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: nht68-3.34OpenDATE: 05/14/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Department of California Highway Patrol TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of March 1, 1968, to Mr. Edwin L. Slagle, requesting a clarification of the location requirements for identification lamps on real trailers. The brochures attached to your letter describe two types of reel trailers as manufactured by the Standard Trailer Company and designated as the "Reelmaster" and "Cable Winder/Stringer." These trailers are completely open in the rear with no permanently attached crossbar for mounting rear identification lamps. On these trailers, identification lamps mounted on permanently attached swinging arms which are located near the wheels of the trailers would appear to conform to the requirements of Motor Vehicle Safety Standard No. 108. With respect to the requirements of Standard No. 108. I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, 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 the standard. Thank you for writing. |
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ID: nht68-3.35OpenDATE: 05/07/68 FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA TO: Heiskell; Donelson; Adams; Williams & Wall TITLE: FMVSR INTERPRETATION TEXT: Mr. Bridwell has asked that I reply to your letter of April 9, 1968. Enclosed for your information is a copy of the chassis-cab ruling and regulation issued December 29, 1967. Under the terms of the ruling and regulation and the National Traffic and Motor Vehicle Safety Act of 1966, when a truck body manufacturer assembles the truck body to a chassis-cab he is responsible for certification only if the completed vehicle is delivered to a dealer or distributor. The body manufacturer assembling the body to the chassis-cab would, however, be responsible for the vehicle's compliance with the lighting standard if not previously met by the chassis-cab manufacturer. Moreover if the addition of the body affects the chassis-cabs previous compliance with standards the body manufacturer would be responsible for compliance. With regard to bodies mounted on chassis-cabs manufactured prior to January 1, 1968 compliance and certification is not required. However, the body, if manufactured on or after January 1, 1968, would have to contain glazing that complies with Standard No. 205 because the body is manufactured for use on motor vehicles and as such must meet any applicable equipment standards. |
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ID: nht68-3.36OpenDATE: 05/10/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Kaiser Jeep Corporation TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of April 17, 1968, to Mr. George C. Nield, requesting a confirmation of your interpretation of the visibility requirements for back-up lamps as specified in Motor Vehicle Safety Standard No. 108. You are correct in your interpretation that the visibility requirements for back-up lamps on multipurpose passenger vehicles and trucks will be predicated on the normal driving, or closed tail gate, position. Thank you for your interest in meeting the intent of the requirements of Standard No. 108. |
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ID: nht68-3.37OpenDATE: 05/13/68 FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA TO: Utility Body Company TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of March 7, 1968 in which you asked if your company, a manufacturer of truck bodies and truck equipment that installs its product on a chassis furnished by a dealer or the ultimate user, is required to certify that "the completed package, including the chassis, meets Standard 108?" Under the National Traffic and Motor Vehicle Safety Act of 1966, you are responsible for completing the vehicle so that it meets applicable standards. This means the vehicle should be assembled in a way that will not disturb existing compliance, and that portion of the vehicle you add must comply with any applicable standard. This is a duty separate from certification. You are required to certify compliance under section 114 of the Act only if you deliver a completed vehicle to a distributor or dealer, and the certification would be as to all standards applicable to the vehicle, including Standard 108. |
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ID: nht68-3.38OpenDATE: 07/08/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Gypsy Campers TITLE: FMVSR INTERPRETATION TEXT: Thank you for your letter of May 29, 1968, in which you state that your camper conversion is not subject to the requirements of the Federal Motor Vehicle Safety Standards. Please note the requirements for glazing in Federal Motor Vehicle Safety Standard No. 205, contained in our letter to you dated May 24, 1968. Should your modification involve installation of glazing, then these requirements would apply. Note also Standards No. 103, 106, 107, 111, and 211, which are applicable to a multi-purpose passenger vehicle. Your conversion of a van to a camper is conversion of a truck to a multi-purpose passenger vehicle, and therefore, requires compliance with applicable standards. |
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ID: nht68-3.39OpenDATE: 07/09/68 FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA TO: Mr. Philips B. Boyer TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of June 24 to the Department of Transportation asking if manufacturers of motor homes are "required to equip the seats in such units with seat belts." The self-propelled motor home is classified as a "multipurpose passenger vehicle" for purpose of the Federal motor vehicle safety standards. Currently seat belt installations and seat belt assembly anchorages are not required for multipurpose passenger vehicles, but if a seat belt assembly is(Illegible Word) by the vehicle manufacturer it must meet the requirement of Federal standard No. 209. On October 14, 1967 the Federal Highway Administrator established dockets to receive comments on possible requirements for seat belt installations and seat belt assembly anchorages in multipurpose passenger vehicles. These comments are now under evaluation. |
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ID: nht68-3.4OpenDATE: 10/03/68 FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA TO: Deputy Chief Experimental TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of August 23, 1965, to Dr. William Haddon, Jr., concerning windshield washers. Based upon the information you provided, your annually operated windshield washer system appears to meet the requirements of Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems. You state your washer system will deliver the required 15 cc of fluid to windshiell (as specified in paragraph 2.11 of SAB Recommended Practice J942, November 1965) within a period of 3 seconds or less (as specified in paragraph 4.4.2(b) of J942). You also state your manual system will meet the washer system capability requirements of paragraph 3.1 and the durability requirements of paragraph 3.4 of J942. Apparently your concern is that your annually operated system will not deliver 15 cc of fluid per stroke. However, if you can provide the required 15 cc of fluid by using additional strokes within a 3 second period and if this type of operation will clear 75% of the effective wipe pattern within 10 cycles, you meet the performance requirements we consider necessary for highway safety. |
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ID: nht68-3.40OpenDATE: 07/12/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Western Body and Hoist Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of April 9, 1968, to the Federal Highway Administration, in which you requested clarification of the requirements for amber side marker lamps and amber side reflectors. A copy of presently applicable standards, and some proposed standards are enclosed. Note that Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1969, requires amber front side marker lamps, and amber front side reflectors for vehicles of less than 30 feet overall length, and 80 or more inches in overall width. When the overall vehicle length is less than 30 feet and the front side marker lamps and front side reflectors have been mounted on the cab by the chassis-cab manufacturer, an additional set of the foregoing lamps and reflectors is not required on the body when it is installed. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, 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 the standard. I trust this answers your questions. |
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ID: nht68-3.41OpenDATE: 07/22/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Lodal, Incorporated TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of June 17, 1968, to the National Highway Safety Bureau, attention of Mr. Joseph R. O'Gorman, concerning the requirements for rear identification lamps and rear clearance lamps on your EVO Refuse Packer. Since no mounting height restrictions are specified for rear identification lamps in Motor Vehicle Safety Standard No. 108, these lamps may be mounted on or below the cross member between the rear wheels. Shielding may be necessary to protect the lamps. No clearance lamp may be combined optically with any tail lamp or identification lamps. Combination rear clearance and side marker lamps may be used providing the requirements for each are met. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, 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. |
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ID: nht68-3.42OpenDATE: 07/22/68 FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D. NHTSA TO: General Motors Technical Center TITLE: FMVSS INTERPRETATION TEXT: This is in reference to your letter of June 14, 1968. Enclosed is the Grant of Approval for equivalent seat assembly attachment hardware as requested in your letter. U.S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION NATIONAL HIGHWAY SAFETY BUREAU General Motors Corporation General Motors Technical Center Warren, Michigan 48090 GRANT OF APPROVAL In accordance with Paragraph S3. of Motor Vehicle Safety Standard No. 209, as amended, effective March 1, 1967, an interrupted thread bolt is an approved equivalent to the bolts specified in paragraph (f) of section 9.3 of Department of Commerce, National Bureau of Standards, Standards for Seat Belts for Use in Motor Vehicles (15 CFR 9) (31 F.R. 11528), provided it meets all other requirements of 15 CFR 9. Sincerely, William Haddon, Jr., M.D. Director Issued in Washington, D. C. on July 22, 1968 |
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.