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: aiam1757OpenMr. Norman E. Salzman, General Manager, The Fairmount Press, P.O. Box 3, Bronx, NY 10453; Mr. Norman E. Salzman General Manager The Fairmount Press P.O. Box 3 Bronx NY 10453; Dear Mr. Salzman: This is in response to your letter of December 31, 1974, inquiring a to the compliance of your MVF odometer disclosure form with the Federal odometer requirements.; The MVF form enclosed in your letter appears to comply with th requirements of Part 580, *Odometer Disclosure Requirements*.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1867OpenMrs. Valerie L. Stein, Specialty Sales Assistant, William Penn Laboratories, 1882 Guildhall Building, Cleveland, Ohio 44115; Mrs. Valerie L. Stein Specialty Sales Assistant William Penn Laboratories 1882 Guildhall Building Cleveland Ohio 44115; Dear Mrs. Stein: This is in reply to your letter of March 26, 1975, to Mr. Schultz enclosing a sample brake fluid can, and asking whether it meets paragraph S5.2.1 of Motor Vehicle Safety Standard No. 116.; Since the inner metal pressed-in closure must be punctured or otherwis damaged, or removed, in order to use the fluid, the can meets our container sealing requirement.; The can also meets other requirements of Standard No. 116 with t exceptions, The phrase 'Conforms to Federal Standard No. 116' should be phrased 'Conforms to Federal Motor Vehicle Safety Standard No. 116' in order to meet S5.2.2.2(a). In addition, the designation of the contents as 'DOT 3 MOTOR VEHICLE BRAKE FLUID' must appear on the can in accordance with S5.2.2.2(e). This designation in such form presently does not appear on the container.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0480OpenMr. E. Theodore Gunaris, Chief Deputy Registrar, Registry of Motor Vehicles, The Commonwealth of Massachusetts, 100 Nashua Street, Boston, MA, 02114; Mr. E. Theodore Gunaris Chief Deputy Registrar Registry of Motor Vehicles The Commonwealth of Massachusetts 100 Nashua Street Boston MA 02114; Dear Mr. Gunaris: Thank you for your letter of September 17, 1971, asking if presen Federal regulations would preempt the Massachusetts requirement that certain outside rearview mirrors be provided with reflective material over the rear surface.; Section 103(d) of the National and Motor Vehicle Safety Act, 15 U.S.C 1392(d), states in pertinent part:; >>>'Whenever a Federal motor vehicle safety standard . . . is i effect, no State . . . shall have any authority . . . to establish . . . with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.'<<<; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices, and Associated Equipment*, establishes requirements for reflective materials used on motor vehicles. The NHTSA considers this standard to include within its scope all reflective materials required to be used on motor vehicles to which it applies. Any State requirements that have the effect of regulating such reflective materials must therefore be identical to the relevant provisions of Standard No. 108. The Massachusetts statute that you have brought to our attention is not identical to the Federal standards relating to that aspect of performance, and must therefore be considered to be invalidated by the operation of the National Traffic and Motor Vehicle Safety Act.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4210OpenMr. Eric E. Gough, Manager, Corporate Technical Affairs, Lucas Industries, Inc., P.O. Box 7002, Troy, MI 48007-7002; Mr. Eric E. Gough Manager Corporate Technical Affairs Lucas Industries Inc. P.O. Box 7002 Troy MI 48007-7002; Dear Mr. Gough: This is in reply to your letter of August 19, 1986, to this Office asking for confirmation of your understanding 'that other light sources can be added to a replaceable bulb headlamp, such as a parking lamp or signal lamp function, as long as the lamps operate independently of each other and are in full compliance with FMVSS 108.'; Your interpretation is essentially correct, and I am enclosing a cop of a recent letter that we sent to Ichikoh Industries on the same subject. In order to be in full compliance with Standard No. 108, if a replaceable bulb headlamp also incorporates a turn signal lamp, the requisite separation distance or candela ratio specified by the standard must be met.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1490OpenMr. Francois Louis, Manager, Technical Standards Department, Renault, Inc., 100 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Francois Louis Manager Technical Standards Department Renault Inc. 100 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Louis: This is in response to your letter of May 3, 1974, requesting a interpretation of the test procedure specified in Standard No. 301 (Docket No. 73-20, Notice 2) concerning the operation of the vehicle's fuel pump during testing.; Paragraph S7.1.3 of the standard requires that electrically driven fue pumps be in operation during the barrier crash tests if they normally operate with the activation of the vehicle's electrical system. If the pump is incapable of functioning with the independent activation of the electrical system and requires the operation of the vehicle's engine, then the pump should not be running during the barrier crash tests.; Thus, the interpretation of the requirement expressed in your letter i correct.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0271OpenMr. Michael Grossman, Peugeot, Incorporated, 300 Fuller Road, Clifton, NJ 07015; Mr. Michael Grossman Peugeot Incorporated 300 Fuller Road Clifton NJ 07015; Dear Mr. Grossman: This is in response to your letter of December 15, 1970, in which yo asked whether it would be permissible to add the words 'and Canadian' to your certification label.; With reference to a telephone conversation between you and Mr. Dyson o this office, I understand that the Canadian authorities will accept the certification statement that we presently require as long as the expression 'U.S.' does not appear on the label. Since use of the 'U.S.' is optional with the manufacturer under 49 CFR S367.4(g)(3), this appears to solve your problem in this regard.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4661OpenMr. Wolfred Freeman Freeman & Company P.O. Box 5062 San Marcos, CA 92069; Mr. Wolfred Freeman Freeman & Company P.O. Box 5062 San Marcos CA 92069; "Dear Mr. Freeman: This is in reply to your letter to June 22, l989, t the Administrator-Designate, General Curry, in which you 'petition...for permission to produce a color coded (Green-Amber-Red) rear light device for all types of motor vehicles.' You have designed 'a workable auxiliary system that can be adopted to cars and trucks on the road.' We are treating your letter as a request for an interpretation of whether your device would be permissible for sale and use as an item of aftermarket equipment under the regulations and statutes administered by this agency. By aftermarket, we mean sale of the device for installation on cars and trucks in use, as contrasted with sales by dealers for installation on new cars. The principal regulation of this agency pertaining to motor vehicle lighting equipment is Federal Motor Vehicle Safety Standard No. l08. The only requirements it establishes for the aftermarket is for equipment that is intended to replace the original lighting equipment specified by the standard (for example, headlamps and stop lamps). As your device is not a required item of motor vehicle lighting equipment, there is no Federal standard that applies to it. However, the National Traffic and Motor Vehicle Safety Act has a direct relationship to the acceptability of aftermarket equipment. The Act prohibits modifications by persons other than the owner of the vehicle if they render inoperative, in whole or in part, equipment that is installed pursuant to a safety standard. Under Standard No. l08, this equipment includes stop lamps, turn signal lamps, hazard warning signals, turn signals, backup lamps, taillamps, and the license plate lamp. On large trucks, it also includes identification lamps and clearance lamps. If the potential effect of an auxiliary lighting device is to create confusion as to the intended message of any lighting device required by Standard No. l08, we regard the auxiliary light as having rendered the required lamp partially inoperative within the prohibition of the Act. Thus, the question is whether your device has the potential to create confusion so that its installation by a manufacturer, distributor, dealer, or motor vehicle repair business would be a violation of the Act. We do not conclude that the device has this potential. In your device, a steady-burning amber light would signal that the accelerator had been released (and that neither the accelerator nor brake pedal were being applied). Amber is the recognized signal for caution. This signal will extinguish when either the accelerator (green signal) or brake pedal (red signal) is applied. Furthermore, it is steady burning whereas other rear lamps where amber is an optional color (turn signals and hazard warning signals) flash in operation. Therefore, it does not appear that your device would create confusion with required items of lighting equipment. You must also consider whether the device would be acceptable under the laws of any State where it is sold and used. We are unable to advise you on State laws, and recommend that you contact the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. However, we believe that in several Western States, there has been specific legislation that would permit your device. We appreciate your interest in enhancing vehicle safety through improvement in rear lighting systems. We believe that improvements, such as the center highmounted stop lamp, should be introduced as standardized, mandatory lighting equipment on vehicles, rather than as optional aftermarket devices. Contrary to your understanding, our studies of a system similar to yours showed no discernible improvement in reaction time or accident avoidance over current systems. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam5445OpenMr. Gerald J. Gannon General Motors Corporation Legal Staff N Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit, MI 48232; Mr. Gerald J. Gannon General Motors Corporation Legal Staff N Center One Building 3031 West Grand Boulevard P.O. Box 33122 Detroit MI 48232; Dear Mr. Gannon: This responds to your letter asking whether NHTS intended, in a recent final rule, 'to require that vehicles with an automatic transmission with a 'park' provision must prevent steering after removal of the key in order to have an ignition key-operated transmission shift override device?' You stated that the final rule might be interpreted to produce that result, but argued, based on the preamble, that a more limited result was intended. You suggested that a clarifying amendment would be appropriate. We apologize for the delay in our response. After reviewing your letter, we have concluded that the issue you raise should be addressed in rulemaking. We anticipate that a notice addressing this issue will be issued shortly. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1118OpenProfessor Dr.-Ing. L. Meckel, Fachgruppe 3.2, Bundesanstalt fur Materialprufung (BAM), Unter Den Eichen 87, 1 Berlin 45, West Germany; Professor Dr.-Ing. L. Meckel Fachgruppe 3.2 Bundesanstalt fur Materialprufung (BAM) Unter Den Eichen 87 1 Berlin 45 West Germany; Dear Professor Dr. Meckel: This is in reply to your question regarding Standard No. 302 'Flammability of Interior Materials,' in your March 15, 1973, letter to Dr. John D. Hoffman, that has been forwarded to this office. You ask whether the test cabinet described in the standard in the 'only right one'.; While the test cabinet described in Standard No. 302 is not the onl test cabinet that could be used for testing under the standard, whether a material complies with the standard will be determined by the National Highway Traffic Safety Administration by means of this described cabinet. The only requirement of the standard is that the material must be capable of meeting the requirements when tested in the described cabinet. Accordingly, any test results derived from the use of a different cabinet should be correlated with the results that would be obtained from the test cabinet described in the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1321OpenMr. Darrell Gambill, Standards Engineer, Crane Carrier Company, P.O. Box 4508, Tulsa, OK 74104; Mr. Darrell Gambill Standards Engineer Crane Carrier Company P.O. Box 4508 Tulsa OK 74104; Dear Mr. Gambill: This is in reply to your letter of November 7, 1973, to Mr. Schneide asking whether Standard No. 108 permits four identification lamps.; It does not. The purpose of the three-lamp system is that vehicles 8 inches or more in overall width be clearly identified as large vehicles, and only the three-lamp system specified by the standard is permissible. Standard No. 108, however, allows some latitude in mounting. The system need not be mounted on the vertical centerline of the vehicle if the manufacturer determines that is impracticable. Since you appear to have made such a determination, the front identification lamp system should be placed 'as close as practicable to the vertical centerline' with height and spacing requirements in accordance with Standard No. 108.; 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.