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: nht79-4.47OpenDATE: 10/16/79 FROM: EDWIN F. RIEDEL -- COMMONWEALTH OF MASSACHUSETTS REGISTRY OF MOTOR VEHICLES TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/09/89 FROM STEPHEN P. WOOD -- NHTSA TO BLANCHE KOZAK; REDBOOK A33 (2); VSA 108 [A] [1] [A]; LETTER DATED 04/04/89 FROM NANCY L. BRUCE -- DOT TO CHESTER ATKINS -- HOUSE; LETTER DATED 03/29/89 FROM CHESTER G. ATKINS -- HOUSE TO NANCY BRUCE -- DOT, RE MRS. BLANCHE KOZAK; LETTER DATED 09/26/88 FROM BLANCHE KOZAK TO BERRY FELRICE; REPORT UNDATED; LETTER DATED 08/09/88 FROM BLANCHE G. KOZAK TO DEPARTMENT OF TRANSPORTATION TEXT: Re: Lawrence General Hospital, 1 General Street Lawrence, Massachusetts 01842 Reg. #TX6539, issued 10-16-79 1976 Cushman, Police vehicle with enclosed cab V.I. #501081 A three wheeled vehicle with enclosed cab is by definition of law not a motorcycle and therefore the operator of[Illegible Word] is not required to be licensed for motorcycles. Yours truly, [Please be informed the above unit is not enclosed since it does not have doors. Blanche G. Kizak] |
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ID: nht94-1.82OpenTYPE: INTERPRETATION-NHTSA DATE: March 16, 1994 FROM: Gary Klingaman -- Engineer, Inter Pipe, Inc. TO: Office Of Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 4/21/94 From John Womack To Gary Klingaman (A42; Redbook (2); PART 567) TEXT: Dear Sir: We are a manufacturer of water trucks and lube/fuel service trucks. We take incomplete vehicles and add water tanks and various other apparatus, making it a complete vehicle. By Federal Motor Vehicle Safety Standards we are required to identify this vehicle by a sticker indicating manufacturer, incomplete vehicle manufacturer, date of manufacturer, GVWR with indicated tires, tire pressure, and vehicle identification number. We also may use pre-owned chassis in construction of our product. Do we need this sticker for this type of vehicle? I would appreciate any further information on this tag that is required and if it is required on used chassis belonging to either the customer or one we have purchased to sell. Regards, INTER PIPE, INC. |
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ID: nht94-7.43OpenDATE: March 16, 1994 FROM: Gary Klingaman -- Engineer, Inter Pipe, Inc. TO: Office Of Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 4/21/94 From John Womack To Gary Klingaman (A42; Redbook (2); PART 567) TEXT: Dear Sir: We are a manufacturer of water trucks and lube/fuel service trucks. We take incomplete vehicles and add water tanks and various other apparatus, making it a complete vehicle. By Federal Motor Vehicle Safety Standards we are required to identify this vehicle by a sticker indicating manufacturer, incomplete vehicle manufacturer, date of manufacturer, GVWR with indicated tires, tire pressure, and vehicle identification number. We also may use pre-owned chassis in construction of our product. Do we need this sticker for this type of vehicle? I would appreciate any further information on this tag that is required and if it is required on used chassis belonging to either the customer or one we have purchased to sell. Regards, INTER PIPE, INC. |
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ID: nht88-2.52OpenTYPE: INTERPRETATION-NHTSA DATE: 06/20/88 FROM: BYUNG M. SOH -- TARGET MARKETING SYSTEMS, INC, MARKETING DIRECTOR TO: OFFICE OF CHIEF COUNSEL, NHTSA TITLE: DOT RULING OR OPINION ATTACHMT: ATTACHED TO LETTER DATED 9-13-88 TO BYUNG M. SOH FROM ERIKAZ. JONES TEXT: Please find in enclosuree photocopies pertaining to informations on two devices which we intend to import to U.S.A. Even though these are not well written, I hope that the copies contain enough informations with which you could give us your opinion whet her these devices require approvals from D.O.T. These are 1. Logical beam: foglight converter 2. C.L.S. system: head-lamp intensity modulator These devices do not require to change existing lighting devices. We believe that these devices enhance road safety. If you require further information, we can be reached at (312)-673-7333 or by fax. (312)-673-7356. Thank you. ENC: 1 one set of photocopies of 'logical beam' and 'C.L.S. Systems' |
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ID: nht94-2.15OpenTYPE: INTERPRETATION-NHTSA DATE: April 4, 1994 FROM: William G. Franz -- Vice President, Fabrication, Wells Aluminum TO: Walter Myers -- NHTSA TITLE: Federal Motor Vehicle Safety Standard No. 217 ATTACHMT: Attached to letter dated 8/5/94 from John Womack to William G. Franz (Std. 217) TEXT: Dear Mr. Myers: Subsequent to our recent phone conversation, I am formally requesting an interpretation of paragraph S.5.1.2 regarding the window opening size. Specifically, my question is as follows: Does the 8 inch window opening size apply to the total outside frame dimension or does it apply to each pane of glass? The enclosed picture shows a typical retention test being performed on a push out window with two separately framed pieces of glass. In other words, would a pane of glass which measures less than 8 inches across need to be subject to the retention test? For your information, Wells Aluminum Corporation manufactures push out windows for the school bus industry. I look forward to your response. WGF/cih myers.ltr |
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ID: nht89-1.77OpenTYPE: INTERPRETATION-NHTSA DATE: 04/20/89 FROM: HENRY J. NOWAK -- CONGRESS TO: JOHN STONER -- CONGRESSIONAL RELATIONS OFFICER DEPARTMENT OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/27/89 FROM STEPHEN P. WOOD -- NHTSA TO HENRY J. NOWAK -- CONGRESS; REDBOOK A33; PART 571; LETTER DATED 04/14/89 FROM EUGENIA M. PIERAKOS AND JAMES L. PIERAKOS -- SNOWFIGHTING EQUIPMENT AND CONSULTING OF BUFFALO INC; SPECIFICATIONS DATED 03/01/89 EST, FROM JAEGER INDUSTRIES INC, JAEGER PL SERIES, TYPICAL BODY SPECIFICATIONS; SPECIFICATIONS DATED 01/06/89 FROM JAEGER CANADA EQUIPMENT LIMITED; PURCHASE SPECIFICATIONS DRAFT PL SERIES POWER LOADING CURBSIDE AND DRAFT PIC KUP OF SOURCE SEPARATED RECYCLABLE MATERIALS; CHASSIS; CAB; BODY TEXT: Dear Mr. Stoner: Enclosed is a self-explanatory letter from a constituent concerning a Canadian firm's difficulties in obtaining the federal regulations which certain imported equipment must meet. I would appreciate it if you reviewed the enclosed material and provided the needed technical information. Your timely consideration of this matter is greatly appreciated. With best wishes and kindest regards, Sincerely, |
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ID: nht94-7.6OpenDATE: April 4, 1994 FROM: William G. Franz -- Vice President, Fabrication, Wells Aluminum TO: Walter Myers -- NHTSA TITLE: Federal Motor Vehicle Safety Standard No. 217 ATTACHMT: Attached to letter dated 8/5/94 from John Womack to William G. Franz (Std. 217) TEXT: Dear Mr. Myers: Subsequent to our recent phone conversation, I am formally requesting an interpretation of paragraph S.5.1.2 regarding the window opening size. Specifically, my question is as follows: Does the 8 inch window opening size apply to the total outside frame dimension or does it apply to each pane of glass? The enclosed picture shows a typical retention test being performed on a push out window with two separately framed pieces of glass. In other words, would a pane of glass which measures less than 8 inches across need to be subject to the retention test? For your information, Wells Aluminum Corporation manufactures push out windows for the school bus industry. I look forward to your response. WGF/cih myers.ltr |
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ID: nht74-3.10OpenDATE: 01/08/74 FROM: RICHARD B. DYSON -- NHTSA ASSISTANT CHIEF COUNSEL TO: DARROLL P. YOUNG -- PRESIDENT YOUNG'S MACHINE CO. MONTICELLO, UTAH 84535 TITLE: N40-30 (TWH) ATTACHMT: LETTER DATED 12/26/73 FROM DARRELL P. YOUNG -- PRESIDENT YOUNG'S MACHINE COMPANY TO THE OFFICE OF CHIEF COUNSEL NHTSA U.S. DEPARTMENT OF TRANSPORTATION TEXT: Dear Mr. Young: In place of the two standards which you requested in your letter of December 26, 1973, I am providing the following discussion of what vehicles qualify as "motor vehicles" subject to our regulations. If your vehicles are not "motor vehicles" under this definition, they are not required to conform to Standards 105a and 121. Section 102(3) of the Act defines motor vehicle as: any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. Thus, a motor vehicle is a vehicle which the manufacturer expects will use public highways as part of its intended function. Tracked and other vehicles incapable of highway travel are not motor vehicles. Agricultural equipment is another non-motor vehicle category, because Congress clearly did not intend to include them in its coverage. In addition, vehicles intended and sold solely for off-road use (e.g. aircraft runway vehicles and underground mining vehicles) are not considered vehicles even if operationally capable of highway travel. They would, however, be considered motor vehicles if the manufacturer knew that a substantial proportion of his customers actually would use them on the highway. Just as clearly, vehicles which use the highway on a necessary and recurring basis to move between work sites are motor vehicles. The primary function of some vehicles is of a mobile, work-performing nature and as such their manufacturer contemplates a primary use of the highway. Mobile cranes, mobile drill rigs, and towed equipment such as brush chippers and pull-type street sweepers are examples in this area. Even if the equipment uses highways infrequently, it is considered a motor vehicle on the same basis as is a "mobile structure trailer" which is often towed only once from the factory to the home site. All these motor vehicles qualify as trucks or trailers. As such they are subject to several of the motor vehicle safety standards, and their manufacturer must comply with other regulations in Chapter V of Title 49, Code of Federal Regulations. There are some vehicles which are excepted from the motor vehicle classification despite their use of the highway. Highway maintenance and construction equipment such as lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles. From these guidelines you should be able to determine whether your equipment qualifies as a motor vehicle, and if so, as a truck or a trailer. Please write again if you are unable to make this determination. I have enclosed an information sheet that advises you how to obtain an up-to-date copy of the regulations which apply to motor vehicles and their manufacturers. ENCLOSURE Yours truly, |
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ID: nht94-6.2OpenDATE: May 5, 1994 FROM: J. L. Steffy -- Triumph Designs Ltd. TO: Taylor Vinson -- Office of Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 5/31/94 From John Womack To J.L. Steffy (A42; Std. 108) TEXT: Dear Taylor An additional concern for another unit with respect to FMVSS 108: This is a self contained seal unit that would allow for symetric design & lighting. It comprises a headlight with high and low beams and 2 symetrically flanking front auxillary lamps possessing low beam that augment the headlight. Can you please comment on this as it affects our immediately plans for U.S. importation. Thank you for your assistance |
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ID: nht93-9.16OpenDATE: December 15, 1993 EST FROM: Robert Matulich TO: Office of Chief Council, NHTSA TITLE: None ATTACHMT: Attached to letter dated 4/7/94 from John Womack to Robert Matulich (A42; Std. 111) TEXT: Per my phone conversation with Kevin Carvey and Richard Vanirerstine on 12-7-93, I was instructed to contact your office. The enclosed material explains clearly how my patent works. I wish some feedback from your office, hopefully positive, as I am in the marketing stage, as to any advice you have concerning my product and how it relate to federal safety standards. At present, I do know 98% of vehicle mirrors exceed the federal standard for mirror area. Thus I am not inquiring as to the legality of the mirror area lost to the adhesion area of my product. I have given this matter much thought, hopefully you can help me further.
ATTACHMENT (Drawing and text 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.