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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| search results table | |
ID: aiam1049OpenMr. Elmer Morgan, Mapother and Morgan, 521 West Market Street, Louisville, KY 40202; Mr. Elmer Morgan Mapother and Morgan 521 West Market Street Louisville KY 40202; Dear Mr. Morgan: This is in response to your question concerning the status o repossessing banks and finance companies as transferors under the odometer disclosure requirements of the Motor Vehicle Information and Cost Savings Act.; Banks and finance companies are obliged to make a disclosure upo resale of a repossessed vehicle. It is advisable to provide a disclosure form to be filled out by the defaulting transferor upon repossession. Should the defaulting transferor refuse to complete the form and the odometer is later found to be in error he may be subject to civil action under the Act.; In any case, if the bank or finance company does not know that th mileage is wrong, they should not state that the mileage is in error. If the repossessor wishes to add a statement that the vehicle has been repossessed or otherwise outside his control, he may do so.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3074OpenMr. J. C. Eckhold, Director, Automotive Safety Office, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold Director Automotive Safety Office Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. Eckhold: This is in response to your letter of August 3, 1979, asking whethe Ford may ship to distributors and dealers vehicles with bumper guards, needed for compliance with Part 581, *Bumper Standard* (49 CFR Part 581), placed inside the vehicles for installation prior to sale of the vehicles to consumers. You state that the bumper guards, which would be attached by dealers and others making use of pre-processed mounting holes in the vehicle bumpers, would reduce railroad car capacity, if installed prior to shipment. You also suggest that absence of reference in the Customs regulations (19 CFR Part 12) to readily attachable components needed to comply with regulations issued under the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901), may lead to complications in the importation of vehicles prior to installation of readily attachable bumper components.; The National Highway Traffic Safety Administration has no objection t the shipment of vehicles with readily attachable bumper components stored in the vehicles for later installation, provided the components are attached before the vehicles are offered for sale to the first purchaser for purposes other than resale. Further, regulations governing importation of motor vehicles (19 CFR 12.80) apply only to compliance with Federal motor vehicle safety standards, as set forth in 49 CFR Part 571, and the question of compliance with Part 581, therefore, should not arise.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1419OpenMr. Merle R. Flagg, Attorney at Law, Flagg, Cooper, Hayner, Miller, Long & Owen, 28th Floor 2001 Bryan Tower, Dallas, TX 75201; Mr. Merle R. Flagg Attorney at Law Flagg Cooper Hayner Miller Long & Owen 28th Floor 2001 Bryan Tower Dallas TX 75201; Dear Mr. Flagg: This is in reply to your letter of January 17, 1974, in which yo enclose a sample of the wording your client intends to use on his certification label, and solicit our comments.; The proposal that would allow an alternative to the required listing o individual axles (Docket No. 73-31, Notice 1) would become effective on the date of publication of the final rule, Consequently, certifiction labels using a single value for identical weight ratings may not be used until that time. The label you submit for approval does conform to the current proposal. However, we are considering requiring the inclusion of tire-size designations on the certification label when the gross axle weight ratings are combined.; We have no objection to the additional information contained on th label on the right of the required information. As we understand it, this will lessen the likelihood of mislabeling by the asembler in the field. It would not be possible for him to use a label that would overrate the trailer.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam3424OpenMr. Erik Sundelin, Diplomengineer, Trelleborg AB, Tire Division, Box 501, Fack 231 01, Trelleborg, Sweden; Mr. Erik Sundelin Diplomengineer Trelleborg AB Tire Division Box 501 Fack 231 01 Trelleborg Sweden; Dear Mr. Sundelin: This responds to your recent letter asking for information concernin the requirements of Safety Standard No. 119 (49 CFR S 571.119), as it applies to motorcycle tires. Specifically, you asked what markings must be on the sidewalls of knobby motocross tires (motorcycle tires designed for off-road use) to satisfy the requirements of Standard 119.; If your company designs the tires exclusively for off-road use, with n expectation that they will be used when the motorcycle is on the public roads, Standard 119 is not applicable to the tires. Therefore, no markings would be required on the sidewall of the tires. On the other hand, if you believe the motocross tires will, in fact, be used on the public roads, as well as off-road, they must meet the marking requirements specified in section S6.5 of Standard No. 119 (copy enclosed).; Standard No. 119 and its marking requirements apply to all new tire designed for highway use on non-passenger-car motor vehicles. In response to the petitions for reconsideration of Standard 119, the agency stated that manufacturers of motocross tires would have to determine if the tires were designed for highway use (see 39 FR 5191, February 11, 1974, copy enclosed). In the absence of a showing to the contrary, however, this agency would assume that motorcycles equipped with motocross tires are ridden on the public highways to and from race competition or trail use, which would mean the tires are subject to the requirements of Standard 119.; Following the publication of the above-mentioned notice, a manufacture of motocross tires requested an interpretation of Standard 119, and stated that its motocross tires are not suitable for use on public roads, and are not designed for such use. The agency responded that such tires are not subject to the requirements of Standard 119, based on this set of circumstances.; However, as noted above, each manufacturer must make thi determination. Please note that if you decide that the tires are not subject to Standard 119, 49 CFR Part 574 prohibits the DOT certification label from appearing on the sidewall of the tire. Please further note that a manufacturer's determination of this point is not dispositive. That is, this agency has authority to independently re-examine the manufacturer's determination. If the manufacturer's determination was incorrect, the manufacturer would be liable for civil penalties of up to $1,000 for each tire imported into this county which did not meet all the requirements of Standard 119. If you need any further information on this subject, please do not hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2665OpenMr. R. W. Hildebrandt, Group Director of Engineering, Bendix Heavy Vehicle Systems Group, The Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hildebrandt Group Director of Engineering Bendix Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hildebrandt: This is to advise you that the National Highway Traffic Safet Administration (NHTSA) has decided to grant The Bendix Corporation's September 14, 1977, petition requesting the revision of the parking brake release requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 121, *Air Brake Systems*. A similar petition was received from Fruehauf Corporation and it is also being granted.; You should understand that our commencement of a rulemaking proceedin does not signify that the rule in question will be issued. A decision to the issuance of the rule will be made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.; You also requested written confirmation that the interpretation o S5.6.3 of FMVSS No. 121 given by NHTSA to Motor Coach Industries, Inc. on April 14, 1976, would pertain to the air/spring parking brake system described in your letter. Your assumption is correct, and this letter constitutes such written confirmation.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0658OpenMr. Joseph Mazzafro, Manager Production Engineering, Strick Corporation, U.S. Highway No. 1, Fairless Hills, PA 19030; Mr. Joseph Mazzafro Manager Production Engineering Strick Corporation U.S. Highway No. 1 Fairless Hills PA 19030; Dear Mr. Mazzafro: This is in reply to your letter of February 25, 1972, enclosing sampl certification labels and requesting our review and comments. The labels you have submitted follow correspondence to you from NHTSA dated February 18, 1972, wherein we disapproved an earlier format you wished to use. Your revised label consists of multiple listings using punched holes and overlays to indicate appropriate information.; We do consider your revised label to be completely consistent with th Certification regulations (Part 567) in that the information is still presented in a way that is somewhat (and we might add unnecessarily) confusing. This confusion occurs because you do not fully delete information that is inapplicable to the vehicle in question. For example, regarding GVWR and GAWR in samples 2 and 3, you do not delete the entire number (leaving the zeroes and the suffix, lbs.) and it is not clear, in our view, whether the figures have been deleted or whether the label is disfigured. We believe the entire figure should be deleted where it is not applicable. Similarly, in the case of month and year, and vehicle number, all the information you wish to omit should be completely deleted. This would require deletion of all months other than the month of manufacture and all numbers other than the vehicle number.; Finally, in using an overlay (sample 4), the overlay should be done i such a manner that the label does not give the appearance of having been tampered with.; We trust this clarifies the situation. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam3977OpenMr. V. Stuart James, Executive Vice President, X-Ten Corporation, 855 Sansome Street, San Franciso(sic), California 94111; Mr. V. Stuart James Executive Vice President X-Ten Corporation 855 Sansome Street San Franciso(sic) California 94111; Dear Mr. James: this responds to your letter to Mr. Kratzke of my staff, asking for a interpretation of the requirements of Standard No. 121, *Air Brake Systems* (49 CFR S571.121). Specifically, you asked if the timing requirements of S5.3.3 and S5.3.4 must be satisfied by trailers which are 'heavy hauler trailers' within the meaning of S4. As Mr. Kratzke told you in a telephone conversation, heavy hauler trailers are exempted from all the requirements of S5.3, including the timing requirements.; You stated that your company is manufacturing extendable containe chassis trailers. The brake lines in those vehicles are designed to extend with the vehicle frame. S4 of Standard No. 121 defines, in part, a heavy hauler trailer as a trailer whose 'brake lines are designed to adapt to separation or extension of the vehicle frame...' Thus, your trailer would be considered a heavy hauler trailer for the purpose of Standard No. 121.; Section S5.3 sets forth road test requirements, compliance with whic must be certified for all trucks, buses and trailers. Generally, all trailers are required to be certified as complying with the timing requirements of S5.3.3 and S5.3.4. This general rule is limited by the last sentence of the S5.3, which specifies, 'However, *a heavy hauler trailer* and the truck and trailer portions of an auto transporter *need not meet the requirements of S5.3*' [Emphasis added] Thus, heavy hauler trailers are expressly exempted from all the requirements of S5.3, including the timing requirements.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2235OpenMr. Heinz W. Gerth, Vice President, Engineering and Service, Mercedes- Benz of North America, Inc., One Mercedes Drive, P. O. Box 350, Montvale, NJ 07645; Mr. Heinz W. Gerth Vice President Engineering and Service Mercedes- Benz of North America Inc. One Mercedes Drive P. O. Box 350 Montvale NJ 07645; Dear Mr. Gerth: This is in response to your letter of January 26, 1976, concerning th applicability of the pendulum impact requirements of Standard No. 215, *Exterior Protection*, to vehicles that are capable of height adjustment through the suspension system controls.; You described in your letter a system on your 450SEL 6.9 liter mode which allows a driver to adjust the height of the vehicle with the suspension system controls. When the vehicle is in the elevated position, a red warning lamp in the instrument cluster is illuminated in order to alert the driver to the fact that the vehicle is not in its recommended driving position for normal road conditions. In addition, the owner's manual informs the driver that the vehicle should be operated in the raised position only when being driven on rough terrain.; Standard No. 215 requires that vehicles be capable of complying wit certain damage criteria when impacted at any height between 16 and 20 inches by a pendulum test device. Since the 450SEL is constructed in such a manner as to allow its operation at a range of heights, testing for compliance with the pendulum impact requirements must be conducted with the vehicle in all such positions.; There is no language in the standard which would limit it applicability to vehicles in only their recommended driving position for normal roadways. The range of heights available for operation must be addressed during compliance testing and the vehicle must satisfy the damage criteria at all levels. The warning light that is activated when the vehicle is in the raised position and the owner's manual warning that the vehicle should be operated in the raised position only when driving over rough terrain do not alter the responsibility of the manufacturer to assure vehicle compliance at all positions with the bumper pendulum requirements. The vehicle is capable of being driven at any and all times in the raised position and, therefore, must comply with the bumper standard's pendulum requirements.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0208OpenMr. W. B. Colquhoun, Executive Vice-President, Norton Villiers Corporation, North Way, Andover, Hampshire, England; Mr. W. B. Colquhoun Executive Vice-President Norton Villiers Corporation North Way Andover Hampshire England; Dear Mr. Colquhoun: Thank you for your letter of January 22, 1970, enclosing ten copies o the Consumer Information for motorcycles produced by Norton Villiers Corporation.; Your submittal has on its face eliminated the problems that were calle to your attention in our letter of January 9. The form in which the information is presented deviates, however, from the form prescribed by the regulations, sections 375.101 and 106. The most significant deviation is the omission of the explanatory statements that are required for both types of information. The figures included with each section of the regulations should be followed closely in your presentation of the information to purchasers.; Please let us know if we can be of further assistance. Sincerely, Douglas W. Toms, Director |
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ID: aiam2720OpenMr. Tokio Iinuma, Nissan Motor Co., Ltd., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, New Jersey 07632; Mr. Tokio Iinuma Nissan Motor Co. Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs New Jersey 07632; Dear Mr. Iinuma: This responds to your October 4, 1977 letter asking whether Standar No. 118 *Power-Operated Window Systems*, prohibits the operation of power windows when the ignition key is in the 'Accessories' position.; Standard No. 118 requires only that power windows be inoperable whe the key is in the 'off' position or is removes from the lock, with certain exceptions outlines in S3. It is permissible for the windows to operate normally when the key is in the 'Accessories' position.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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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.