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: aiam3585OpenMr. Ron Gustafson, Furudals Buruks Kursinternat, 790 70 FURUDUAL Sweden; Mr. Ron Gustafson Furudals Buruks Kursinternat 790 70 FURUDUAL Sweden; Dear Mr. Gustafson: This responds to your letter of June 28, 1982, asking abou requirements applicable to child restraints sold in the United States as well as any necessary permits or licenses. You also asked about any U.S. testing organizations, procedures or standards for child restraints.; All child restraints sold in the U.S. must conform with the minimu performance requirements of Federal Motor Vehicle Safety Standard No. 213, *Child Restraint Systems*. The standard also sets out the test procedures that are used to measure the performance of child restraints. There are no other performance requirements or test procedures applicable to child restraints. I am enclosing a copy of the standard.; You are not required to obtain a permit or license from this agenc prior to selling a child restraint in the U.S., nor are you required to obtain approval from any U.S. testing organization. As a manufacturer of motor vehicle equipment, you are required by Part 566, *Manufacturer Identification*, of our regulation to submit certain identifying information to the agency. I have enclosed a copy of Part 566.; In addition, you would be required by the National Traffic and Moto Vehicle Safety Act (15 U.S.C. S1392 *et seq*.) to certify that your child restraint complies with all applicable Federal Motor Vehicle Safety Standards. Under the Act, you would also be responsible for conducting a notification and remedy campaign for any safety-related defect in your product. I am enclosing a copy of the Act, which defines your responsibilities as a manufacturer.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4832OpenMr. Billy S. Peterson President Automotive Safety Testing, Inc. at TRC of Ohio, Bldg. 20 Rd. 152 & SR 33 East Liberty, OH 43319; Mr. Billy S. Peterson President Automotive Safety Testing Inc. at TRC of Ohio Bldg. 20 Rd. 152 & SR 33 East Liberty OH 43319; Dear Mr. Peterson: This is in reply to your letter of February 7, l99l to the Office of Chief Counsel asking for a clarification of allowable mounting locations and photometric output requirements for tail/stop lamps on passenger cars. One of your clients wishes to mount 'two-part' stop/tail lamps 'so that one lamp is mounted on the fixed quarter panel and a duplicate lamp is mounted on the trunk lid.' Each part of the two-part lamp is a combination tail/stop lamp. You have asked whether the minimum photometric requirements must be met by 'the lamp mounted to the quarter panel or may the portion mounted on the trunk lid count toward the photometric requirements.' Your 'two-part lamp' would be treated as two separate lamps. For purposes of compliance, only one of these two adjacent lamps must be designed to conform to Standard No. 108, and this conformance must be independent of any 'contribution' by the adjacent lamp. Although Standard No. 108 permits either the deck or the body mounted lamp to be the complying lamp, it would be our preference that the body mounted lamp be the one that complies, so that the benefit of a conforming stop/tail lamp would be realized during those occasions when the lid may be raised. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam2174OpenMr. R. D. Coughlin, Vice President, Rol'on America, Inc., Melbourne, FL 32901; Mr. R. D. Coughlin Vice President Rol'on America Inc. Melbourne FL 32901; Dear Mr. Coughlin: This is in response to your letter of December 10, 1975, regarding th applicability of existing Federal regulations to the manufacture of 'Helmate.'; At the present time, there is no regulation pertaining directly to th type of helmet accessory your corporation produces. The general regulation concerning motorcycle helmets is 49 CFR S 571.218, Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets*. This standard establishes minimum performance requirements for helmets designed for use by motorcyclists and other motor vehicle users.; If a manufacturer, distributor, dealer, or motor vehicle repai business were to install 'Helmates' on helmets, the helmets would have to remain in conformity with the requirements of Standard 218. However, persons other than manufacturers, distributors, dealers, and repair businesses may modify products, after purchase by a user, without regard to the requirements of a Federal safety regulation. Thus, if 'Helmate' is mounted on the helmet by an ordinary consumer, safety Standard 218 is inapplicable.; There is some question as to whether motorcycle helmets will still mee the performance requirements of Standard 218, after the 3/8 inch hole required to mount the 'Helmate' is drilled. If it becomes apparent that installing 'Helmate' type helmet accessories causes the performance level of helmets to drop below the requirements of Standard 218, the NHTSA might find it necessary to enact regulations to rectify the situation. Our main concern is to assure that motorcycle helmets afford riders the protection and safety needed.; If I can be of any further assistance, please feel free to write. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2745OpenMr. James M. Beach, Collins Industries, Inc., P.O. Box 58, Hutchinson, KS 67501; Mr. James M. Beach Collins Industries Inc. P.O. Box 58 Hutchinson KS 67501; Dear Mr. Beach: This responds to your November 15, 1977, letter asking severa questions concerning Standard No. 217, *Bus Window Retention and Release*.; In your first question, you paraphrase the requirements of S5.3. concerning emergency exit force requirements and release motion and ask whether your understanding of the section is correct. Your interpretation of the standard's requirements are accurate.; Second, you enclosed photographs of a manufacturer's rear emergenc door release mechanism and asked whether it complies with the standard's requirements. The force release mechanism shown in the pictures does not comply with the requirements of Standard No. 217. The release mechanism is not located in the high force access region as required by the standard, and the motion required for release of the exit is not upward as required by paragraph S5.3.3.; Finally, you asked whether your enclosed copy of Standard No. 217 whic includes paragraph S5.2.3.1 is up-to-date. The answer to your question is yes. You have been confused by paragraph S5.2.3.1 because it states that a bus must have, at a minimum, one rear emergency door or a side emergency door and a rear push-out window. The requirement for one rear emergency door does not preclude a schoolbus with a 10,000 pound GVWR or less from using two (double) rear emergency doors. Paragraph S5.4.2.2 states '...the opening of the rear emergency door *or doors* shall be ...' (Emphasis added). The use of the term 'doors' in paragraph S5.4.2.2 indicates that double doors are permitted.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0842OpenMr. Richard Stevens, Cody Chevrolet, Inc. Barre-Montpelier Road, Montpelier, VT 05602; Mr. Richard Stevens Cody Chevrolet Inc. Barre-Montpelier Road Montpelier VT 05602; Dear Mr. Stevens: This is in reply to your letter of August 1, 1972, to the attention o Mr. Jerome Palisi of our White Plains, New York Office, concerning certification requirements for a vehicle which you describe and indicate will be used by a college to transport ball teams and school personnel, but will not be equipped with flashing lights or other special school bus equipment. You apparently wish to know whether you must consider this vehicle as a school bus for purposes of certification to Federal requirements.; 'School bus' is defined in the motor vehicle safety standards to mean bus 'designed primarily to carry children to and from school, but not including buses operated by common carriers in urban transportation of school children' (49 CFR 571.3). Based upon the description you provide, the NHTSA would not consider the vehicle you describe to be a school bus. For purposes of certification to Federal requirements (49 CFR Parts 567 and 568), there, 'gross vehicle weight rating' should not be computer under the minimum values specified for school buses. In addition, the requirement that vehicle type be inserted on the certification label should be met in inserting, 'BUS.'; This letter should not be construed to mean that the NHTSA takes position as to whether this vehicle need, under State law, conform to requirements for school buses. The State must determine the scope and application of its own laws.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2865OpenMr. Robert B. Kurre, Director of Engineering, Wayne Corporation, P. O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director of Engineering Wayne Corporation P. O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your recent letter asking whether Safety Standard No 208 applies to side-facing seats in multi-purpose passenger vehicle vans. You also ask to be advised of the criteria to be used for the installation of seat belts in these vehicles.; Safety Standard No. 208, *Occupant Crash Protection*, does requir side-facing seats in multipurpose passenger vehicles to comply with one of the options under paragraph S4.2.2, since the side-facing seats in question would be considered designated seating positions. If a manufacturer chooses to install seat belts under one of the options of that paragraph, the seat belt assemblies must comply with Safety Standard No. 209, *Seat Belt Assemblies*, and Safety Standard No. 210, *Seat Belt Anchorages*.; Safety Standard No. 210 does exempt side-facing seats from its strengt requirements, but all other requirements of the standard would be applicable. However, we strongly recommend that belt anchorages for side- facing seats be of at least equivalent strength to anchorages for forward and rearward facing seats, since the strength specifications are only minimum performance requirements. Side-facing seats were excepted from the strength requirements specified in the standard because the forces acting on side-facing seats are different from those acting on forward or rearward facing seats and the requirements and procedures were specifically developed for these latter seats.; Please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3059OpenMr. Peter Bigwood, Chief Engineer, Ontario Bus Industries Inc., 5395 Maingate Drive, Mississauga, Ontario; Mr. Peter Bigwood Chief Engineer Ontario Bus Industries Inc. 5395 Maingate Drive Mississauga Ontario; Dear Mr. Bigwood: This responds to your July 16, 1979, letter asking two questions abou the test procedures of Standard No. 217, *Bus Window Retention*, as they apply to buses you manufacture.; First, you ask whether side service doors can be counted in determinin the proper amount of bus emergency exits as required by the standard. As long as side service doors comply with all requirements applicable to emergency doors, they can be considered emergency exits for purposes of compliance with the standard.; Your second question asks whether glazing in a door is tested fo window retention, and if so, whether it is tested while the door is installed in a bus. The answer to both parts of this question is yes. All bus glazing, that is of the minimum size specified in the standard, must comply with the window retention requirement. The intent of the window retention requirement is to prevent openings in buses that might result in the ejection of occupants from the vehicle during an accident. In order for this requirement to have meaning, the glazing must be tested as it is installed in the vehicle to ensure the integrity of both the glazing and its surrounding structure. This means that glazing in vehicle doors is tested while the door is in the normal closed condition. If the door opens during the test, the vehicle would not be in compliance with the requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0873OpenMr. Heinrich von Wimmersperg, Development Engineer, 15929 Grand River Avenue, Detroit 27, MI; Mr. Heinrich von Wimmersperg Development Engineer 15929 Grand River Avenue Detroit 27 MI; Dear Mr. von Wimmersperg: Thank you for your letter of October 2, 1972, concerning the For 'Tot-Guard' and your child restraint patents.; The consumer complaints that we have received on the Ford Tot-Guar have been complaints focussing on the fit of the device for minimum recommended size children. The comments relate both to the ease with which small children may climb out of the device and slide under it, as well as to the vision restriction problem for the small child.; The Tot-Guard has proven to perform well in 30 mph frontal impacts wit the three- year-old child dummy in our research programs, but can be improved in lateral protection capability and in performance with the 50-pound child dummy.; We have just completed a research program to develop new concepts i child restraints and will very shortly be making these designs available for any manufacturer who chooses to produce one of these advanced design restraints.; A copy of your letter will be placed in the public docket along wit plans for the restraints developed on our child restraint development contract.; We are interested in reviewing and placing in the public docket copie of your designs for the infant car bed, which you mention in hopes of stimulating the production of a crashworthy design for such a device.; We appreciate your letter and are looking forward to hearing from yo in the near future.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam4257OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of November 21, 1986, with reference t the distance between a front turn signal lamp and a lower beam headlamp.; In brief, SAE Standard J588e, incorporated by reference in Standard No 108 requires a minimum separation distance of 4 inches between the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the lower beam headlamp. You have pointed out that a replaceable bulb headlamp does not have a retaining ring, and you have presented two possible substitutes as a measuring point. The first (your Item A) is the outer edge of the headlamp, and the second (your Item B) is the end of the effective area of the reflector. You believe that Item B is the more appropriate.; We concur with your interpretation. Of the two options, the distance t the edge of the effective area of the reflector is the one most similar to the inside diameter of the retaining ring of the lower beam headlamp. The basis for this interpretation is the assumption that the headlamp lens between the outer edge of the headlamp and the edge of the effective area of the reflector is not used for production of the lamp's beam, has no significant luminance, and therefore will not mask the turn signal.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3707OpenMr. William E. Meiter, Middletown Van Pool Association, 60 Wallace Road, Middletown, NJ 00748; Mr. William E. Meiter Middletown Van Pool Association 60 Wallace Road Middletown NJ 00748; Dear Mr. Meiter: This responds to your note of May 27, 1983, attaching correspondenc between yourself and a District Manager for Ford Motor Company. You requested that we investigate the Ford E-150 van (which you state is a 15-passenger van) to determine if the stated Gross Vehicle Weight Rating of that vehicle is accurate.; Each manufacturer of a motor vehicle is required by the agency' regulations to place a certification label on the vehicle specifying that the vehicle is in compliance with all Federal motor vehicle safety standards and regulations (issued pursuant to the National Traffic and Motor Vehicle Safety Act of 1966). This certification label must include information regarding the vehicle's Gross Vehicle Weight Rating, as specified in 49 CFR 567.4(g)(3):; >>>(3) 'Gross Vehicle Weight Rating' or 'GVWR', followed by th appropriate value in pounds, which shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. However, for school buses the minimum occupant weight allowance shall be 120 pounds.'<<<; Thus, you are correct in your assumption that the GVWR for 15-passenger vehicle would have to include 2,250 pounds for occupant weight. Further, if a 15- passenger vehicle has a stated GVWR of 6,200 pounds, its unloaded vehicle weight could not exceed 3,950 pounds. I cannot state whether the Ford E-150 van has an unloaded vehicle weight in excess of this figure. However, I am sending a copy of your correspondence to our Office of Enforcement so that they may review this matter.; 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.