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: aiam2135OpenFile; File; On December 1, 1975, I received a telephone call from Mr. Nakajima o Bridgestone Tire Co. (213-320-6030) concerning the meaning of the March 1, 1975, effective date of Standard No. 119. He wanted confirmation that tires, for vehicles other than passenger cars, that were manufactured before that date are not subject to the standard's labeling requirements. I explained that his understanding was correct, citing 49 CFR S571.7.; Mark Schwimmer |
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ID: aiam0108OpenMr. Stephen E. O'Toole, National Highway Users Conference, National Press Building, Washington, DC 20004; Mr. Stephen E. O'Toole National Highway Users Conference National Press Building Washington DC 20004; Dear Mr. O'Toole:#Thank you for your letter of August 23, to Mr. Georg Nield, concerning the compliance of crane carriers and fire engines with Federal Motor Vehicle Safety Standards 103 and 104.#The crane carrier you have described is a 'motor vehicle' subject to the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. For purposes of the Federal Motor Vehicle Safety Standards the described crane carrier is classified as a 'truck.' Although currently Federal Standards 103 and 104 do not apply to trucks both standards, by amendment, issued April 24, 1968, (33 F.R. 6466-69), will be applicable to trucks manufactured on or after January 1, 1969.#Similarly, a fire truck is a 'motor vehicle' and a 'truck' and subject to all Federal Motor Vehicle Safety Standards applicable to this category of vehicle, including Standards 103 and 104. However, the open cabs found on many fire trucks may make full compliance with Standard 103 impossible. A public docket, Docket No. 24, has been established to receive comments pertaining to the possible classification of fire fighting equipment as a separate vehicle category which might be exempt from certain standards.#Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations; |
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ID: aiam1349OpenMr. Gorou Utsunomiya, Branch Manager, Toyo Kogyo U.S.A., Suite 462, 23777 Greenfield Road, Southfield, MI 48075; Mr. Gorou Utsunomiya Branch Manager Toyo Kogyo U.S.A. Suite 462 23777 Greenfield Road Southfield MI 48075; Dear Mr. Utsunomiya: This is in reply to your letter of December 6 to Mr. Lewis Owen of thi Office concerning the use of a special parking lamp bulb in one of your tail lamp assemblies.; The location of the subject bulb in the lamp assembly, regardless o whether the switch is removed to make it inoperative, is permitted, providing that the other required lamps function as specified in Federal Motor Vehicle Safety Standard No. 108.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam3374OpenMr. Clint Moye, Assistant Director, Motor Vehicle Division, State Revenue Department, Room 101, Trinity Washington Building, Atlanta, GA 30334; Mr. Clint Moye Assistant Director Motor Vehicle Division State Revenue Department Room 101 Trinity Washington Building Atlanta GA 30334; This is in response to your request on the adequacy of the Georgi certificate of title for use in lieu of a separate Federal odometer form.; As you know, the Federal odometer requirements that became effective a of January 1, 1978, have been substantially increased. We have made provision for those states that wish to include odometer information on their titles to use a shortened form that was adopted by the American Association of Motor Vehicle Administrators (AAMVA). We consider the AAMVA form to include the minimum amount of information ncessary for an adequate disclosure.; In addition to the information included on the sample title which yo submitted to our office, the buyer's signature is also required. If this signature is included, the title may be used in lieu of a separate Federal form.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam1719OpenMr. Helmuth von Beckman, Technical Director, Tamper, Inc., 2401 Edmund Road, West Columbia, SC 29169; Mr. Helmuth von Beckman Technical Director Tamper Inc. 2401 Edmund Road West Columbia SC 29169; Dear Mr. von Beckman: This responds to your November 22, 1974, request for a determination o whether Tamper Corporation's products qualify as motor vehicles subject to Standard No. 121, *Air brake systems*. All of the vehicles you describe are designed only for use on a rail or rails, except for the Kal-Trac switcher, which has both steel wheels for rail use and pneumatic tires for highway use.; I have enclosed a discussion of our regulatory authority over moto vehicles which explains that all of your products which operate exclusively on a rail or rails are not subject to our regulations.; In a December 9, 1974, telephone call with Mr. Herlihy of this office you stated that the Kal- Trac switcher has axles with a gross axle weight rating (GAWR) in excess of 29,000 pounds. I enclose a copy of an NHTSA proposal that would exempt such a vehicle from Standard No. 121. We will consider your letter as support for this proposal.; Please contact Mr. Herlihy by phone (202-426-9511) after January 15 1975, to be advised if this proposal has been made final as an exemption for your vehicles from the standard.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam3724OpenMr. Chuck Howard, President, Safety Alert Co., Inc., 1667 9th Street, Santa Monica, CA 90404; Mr. Chuck Howard President Safety Alert Co. Inc. 1667 9th Street Santa Monica CA 90404; Dear Mr. Howard: This is in reply to your letter of June 28, 1983, occasioned by wha you believe is our misconception of the way your 'Safety Alert' system operates. In my letter of June 17 I stated that 'Safety Alert', which was intended to flash a yellow bulb installed in the backup lamp system, would create a noncompliance with Standard No. 108 which requires backup lamps to be white in color and steady burning when in use. You now bring it to our attention that your system does not alter the normal operation of the backup lamps which are steady burning when a vehicle is in reverse, even when 'Safety Alert' is installed.; We understood this when we advised you that you could use 'Safet Alert' through any rear lighting system which Standard No. 108 allows to flash for signalling purposes such as the hazard warning or turn signal systems. The converse of this is that 'Safety Alert' cannot be used through any rear lighting system that Standard No. 108 requires to be steady-burning when in use, such as the backup lamp system, even though when used as a backup lamp it is steady burning. I am sorry this was not clear to you.; We are unaware that any foreign manufacturer is failing to comply wit Standard No. 108 by installing a backup lamp system that 'reflects amber' as you have told us.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2836OpenMr. Charles Pfaff, Motor Vehicle Administration, Maryland Department of Transportation, 6601 Ritchie Highway, N.E., Glen Burnie, MD 21062; Mr. Charles Pfaff Motor Vehicle Administration Maryland Department of Transportation 6601 Ritchie Highway N.E. Glen Burnie MD 21062; Dear Mr. Pfaff: Thank you for your letter of June 16, 1978, requesting our opinion o whether the Maryland Certificate of Title meets the Federal requirements for the odometer disclosure form as set forth in 49 CFR Part 580.; The proposed Certificate of Title which you enclosed with your lette differs from the Federal odometer disclosure form in the following ways:; (1) The Maryland Certificate of Title shortens the reference to th Federal law,; (2) the set of certifications relating to the distance that the vehicl has travelled are shortened by adopting language similar to that recommended by the American Association of Motor Vehicle Administrators,; (3) the certifications relating to alteration of the odometer ar deleted, and; (4) although the transferee is required to sign the statement, th signature does not specifically acknowledge receipt of a copy of the statement, as is required by the Federal law.; The National Highway Traffic Safety Administration (NHTSA) has reviewe Maryland's proposed Certificate of Title and has determined that it will further the goal of the Federal odometer law, despite its differences from the Federal form. Therefore, pursuant to 49 CFR S 580.4(f)(2), I hereby grant your request to use Maryland's Certificate of Title as a substitute for the Federal odometer disclosure form.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam5023OpenMr. Neil Friedkin Attorney at Law 325 Exterior Street Bronx, NY 10451; Mr. Neil Friedkin Attorney at Law 325 Exterior Street Bronx NY 10451; "Dear Mr. Friedkin: This responds to your follow-up letter to th agency requesting that the agency provide 'the applicable 1986 standard for convertible passenger cars.' In an earlier letter, you had asked about our regulations with respect to converting a vehicle from a hardtop to a convertible. I am pleased to have this opportunity to respond to your inquiry. To begin, there is no single standard applicable to convertible passenger cars, or any other motor vehicles. Instead, the National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. We have exercised this authority to establish many standards that apply to passenger cars, including convertible passenger cars. These standards, which are collectively called the Federal motor vehicle safety standards, are set forth in 49 CFR Part 571. They cover many different vehicle systems, including controls and displays, vehicle lighting, braking, occupant crash protection, and fuel system integrity. As you review the safety standards in Part 571 to see which aspects of performance are of particular interest to you, you will see that the standards are generally identical for passenger cars and convertible passenger cars. There are some differences, however, including the permissible location for the center high mounted stop lamp (S5.3.1.8 of Standard No. 108, Lamps, Reflective Devices and Associated Equipment) and the inapplicability of the roof crush standard to convertibles (S3 of Standard No. 216, Roof Crush Resistance). Additionally, Standard No. 208, Occupant Crash Protection, required the front outboard seating positions of 1986 passenger cars that were not equipped with automatic crash protection (either air bags or automatic belts) to be equipped with a lap/shoulder belt and all other seating positions to be equipped with either a lap belt or a lap/shoulder belt (S4.1.2.3.1 of Standard No. 208). However, convertible passenger cars were permitted to offer either a lap belt or a lap/shoulder belt at every designated seating position, including the front outboard positions (S4.1.2.3.2 of Standard No. 208. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0221OpenJohn S. Cushman, Esq.,Special Assistant Attorney General, Consumer Division, 102 State Capitol, St. Paul, Minnesota 55101; John S. Cushman Esq. Special Assistant Attorney General Consumer Division 102 State Capitol St. Paul Minnesota 55101; Dear Mr. Cushman: Your letter of February 16, 1979, transmitting Mr. John M. Schneider' letter, concerning tire selection for his 25,500-lb. GVW Truck, to the Federal Trade Commission has been referred to the National Highway Safety Bureau for reply.; There are no Federal standards at the present time for Tire Selectio and Rims for trucks. We are currently in the rule making phase to establish such a standard, however, we anticipate the effective date of this standard to be more than a year in the future.; The lack of Federal Standards in no way relieves a vehicle manufacture from his responsibility to design vehicles with equipment that will perform safely. this was evidenced in recent negotiations between General Motors and the National Highway Safety Bureau on a problem concerning three piece Kelsey-Hayes wheels. As you may know, at present, there are no standard covering wheel performance.; Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs; |
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ID: aiam5473OpenMr. Ed Irvine Midwest Conservation Systems P.O. Box 397 Silver Lake, KS 66539; Mr. Ed Irvine Midwest Conservation Systems P.O. Box 397 Silver Lake KS 66539; Dear Mr. Irvine: This responds to your letter asking whether a newl manufactured commercial utility trailer must be equipped with an emergency breakaway system. You state that your customer wishes to purchase a trailer without the battery powered breakaway system that comes with the trailer. Instead, you would like to install your solar energized breakaway system. In a December 7, 1994 telephone conversation with Mr. Marvin Shaw of my staff, you stated that the trailers in question are typically small utility trailers that do not rely on the use of air pressure. I am pleased to have this opportunity to explain the applicable requirements issued by this agency, the National Highway Traffic Safety Administration (NHTSA). You may also wish to request an interpretation of 49 CFR 393.43 from the Federal Highway Administration (FHWA), which is the agency that issued that regulation. By way of background information, NHTSA and FHWA are both part of the United States Department of Transportation. Each agency has the authority to issue regulations related to your question. NHTSA, which regulates newly manufactured vehicles, has the authority to issue Federal motor vehicle safety standards (FMVSS) which apply to new motor vehicles and new items of motor vehicle equipment. FHWA, which regulates the use of commercial motor vehicles, has the authority to issue Federal Motor Carrier Safety Regulations (FMCSRs), which are applicable to commercial motor vehicles and their operators. We have referred your letter to the Federal Highway Administration's (FHWA) Office of Motor Carrier Standards, since that agency issued 49 CFR 393.43. While NHTSA has the authority to issue FMVSSs, the agency has not issued any FMVSS that would directly affect the braking performance of a small utility trailer, unless the trailer relies on air pressure. Therefore, if the trailers in question are not air braked vehicles, then you would not need to certify that such a trailer's braking performance complies with an FMVSS, since no applicable FMVSS exists. Please note that your solar energized trailer breakaway system would be considered 'motor vehicle equipment' within the meaning of the statute administered by NHTSA. If this system contained a defect (either in manufacture, design, or performance) that relates to motor vehicle safety, the manufacturer would be required to conduct a recall campaign to notify owners and to remedy the defect free of charge. I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. If you wish to contact someone in the FHWA's Office of Chief Counsel concerning the motor carrier standards, please call Charles Medalen at (202) 366-1354. Sincerely, Philip R. Recht 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.