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: aiam0396OpenKendall M. Barnes, Esq., General Counsel, Department of the Army, Headquarters United States Army Material Command, Washington, D.C. 20315; Kendall M. Barnes Esq. General Counsel Department of the Army Headquarters United States Army Material Command Washington D.C. 20315; Dear Mr. Barnes: This is in reply to your letter of June 29 with its enclosures from th Staff Judge Advocate, Aberdeen Proving Ground. The Judge Advocate requests an 'interpretation of the applicability of the [military] exception to recent motor vehicle brake fluid legislation,' stating his specific interest in 'the use of MIL-P-46046' brake fluid.; We are unaware of any 'legislation' that affects the manufacture an use of MIL-P-46046 brake fluid. The NHTSA issued an amended brake fluid standard on June 24 but this does not affect the exception provided in 49 CFR S 571.7(c) that 'No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specification.' Thus continued use of MIL-P-46046 brake fluid by military personnel appears permissible as far as this agency is concerned.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0397OpenKendall M. Barnes, Esq., General Counsel, Department of the Army, Headquarters United States Army Material Command, Washington, DC 20315; Kendall M. Barnes Esq. General Counsel Department of the Army Headquarters United States Army Material Command Washington DC 20315; Dear Mr. Barnes: This is in reply to your letter of June 29 with its enclosures from th Staff Judge Advocate, Aberdeen Proving Ground. The Judge Advocate requests an 'interpretation of the applicability of the military exception to recent motor vehicle brake fluid legislation,' stating his specific interest in 'the use of MIL-P-46046' brake fluid.; We are unaware of any 'legislation' that affects the manufacture an use of MIL-P- 46046 brake fluid. The NHTSA issued an amended brake fluid standard on June 24 but this does not affect the exception provided in 49 CFR S 571.7(c) that 'No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with the contractual specifications.' Thus continued use of MIL-P-46046 brake fluid by military personnel appears permissible as far as this agency is concerned.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam1950OpenMr. Carl H. Johnson, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. Carl H. Johnson The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Johnson: Please refer to Mr. Ronald W. Mohler's letter of September 6, 1974 (copy enclosed) and Mr. Snyder's telephone conversation with you on January 23, 1975, regarding the transfer of tread code mark 'BFK' from the 'Griffin General Tire Service, Inc.' retread company operated by Mr. James W. Griffin to the 'Griffin General Tire Service' company operated by The General Tire and Rubber Company.; The enclosed copy of the May 17, 1973, letter to Mr. Daniels of th Daniels Tire Service, Inc. company outlines the conditions which must prevail for this company and the 'Griffin General Tire Service, Inc.' company to use the same code mark BFK. With respect to the 'Griffin General Tire Service, Inc.' the various limiting conditions prevailing at that time and which we understand will continued by your acquired company are:; >>>1. Recordkeeping procedures must be internal, i.e., within th specific company.; 2. Production is limited. Mr. Griffin advised us that production i 1973 was approximately five truck tires per day.; 3. The plant serves only local trade in the vicinity of Hornell, Ne York.<<<; Please advise us whether our understanding is correct that thes conditions will be met by the 'Griffin General Tire Service' company operating under the control of The General Tire and Rubber Company. If not, a new code number must be assigned to this plant.; We further wish to advise you that the conditional usage of code mar BFK will not be extended to any future disposition of the 'Griffin General Tire Service' company. To perpetuate the abnormal condition where two retread plants use the same code mark is highly undesirable due to the potential confusion, the extra necessary control effort, as well as the personal supervision required at our computer operation.; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam1951OpenMr. Carl H. Johnson, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. Carl H. Johnson The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Johnson: Please refer to Mr. Ronald W. Mohler's letter of September 6, 1974 (copy enclosed) and Mr. Snyder's telephone conversation with you on January 23, 1975, regarding the transfer of tread code mark 'BFK' from the 'Griffin General Tire Service, Inc.' retread company operated by Mr. James W. Griffin to the 'Griffin General Tire Service' company operated by The General Tire and Rubber Company.; The enclosed copy of the May 17, 1973, letter to Mr. Daniels of th Daniels Tire Service, Inc. company outlines the conditions which must prevail for this company and the 'Griffin General Tire Service, Inc.' company to use the same code mark BFK. With respect to the 'Griffin General Tire Service, Inc.' the various limiting conditions prevailing at that time and which we understand will continued by your acquired company are:; >>>1. Recordkeeping procedures must be internal, i.e., within th specific company.; 2. Production is limited. Mr. Griffin advised us that production i 1973 was approximately five truck tires per day.; 3. The plant serves only local trade in the vicinity of Hornell, Ne York.<<<; Please advise us whether our understanding is correct that thes conditions will be met by the 'Griffin General Tire Service' company operating under the control of The General Tire and Rubber Company. If not, a new code number must be assigned to this plant.; We further wish to advise you that the conditional usage of code mar BFK will not be extended to any future disposition of the 'Griffin General Tire Service' company. To perpetuate the abnormal condition where two retread plants use the same code mark is highly undesirable due to the potential confusion, the extra necessary control effort, as well as the personal supervision required at our computer operation.; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam1185OpenMr. Glen Tillotson, R. R. #2, Cokaton, MN 55321; Mr. Glen Tillotson R. R. #2 Cokaton MN 55321; Dear Mr. Tillotson: This is in reply to your letter of July 6, 1973, concerning problem that you foresee for your company under Federal Motor Vehicle Safety Standard No. 121. The primary problem you describe is the need to test brakes on vehicles that you produce in very small quantities.; The standards promulgated by this agency under the National Traffic an Motor Vehicle Safety Act do not impose a mandatory level of testing on regulated manufacturers. If we purchase a manufacturer's product, test it, and find that it fails an applicable standard, to avoid liability for noncompliance, the manufacturer must then establish that he exercised due care in assuring himself that the product conformed to the standard. The most common method by which manufacturers assess their product's conformity with a standard is by testing the products in accordance with the procedures of the standard. A manufacturer may, however, contract to have this testing done by an outside laboratory, may rely on adequate information provided him by a supplier, or use other reasonable means to make sure that his products comply.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2398OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This is in response to your letter of August 24, 1976, in which you as whether emergency exits required by a State beyond those required by Standard No. 217, *Bus Window Retention and Release*, are subject to the performance requirements outlined in S4(b) of Standard No. 220, *School Bus Rollover Protection*.; Standard No. 220 requires that all emergency exits provided i accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits provided in accordance with Standard No. 217' and, therefore, would not be subject to the requirements os S4(b) of Standard No. 220.; You should note that Standard No. 217, in addition to mandating th provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2399OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This is in response to your letter of August 24, 1976, in which you as whether emergency exits required by a State beyond those required by Standard No. 217, *Bus Window Retention and Release*, are subject to the performance requirements outlined in S4(b) of Standard No. 220, *School Bus Rollover Protection*.; Standard No. 220 requires that all emergency exits provided i accordance with Standard No. 217 must meet certain minimum performance levels during and after the simulated rollover test. Additional emergency exits mandated by State law are not exits 'provided in accordance with Standard No. 217' and, therefore, would not be subject to the requirements of S4(b) of Standard No. 220.; You should note that Standard No. 217, in addition to mandating th provision of certain school bus doors and exits under S5.2, also regulates certain aspects of all emergency exits under other provisions of the regulation.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam3389OpenMr. John M. Klinger, Sales Manager, Medallion Instruments, Inc., 917 W. Savidge Street, Spring Lake, Michigan 49456; Mr. John M. Klinger Sales Manager Medallion Instruments Inc. 917 W. Savidge Street Spring Lake Michigan 49456; Dear Mr. Klinger: This responds to your letter of December 10, 1980, to Joan Griffin o my staff regarding Safety Standard No. 127, *Speedometers and Odometers*. In your letter, you state that you manufacture speedometers and odometers for replica car manufacturers. You ask whether you can be exempted from the requirements of Standard No. 127 in light of the small number of speedometers and odometers that you sell.; The National Highway Traffic Safety Administration (NHTSA) has n authority to exempt manufacturers of motor vehicle equipment from compliance with the Federal Motor Vehicle Safety Standards. Thus, your Speedometers and odometers must comply with the requirements of Standard No. 127 that are in effect at the time of manufacture.; We hope you find this information helpful. Please contact this offic if you have any questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0122OpenMr. Praxl, Chief of Series Design and Development, NSU Motorenwerke Aktiengesellschaft, 7107 Neckarsulm, Germany; Mr. Praxl Chief of Series Design and Development NSU Motorenwerke Aktiengesellschaft 7107 Neckarsulm Germany; Dear Mr. Praxl: Thank you for your letter of October 8, 1968, to Mr. Eugene Laskin Acting Director, Office of Standards Preparation, concerning reflex reflectors.; The use of two Class B reflectors combined with the tail lamps on th rear of your vehicles will not impair the effectiveness of the two Class A red reflex reflectors required in Motor Vehicle Safety Standard No. 108. These devices are therefore in accordance with Standard No. 108, including paragraph S3.1.2.; Since this Bureau does not issue approval on items of lightin equipment or on vehicle designs incorporating this equipment, the above comments are for your information only, and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam1656OpenMr. Gorou Utsunomiya, Liaison Engineer in U.S.A., Toyo Kogyo Detroit Office, 3841 Mystic Valley Drive, Bloomfield Hills, MI 48013; Mr. Gorou Utsunomiya Liaison Engineer in U.S.A. Toyo Kogyo Detroit Office 3841 Mystic Valley Drive Bloomfield Hills MI 48013; Dear Mr. Utsunomiya: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 8,422 - Mazda Rotary picku trucks, concerning deformed exhaust pipe protector which may cause tall dry grass to smolder if the vehicle is parked and the grass is in contact with the pipe protector.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74-0193*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject vehicle states that a defect exists 'in the exhaust system of the 1974 Mazda. . . .' This does not conform to Part 577.4(b) since, where vehicles are involved, the defect should be described in this sentence as existing in the vehicle. The reference in the regulation to 'item of motor vehicle equipment' only applies to equipment campaigns. Since this discrepancy in your notification letter does not appear to be serious, mailing of a revised letter will not be required.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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.