Associated Equipment*) nor would their installation appear to impair the effectiveness of lighting equipment required by Standard No. 108, which could raise a question as to their legality.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2621OpenMr. Jack Gromer, Vice President - Technical Operations, Timpte, Inc., 5990 N. Washington Street, Denver, CO 80216; Mr. Jack Gromer Vice President - Technical Operations Timpte Inc. 5990 N. Washington Street Denver CO 80216; Dear Mr. Gromer: This responds to your May 6, 1977, letter asking whether your tir information label complies with the requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, and Part 567, *Certification*. Further, you request that the National Highway Traffic Safety Administration (NHTSA) expedite treatment of Docket No. 73-31, Notice 1, which, if implemented would simplify the certification and information labels.; Concerning Docket 73- 31, the NHTSA published on June 20, 1977, notice (42 FR 31161) implementing Notice 1 which proposed the use of the designation 'all axles' rather than listing each axle individually on the certification label. The implementation of this regulation should resolve many of your problems.; Regarding the sample information label you submitted with your letter the NHTSA does not give advance approvals of compliance with Federal safety regulations or standards. We will, however, give an informal opinion of whether your label appears to comply with the requirements. The label you submitted does not appear to comply with the requirements of Part 567 or Standard No. 120. I have enclosed copies of both of these regulations for your information.; Your certification label should use the designation 'all axles' no 'each axle.' The tire and rim information should follow that designation stated in the form presented in the examples in Standard No. 120 and Part 567.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3933OpenMr. Hayley Alexander, Marketing Consultant, The LondonCoach Co., Inc., P.O. Box 1183, Mt. Clemens, MI 48043; Mr. Hayley Alexander Marketing Consultant The LondonCoach Co. Inc. P.O. Box 1183 Mt. Clemens MI 48043; Dear Mr. Alexander: This is in reply to your letter of March 25, 1985, asking for ou comments on your planned London Taxi marketing program.; Under the program, products of Carbodies Ltd. of Coventry, England would be imported 'devoid of an engine, transmission, and finished interior.' LondonCoach would then install 'an American engine, transmission and driveshaft, interior seats, coverings and details, and various exterior cosmetic trim items.' However, a 'representative' vehicle with the modifications mentioned above will have undergone all testing necessitated by the standards, at the Motor Industry Research Association in England. Vehicles would be certified by Carbodies as meeting the standards prior to importation, and LondonCoach Co., Inc., in the role of alterer, would attach the label attesting to continued compliance required by 49 CFR Section 567.7 upon completion of the modifications.; Under the National Traffic and Motor Vehicle Safety Act, certificatio of compliance of a motor vehicle can only be provided by the manufacturer or importer of a completed motor vehicle. Certification of compliance with at least four Federal motor vehicle safety standards is directly dependent upon the manner in which the Carbodies vehicles are completed by LondonCoach: Standard No. 124, *Accelerator Control Systems*, Standard No. 207, *Seating Systems*, Standard No. 301, *Fuel System Integrity*, and Standard No. 302, *Flammability of Interior Materials*. Therefore, LondonCoach is the only party who can certify compliance of the completed vehicle with Federal motor vehicle safety standards. As the manufacturer, LondonCoach is also responsible for assigning and affixing the vehicle identification number (VIN) to each vehicle, according to the requirements of Standard No. 115, *Vehicle Identification Number--Basic Requirements*, and 49 CFR Part 565, *Vehicle Identification Number--Content Requirements*.; The Carbodies products are an assemblage of items of motor vehicl equipment and should be labeled as equipment items for importation into the United States. Carbodies should certify that each item of motor vehicle equipment that is covered by a Federal motor vehicle safety standard complies with such standard. Those items are brake hoses, new pneumatic tires, brake fluid, surface glazing, seat belt assemblies, and lamps, reflective devices, and associated equipment. This certification should free LondonCoach, as the importer, from the obligation under 19 CFR 12.80 to post a compliance bond upon entry into the United States.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2271OpenMr. Roger E. Stange, President, Norton Triumph Corporation, P.O. Box 275, Duarte, California 91010; Mr. Roger E. Stange President Norton Triumph Corporation P.O. Box 275 Duarte California 91010; Dear Mr. Stange: This is in reply to your letter of April 1, 1976, which requests a interpretation of Motor Vehicle Safety Standard No. 123 as it applies to a motor-driven cycle that your company intends to import.; "The speedometer on this machine displays both minor numerals and mino graduations at 5 mph intervals. Paragraph S5.2.3 and Column 3 of Table 3 of Standard No. 123 require that, if a motorcycle is equipped with a speedometer, 'Major graduations and numerals shall appear at 10 mph intervals, minor graduations at 5 mph intervals.' S5.2.3 also states that the abbreviations used in Column 2 and 3 are j minimum requirements and 'appropriate word may be spelled in full.' It is your interpretation that 'if the abbreviations used in Column 3 are minimum requirements ... the speedometer in question meets the minimum requirements and is therefore in conformity with the standard.'"; The 'abbreviations' only refer to words and not to numerals o graduations. However, since there is no specific prohibition against providing minor numerals at the minor graduations, we have concluded that Standard No. 123 allows a motorcycle manufacturer to furnish a speedometer with them if he so chooses.; Yours truly, Stephen P. wood, Assistant Chief Counsel |
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ID: aiam3899OpenMr. Ernest Farmer, Director, Pupil Transportation, Tennessee State Department of Education, Office of Commissioner, Cordell Hull Building, Nashville, TN 37219-5335; Mr. Ernest Farmer Director Pupil Transportation Tennessee State Department of Education Office of Commissioner Cordell Hull Building Nashville TN 37219-5335; Dear Mr. Farmer: This responds to your letter to me regarding our motor vehicle safet standards for school buses. You asked several questions about Standard No. 222, *School Bus Passenger Seating and Crash Protection*, and Standard No. 301, *Fuel System Integrity*. In a telephone conversation you had on February 8, 1985, with Ms. Hom of my staff, you also asked about the safety standards that apply to vans carrying 10 or less persons that are used to transport school children.; To begin, I would like to explain that the motor vehicle safet standards issued by our agency apply to the manufacture and sale of new motor vehicles. As you know, in 1974, Congress expressly directed us to issue standards on specific aspects on school bus safety. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. A manufacturer or dealer who sells a new bus to a school must sell a bus that complies with the motor vehicle safety standards applicable to school buses.; Under our regulations, a 'bus' is defined as a motor vehicle designe for carrying 11 or more persons. 'School bus' is defined as a bus that is sold for purposes that include carrying students to and from school or related events (excluding buses sold as common carriers in urban transportation). A van type vehicle, constructed on a truck chassis, carrying 10 persons or less is classified as a multipurpose passenger vehicle (MPV). New MPV's sold to schools need not meet the school bus safety standards, since these vehicles are not buses. However, there are many motor vehicle safety standards applicable to MPV's. New MPV's must be certified by their manufacturers as complying with these safety standards. I have enclosed a list of the motor vehicle safety standards applicable to MPV's, as you requested.; The first question in your letter asked whether we require 'Type A vehicles which carry 15 to 22 passengers to comply with the provisions of Standards Nos. 222 and 301. Over the telephone, you explained that these vehicles are school buses with gross vehicle weight ratings (GVWR) of 10,000 pounds or less.; The answer to this question is yes. Standard No. 222 applies to al school buses. However, the requirements of the standard vary depending on the GVWR of the bus. Standard No. 301 applies to all school buses that use fuel with a boiling point above 32 degrees F. A new school bus must be certified as complying with the applicable requirements of these safety standards.; The first part to your second question asked, 'Does NHTSA consider 14- inch crash barrier installed in front of standard 39-inch bench seats on the right side of the aisle in these vehicles to be in compliance with FMVSS 222?'; The answer to this question is that there is no violation of Standar No. 222's restraining barrier requirements. This is because the restraining barrier requirements do not apply to school buses of 10,000 pounds or less GVWR. Paragraph S5(b) of the standard lists the requirements that apply to these smaller school buses, and the restraining barrier requirements found in paragraph S5.2 are not listed in S5(b). If a manufacturer voluntarily chooses to install a restraining barrier in these buses, there is no violation of Standard No. 222 if the barrier is not as wide as the designated seating positions behind it.; The second part of this question asked, 'Would seat belts on the fron row of seats void the crash barrier requirement in this statement for Type A vehicles? (We are aware that NHTSA requires seat belts on all Type A vehicles)'; The answer to this question is similar to that given above. Restrainin barriers on school buses with GVWR's of 10,000 pounds or less are not required by Standard No. 222. Since these smaller school buses are equipped with seat belts, the standard does not regulate seat spacing in these vehicles.; The third part of this question asked, 'Would the location of the ga tank between frame members also void the requirement in FMVSS 301 for a protection barrier?'; The answer is that Standard No. 301 sets performance requirements tha each school bus must meet, it does not require specific designs, such as a protective barrier. A manufacturer can position its gas tank at any location as long as it can meet the performance requirements of the standard at that location.; Your third question asked, 'Does NHTSA require the installation of metal shield between the exhaust system and the gas tank when such locations are 12 inches or less from each other? (Note: We have some Type A vehicles with variations of 6 to 8 inches that supposedly have NHTSA approval.)'; Neither Standard No. 301 nor any of the agency's other standards se any requirements concerning the installation of metal shields between the exhaust system and the gas tank.; If you have further questions, please do not hesitate to contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4872OpenMr. Paul R. Kirchgraber Souvenirs of the Future Suite 201-71 3435 Ocean Park Blvd. Santa Monica, CA 90405; Mr. Paul R. Kirchgraber Souvenirs of the Future Suite 201-71 3435 Ocean Park Blvd. Santa Monica CA 90405; Dear Mr. Kirchgraber: This is in reply to your letter of April 16 1991, with respect to which Federal motor vehicle safety standards, if any, must be met in order to sell an exterior tire/wheel cover with reflective characteristics that will help to make 'the vehicle more visible to the surrounding traffic.' In addition, you 'want to be certain that the reflective nature of the fabric used in this cover does not present a safety hazard', and ask for the citation to 'appropriate federal test standards from the code of federal regulations for similar automotive accessories.' There are no Federal motor vehicle safety standards that establish performance requirements for reflective material of this nature, or for wheel coverings on exterior-mounted tires. The standard on vehicle lighting, Motor Vehicle Safety Standard No. 108, does prohibit, as original equipment, the installation of a 'reflective device or other motor vehicle equipment' that impairs the effectiveness of lighting equipment required by the standard. It is theoretically possible that your material could create glare in the eyes of a following operator so that (s)he would fail to respond to a stop signal, or a turn signal. The samples submitted with your letter are too small for us to judge its reflectivity, and we suggest that you conduct your own tests, approaching a vehicle with the tire cover from the rear, with headlamps on the lower beam. This, to us, is preferable to your redesigning the material to conform to any federal test standard relating to reflectivity. Although the color of lighting equipment on the rear is generally red, with amber permitted for turn signals, and white required for back up lamps, we do not believe that the use of additional colors would create any confusion. In short, we believe that the wheel cover will be perceived for the wheel cover it is. I hope that this responds to your concerns. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0098OpenMr. John W. Carlin, Calumet Corporation, P. O. Box 389, Kaukauna, WI 54130; Mr. John W. Carlin Calumet Corporation P. O. Box 389 Kaukauna WI 54130; Dear Mr. Carlin: Thank you for your letter of July 22, 1968, to Mr. George C. Nield concerning the applicability and effective date of Motor Vehicle Safety Standard 108.; Standard No. 108 is applicable to new vehicles manufactured on or afte the effective date of the standard. Initial Standard No. 108 was published on February 3, 1967, and became effective January 1, 1968. The initial standard is applicable only to vehicles that are 80 inches or more in overall width. Revised Standard No. 108 was published on December 16, 1967, and becomes effective January 1, 1969. The revised standard is applicable to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers and motorcycles, regardless of overall width, however, the special requirements for vehicles that are 80 inches or more in overall width have been identified in the standard. Copies of the initial and revised standard are enclosed for your information.; In reply to your specific questions, information is provided a follows:; >>>1. With respect to your first question, Standard No. 108 i applicable to trailers manufactured for personal use by an individual and for commercial use.; 2. With respect to your second question, Revised Standard No. 108 effective January 1, 1969, specifies the lighting requirements for trailers that are less than 80 inches in overall width.; 3. With respect to your third question, the regulations of individua States and of the Bureau of Motor Carrier Safety (for vehicles engaged in interstate commerce) presently govern the lighting required on trailers that are less than 80 inches in overall width. Effective January 1, 1969, these trailers will be subject to the requirements of Revised Standard No. 108. Installation and location requirements for the individual lamps are contained in the referenced SAE standards (see Table III of Standard No. 108) and in Table IV of Standard No. 108.<<<; Also enclosed is a copy of the notice of 'Certification Requirement, which provides information on the manufacturer's certification of vehicles that are subject to the Federal motor vehicle safety standards.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam0562OpenMr. Paul M. Frank, Blumberg, Singer, Ross, Gottesman & Gordon, 245 Park Avenue, New York, NY, 10017; Mr. Paul M. Frank Blumberg Singer Ross Gottesman & Gordon 245 Park Avenue New York NY 10017; Dear Mr. Frank: In response to your letter of December 9, 1971, it is correct tha Standard No. 302, 'Flammability of Interior Materials,' applies only to motor vehicles (passenger cars, multipurpose passenger vehicles, trucks, and buses) manufactured on or after September 1, 1972. The standard does not apply to replacement or aftermarket seat covers.; Sincerely, Richard B. Dyson, Assistant 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.