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: 10161Open Ms. Sally O'Cordan Dear Ms. O'Cordan: This responds to your question about whether any Federal motor vehicle safety standard (FMVSS) applies to glass used in a travel trailer. You stated that your law office was investigating an accident in which an individual was injured by glass of such a vehicle. Please be aware that no FMVSS applies to the glazing (the term the agency uses for glass) in trailers. The agency has issued one standard, FMVSS No. 205, Glazing Materials, (49 CFR '571.205), which applies to glazing in some motor vehicles. However, this standard does not apply to glazing in trailers, which our regulations define as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle" (49 CFR '571.3). You may wish to contact the State of Wisconsin about the regulation of glass in trailers. The State has the authority to regulate the operation and modification of vehicles by their owners. Wisconsin may have used this authority to issue regulations about glazing in travel trailers. I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely,
John Womack Acting Chief Counsel ref:205 d:8/26/94
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1994 |
ID: nht72-4.36OpenDATE: 05/08/72 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Lee Equipment Incorporated TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of April 11, 1972, to our New York office, that has been referred to me. Paragraph 568,3 of Title 49 of the Code of Federal Regulations states," 'Final stage' manufacturer means a person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle." The subject is also dealt with in the Preamble to Part 568" . . . The definitions by which the regulation establishes the categories of 'incompete vehicle,' 'completed vehicle,' and the three categories of vehicle manufacturers provide a framework within which each may categorize himself and his products. Of necessity, the definitions are broad and may not clearly define individual situations . . . . In the usual case, it will be possible for the affected manufacturers to reach agreement between themselves as to their respective obligations . . . ." (emphasis added) In the event that the matter is in dispute between yourself and the tank installer we would be inclined, based on the information in hand, to rule that the tank installer is the final stage manufacturer inasmuch as the equipment that you install would be "readily attachable." Your obligations as a manufacturer would be the same whether the tank you install on the new chassis is new or used. I trust this will answer your questions. |
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ID: 11799.MLSOpen Mr. Tom Byrne Dear Mr. Byrne: This responds to your April 19, 1996 request for an interpretation of certain hydraulic brake hose labeling requirements in Federal Motor Vehicle Safety Standard No. 106, ABrake Hoses.@ You ask whether a hydraulic brake hose that is sold as part of a brake hose assembly would meet the requirements of S5.2.1 and S5.2.2 if it has the stripes specified in S5.2.1 but does not include the information in S5.2.2(a) through (e). The answer is yes. Hydraulic brake hoses must be marked with: (1) two stripes meeting the requirements of '5.2.1 of Standard No. 106, unless the hose is of a type excluded under that paragraph; and (2) the information set forth in '5.2.2(a) through (e), until the hose is made into a brake hose assembly. After such assembly, the labeling information of '5.2.2(a) through (e) Aneed not be present on hose . . . .@ (See last sentence of '5.2.2.) However, the hose must continue to have the stripes required by '5.2.1. In addition, the hose assembly would have to be labeled in accordance with the requirements of '5.2.4 or '5.2.4.1 for labeling hydraulic brake hose assemblies. If you have any further questions, please contact Mr. Marvin Shaw of this office at (202) 366-2992. Sincerely,
Samuel J. Dubbin Chief Counsel ref:106 d:5/10/96 |
1996 |
ID: nht87-3.16OpenTYPE: INTERPRETATION-NHTSA DATE: OCTOBER 20, 1987 FROM: T. J. BROWN -- GENERAL MGR., PRODUCT SERVICES, MOHAWK TIRE COMPANY TO: ERIKA Z. ZONES -- CHIEF COUNSEL, NHTSA ATTACHMT: 11/23/88 letter from Erika Z. Jones to T.J. Brown (A33; Std. 109) TEXT: The Mohawk Rubber Company is in the process of purchasing for resale, a group of metric size tires from a manufacturer in the Far East. It has come to our attention that the maximum load and maximum pressures molded on the sidewalls of the tires are ind icated in kilograms and kilopascals only without any indication of the maximum pounds and PSI pressure. After reviewing MVSS #109, it is not clear as to whether or not these tires are in compliance with the standard and the purpose of this letter is to request your interpretation or ruling in this matter. The actual stamping on the tires is indicated as follows: Size 165SR15 Load Range B Maximum Load 530kgs - Maximum Pressure 230KPA 185SR14 Load Range B Maximum Load 600kgs - Maximum Pressure 230KPA 175SR14 Load Range B Maximum Load 560kgs - Maximum Pressure 230KPA 165SR13 Load Range B Maxim um Load 475kgs - Maximum Pressure 230KPA 155SR13 Load Range B Maximum Load 420kgs - Maximum Pressure 220KPA According to the European Tire and Rim Technical Organization, the loads and pressures are correctly designated on these tires, however, we do question if the omission of the load designation and pressure in pounds prohibits them being sold in the U.S .A. We will appreciate your response to our request for a ruling in this matter. |
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ID: nht76-3.41OpenDATE: 11/10/76 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Mr. J. W. Lawrence TITLE: FMVSR INTERPRETATION TEXT: This is in response to your July 19, 1976, letter requesting an interpretation of @ 567.4(g) of 49 CFR Part 567, Certification, with respect to the listing of pound and kilogram weight ratings. You have cited my June 30, 1976, letter to Toyota Motor Sales, which stated that weight ratings may be expressed in both pounds and kilograms, provided that each kilogram rating appears "after" the corresponding pound rating. You have also cited 49 CFR Part 567.4(g), which specifies that "Gross Axle Weight Rating" or "GVWR" be "followed by" the pound ratings for each axle, identified in order from front to rear. If A and B are two items of information on a label, the NHTSA interprets "A is followed by B" to mean "B appears to the right of A or below A or both." We consider "B appears after A" to have the identical meaning. The pairing of pound and kilogram ratings that is permitted by the interpretation in the Toyota letter must appear hierarchically within the sequence of axle ratings specified in @ 567.4(g). For example, the following listing is permitted: GAWR FRONT 2000lbs/907kgs Rear 2200lbs/998kgs while the following listing is not permitted: GAWR FRONT 2000lbs REAR 2200lbs (907kgs/998kgs). |
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ID: 15403.ogmOpenMs. Shirley Thornber Dear Ms. Thornber: You have asked if Chapter 329 of Title 49 of the United States Code, "Automobile Fuel Economy," and "Motor Vehicle and Driver Programs in Title 49, United States Code, Administered by The National Highway Traffic Safety Administration," both issued in May 1995, have been amended. In the event that the documents were amended since May 1995, you request that new copies be provided. If the documents have not been amended, you ask that we provide you with any expected amendment date. Chapter 329, "Automobile Fuel Economy," while provided to you in a separate document, is included within the document entitled "Motor Vehicle and Driver Programs in Title 49, United States Code, Administered by The National Highway Traffic Safety Administration." Both documents contain statutes administered by the National Highway Traffic Safety Administration. These statutes, which as federal laws, were created and are subject to amendment by the United States Congress conditioned upon approval by the President, have not been amended since May 1995. As any amendments to these statutes are acts of Congress rather than this agency, we cannot predict when future amendments will occur. I hope that this is responsive to your inquiry. Sincerely, |
1997 |
ID: 20513.ztvOpenMr. Gary D. Weintraub Dear Mr. Weintraub: This is in reply to your letter of August 9, 1999, asking about the legality of front "brake" lamp systems. I enclose copies of two notices that we published in the Federal Register in December 1996, (61 FR 65510) and November 1998 (63 FR 59482) on supplementary vehicle lighting systems, including, specifically, front "brake" lamp systems (see discussions at 65515, and 59484 and 59486). In response to our December 1996, request for comments, Volvo commented that we should not prohibit front "brake" lamps. As we explained in the November 1998 response to the comments (at 59484), front "brake" lamps are prohibited only if they impair the effectiveness of front lighting equipment required under Federal law, and that "assuming front 'brake' lamps were implemented so as not to interfere with the effectiveness of required front lighting equipment, front brake lamps are permitted to be installed on vehicles now, without any changes to the [U.S. Federal motor vehicle lighting standard]." If you have any questions, you may phone Taylor Vinson of this Office (202-366-5263). Sincerely, |
1999 |
ID: nht78-1.22OpenDATE: 09/22/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Dunlop Tire Company TITLE: FMVSS INTERPRETATION TEXT: This responds to your August 2, 1978, letter noting two standards of the National Highway Traffic Safety Administration that you consider to be in conflict. You suggest that Part 569, Regrooved Tires, conflicts with Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, in their requirements for the size of the molding of the word "regroovable". Standard No. 119 specifies all of the labeling of tires for motor vehicles other than passenger cars. The size of that required labeling is set at not less than .078 inches. This size provision applies generally to all of the various information required to be labeled on a tire. The information labeled on the tire includes the tire identification number and word "regroovable" if appropriate. Both of these requirements, however, are subjects of their own regulations. The tire identification number is specifically regulated by Part 574 and regroovable tires are regulated by Part 569. Each of these Parts further specifies the size designation of the information that it requires. For example, Part 569 specifically requires the word "regroovable" to be in letters .38 to .50 inches in height. The two standards do not conflict. The size requirement in Part 569 falls within the acceptable size levels of Standard No. 119. Part 569 merely further restricts the size of the word "regroovable" beyond that specified in Standard No. 119. Accordingly, the two are consistent. To understand both requirements, apply the general size requirements of Standard No. 119 to all information that is not otherwise regulated elsewhere. For information specifically regulated elsewhere, apply the size criteria specified in the applicable regulation. |
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ID: nht94-4.9OpenTYPE: Interpretation-NHTSA DATE: August 26, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Sally O'Cordan -- Ashley, Hannula & Halom (Superior, WI) TITLE: None ATTACHMT: Attached to letter dated 7/5/94 from Sally O'Cordan to Office of Chief Council, NHTSA TEXT: This responds to your question about whether any Federal motor vehicle safety standard (FMVSS) applies to glass used in a travel trailer. You stated that your law office was investigating an accident in which an individual was injured by glass of such a vehicle. Please be aware that no FMVSS applies to the glazing (the term the agency uses for glass) in trailers. The agency has issued one standard, FMVSS No. 205, Glazing Materials, (49 CFR S571.205), which applies to glazing in some motor vehicles. However, th is standard does not apply to glazing in trailers, which our regulations define as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle" (49 CFR S571.3). You may wish to contact the State of Wisconsin about the regulation of glass in trailers. The State has the authority to regulate the operation and modification of vehicles by their owners. Wisconsin may have used this authority to issue regulations ab out glazing in travel trailers. I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. |
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ID: nht71-3.19OpenDATE: 06/10/71 FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER TO: Triplex Safety Glass Co. Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of May 28, 1971, concerning the marking requirements in the proposed amendment to Standard No. 205, "Glazing Materials" (Docket No. 71-1; Notice 1). These requirements are only proposed at present, as is their effective date, and do not represent the agency's final decision on the matter. If the agency determines to amend the standard, and before any compliance with new requirements is required, a "final rule" will be issued that is based on the proposed rule but may differ in some respects from it. The final rule will specify an effective date for these new requirements which, in this instance, will probably be later than the effective date proposed. You ask whether the effective date of the proposed standard would apply to the manufacture of the glazing, or to the fitting of the material into the vehicle. Standard No. 205 applies to "glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses", and the effective date of any amendment to this standard refers to the date of manufacture of the glazing material, and not to its fitting into the vehicle. Your second question, whether we will accept your marking without a hyphen between the "DOT" symbol and your code mark, has been answered in our letter to you of May 26, 1971. I hope this clarifies the situation. |
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.