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: nht95-6.2OpenTYPE: INTERPRETATION-NHTSA DATE: August 7, 1995 FROM: Karey Clock -- Moriden America, Inc. TO: John Womack TITLE: NONE ATTACHMT: ATTACHED TO 9/25/95 LETTER FROM JOHN WOMACK TO KAREY CLOCK (A43; REDBOOK 2; STD. 302) TEXT: Dear Mr. Womack: I need to obtain some clarification regarding the FMVSS302 Flammability specification. The specification states the following information: A specimen that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals. A device that may be used for supporting this type of material is an addition U-shaped frame, wider that the U-shaped frame containing the specimen, spanned by 10-mil wires of heat resistant composition at 1-inch intervals, inserted over the bottom U-shaped frame. What material does the above mentioned statement pertain to. Currently, Moriden America is testing the following types of materials and need to determine if it is acceptable to use wires during the test: * Flat Woven * Double Raschel * Tricot * Moquette All of these materials also are laminated by two types of foam backings, CK scrim and 780 Dow Film. The material's thickness varies from 0mm to 8mm. I would appreciate if you could determine if the material should be tested with wires. If you have any questions, please call. |
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ID: nht95-3.78OpenTYPE: INTERPRETATION-NHTSA DATE: August 7, 1995 FROM: Karey Clock -- Moriden America, Inc. TO: John Womack TITLE: NONE ATTACHMT: ATTACHED TO 9/25/95 LETTER FROM JOHN WOMACK TO KAREY CLOCK (A43; REDBOOK 2; STD. 302) TEXT: Dear Mr. Womack: I need to obtain some clarification regarding the FMVSS302 Flammability specification. The specification states the following information: A specimen that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals. A device that may be used for supporting this type of material is an addition U-shaped frame, wider that the U-shaped frame containing the specimen, spanned by 10-mil wires of heat resistant composition at 1-inch intervals, inserted over the bottom U-shaped frame. What material does the above mentioned statement pertain to. Currently, Moriden America is testing the following types of materials and need to determine if it is acceptable to use wires during the test: * Flat Woven * Double Raschel * Tricot * Moquette All of these materials also are laminated by two types of foam backings, CK scrim and 780 Dow Film. The material's thickness varies from 0mm to 8mm. I would appreciate if you could determine if the material should be tested with wires. If you have any questions, please call. |
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ID: nht95-5.56OpenDATE: August 7, 1995 FROM: Karey Clock -- Moriden America, Inc. TO: John Womack TITLE: NONE ATTACHMT: ATTACHED TO 9/25/95 LETTER FROM JOHN WOMACK TO KAREY CLOCK (A43; REDBOOK 2; STD. 302) TEXT: Dear Mr. Womack: I need to obtain some clarification regarding the FMVSS302 Flammability specification. The specification states the following information: A specimen that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals. A device that may be used for supporting this type of material is an addition U-shaped frame, wider that the U-shaped frame containing the specimen, spanned by 10-mil wires of heat resistant composition at 1-inch intervals, inserted over the bottom U-shaped frame. What material does the above mentioned statement pertain to. Currently, Moriden America is testing the following types of materials and need to determine if it is acceptable to use wires during the test: * Flat Woven * Double Raschel * Tricot * Moquette All of these materials also are laminated by two types of foam backings, CK scrim and 780 Dow Film. The material's thickness varies from 0mm to 8mm. I would appreciate if you could determine if the material should be tested with wires. If you have any questions, please call.
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ID: nht94-5.29OpenDATE: May 16, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Fred Carr -- Engineer, Utilimaster TITLE: None ATTACHMT: Attached To Letter Dated 4/21/94 From Fred Carr To John Womack (OCC-9912) TEXT: Dear Mr. Carr: This responds to your question asking whether Federal Motor Vehicle Safety Standard No. 211, Wheel nuts, wheel discs, and hub caps, applies to "motor vehicle equipment relating to light duty, medium duty, and heavy duty trucks or truck manufacturers." As explained below, Standard No. 211 does not apply to trucks, or truck equipment. S2. Application of Standard No. 211 states the following: This standard applies to passenger cars, multipurpose passenger vehicles, and passenger car and multipurpose passenger vehicle equipment. "Multipurpose passenger vehicle" is defined at 49 CFR @ 571.3 as a motor vehicle designed to carry 10 persons or less, which is constructed either on a truck chassis or with special features for occasional off-road operation. Since Standard No. 211 applies only to passenger cars, multipurpose passenger vehicles, and their equipment, Standard No. 211 does not apply to trucks, or truck equipment. "Truck" is defined at 49 CFR @ 571.3 as a motor vehicle designed primarily for the transportation of property or special purpose equipment. Accordingly, manufacturers of trucks or truck equipment are not required to certify their trucks and truck equipment to the requirements of Standard No. 211. I hope this information is helpful. If there are any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, |
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ID: nht92-8.27OpenDATE: March 13, 1992 FROM: Wally Herger -- Member of Congress, U.S. House of Representatives TO: Nancy Bruce -- Director of Congressional Affairs, DOT TITLE: None ATTACHMT: Attached to letter dated 2/28/92 from Bill Gaines to Wally Herger; Also attached to letter dated 4/27/92 from Frederick H. Grubbe to Wally Herger (A39; Std. 301) TEXT: I am writing on behalf of Mr. Bill Gaines of Transfer Flow, Inc., who has requested my assistance regarding difficulties with the Department of Transportation. Transfer Flow, Inc. is a manufacturer of fuel tanks and fuel systems. The company's problem stems from the rigid requirements of the Federal Motor Vehicle Safety Standard No. 301-75. It is my understanding that current technology has made it possible to meet required safety standards by utilizing less expensive testing procedures than the FMVSS 301 test, and that less stringent testing is permitted for vehicles over 10,000 GVW and vehicles under 10,000 GVW that have been sold to the end user. If that is indeed the case, then I would very much appreciate your thorough review of the problem faced by Transfer Flow, Inc. Further, I would like to know if it is possible to administratively update these requirements. I have enclosed a copy of Mr. Gaines letter and related documentation for your information and review. If you require further information, please contact my office or Mr. Gaines directly. I have assigned this case to my staff assistant, Dave Meurer. He can be reached at (916) 893-8363 or at the address checked above. I appreciate your consideration of this matter. |
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ID: nht94-2.86OpenTYPE: INTERPRETATION-NHTSA DATE: May 16, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Fred Carr -- Engineer, Utilimaster TITLE: None ATTACHMT: Attached To Letter Dated 4/21/94 From Fred Carr To John Womack (OCC-9912) TEXT: Dear Mr. Carr: This responds to your question asking whether Federal Motor Vehicle Safety Standard No. 211, Wheel nuts, wheel discs, and hub caps, applies to "motor vehicle equipment relating to light duty, medium duty, and heavy duty trucks or truck manufacturers." As explained below, Standard No. 211 does not apply to trucks, or truck equipment. S2. Application of Standard No. 211 states the following: This standard applies to passenger cars, multipurpose passenger vehicles, and passenger car and multipurpose passenger vehicle equipment. "Multipurpose passenger vehicle" is defined at 49 CFR @ 571.3 as a motor vehicle designed to carry 10 persons or less, which is constructed either on a truck chassis or with special features for occasional off-road operation. Since Standard No. 211 appl ies only to passenger cars, multipurpose passenger vehicles, and their equipment, Standard No. 211 does not apply to trucks, or truck equipment. "Truck" is defined at 49 CFR @ 571.3 as a motor vehicle designed primarily for the transportation of propert y or special purpose equipment. Accordingly, manufacturers of trucks or truck equipment are not required to certify their trucks and truck equipment to the requirements of Standard No. 211. I hope this information is helpful. If there are any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, |
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ID: 07-002890drn-2OpenMr. Bruce Blocksom VMI Chief Compliance Officer Vantage Mobility International 5202 South 28th Place Phoenix, AZ 85040 Dear Mr. Blocksom: This responds to your request for clarification as to the appropriate time to remove the Monroney label from the OEM manufactured van. You provided a specific vehicle processing sequence. The labels you ask about are required by the Automobile Information Disclosure Act, which is commonly known as the Monroney Act or Price Sticker Act. Please be advised that although the National Highway Traffic Safety Administration (NHTSA) is responsible for New Car Assessment Program (NCAP) safety rating information (also known as Stars on Cars) on the Monroney label, the U.S. Department of Justice (DOJ), rather than NHTSA, generally administers and enforces the Monroney Act. Since we do not administer the Monroney Act with respect to the issue you ask about, we cannot provide an authoritative interpretation. I am enclosing a page titled Automobile Information Disclosure Act from the DOJs website, which provides information that you may find helpful. I note that the page states, among other things, that The Act prohibits the sticker from being removed or altered prior to sale to a consumer. If you have further questions about how DOJ administers and enforces the Monroney Act, please write to: U.S. Department of Justice Civil Division 950 Pennsylvania Avenue, NW Washington, DC 20530-0001 If you have questions about NHTSAs requirements, please feel free to contact Ms. Dorothy Nakama of my staff by telephone at (202) 366-2992 Sincerely yours, Anthony M. Cooke Chief Counsel Enclosure ref:575 d.8/30/07 |
2007 |
ID: nht93-7.37OpenDATE: October 22, 1993 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Thomas G. Cehelnik -- Ph.D., Accutron T.C.S., Inc. TITLE: None ATTACHMT: Attached to letter dated 1/25/80 from Stephen P. Wood to Larry S. Snowhite (Std. 108) and letter dated 9/28/93 letter from Thomas G. Cehelnik to Office of Chief Council, NHTSA (OCC-9172) TEXT: We are replying to your letter of September 28, 1993, requesting information on Federal Motor Vehicle Safety Standard No. 108 (you will find the complete text of this standard at 49 CFR 571.108). Your company has developed "a light system to indicate the deceleration of the vehicle." You have been informed that this agency is "investigating the safety of such a device," and "that lights that indicate braking must be 'steady-burning.'" The agency is not investigating deceleration warning systems, thus I am unable to provide you with "information on the status of the safety investigation" as you requested. Paragraph S5.5.10 of Standard No. 108 applies to all lamps provided as original motor vehicle equipment, and lists the lamps that may flash, such as turn signal lamps, but this list does not include stop lamps. A final catchall subparagraph (d) requires that "(a)11 other lamps shall be wired to be steady-burning," and this includes stop lamps. You also asked "is it and will it become legal to turn on a warning or stop light that indicates the particular dynamic state of the vehicle?" and "(m)ust such a system necessarily be considered as a brake light?" We have encountered some deceleration warning systems that activate the stop lamps by means other than application of the service brake pedal. This is prohibited by paragraph S5.5.4 which states that "(t)he stop lamps on each vehicle shall be activated upon application of the service brakes." We have interpreted this as meaning that the stop lamps may be activated only by application of the service brakes, and that they may not be activated by reduced pressure on the accelerator pedal. A stop lamp can only be operated to indicate that the brake pedal has been applied for the purpose of slowing or stopping a vehicle. You may find of interest a letter of interpretation which I enclose (letter to Larry Snowhite, January 25, 1990) which expresses more fully our views on this subject. |
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ID: 9172Open Thomas G. Cehelnik, Ph.D. Dear Dr. Cehelnik: We are replying to your letter of September 28, 1993, requesting information on Federal Motor Vehicle Safety Standard No. 108 (you will find the complete text of this standard at 49 CFR 571.108). Your company has developed "a light system to indicate the deceleration of the vehicle." You have been informed that this agency is "investigating the safety of such a device," and "that lights that indicate braking must be `steady- burning.'" The agency is not investigating deceleration warning systems, thus I am unable to provide you with "information on the status of the safety investigation" as you requested. Paragraph S5.5.10 of Standard No. 108 applies to all lamps provided as original motor vehicle equipment, and lists the lamps that may flash, such as turn signal lamps, but this list does not include stop lamps. A final catchall subparagraph (d) requires that "[a]ll other lamps shall be wired to be steady-burning," and this includes stop lamps. You also asked "is it and will it become legal to turn on a warning or stop light that indicates the particular dynamic state of the vehicle?" and "[m]ust such a system necessarily be considered as a brake light?" We have encountered some deceleration warning systems that activate the stop lamps by means other than application of the service brake pedal. This is prohibited by paragraph S5.5.4 which states that "[t]he stop lamps on each vehicle shall be activated upon application of the service brakes." We have interpreted this as meaning that the stop lamps may be activated only by application of the service brakes, and that they may not be activated by reduced pressure on the accelerator pedal. A stop lamp can only be operated to indicate that the brake pedal has been applied for the purpose of slowing or stopping a vehicle. You may find of interest a letter of interpretation which I enclose (letter to Larry Snowhite, January 25, 1990) which expresses more fully our views on this subject. Sincerely, John Womack Acting Chief Counsel Enclosure ref:108 d:10/22/93 |
1993 |
ID: GF007988OpenMs. Amy Homan Dear Ms. Homan: This responds to your October 21, 2004, e-mail to George Feygin of my staff. You ask whether two oilfield equipment rigs manufactured by your company would be classified as "motor vehicles" and subject to the requirements of Federal motor vehicle safety standard (FMVSS) No. 121, Air brake systems. Title 49 U.S.C. Chapter 301 authorizes the National Highway Traffic Safety Administration (NHTSA) to prescribe Federal motor vehicle safety standards (FMVSSs) applicable to new motor vehicles and new items of motor vehicle equipment. Section 30102(a)(6) defines "motor vehicle" as:
NHTSA has issued several interpretations of this language. We have stated that vehicles equipped with tracks, agricultural equipment, and other vehicles incapable of highway travel are not motor vehicles. We have also determined that certain vehicles designed and sold solely for off-road use (e.g. , airport runway vehicles and underground mining vehicles) are not motor vehicles, even if they may be operationally capable of highway travel. Finally, we have concluded that items of mobile construction equipment that use the highways only to move between job sites and that typically spend extended periods of time at a single site are not motor vehicles. However, we do consider vehicles that use the public roads on a necessary and recurring basis to be motor vehicles. In the present case, the information you have provided describes two oilfield equipment rigs designed to service oil and gas wells. One is a tandem/tandem, which has four axles; the front two axles are steer axles. This units GVWR is 95,600 pounds. The second is a tandem/tridem, which has five axles; the front two axles are steer axles. This units GVWR is 120,600 pounds. Your letter indicates that these rigs travel on local roads and interstate highways between well locations. The period of time a rig spends at a single location varies depending on the end-user. You indicated that the rigs may be required to stay on a lease for a day, a week or a month at a time. The vehicles you ask about appear similar to items of mobile construction equipment which are not considered motor vehicles. Given this similarity and the limited usage you describe, we believe that the vehicles are not "motor vehicles" subject to the Federal motor vehicle safety standards. I hope you find this information helpful. If you have any other questions please contact Mr. George Feygin at (202) 366-2992. Sincerely, Jacqueline Glassman 2 Enclosures ref:571 |
2005 |
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.