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: nht90-3.44OpenTYPE: Interpretation-NHTSA DATE: August 2, 1990 FROM: Paul Jackson Rice, NHTSA TO: T. Spingler, Robert Bosch GmbH TITLE: None ATTACHMT: Letter dated 7-19-90 to R. v. Iderstine from T. Spingler; (OCC 5014) TEXT: This is in reply to your FAX of July 19, 1990, to Richard Van Iderstine of this agency asking for confirmation of an oral interpretation provided you by Jere Medlin, Office of Rulemaking, with respect to replaceable bulb headlamps. Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, defines (section S3) a replaceable bulb headlamp as "a headlamp comprising a bonded lens and reflector assembly and one or two standardized replaceable light sour ces." In Europe you fix the lens to the reflector assembly with a rubber seal and clips. For the U.S. market you propose to add "silicone-glue at four places between lens and housing to prevent removal of the lens." Mr. Medlin informed you that this w ould be a "bonded lens and reflector assembly." The standard does not define "bonded", but the intent of the definition is that, once the lens is joined to the reflector assembly, it shall not be separable. Any method of adhesion that accomplishes this would be a sufficient bond for purposes of the d efinition. If the application of silicone glue at four places between the lens and the reflector assembly is sufficient to prevent manual separation of the lens from the assembly, then it would be a sufficient bond. I hope that this answers your question. |
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ID: nht95-4.44OpenTYPE: INTERPRETATION-NHTSA DATE: October 3, 1995 FROM: Tom Byrne -- Vice President, Goodridge (USA) Inc. TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: NONE ATTACHMT: 12/12/95 letter from Samuel J. Dubbin to Tom Byrne (Redbook (2); Std. 106) TEXT: Goodridge (UK) Ltd. has been awarded approval/certification for its Brakelines by the TUV Manheim, Germany. The test procedures and requirements were those of FMVSS 106. We are therefore now able to offer Stainless Steel Braided Brakelines that are leg al for Street and Highway use in Europe and we believe the United States. We have completed the necessary paperwork and have filed for a USA DOT Manufacturers number. In order to avoid any possible confusion or irregularity, can you please confirm: * an independent laboratory certification that the line meets the requirements of FMVSS 106 is valid for the United States. * that such a brakeline can be used with an adapter into the master cylinder or caliper (for example, where pipe thread has been used). * are there any special marking requirements for the United States? We are required to tag with our manufacturers nam e, type of assembly and date of manufacture. I am submitting to you a copy of our TUV Certificate and an English translation. This is confidential material and I ask that you please give it confidential treatment. I thank you for your consideration of my request and look forward to your timely res ponse. Please feel free to contact me at (408) 452-1664. |
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ID: nht81-3.2OpenDATE: 07/28/81 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: The Armstrong Rubber Company TITLE: FMVSS INTERPRETATION TEXT: This responds to your recent request for an interpretation of the labeling requirements of Safety Standard No. 119 (49 CFR @ 571.119). Specifically you asked if the requirements of section S6.5(f), requiring the tire label to show the actual number of plies, and the composition of the ply cord material would be satisfied by the Marking: "Tread - 2 plies Polyester + 2 Aramid Woven Belts Sidewall - 2 plies Polyester." It has been a longstanding policy of this agency not to issue advance approval of labeling information. However, we will state that marking appears to satisfy the requirements of section S6.5(f) if it is slightly modified. Specifically, the reference to "belts" should be deleted, and the word "plies" should be substituted. The purpose of the marking requirements in Standard No. 119 is to ensure that the user of the tire is provided with technical information in a straightforward manner. This information is necessary for the safe use of the tire. Section S6.5(f) of the Standard requires that the marking include only the actual number of plies and the composition of the ply cord material. To satisfy this requirement, the information for the tread should appear as: "Tread - 2 plies Polyester + 2 plies Woven Aramid." Your desire to represent the ply cords as belts probably represents a marketing effort by Armstrong to convince purchasers to buy this particular tire. This agency has no reason to believe that these tires are not outstanding performance tires or to reduce your marketing efforts. However, it is inappropriate to extend this marketing effort to the Federally required markings on the sidewall of the tires. Sincerely, ATTACH. May 8, 1981 Frank Berndt, Chief Counsel of National Highway Traffic Safety Administration -- U.S. Department of Transportation Dear Mr. Berndt: This letter is a request for an interpretation of identification for material placed in a tire as specified in Part 571.119, S5.6(f). The Armstrong Rubber Company is planning to produce radial ply tires with an Aramid Woven Belt. Our preference would be to mark the sidewall of the tire as follows: Tread - 2 plies Polyester + 2 Aramid Woven Belts Sidewall - 2 plies Polyester This woven belt is a new design for tread reinforcing material that has been tested by The Armstrong Rubber Company and found to be very satisfactory for use in radial ply tires. I trust this information will permit you to respond. Sincerely, THE ARMSTRONG RUBBER COMPANY; R. W. Cheetham -- Director of Quality Assurance cc: Francis Armstrong |
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ID: nht78-4.10OpenDATE: 09/05/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Vespa of America Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of July 3, 1978, requesting an interpretation of Motor Vehicle Safety Standard No. 108, specifically, whether turn signal systems installed on mopeds must meet the standard's requirements. One of NHTSA's engineers has informally advised you, in your words, "that because turn signal units on mopeds are not required devices. . . they are not required to meet the specific requirements in FMVSS 108 relative to motorcycles as long as they do not affect the operation of the other required equipment." We are pleased that Vespa is considering installing turn signal lamps on motor vehicles that S4.1.1.26 excuses from having them. If you wish to install systems that you intend to comply with Standard No. 108 and which for one reason or another fail to do so, it is doubtful that NHTSA would take any action against Vespa since the equipment is clearly optional and added only at a manufacturer's discretion. We would also view as preempted under Section 103(d) of the National Traffic and Motor Vehicle Safety Act any State action either to require turn signal lamps on mopeds or to establish requirements for such were they added at the option of the manufacturer. I hope this clarifies the matter for you. SINCERELY, vespa of america corporation July 3, 1978 Joseph J. Levin, Jr. Chief Counsel U.S. DEPT. OF TRANSPORTATION National Highway Traffic Safety Administration Dear Mr. Levin: It is suggested, by Mr. George Shifflet, that an official comment should be solicited from your office to verify our interpretation regarding voluntary equipment of turn signal systems on mopeds (motorized bicycles). It has been the understanding of Vespa of America Corporation that if a piece of equipment is offered on a moped which is exempted from its requirement (as turn signal systems are exempted as specified - FMVSS 108 Sec. S4.1.1.26) than that piece of equipment must meet all requirements set forth in the respective FMVS Standard. During my phone conversation with Mr. Shifflet, he offered information to the contrary. He stated, that because turn signal units on mopeds are not required devices under FMVS Standards, they are not required to meet the specific requirements in FMVSS 108 relative to motorcycles as long as they do not affect the operation of the other required equipment. If Mr. Shifflet's statement is true, then existing State requirements would apply to moped turn signal units. I am anxiously awaiting your comments as they are the basis for our action. I remain, Donald Beyer National Service Manager |
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ID: 19663.DRNOpenThe Honorable Lee Terry Dear Congressman Terry: Thank you for your letter forwarding correspondence from Ms. Gina Dunning, former Director of the Nebraska Department of Health and Human Services, Regulation and Licensure. Your letter was forwarded to my office for reply, because the National Highway Traffic Safety Administration (NHTSA) administers the Federal school bus safety program. Ms. Dunning wrote to you with concerns about a NHTSA regulation affecting child care centers and Head Start programs. In essence, Ms. Dunning was concerned that we have interpreted our statute to disallow dealers' sales of certain new buses to after school care programs that will significantly use the bus to transport school children "to or from school or an event related to school." The buses are those that are not certified as meeting NHTSA's school bus standards. Ms. Dunning has written a separate letter to me, expressing her concern about our interpretation and how it would affect child care transportation providers in Nebraska. Her letter to me is substantially similar to the letter she addressed to you. While we understand that Ms. Dunning is no longer the Director of the state agency, we responded to her successor, Mr. Richard Nelson, on March 25, 1999. I am enclosing a copy of my response for your information, with all referenced enclosures. I hope that the enclosed items are helpful. If you have any further questions, please feel free to contact me. Sincerely, |
1999 |
ID: 2778yOpen Herr T. Spingler FAX 07121/35-1792 Dear Herr Spingler: This is in reply to your FAX of July l9, l990, to Richard Van Iderstine of this agency asking for confirmation of an oral interpretation provided you by Jere Medlin, Office of Rulemaking, with respect to replaceable bulb headlamps. Motor Vehicle Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment, defines (section S3) a replaceable bulb headlamp as "a headlamp comprising a bonded lens and reflector assembly and one or two standardized replaceable light sources." In Europe you fix the lens to the reflector assembly with a rubber seal and clips. For the U.S. market you propose to add "silicone-glue at four places between lens and housing to prevent removal of the lens." Mr. Medlin informed you that this would be a "bonded lens and reflector assembly." The standard does not define "bonded", but the intent of the definition is that, once the lens is joined to the reflector assembly, it shall not be separable. Any method of adhesion that accomplishes this would be a sufficient bond for purposes of the definition. If the application of silicone glue at four places between the lens and the reflector assembly is sufficient to prevent manual separation of the lens from the assembly, then it would be a sufficient bond. I hope that this answers your question. Sincerely,,
Paul Jackson Rice Chief Counsel ref:l08 d:l2/24/90 |
1990 |
ID: 2632yOpen Mr. Herr T. Spingler FAX 07121/35-1792 Dear Herr Spingler: This is in reply to your FAX of July l9, l990, to Richard Van Iderstine of this agency asking for confirmation of an oral interpretation provided you by Jere Medlin, Office of Rulemaking, with respect to replaceable bulb headlamps. Motor Vehicle Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment, defines (section S3) a replaceable bulb headlamp as "a headlamp comprising a bonded lens and reflector assembly and one or two standardized replaceable light sources." In Europe you fix the lens to the reflector assembly with a rubber seal and clips. For the U.S. market you propose to add "silicone-glue at four places between lens and housing to prevent removal of the lens." Mr. Medlin informed you that this would be a "bonded lens and reflector assembly." The standard does not define "bonded", but the intent of the definition is that, once the lens is joined to the reflector assembly, it shall not be separable. Any method of adhesion that accomplishes this would be a sufficient bond for purposes of the definition. If the application of silicone glue at four places between the lens and the reflector assembly is sufficient to prevent manual separation of the lens from the assembly, then it would be a sufficient bond. I hope that this answers your question. Sincerely,,
Paul Jackson Rice Chief Counsel ref:l08 d:8/2/90 |
1990 |
ID: nht95-2.84OpenTYPE: INTERPRETATION-NHTSA DATE: May 17, 1995 FROM: Phyllis Armstrong -- General Sales Manager, Saturn of Puyallup (Washington) TO: Phillip Reckt, Chief Counsel, NHTSA TITLE: Phone Conference Evonne Ropell and Dick Morris ATTACHMT: ATTACHED TO 11/28/95 LETTER FROM Samuel J. Dubbin to Phyllis Armstrong (A43; Part 580); Also attached to 7/20/89 letter from Kathleen DeMeter to B.L. Swank TEXT: Dear Mr. Reckt: On May 17th, 1995, I called Nancy Kelly, Administrator of Department of Licensing for the State of Washington, regarding the towing mileage on the Saturn. As you may or may not be aware, the mileage on the Saturn does not register as the car is being to wed. Only driven miles record on the odometer. Nancy Kelly said she would investigate by having her office communicate with the National Highway Traffic Safety Association in Washington, D.C. and have a definitive answer for me today. I soon received a phone call from Evonne Ropell, Nancy Kelly's assistant, who had just completed a phone conference with Dick Morris. Evonne said that the NHTSA was well aware that Saturns did not record towed miles, and that the actual miles driven are what is to be recorded on the odometer statements. For example if a Saturn is towed and reflects 10,000 miles on the odometer, then the odometer statement should show 10,000. I am requesting a letter confirming these findings, as it is crucial information in our daily business affairs. It is terrific to have an agency that is readily available and supportive. |
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ID: nht76-3.48OpenDATE: 03/30/76 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Pullman Trailmobile TITLE: FMVSS INTERPRETATION TEXT: This responds to Trailmobile's March 4, 1976, letter asking if a trailer equipped with one or more axles that have a gross axle weight rating (GAWR) of 24,000 pounds or more is excluded from the requirements of Standard No. 121, Air Brake Systems. Section S3. of Standard No. 121 provides in part that any vehicle manufactured before September 1, 1977, that has a GAWR for any axle of 24,000 pounds or more is excluded from the standard. The determination of GAWR is made by the vehicle manufacturer (49 CFR 571.3) and must be based on the capabilities of the axle system at 60 mph. Because the determination is made by the vehicle manufacturer, the NHTSA is unable to say that the components you mention in your letter would necessarily constitute an axle system with a GAWR of 24,000 pounds. YOURS TRULY, Pullman Trailmobile March 4, 1976 Mr. Sidney F. Williams, Jr. National Highway Traffic Safety Administration Department of Transportation Regarding our telephone conversation of March 3rd, would you confirm our discussion that a van trailer, having an axle rated at 24,000 pounds GAWR, based on adequate springs, axle beam, bearings, etc. and tires per Tire and Rim Association 60 MPH Rating would indeed be exempt from the Standard No. 121 "Air Brake Systems". John R. Pratte Manager Materials Engineering |
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ID: nht81-2.20OpenDATE: 05/06/81 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: J. G. Frail TITLE: FMVSS INTERPRETATION TEXT: U.S. Department of Transportation National Highway Traffic Safety Administration May 6, 1981 NOA-30 Mr. John G. Frail P.O. Box 581 Bronxville, New York 10708 Dear Mr. Frail: This is in reply to your letter of April 9, 1981, to this agency asking, with respect to Motor Vehicle Safety Standard No. 108, "whether the minimum edge to edge separation distance between lamp and tail or stop lamp of 4 inches is measured outside of the lamp or inside of the lamp." You have asked this question in behalf of an "OEM supplier" in Germany. The requirement in Table IV of Standard No. 108 is that the minimum edge to edge separation distance between a turn signal lamp and a tail or stop lamp be 4 inches while the turn signal lamps themselves must have a minimum separation distance of 9 inches between their centerlines. (Your design is somewhat confusing as it depicts centerlines of stop lamps and turn signal lamps at 9 inches.) We interpret this as meaning the minimum separation distance between the edge of lighted area to be 4 inches, as depicted in "B" in your design. Of course, final responsibility for compliance with this requirement rests on the vehicle manufacturer rather than the equipment manufacturer. Sincerely, Original Signed By Frank Berndt Chief Counsel
John G. Frail Post Office Box 581 Bronxville, New York 10708 April 9, 1981 U.S. Department of Transportation National Highway Traffic Safety Administration Washington, D.C. 20590 Re: FMVSS 108 interpertation. Gentlemen: The attachment from the Federal Motor Vehicle Safety Standards and Regulations from ULO-WERK of West Germany questions the following: The contents of the attachment are that of Table III & Table IV (Part 571; S 108 11/12). They are interested, as illustrated by the client, the interpertation as to whether the minimum edge to edge separation distance between lamp and tail or stop lamp of 4 inches is measured outside of the lamp or inside of the lamp. They have not specified their concern other than being OEM suppliers. This question may have risen as a result of two manufacturers supplying the lamp for one vehicle. The outside ornamentation of the lamp may be the question resulting in how one should measure the distance. Also, if we assume the distance is basically for light output of the lamp (night time driving) they may have a reasonable question. So that I may inform our client, please advise in writing the proper interpertation of the subject specification as to wether the measurement of 4 inches regarding the distance between tail-stop-lamp and indicator lamp will be measured at the inside or outside of the spare lens. Please forward your answer to my above post office box address at your earliest convenience. Very truly yours, John G. Frail Attachment Omitted |
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.