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: nht92-2.2OpenDATE: 11/26/92 FROM: NILTON MELLO -- VITROTEC - VIDROS DE SEGURANCA LTDA TO: KATHLEEN DEMETER -- ASSISTANT CHIEF COUNSEL FOR GENERAL LAW, NHTSA COPYEE: I.A.T. TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 2-17-93 FROM JOHN WOMACK TO NILTON MELLO (A40; STD. 205) TEXT: We have received your letter dated November 13, 1992 that confirm our agent I.A.T. and conforms to your procedural requirements. We have also received on November 25th., 1992 our D.O.T. number (515). We need to know if with these (DOT 515), we are able to export our laminated windshields and others 1for motor vehicles, or if it is needed by law that we perform tests at the one of the American Laboratoryes, and then clear the process of requirements to export. We would appreciate a swift answer. Since now we appreciate your help. |
|
ID: RUSHFORD.RBMOpen Ms. Lisa Rushford Dear Ms. Rushford: This is to acknowledge your letter concerning the problems with air bags. Please be assured that your comments and concerns will be taken into consideration as the agency develops a solution to these problems. Enclosed is a list of Questions and Answers regarding air bags that I hope will be helpful to you. Sincerely, John Womack Acting Chief Counsel Enclosure cc: The Honorable Charles W. Stenholm ref:208 d:11/27/96 |
1996 |
ID: nht88-3.6OpenTYPE: INTERPRETATION-NHTSA DATE: 08/15/88 FROM: LEBOEUF LAMB LEIBY AND MACRAE TO: KATHLEEN DEMETER -- ASSISTANT CHIEF COUNSEL FOR GENERAL LAW NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: PORSCHE'S JUNE 28 REQUEST FOR REGULATORY INTERPRETATION FMVSS 101 AND 102 ATTACHMT: ATTACHED TO LETTER DATED 04/03/89 FROM ERIKA Z. JONES -- NHTSA TO KARL H. MAYER, REDBOOK A33 (4), STANDARD 101, STANDARD 102; CONFIDENTIAL LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES, REQUEST FOR INTERPRETATION -- CLARIFICATION F MVSS 101 AND FMVSS 102; LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES -- NHTSA, REQUEST FOR CONFIDENTIAL TREATMENT TEXT: Dear Ms. DeMeter: I write to confirm our conversation of August 15 concerning Porsche's June 28, 1988 request for a regulatory interpretation of FMVSS 101 and 102. We ask that the June 28 request and the attachments to that request remain confidential until September 30, 1988, at which time this information may be made public. I understand from our conversation with NHTSA will honor our request to keep the information confidential until September 30. If my understanding is not accurate, please let me know. Thank you for your cooperation. Yours truly, |
|
ID: nht75-2.39OpenDATE: 05/30/75 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Stanley Electric Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This responds to your letter of May 15, 1975, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 108 requirements for Type 1A and 2A automotive headlamps. The following answers are provided for your specific questions 1. FMVSS No. 108 would not prohibit use of metal-back Types 1A and 2A headlamps that conform to all requirements of the standard. 2. The National Highway Traffic Safety Administration does not issue approvals on automotive equipment. The equipment manufacturer self certifies that the equipment conforms to the applicable FMVSS. The various states may, however, require equipment approval. Information on these approvals may be obtained from the American Association of Motor Vehicle Administrators, 1201 Connecticut Avenue, Washington, D. C. 20036. 3. The drawings of the Type 1A and 2A headlamp submitted with your letter, indicate that aiming pads have been deleted. Aiming pads are required by FMVSS No. 108. For your information enclosed is a copy of FMVSS No. 108, which includes requirements for Types 1A and 2A headlamps, and a copy of Docket No. 75-8 Notice 1, that proposes to allow use of the four-lamp rectangular systems indefinitely. |
|
ID: nht89-1.33OpenTYPE: INTERPRETATION-NHTSA DATE: 03/08/89 FROM: PATRICIA KLINGER WATHEN -- SPECIAL ASSISTANT TO THE DIRECTOR OFFICE OF CONGRESSIONAL AFFIARS DEPARTMENT OF TRANSPORTATION TO: HARRY REID -- UNITED STATES SENATE TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 05/25/89 FROM STEPHEN P. WOOD -- NHTSA TO HARRY REID -- SENATE; REDBOOK A33 [4]; VSA 108 [A] [2] [A]; STANDARD 208; LETTER DATED 02/23/89 FROM HARRY REID -- SENATE TO DOT; LETTER DATED 02/03/89 FROM STEVEN P. ELLIOTT TO HARRY REID -- SENATE, RE AUTHORIZATION TO DISCONNECT AUTOMOBILE AIR BAGS; REPORT FROM DAVID J. ROMEO AND JOHN B. MORRIS, DRIVER AIR BAG POLICE FLEET DEMONSTRATION PROGRAM A 24 MONTH PROGRESS REPORT AT EXPERIMENTAL SAFETY VEHICLE CONFERENCE OXFORD, ENGLA ND, JULY 1-5, 1985; RESEARCH NOTES ON CRASH EXPERIENCE OF GOVERNMENT SPONSORED AIR BAG VEHICLES THROUGH 03/31/89, FROM VERNON ROBERTS TEXT: Dear Senator Reid: Thank you for your letter forwarding correspondence from your constituent, Mr. Steven P. Elliott. I have transmitted your inquiry to the appropriate Departmental officials who are familiar with this matter and they will respond to you directly. I appreciate your contacting me and hope you will not hesitate to call if I can be of any further assistance. Sincerely, |
|
ID: nht95-6.11OpenTYPE: INTERPRETATION-NHTSA DATE: August 11, 1995 FROM: Yoshiaki Matsui -- Manager, Automotive Equipment, Legal And Homologation Section, Stanley Electric Co., Ltd. TO: Chief Counsel -- NHTSA TITLE: Headlamp system containing fog lamp ATTACHMT: ATTACHED TO 9/20/95 LETTER FROM JOHN WOMACK TO YOSHIAKI MATSUI (A43; REDBOOK 2; STD. 108) TEXT: We are planning to develop headlamp systems that produce high beam, low beam and fog lamp beam. The fog lamp is reciprocally incorporated with the high beam headlamp, using one dual-filament bulb (ex.; HB2). The high beam and the fog lamp will not be lit simultaniously. Please refer to the attached drawing for the possible operating conditions. The FMVSS No. 108 specifies no requirement for fog lamp, except that the lamp shall not impair the effectiveness of lighting equipment required by the Standard. (S5.1.3) And we believe such a combination we are planning will not impair the effectiveness of the headlamp. We would like to ask you to give your advice whether such a combination of fog lamp and high beam can be accepted under the FMVSS No. 108. Your answer will be highly appreciated. (Drawing omitted.) |
|
ID: nht95-3.88OpenTYPE: INTERPRETATION-NHTSA DATE: August 11, 1995 FROM: Yoshiaki Matsui -- Manager, Automotive Equipment, Legal And Homologation Section, Stanley Electric Co., Ltd. TO: Chief Counsel -- NHTSA TITLE: Headlamp system containing fog lamp ATTACHMT: ATTACHED TO 9/20/95 LETTER FROM JOHN WOMACK TO YOSHIAKI MATSUI (A43; REDBOOK 2; STD. 108) TEXT: We are planning to develop headlamp systems that produce high beam, low beam and fog lamp beam. The fog lamp is reciprocally incorporated with the high beam headlamp, using one dual-filament bulb (ex.; HB2). The high beam and the fog lamp will not be l it simultaniously. Please refer to the attached drawing for the possible operating conditions. The FMVSS No. 108 specifies no requirement for fog lamp, except that the lamp shall not impair the effectiveness of lighting equipment required by the Standard. (S5.1.3) And we believe such a combination we are planning will not impair the effectiveness of the headlamp. We would like to ask you to give your advice whether such a combination of fog lamp and high beam can be accepted under the FMVSS No. 108. Your answer will be highly appreciated. (Drawing omitted.) |
|
ID: nht72-6.25OpenDATE: 05/31/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Rhode Island Consumers' Council TITLE: FMVSS INTERPRETATION TEXT: We have received your letter of March 15, 1972, which was forwarded to us by the Federal Trade Commission, concerning problems experienced by Mr. Ronald Dandeneau regarding a repossessed vehicle he purchased which was equipped with tires marked "NA." Mr. Dandeneau claims he was told by a tire dealer that such tires are considered unserviceable, cannot be repaired, and are unsafe. The sale of these tires by the tire manufacturer (we understand that the practice is not limited to Uniroyal) is not prohibited by the National Traffic and Motor Vehicle Safety Act, and the Federal standard applicable to passenger car tires. The Federal standard applies only to tires before their first sale to a consumer, and does not apply to used tires such as these. We understand that tires marked "NA" are tires that have been adjusted previously, but for reasons that are not considered to affect the safety of the tire. Examples of such reasons are a lack of roundness and uniformity. While these conditions may produce riding qualities which some people find unsatisfactory, we presently have no evidence that such tires cannot be repaired or that they are unsafe. |
|
ID: 77-5.13OpenTYPE: INTERPRETATION-NHTSA DATE: 12/21/77 FROM: JOSEPH J. LEVIN CHIEF COUNSEL TO: JAMES TYDINGS -- THOMAS BUILT BUSES, INC. TITLE: NOA - 30 ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO R.C. ROST FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108; LETTER DATED 03/18/88 TO CHIEF COUNCIL -- NHTSA FROM R.C. ROST RE REQUEST THAT HEADSTART BUSES NOT BE REQUIRED TO HAVE ROOF WARNING LIGHTS IF A COLOR OTHER THAN SCHOOL BUS YELLOW IS USED, OCC-1763; LETTER DATED 02/11/88 TO SHANON L. FOND FROM JERRY SMITH RE FEDERAL INTERPRETATION OF SCHOOL BUS USER; LETTER DATED 02/25/88 TO SHARON FORD, FROM JERRY SMITH; UNDATED BROCHURES ON SCHOOL BUS BY WAYNE CORPORATION TEXT: Dear Mr. Tydings: This responds to your November 11, 1977, letter asking whether Head Start facilities are considered preprimary schools for purposes of applying the Federal school bus safety standards. The National Highway Traffic Safety Administration (NHTSA) has determined that these facilities are primarily involved with the education of preprimary school children. Thus, the buses used to transport children to and from the Head Start facilities are considered school buses under the National Traffic and Motor Vehicle Safety Act (as amended by the Motor Vehicle and School Bus Safety Amendments of 1974) and must meet all Federal school bus safety standards. Sincerely, |
|
ID: nht90-2.59OpenTYPE: INTERPRETATION-NHTSA DATE: 05/30/90 FROM: NANCY L. BRUCE -- DOT DIRECTOR, OFFICE OF CONGRESSIONAL AFFAIRS TO: J. SMITH -- HOUSE OF REPRESENTATIVES TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/25/90, FROM PAUL JACKSON RICE -- NHTSA TO LAWRENCE J. SMITH -- CONGRESS; A35, VSA 108 [A] [2] [A]; STANDARD 205; LETTER DATED 05/25/90 FROM LAWRENCE J. SMITH -- CONGRESS TO NANCY BRUCE -- DOT; NEWSPAPER ARTICLE; UNDA TED BY UPI; US SUES 4 AUTO TINTING SHOPS; OCC 4842; NEWSPAPER ARTICLE DATED 03/30/90; BY STEVE MOORE -- BUSINESS MARKETS; LOCAL CRAFTSMAN UNSWAYED BY FEDERAL CIVIL LAWSUITS; NEWSPAPER ARTICLE DATED 03/29/90 BY BRUCE VIELMETTI -- ST PETERSBURG TIMES; US C RACKS DOWN ON WINDOW TINTERS; NEWSPAPER ARTICLE DATED 03/29/90 FROM JIM LEUSNER -- ORLANDO SENTINEL; US SUES CAR-WINDOW TINTERS - LET THERE BE MORE LIGHT; 1984 FLORIDA AUTO TINT LAW; PRESS RELEASE DATED 03/28/90 BY UNITED STATES ATTORNEY MIDDLE DISTRICT OF FLORIDA TEXT: Thank you for your letter forwarding correspondence from your constituent, Mr. Joel Leitson. I have transmitted your inquiry to the appropriate Departmental officials who are familiar with this matter and they will respond to you directly. I appreciate your contacting me and hope you will not hesitate to call if I can be of any further assistance. Sincerely, |
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.