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: nht80-2.40OpenDATE: 05/29/80 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Isuzu Motors America, Inc. TITLE: FMVSS INTERPRETATION TEXT: Mr. Hiroshi Abe Assistant General Manager Isuzu Motors America, Inc. 21415 Civil Center Drive Southfield, Michigan 48076 Dear Mr. Abe: This is in response to your letter of April 3, 1980, concerning the application of Federal Motor Vehicle Safety Standard No. 115 to incomplete vehicles. S4.1 of Standard No. 115 provides that "(e)ach vehicle manufactured in more than one stage shall have a VIN and check digit assigned by the incomplete vehicle manufacturer." Consequently, Isuzu Motors, Inc. would be the entity responsible for assigning the vehicle identification number (VIN) to incomplete vehicles which it ships to the United States. You wish to know whether the manufacturer identifier in the VIN of each of these vehicles may designate the vehicle as a "truck" instead of as an "incomplete vehicle" if Isuzu knows that the completed vehicle will be a truck. S4.5.1 of the standard provides that the first three characters of the VIN shall identify the manufacturer, make and type of vehicle. Table I of S4.5.2 delineates the different types of vehicles and includes a separate type designation for "incomplete vehicles." As explained in the preamble to Notice 8 (March 22, 1979, 44 FR 17489, at 17490), the "incomplete vehicle" category was added because "incomplete" vehicle manufacturers would have little way of knowing the final configuration of the vehicles they produce." It was never the intent of the agency, however, to preclude a manufacturer from indicating the precise types of completed vehicles if this is known. Sincerely, Frank Berndt Chief Counsel
April 3, 1980 Mr. Frederick Schwarts, Jr. Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 Subject: Incomplete Vehicle Attributes --- FMVSS 115 VIN Dear Mr. Schwarts: This letter is intended to seek your advice on whether the use of VIN for our incomplete trucks meets the requirements of FMVSS 115 --- Vehicle Identification Number. We currently manufacture and ship to the U.S. incomplete vehicles for which we assume "legal responsibility for all duties and liabilities imposed by the Act, with respect to the vehicle as finally manufactured" as specified in 49 CFR Part 567 ---Certification, 567.5(e). All the vehicles are completed into trucks by the final manufacturer in the U.S. Therefore, the vehicle type description shown in the certification label as set forth in 567.5(e) is "Truck." In light of this situation, we are planning to use the VIN (the first three characters) assigned to our trucks rather than to incomplete vehicles. The same would apply to the VIN appearing on the above-mentioned certification label. We believe this arrangement would not contradict the requirements of FMVSS Part 115, but would appreciate your confirmation. We are looking forward to hearing from you. Thank you in advance for your cooperation. Sincerely yours, H. Abe Assistant General Manager 05/29/80 |
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ID: 77-3.49OpenTYPE: INTERPRETATION-NHTSA DATE: 08/18/77 FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Truck Body & Equipment Assoc., Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your July 22, 1977, request for clarification of my July 21, 1977, letter to you stating that, in the case of brake and axle modifications to change the function of a used vehicle from that for which it was originally manufactured, it is the NHTSA's view that degradation of the brake system would only occur as prohibited by the National Traffic and Motor Vehicle Safety Act (@ 108(a)(2)(A)) if portions of the brake system originally installed are removed, disconnected, or otherwise rendered inoperative. You asked whether a change in "function" of a vehicle would include a modification that simply increases the load-carrying capacity or stability of the vehicle to carry out the same task for which it was originally manufactured. The answer to your question is no. In the NHTSA's view, the changes you describe would only increase the capabilities of the vehicle to perform its originally manufactured function. Thus, the "element of design" that constitutes the original braking system of the vehicle could be knowingly degraded by the installation of an additional axle that does not provide the capability that would have been required for it if installed in the new vehicle. SINCERELY, TRUCK BODY AND EQUIPMENT ASSOCIATION, INC July 22, 1977 Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration In response to your letter of July 20, 1977, (see attachment #1), a question has arisen concerning the Agency's use of the term "function" as it relates to a truck. It would appear that a change in a truck's function dictates whether or not an anti skid unit is applied to the additional axle installed on a used vehicle. (See attachment #2). Whenever our industry adds an axle to any vehicle, our intent is always to change the function of the vehicle by either increasing the load carrying capacity or by increasing the vehicle's stability. A used moving van may be originally operated to transport furniture but upon resale to the second owner, an additional axle may be installed to allow the vehicle to transport heavy machinery. Just as in the original example cited in our letter of April 12, 1977, the addition of the second rear axle to the van type truck clearly changes the function of the vehicle. We recognize that the Agency must ensure that no one deliberately attempts to circumvent the requirements of the Law by claiming that a vehicle is used and therefore not subject to the Federal Motor Vehicle Safety Standards. But in the same sense, whenever a vehicle is reworked to provide a different service after it initially has been operated to perform a specific vocational duty, the vehicle has clearly established a new job function. Therefore, with respect to your letter of July 20, 1977, are we correct in assuming that when referring to a used vehicle, the term "function", indicates either a physical or job related operational change? Byron A. Crampton Manager of Engineering Services |
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ID: nht87-2.44OpenTYPE: INTERPRETATION-NHTSA DATE: JULY 9, 1987 FROM: WILLIAM SHAPIRO -- MANAGER, REGULATIONS AND COMPLIANCE - VOLVO TO: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL TITLE: PART 581; BUMPER STANDARD DAMAGEABILITY REQUIREMENTS - REQUEST FOR INTERPRETATION ATTACHMT: ATTACHED TO AUGUST 31, 1987 LETTER FROM JONES TO SHAPIRO TEXT: In Part 581 the performance requirements for vehicle bumpers is set forth. Section 581.6 describes the condition of the bumper for testing. Paragraph (a)(5) of this section allows for headlamp washers to be removed prior to the test. This standard was promulgated prior to the advent of headlamp washer-wiper systems. Volvo believes the interpretation of "headlamp washers" can therefore be expanded to include headlamp washer-wiper systems so the standard can remain current with automotive technology. We look forward to hearing from you on this matter. If you have any questions, please don't hesitate to contact me. |
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ID: nht95-4.89OpenTYPE: INTERPRETATION-NHTSA DATE: November 28, 1995 FROM: Clifford C. Sharpe TO: Legal Division, U.S. DOT TITLE: NONE ATTACHMT: 2/2/96 letter from Samuel J. Dubbin to Clifford C. Sharpe (A44; Std. 109) TEXT: I represent a client who purchased a Turbo Plus Radial GT steel belted radial tire bearing Dept of Transportation Serial No.: ADHY28M166 manufactured by General Tire, Inc. between April 20-26, 1986 at its Mayfield, KY plant. My client purchased the tire as "new" on November 12, 1991. The tire unraveled in March of 1993 after about 14,000 miles of travel causing injury. Are there any regulations that address the selling as new of a tire that was manufactured 5 years hence? Are you aware of any studies or information on the affects of age/time on an unused tire? I will be responsible for all costs associated with this request. |
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ID: nht72-1.6OpenDATE: 06/13/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: FMC Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of May 25 inquiring about compliance of your planned motorhome with Federal Motor Vehicle Safety Standards Nos. 101 and 104. Standard No. 101 requires certain controls to be illuminated. We interpret this to mean sufficiently illuminated that the control identification, if verbal, can be read, or if pictorial, can be understood. Therefore, illumination from any course is satisfactory as long as the basic requirement of comprehension is met. Standard No. 104 does not describe the type of windshield wiping system that must be used to meet its requirements. It is the manufacturer's responsibility to insure, whatever system is used and whatever configuration of windshield is employed, that the wiped and washed area requirements are met. |
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ID: nht73-2.40OpenDATE: 02/23/73 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: The Gates Rubber Company COPYEE: BRAD MARKS; EDWARD B. FINCH -- FTC; MR. PESKOE TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of January 24, 1973, inquiring what NHTSA would consider to be an appropriate generic name for Dupont's Fiber B. The approval of generic names of cord materials is under the jurisdiction of the Federal Trade Commission. We understand that agency has issued a temporary approval with regard to this material, and that a further petition is currently under review. For purposes of conformity to Standard No. 109 we will, of course, accept any generic name approved by the Federal Trade Commission. If you desire further information regarding this matter, you may write to Mr. Edward B. Finch, Assistant Director for Textiles and Furs, Federal Trade Commission, Washington, D. C. 20580. |
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ID: nht69-1.26OpenDATE: 08/27/69 FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA TO: Rubber Manufacturers Association TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your letter of August 1, 1968, to the National Highway Safety Bureau, requesting the addition of test rims for certain tire size designations to Table II of the Federal Motor Vehicle Safety Standard No. 110. With your letter your transmitted data indicating satisfactory completion of the test requirements specified in the Federal Motor Vehicle Safety Standards No. 109 and No. 110. On the basis of this information, your request for the approved equivalent rims is granted. Accordingly, the following approved equivalent rims will be added to Table II of the Federal Motor Vehicle Safety Standard No. 110. Tire Size Designation Alternate Rim E70-14 7JJ E70-15 8JJ G78-14 7JJ E70-15 7JJ |
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ID: nht69-2.49OpenDATE: 08/18/69 FROM: AUTHOR UNAVAILABLE; S. K. Booth; NHTSA TO: Cox Trailors Incorporated COPYEE: CENTRAL FILE(2); ANDERS; COMPTON; LEYSATH; NIELD; 512 CHRON; 510A CHRON; INTERPRETATIONS: STD.108; DYSON (2); CC-2921 TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of August 6, 1969, concerning the location of the side marker lamp and reflector on boat trailers manufactured by your company, as discussed by your Mr. Oglesby with Mr. Tyson of this office. Paragraph S3.2.1.4 of Standard 108 states: "On trailers, the amber front side reflex reflectors and amber front side marker lamps may be located as for forward as practicable exclusive of the trailer tongue." The forward location chosen will be satisfactory if you can provide reasonable justification for not placing it farther forward, that is, closer to the base of the trailer tongue. We are pleased to be of assistance. |
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ID: nht91-1.26OpenDATE: January 16, 1991 FROM: Marvin A. Leach, D.Ed. -- Regional Program Manager, NHTSA TO: S.V. Kaaria COPYEE: Kathleen DeMeter TITLE: None ATTACHMT: Attached to letter dated 1-3-91 from S.V. Kaaria to NHTSA; Also attached to letter dated 2-11-91 from Paul Jackson Rice to S.V. Kaaria (A37; Std. 108) TEXT: Thank you for your letter of January 3, 1991, seeking information about problems related to negotiating a settlement with auto manufacturers on a design you were involved in developing. I am taking the liberty of forwarding your letter to: Ms. Kathleen DeMeter General Law Division Office of the Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W., NCC30 Washington , D.C. 20590 I hope this will be of assistance toward the resolution of your inquiry. |
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ID: nht91-2.48OpenDATE: March 25, 1991 FROM: Dan P. Strauser -- Manager, Research and Development, Elgin Sweeper Company TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-8-91 from Paul Jackson Rice to Dan P. Strauser (A37; VSA 102(3) TEXT: I would ask that you review the enclosed literature on Elgin Sweeper model Whirlwind, Crosswind and Eagle 4-wheel street sweepers, along with Pelican "SE" and Pelican "P", 3-wheel street sweepers. I am also enclosing literature from our sister division Ravo, Models 4000 and 5000 street sweepers. I would like a letter of interpretation on the above models. We would also be interested in determining what the criteria is for sweepers classified as falling under the FMVSS requirements. If additional information is required, please call me at (708) 741-5370. |
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.