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: 18267.drnOpenMr. Jeff Hibbs, Fleet Coordinator Dear Mr. Hibbs: This responds to your letter regarding the use of 15-passenger vans by a child care facility to drop off and pick up school children from schools. You ask whether the vans are "school buses" under Federal law. In a telephone conversation with Dorothy Nakama of my staff, you explained that you believe that the children will be transported "to and from school" on a regular basis, perhaps as often as five days a week. I am enclosing a copy of our July 23, 1998, letter to Mr. Don Cote of Northside Ford in San Antonio, who asked us the same question about vans regularly used by a child care facility for school transportation. In that letter, we explain that such a van is a "school bus" under our regulations. Thus, when a dealer sells or leases a new van for such use, the dealer must sell or lease only buses that meet Federal motor vehicle safety standards for school buses, even when the purchaser is a child care facility. The National Highway Traffic Safety Administration (NHTSA) believes that school buses are one of the safest forms of transportation in this country, and therefore strongly recommends that all buses that are used to transport school children be certified as meeting NHTSA's school bus safety standards. In addition, use of 15-passenger vans that do not meet the school bus standards to transport students could result in increased liability to the school bus operator or seller in the event of a crash. Since such liability would be determined by State law, you should consult your attorney and insurance carrier for advice on this issue. I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama at this address or by telephone at (202) 366-2992. Sincerely, |
1998 |
ID: nht94-2.67OpenTYPE: Interpretation-NHTSA DATE: May 5, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Tilman Spingler -- Robert Bosch GmbH TITLE: None ATTACHMT: Attached to letter dated 3/25/94 from Tilman Spingler to John Womack (OCC-9889) TEXT: This responds to your letter of March 25, 1994, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems. You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are "requirements for this cable concerni ng indivisibility and integration...." There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design. |
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ID: nht75-1.6OpenDATE: 02/11/75 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Insurance Institute for Highway Safety TITLE: FMVSS INTERPRETATION TEXT: Feb. 11, 1975 N40-30 Mr. A. B. Kelley Senior Vice President Insurance Institute for Highway Safety Suite 300 600 New Hampshire Avenue, N.W. Washington, D. C. 20037 Dear Ben: This is to confirm our understanding with respect to public meetings to be held on the subject of the Hydraulic Brake Standard, No. 105-75. If any significant changes are to be made in the standard, a notice of proposed rulemaking will be issued. Toward the end of the comment period on that NPRM, the agency will hold a public hearing concerning the contents of the proposal. At that time you will have the opportunity to present your views in full. Sincerely, Richard B. Dyson Assistant Chief Counsel |
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ID: nht74-3.21OpenDATE: 10/10/74 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Joseph Lucas North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your letter of September 30, 1974, enclosing sample brake hose assemblies and requesting approval of Girling's labeling and banding techniques to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, for labeling brake hoses and brake hose assemblies. The NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design. |
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ID: nht94-5.50OpenDATE: May 5, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Tilman Spingler -- Robert Bosch GmbH TITLE: None ATTACHMT: Attached to letter dated 3/25/94 from Tilman Spingler to John Womack (OCC-9889) TEXT: This responds to your letter of March 25, 1994, asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems. You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are "requirements for this cable concerning indivisibility and integration...." There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design. |
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ID: nht73-4.33OpenDATE: 07/17/73 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Volvo of America Corporation TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of July 11, 1973, asking for a waiver of 49 CFR @ 575.6(c) with respect to consumer information that Volvo of America would like to supply to prospective purchasers of 500 passenger cars beginning July 30, 1973. There is no provision in the Consumer Information Regulations empowering the Administrator to waive the 30 day requirement and therefore we are unable to grant this request. We do not view the lack of this authority as unjust, given the purpose of the requirement "so that there may be an evaluation and dissemination to the public of this information if deemed appropriate" (34F.R.11501). We received your material on July 12, and the 30 day period will expire on August 11. |
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ID: nht90-2.46OpenTYPE: Interpretation-NHTSA DATE: May 17, 1990 FROM: Ron Boucher -- Energy Savings System TO: Miss Carnes -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 7-27-90 to R. Boucher from P. J. Rice; (A35; VSA 102(4)); also attached to letter dated 5-29-90 to NHTSA Office of Chief Counsel from R. Boucher; (OCC 4837) TEXT: Regarding our conversation this morning, you requested me to fax you this information about the item that I'm wanting to know and be sure that the product is OK to use for vehicle breakdowns and also for bicycling identification. If you need more information, please call me. Just want to be certain that I am in compliance with the laws of the land. Miss Carnes, thanks again for your help in this matter. |
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ID: nht88-4.8OpenTYPE: INTERPRETATION-NHTSA DATE: NOVEMBER 11, 1988 FROM: C. I. NIELSEN III -- VICE PRESIDENT, WESBAR TO: ERIKA Z. JONES -- CHIEF COUNSEL, D.O.T., NHTSA TITLE: NONE ATTACHMT: ATTACHED TO MEMO DATED 12-30-88, TO C.I. NIELSEN, FROM ERIKA 2. JONES -- NHTSA, STD 108, REDBOOK A33 TEXT: Thank you for your November 3 letter to our A1 Cunningham clarifying the definition of single compartment and multiple compartment lamps. It is most helpful to understand these terms to assure we comply with applicable D.O.T. requirements. We now write you to please clarify for us the minimum square inches required of a turn signal lens for a trailer/vehicle, 80" or more in overall width, using a single compartment lamp assembly. We believe the answer should lie in J588e, but we find the text not only unclear, but confusing. Your response on this clarification will be most appreciated. |
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ID: 1985-04.51Open TYPE: INTERPRETATION-NHTSA DATE: 12/31/85 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Mr. Warren H. Cox TITLE: FMVSS INTERPRETATION TEXT:
December 31, 1985 Mr. Warren H. Cox Haynesville Correction Unit #17 Haynesville, VA 22472 Dear Mr. Cox: This is to follow-up on the letter of October 11, 1985, sent to you concerning the effect of our regulations on modifications made to used vehicles. Unfortunately, there was a typographical error in the third sentence of the third paragraph, The sentence should have read "However, in making modifications to a used vehicle, commercial businesses do not have to comply with the safety standards that would apply if the modifications are made before the vehicle is first sold." We regret the error. Sincerely, Original Signed By Erika Z. Jones Chief Counsel
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ID: nht73-5.5OpenDATE: 09/14/73 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: General Motors Corporation TITLE: FMVSR INTERPRETATION TEXT: Dr. Gregory has asked me to reply to your letter of August 28, 1973, in which you request our endorsement of new labels General Motors intends to use to fulfill its responsibilities under part 567 of Title 49 of the Gode of Federal Regulations. The wording on the label meets the requirements of paragraph 567.4(g). The color of the paint under the label "window" would determine conformity with the contrasting color requirements in paragraph 567.4(f) It would appear that the material would ". . . be permanently affixed . . ." if it ". . . is tightly bonded to the surface of the vehicle panel . . . ." However, it has not been the practice of the National Highway Traffic Safety Administration to endorse label materials. Thank you for your continuing cooperation. |
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.