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: aiam0908OpenMr. Stan Haransky, Associate Director, Truck Body & Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Associate Director Truck Body & Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: Thank you for your letter of November 15, 1972, and your kind word about my participation in your convention.; In your letter you asked a question that arose at the convention concerning the responsibility of a tank manufacturer who completes a tank truck for a customer who carries both gasoline an fuel oil. You asked,; >>>'Can a tank manufacturer by simply certifying the GVWR make a uni which will be legal at full load with gasoline, the lighter of the two products, and leave it to the user to ensure that he does not exceed the GVWR when he is carrying a mixed load or fuel oil only?'<<<; On the specific and limited facts that you have given, the answer i that the manufacturer will not be in violation of the Certification regulations. There are two ways in which a manufacturer might find himself liable on slightly different facts, however. If in an way the manufacturer provides information to the purchaser, through owner's manuals, promotional materials, or otherwise, which could reasonably be considered a 'rated cargo load', he will be in violation of S567.5(a)(5) if the GVWR does not reflect that figure. For example, if the vehicle were described explicitly as being capable of carrying 5,000 gallons of fuel oil, we would consider that to be the equivalent of a rating of that volume times the normal density of the oil.; The other possible liability would be for a safety-related defect. Thi would arise in a case where the vehicle was found to be unsafely equipped for carrying the loads that the manufacturer has reason to know would be imposed on it. Such a finding would depend on all the facts of an individual case. Obviously, the best course for the manufacturer, from the standpoint of both safety and the avoidance of liability, is to equip his vehicles fully with equipment that is rated to carry the loads that he believes the vehicles will carry.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2935OpenMr. James R. Randolph, 765 Malley Drive, Northglenn, CO 80233; Mr. James R. Randolph 765 Malley Drive Northglenn CO 80233; Dear Mr. Randolph: This responds to your December 28, 1978, letter concerning an auxiliar fuel tank installed by the dealer on a 1978 Ford van that you purchased. You are concerned that the auxiliary tank represents a safety hazard due to the location of the tank's filler cap in the left rear wheel-well.; Federal Motor Vehicle Safety Standard No. 301-75, *Fuel Syste Integrity*, specifies performance requirements for fuel systems on motor vehicles. Although the standard applies to completed vehicles rather than to fuel tanks or other fuel system components, your dealer had to assure that your van complied with the standard. A person who mounts an auxiliary fuel tank on a new motor vehicle before the vehicle's first purchase in good faith for purposes other than resale is a vehicle alterer under National Highway Traffic Safety Administration regulations. That person is required by 49 CFR 567.7 to affix a label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards--including Safety Standard No. 301-75. Therefore, there should be an 'alterer' label on your van in addition to the certification label placed on the vehicle by the original manufacturer.; Even if the vehicle complies with Safety Standard No. 301-75, th location and design of the auxiliary fuel tank could constitute a safety-related defect for which the manufacturer would also be responsible. I am, therefore, forwarding a copy of your letter to the agency's Office of Defects Investigation. That office will examine this situation and may be in touch with you at a later date.; Thank you for your letter and for bringing this matter to ou attention.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3627OpenMr. F. Michael Petler, Head, Administration, Government Relations Department, Suzuki Motor Co., Ltd., P.O. Box 1100, Brea, CA 92621; Mr. F. Michael Petler Head Administration Government Relations Department Suzuki Motor Co. Ltd. P.O. Box 1100 Brea CA 92621; Dear Mr. Petler: This responds to your October 27, 1982, letter asking for permission t place the certification labels for certain motorcycles produced by Suzuki Motor Co. in locations not previously permitted by Part 567, *Certification*.; You request alternative locations, because some motorcycles ar equipped with fairings as standard equipment. These fairings would obscure the certification labels if the labels were to be installed in their required location. You propose, as an alternative, the installation of the labels on the down tubes in front of the engine on either the right or left side. In consideration of the problems of installing the certification labels in their normal positions on vehicles equipped with fairings and since the agency desires that these labels be easily readable, we grant your request to install your labels in these limited instances in the alternative locations that you suggested.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3332OpenMr. Olin F. Wenrick, Trophy, Rt. 1, Box 19875, Hwy. M 205, Edwardsburg, Michigan 49112; Mr. Olin F. Wenrick Trophy Rt. 1 Box 19875 Hwy. M 205 Edwardsburg Michigan 49112; Dear Mr. Wenrick: This will confirm your telephone conversation with Mr. Schwartz of m office concerning the compliance of your vehicle identification numbering system with the requirements of Federal Motor Vehicle Safety Standard No. 115, *Vehicle Identification Number*.; The National Highway Traffic Safety Administration does not giv 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 will apparently comply with Standard No. 115 upon receipt of the chart you are sending identifying the coding used to designate the length of your vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2870OpenMr. Brian Gill, Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, Gardena, California 90247; Mr. Brian Gill Manager Certification Department American Honda Motor Co. Inc. P.O. Box 50 Gardena California 90247; Dear Mr. Gill: This is in reply to your letter of August 24, 1978, asking for a interpretation of Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*. Specifically, you have asked whether Honda's proposed manual fuel shutoff control design would comply with the standard. In this proposed design, in your word 'a second 'Off' position will be provided 180 degrees from the required position.'; Standard No. 123 requires the manual fuel shutoff control to b 'operable as specified in Column 3 [of Table 1]' (S5.2.1). Table 1 specifies that the 'Off' position is with the 'control forward.' Although the control in your proposed design shuts the fuel valve when pointed forward, it also shuts the valve at a position 180 degrees from the complying one, with the 'control backward,' so to speak. Thus, the control is not 'operable as specified' within the meaning of the requirement.; As you know, the safety purpose of standardization of control locatio and operation is to insure that the novice cyclist, and those who change cycles frequently, are not confused when controls must be operated under emergency conditions. Since your proposed control design is operable both forward and backward it does not comply with Standard No. 123.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3762OpenMs. Susan Reilly, Reilly Manufacturing, P.O. Box 51, Mt. Vernon, IA 52314; Ms. Susan Reilly Reilly Manufacturing P.O. Box 51 Mt. Vernon IA 52314; Dear Ms. Reilly: This responds to your letter asking whether a motorcycle helme fastener your company produces, called 'Alpha Clip,' complies with Federal requirements.; By way of background information, this agency does not give approval of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable standards.; Safety Standard No. 218, *Motorcycle Helmets*, includes various minimu performance requirements for motorcycle helmets. The only requirement directly relevant to your fastener is the retention test, which is set forth at section S5.3. The letter you enclosed from the University of Southern California suggests that the clip passes that test.; I would note that Standard No. 218 only applies to new motorcycl helmets and not to replacement equipment for motorcycle helmets. Thus, unless your clip was sold as part of a new motorcycle helmet, the requirements of Standard No. 218 would not be directly applicable. (Please note, however, that the agency discourages helmet users from modifying their helmets. Section S5.6.1 of the standard requires that the following instruction be placed on helmets: 'Make no modifications....'); I would also note that should a safety- related defect be discovered i your device, whether by the agency or by yourself, you as the manufacturer would be required under sections 151 *et seq*. of the Act to notify owners, purchasers, and dealers and provide a remedy for the defect. These provisions apply regardless of whether the device is covered by a safety standard. A copy of the Act is enclosed.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3298OpenMr. Emerson D. Gilbert, Engineer, Yellowstone, Inc., 28163 C.R. 20 West, P.O. Box 1128, Elkhart, Indiana 46515; Mr. Emerson D. Gilbert Engineer Yellowstone Inc. 28163 C.R. 20 West P.O. Box 1128 Elkhart Indiana 46515; Dear Mr. Singleton(sic): This will confirm your telephone conversation of April 23, 1980, wit Mr. Nelson Erickson of the Office of Vehicle Safety Standard concerning 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 standard 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.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2523OpenMr. W.G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W.G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your February 8, 1977, letter asking whether a Ne York state requirement mandating the installation of both side emergency doors and rear emergency doors in school buses would mean that both emergency doors would be required to comply with the school bus exit specifications in Standard No. 217, *Bus Window Retention and Release*.; The NHTSA has determined previously that only those exits required b S5.2.3 must meet the requirement specified for school bus emergency exits in Standard No. 217. Paragraph S5.2.3 requires either a rear emergency door or a side emergency door and a rear push out window. The side emergency door to which you refer is installed in addition to a rear emergency door. The presence of the rear emergency door, alone, satisfies the requirements of S5.2.3. Therefore, a side emergency door is not required by the standard and need not meet the specifications for school bus emergency exits. Emergency exits installed in school buses beyond those required in S5.2.3 must comply with regulations applicable to emergency exits in buses other than school buses. These requirements are also detailed in Standard No. 217.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2173OpenMr. Warren M. Heath, Commander, Enforcement Services Division, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA, 95804; Mr. Warren M. Heath Commander Enforcement Services Division Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Mr. Heath: This is in response to your letter of December 8, 1975, asking fou questions, the answers to which would provide an interpretation of Standard No. 108 with respect to separation distance of a turn signal lamp from the nearest edge of a Type 2 headlamp.; SAE Standard J588d, *Turn Signal Lamps*, June 1966, incorporated b reference in Standard No. 108, requires in pertinent part that 'The optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam . . . .' We agree with your opinion that the reference to filament center may have been added because of the difficulty of determining the location of the optical axis in certain instances. In the vast majority of cases, however the filament center is on the optical axis, and the addition of the provision assists in determining compliance with the requirement.; You have asked:>>> '1. Is the filament center always to be taken as the center of th optical axis?'<<<; The answer to this question is no. In some instances the filamen center will not be on the optical axis. When this is the case the standard is ambiguous as to whether distance is measured from the optical axis or the filament center. While we prefer the optical axis, under the present wording either must be viewed as legally supportable.>>>; '2. Is the center of the emitted light always to be taken as the cente of the optical axis?'<<<; The answer is yes.>>> '3. If the answers to the above two questions are no, does the vehicl manufacturer have the choice as to which method is most favorable to him?'<<<; Yes, because of the ambiguity the manufacturer may choose either th optical axis or filament center as the point of measurement.>>>; '4. What is the optical axis of a two- or three- compartment lamp?'<<< The optical axis of a multi-compartment lamp is the center of the ligh emitted by the array, treated as a single complex light source. The 'half-value' method you described in your letter is a valid method of finding the optical axis of a complex light source as well as that of a simple one.; Finally you have asked whether, if we agree with the need fo clarification, the letter can be considered a petition for rulemaking or whether a formal petition should be submitted.; We agree that clarification is needed and accordingly plan to issue notice of proposed rulemaking in the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2489OpenMr. Salvatore Messina, The Govmark Organization, Inc., P.O. Box 807, Bellmore, NY, 11710; Mr. Salvatore Messina The Govmark Organization Inc. P.O. Box 807 Bellmore NY 11710; Dear Mr. Messina: This responds to your December 10, 1976, letter asking whether Standar No. 302, *Flammability of Interior Materials*, applies to the living area of motor homes and mobile homes.; The National Highway Traffic Safety Administration (NHTSA) no longe regulates mobile homes. The National Mobile Home Construction and Safety Standards Act of 1974 (42 U.S.C. 5401 et seq.) ('the Mobile Home Act') established within the Department of Housing and Urban Development a comprehensive program for the regulation of mobile homes. We have concluded that one result of that statute's enactment was the implied repeal of the NHTSA's authority with respect to mobile homes. Accordingly, we consider that the enactment had the effect of amending the Vehicle Safety Act's definition of 'motor vehicle' to exclude 'mobile homes' as the latter term is defined in the Mobile Home Act.; A motor home, on the other hand, is classified as a multipurpos passenger vehicle (or a bus if it is designed to carry more than 10 persons) and is subject to the requirements of Standard No. 302. The standard mandates that certain enumerated components located within the vehicle occupant compartment meet specified burn test requirements. The living area of a motor home constitutes part of the vehicle occupant compartment, and therefore, any component listed in S4.1 of the standard and situated within the living area must comply with the standard.; Sincerely, Frank A. Berndt, Acting 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.