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: aiam3349OpenMr. William Blythe, 1545 University Avenue, Palo Alto, CA 94301; Mr. William Blythe 1545 University Avenue Palo Alto CA 94301; Dear Mr. Blythe: This responds to your recent letter asking questions concerning th test procedures of Safety Standard No. 216, *Roof Crush Resistance* (49 CFR 571.216). Specifically, you are concerned with the proper applications of the test block forces specified in paragraphs S6.3 and S6.2(d) of the standard.; Your first question asks whether paragraph S6.3 allows the force on th test block to be applied 'essentially opposite the initial contact point of the roof to the block.' Paragraph S6.3 specifies that the force required by the standard shall be applied in a downward direction to the lower surface of the test device. Figure 1 of the standard illustrates this procedure and indicates that the force is to be centrally applied to the loading block. This procedure will be followed during tests by the agency to determine the compliance of particular passenger cars with Safety Standard No. 216. Therefore, we would not recommend that you apply the force opposite the initial contact point of the test block with the roof.; Paragraph S6.2(d) of the standard specifies that the initial contac point (with the roof) is on the longitudinal centerline of the lower surface of the test device and 10 inches from the forwardmost point of the centerline. Your second question asks whether this 10-inch dimension should be maintained if this places the leading edge of the test device behind the leading edge of the roof and the A-pillars. You state that this would occur with certain roof configurations which tend to be high in the center (i.e., in which the leading edge of the roof is not the highest point of the roof). A manufacturer should adhere to the 10-inch dimension even if this means the leading edge of the test device will not be forward of the A-pillar and the roof's forward edge. The test procedures specified are standardized procedures which the agency applies to all passenger cars regardless of roof configuration. Thus, the agency would maintain the 10-inch dimension even when testing a roof with a higher center than its leading edge.; I would like to point out, however, that the test procedures specifie in the safety standards only document how the agency will conduct its compliance tests. Manufacturers are not required to test vehicles according to the procedures specified. A manufacturer's responsibility is to exercise due care to ascertain that its vehicles are in fact in compliance with the standards (15 U.S.C. 1397). If you are convinced that the procedures mentioned in your letter would accurately test the compliance of a particular vehicle with Safety Standard No. 216, you are certainly permitted to use those procedures. It is up to the manufacturer, however, to determine whether it has in fact exercised due care to determine compliance.; I hope this has been responsive to your inquiry. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5619OpenThe Honorable Bart Stupak U.S. House of Representatives 902 Ludington St. Escanaba, MI 49829; The Honorable Bart Stupak U.S. House of Representatives 902 Ludington St. Escanaba MI 49829; Dear Mr. Stupak: Thank you for your letter enclosing correspondenc from your constituent, Mr. Kurt B. Ries, concerning our requirements for school vehicles. Your letter was referred to the National Highway Traffic Safety Administration (NHTSA) for reply, since NHTSA regulates the manufacture of all vehicles, including vans and school buses. Mr. Ries, Director of the Northeast Michigan Consortium, asks for relief from what he believes is a new Federal regulation. The Northeast Michigan Consortium uses a number of 15-passenger vans to transport students to employment training programs and jobs. Mr. Ries believes the new Federal regulation will require all vehicles transporting students, including vans, to be replaced with 'mini-school buses,' which he believes is economically unfeasible. I appreciate this opportunity to address your constituent's concerns. As explained below, the new regulation that Mr. Ries is concerned about is not a Federal regulation, but one that Michigan is considering adopting as State law. NHTSA has issued safety standards applicable to new motor vehicles, including school buses. Under our regulations, a 'school bus' is a vehicle carrying 11 or more persons, that is sold to transport children to school or school-related events. Congress has directed NHTSA to require school bus manufacturers to meet safety standards on aspects of school bus safety, including floor strength, seating systems, and crashworthiness. Each seller of a new school bus must ensure that the vehicle is certified as meeting these safety standards. While NHTSA regulates the manufacture and sale of new school buses, this agency does not regulate the use of vehicles. Thus, we do not have a present or pending requirement that would require Mr. Ries to cease using his vans for school transportation. The requirements for the use of school buses and other vehicles are matters for each State to decide. We understand from Mr. Roger Lynas, the State Pupil Transportation Director in Michigan, that Michigan is considering changing its school bus definition to make it more similar to NHTSA's. Such an amendment could affect what vehicles can be used for school transportation under State law. For more information about Michigan's proposed amendment, we suggest Mr. Ries contact Mr. Lynas at (517) 373-4013. NHTSA does not require States to permit only the use of 'school buses' when buses are used for school transportation. However, we support State decisions to do so. NHTSA provides recommendations for the States on various operational aspects of school bus and pupil transportation safety programs, in the form of Highway Safety Program Guideline No. 17, 'Pupil Transportation Safety,' copy enclosed. Since school buses have special safety features that conventional buses do not have, such as padded, high-backed seats, protected fuel tanks, and warning lights and stop arms, they are the safest means to transport school children. Guideline 17 recommends that all buses regularly used for student transportation meet our school bus safety standards. I hope this information is helpful. If you have any further questions, please do not hesitate to contact me. Sincerely, Carol Stroebel Director of Intergovernmental Affairs Enclosure; |
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ID: aiam2426OpenMs. Valerie Hood, Triplex Safety Glass Co., Eckersall Road Kings Norton, Birmingham B38 8SR, England; Ms. Valerie Hood Triplex Safety Glass Co. Eckersall Road Kings Norton Birmingham B38 8SR England; Dear Ms. Hood: This is in response to your September 8, 1976, letter requestin information concerning the Federal regulations that would be applicable to safety glazing for use in 'slow moving' vehicles. Please excuse our delay in answering your questions. Apparently, your earlier letter of February 5, 1976, was misplaced.; Standard No. 205, *Glazing Materials*, specifies requirements fo glazing materials for use in most motor vehicles and motor vehicle equipment. A glazing manufacturer must certify any glazing that is to be used in a motor vehicle (other than a trailer) as being in compliance with Standard No. 205. 'Motor vehicle' is defined in S 102(3) of the National Traffic and Motor Vehicle Safety Act of 1966. I am enclosing a copy of the agency's opinion of what vehicles qualify as 'motor vehicles' under the definition. Glazing material that is to be used in a vehicle that does not qualify as a 'motor vehicle' does not have to meet the performance requirements of Standard No. 205.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5249OpenMr. Richard Glover Evenflo Juvenile Furniture Co. 1801 Commerce Dr. Piqua, OH 45356; Mr. Richard Glover Evenflo Juvenile Furniture Co. 1801 Commerce Dr. Piqua OH 45356; "Dear Mr. Glover: This responds to your letter and telephone call about the child seat registration form you are considering. The form is required by S5.8 of Standard 213, 'Child Restraint Systems,' and is depicted in figures 9a and 9b of the standard. You ask whether S5.8(c) permits you to place certain additional information in the shaded area on the form. The information is a bar code that you said on the telephone contains information on 'date of manufacture, shift, location and serial number for the product that the card represents.' You explain that the bar code is desired because it can be automatically scanned, which would avoid possible 'mis-keying' of the information into the data record. Further, you state that the bar code has to be surrounded by a slightly larger unshaded 'quiet zone' to enable the scanner to record the bar code information. You are concerned whether NHTSA would conclude that the quiet zone renders a part of the shaded area unshaded. It is our opinion that a bar code that contains the information you described is permitted in the shaded area (the area outside of the space for the consumer to fill in). S5.8(c) of Standard 213 specifies the information that must be provided on the form and states the following: No other information shall appear on the postcard, except identifying information that distinguishes a particular child restraint system from other systems of that model name or number may be preprinted in the shaded area of the postcard, as shown in figure 9a. The bar code, printed in the shaded area, is permitted by S5.8(c). The information provided by the bar code distinguishes a particular child seat from another of the same model name or number. We consider the quiet zone as part of the bar code since it is needed for the bar code to be reliably read. The quiet zone therefore need not be shaded, since the printed bar code (or any other identifying information permitted by S5.8(c)) itself is not. Please note that, while the bar code is permitted, the information on the model name or number and date of manufacture must still be in English under S5.8(c). This information must be in English so that a consumer can see that this information has been provided and that only minimal effort is needed to fill out the registration form. We also wish to note another feature of the form you faxed. Your form has the words 'please print' after the instructions to the consumer 'just fill in your name and address.' 'Please print' is not on the form depicted in figures 9a and 9b of Standard 213. In an earlier letter, NHTSA decided that a minor variation in the wording of a warning expressly specified by Standard 213 was permitted when the change clarified the warning and did not make any substantive change to the warning's meaning. (Letter to Mr. McGuigan, December 18, 1980.) Similarly, 'please print' is a minor variation to the wording of the instructions that clarifies the instructions and does not substantively change them. Thus, it is permitted. I hope this information is helpful. Please call Ms. Fujita at (202) 366-2992 if you have further questions. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2076OpenMr. Douglas S. McClenahan, President, Charter Arms Corporation, 430 Sniffens Lane, Stratford, CT 06497; Mr. Douglas S. McClenahan President Charter Arms Corporation 430 Sniffens Lane Stratford CT 06497; Dear Mr. McClenahan: This is in response to your letter of September 16, 1975, inquirin whether approval from the Federal Government is necessary before selling motorcycles manufactured by you.; No approval is necessary in order to market your motorcycles. However you should be aware of the regulations governing manufacturer identification and vehicle certification. Each manufacturer who begins to manufacture motor vehicles must submit certain information to the National Highway Traffic Safety Administration describing the type of motor vehicle manufactured (49 CFR Part 566, copy enclosed). In addition, each vehicle must be certified as being in compliance with all applicable Federal Motor Vehicle Safety Standards in effect at the time of manufacture (49 CFR Part 567, copy enclosed).; If you have any further questions, please contact us. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4008OpenMr. Sam Verma, President, Erincraft Mfg. Co., Inc., 742 East 8th Street, Michigan City, IN 46360; Mr. Sam Verma President Erincraft Mfg. Co. Inc. 742 East 8th Street Michigan City IN 46360; Dear Mr. Verma: This responds to your letter of August 6, 1985, asking how to obtain 'DOT number,' so that your company can import truck tires into the United States from a plant in India. The procedures to be followed are set forth in 49 CFR Part 574, *Tire Identification and Recordkeeping*, a copy of which is enclosed for your information.; That regulation requires every tire sold in this country to be labele with certain information (see S574.5), including the identification mark assigned to the manufacturer. To obtain an identification mark, the actual manufacturer of the tires should provide the information specified in S574.6 of the regulation. Please note that an identification mark will be assigned only to the actual manufacturer of tires, and not to companies importing those tires. This is because S574.5 requires that this identification mark be *molded* into or onto all new tires. The only party which can mold the mark on the tire is the actual manufacturer. Therefore, the entity which owns the tire plant in India must apply for the identification mark. An identification mark is normally assigned within two weeks after the receipt of such a request.; The owner of the tire plant in India should also be aware of procedural rule which applies to all parties subject to the regulations of this agency, 49 CFR Part 551 (copy enclosed). This rule requires all manufacturers headquartered outside of the United States to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. The agency may be either an individual or a business entity. The identification mark required by Part 574 will *not* be assigned until this agency has received a valid designation of agent from the Indian tire manufacturer. Part 551 specifies that the designation of agent must contain the following six items of information:; 1. A certification that the designation is valid in form and binding o the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made,; 2. The full legal name, principal place of business and mailing addres of the Indian tire manufacturer,; 3. Marks, trade names, or other designation of origin of any of th manufacturer's tires which do not bear its name,; 4. A statement that the designation shall remain in effect unti withdrawn or replaced by the Indian tire manufacturer.; 5. A declaration of acceptance duly signed by the agent appointed b the Indian tire manufacturer, and the agent may be an individual or a U.S. firm or corporation, and; 6. The full legal name and address of the designated agent. If you need any further information or a clarification of some of th information set forth in this letter, please contact Steve Kratzke of my staff at this address or by telephone (202) 426-2992.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam3237OpenMr. Francois Louis, Governmental Affairs, Renault USA, 14250 Plymouth Road, Detroit, MI 48232; Mr. Francois Louis Governmental Affairs Renault USA 14250 Plymouth Road Detroit MI 48232; Dear Mr. Louis: This responds to your letter of March 3, 1980, requesting a interpretation concerning the proper designated seating capacity for the rear seat in the Renault Le Car vehicle. You state that the rear seat of the Le Car has 48.2 inches of hip room, and ask whether the vehicle would qualify as having only two designated seating positions.; I am enclosing a copy of a letter of interpretation the agency recentl issued to Toyota Motor Company regarding the designated seating capacity of the rear seats in several of its models. The rear-seat designs of these Toyota models are very similar to the Le Car, in that the presence of wheel wells results in hip room measurements below 50 inches under the strict measurement technique specified in the definition of 'designated seating position' (SAE J1100a). As was pointed out in that letter, however, if occupants move their hips slightly forward of the wheel wells, which extend only a few inches out into the seat, there is over 50 inches of usable hip room in these vehicles.; Your letter states that the close proximity of the two inboard portion of the rear seat belt assemblies in the Le Car indicates that only two positions are intended by the manufacturer. The agency would give more credence to this factor if the inboard portions of the belt assemblies were on stiff, immovable cables (or similar design). With the current design, a person wishing to sit in the center position can easily move the belts out of the way, so the belts are not real impediments to use of the center position.; In answer to your ultimate question, the agency must conclude that th rear seat in the Le Car vehicle could qualify as having only two designated seating positions since the hip room is below 50 inches according to the technical measurement procedure specified in the standard. However, we think this is an extremely close case since there is over 48 inches of hip room even between the wheel wells and greater than 50 inches of hip room if the measurement is made mid-way the seat cushion. Therefore, we strongly urge Renault to modify its seat design or to add a third set of belts in this vehicle model. As noted in the letter to Toyota, if manufacturers do not voluntarily comply with the clear intent of the definition of 'designated seating position', the agency may find it necessary to modify the measurement technique that is currently specified.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4458OpenMrs. Charlotte E. O'Neil l46 Transit Street Waterbury, CT 06704; Mrs. Charlotte E. O'Neil l46 Transit Street Waterbury CT 06704; "Dear Mrs. O'Neil: This responds to your letter concerning the locatio of the clutch, brake and accelerator controls in a school bus that you drive. We apologize for the delay in our response. You stated that the seat of the school bus is about four inches too far to the right, and that these controls are therefore not in the usual location relative to the seat. You stated: 'In order to reach the brake pedal I have to cross my right foot over my left,' and expressed concern that a driver might accidentally hit the accelerator instead of the brake. You asked whether Federal Motor Vehicle Safety Standard No. l0l, Controls and Displays, prohibits placing controls in such difficult to reach locations and, if not, whether there is any way to get the law changed. The National Highway Traffic Safety Administration (NHTSA) issues safety standards covering new motor vehicles and/or new motor vehicle equipment. Since these standards do not apply to used vehicles, the issue of whether the bus you drive was required to meet Standard No. l0l depends on its date of manufacture. As you noted in your letter, Section S5.l of Standard No. l0l requires that certain controls, including the service brake, accelerator, and clutch, be 'operable by the driver' when the driver is restrained by the crash protection equipment required by Standard No. 208. You asked whether, with this wording, any control that can be reached at all, even with difficulty, must be considered 'operable.' One of the stated purposes of Standard No. l0l is 'to ensure the accessibility . . . of motor vehicle controls . . . in order to reduce the safety hazards caused by the diversion of the driver's attention from the driving task, and by mistakes in selecting controls.' Thus, it is the intent of section S5.l to ensure that drivers are able to operate specified controls as part of the normal driving task. We note, however, that neither Standard No. l0l nor any other standard specifies the precise location of the service brake, accelerator and clutch controls, either relative to each other or to the seat. In answer to your question concerning how you may be able to get requirements changed 'to forbid putting controls in difficult to reach locations,' interested persons may petition the agency to commence rulemaking to issue or amend safety standards. I am enclosing a copy of the agency's regulation which sets forth procedures for submitting petitions for rulemaking. I am forwarding your letter to NHTSA's Office of Enforcement, which investigates consumer complaints about safety. A copy of this correspondence is being placed in the public docket. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam3667OpenMr. Houtan Mostaghim, Vice President, Pan United Inc., 154 Hillwood Avenue, Falls Church, VA 22046; Mr. Houtan Mostaghim Vice President Pan United Inc. 154 Hillwood Avenue Falls Church VA 22046; Dear Mr. Mostaghim: This responds to your letter of March 4, 1983, asking whether there ar any Federal regulations applicable to an accessory component used to secure pets to vehicle seat belts. The component latches into the seat belt buckle and is then attached to the pet's collar or leash. Your company intends to import these accessories.; There are no Federal motor vehicle safety standards or regulation applicable to the product you describe. Therefore, as far as this agency is concerned, there are no responsibilities you must meet prior to importing this item (i.e., there are no testing or licensing requirements). You should, however, contact State authorities to determine if they have any licensing requirements or regulations that would be applicable to the sale of such a device.; You will have to contact private counsel to determine the produc liability implications and insurance needs of your enterprise.; Thank you for your inquiry. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0948OpenMr. Edward L. Hawes, President, Hawes Industries, Inc., 1651 E. 9 Mile Road, Hazel Park, Michigan 48030; Mr. Edward L. Hawes President Hawes Industries Inc. 1651 E. 9 Mile Road Hazel Park Michigan 48030; Dear Mr. Hawes: This is in response to your letter of December 7, 1972, regardin Standard 125, Warning Devices. I am sorry that you misunderstood our previous letter of November 27, 1972. We believe that the standard clearly permits the manufacture and sale of your device, for the reasons already discussed, and therefore an amendment is unnecessary. If you still have questions on this matter, do not hesitate to call me.; Yours truly, 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.