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: nht89-2.19OpenTYPE: INTERPRETATION-NHTSA DATE: 06/22/89 FROM: WOLFRED FREEMAN -- FREEMAN AND COMPANY TO: ADMINISTRATOR NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/06/89 FROM STEPHEN P. WOOD -- NHTSA TO WOLFRED FREEMAN; REDBOOK A34; STANDARD 108 TEXT: Dear General Curry, I hereby petition your bureau for permission to produce a color coded (Green-Amber-Red) rear light device for all types of motor vehicles. This type of signal would provide information to the driver of the following vehicle as to what actions is taking place. Just as one seeing a "white back up light" knows that the driver intent is to back up, whether the vehicle is moving or not. With my proposed device one would immediately know what the drivers intentions were. If the driver had their foot on the gas the light would be Green, as soon as the foot was removed from the throttle, the light would show Amber alerting the following driver that the driver in front had removed their foot from the gas and was costing or about to make a move either to the gas or the brake. The present system of Red light intensity provides no information as to driver intent. I think the variable glow Red has a tendency to mesmerize one over a period of time and should be improved for traffic safety. It is my understanding that research has already been done by your Bureau on human factor reaction time to my proposed signal as opposed to light intensity differential systems now in use. It is also my understanding that this research favored my type o f system. We have designed a workable auxiliary system that can be adopted to cars and trucks now on the road. But before we go any further we want to be sure that we will not be beating our heads against a bureaucracy wall. I think your review of my request will disclose enough research and development to allow for a speedy approval of my request. Awaiting your reply, I remain, Sincerely. |
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ID: 86-3.47OpenTYPE: INTERPRETATION-NHTSA DATE: 06/12/86 FROM: JAMES J. DABROWSKI -- REGULATIONS/STATISTICS COORDINATOR JAGUAR TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN. TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 07/15/86 TO, JAMES J. DABROWSKI, FROM ERIKA Z. JONES, REDBOOK A29 (4); SEC 102, 151; RECALL LETTER TO GRAY MARKET VEHICLE OWNERS FROM JAGUAR CARS INC AND RELEASE DATED 06/12/86 EST TEXT: Dear Ms. Jones: Attached you will find a copy of our letter to individuals or firms who have been identified as being in possession of or who have imported a Gray Market Jaguar vehicle that may be subject to a manufacturer's recall campaign. Also attached is a standard release form which we will require the owner/importer to sign before we attempt any recall repair. As we understand, Jaguar Cars has no legal responsibility to notify owners of these vehicles or to repair these vehicles. Therefore, the usual NHTSA recall notification, owner letter, and reporting, etc., requirements are not binding. By way of explanation, however, the fact that we are not bound by these regulations is not the reason for our "abbreviated" owner notification approach. The convoluted nature of virtually all aspects of this undertaking from sorting out complicated and often poor attempts at compliance modifications, unknown technology and unknown repair times to logistical questions regarding a cooperating dealer and arranging for a pre-repair inspection, etc., dictate a simple letter. It would be impossible under these circumstances to produce an all encompassing owner notification letter. In this instance, it is more efficient to liaise with the customer via phone. We would like to make you aware of our endeavor. Mr. D. Allen of your office has, via Mr. F. Armstrong, seen our letters and expressed no objection. Would you please be kind enough to review the attached documents and confirm that Jaguar Cars is not bound by normal NHTSA recall procedures. ATTACHMENT Yours sincerely, |
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ID: nht69-1.5OpenDATE: 05/01/69 EST FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA TO: Concorde Rubber Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 2, 1969, requesting a Department of Transportation (DOT) code number be assigned the Concorde Rubber Company. According to your letter, Concorde has tires manufactured for it by (Illegible Word) Tire and Rubber Company of Hadera, Israel, and by Lee Tire and Rubber Company of Conehehocken, Pennsylvania, which are labeled with Concorde's brand name and the manufacturer's code number (alliance Tire and Rubber Company uses approved code number DOT 187 and Lee Tire and Rubber Company uses approved code number 152). Pursuant to Motor Vehicle Safety Standard No. 109, DOT numbers to be molded onto new tires, where a brand name is used rather than the manufacturer's own name, are assigned to tire manufacturers so the seller of the tire may identify the manufacturer to a purchaser upon request. The legislative history of section 201 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 4121) e.g., see 112 Cong. Rec. 18792 (daily ed. August 17, 1966), and the plain meaning of section 201 of the Act demonstrates that Congress intended to have tires made for sale under the private brand of a merchandiser bear the name or code mark of the concern that actually produces the tire, not merely an identification of the merchandiser distributing and selling the tires to the public. The Act provides that tire labeling shall include "suitable identification of the manufacturer . . . unless the tire contains a brand name other than the name of the manufacturer in which case it shall also contain a code mark which would permit the seller of such tire to identify the manufacturer thereof to the purchaser upon his request." Accordingly, your request for the Concorde Rubber Company's own code number, so that tires manufactured for Concorde by different tire producers can have the same code number, must be denied. |
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ID: nht91-1.35OpenDATE: February 7, 1991 FROM: Billy S. Peterson -- President, Automotive Safety Testing, Inc. TO: Office of Chief Council, DOT/NHTSA TITLE: None ATTACHMT: Attached to letter dated 3-8-91 from Paul Jackson Rice to Billy S. Peterson (A37; Std. 108) TEXT: This letter is a request for clarification of allowable mounting locations and photometric output requirements for tail/stop lamps on passenger cars. We have a client who wishes to mount two-part tail/stop lamps on the rear of their vehicle so that one lamp is mounted on the fixed quarter panel and a duplicate lamp is mounted on the trunk lid. The specific question we have is: Must the minimum photometric requirements be met by the lamp mounted to the quarter panel or may the portion mounted to the trunk lid count toward the photometric requirements? The confusion arises from a letter from your office to this office dated 1/28/88 which stated that the trunk lid is considered a rigid body panel for purposes of this standard because it is meant to be closed during normal operation and, therefore, the mounting of reflectors and back-up lamps on it is allowed. Another letter, addressed to Volkswagen of America, dated 7/30/80, states essentially the same thing except it contains the opinion that placement of the tail/stop lamps on the trunk lid may be viewed as a defect in performance, subject to recall. Our interpretation of this letter was that VW had planned to mount lamps only on the trunk lid and not the body quarter panel and this could pose a problem. Since our client's intention to mount duplicate tail/stop lamps on both the body quarter panel and the trunk lid was not specifically addressed in the earlier letters noted above, this letter serves as a request for clarification of the requisite output requirements associated with that mounting arrangement. A drawing of the proposed lamp combination is attached to this letter.
Attachment Drawing of proposed lamp combination (Graphics omitted) |
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ID: nht93-3.15OpenDATE: April 23, 1993 EST FROM: Patrick P. Radice -- Director of Operations, Electronics Division, Tridon TO: Chief Counsel -- U.S. Department of Transportation, NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-5-93 from John Womack to Patrick P. Radice (A41; Std. 108) TEXT: We understand aftermarket manufacturers of turn signal flashers and hazard warning signal flashers must certify their flashers comply with the applicable requirements specified in FMVSS-108 prior to sale. For vehicles having combination turn signal/hazard warning signal flashers, must the manufacturer certify the aftermarket flasher also meet both the turn signal and hazard warning flasher requirements of FMVSS-108 or can they certify their flashers to meet either the turn signal flasher or hazard warning signal flasher or FMVSS-108 but not both? I look forward to your response. |
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ID: nht93-7.39OpenDATE: October 22, 1993 FROM: Jim Davis -- President, Russell Performance Products TO: Office of Vehicle Safety Standards, Crash Avoidance Division, NHTSA COPYEE: David Elias -- DOT; Bill Collins -- Titeflex TITLE: None ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Jim Davis (A42; Std. 106), letter dated 10/22/93 from Jim Davis to David Elias (OCC-9249), and letter dated 11/16/93 from Jim Davis to David Elias TEXT:
At the direction of David Elias, Chief Counsel of the D.O.T., we are submitting a sample of our identifying symbol "R" that will be used in conjunction with brake hose assemblies that we will be manufacturing and marketing as meeting D.O.T. Specification MVSS 106. Please contact the undersigned if you have any questions or need further clarification. |
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ID: nht94-4.6OpenTYPE: INTERPRETATION-NHTSA DATE: August 18, 1994 FROM: Ken Daining -- Supervisor, Vehicle Test and Development, ITT Automotive TO: Marvin Shaw -- NHTSA TITLE: None ATTACHMT: ATTACHED TO 3/8/95 LETTER FROM PHILIP R. RECHT TO KEN DAINING (REDBOOK (2)); STD. 105 TEXT: I received your name through a recent phone conversation with Mr. George Soodoo. I work for ITT Automotive as the supervisor of the Chrysler vehicle ABS/TCS test and development department. I am interested in obtaining information relating to any existi ng (or future) legislation on the legalities of an ABS on/off switch. Currently, Chrysler Jeep owners which enjoy serious off-road driving, disengage their ABS because of the perceived degraded performance it offers on off-road situations. One proposal being kicked around is the possibility of automatically disengaging ABS function through the shifting of the vehicle into the 4WD-LO configuration (as most serious off-roaders do today). Any information you can provide will be very helpful. Thank you for your time and cooperation. |
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ID: nht93-8.28OpenDATE: November 23, 1993 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: J. C. DeLaney -- Manager, Technical Programs, Motorcycle Industry Council, Inc. TITLE: None ATTACHMT: Attached to letter dated 10/18/93 from J. C. DeLaney to John Womack (OCC-9226) TEXT: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 123; Motorcycle controls and displays. You asked whether a motorcycle side stand complies with Standard No. 123 if the stand passes SAE J1587 Motorcycle Side Stand Retraction Test Procedure. Standard No. 123 specifies at S5.2.4 Stands that: "A stand shall fold rearward and upward if it contacts the ground when the motorcycle is moving forward." Neither S5.2.4 nor any other provision of Standard No. 123 incorporates by reference, SAE J1587. Thus, if a motorcycle side stand passes the SAE J1587 test procedure, it does not automatically follow that the side stand complies with Standard No. 123. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. |
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ID: 9226Open Mr. J. C. DeLaney Dear Mr. DeLaney: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 123; Motorcycle controls and displays. You asked whether a motorcycle side stand complies with Standard No. 123 if the stand passes SAE J1587 Motorcycle Side Stand Retraction Test Procedure. Standard No. 123 specifies at S5.2.4 Stands that: "A stand shall fold rearward and upward if it contacts the ground when the motorcycle is moving forward." Neither S5.2.4 nor any other provision of Standard No. 123 incorporates by reference, SAE J1587. Thus, if a motorcycle side stand passes the SAE J1587 test procedure, it does not automatically follow that the side stand complies with Standard No. 123. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:123 d:11/23/93 |
1993 |
ID: nht89-2.62OpenTYPE: Interpretation-NHTSA DATE: August 8, 1989 FROM: Luke Baer -- Vice President/General Counsel, Porsche Cars North America, Inc. TO: Emory L. Lariscy -- President, Lariscy Enterprises, Inc. TITLE: None ATTACHMT: Attached to letter dated 9-4-90 from P.J. Rice to E.J. Lariscy (A36; Std. 108; Std. 124; Std. 301); Also attached to letter dated 8-28-90 from E.L. Lariscy to G. Shifflett (OCC 3910) with Patent Application for Vehicle Safety Light Assembly (gr aphics omitted); Also attached to letter dated 7-14-89 from J.M. Mundy to E. Lariscy; Also attached to letter dated 7-14-89 from J.M. Staples to E.L. Lariscy; Also attached to letter dated 7-28-89 from A.M. Kennedy to E.L. Lariscy TEXT: Thank you for your recent submission to us of your Vehicle Safety Light Assembly. We have forwarded this material to Mr. Juergen Herrmann of the Patent Department of Porsche AG for consideration and response. Thank you for your interest in Porsche. |
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.