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: 002148drnOpenJanice Eret, Program Specialist Dear Ms. Eret: This responds to your March 26, 2003, letter to Dorothy Nakama of my staff requesting our views about proposed changes to the Nebraska Department of Educations pupil transportation rules that would create a multi-function activity bus classification that your State would permit to be used to transport pupils on school activity trips. In essence, the multi-function activity bus is a school bus without the school bus stop arm and the rear flashing lamps. You ask if the proposed changes would be permitted under the National Highway Traffic Safety Administration (NHTSAs) regulations. As you know, NHTSA is considering creating a new school bus vehicle subcategory that can be sold for school activity purposes. On November 5, 2002, (67 FR 67373) NHTSA issued a notice of proposed rulemaking (NPRM) to establish a new school bus subcategory, the Multifunction School Activity Bus (MFSAB). As proposed, an MFSAB would be a school bus with a gross vehicle weight rating of 6,804 kilograms (15,000 pounds) or less that meets all school bus Federal motor vehicle safety standards (FMVSSs), except for those requiring the stop arm and the flashing lights of a school bus. If NHTSA issues a final rule establishing the MFSAB subcategory, school bus manufacturers and dealers will be permitted to sell new MFSABs to schools and school districts for activity purposes. At present, school buses must have the stop arm required by FMVSS No. 131 and the rear flashing lamps required by FMVSS No. 108. Because multi-function activity buses would not have the stop arms and flashing lights, they could not be certified as meeting all school bus FMVSSs and thus cannot be sold to transport pupils to or from school or on school activities. If NHTSA makes the changes proposed by the November 2002 NPRM, then Nebraskas change to its regulation that permits the sale of the activity buses for school activity trips would be permitted. The agency is presently reviewing the comments responding to the NPRM and anticipates issuing a decision shortly. If you have any further questions, please feel free to contact Dorothy Nakama at this address or at (202) 366-2992. Sincerely, Chief Counsel |
2003 |
ID: nht69-2.30OpenDATE: 09/19/69 FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA TO: International Harvester Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter dated June 19, 1969, in which you request approval of an alternative to the specified certification label location in accordance with Part 367.4(c) of the regulations. Due to an oversight, your letter has not reached me until now, and I apologize for the delay in responding. Your proposed label location for models MA-1200 and MA-1500 Metro, on the panel below the wing glass, as shown in your enclosed sketch, is approved. |
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ID: nht74-5.57OpenDATE: 05/15/74 FROM: LAWRENCE R. SCHNEIDER -- CHIEF COUNSEL, NHTSA TO: PETER J. PITCHESS -- SHERIFF, COUNTY OF LOS ANGELES, TITLE: NONE TEXT: This is in response to your letter of May 2, 1974, requesting the results of the public hearing concerning safety standards for police vehicles held on December 10, 1973, and your petition in this regard. As you know, that hearing was held in conjunction with an advance notice of proposed rulemaking issued by this agency. We are in the final stage of analysis of both the public bearing and the comments in response to the advance notice, and will issue our conclusions in the near future. In the interim, all Federal Safety Standards continue to be applicable to police vehicles although you remain free to alter your vehicles after they are delivered to you. |
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ID: nht71-1.2OpenDATE: 07/12/71 FROM: AUTHOR UNAVAILABLE; D. Schneider; NHTSA TO: Toyota Motor Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of June 9, 1971, regarding the definition of "curb weight" in Motor Vehicle Safety Standard No. 110. The air conditioner and the additional weight optional engine are to be included in "curb weight" if the motor vehicle is equipped with these items. If the motor vehicle is not so equipped, then the items are not to be included in the "curb weight" or the "accessory weight". |
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ID: nht75-1.20OpenDATE: 08/21/75 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Toyoda Gosei Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: Please forgive the delay in responding to your letter of April 25, 1975, which questioned our interpretation of March 13, 1975, of the adhesion requirement of S7.3.7 of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses. Our interpretation was that the requirement applies to each pair of adjacent layers of a brake hose. Multilayer hose manufactured in the United States and Europe is in fact made with bonding between all pairs of adjacent layers. There is no change in our interpretation. |
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ID: nht73-5.38OpenDATE: 10/31/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Bankers Trust Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of September 17, 1973, which asks whether a bank must make an odometer disclosure statement upon transfer to an auctioneer of a repossessed vehicle in which the bank has only a security interest. To the extent that the bank is acting in the place of the repossessed owner, and in the absence of any other party available to make a statement, it is our opinion that the bank is acting as transferor and should make the disclosure specified in Part 580. Normally the bank does not know that the odometer is inaccurate and should only fill in the blank with the recorded mileage. The bank could authorize its collection agency to actually make the disclosure. |
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ID: nht92-2.6OpenDATE: 11/25/92 FROM: PHILIP E. STERN -- ATTORNEY FOR THE SUSSEX WANTAGE REGIONAL BOARD OF EDUCATION, RAND, ALGEIER, TOSTI AND WOODRUFF, ATTORNEYS AT LAW TO: PAUL JACKSON RICE -- NHTSA COPYEE: DR. DIBENEDETTO ATTACHMT: ATTACHED TO LETTER DATED 12-28-92 FROM PAUL J. RICE TO PHILIP E. STERN (A40; STD. 221) TEXT: Please be advised that I am the attorney for the Sussex Wantage Board of Education, a school district in Northern New Jersey. The School Board is interested in placing video cameras on school buses in order to promote safety. In order to best serve the interests of my client, kindly forward to my attention any information you may have on the issue of video cameras on school buses. I am particularly interested in speaking with any other school districts that may use video cameras on their school buses. Thank you in advance for your anticipated courtesy and cooperation in this matter. |
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ID: nht68-1.3OpenDATE: 08/22/68 FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA TO: E.T.R.T.O. TITLE: FMVSS INTERPRETATION TEXT: This in response to your letters of May 24, requesting (1) a footnote to Table 1-A to provide that equivalent millimeter designations may be marked on tire sizes in addition to the dimension sizes in inches; and (2) a footnote to Table 1-C to provide that the tire sizes provided in this table can be marked on the tire by giving the millimeter equivalent either before or after the size designation in inches. We do not consider that Table 1-A of the standard, as presently written, prohibits equivalent marking in millimeters as long as the conversion from inches to millimeters is exact and the tire meets the size and load carrying requirements shown in Table 1-A. Similarly, we do not consider that the standard as presently written prohibits the marking of the tire with equivalent millimeter sizes before or after the marking which gives the size of the tire in inches. In view of the above, a footnote is not considered necessary. |
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ID: nht69-2.5OpenDATE: 01/24/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: Nissan Motor Corporation in U.S.A. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of December 6, 1968, to Dr. William Haddon, Jr., Director, National Highway Safety Bureau, requesting a clarification of the requirements for a turn signal pilot indicator as specified in Motor Vehicle Safety Standard No. 108. With respect to the turn signal pilot indicator only, you are correct in your interpretation that so long as the indicator is the color green, the diameter circle is more than 3/16 inches, and the driver has a clear and unmistakable indication, it is not necessary to apply other test procedures in order to meet the requirements of Standard No. 108. The above provision in no way excepts turn signal lamps from meeting the requirements of SAR Standard J588d, June 1966. |
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ID: nht70-2.37OpenDATE: 12/02/70 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Charles O. Verrill, Esq. TITLE: FMVSS INTERPRETATION TEXT: In your letter of November 16 you inquire whether the Bureau's interpretation of "overall width" (49 CFR @ 571.21, with reference to Federal Motor Vehicle Safety Standard No. 108) can "embrace the situation where the entire lighting assembly, including the taillamps, stop lamps, and back-up lamps, as well as signal lamps, add to the dimension of the vehicle". Since "overall width" means "the nominal design dimension of the widest part of the vehicle exclusive of signal lamps [and] marker lamps . . . .", the Bureau concurs in your requested interpretation. Taillamps, stop lamps, and back-up lamps are "signal" lamps, and their combined mounting in a fixture which may extend beyond the widest part of a boat trailer does not result in a corresponding increase in the "overall width" of the trailer. |
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.