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: nht68-4.6OpenDATE: 08/27/68 FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA TO: Volkswagen of America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your letter of July 31, 1968, to Mr. George C. Neild, Motor Vehicle Safety Performance Service, requesting the addition of a 5-K rim for use with a 5.60 x 15 tire to Table II of Federal Motor Vehicle Safety Standard No. 110. On the basic of the data submitted showing satisfactory completion of the test requirements specified in the Federal Motor Vehicle Safety Standards No. 109 and No. 110, your request for the approved equivalent rim is granted. The 5-K rim will be listed in Table II of Standard No, 110 and published in the Federal Register. |
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ID: nht72-4.31OpenDATE: 10/01/72 EST FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Chesapeake Marine Products TITLE: FMVSR INTERPRETATION TEXT: In your letter of September 21, 1972, you ask, "are there any "partial built" certification standards which would govern our operation as a boat trailer distributor?" I enclose a copy of 49 CFR Part 567, Certification, and Part 568, Vehicles Manufactured in Two or More Stages, for your review as to their applicability to your operations. They apply to manufacturers who initiate or complete the manufacturer of motor vehicles. They do not, however, impose an obligation upon a distributor of boat trailers who does not alter the vehicle he receives from a manufacturer in a manner that affects compliance with applicable standards. |
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ID: 22613.ztvOpen Mr. Paul Michelotti Dear Mr. Michelotti: This is in reply to your letter of January 12, 2001, to Frank Seales, Jr., the former Chief Counsel of this agency. You have asked whether "Federal Motor Vehicle Safety Standard No. 108 or any other federal regulation prohibit a hazard warning operating system that provides for automatic activation of vehicle hazard warning lights in an accident situation, in situations of rapid deceleration to a complete stop, or in situations of rapid deceleration in the speed of a vehicle over a short time interval?" Tables I and III of Standard No. 108 require motor vehicles to be equipped with vehicular hazard warning signal operating units, as specified in SAE Recommended Practice J910, February 1966. Paragraph 1 of SAE J910 defines the operating unit, in part, as "a driver controlled device which causes all turn signal lamps to flash simultaneously." We interpret "driver controlled" as meaning that the hazard warning signal unit must be activated and deactivated by the driver and not by automatic means. Sincerely, John Womack ref:108 |
2001 |
ID: nht71-2.45OpenDATE: 05/06/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Blue Bird Body Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of April 22, 1971, to Mr. Carter concerning section 574.10 of Part 574 - Tire Identification and Record Keeping, as it applies to tires on a chassis for which you sell and mount the body. In cases where the chassis are manufactured and sold with tires by the chassis manufacturer or chassis dealer, it would be permissible for the manufacturer of the chassis to maintain the record of tires on the chassis, and the name of the user of the chassis, and notify the users in the event a defect notification is required. |
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ID: nht68-2.41OpenDATE: 04/30/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Gilbert, Segall and Young TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of April 3, 1968, to Dr. Williams Haddon, Jr., requesting a clarification of the location requirements for license plate lamps as specified by Federal Motor Vehicle Safety Standard No. 108. The installation requirements contained in the SAE Standard that are referenced in Standard No. 108 are enforceable requirements unless specifically excepted by Standard No. 108. With respect to the installation of license plate(Illegible Word), Standard No. 108 provides an exception to the "Installation Recommendation" contained in SAE Standard(Illegible Words) in that Standard No. 108 requires a location(Illegible Word) rear license plate." This exception permits installation of the license plate lamp or lamps at the top, sides or bottom of the license plate, instead of top and sides only as specified by the SAE installation recommendations. Thank you for writing. |
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ID: 86-4.24OpenTYPE: INTERPRETATION-NHTSA DATE: 07/28/86 FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA TO: M. ARISAKA -- MANAGER, AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPARTMENT STANLEY ELECTRIC CO., LTD. TITLE: NONE ATTACHMT: LETTER DATED 06/18/86 TO ERIKA Z. JONES FROM M. ARISAKA TEXT: Dear Mr. Arisaka: This is in reply to your letter of June 18, 1986, in which you ask whether it is permissible to leave an inoperative center high-mounted stop lamp installed in a vehicle when an operative one is mounted on a spoiler at the rear of the car. We assume that the new lamp fully complies with the requirements of Motor Vehicle Safety Standard No. 108 for center high-mounted stop lamps. Our answer is that it is permissible to leave the inoperative lamp in place since its function has been assumed by a conforming lamp. We have no regulations that would either prohibit or require the removal of an inoperative lamp. Sincerely, |
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ID: nht72-1.13OpenDATE: 09/22/72 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Mr. Darrell L. Lindemann TITLE: FMVSS INTERPRETATION TEXT: This is in reference to your letter of September 8, 1972, concerning glare from chrome trim on the hood of your 1971 Ford Torino, which was forwarded to our attention by the National Transportation Safety Board. Federal Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces . . .", regulates the specular gloss of four types of bright metal components in the driver's field of view but does not include chrome trim on the hood of a vehicle. In an effort to extend the scope of this standard to make it more effective in reducing daylight glare, the National Highway Traffic Safety Administration has sponsored four contract investigations dealing with glare. The final report on the last entry will be completed soon. After studying the results of this research. We intend to revise Standard No. 107 to cover other glare-producing areas of the vehicle. |
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ID: nht91-2.41OpenDATE: March 20, 1991 FROM: H. Hurley Haywood -- Vice President, Brumos Motor Cars, Inc. TO: Chief Consul -- U.S. Department of Transportation, NHTSA TITLE: None ATTACHMT: Attached to letter dated 4-8-91 from Paul Jackson Rice to H. Hurley Haywood (A37; Part 591) TEXT: A company in England would like information regarding the sale of a very limited number of specially built cars in the U.S. All component parts, i.e.; engine, suspension, gear box would be manufactured by Porsche. The chassis would be a carbon fiber 962 racing tub with hand built body. The car could be built completely in England or shipped to the U.S. as a kit car and assembled here. The company would like information regarding low-volume manufacturers exemptions from certain DOT regulations, emmissions, passive restraints, bumper height, and all other pertinent information regarding manufacturing and sale of vehicles in the U.S. Thank you for your cooperation. |
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ID: nht75-3.21OpenDATE: 07/22/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Crown Coach Corporation TITLE: FMVSR INTERPRETATION TEXT: This is in reponse to your letter of June 26 in which you request a clarification of the definition of "date of manufacture" as that term is found in Section 567.4 of the certification regulations. As your vehicles are not manufactured in two or more stages, you are subject to the requirements of Section 567.4 with respect to certification. Section 567.4(g) (2) specifies the month and year of manufacture as "the time during which work was completed at the place of main assembly of the vehicle." This is when the vehicle is finished by you. The vehicle should be certified as meeting all of the Federal motor vehicle safety standards applicable as of that date. We trust that the above information is of assistance. If you have any further inquiries, please let us know. |
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ID: nht71-2.37OpenDATE: 04/30/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Recreational Vehicle Institute TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 8, 1971, requesting a confirmation of your understanding as to two sections of Standard No. 208, Occupant Crash Protection. You are correct in reading section S4.3 to provide options for trucks and multipurpose passenger vehicles of more than 10,000 pounds GVWR that differ from the options provided under S4.2 for trucks and multipurpose passenger vehicles with a GVWR of 10,000 pounds or less. You are also correct in reading S4.2.2 and S4.2.3 to mean "chassis-mount camper" when the term "vehicles carrying chassis-mount campers" is used. The petitions filed by RVI requesting amendments to Standards No. 208 and 210 are under active consideration and you should expect to receive an answer in the very near future. |
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.