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 |
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ID: nht94-3.38OpenTYPE: INTERPRETATION-NHTSA DATE: June 15, 1994 FROM: Reidar Brekke -- Market Analyst, Norwegian Trade Council TO: Chief Council, NHTSA TITLE: Legal Interpretation on "Belly Safe" a safety device used by pregnant women ATTACHMT: Attached to letter dated 7-14-94 from John Womack to Reidar Brekke (A42; STD 208) TEXT: The Norwegian Trade Council- New York (NTC-NY) is currently representing the Norwegian companies, HTS and Loyd's Industri, in their effort to introduce Belly Safe to the US market. Belly Safe is a safety device made to protect the "unborn life". Belly Safe forces the car lap belt under the bulge of the stomach, and ensures that in the event of an emergency stop or a collision, that the "damaging" pressure will be concentrated on t he hip bone and not on the stomach where the fetus is situated. We were recommended by Mr. Dan Orden, Chief of Import Division, Office of Vehicle Compliance, to contact you for a legal interpretation of this safety device. He felt that this was important even though there are no applicable standard for this type of products in the US. As you will se from the information enclosed, the product has been tested and approved in both Sweden and in Germany. The product is made of Polyester and Acetal (see Constructional data form). The product is currently sold in several European countries and in Australia. Belly Safe is patented in Europe and in the US. We hope this information will be sufficient for you to give Belly Safe an legal interpretation. 4 Pleas contact us if you have any questions or if you need more information. Enclosed: German approval of Belly Safe under ECE R 16 rules and regulations Constructional data form from TUV Rheinland e.V. Preliminary translation of instructions Test results from the Swedish National Testing Institute Advertisement with references |
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ID: nht73-1.35OpenDATE: 12/19/73 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Toyo Kogyo U.S.A. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of December 6 to Mr. Lewis Owen of this Office concerning the use of a special parking lamp bulb in one of your tail lamp assemblies. The location of the subject bulb in the lamp assembly, regardless of whether the switch is removed to make it inoperative, is permitted, providing that the other required lamps function as specified in Federal Motor Vehicle Safety Standard No. 108. Sincerely, TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE December 6, 1973 Lewis Owen -- National Highway Traffic Safety Administration, U. S. Department of Transportation Dear Mr. Owen: This is in confirmation to our discussion on Nov. 27, 1973. On one of our models, we are now considering to utilize the parts for, between U. S. A. and Japan. In these rear combination lamps, there are No. 12 lamp, which is called with parking lamp which is different from FMVSS 108. Please find the attached sheet. The parking lamp is required in Japanese regulation, but not required in U. S. A. We are now thinking it will become irregular if it works. So we want to remove the switch from this lamp and it cannot work. But, for the U. S. A., we want the bulb to remain ( 3.4 W ) and end of coupler and cord. We must emphasize that there are no influences to another mechanism, ( Stop, tail, & backup lamp ). On the lamp housing, we want to put the caution. This parking lamp is only for Japan namely, "Japan 12 V, 3.4 W". We believe there is no mistake in user. Warmest regards, Gorou Utsunomiya -- Branch Manager, Detroit Branch cc; Dr. Sakashita, Mr. Niguma Enclosurer |
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ID: 86-1.1OpenTYPE: INTERPRETATION-NHTSA DATE: 01/01/86 EST FROM: MICHAEL M. FINKELSTEIN -- ASSOCIATE ADMINISTRATOR FOR RESEARCH AND DEVELOPMENT NHTSA TO: CHARLES SCHAMBLIN TITLE: NONE TEXT: Dear Mr. Schamblin: Your letter to Elizabeth Hanford Dale. Secretary of Transportation, was forwarded to me for response. Thank you for sending the sample of the Flag-It Fluorescent Safety Signaling Device and the information that it is being manufactured in the United States. We share your concern with the problem of school bus safety and appreciate your efforts to develop a device to reduce the problem. However, as I am sure you can understand, government agencies cannot endorse commercial products. Thank you, again, for your interest in improving highway safety. Sincerely, |
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ID: nht78-3.43OpenDATE: 06/21/78 FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA TO: Mellon Bank TITLE: FMVSR INTERPRETATION TEXT: This is in response to your recent telephone conversation with Kathy DeMeter of my staff concerning the retention of odometer disclosure statements. The question you raised was in what order the statements should be retained. The two methods you proposed using were alphabetically by the name of the individual or organization to which you transferred to the vehicle. 49 CFR requires each dealer or distributor of a motor vehicle to retain the statements "in an order that is appropriate to his business requirements and that permits systematic retrieval." Either method you propose would probably permit systematic retrieval and you may therefore select the method which best suits your business requirements. |
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ID: 77-5.9OpenTYPE: INTERPRETATION-NHTSA DATE: 12/21/77 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Office of Standards Enforcement TITLE: FMVSS INTERPRETATION TEXT: I have received your November 8, 1977, memorandum questioning the applicability of the performance requirements in Section S5.4 of Standard No. 217 to knock-out rear windows. You suggest that these requirements may apply only to push-out windows, not knock-out windows. It is our interpretation that the requirements of the standard apply to both push-out and knock-out windows. We realize that this may create some difficulty for purposes of conducting compliance testing since knock-out windows must be reinstalled in order to conduct subsequent tests upon them. Nonetheless, the window should be required to comply with the standard. |
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ID: nht72-4.43OpenDATE: 03/30/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Oshkosh Truck Corporation TITLE: FMVSR INTERPRETATION TEXT: In your letter of March 13 you ask for an interpretation of certification requirements applicable to remanufactured vehicles. The National Traffic and Motor Vehicle Safety Act of 1966 and 49 CFR Part 567 require only that certification of vehicle conformity be providal prior to the first purchase for purposes other than resale. On the basis of the work that you described as your "remanufacturing", specifically hat the vehicle retains its "original frame, cab, body, axles, and transmission", we concur in your interpretation that vehicles of this nature are not new vehicles requiring certification of conformity with the Federal motor vehicle safety standards. |
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ID: nht73-4.7OpenDATE: 04/11/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: American Retreaders' Association, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 20, 1973, in which you ask whether, if a retreaded tire cannot meet the dimensional requirements for its original casing size, it can be considered as and labeled with a smaller size, if it meets the dimensional requirements for the smaller size. S5.1.4 of Standard No. 117 prohibits a retread tire from having a size designation, maximum load rating, or maximum inflation pressure greater than that originally specified on the casing. It does not prohibit a retreaded tire from having a smaller size than its casing, as long as the retreaded tire meets all the requirements for its labeled size designation. |
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ID: nht90-4.66OpenTYPE: Interpretation-NHTSA DATE: November 28, 1990 FROM: William A. Batten -- Eaton Corp., Truck Components Operations- North America TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: Re FMVSS 124 Accelerator Control Systems ATTACHMT: Attached to letter dated 3-4-91 from Paul Jackson Rice to William A. Batten (A37; VSA 108(b)(1); VSA 108 (a)(2)(A); Std. 124) TEXT: The purpose of this letter is to obtain an interpretation from your office relative to FMVSS No. 124. The question is: What is the applicable mileage requirement or time domain that a Class 8 Truck (over 10,000 pounds GVWR) must comply with FMVSS No. 124? I would like to thank you in advance for your consideration in this manner. |
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ID: nht74-3.3OpenDATE: 03/26/74 FROM: LAWRENCE R. SCHNEIDER -- NHTSA CHIEF COUNSEL TO: BRIAN GILL -- AMERICAN HONDA MOTOR COMPANY, INC. COPYEE: SCHWARTZ TITLE: N40-30 [FWS] TEXT: Dear Mr. Gill: This is in response to your letter of February 22, 1974, requesting an official interpretation concerning the proposed amendment to Standard 108 (Docket No. 69-19, Notice 3). You wish to know whether a steady burning lamp which is combined with a turn signal lamp shall be deactivated when the turn signal is flashing as part of the hazard warning system. It is our view that a steady burning lamp must always be deactivated when the turn signal lamp is flashing, whether in the turning phase or the hazard warning phase. Sincerely, |
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ID: nht73-1.3OpenDATE: 04/05/73 FROM: R. B. Dyson; NHTSA TO: Holiday Rambler Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 20, 1973, to this agency asking about the applicability of paragraph S4.1.2 of Federal Motor Vehicle Safety Standard No. 104 to vehicles other than passenger cars. Your understanding is correct that the standard establishes wiped area requirements only for passenger car windshields. The NHTSA is engaged in research with the intent of establishing as all-weather visibility standard, combining Standards No. 103 and 104, that would among other things extend the windshield wiped area requirements to vehicles other than passenger cars. However, it is not possible to say when we will issue a rulemaking proposal on this subject. |
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.