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: aiam1611OpenMr. Tatsuo Kato, Staff, Safety, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood Cliffs, New Jersey 07632; Mr. Tatsuo Kato Staff Safety Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood Cliffs New Jersey 07632; Dear Mr. Kato: This is in reply to your letter of September 11, 1974 asking for a interpretation of paragraph S5.3.5 of Standard No. 105-75. You indicate that a prospective Nissan design uses a common indicator lamp to show both loss if fluid pressure and low brake fluid level. You ask if the indicator lamp lens may be labeled 'Brake Failure.'; The answer is no. If separate indicator lamps are used, Standard No 105-75 allows words in addition to 'Brake' to indicate the specific area where a problem may exist, *e.g.* an indicator lamp may be labelled 'Brake Fluid' to indicate a low level of fluid. However, if a lamp indicates more than one type of condition, paragraph S5.3.5 specifies that only a single word, 'Brake', may be used. This alerts a driver in a general way that a problem exists somewhere in the brake system. We think the restriction of S5.3.5 preferable for most circumstances. In the configuration you propose for example, the word 'Failure' would not accurately describe a low level of brake fluid.; We appreciate your continued interest in vehicle safety. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2894OpenMr. D.P. Weiher, Office of Corporate Safety, Emissions and Noise Control, AM General Corporation, 32500 Van Born Road, Wayne, Michigan 48184; Mr. D.P. Weiher Office of Corporate Safety Emissions and Noise Control AM General Corporation 32500 Van Born Road Wayne Michigan 48184; Dear Mr. Weiher: This responds to your August 2, 1978, letter asking whether it i permissible to perform the tests of Standard No. 124, *Accelerator Control Systems*, with only part of the vehicle mechanism at the designated temperatures. You state further that there is not sufficient time to find an environmental chamber large enough to accommodate the size vehicle that you are testing.; "The National Highway Traffic Safety Administration (NHTSA) does no issue approvals of manufacturer's plans for compliance with agency standards. Standard No. 124 mandates that a vehicle shall meet the j requirements of the standard at any temperature between -40 degrees F. and 125 degrees F. When the agency tests for compliance with the standard, it fins a chamber sufficiently large to accommodate the entire vehicle and tests according to the standard. Any manufacturer deviation from this accepted test procedure carries with it certain risks that a vehicle may not conform to the requirements."; With respect to the vehicles that you are constructing, you state i your letter that they are being manufactured for use by the army. As such, These vehicles are not required to comply with the agency's safety standards, and the NHTSA would not test these vehicles for compliance.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3786OpenMr. Richard McCarl, American Isuzu Motors Inc., Whittier, CA 90601; Mr. Richard McCarl American Isuzu Motors Inc. Whittier CA 90601; Dear Mr. McCarl: This responds to your November 23, 1983 letter regarding th applicability of motor vehicle certification requirements to a new vehicle to be imported by Isuzu Motors. This small utility vehicle would be certified as a truck. Isuzu dealers will offer for the vehicle an optional rear seat which can be installed by simply bolting it to the vehicle. The basic vehicle already has the necessary mountings for the seat, so the seat installation can apparently be readily accomplished. You have asked whether installation of these seats constitutes 'alteration' of the vehicle by the dealer, requiring the addition of an alterer's label in accordance with 49 CFR 567.7.; Based on your description of the seat installation process, it appear that dealers installing the seats would be subject to 49 CFR 567.6, 'Requirements for persons who do not alter certified vehicles or do so with readily attachable components.' Since the seats appear to be 'readily attachable components,' section 567.6 requires dealers to leave the manufacturer's certification label in place and requires no alterer's label to be added.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4043OpenMr. Roger F. Hagie, Government Relations Manager, Kawasaki Motors Corporation, U.S.A., P. O. Box 11447, Santa Ana, CA 92711; Mr. Roger F. Hagie Government Relations Manager Kawasaki Motors Corporation U.S.A. P. O. Box 11447 Santa Ana CA 92711; Dear Mr. Hagie: This responds to your April 11, 1986, letter to this office requestin an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 106, *Brake Hoses*. We regret the delay in our response; You asked whether brake hoses that comply with all requirements o Standard No. 106 except the whip resistance test of S5.3.3 may be used in locations not subject to movement during vehicle operation. As explained below, the answer to your question is no.; As you know, Standard No. 106 defines 'brake hose' as 'a flexibl conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.' Manufacturers of brake hoses must certify that their hoses comply with all applicable requirements of the standard. From your letter, it appears that while you agree that the equipment you manufacture are brake hoses, you believe that they should not be subject to whip resistance test because your hoses would not be used between articulating parts.; We do not agree that the whip test does not apply to brake hoses use between non- articulating parts. No provision has been made in the standard or in the whip resistance test of S5.3.3 to exclude hoses manufactured for use between non-moving parts. In contrast, the standard has set separate requirements under certain tests for brake hoses used between articulating parts when it is appropriate to distinguish between articulating and non-articulating applications (see, for example, the tensile strength test of S7.3.10 for air brake hose assemblies).; Further, we believe that there is a safety need to test brake hose intended for non-articulating applications for fatigue resistance, since they are also subject to vibration, bending and articulating stress while the motor vehicle is being operated or repaired.; If you have further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1241OpenMr. David E. Martin, Manager, Automotive Safety Engineering, Environmental Activities Staff, General Motors Technical Center, General Motors Corporation, Warren, MI 48090; Mr. David E. Martin Manager Automotive Safety Engineering Environmental Activities Staff General Motors Technical Center General Motors Corporation Warren MI 48090; Dear Mr. Martin: Dr. Gregory has asked me to reply to your letter of August 28, 1973, i which you request our endorsement of new labels General Motors intends to use to fulfill its responsibilities under part 567 of Title 49 of the Code of Federal Regulations.; The wording on the label meets the requirements of paragraph 567.4(g) The color of the paint under the label 'window' would determine conformity with the contrasting color requirements in paragraph 567.4(f).; It would appear that the material would '. . .be permanently affixed. .' if it '. . .is tightly bonded to the surface of the vehicle panel. . . .' However, it has not been the practice of the National Highway Traffic Safety Administration to endorse label materials.; Thank you for your continuing cooperation. Sincerely, Robert L. Carter |
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ID: aiam1255OpenMr. J. T. Monk, Director of Engineering, Taylor Machine Works, Inc. P.O. Box 150, Louisville, MS 39339; Mr. J. T. Monk Director of Engineering Taylor Machine Works Inc. P.O. Box 150 Louisville MS 39339; Dear Mr. Monk: This is in reply to your letter of August 6, 1973, in which you as whether a sample certification label you enclosed will conform to NHTSA Certification regulations (49 CFR Part 567). We assume from the weight ratings specified in the sample that the trailer is a semitrailer.; As we indicated to you in our letter of June 26, 1973, the regulation do not provide for the listing of inflation pressure with the tire size designation, and the inflation pressure you have included should not appear in its present location on the label. You may, if you wish, include it following all the required information.; Apart from this item, a label similar to that you have submitted affixed in both an appropriate manner and location, will conform to Part 567.; We are happy to have been of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3268OpenMr. Arnold van Ruitenbeek, Vice President, Continental Product Corporation, 1200 Wall Street West, Lyndhurst, new Jersey 07071; Mr. Arnold van Ruitenbeek Vice President Continental Product Corporation 1200 Wall Street West Lyndhurst new Jersey 07071; Dear Mr. Ruitenbeek: This responds to your March 28, 1980, letter to this office in whic you inquired about permissible markings on motorcycle tires. Specifically, you asked whether you could insert language in addition to that specified in Standard No. 119 when labeling the load rating and inflation pressure on certain tire sizes. The answer to your question is no.; Standard No. 119 ( 49 CFR S 571.119) specifies certain requirement which all motorcycle tires offered for sale in this country must meet. One of these provisions is the labeling requirement set fourth in paragraph s6.5 of the standard. Subparagraph (d) of s6.5 requires the maximum load rating and corresponding inflation pressure to appear on the tire in the following words: 'Max load * *lbs at * *psi cold.' The language of the subsection is mandatory and does not permit any variation. Therefore, the insertion of the phrase 'in USA and Canada,' as you suggest, would mean the tire would not comply with the labeling requirement of Standard No. 119.; The reason for this strict wording requirement is to ensure that th information labeled on motorcycle tires conveys necessary information to the purchaser of the tire in a clear, straightforward manner that is uniform with all motorcycle tires. Adding language which suggests that the maximum load of a tire depends on the country in which the tire is being used could confuse the user of the tire. Further, it suggests that the printed maximum load is not rally the maximum. Either of the results frustrates the purpose of the labeling requirement in Standard No. 119.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2880OpenMr. James D. Carney, Executive Director, Truck Equipment & Body Distributors Association, 25900 Greenfield Road, Oak Park, MI 48237; Mr. James D. Carney Executive Director Truck Equipment & Body Distributors Association 25900 Greenfield Road Oak Park MI 48237; Dear Mr. Carney: This responds to your September 12, 1978, letter asking severa questions about the applicability of the certification regulations to various manufacturers. In particular, you want to know when a manufacturer is considered an intermediate or a final-stage manufacturer for purposes of applying the regulations.; Part 568, *Vehicles Manufactured in Two or More Stages*, clearl defines incomplete, intermediate, and final-stage manufacturers. Using those definitions, you should be able to determine the certification responsibilities of any manufacturer based upon the manufacturing operation.; From the facts described in your letter, it is not possible for th agency to state with certainty whether a body installer would be an intermediate manufacturer or a final-stage manufacturer. These classifications depend upon the type of manufacturing done by each manufacturer. If the body installer performs such operations on an incomplete vehicle, as defined in Part 568, that the vehicle becomes a completed vehicle, then the body installer would be considered a final-stage manufacturer. A completed vehicle is also defined in Part 568. A manufacturer subsequently installing a refrigeration unit would be an alterer of that vehicle. If, on the other hand, the body installer is not performing final-stage manufacturing operations, then it must certify as an intermediate manufacturer. This would occur when, for example, the vehicle was not completed in a manner enabling it to be used on the highways without some further manufacturing operations.; The National Highway Traffic Safety Administration (NHTSA) through it certification regulations is simply requiring that each manufacturer certify the compliance of the vehicle to the extent possible given its manufacturing operations. If a manufacturer makes a good faith determination that it is a certain type of manufacturer or alterer, the NHTSA is likely to accept the certification so long as the appropriate label for that type of manufacturer is attached to the vehicle in the manner prescribed by the regulations.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4057OpenMr. Robert Juckett, Transglogal Industries, Inc., P.O. Box 98, Whitehall, NY 12887; Mr. Robert Juckett Transglogal Industries Inc. P.O. Box 98 Whitehall NY 12887; Dear Mr. Juckett: This responds to your letter of September 9, 1985, regarding th applicability of Standard No. 121 to a partially used and partially new trailer. You asked whether your customer, who plans to purchase a trailer frame, air tank, and air valve from you is responsible for compliance with Safety Standard 121. Your customer plans to mount on his newly purchased frame his own used suspension, wheels, brakes and axles.; By way of background information, this agency does not give approval of motor 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 requirements. A manufacturer then certifies that its vehicles and equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter.; If your customer intends to use the trailer which he is assembling fo his own use, then he is not governed by the Federal motor vehicle safety standards. Section 108(a) of the National Traffic and Motor Vehicle Safety Act of 1966 provides:; >>>(a) No person shall: (1) Manufacture for sale, sell or deliver for introduction int interstate commerce or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this rule unless it is in conformity with such standard.<<<; Section 102(5) of that Act defines 'manufacturer' as 'any perso engaged in the manufacturing or assembling of motor vehicles...for resale.' Your customer is not covered by the Federal motor vehicle safety standards unless he is assembling the vehicle you mention for sale.; In the event that your customer is a manufacturer within the meaning o the Act, he may still be excepted from the requirements of Standard No. 121. You noted that your customer will mount a new trailer frame, air tank and air valve on his own used suspension, wheels, brakes and axles. 49 CFR Part 571.7(f) excludes from Standard No. 121 partly new and partly used trailers when the trailer running gear assembly (axle(s), wheels, braking and suspension) is not new and was taken from an existing trailer. In addition, the reassembled vehicle must use the same vehicle identification number as the original trailer and the original trailer must be owned or leased by the user of the reassembled vehicle.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3792OpenMr. Bob D. Troxel, Vice President and General Manager, J. F. Enterprises, Inc., Box 583, Wakarusa, IN 46573; Mr. Bob D. Troxel Vice President and General Manager J. F. Enterprises Inc. Box 583 Wakarusa IN 46573; Dear Mr. Troxel: This responds to your recent letter to Mr. Steve Kratzke of my staff asking for a clarification of the requirements of Federal Motor Vehicle Safety Standard No. 302, *Flammability of Interior Materials* (49 CFR S571.302). Specifically, your company manufactures innerspring mattresses, some of which are used in motor vehicles. You noted that the mattress covers on those mattresses for use in motor vehicles must comply with the flammability requirements of Standard No. 302, and that you had interpreted the mattress cover to consist only of the covering applied over the finished mattress. Hence, under your interpretation, Standard No. 302 would not apply to the ticking used as the outside of the mattress. However, you were told by several ticking manufacturers that a recent decision by this agency stated that ticking used on mattresses for use in motor vehicles must also satisfy the flammability requirements of the standard. It is correct that the ticking must satisfy Standard No. 302's flammability requirements.; The mattress cover has been interpreted by this agency to include bot a covering put over a finished mattress and the permanent mattress ticking since Standard No. 302 became effective. Hence, the information that this was a recent decision by this agency is incorrect. For your information, I have enclosed a 1973 letter to the Recreational Vehicle Institute setting forth this interpretation over ten years ago.; Should you have any other questions about the applicability of Standar No. 302 to your products, please do not hesitate to contact Mr. Kratzke at this address or by telephone at (202) 426-2992.; Sincerely, Frank Berndt, 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.