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: nht94-2.56OpenTYPE: Interpretation-NHTSA DATE: April 25, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Richard Kreutziger -- Executive Director, New York State Bus Distributors Ass'n. TITLE: None ATTACHMT: Attached to letter dated 4/13/94 from Richard Kreutziger to John Womack (OCC-9865) TEXT: This responds to your request of April 13, 1994, for an interpretation of Motor Vehicle Safety Standard No. 108. You reference paragraphs S5.5.7(a) and (b) which apply to vehicles of less than 80 inches overall width and ask whether there are similar requirements for wider vehicles. Paragraph S5.5.7(a) requires that "(w)hen the parking lamps are activated, the tail lamps, license plate lamps, and side marker lamps shall also be activated." There is no similar requirement for vehicles whose overall width is 80 inches or more because these vehicles are not required to have parking lamps (see Table I of Standard No. 108). Paragraph S5.5.7(b) requires that "(w)hen the headlamps are activated in a steady-burning state, the tail lamps, parking lamps, license plate lamps and side marker lamps shall also be activated." Paragraph S5.5.3 requires tail lamps on all vehicles, reg ardless of width, to be activated when the headlamps are activated in a steady burning state. As noted in the preceding paragraph, wide vehicles are not required to have parking lamps. This leaves the question of license plate lamps and side marker lamps. As you have surmised, there is no specific requirement in Standard No. 108 that these lamps be simultaneously activated with the headlamps on vehicles whose overall width is 80 inche s or greater. However, we understand that it is industry practice to wire its large vehicles in this manner. We also believe that those who do not wire the side marker lamps to operate with the headlamps include them in the separate switch that activat es the clearance and identification lamps. |
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ID: nht73-3.15OpenDATE: 01/22/73 FROM: AUTHOR UNAVAILABLE; E.T. Driver; NHTSA TO: Independent Tyre Sales and Service Pty. Limited TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of December 4, 1972, regarding the importation of radial ply retreaded tires into the United States. In order to import retreaded tires into the United States, they must comply with the Applicable Federal motor vehicle safety standards and regulations. Federal Motor Vehicle Safety Standard No. 117, "Retreaded(Illegible Word) Tires," (copy enclosed) was to become effective January 1, 1973.(Illegible Line) S5.1.1(d) and S5.1.1(e) of the standard will be deleted. A notice specifying the effective dates for the remaining provisions of the standard will be published in the(Illegible Words), and all retreaded tires manufactured after those dates must conform to the standard in order to be eligible for importation. Regulation Part 574 entitled "Tire Identification and Recordkeeping" applies to all tires manufactured after May 22, 1971, including retreads, for use on motor vehicles. A copy is enclosed. Please note that identification markings must be applied to tires by the manufacturer or retreader(Illegible Words)(Illegible Line) Complete instructions for obtaining a code and for its use are described in the(Illegible Word). A sample application form showing the information needed for assignment of a manufacturer's code number is also enclosed. It should be noted that Regulation Part 574 requires that the name and address of the tire purchaser be maintained by the manufacturer, or his designee, for a period of three years. The manufacturer is also to provide distributors and dealers the means for recording the required information. In addition to the above, there is a requirement that an agent be designated in accordance with section 110(e) of the National Traffic and Motor Vehicle Safety Act of 1966 and as set forth in the Procedural Rules, Subpart D - Service of Process: Agents, copy enclosed. The designation of agent should be mailed to the National Highway Traffic Safety Administration, Office of Chief Counsel, at this address. Please let us know if we can be of further assistance. |
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ID: nht75-5.5OpenDATE: 08/13/75 FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA TO: Continental Hydraulic Hose Corp. TITLE: FMVSR INTERPRETATION TEXT: Please forgive the delay in responding to your letter 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 Forces, 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, March 5, 1975 U. S. Department of Transportation National Highway Traffic Safety Adm.. Attention: Francis Armstrong Subject: MVSS No. 106 Effective March 1, 1975 we started shipping hydraulic brake hose to our various customers, conforming to subject standard. This includes the new labeling band which requires a price increase. One customer, A. M. General, in South Bend, Indiana has objected to this. Their end product is military vehicles on prime government contracts, which they claim are not covered by the standard. Please advise if such vehicles are included in the standard. CONTINENTAL HYDRAULIC HOSE CORP. James W. Long President |
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ID: 9865Open Mr. Richard Kreutziger Dear Mr. Kreutziger: This responds to your request of April 13, 1994, for an interpretation of Motor Vehicle Safety Standard No. 108. You reference paragraphs S5.5.7(a) and (b) which apply to vehicles of less than 80 inches overall width and ask whether there are similar requirements for wider vehicles. Paragraph S5.5.7(a) requires that "[w]hen the parking lamps are activated, the tail lamps, license plate lamps, and side marker lamps shall also be activated." There is no similar requirement for vehicles whose overall width is 80 inches or more because these vehicles are not required to have parking lamps (see Table I of Standard No. 108). Paragraph S5.5.7(b) requires that "[w]hen the headlamps are activated in a steady-burning state, the tail lamps, parking lamps, license plate lamps and side marker lamps shall also be activated." Paragraph S5.5.3 requires tail lamps on all vehicles, regardless of width, to be activated when the headlamps are activated in a steady burning state. As noted in the preceding paragraph, wide vehicles are not required to have parking lamps. This leaves the question of license plate lamps and side marker lamps. As you have surmised, there is no specific requirement in Standard No. 108 that these lamps be simultaneously activated with the headlamps on vehicles whose overall width is 80 inches or greater. However, we understand that it is industry practice to wire its large vehicles in this manner. We also believe that those who do not wire the side marker lamps to operate with the headlamps include them in the separate switch that activates the clearance and identification lamps. Sincerely, John Womack Acting Chief Counsel ref:108 d:4/25/94 |
1994 |
ID: nht94-6.11OpenDATE: April 25, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Richard Kreutziger -- Executive Director, New York State Bus Distributors Ass'n. TITLE: None ATTACHMT: Attached to letter dated 4/13/94 from Richard Kreutziger to John Womack (OCC-9865) TEXT: This responds to your request of April 13, 1994, for an interpretation of Motor Vehicle Safety Standard No. 108. You reference paragraphs S5.5.7(a) and (b) which apply to vehicles of less than 80 inches overall width and ask whether there are similar requirements for wider vehicles. Paragraph S5.5.7(a) requires that "(w)hen the parking lamps are activated, the tail lamps, license plate lamps, and side marker lamps shall also be activated." There is no similar requirement for vehicles whose overall width is 80 inches or more because these vehicles are not required to have parking lamps (see Table I of Standard No. 108). Paragraph S5.5.7(b) requires that "(w)hen the headlamps are activated in a steady-burning state, the tail lamps, parking lamps, license plate lamps and side marker lamps shall also be activated." Paragraph S5.5.3 requires tail lamps on all vehicles, regardless of width, to be activated when the headlamps are activated in a steady burning state. As noted in the preceding paragraph, wide vehicles are not required to have parking lamps. This leaves the question of license plate lamps and side marker lamps. As you have surmised, there is no specific requirement in Standard No. 108 that these lamps be simultaneously activated with the headlamps on vehicles whose overall width is 80 inches or greater. However, we understand that it is industry practice to wire its large vehicles in this manner. We also believe that those who do not wire the side marker lamps to operate with the headlamps include them in the separate switch that activates the clearance and identification lamps. |
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ID: nht67-1.20OpenDATE: 10/02/67 FROM: AUTHOR UNAVAILABLE; George C. Neild; NHTSA TO: Patton, Blew, Verrill, Krand and Boggs TITLE: FMVSS INTERPRETATION TEXT: In your letter of August 10, 1967, you requested clarification of the application of Motor Vehicle Safety Standard No.(Illegible Word) to boat trailers. Although a boat trailer does in some respect resemble a "pole trailer," it does not completely conform to the definition of a "pole trailer," as stated in Section 235.3 of the Initial Federal Motor Vehicle Safety Standards. This section states in part that a "pole trailer" is for transporting long or irregularly shaped loads such as poles, pipes, or structural members capable generally of sustaining themselves as(Illegible Word) between the supporting connections. The single load (a boat) on the boat trailer does not appear to meet these stated provisions of the definition. The primary purpose of clearance and identification lights is to identify a vehicle that is 80 or more inches in overall width, regardless of the height of the vehicle. It should be noted, in this respect, that a "height-above-road-surface"(Illegible Word) for location of the lights is not specified in Standard No.(Illegible Word). Nevertheless, we have initiated a study to further determine the applicability of identification lights to best trailers. With regard to your several questions on the use and location of side marker lights, it appears that each trailer model must be considered individually, particularly with respect to the front side marker lights. As you suggested, the extreme rear of the transverse marker provides a possible location for the rear side marker light. On those trailer models having a long transverse marker, it appears possible to locate the front side marker light on the extreme front side of the transverse marker. For those models having an extremely short transverse marker, it appears that a location as far forward as possible, exclusive of the trailer tongue, would meet the requirements of the standard. Thank you for your interest in the motor vehicle safety standards. |
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ID: GPScrashsensor.rtfOpen Mr. Ralph Longton Dear Mr. Longton: This responds to your letter of June 1, 2001. In that letter, you inquire about a system that LoJack is currently developing. This system will be located in the passenger compartment of a vehicle. In the event the vehicle is in a crash, the system will rate the crash as minor or major, alert a G.P.S. locator, and contact a clearinghouse. The clearinghouse will attempt to contact the driver or send assistance. You would like to know whether there are any regulatory obligations you may need to meet in the deployment and operation of such a device. The National Highway Traffic Safety Administration (NHTSA) cannot speak to all of your regulatory obligations, but only to Federal requirements in the area of automotive safety. We do not have any Federal motor vehicle safety standards (FMVSS) for this type of device. However, the FMVSS could be relevant to your device if the device affects a vehicle's compliance with any of the standards. We do not have sufficient information about your system to comment on whether it would likely affect a vehicle's compliance with the FMVSS. I have enclosed a copy of a paper titled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment" which identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers. I hope this answers your question. Should you have any more questions, please contact Edward Glancy of my staff at (202) 366-2992. Sincerely, John Womack Enclosure NCC-20:Eglancy:mar:6/26/01:62992:OCC23204 |
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ID: nht72-5.6OpenDATE: 09/26/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Blue Bird Body Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of August 24, 1972, requesting an opinion as to appropriate steps to take in certifying vehicles you complete when the chassis, as delivered to you, are equipped with tires which are inadequate for the loads the vehicles are intended to carry. You state you are presently certifying the vehicles on the basis of the load ratings of correct tires, arranging for these tires to be installed by the dealer, and requesting a notarized statement from him to that effect. As a basis for this procedure, you refer to our previous correspondence to you dated March 24, 1972, in which we authorized a somewhat similar procedure involving certain school buses. As stated to you in our letter of March 24, the procedure outlined therein "is allowed only as to chassis that have already been received by Blue Bird as of the receipt of this letter . . ." Blue Bird is the final-stage manufacturer, and is responsible for the weight ratings applied to the vehicles presently in question. These ratings must be consistent with the definitions of those terms in the regulations, and must reflect the characteristics of the vehicles at the time of their sale to the consumer, assuming further manufacturing does not occur. Although you receive assurances from a dealer that he will change the tires, this will not absolve you from responsibility under the regulations should the dealer fail to do so. We are of the opinion that the best procedure for Blue Bird to follow is to replace the tires before delivery to the dealer.
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ID: 1983-2.12OpenTYPE: INTERPRETATION-NHTSA DATE: 05/24/83 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Stephen E. Parmeter TITLE: FMVSS INTERPRETATION TEXT:
MAY 24 1983 NOA-30
Mr. Stephen E. Parmeter Route 4 Potsdam, New York 13676
Dear Mr. Parmeter:
This responds to your recent letter concerning the process of repairing breaks in automobile windshields. You ask whether such repairs would conflict with any present Federal motor vehicle safety standards.
The National Highway Traffic Safety Administration has issued Federal Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair process such as you describe, however. There is no Federal regulation which would prohibit the use of a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use.
Please note, however, that using such a material or process in a new windshield which may require repair (as a result of damage sustained, for example, in shipment) could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, or could fail to bring a noncomplying windshield back into compliance. Either case of noncompliance would be the responsibility of the person selling the windshield (49 CFR 567.7, copy enclosed). Therefore, we do not recommend use of windshield repair processes prior to the first purchase of a new windshield by a consumer. You will have to contact a private attorney to determine your liability under civil law with regards to such a business. Please contact Hugh Oates of my staff if you have any further questions.
Sincerely, Frank Berndt Chief Counsel
Enclosures |
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ID: nht76-2.42OpenDATE: 12/01/76 EST FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Koito Manufacturing Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of November 2, 1976, regarding questions on Docket No. 75-8; Notice 5, for a two-lamp rectangular headlamp system. The answers are provided in accordance with the paragraph numbering of your letter. 1) The two-lamp rectangular headlamps must meet the requirements of SAE J579c. This is an improved performance lamp over the requirements of SAE J579a and, therefore, must meet the requirements of SAE J579c. 2) The maximum permissible candela for the Type 2B headlamp is 75,000 as specified in SAE J579c. The lower limit for other types of headlamps is retained awaiting future rulemaking action. 3) SAE J580b as specified in the 1976 edition of the SAE Handbook is the correct reference specification for the Type 2B Sealed Beam Headlamp Assembly. 3-1) Answered above 3-2) Answered above 3-3) Appropriate revisions to subreferenced SAE standards have at this time not been made for the Type 2B headlamp. In the case of SAE J580b, conducting the tests with a modified deflectometer to fit the Type 2B lamp would be sufficient. It is anticipated that revisions will soon be made to the appropriate subreferenced SAE standards for the Type 2B headlamp. Your suggested revisions for the referenced and subreferenced SAE standards to incorporate the Type 2B headlamp, including a modified design of deflectometer, may be sent directly to: Society of Automotive Engineers Detroit Office, Suite 206 2100 West Big (Illegible Word) Troy, Michigan 43084 ATTENTION: Mr. James Tishkowski We hope this clarifies the questions contained in your letter. If you have additional questions, please do not hesitate to contact us. |
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.