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: aiam3354OpenMr. Rodney Ehrlich, Director of Engineering Monon Trailer Division, Evans Transportation Company, 117 North Walnut, P.O. Box 655, Monon, Indiana 47959; Mr. Rodney Ehrlich Director of Engineering Monon Trailer Division Evans Transportation Company 117 North Walnut P.O. Box 655 Monon Indiana 47959; Dear Mr. Ehrlich: This will confirm your telephone conversation with Mr. Frederi Schwartz of my office concerning your proposed compliance scheme for the Federal Motor Vehicle Safety Standard No. 115 - Vehicle identification number.; The National Highway Traffic Safety Administration (NHTSA) does no give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115. This system may be implemented immediately.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4491OpenMr. Richard J. Matysiak President Auto Chek, Inc. P.O. Box 258 Stone Mountain, GA 30086-0258; Mr. Richard J. Matysiak President Auto Chek Inc. P.O. Box 258 Stone Mountain GA 30086-0258; "Dear Mr. Matysiak: This responds to your letter to Mr. Frank Ephrai of our Office of Plans and Policy, asking about the effects of the Federal Motor Vehicle Theft Prevention Standard (49 CFR Part 541, copy enclosed) on certain body repair processes. Specifically, you asked how the theft prevention standard would affect the body repair process of 'clipping' body sections from one vehicle and attaching the clipped section to a different vehicle. This repair process is not prohibited or regulated by the theft prevention standard, as explained below. The purpose of the theft prevention standard is to reduce the incidence of motor vehicle thefts by facilitating the tracing and recovery of parts from stolen vehicles. To achieve this purpose, the theft prevention standard requires manufacturers to affix or inscribe identification markings onto 14 major original equipment and replacement parts of certain high theft cars. Dealers and repair shops are prohibited from removing, obliterating, tampering with, or altering these identification markings, unless the removal, obliteration, tampering, or alteration is reasonably necessary to repair the part or vehicle, see 18 U.S.C. 511. These requirements should not significantly impact the repair process of 'clipping' described in your letter. Nothing in the theft prevention standard or the law prohibits a repair shop from clipping sections from wrecked vehicles. The repair shop would be required by law to leave in place any identification markings on the 'clipped' section that were not damaged in the 'clipping' process. As noted in your letter, the repaired vehicle might have two different vehicle identification numbers (VIN's) marked on its major parts, with some parts marked with the VIN assigned to the repaired vehicle and other parts marked with the VIN assigned to the damaged vehicle from which the section was 'clipped.' The Motor Vehicle Theft Law Enforcement Act of 1984, which ordered this agency to promulgate the theft prevention standard, clearly contemplates that vehicles undergoing repair could wind up with some parts numbered differently than the parts originally on the car. That law is based on the idea that some major parts are likely to survive a crash undamaged and that those parts can legitimately be used to repair other vehicles. Such repairs would naturally result in repaired cars having some parts numbered differently than the rest of the car. Since the law enforcement community vigorously supported this law, they must not have believed that cars with some parts numbered differently than the other parts of the car would pose particular problems for them. You also asked how the 'clipping' process would affect our disclosure and titling requirements. We answered the question of how the disclosure requirements apply in an October 15, 1980 letter to Mr. John Kelly of the Iowa Department of Transportation. In the letter to Mr. Kelly, we said, '... if a vehicle is constructed from the parts of several vehicles, the odometer statement must still be completed at the time of sale. If the seller knows the mileage on the various components used to construct the vehicle, he should inform the purchaser of the highest mileage that he knows, or the mileage on the chassis if he knows it. If he does not know the mileages, he will be required to state that the mileage is not accurate and should not be relied upon. Titling requirements and designations such as 'salvage' and 'rebuilt' vehicles are determined by State law, not Federal law. If you have any further questions on this matter, please contact Steve Kratzke of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam1369OpenMr. Danny Lanzdorf,Oshkosh Truck Corporation,2307 Oregon St.,Oshkosh, Wisconsin 54901; Mr. Danny Lanzdorf Oshkosh Truck Corporation 2307 Oregon St. Oshkosh Wisconsin 54901; Dear Mr. Lanzdorf:#This is to confirm your conversation of December 12 1974, with Mark Schwimmer of this office, in which you requested information on the permissibility of spray painting brake hose end fittings in the trucks which you manufacture.#Because the construction of the brake hose assembly is completed before the spray painting would take place, the only requirement of Motor Vehicle Safety Standard No. 106-74 which might prohibit the painting would be a vehicle requirement. Standard No. 106-74 as applied to vehicles is not effective until September 1, 1975, therefore, you may spray paint end fittings until then. The next Federal Register notice concerning the standard will deal with the permissibility of painting end fittings after the September, 1975 effective date.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam3704OpenMr. H. Nakaya, Manager, Mazda (North America) Inc., 23777 Greenfield Road - Suite 462, Southfield, MI 48075; Mr. H. Nakaya Manager Mazda (North America) Inc. 23777 Greenfield Road - Suite 462 Southfield MI 48075; Dear Mr. Nakaya: This is in reply to your letter of May 24, 1983, asking whether th headlamp bezel is considered a 'styling ornament or other feature' for purposes of paragraph 5.2 of SAE J580 *Sealed Beam Headlamp Assembly*, Aug 79 incorporated by reference in Standard No. 108.; The referenced SAE paragraph prohibits styling ornaments or othe features in front of the lens when the headlamp is in use. The intent of this paragraph is to guarantee optimum light output from the headlamp by insuring that no part of the vehicle interferes with the light pattern. If a headlamp bezel is so large that it could interfere with the design light patterns of the lamp, we would consider it a 'styling ornament or other feature' within the meaning of paragraph 5.2.; An oversize bezel interfering with light output would also b prohibited by paragraph S4.1.3 of Standard No. 108 which prohibits installation of motor vehicle equipment that impairs the effectiveness of lighting equipment which the standard requires.; I hope that this answers your question. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1739OpenMr. Harry J. Warmkessel,Mack Trucks, Inc.,Box M,Allentown, Pennsylvania 18105; Mr. Harry J. Warmkessel Mack Trucks Inc. Box M Allentown Pennsylvania 18105; Dear Mr. Warmkessel:#This responds to the August 1, 1974, request o Mack Trucks, inc., that the painting of brake hose end fittings be permitted under the Federal Motor Vehicle Safety Standards No. 106-74.#In the preamble to amendments to the standard which were published June 28, 1974 (39 FR 24012, Docket No. 1-5, Notice 11), the NHTSA interpreted S5.2.3 as prohibiting the painting of end fittings because required labeling would be obscured.#New information indicates that spray painting of end fittings leaves their labeling visible in most cases and that, in the occasional instance where labeling is obscured, excess paint may be easily scraped off. In addition, painting protects the labeled and fittings against corrosion. Therefore, the NHTSA is changing its interpretation of this section, so that the painting of end fittings will not be considered a violation of the standard.#The issue of masking brake hose labeling will be dealt with in the next Federal Register Notice regarding Standard No. 106-74.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2816OpenMr. Robert J. Voshell, Director, Motor Vehicle Division, State of Delaware, P.O. Box 698, Dover, DE 19901; Mr. Robert J. Voshell Director Motor Vehicle Division State of Delaware P.O. Box 698 Dover DE 19901; Dear Mr. Voshell: This is in reply to your letter of May 18, 1978 which asks th following questions:; >>>'Is there a Motor Vehicle Safety Standard which requires al motorcycles to be equipped with turn signals, other than those expressly exempted under FMVSS 108 (whose speed attainable in 1 mile is 30 mph or less) S4.1.1.26?'<<<; Yes. Paragraph S4.1.1 of Standard No. 108 requires, in part, that moto vehicles be equipped with the lamps specified in Table III. Turn signal lamps are required for motorcycles under Table III.; >>>'Does the standard apply to only highway-use vehicles wit trail-bikes exempted?'<<<; Yes. The motorcycles covered by Standard No. 108 must be 'moto vehicles' in the first instance, in order to be subject to the regulatory authority of the National Traffic and Motor Vehicle Safety Act. A 'motor vehicle' is one 'manufactured primarily for use on the public streets, roads and highways'. This would exclude a trail bike unless its manufacturer had certified it to meet all applicable Federal motor vehicle safety standards, indicating his intent that it be used on-road as well as off-road.; We are enclosing a copy of Standard No. 108 as you requested. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3211OpenMr. 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: aiam4184OpenMr. William H. Spain, National Management, Inc., P.O. Box 3528, Montgomery, AL 36109; Mr. William H. Spain National Management Inc. P.O. Box 3528 Montgomery AL 36109; Dear Mr. Spain: Thank you for your letter of May 20, 1986, asking how our regulation would apply to a wooden steering wheel you manufacture. You explained that you use a standard steering wheel with a steel outer rim. The steel outer rim is then veneered with wood, which is covered with a protective finish. The finished wheel will then be used as an item of original equipment by a vehicle manufacturer. I hope the following discussion answers your question.; The agency has issued two Federal Motor Vehicle Safety Standards tha set occupant crash protection performance requirements for vehicle steering systems, which includes the steering wheel. Those standards are Standard No. 203, *Impact Protection for the Driver from the Steering System*, and Standard No. 204, *Steering Column Rearward Displacement*. Those two standards do not regulate the types of material that may be used in the steering wheel, but instead set performance requirements that the steering systems must meet under certain test conditions. Therefore, a manufacturer may use any material in its steering wheel, as long as the steering system still complies with the performance requirements of Standard Nos. 203 and 204.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3641OpenCharles R. Sidner, CPSM, Product Safety Engineer, Grumman Flxible Corporation, 970 Pittsburgh Drive, Delaware, OH 43015; Charles R. Sidner CPSM Product Safety Engineer Grumman Flxible Corporation 970 Pittsburgh Drive Delaware OH 43015; Dear Mr. Sidner: This responds to your March 31, 1983, letter asking about the lo-ai pressure warning device that is required by Standard No. 121, *Air Brake Systems*. In particular you ask whether the requirement must be met with two switches, one on the primary and one on the secondary air tank, or whether one switch on the supply tank would be sufficient.; S5.1.5 of the standard states that a warning signal shall be provide to give a continuous warning of a loss of pressure in the service reservoir system below 60 p.s.i. The intent of the section clearly is to provide a warning to a driver of any instance that results in a loss of pressure in either the primary or secondary service reservoir system.; Depending upon the design of any individual brake system, it might b necessary for more than one switch to ensure that the driver will be alerted to such an air loss. For example, a single switch on the supply tank might be inadequate to signal a loss of pressure in the primary or secondary service reservoir system if the action of the compressor masks such loss of pressure. It is up to the manufacturer to determine whether its system is designed in a way that requires more than one switch.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2953OpenMr. Hisakazu Murakami, Staff, Safety, Nissan Motor Co., Ltd., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Hisakazu Murakami Staff Safety Nissan Motor Co. Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Murakami: This responds to your January 9, 1979, letter concerning a mistake o the certification labels of approximately 2000 Datsun trucks. You stated that the vehicles, although manufactured in 1979, were incorrectly dated on their certification labels as being manufactured in 1978. You propose to remedy the affected vehicles by crossing out the incorrect date and inserting the correct information.; Your proposed correction is acceptable to the National Highway Traffi Safety Administration. As long as all other information on the certification label is correct, your modification of existing certification labels will comply with the agency's regulations.; Sincerely, Joseph J. Levin, Jr., 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.