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: nht92-1.7OpenDATE: December 29, 1992 FROM: David H.B. Lee -- President, Lee Family, Inc. TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 1/26/93 from John Womack to David H.B. Lee (A40; Std. 108) TEXT: I currently have in my possession a U.S. patent on a device created in Taiwan. I have included copies of the documents and have enclosed two samples of the Third Brake Light Conditions Sensor along with a demonstration videotape. At the present time, Japan's Department of Vehicles is considering an alteration of their laws to include a requirement of blinking third brake lights. What we hope to accomplish in the near future is to reduce the rate of collisions by grasping the United States' attention that the Third Brake Light Conditions Sensor is helpful as a safety device in vehicles. However, in order for our business to succeed, we need your assistance. What we are requesting of you is a thorough review and testing of our device by your highly trained technicians. Also a series of tests, we would greatly appreciate any comments and advice on the sale and promotion of our product. Please contact me about the results as soon as possible. Your time and cooperation is greatly desired and appreciated. Thank you very much. |
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ID: nht71-3.11OpenDATE: 06/01/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: The General Tire & Rubber Company TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of May 17, 1971, concerning the applicability of the Tire Identification and Record keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill. As you mentional in your letter, under the regulation, a vehicle dealer has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer. The Tire Identification and Record Keeping Regulation and the Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations. |
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ID: nht93-9.6OpenDATE: December 8, 1993 FROM: Michael J. Siris -- Attorney at Law TO: Mary Versailles -- NHTSA COPYEE: Roger Harvey TITLE: Standard 114 ATTACHMT: Attached to letter dated 3/10/94 from John Womack to Michael J. Siris (A42; Std. 114; VSA S108(k)) TEXT: Although you were nice enough to answer my questions regarding standard no. 114, I still would like to have some confirmation that a manufacture's compliance with a given NHTSA standard does not necessarily exonerate the manufacture. Is that proposition published in the CFR. Also, given the scenario we discussed, i.e., the 1987 Ford which allowed the automatic transmission to be shifted while the key was not in the steering column, do you have any other suggestions besides no. 114? In other words, is there some other source of standards that might be more stringent than NHTSA's standards? Thank you for your anticipated attention to this matter. |
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ID: nht72-2.15OpenDATE: 07/11/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Barry Kulik TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of May 14, 1972, to Mr. Armstrong asking whether combination turn signal and hazard warning signal flashers conforming to Federal requirements effective January 1, 1973, may be installed in vehicles manufactured before that date. The answer is yes. Motor Vehicle Safety Standard No. 108 was amended on December 28, 1971 to allow use of flashers manufactured to conform with Standard No. 108a. I enclose a copy of the amendment for your information. |
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ID: 1982-1.15OpenTYPE: Interpretation-NHTSA DATE: February 16, 1982 FROM: Frank Berndt -- Chief Counsel, NHTSA TO: Brian Gill -- Manager, Certification Department, American Honda Motor Company TITLE: None ATTACHMT: Attached to letter dated 12-24-90 to Stanley S. Zinner from Paul Jackson Rice (A37; Std. 123); Also attached to letter dated 12-4-90 to Paul Jackson Rice from Stanley S. Zinner (OCC 5479); Also attached to letter dated 10-26-73 to Brian Gill from Richard B. Dyson TEXT: This is in reply to your letter of December 11, 1981, asking for confirmation of your interpretation of paragraph S5.2.5 of Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays. Paragraph S5.2.5 requires that "Each footrest for a passenger other than an operator shall fold rearward and upward when not in use." Honda would like to use a "footboard" instead of a "footrest". In folding, the footboard folds upward in a clockwise manner and rearward and Honda believes that this meets Standard No. 123. We consider that the purpose of S5.2.5 is to prevent accidents caused by rigid footrests contacting the ground in a banking turn. The outer edge of the footboard in plan view lies inboard of wider parts of the vehicle such as the engine guard pipe and side bumper. This means that these portions of the motorcycle would contact the ground in an extreme banking turn before the proposed footboard. The standard specifies no direction of upward motion of the footrest. We believe your design complies with the intent of Standard No. 123. |
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ID: nht76-1.12OpenDATE: 01/06/76 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Nissan Motor Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This responds to Nissan's December 12, 1975, question whether a manufacturer may comply with the requirement of Standard No. 105-75, Hydraulic Brake Systems, for "a lens labeled in letters" (S5.3.5) by means of painting or otherwise printing the required label directly onto the lens. The answer to your question is yes. Section S5.3.5's requirement for "a lens labeled in letters" permits labeling by means of printing directly on the lens itself. |
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ID: nht71-2.42OpenDATE: 05/05/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Michelin Tire Corporation TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your phone call to David Schmeltzer of this office on April 27, 1971 and to confirm that the Tire Identification and Record Keeping regulation, Part 574, as published in the Federal Register January 26, 1971 (36 F.R. 1196) applies only to tires manufactured on or after May 22, 1971. Therefore, vehicles manufactured after that date are only required to have tires with identification numbers if the tires were manufactured after May 22. |
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ID: nht74-3.38OpenDATE: 05/09/74 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Alfa Romeo, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 5, 1974 to Mr. Schneider. You state that you are unable to obtain the ASTM E-249 test tire (4 ply rayon) referenced in the ASTM Method used to determine skid numbers, and you ask whether you may use the ASTM E-501 test tire (belted bias). Your obligation as a manufacturer is to insure that your certification of compliance is not false and misleading in a material respect, and that you exercise due care in manufacturing to conform to the federal motor vehicle safety standards. A manufacturer is not required to follow specifically the test procedures of the standards, but to ascertain that his product will conform to the standard's requirements when it is tested by these procedures. In determining (Illegible Word) number, therefore, you are not required as a matter of (Illegible Word) to use the ASTM E-249 tire if you can reach the required result with equivalent procedures. We understand that the original E-501 tire provided a slightly higher reading on dry pavement than the E-249 tire and that it is being redesigned so that the two tires give equivalent readings. We anticipate that, when the tire has been approved by ASTM for use in determining and number pursuant to ASTM Method E-274, we will propose a corresponding amendment to our definition of skid number, presently used in 49 CFR @@ 571.105-75, 571.121, 571.122, and 575.2. |
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ID: nht73-6.24OpenDATE: November 26, 1973 FROM: Robert R. Aronson -- President, Electric Fuel Propulsion Corp. TO: Lawrence Schneider -- Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 12/10/73 from Richard B. Dyson to Robert R. Aronson TEXT: In reference to FMVSS 301, our electric cars are equipped with a 2-quart gasoline tank which powers a Stewart Warner Water Heater for heating and defrosting cars. The location of the gas tank and heater is in the rear of the car. Please let us know if Standard 301 applies to this gas tank. |
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ID: 86-2.21OpenTYPE: INTERPRETATION-NHTSA DATE: 04/15/86 FROM: FRANCISCO DEETAN -- FRG INDUSTRIAL CORPORATION TO: NHTSA TITLE: HS 7 FORM APPLICATION APPROVAL FOR REAR WINDOW 3RD STOP LIGHT ATTACHMT: ATTACHED TO LETTER DATED 07/23/86 EST, TO FRANCISCO DEETAN FROM ERIKA Z. JONES, REDBOOK A29(3); STANDARD 108 TEXT: Dear Sirs, Concerning our importation of rear window 3rd stop light which meets requirement for a high mounted brake light: Our company have prepared a trial order for more or less Three Thousand Dollars worth of rear window 3rd stop light importation, but before the letter of credit is opened we would like to get your approval for the products we will import, So, please inform and assist us in getting your HS-7 permit in compliance with FMVSS 108 requirement; Enclosed is our brochure and proform invoice copy from our supplier aboard, in case your good office need the sample test of the rear window 3rd stop light which we wish to import, please urgent inform us and indicate whom we should send it to, we will send you a sample immediately upon we receive you advise. Thank you in advance for you kind co-operation, we remain, Very Truly Yours, |
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.