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: nht78-4.2OpenDATE: 01/13/78 FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA TO: State Farm Insurance Companies TITLE: FMVSR INTERPRETATION TEXT: This is to confirm your telephone conversation of December 1, 1977, with Kathy DeMeter of my staff. The question you raised was whether odometer disclosure statements have to be executed under section 580.4 and retained under section 580.7 of title 49, Code of Federal Regulations when the vehicle involved is a salvage vehicle. If the vehicle is repairable and will subsequently be used as a motor vehicle, disclosure would have to be made. Likewise, the disclosure statements would have to be maintained if section 580.7 is adopted as a final rule. However, if the vehicle is so badly damaged that it cannot be returned to the road, it will have ceased to be a motor vehicle for purposes of the regulations. Disclosure would therefore not be required. |
|
ID: nht95-4.73OpenTYPE: INTERPRETATION-NHTSA DATE: November 13, 1995 FROM: David T. Zelis -- Marketing Manager, Buyers Products Company TO: Office Of Chief Counsel -- NHTSA TITLE: NONE ATTACHMT: 12/22/95 letter from Samuel J. Dubbin to David T. Zelis (A43; Part 581) TEXT: Enclosed please find a copy of literature describing a new product from our company. The Pintle Mount Bumper basically is designed to take the place of a vehicle bumper and the receiver tube assembly on a light duty truck. Would you please send a copy of NHTSA standards that may apply to the use or manufacture of this product. Please feel free to contact me with any questions, at (216) 974-8888. Thank you for your assistance. (Literature omitted.) |
|
ID: nht95-7.36OpenTYPE: INTERPRETATION-NHTSA DATE: November 13, 1995 FROM: David T. Zelis -- Marketing Manager, Buyers Products Company TO: Office Of Chief Counsel -- NHTSA TITLE: NONE ATTACHMT: 12/22/95 letter from Samuel J. Dubbin to David T. Zelis (A43; Part 581) TEXT: Enclosed please find a copy of literature describing a new product from our company. The Pintle Mount Bumper basically is designed to take the place of a vehicle bumper and the receiver tube assembly on a light duty truck. Would you please send a copy of NHTSA standards that may apply to the use or manufacture of this product. Please feel free to contact me with any questions, at (216) 974-8888. Thank you for your assistance. (Literature omitted.) |
|
ID: nht69-1.21OpenDATE: 08/29/69 FROM: WARREN M. HEATH -- COMMANDER ENGINEERING SECTION CALIFORNIA HIGHWAY PATROL TO: ROBERT BRENNER -- ACTING DIRECTOR NATIONAL HIGHWAY SAFETY BUREAU COPYEE: GAIL STRADER -- SAFETY SERVICES DIV. DEPT. REV. TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 08/29/69 FROM CHARLES A. BAKER -- NHTSA TO WARREN M. HEATH TEXT: Dear Dr. Brenner: A vehicle manufacturer has notified us that their 1970 model vehicles will be equipped so that the sidemarker lamps will flash when the turn signal switch is activated. The flashing will occur on the side contemplated for the turn. An interpretation is requested as to whether or not Section S3.5 of Federal Motor Vehicle Safety Standard No. 108 would permit the flashing of sidemarker lamps simultaneous with the turn signal lamps on the side to which a turn is contemplated. Very truly yours, |
|
ID: nht73-2.50OpenDATE: 12/03/73 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Car Credit Corporation TITLE: FMVSR INTERPRETATION TEXT: The National Highway Traffic Safety Administration has received a complaint from Mr.(Illegible Words) of South Forest Street, Chicago, Illinois, that a 1967 Chrysier may have been sold to him with an altered odometer and an incomplete odometer disclosure statement. This agency administers the Motor Vehicle Information and Cost Savings(Illegible Word) which(Illegible Word) the alteration, disconnection, or resetting of customers are requires a transferer to make a mileage Requirements. Copies of the law and regulations are enclosed. Under the law(Illegible Words) may have a civil action for damages of $ 1.500 or more and attorney's fees. The U. S. Attorney General is authorized to seek injunctive relief against persons who violate the Act. If we received continued Modification of(Illegible Words) by the Car Credit Corporation, we will ask the U. S. Attorney to investigate the matter and to take appropriate action. ENC. |
|
ID: nht88-2.87OpenTYPE: INTERPRETATION-NHTSA DATE: AUGUST 4, 1988 FROM: TAYLOR HONG -- PRESIDENT, FAIR SUN INDUSTRIAL CO., LTD., TAIPEI, TAIWAN TO: U.S. DEPARTMENT OF TRANSPORTATION, NHTSA TITLE: TURN SIGNAL FLASHERS FOR FOR "DOT" APPROVAL ATTACHMT: Attached to letter dated September 13, 1989 to Taylor Hong, Fair Sun Industrial Co., Ltd. from Stephen P. Wood, NHTSA; [Redbook A34; Std. 108] TEXT: We are a manufacturer of above said items and are planning to sell this item to U. S. A. Market. To determine compliance of our Flashers with Federal Motor Vehicle Safety Standard No. 108 and to get an "DOT" approval, we would ask for your help the foll ows: 1). How we get an "DOT" approval? 2). Should ask for an application forms from you and send one lot of samples for your test? Or 3). We may send samples to any other Laboratory and get an approval? We appreciate your kind reply to our this letter. Thank you and we are Sincerely yours, |
|
ID: nht95-5.36OpenTYPE: INTERPRETATION-NHTSA DATE: JULY 25, 1995 FROM: Robert J. Ponticelli -- President, American International TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO 9/19/95 LETTER FROM JOHN WOMACK TO ROBERT J. PONTICELLI (A43; REDBOOK 2; STD. 114) TEXT: Dear Mr. Womack, I would like to request an opinion on the regulations concerning an aftermarket anti-theft device. This device is installed between the steering wheel and the steering shaft. When a key swich is activated the steering wheel is disengaged and becomes freewheeling, preventing the vehicle from being driven. I am requesting an interpretation of federal regulations to identify any restrictions or conditions which apply to this device when installed on a motor vehicle. Please distinguish which, if any, would apply to a regulated party such as a new car dealer and to aftermarket service businesses. Thank you for your time and assistance with this matter, any information you could provide would be greatly appreciated. If you have any questions concerning this device I can be reached at (800) 336-6500 ext. 528 |
|
ID: nht88-3.74OpenTYPE: INTERPRETATION-NHTSA DATE: 10/19/88 FROM: JIM BATES -- MEMBER OF CONGRESS TO: DIANE K. STEED -- ADMINISTRATOR U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 01/23/89 FROM DIANE K. STEED -- NHTSA TO JIM BATES -- CONGRESS, REDBOOK A33, STANDARD 108 TEXT: Dear Ms. Steed: I was recently contacted by a constituent, Angelo R. Collica, regarding a plan he has developed for a lighting safety device which is not currently authorized for motor vehicles. Essentially, this device will promote driving safety, relieve lane changing tensions and create a more relaxed atmosphere on the highways. I would appreciate your providing me with information as to the requirements necessary to install lighting devices on motor vehicles. Should you have any questions or require additional information, please feel free to contact Alice Lara of my district office at (619) 691-1166. Thank you for your assistance. Please respond to me at 430 Davidson Street, Suite A, Chula Vista, California 92010. Sincerely, |
|
ID: nht93-4.23OpenDATE: June 4, 1993 FROM: Margaret W. Mouzon -- Mouzon Information Services TO: Mary Versailles -- Office of the General Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 7/21/93 from John Womack to Margaret W. Mouzon (A41; Std. 208; VSA 108(b)(1)), 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 (Std. 208) TEXT: Could you please describe and provide and interpretation of any federal regulations regarding dealer responsibility for occupant restraint system installations? For example, if a new or used car dealer sells a used car with an occupant restraint system which has been rendered inoperable, for example, a deployed airbag, does the dealer have to restore the restraint system to its original condition before delivering the vehicle to the purchaser? What if the dealer is selling the showroom model or demonstration model of an otherwise "new" vehicle, does the occupant restraint system have to be operable? I would much appreciate a response to these questions. Thank you very much for your assistance. |
|
ID: steffyOpen Mr. J. L. Steffy Dear Mr. Steffy: This responds to your FAX of May 5, 1994, to Taylor Vinson of this Office, requesting an interpretation of Motor Vehicle Safety Standard No. 108. You enclose a motorcycle headlamp design that "contains asymmetrical shaped lenses." The headlamp itself is a symmetrical unit mounted on the motorcycle's vertical centerline. It is your interpretation that this lamp is permitted under Standard No. 108 "as long as we do not create an asymmetric lighting arrangement physically where dipped beam is on one side only and main beam on one side only." I enclose a copy of a recent interpretation to Kawasaki Motors Corp. U.S.A. with respect to a headlamp similar to yours. If this does not answer your question, we shall be pleased to consider the matter further. Sincerely,
John Womack Acting Chief Counsel Enclosure ref:108 d:6/28/94
|
1994 |
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.