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: 0722Open Herr Tilman Spingler Dear Herr Spingler: We have received your FAX of February 15, 1995, asking whether a proposed design "for a lens-reflector-joint can be considered as conforming to the appropriate definition in FMVSS 108." The agency does not advise manufacturers whether particular designs are regarded as "conforming." That determination is to be made by the manufacturer in certifying that its product conforms to all applicable Federal Motor Vehicle Safety Standards. However, we can provide you with an interpretive guideline. Section S4 defines a "replaceable bulb headlamp" as a headlamp "comprising a bonded lens reflector assembly and one or two replaceable light sources." The intent of the definition was that the lens and reflector assembly be an indivisible unit upon manufacture of the headlamp. This means that, if a lens is broken, the entire lens reflector assembly must be replaced. If your design is such that the lens cannot be removed from the reflector assembly for replacement, it would appear to meet the definition in S4. As you are well aware, NHTSA granted your company's petition for rulemaking, and, in November 1994, proposed an amendment of the definition of "replaceable bulb headlamp" that would allow a replaceable lens if the headlamp incorporates a vehicle headlamp aiming device conforming to S7.8.5.2. Comments were due on this proposal February 21, 1995. In due course, after review of the comments, NHTSA will decide whether it will pursue further rulemaking or terminate the rulemaking action. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:3/8/95
|
1995 |
ID: 11392Open Terence J. Kann, P.A. Dear Mr. Kann: This responds to your letter of November 14, 1995, to Ricardo Martinez, M.D. Administrator of the National Highway Traffic Safety Administration. You have asked whether "pole trailers such as those used in the logging industry, [are] required to have retro- reflective sheeting, reflex reflectors, or a combination?" If not, you asked whether NHTSA issued "any explanation for failing to extend the requirements to pole trailers." As you noted, Section S3(a) of Motor Vehicle Safety Standard No. 108 applies to "trailers (except pole trailers) . . . ." This means that pole trailers, as defined in 49 CFR 571.3(b) are exempted from all the requirements of Standard No. 108 including those of Section S5.7 which specifies conspicuity requirements for "each trailer of 80 or more inches overall width and with a GVWR over 10,000 pounds". Pole trailers have always been excluded from Standard No. 108 (see 23 CFR 255.51, Motor Vehicle Safety Standard No. 108, Section S2, effective January 1, 1968). Thus, the agency never proposed in the first instance that conspicuity requirements apply to pole trailers, and there was no discussion of pole trailers in the preambles to the proposal and final rule. Apparently, pole trailers were defined and excluded on the basis of comments to Standard No. 108 as originally proposed late in 1966 that a standardized lighting scheme might be impracticable for this category of vehicle. If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely,
Samuel J. Dubbin Chief Counsel ref:108 d:12/22/95 |
1995 |
ID: nht90-2.85OpenTYPE: INTERPRETATION-NHTSA DATE: 06/14/90 FROM: PAUL JACKSON RICE -- NHTSA CHIEF COUNSEL TO: JOSEPH R. WHEELER TITLE: NONE ATTACHMT: LETTER DATED 06/08/90 FROM JOSEPH R. WHEELER TO KEN WEINSTEIN -- NHTSA TEXT: This is in response to your letter to Kenneth Weinstein of my staff requesting information about actions by the Secretary of Transportation pursuant to Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR @ 571.208). More spe cifically, you noted that S4.1.4.1 of Standard No. 208 states that, "Except as provided in S4.1.5 [and another section not relevant to your inquiry], each passenger car manufactured on or after September 1, 1989 shall comply with the [automatic restraint requirements]." S4.1.5 of Standard No. 208 provides that: "If the Secretary of Transportation determines, by not later than April 1, 1989, that state mandatory safety belt usage laws have been enacted that meet the criteria specified in S4.1.5.2 and tha t are applicable to not less than two-thirds of the total population . . ., [the automatic restraint requirements will not go into effect]." You asked whether the Secretary ever made a determination under S4.1.5 regarding State safety belt use laws. The answer is no. Under S4.1.5, the Secretary was not required to make any determination about any State safety belt laws. In fact, the Secretary never did so. Because no determination was made under S4.1.5, the automatic restraint requirements are now in effect for all passenger cars. This letter expresses no opinion about the implications under Tennessee law of the absence of a determination by the Secretary of Transportation regarding any State's safety belt law.
|
|
ID: nht93-3.32OpenDATE: May 4, 1993 FROM: St. F. Steiner -- Consultant, AET Network TO: John Womack -- Chief Council, U.S. Department of Transportation, NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-17-93 from John Womack (Signature by Stephen P. Wood) to St. F. Steiner (A41; Part 591) TEXT: As an environmentally, concerned company, our goal is to become proactive before the new California 2010 Emissions State Law is to be effective and the President of the United States signs the new Environmental Protection Laws. We think it's time to aggressively contribute in the development of human responsibility and thus, build up an agreeable base for our children and future. Because of this, our company is into environmental protection by way of contributing toward the reduction of gasoline pollution attributed to the transportation industry. In our efforts, our goal is to import electric automobiles from Europe for research and exploration. In order to do this, we need your assistance on the following U.S. laws and D.O.T. requirements for 3 and 4 wheelers with 1 to 5 passengers. o Are there any safety standards and regulations for the above mentioned automobiles? o Is there a minimum speed standard regulation for the above mentioned automobiles? o Are there weight limitations for the above mentioned automobiles? o What conversions would be required in order to meet U.S. specifications and standards? o Could these automobiles be permitted on highways? Thank you for taking the time to review our needs. Your immediate response and assistance would be greatly appreciated in supporting our effort towards improving our environment. If you should inquire additional information about our electric automobiles please feel free to contact us. |
|
ID: 2498yOpen Joseph R. Wheeler, Esq. Dear Mr. Wheeler: This is in response to your letter to Kenneth Weinstein of my staff requesting information about actions by the Secretary of Transportation pursuant to Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208). More specifically, you noted that S4.1.4.1 of Standard No. 208 states that, "Except as provided in S4.1.5 [and another section not relevant to your inquiry], each passenger car manufactured on or after September 1, 1989 shall comply with the [automatic restraint requirements]." S4.1.5 of Standard No. 208 provides that: "If the Secretary of Transportation determines, by not later than April 1, 1989, that state mandatory safety belt usage laws have been enacted that meet the criteria specified in S4.1.5.2 and that are applicable to not less than two-thirds of the total population . . ., [the automatic restraint requirements will not go into effect]." You asked whether the Secretary ever made a determination under S4.1.5 regarding State safety belt use laws. The answer is no. Under S4.1.5, the Secretary was not required to make any determination about any State safety belt laws. In fact, the Secretary never did so. Because no determination was made under S4.1.5, the automatic restraint requirements are now in effect for all passenger cars. This letter expresses no opinion about the implications under Tennessee law of the absence of a determination by the Secretary of Transportation regarding any State's safety belt law. Sincerely,
Paul Jackson Rice Chief Counsel /ref:208 d:6/l4/90 |
1970 |
ID: nht95-2.12OpenTYPE: INTERPRETATION-NHTSA DATE: March 27, 1995 FROM: Yvonne Roppel -- Liaison Officer, Title and Registration Services, State of Washington, Department of Licensing TO: Phillip Reckt -- Chief Council, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM JOHN WOMACK TO YVONNE ROPPEL (A43; REDBOOK 2; Part 580) TEXT: Dear Mr. Reckt: I recently conferred with Dick Morse of NHTSA who asked me to request of you a written reply to my question. I had asked Mr. Morse as to who should sign an original title application for a leased vehicle, the lessee or the lessor. As background, I advised Mr. Morse that in Washington State the lessee is shown on the title as a registered owner and is required to sign the original application at the dealership. (This is only concerning a vehicle still under the Manufacturer's Cert ificate of Origin.) Normally the lessee is choosing the vehicle from the dealer inventory. The yearly license renewal notice is mailed to the lessee in most cases. The registered owner or lessee is liable if any legal action is filed against the vehicl e. Mr. Morse has indicated that when the lessee is shown on the title, they would be considered a registered owner and would therefore acknowledge the odometer disclosure made bythe selling dealer. I asked if he would put this in writing at which time he i ndicated that I would have to write to your office. Therefore, I am asking if I could have a letter sent to me verifying in writing his reply. Thank you for your assistance in this matter. |
|
ID: nht95-4.82OpenTYPE: INTERPRETATION-NHTSA DATE: November 21, 1995 FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA TO: A.D. Fisher TITLE: NONE ATTACHMT: ATTACHED TO 10/11/95 LETTER FROM A.D. Fisher to John Womack TEXT: Dear Mr. Fisher: This is in reply to your letter of October 11, 1995, asking for our comments on the relationship of your lighting invention, "The Enlightener," to Federal Motor Vehicle Safety Standard (FMVSS) No. 108. The Enlightener is intended to replace the center highmounted stop lamp. The lens has two colors, divided between amber at the top and red at the bottom. The amber portion is lit in a steady burning mode when both the accelerator and brake are not depre ssed, and in a flashing mode when the transmission lever is in Referse. The red portion is lit when the brake pedal is depressed and amber is extinguished. This devise would not be permissible under FMVSS No. 108. The center highmounted stop lamp must stand alone; the lamp cannot serve another function, and paragraph S5.4(a) prohibits combining it with any other lamp. In addition, the backup function on motor vehicles is furnished by a steady burning white lamp, required by FMVSS No. 108. The presence of a flashing amber lamp operating simultaneously would impair the effectiveness of the backup lamp by sending a conf licting signal. I am sorry that we cannot provide you a more positive response. If you have any questions, you may refer them to Taylor Vinson of this office by calling (202) 366- 5263. Sincerely, |
|
ID: nht72-4.46OpenDATE: 05/25/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: National Association of School Bus Contract Operators TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of April 21, 1972, concerning problems some school bus manufacturers are having completing school buses manufactured with chassis ordered before January 1, 1972. You request our opinion as to whether these buses can be delivered even though they exceed by 350 pounds the GAWR specified for the rear axle of the chassis. One purpose of the Certification requirements and the requirements regarding "Vehicles Manufactured in Two or More Stages," which went into effect January 1, 1972, and which require manufactures to specify GAWR and GVWR, was to prevent the construction of motor vehicles of insufficient capability to carry anticipated loads. In our view, a manufacturer who completes a vehicle whose loaded weight or axle loads are in excess of its weight ratings is manufacturing a potentially unsafe vehicle which could be subject to the defect notification provisions of the National Traffic and Motor Vehicle Safety Act. The regulations apply to motor vehicles completed after January 1, 1972, and will apply to the school buses in question. We do not consider the notice of December 28, 1971, to allow these manufacturers to omit GAWR and GVWR from their certification labels. That notice allows this to be done only when a final-stage manufacturer, using a chassis manufactured before January 1, 1972, does not have and cannot obtain the gross axle and vehicle weight ratings for particular vehicles. These ratings have evidently been furnished to the school bus manufacturers who are the subject of your letter, and as a consequence they are responsible for placing these values on the labels of the completed vehicles. |
|
ID: nht95-7.42OpenTYPE: INTERPRETATION-NHTSA DATE: November 21, 1995 FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA TO: A.D. Fisher TITLE: NONE ATTACHMT: ATTACHED TO 10/11/95 LETTER FROM A.D. Fisher to John Womack TEXT: Dear Mr. Fisher: This is in reply to your letter of October 11, 1995, asking for our comments on the relationship of your lighting invention, "The Enlightener," to Federal Motor Vehicle Safety Standard (FMVSS) No. 108. The Enlightener is intended to replace the center highmounted stop lamp. The lens has two colors, divided between amber at the top and red at the bottom. The amber portion is lit in a steady burning mode when both the accelerator and brake are not depressed, and in a flashing mode when the transmission lever is in Referse. The red portion is lit when the brake pedal is depressed and amber is extinguished. This devise would not be permissible under FMVSS No. 108. The center highmounted stop lamp must stand alone; the lamp cannot serve another function, and paragraph S5.4(a) prohibits combining it with any other lamp. In addition, the backup function on motor vehicles is furnished by a steady burning white lamp, required by FMVSS No. 108. The presence of a flashing amber lamp operating simultaneously would impair the effectiveness of the backup lamp by sending a conflicting signal. I am sorry that we cannot provide you a more positive response. If you have any questions, you may refer them to Taylor Vinson of this office by calling (202) 366- 5263. Sincerely, |
|
ID: nht95-4.70OpenTYPE: INTERPRETATION-NHTSA DATE: November 8, 1995 FROM: Jane Thornton Mastrucci -- Thornton, Mastrucci and Sinclair TO: John Womack -- Chief Counsel, NHTSA TITLE: NONE ATTACHMT: 12/26/95 letter from Samuel J. Dubbin (signed by John Womack) to Jane Thornton Mastrucci (A43; Part 571.3; VSA 102) TEXT: We represent the Dade County School Board with respect to its vehicular litigation. The Florida Legislature has just passed a new law, F.S. 234.02 (1)(a) which allows a School Board to use, in addition to passenger cars not exceeding eight students, any other motor vehicle designed to transport ten on fewer persons which meets all fe deral motor vehicle safety standards for passenger cars. Similarly, the Department of Education Rule 6A-3.017 (10)(c) allows the transportation of students, when necessary or practical, in multipurpose vehicles, providing the MPV meets all of the applica ble passenger car federal motor vehicle safety standards, except the standard pertaining to window tinting. Copies of both of these statutes are attached. Would you please advise which passenger vehicles which multipurpose vehicles meet all federal motor safety standards. Thanking you for your courtesy and cooperation in advance, I remain, Florida statutes are omitted. |
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.