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: aiam0176OpenMr. W. W. King, Vice President, Marketing, Meyer Products, Inc., 18513 Euclid Avenue, Cleveland, OH 44112; Mr. W. W. King Vice President Marketing Meyer Products Inc. 18513 Euclid Avenue Cleveland OH 44112; Dear Mr. King: I regret the delay in responding to your letter of April 23, in whic you provided certain certification information and details on your wheeled spreaders.; The wheeled spreaders attached to a towing vehicle are considered moto vehicles under the National Traffic and Motor Vehicle Safety Act of 1966, and have been categorized as 'trailers'. Federal Motor Vehicle Safety Standard 108 is currently the only standard applicable to trailers, specifically those 80 inches and more in overall width.; This Standard will also apply to trailers of lesser width manufacture after December 31, 1968.; Accordingly Meyer Products is required to certify compliance i accordance with section 114 of the Act. I enclose for your guidance copies of the Act, Federal Standard No. 108, and the certification Notice currently in effect.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam5374OpenMr. Neil Rowe Rowe Manufacturing 1266 Highway 96 - Box 386 Gladbrook, IA 50635-0386; Mr. Neil Rowe Rowe Manufacturing 1266 Highway 96 - Box 386 Gladbrook IA 50635-0386; "Dear Mr. Rowe: This responds to your letter requesting informatio about Federal requirements applicable to your product, the Glad Grip. You stated that this product serves as a handle to help connect and disconnect truck tractor air brake hoses at the glad hand. I am pleased to have this opportunity to explain our regulations to you. By way of background, NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue Federal motor vehicle safety standards (FMVSSs) that set performance requirements for new motor vehicles and new items of motor vehicle equipment, such as your product. However, NHTSA has not issued any FMVSS for your product. Our standard for brake hoses (FMVSS 106) applies to air brake hoses, end fittings and assemblies installed as original equipment and to those sold in the aftermarket. Standard 106 defines 'brake hose end fitting' as a coupler, other than a clamp, designed for attachment to the end of a brake hose. You describe the Glad Grip as a device which attaches to the end fitting of an air brake assembly and the glad hand. Since the brake hose that attaches to the Glad Grip is equipped with its own end fittings, the Glad Grip itself is not an end fitting. Therefore, Standard 106 is inapplicable. While it does not appear that you will market your device as original equipment on new vehicles, bear in mind that FMVSS No. 121, Air Brake Systems, applies to trucks and trailers. Any new truck or trailer that has your product as original equipment must meet the standard's requirements with your product installed. I note also that, while NHTSA has not issued any standards for a device such as yours, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall of products with defects related to motor vehicle safety. In the event that the manufacturer or NHTSA determines that the Glad Grip contains a safety related defect, you as the manufacturer of the product would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Further, the Glad Grip is also subject to the requirements of 49 CFR Part 393.45 and 393.46 (copy enclosed), which are regulations administered by the Federal Highway Administration (FHWA) for commercial vehicles. If you are interested in these FHWA requirements, you can write to that agency at the addressed provided in the enclosed information sheet. I hope this information is helpful. If you have any other questions about NHTSA's safety standards, please contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures"; |
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ID: aiam1337OpenMr. Mel Aanerud, Manager, Reservation Business Enterprise, Star Route, Box 116, Vineland, MN 56359; Mr. Mel Aanerud Manager Reservation Business Enterprise Star Route Box 116 Vineland MN 56359; Dear Mr. Aanerud: This is in reply to your letter of November 16 concerning a definitio of 'steady burning' lamps.; Our definition of 'steady' is 'regular, uniform, not changed, replace or interrupted, not fluctuating or varying widely.' Stop lamps activated by the Pulsating Safety Brakelite would therefore not be 'steady burning.'; Thank you for your interest in highway safety. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam4135OpenMr. Takeshi Tanuma, Nissan Research & Development, Inc., P.O. Box 8650, Ann Arbor, MI 48104; Mr. Takeshi Tanuma Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Tanuma: Thank you for your letter of February 5, 1986 (ref. W-141-H) concerning the application of Standard No. 201, *Occupant Crash Protection in Interior Impact*, to an inside door 'pull-handle.' You explained that the pull-handle is made of unpadded plastic and does not have a hard inside frame. The drawing provided in your letter shows that the pull-handle is 7.44 inches (186 mm) long, 1.12 inches (28 mm) wide, and projects 1.09 inches (27 mm) from the side of the door. I hope that the following discussion answers your questions.; You first asked if the armrest requirements of S3.5 of the standar would apply to the pull-handle if it is located within the pelvic impact area of either the front or rear passenger door. In determining whether the requirements of S3.5 apply to the structure, the agency has looked at the design and location of the structure, to determine whether it is an armrest (see, for example, the agency's interpretation letter of September 21, 1983, to Mr. Suzuki of your company.). In this case, the pull-handle projects far enough from the side of the door so that it could be used to rest the arm. Further, if the pull-handle were located in the pelvic impact area, it is likely to be used to rest the arm. Thus, we would consider such a pull-handle located in the pelvic impact area to be an armrest which must meet the requirements of S3.5 of the standard.; You also asked if the pull-handle would have to meet the requirement of S3.5 of the standard if it were located outside of the pelvic impact area at the upper portion of the door. In a conversation with Mr. Oesch of my staff, Mr. Hayaski explained that the pull-handle would probably be located near the rearmost edge of the door. In this case, it appears that the pull-handle would be positioned above and to the rear of where occupants would normally be expected to rest their arms. Thus, we would not consider a pull-handle located in the upper portion of the door and near the door's rear edge to be an armrest.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0875OpenShigemitsu Morita, General Manager, Daicel Ltd., New York Liaison Office, 200 Park Avenue, New York, NY, 10017; Shigemitsu Morita General Manager Daicel Ltd. New York Liaison Office 200 Park Avenue New York NY 10017; Dear Mr. Morita: This is in reply to your letter of September 15, 1972, to Mr. Jerome A Palisi, requesting information concerning the application of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to various components of vehicle occupant compartments made of plastic or plastic and metal.; The components that must meet the requirements of the standard ar listed in paragraph S4.1. Some of the components you have asked about are covered by the standard and others are not. Dashboards and instrument panels are considered to be 'front panels' and are therefore covered. Steering wheels normally are 'designed to absorb energy ... in the event of a crash' and, in that case, are covered. The components not covered specifically are handles of handbrakes, meter housings, steering column covers, console boxes, and handle knobs to open and shut windows. These components, such as console boxes, will nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash.' We cannot identify what you mean by 'change lever knobs' and, therefore, we cannot comment on this component.; You also ask whether finished or unfinished components should be teste according to the procedures described in S5 of the standard, and what kind of specimens should be prepared for plastic components with metal insertions. The standard does not apply to intermediate or unfinished materials, and compliance testing by the Government is carried out with components removed from motor vehicles that have been marketed. Test specimens should be prepared according to S5.2.1 of the standard regardless of the materials that are present in a given component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2848OpenMs. Anna Racanelli, Assistant General Manager, Nippondenso Company, Ltd., 16 Henderson Drive, W. Caldwell, NJ 07006; Ms. Anna Racanelli Assistant General Manager Nippondenso Company Ltd. 16 Henderson Drive W. Caldwell NJ 07006; Dear Ms. Racanelli: This is in reply to your letter of August 10, 1978, to Mr. Vinson o this office requesting confirmation of interpretations of Paragraph S4.7 of Motor Vehicle Safety Standard No. 108.; This confirms your interpretations. Paragraph S2, *Application* states the coverage of the standard: t specified vehicle types 'and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies' i.e. those vehicles manufactured on or after January 1, 1972. The equipment items listed in Tables I and III are required motor vehicle lighting equipment, and any item manufactured as a replacement for one of these items that has been original equipment on 1972 or later model vehicles, must meet Standard No. 108's requirements and be so certified.; Paragraph S4.7 allows certification by means of a DOT symbol placed o the item itself. No specific design or size is required. The manufacturer may certify by other means as well, specifically those set forth for all equipment items covered by a standard, in Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403): 'a label or tag on [the] item or on the outside of a container in which such item is delivered'. We would view an indelible stamp on the container as 'a label' within the meaning of Section 114 if Nippondenso wished to certify by this means.; I have no other suggestions regarding use of the DOT symbol, excep that it should be of a size and in a location sufficient to readily identify the item as meeting Federal requirements, thereby avoiding any possible misunderstanding.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1767OpenMr. R.W. Hildebrandt, Group Director of Engineering,Bendix Heavy Vehicle Systems Group,901 Cleveland Street,Elyria, Ohio 44035; Mr. R.W. Hildebrandt Group Director of Engineering Bendix Heavy Vehicle Systems Group 901 Cleveland Street Elyria Ohio 44035; Dear Mr. Hildebrandt:#This responds to your letter of January 17, 1975 requesting confirmation if a telephone discussion between Mr. R.J. Clifford of Bendix and Mark Schwimmer of this office, concerning the effective dates and labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. Your letter posed several questions and suggested their answers. The answers which you have presented represent correct interpretations of Standard No. 106-74.#Please Forgive our delay in responding to your request of October 1, 1974, for an interpretation of the term 'manufacturer of the hose assembly' as used in S5.2.4(b) of the standard. The NHTSA is aware of the problems which you have pointed out, and the issue will be dealt with in a forthcoming notice in the Federal Register.#Your truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4565OpenMr. Clarence M. Ditlow III Executive Director Center for Auto Safety 2001 S Street, NW Suite 410 Washington, DC 20009; Mr. Clarence M. Ditlow III Executive Director Center for Auto Safety 2001 S Street NW Suite 410 Washington DC 20009; "Dear Mr. Ditlow: This responds to your most recent letter to m concerning retrofitting of cars originally equipped with rear seat lap belts with rear seat lap/shoulder belts. In my November 1, 1988 letter to you, I explained that we have sought the voluntary cooperation of manufacturers to make retrofit kits available for those customers who desire them and that the vehicle manufacturers have responded positively to our efforts. I also explained that the fact that retofit kits are not available for all model lines produced by each manufacturer does not suggest some failure on the part of the vehicle manufacturers or of our policy to encourage the manufacturers to make such retrofit kits available. In a November 7, 1988 letter, you asserted that my November 1 letter 'reflects such callous disregard and ignorance of the facts as to defy belief that you are doing little more than covering up for a GM policy that will kill rear seat passengers.' You stated that you would welcome a 'substantive response' to this letter. I am happy to be able to give you such a response. Let me begin by emphasizing that the lap belts in the rear seat of most vehicles on the road today are effective in reducing the risk of death and injury in a crash. Based on our analysis of a number of crash data files, we estimate that rear seat lap belts saved about 100 lives and prevented over 1500 serious injuries in 1987 alone. These figures would have been substantially higher if more rear seat occupants used their lap belts. In fact, if everyone had worn their rear seat lap belts each time they rode in a vehicle, those belts would have saved about 660 lives and prevented more than 10,000 serious injuries in 1987 alone. These facts illustrate that the fastest and most effective way to save the greatest number of lives and prevent the greatest number of injuries is to convince the public to use the safety belts, including the rear seat lap belts, that are in their vehicles every time they ride in those vehicles. Because of these facts, I do not accept your assertion that GM's policy of not providing rear seat lap/shoulder belt retrofit kits for a few of their past models will 'kill people.' To the extent that reckless assertions like this tell the public that they should not wear their rear seat lap belts, it is unfortunate that you have chosen to divert attention away from the overriding issue of convincing the public to use their safety belts, and instead chosen to mislead the public about the quality of their safety belts. Even though lap belts have been proven to be effective in reducing the risk of death and injury in a crash, we agree that properly designed lap and shoulder belts have the potential to offer even greater crash protection than lap belts alone. For this reason, we have proposed to require that all new passenger cars sold in the United States be equipped with rear seat lap and shoulder belts beginning in the 1990 model year. Additionally, we have actively sought the car manufacturers' cooperation in providing retrofit kits to interested consumers. As you may know, every domestic manufacturer and many foreign manufacturers now offer retrofit kits for many of their vehicle models. You objected to General Motors' (GM) statement in its Information Bulletin that retrofit kits are not offered for its 1978-88 Oldsmobile Cutlass, Buick Regal, Chevrolet Monte Carlo, or Pontiac Grand Prix, 'because GM safety engineers have concluded that in these cars, a rear seat lap/shoulder belt combination would not enhance the safety offered by the lap belt alone.' You asserted that since Leonard Evans, a GM employee, has concluded that lap/shoulder belts are significantly more effective than lap belts and since the National Highway Traffic Safety Administration (NHTSA) is proposing to require rear seat lap/shoulder belts, there is no 'possible scientific basis' for GM's conclusion. NHTSA's proposal reflects our tentative conclusion that rear seat lap/shoulder belts that are designed and installed at the factory have the potential to offer even greater crash protection than lap belts alone for vehicles in general. However, any particular vehicle model's floor pan design, seat stiffness, and seat design (as it relates to occupant posture) can affect the possibility of an occupant submarining under a lap/shoulder belt system in a crash. During the design and production of the vehicle, the vehicle manufacturer can take these factors into account to minimize the likelihood of such submarining and its associated consequences. However, this is emphatically not true for vehicles that were not originally engineered and designed to use rear seat lap/shoulder belts as original equipment. With respect to these vehicles, the effectiveness of a retrofitted rear seat lap and shoulder safety belt system may well depend on the belt system's compatability with the vehicle and the installation of the belt system. The suitability of a particular vehicle for retrofitting is therefore a complex question. It is our view that the judgment as to whether a retrofit lap/shoulder belt system should be installed in a particular vehicle is best made by a vehicle manufacturer, which is most familiar with the detailed seat and structural design and crash performance of the car. I hope this information is helpful. Please let me know if you have any further questions or would like some additional information on this subject. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam2262OpenMr. Michael J. Murphy, President, National Automobile Theft Bureau, 390 North Broadway, Jericho, NY, 11753; Mr. Michael J. Murphy President National Automobile Theft Bureau 390 North Broadway Jericho NY 11753; Dear Mr. Murphy: This is in response to your letter of January 8, 1976, concernin 'track sheets' and 'autotels.'; Section S4 of the Federal Motor Vehicle Safety Standard No. 302 *Flammability of Interior Materials*, lists those components of a motor vehicle that must comply with burn resistance requirements. I have enclosed a copy for your information. An 'autotel' under the back seat, between the frame and the body, or pasted to the top of the gas tank does not fall within the ambit of the standard. Consequently, it is our view that this most important and effective deterrent to vehicle theft is not discouraged by any existing motor vehicle safety standard.; The National Highway Traffic Safety Administration has proposed tha Standard No. 302 be amended to include all materials exposed to the occupant compartment air space. If this amendment is adopted, an 'autotel' under the seat presumably would fall within the purview of the standard. In this case, the 'autotel' could not burn at a rate of more than 4 inches per minute. We believe that this would not prove an impediment to the continuation of the 'autotel' program as a flame-retardant paper is readily available.; If I can be of further assistance in this matter, please do no hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2798OpenMr. Robert B. Kurre, Wayne Corporation, P.O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Wayne Corporation P.O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your February 28, 1978, letter asking whether portion of your van-type school bus have to comply with the head protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*. You enclosed pictures showing portions of the bus designated in pink and yellow and question the standard's applicability to them.; The head protection zone requirements do not apply to portions of th school bus that are considered part of the bus sidewall. The National Highway Traffic Safety Administration considers the sidewall to include those surfaces that run parallel to the outboard edge of a forward facing seat. Accordingly, the portions of your bus designated in yellow in the pictures need not comply with the requirements since they are part of the bus sidewall structure. The pink portions of your photographs represent part of the bus structure that is perpendicular to the bus sidewall. The NHTSA does not consider them to be part of the bus sidewall structure. Therefore, since they fall within the head protection zone they must comply with all of the requirements applicable to that zone.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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.