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: aiam3271OpenMr. Warren Robbins, Manager, Automobile Division, Sleek-Craft Boats, P.O. Box 3563, Santa Fe Springs, CA 90670; Mr. Warren Robbins Manager Automobile Division Sleek-Craft Boats P.O. Box 3563 Santa Fe Springs CA 90670; Dear Mr. Robbins: This responds to your recent letter requesting an interpretation o Safety Standard No. 214, *Side Door Strength*, as it would apply to a new sports car that your company intends to market. You state that the side doors of this vehicle design can meet the 'intermediate' and 'peak' crush resistance requirements of the standard but not the 'initial' crush resistance requirement because of an outer fiberglass veneer component of the door. You ask whether the vehicle can be exempt from this 'initial' requirement since the door can withstand the maximum forces required by the standard.; The answer to your question is no. Safety Standard No. 214 require doors to comply with all three stages of the crush resistance requirements and there is no provision for an averaging of the crush resistance abilities. Although inboard mounted structures may be effective in preventing intrusion if the door has a large cross section, with a correspondingly large distance between the protective structure and the inner panel, the standard reflects a determination by the agency that doors afford the greatest protection if the crush resistance elements are as close to the outer panel as possible. Additionally, the 'initial' crush resistance requirements are necessary to ensure that the entire door system is structurally sound. This is particularly important because of the risk of occupant ejection if door hinges and latches separated during an accident, allowing the door to fly open.; Although the relief you seek cannot be granted by interpretation o Safety Standard No. 214, there are provisions for temporary exemptions from Safety Standards or portions of safety standards under certain circumstances, such as economic hardship. I am enclosing a copy of the regulation governing temporary exemptions for your information (49 CFR Part 555). After reviewing this regulation, you may wish to petition the agency for a temporary exemption from the 'initial' crush resistance requirements of the standard. The regulation explains the procedures you must follow.; If you have any further questions, please contact Hugh Oates of m office at 202-426- 2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0981OpenMr. Carl Monk, 428 Southland Boulevard, Louisville, Kentucky 40214; Mr. Carl Monk 428 Southland Boulevard Louisville Kentucky 40214; Dear Mr. Monk: This is in further response to your letter of January 5, 1973, to Mrs Virginia Knauer, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 125, *Warning Devices*.; As you already know from Mr. E.T. Driver's letter of January 24, 1973 and previous correspondence from my office and the Department of Transportation, the National Highway Traffic Safety Administration issued the standard as an equipment item that would be suitable for use in all types of vehicles, from trucks to passenger cars.; In issuing the standard, we were concerned with the great variety o devices presently available, which can create confusion and misunderstanding to the motoring public. We were also concerned with wind stability, and your comments were most useful in our consideration of this aspect of the requirements. FMVSS No. 125 is an attempt to achieve a standardized device having a proper balance of the factors affecting shape, size, cost, visibility, wind stability and weight. These are minimum standards and the manufacture and sale of devices that exceed these requirements is not prohibited.; Again, thank you for your comments. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3141OpenMr. Lawrence D. Smith, Hein, Smith & Berezin, 25 East Salem Street, Hackensack, NJ 07601; Mr. Lawrence D. Smith Hein Smith & Berezin 25 East Salem Street Hackensack NJ 07601; Dear Mr. Smith: This is in response to your letter of October 1, 1979, asking whethe the Federal Government has any rule, regulations or statutes that obligate an insurance carrier to maintain a log of odometer readings with respect to vehicles declared a total loss. If a vehicle is repairable and will subsequently be used as a motor vehicle, disclosure of the actual miles would have to be made to the purchaser and those statements would have to be maintained by the insurance carrier for four years. However, if the vehicle is so badly damaged that it cannot be returned to the road, it will have ceased to be a motor vehicle for purposes of the regulations. Disclosure and retention would, therefore, not be required. In those instances where disclosure and retention are required, the format is specified in 49 CFR Part 580. For your information, I have enclosed copies of the relevant portions of the regulations, along with a sample disclosure form.; Sincerely, John Womack, Assistant |
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ID: aiam0767OpenMr. George J. Natinsky, Normark Corporation, 4839 Memphis Street, Dallas, Texas 75206; Mr. George J. Natinsky Normark Corporation 4839 Memphis Street Dallas Texas 75206; Dear Mr. Natinsky: This is in response to your letter of June 26, 1972, to the Office o the regional administrator, National Highway Traffic Safety Administration, concerning the Bond Bug.; For purposes of Federal motor vehicle safety standards, the Bond bug i classified as a 'motorcycle' since it is a 'motor vehicle...designed to travel on not more than three wheels in contact with the ground'. The only Federal standard currently applicable to it is Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*. Standard No. 123, *Motorcycle Brake Systems* will apply to motorcycles manufactured on or after January 1, 1974. I enclose a copy of each for your information. The new standard on motorcycle controls and displays, No. 123, does not apply to a motorcycle equipped with a steering wheel.; If you are interested in importing this vehicle on a commercial basis suggest that you write us directly for information on obligations of the manufacturer and importer concerning consumer information and safety-related defect notification.; Yours truly, Richard B. Dyson. Assistant Chief Counsel |
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ID: aiam1482OpenMr. Rick Shue, Product Safety Engineer, Volvo of America Corporation, Product Engineering and Development, Rockleigh, NJ 07647; Mr. Rick Shue Product Safety Engineer Volvo of America Corporation Product Engineering and Development Rockleigh NJ 07647; Dear Mr. Shue: This is in response to your letter of April 16, 1974, requesting a interpretation of the test procedure specified in Standard No. 301 (Docket 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.; Once the barrier crash tests have been completed, if the fuel pump wa operating it may be deactivated, as the standard only requires that it operate during the crashes.; Thank you for your inquiry. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0632OpenMr. Harold E. Krause, Vice-President, Zecol Inc., P.O. Box 1100, Milwaukee, Wisconsin 53201; Mr. Harold E. Krause Vice-President Zecol Inc. P.O. Box 1100 Milwaukee Wisconsin 53201; Dear Mr. Krause: In response to your letter of February 28, I enclose a copy of Federa Motor Vehicle Safety Standard No. 116, *Motor Vehicle Brake Fluids*, which became effective March 1, 1972.; Paragraph S5.2 as amended specifies the appropriate labeling fo containers of fluid manufactured on or after March 1. If the labeled on containers in stock do not meet the new requirements, you may affix a conforming gummed label over them.; I recommend that you subscribe to the Federal Register ($25.00 pe year, from Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402). Which contains all Federal regulations as issued or proposed on a daily basis. As a manufacturer in a regulated industry. it is your responsibility to be completely familiar with all applicable regulations. The Superintendent of Documents can also provide you with a subscription service to Federal Motor Vehicle Safety Standards ($8.00 per year), updated as new regulations are issued.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1000OpenMr. Joe Motley, 2704 Sparkman Drive, N.W., Huntsville, AL 35810; Mr. Joe Motley 2704 Sparkman Drive N.W. Huntsville AL 35810; Dear Mr. Motley: This is in reply to your letter of December 15, 1972, regardin requirements applicable to manufacturers of ambulances. Ambulances are considered by NHTSA to be 'multipurpose passenger vehicles', a vehicle type to which several Federal motor vehicle safety standards and regulations are applicable. Manufacturers of ambulances, including those who convert other vehicle types to ambulances, are required to manufacture each ambulance in accordance with those standards and regulations applicable to multipurpose passenger vehicles. The enclosed leaflet contains a short list and description of the standards and regulations, indicating which vehicle types are subject to each standard. The NHTSA is responsible for both the promulgation and the enforcement of these standards.; We rely on persons such as yourself to report possible violations o our requirements, and we appreciate your writing to us. I have referred your letter to our Office of Standards Enforcement, which will take steps to see that vehicles are manufactured in accordance with the Federal motor vehicle safety standards and other NHTSA regulations.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1994OpenMr. James W. Long, President, Continental Hydraulic Hose Corp. P.O. Box 104, Upper Sandusky, Ohio 43351; Mr. James W. Long President Continental Hydraulic Hose Corp. P.O. Box 104 Upper Sandusky Ohio 43351; Dear Mr. Long: #Please forgive the delay in responding to your lette of March 5, 1975, concerning the applicability of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to brake hose and brake hose assemblies used in military vehicles. #Part 571.7(c) of the Federal Motor Vehicle Safety Standards, 49 CFR 571.7(c), provides 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 specifications.<<<#Therefore, brake hose and brake hose assemblies sold to the military in conformity with contractual specifications are not subject to any of the requirements of Standard No. 106-74. While part 571.7(c) appears to exclude from the requirements of Standard No. 106-74 only that hose which is sold directly to the Armed Forced, the NHTSA interprets this section as also excluding that hose which is sold to military contractors, under contracts requiring it to conform to military specifications such as MIL-H-3992C, for installation in vehicles which are in turn sold directly to the military. We are considering the issuance of an interpretive amendment of Part 571.7(c) to this effect. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam2764OpenMr. W. W. Schwartz, Technical Engineer, Research and Development Dept., Vetter Fairing Company, 1150 Laurel Lane, San Luis Obispo, CA 93401; Mr. W. W. Schwartz Technical Engineer Research and Development Dept. Vetter Fairing Company 1150 Laurel Lane San Luis Obispo CA 93401; Dear Mr. Schwartz: This is in reply to your letter of February 1, 1978, on motorcycl headlighting.; You have asked whether the prohibition in SAE J580a *Sealed Bea Headlamp* against headlamp covers applies to a motorcycle. You have also asked the reason for the prohibition.; Sae J580a *Sealed Beam Headlamp* is incorporated by reference in Tabl III of Standard No. 108 as one of the standards applicable to headlamps for use on multipurpose passenger vehicles, trucks, and buses whose overall width is less than 80 inches. One of the SAE standards incorporated by reference for motorcycle headlighting is J584 which, as an option, allows motorcycles to be equipped with headlamps 'meeting the requirements of SAE J579' (i.e. passenger car sealed beam headlamps). There is no reference in J479a to J580a, and we therefore do not read the prohibition against headlamp covers as applying to motorcycles equipped with sealed or unsealed headlamps.; The reason for the prohibition is the degradation in light output tha can result from condensation under unsealed glass covers or from obscuration by grilles in front of the lens.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0520OpenMr. J. A. Westphal, Senior Staff Engineer, FWD Corporation, Clintonville, WI 54929; Mr. J. A. Westphal Senior Staff Engineer FWD Corporation Clintonville WI 54929; Dear Mr. Westphal: This is in response to your letter of November 18, 1971, requesting fo twenty-six of your trucks a temporary exemption from Standard No. 206. You reported that these trucks represent the final units to be produced in two soon-to-be-discontinued cab styles.; We regret that we are unable to consider your request, since ou authority under section 123 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410) to grant such exemptions expired in April of this year.; Beginning January 1, 1972, the manufacture of any truck not i compliance with the standard will be prohibited. Section 108(a) of the Act provides that; >>>'(n)o person shall manufacture for sale . . . any motor vehicle . . manufactured on or after the date any applicable . . . standard takes effect . . . unless it is in conformity with such standard . . . ' (15 U.S.C. 1397)<<<; The prohibition is enforceable by civil penalties under section 109 (1 U.S.C. 1398) and injunction under section 110 (15 U.S.C. 1399). In addition, in the event that a noncompliance were determined to be a safety-related defect, notification of the defect would have to be furnished under section 113 (15 U.S.C. 1402) to purchasers of the vehicle.; Let us know if we may be of further assistance. Sincerely, 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.