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: nht71-2.5OpenDATE: 02/11/71 FROM: AUTHOR UNAVAILABLE; Roger H. Compton; NHTSA TO: Midway Products Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of January 27, 1971, to this Administration requesting an interpretation on Federal Motor Vehicle Safety Standard No. 108 as it applies to your motorcycle carriers. Your Model T-400-1 and T-400-2 carriers confom to the definition of "Trailer" as contained in the Federal Motor Vechile Safety Standards, and must, therefore, comply with the requirements of Standard No. 108 as applicable to trailers less than 80 inches in overall width. This Administration has no authority to provide exemption from these requirements. Your comments on the special design and functional features of your vehicles are of interest to us and will be considered in future rule making actions. In the meantime, of course, you have the right to petition for an amendment of the definition of a trailer or of Standard No. 108 it you feel these provisions impose requirements which are not reasonable, practicable, or appropriate for the types of vehicles you manufacture, pursuant to 49 CFR 533.31. |
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ID: nht71-5.62OpenDATE: 11/11/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Tire Review TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of August 10 and October 6, 1971, concerning the size requirements for retreaded tires as specified in Federal Motor Vehicle Safety Standard No. 117. Your letter of August 10 enclosed a draft article that you requested we examine. I have enclosed a copy of the Administration's action on the petitions for reconsideration that were received in response to the standard as published April 17, 1971 (36 F.S. 7315). This action amends the size requirements of 25.12 of the standard by allowing a minus 3 per cent deviation from the section width specified in Table 1 of Appendix A of Standard No. 109 in addition to the plus 10 per cent deviation previously allowed. With reference to your draft article, its discussion of the size requirements, apart from the changes made by the amendments, is accurate. The copies of Appendix A or Standard No. 109 that you were furnished on August 20 have been supplemented, and a copy of the additional material is also enclosed. WE ARE PLEASED TO BE OF ASSISTANCE. ENCLS. |
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ID: nht78-3.25OpenDATE: 10/02/78 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Thomas Built Buses, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your August 25, 1978, letter asking what the term "normal nighttime illumination" mean in Standard No. 217, Bus Window Retention and Release. The term "normal nighttime illumination" is found in paragraph S5.5.2 of the standard. This section requires that all interior exit instructions be legible when the only source of light is the normal nighttime illumination of the vehicle. The term, as used in this paragraph, means that exist instructions must be visible with the normal interior vehicle lighting that is in use when the bus is moving. Interior vehicle lighting may include, for example, reading lamps and overhead lights. SINCERELY, Thomas BUILT BUSES, INC. August 25, 1978 Office of the Chief Counsel U.S. Department of Transportation Attn: Roger Tilton Subject: MVSS 217, Section S5.5.2 - School Bus Dear Mr. Tilton: We are inquiring if a definition has been given to the phrase "Normal Nighttime Illumination". Our interpretation is that the interior lights in the vehicle constitude "Normal Nighttime Illumination". We are most interested in hearing from you in this matter. James Tydings, Specifications Engineer |
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ID: nht72-3.5OpenDATE: 06/08/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Labelmaster TITLE: FMVSS INTERPRETATION TEXT: In response to your letter of May 11, 1972, submitting sample labels for retreaded tires, the samples which you submit, with the appropriate information properly filled in or clearly indicated by an "X" or other mark, will meet the requirements of S6.2 and S6.3 of Standard No. 117. |
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ID: 1987yOpen Mr. Michael E. Kastner Dear Mr. Kastner: Thank you for your letter to Secretary Skinner concerning the National Highway Traffic Safety Administration's (NHTSA's) actions to extend certain Federal Motor Vehicle Safety Standards (FMVSS's) to light trucks and vans. The Secretary has asked me to reply. Your letter was especially concerned with NHTSA's November 1987 amendment to FMVSS 204, Steering Control Rearward Displacement, and our denial of NTEA's petition for reconsideration of that rule. I regret that I am unable to respond to your comments at this time. As you know, the Department and NTEA are presently involved in litigation concerning those actions. In view of the litigation, we feel it would be inappropriate to address your comments in this letter. We appreciate your interest in informing the Department of your views. I can assure you that Secretary Skinner is actively interested in each of the letters he receives regarding NHTSA's mission to improve motor vehicle safety. Let me assure you also that the potential impacts on small businesses is one of our concerns in each of our rulemaking actions. A copy of your letter, and this response, will be placed in NHTSA's docket section. Sincerely,
Jeffrey R. Miller Acting Administrator ref:204 d:8/22/89 |
1989 |
ID: nht72-1.20OpenDATE: 05/31/72 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Armstrong Rubber Company TITLE: FMVSS INTERPRETATION TEXT: We are in receipt of your response of October 7, 1971, to CIR 368.1.1, concerning Admiral Belted 78 tires that were branded on one side only. The Administration considers the act of branding on only one sidewall at a time when the standard required both sidewalls be labeled, to be inexcusable. If similar incidents of overlooking requirements come to our attention we will pursue civil penalties. However, based on the information before us we are closing our files in this case with regard to both civil penalties and defect notification. The Administration reserves the right to reopen this file in the event that further violations of this nature come to its attention. |
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ID: eggiman.ztvOpenMr. J. Michael Eggiman Dear Mr. Eggiman: On January 13, 2003, you wrote us a letter, the purpose of which was "to introduce to you people of the Counsel, a new concept in which the flashing of all brake lights, including the CHMSLs, in the event of a vehicles engine stalling." Thank you for the introduction. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, requires stop lamps to be steady burning in use, and, for this reason, your invention could not be used. All vehicles today are equipped with a hazard warning lamp system which the operator can use to flash the vehicles turn signal lamps if the vehicle stalls. Sincerely, Jacqueline Glassman ref:108 |
1970 |
ID: nht75-1.27OpenDATE: 09/29/75 FROM: ANDREW G. DETRICH FOR ROBERT L. CARTER -- NHTSA TO: Brainerd & Bridges TITLE: FMVSS INTERPRETATION TEXT: This is in response to the May 26, 1975, petition of your client, Kugelfischer Georg Schaefer & Co., for an amendment of the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses. The National Highway Traffic Safety Administration has granted the petitions of General Motors Corporation and Ford Motor Company to delete the banding requirement. A proceeding respecting the issuance of a notice of proposed rulemaking has been commenced. Because the amendment requested by your client is inconsistent with the deletion of the banding requirement, in the strict sense, that petition is hereby denied. You may find, however, that the change now being developed in our rulemaking proceedings will be satisfactory to your client. |
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ID: nht75-3.13OpenDATE: 06/25/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Emmons Brothers TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of May 1, 1975, concerning Federal Motor Vehicle Safety Standard No. 302, Flammability, and in amplification of your telephone conversation with Mr. Schwartz of my office. As Mr. Schwartz advised you, Standard No. 302 applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. Thus, the standard would apply to mattresses used in trucks. Further, it has been proposed to extend Standard No. 302 to campers and trailers other than those sold exclusively for the transportation of cargo (copy enclosed). Consequently, as you requested, I have enclosed a copy of Motor Vehicle Safety Standard No. 302, a recent amendment to that standard, and a proposed amendment which may also be of interest to you. |
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ID: nht76-3.12OpenDATE: 08/20/76 FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA TO: Attwood Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of June 23, 1976, in which you ask whether Standard No. 302, Flammability of Interior Materials, applies to portable toilets. Standard 302 applies to the motor vehicles listed in Section S3, including the equipment installed in them at the time of sale. Section S4 lists those parts of a motor vehicle that must comply with burn resistance requirements, and a portable toilet is not included. Therefore, it is not subject to the standard. I have enclosed a copy of the standard for your information. SINCERELY, June 23, 1976 Federal Highway and Transportation Safety Administration NHTSA DEAR SIR: I am trying to find the Federal Motor Vehicle Standard No. 302 which covers portable toilets. Please send me any information you have on this. Thank you. SINCERELY, ATTWOOD CORPORATION Don Dekker |
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.