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: nht93-9.5OpenDATE: December 7, 1993 FROM: Dennis Platt -- Supervisor, Vehicle Safety & Equipment Section, State of Utah, Department of Public Safety, Utah Highway Patrol TO: Office of the Chief Counsel -- NHTSA TITLE: Air bag installation ATTACHMT: Attached to letter dated 12/30/93 from John Womack to Dennis Platt (A42; Std. 208), letter dated 3/4/93 from John Womack to Robert A. Ernst, and letter dated 1/19/90 from Stephen P. Wood to Linda L. Conrad TEXT: During a recent telephone conversation with a N.H.T.S.A officer, I was informed that no current federal requirement exists for air bag re-installation following a deployment. The Utah Highway Patrol would appreciate a formal opinion or a copy of an opinion rendered to another state on this issue. Your prompt attention to this request is appreciated. |
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ID: nht92-7.39OpenDATE: April 16, 1992 FROM: Neil Friedkin -- Attorney at Law TO: Marvin Shaw -- NHTSA, U.S. DOT TITLE: None ATTACHMT: Attached to letter dated 6/15/92 from Paul J. Rice to Neil Friedkin (A39; Std. 108; Std. 208; Std. 216); Also attached to letter dated 4/13/92 from Paul Jackson Rice to Neil Friedkin TEXT: Enclosed is a copy of the letter provided to me by Paul Jackson Rice on April 13, 1992. I would appreciate your providing me with the applicable 1986 standard for convertible passenger cars, if possible. Once again, thank you for your courtesy and cooperation. Attachment NHTSA interpretation letter dated 4/13/92 from Paul J. Rice to Neil Friedkin. (Text omitted here.) |
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ID: nht89-2.3OpenTYPE: INTERPRETATION-NHTSA DATE: 06/15/89 FROM: JOHN E. HAMMER -- JOHN E. HAMMER AND ASSOCIATES TO: KATHLEEN C. DEMETER -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 10/6/89 FROM STEPHEN P. WOOD -- NHTSA TO JOHN E. HAMMER -- JOHN E. HAMMER AND ASSOCIATES; REDBOOK A34, VSA 102, 108 TEXT: Dear Madam: This is an inquiry regarding the legality of an owner rigidly attaching a hood ornament onto a motor vehicle to prevent theft of the ornament by vandals. Mr. Zachary Fraser, Motor Vehicle Safety Administration, suggested an opinion from your office might be helpful. This is a never-ending problem with the Dodge truck Ramhead ornament and we would like to provide an "after market" kit to solve the problem. Sincerely, |
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ID: nht93-5.41OpenTYPE: Interpretation-NHTSA DATE: July 30, 1993 FROM: C.N. (Norm) Littler -- Coordinator - Regulatory Affairs, Motor Coach Industries/TMC TO: Mary Versailles -- Office of Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated January 10, 1994 from John Womack to C.N. Littler (A42; Part 571.7) TEXT: Pursuant to our telecon, I have attached to following materials for your review. - AMF's paid advertisement - National Bus Trader Article - Copy of Cert. of Origin - Copy of Cert. of Title Your comments and opinions relating to MCI's legal recourse with respect to AMF's claims and practices would be greatly appreciated. As stated, we do not feel that a remanufactured MCI Coach should be claimed as new. Thank you.
(Attachments omitted) |
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ID: nht93-5.46OpenTYPE: Interpretation-NHTSA DATE: August 4, 1993 FROM: Toshi Tanaka -- General Manager, Sales & Marketing Dept., Sensor Technology Co., Ltd. TO: Delmas Johnson -- FARS Program Manager, Office of Crashworthiness Research, Research and Development, NHTSA TITLE: Ref. No. TSX-242 ATTACHMT: Attached to letter dated 11/5/93 from John Womack to Toshi Tanaka (A41; Std. 208) TEXT: Could you please let me know of the followings for our understanding on FMVSS 208? 1. Is it true that the belt fastening law now goes into a part of the federal law? 2. Is it true that the cars with airbag do not need to perform "Roll Over Test"? I am looking forward to receiving your repy by return.
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ID: nht91-2.8OpenDATE: March 4, 1991 FROM: John E. Calow -- Sr. Safety Engineer, Oshkosh Chassis Division TO: Chief Council, NHTSA COPYEE: Gary Schmiedel TITLE: None ATTACHMT: Attached to letter dated 5-8-91 from Paul Jackson Rice to John E. Calow (A37; Std. 105; Std. 108) TEXT: Oshkosh Chassis Division (OCD) is submitting this letter for a written interpretation of FMVSS 105 with regard to Parking Brake actuation times. It is OCD's understanding that there is no requirement for Parking Brake actuation times of hydraulic brake systems. This is based upon information attained from reference material 49 CFR 571.105. OCD would appreciate a written affirmation or denial of our understanding of Parking Brake actuation times. Thank you for your time. |
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ID: nht70-1.23OpenDATE: 03/04/70 FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA TO: Trelleborg Rubber Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your letter of February 4, 1970, to the National Highway Safety Bureau concerning the labeling requirements for motor vehicle tires manufactured prior to August 1, 1968. Federal Motor Vehicle Safety Standard No. 109 requires that all motor vehicle passenger car tires manufactured after January 1, 1968, conform to the requirements as cited. I have enclosed a copy of Standard No. 109 and No. 110 with amendments for your reference. Section 54.3 specifies the labeling requirements. You will note 54.3.1 permits the sale of tires manufactured during the period January 1, 1968, to August 1, 1968, which have a label or tag affixed that incorporates the specified information. Inclusion of information on the invoice does not relieve the manufacturer from affiding the proper labeling on each tire. |
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ID: nht73-5.29OpenDATE: 10/24/73 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Franklin J. Kivel TITLE: FMVSR INTERPRETATION TEXT: Your request for information on odometer laws was forwarded to us by the Office of Consumer Affairs. There is at this time no Federal law that requires odometers to be sealed. The Motor Vehicle Information and Cost Savings Act, which we administer, prohibits altering, resetting, or disconnecting odometers except for lawful repair. It does not, however, require sealed odometers and automobile manufacturers do not normally seal odometer units. Some manufacturers incoporate anti-tampering features which stain the odometer drum with ink or that destroy its gears if an attempt is made to reverse its direction. The Act does require disclosure of a vehicle's actual and recorded mileage by a seller before its transfer to a buyer. We are presently conducting a study of the Act's effectiveness. ENC. - REGULATION & ACT |
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ID: 77-2.39OpenTYPE: INTERPRETATION-NHTSA DATE: 05/20/77 FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA TO: Noah Stone TITLE: FMVSR INTERPRETATION TEXT: This letter is to confirm a telephone conversation you had with Kathy DeMeter of this office on May 17, 1977. You asked whether the Federal odometer mileage disclosure statement, required to be executed by 49 CFR Part 580, needed to be a separate piece of paper. The answer is "no." The regulation does not require the disclosure to be separate from other documents. If the full information required by section 580.4 can be included, a disclosure on the bill of sale or other document would satisfy the requirements. The only limitation is that it would have to be executed prior to the completion of the sale as required by section 580.4(a) of the regulation. If you have any further questions, please do not hesitate to write. |
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ID: nht94-1.66OpenTYPE: INTERPRETATION-NHTSA DATE: February 22, 1994 FROM: Blair Abraham -- Biomedical Manager, Mersco Medical TO: Public Affairs Office, NHTSA TITLE: NONE ATTACHMT: Attached to letter dated 6/30/94 from John Womack to Blair Abraham (A42; Part 567) TEXT: I am looking for the steps to take to certify a vehicle for a higher weight rating than what is issued by the manufacturer. We modified the suspension to enable the vehicle to handle an additional 1000 pounds. The GVWR is stamped at 5600 pounds. With our new suspension kit, we would like to certify the vehicle for 6600 pounds. If we cannot increase the GVWR, are we liable for non-compliance of a DOT regulation if we exceed the GVWR? Please send me the information required for increasing the GVWR and coded regulation of compliance. |
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.