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 |
|---|---|
ID: aiam2053OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your letter of July 30, 1975, in which you aske whether the uniform tire quality grading requirements for furnishing information to prospective purchasers of vehicles apply to prospective purchasers of vehicles other than passenger cars that may be equipped with passenger car tires. This was asked in light of the fact that the tire quality grading rule itself applies to tires manufactured for use on passenger cars.; We do not consider that the requirements of S 575.6(a) and (c) regarding the furnishing of consumer information to motor vehicle buyers and prospective purchasers, apply to the sale of trucks or other non-passenger- car vehicles where uniform tire quality grading information is concerned.; We recognize that the language of the regulation may not be entirel clear in this regard, and are considering an interpretive amendment to clarify it.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2293OpenMr. Gilbert Theissen, 6S Hayden Hall, 33 Washington Square West, New York, NY 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York NY 10011; Dear Mr. Theissen: This is in response to your letter of February 5, 1976, to Mrs Winifred Desmond of this agency concerning braking and rollover characteristics of the Jeep vehicle. We are sorry for the delay in our answer.; The Jeep Corporation is correct in saying that 49 CFR 571.105-75 *Hydraulic Brake Systems*, applies only to passenger cars. It will also apply to school buses manufactured after October 25, 1976. Part 575, Consumer Information Regulations, applies as a whole to all motor vehicles (49 CFR 575.4), but the consumer information item requiring reports on brake performance is limited to passenger cars and motorcycles (49 CFR S 571.101).; With regard to rollover resistance, the agency has issued an advanc notice of proposed rulemaking to collect information on rollover resistance, but no requirement to report on rollover performance exists at this time.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam3768OpenMr. Paul Scully, Vice President, Peterson Manufacturing Co., 4200 East 135th Street, Grandview, MO 64030; Mr. Paul Scully Vice President Peterson Manufacturing Co. 4200 East 135th Street Grandview MO 64030; Dear Mr. Scully: This is in reply to your letter of October 25, 1983, to Mr. Cavey o this agency asking for a copy 'of an NHTSA ruling issued sometime ago which supposedly permits the triple identification lights normally mounted on the top rear center line of semi-trailers to be mounted at the lower sill location.'; I enclose a copy of an interpretation furnished the State of Wisconsi on June 18, 1981, concerning this practice by Fruehauf Corporation. In summary, Fruehauf demonstrated to us the impracticability of mounting the lights at the top of a body with high-opening doors and a narrow header (chiefly because of vulnerability of the wiring).; The agency's interpretation was limited to vehicles of that specifi configuration, and was not intended to apply to semi-trailers in general.; If you have any further questions, we shall be glad to answer them. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0360OpenMr. G.K. Pilz, Product Compliance, Mercedes-Benz of North America, Inc., 158 Linwood Plaza, P.O. Box 318, Fort Lee, New Jersey 07024; Mr. G.K. Pilz Product Compliance Mercedes-Benz of North America Inc. 158 Linwood Plaza P.O. Box 318 Fort Lee New Jersey 07024; Dear Mr. Pilz: #This is in reply to your May 21, 1971, letter to Mr E.H. Wallace to determine whether Dunlop is in compliance as to the use of spaces in the tire identification number. #There are no objections to the spaces between the different parts of the number. However, the photograph illustrates another problem, that of a dual size marked tire. Dual size marked tires are not permissible. The tire can be labeled as one size tire with the indication that t replaces another size tire. For example, 20SR14 replaces ER70-14. #The General Secretary of ETRTO has been advised of the 'dual marked' tire usage. #Sincerely, E.T. Driver, Director, Office of Operating Systems, Motor Vehicle Programs; |
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ID: aiam2291OpenMr. Gilbert Theissen, 6S Hayden Hall, 33 Washington Square West, New York, NY 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York NY 10011; Dear Mr. Theissen: This is in response to your letter of February 5, 1976, to Mrs Winifred Desmond of this agency concerning braking and rollover characteristics of the Jeep vehicle. We are sorry for the delay in our answer.; The Jeep Corporation is correct in saying that 49 CFR 571.105-75 *Hydraulic Brake Systems*, applies only to passenger cars. It will also apply to school buses manufactured after October 25, 1976. Part 575, Consumer Information Regulations, applies as a whole to all motor vehicles (49 CFR 575.4), but the consumer information item requiring reports on brake performance is limited to passenger cars and motorcycles (49 CFR S 571.101).; With regard to rollover resistance, the agency has issued an advanc notice of proposed rulemaking to collect information on rollover resistance, but no requirement to report on rollover performance exists at this time.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam1769OpenMr. A.O. Haynes,Dennison Manufacturing Company,Framingham, Massachusetts 01701; Mr. A.O. Haynes Dennison Manufacturing Company Framingham Massachusetts 01701; Dear Mr. Haynes:#Please forgive the delay in responding to your lette of October 11, 1974, enclosing sample labels and requesting approval of Dennison's labeling technique to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, for labeling brake hose assemblies.#The NHTSA interprets a band a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. Furthermore, all of the label information must remain visible after the band has been affixed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of the specific design.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2217OpenMr. John B. White, Engineering Manager, Technical Information Dept. Michelin Tire Corporation, P.O. Box 3467, New Hyde Park P.O., New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation P.O. Box 3467 New Hyde Park P.O. New York 11040; Dear Mr. White: #This is in response to your letter of January 27 1976, concerning the rim listing requirements of Federal Motor Vehicle Safety Standards No. 109 and 110. #You wish to designate the 15x5.5JJ rim a permissible for use with tire sizes 225-15 and 230-15. You have requested confirmation of your interpretation that you need merely list the rim in a document that is furnished to your dealers, to any person on request, and in duplicate to the Tire Division of the NHTSA. Your interpretation is correct. Please note, however, that this listing must include dimensional specifications and a diagram of the rim, unless each of the association publications referred to in S4.4.1(b) of Standard No. 109 in which the rim is listed already contains such specifications and diagram. #We hope that you will also ensure that this tire-rim combination is listed in one of those publications as soon as is possible. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam0682OpenMr. Thomas Templin, Truck Cap Division of Temptation Mfg. Co., 290 Cass Avenue, Mount Clemens, MI 48043; Mr. Thomas Templin Truck Cap Division of Temptation Mfg. Co. 290 Cass Avenue Mount Clemens MI 48043; Dear Mr. Templin: This is in response to your undated letter, which we received on Marc 22, 1972, in which you ask what NHTSA requirements are applicable to a truck cover you manufacture, enclosing a picture.; The picture appears to show a cover designed for installation over th back of a pickup truck. If this unit is not designed to carry persons when the truck is in motion, there are no requirements applicable to it. If, however, it is designed to transport persons, the glazing materials (glass and plastics) used in it must conform to Motor Vehicle Safety Standard No. 205, 'Glazing Materials,' (copy enclosed). In addition, the unit must also be certified as conforming to the standard in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act and the enclosed NHTSA notice of November 4, 1967.; The ASA Test Z26.1-1966 that is incorporated into Standard No. 205 ca be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10018.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2701OpenHonorable Glen English, House of Representatives, Washington, DC 20515; Honorable Glen English House of Representatives Washington DC 20515; Dear Mr. English: This confirms the conversation between Judy Dutterer of your staff an Roger Tilton of my staff concerning the applicability of the new Federal school bus regulations to activity buses.; The Motor Vehicle and School Bus Safety Amendments of 1974 (Pub. L 93-492) defined school bus to include buses used to transport children to and from school and related events. In the legislative history of those amendments, Congress clearly indicated that all buses used to transport school children to and from events related to school should be covered by the new school bus safety standards. Accordingly, the National Highway Traffic Safety Administration requires that all activity buses designed to transport school children to and from such events comply with the new standards.; You should note that we have initiated rulemaking, in response to petition, to examine the issue of whether activity buses should have different requirements applicable to them since they are frequently involved in long distance student transportation. Any action on that issue will be published in the Federal Register.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2216OpenMr. Leon C. Huneke, Chemical Engineer, Midland-Ross Corporation, 490 South Chestnut Street, Owosso, Michigan 48867; Mr. Leon C. Huneke Chemical Engineer Midland-Ross Corporation 490 South Chestnut Street Owosso Michigan 48867; Dear Mr. Huneke: #This is in response to your January 30, 1976, lette requesting clarification of my March 7, 1975, letter concerning the relationship between Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses, and Military Specification MIL-H-3992C. #My previous letter indicated that brake hose and brake hose assemblies sold to the military in conformity with MIL-H-3992C are, because of the provisions of 49 CFR 571.7(c), subject to neither the labeling not the performance requirements of Standard No. 106-74 only that equipment which is sold directly to the Armed Forces, the NHTSA interprets this section as also excluding that equipment 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. #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.