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 |
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ID: aiam3935OpenWayne T. Halbleib, Esq., Assistant Attorney General, Office of the Attorney General, Supreme Court Building, 101 North Eighth Street, Richmond, VA 23219; Wayne T. Halbleib Esq. Assistant Attorney General Office of the Attorney General Supreme Court Building 101 North Eighth Street Richmond VA 23219; Dear Mr. Halbleib: In a letter dated May 25, 1983, you asked the National Highway Traffi Safety Administration whether the provisions on the back of Virginia's Certificate of Title (form VSA-3 2/80) are sufficient to satisfy the odometer mileage disclosure requirements of 49 CFR Part 580. You were advised by the Agency on June 20, 1983, that the title may be used in lieu of a separate odometer statement.; It has come to our attention that some dealers have purchased vehicles altered the odometer reading on the title and subsequently reassigned the title, without signing it and without listing their address. While the Virginia title provides a space for the purchaser's address and signature, the information is apparently furnished only when the buyer applies for title. Due to the practice of permitting a dealer to reassign titles without applying for them in his own name, it has become necessary for us to qualify our initial determination.; Unless the first buyer applies for title in Virginia, a separat odometer disclosure statement, signed by the buyer and containing his address must be issued and a photostat or other facsimile retained by the transferor. This information is required by 49 CFR 580.4(a), (e), and must be included upon the certificate of title before that document can be used in lieu of a separate statement. 49 CFR 480.4(f)(1) (sic). The Agency finds the buyer's signature to be of utmost importance. The signature serves as an acknowledgement that the purchaser was aware of the mileage. It prevents the buyer from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the odometer. Likewise, the address of an intervening dealer-owner is important, should subsequent investigation or enforcement actions become necessary. You may find it feasible to change the format of Virginia's title to include the purchaser's address and signature on the assignment or reassignment space.; If I can be of further assistance, do not hesitate to contact me or Ms Judith Kaleta of my staff at (202) 426-1834.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2365OpenMr. W.G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W.G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to Blue Bird Body Company's June 21, 1976, questio whether S5.3.1 of Standard No. 121, *Air Brake Systems*, requires the installation of an antilock system, or whether the stopping distance and 'no lockup' requirements may be met using modulation of the service brake control by the vehicle driver.; Section S5.3.1 requires that vehicles subject to it must be capable o stopping under specified conditions, within the stopping distance set forth in Table II without leaving a 12- foot-lane and without 'uncontrolled' lockup of certain wheels of the vehicle. There is no requirement for the installation of an antilock system. Also, there is no test condition that specifies a full brake application and modulation of the service brake may be used to reduce or eliminate lockup.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam3548OpenMr. Gary D. Williams, Wisconsin Automobile Truck Dealers Association, P.O. Box 5345, Madison, WS (sic) 53705; Mr. Gary D. Williams Wisconsin Automobile Truck Dealers Association P.O. Box 5345 Madison WS (sic) 53705; Dear Mr. Williams: This is in response to your letter of November 17, 1981, proposing a amendment to Section 580.6 of the Odometer Disclosure Requirements. 49 CFR 580 *et seq*. We regret our delay in responding. Specifically, you proposed the inclusion of a certification on the odometer disclosure statement that 'the odometer reading is not known to be the actual mileage by the seller.' After consideration of this suggestion, we believe that such a certification of lack of knowledge would tend to defeat the purposes of the Federal odometer laws and we, therefore, cannot recommend such a certification for inclusion in the odometer disclosure statement.; Section 408 of the Motor Vehicle Information and Cost Savings Ac requires that each transferor of a motor vehicle furnish to the transferee a written statement certifying the accuracy of the mileage. 15 U.S.C. 1988. The regulations establish a specific scheme for the certification of the accuracy of the odometer reading 49 CFR 580.4(c)(1) - (3). Where a transferor has knowledge that the odometer reading is inaccurate, the regulations require the transferor to certify that the mileage is not accurate and should not be relied upon. However, where the transferor has no reason to believe that the odometer reading is inaccurate, the dealer must certify the accuracy of the odometer reading to the subsequent purchaser. Of course, this scheme also permits a dealer to rely on the statements of prior owners and transferors. This certification scheme ensures as much as possible a reliable and accurate mileage history of a vehicle without subjecting any party to liability without fault.; The purpose of this scheme is to make the practice of alteration o odometers without detection more difficult by creating a record of the mileage stated and acknowledged by buyer and seller at each transaction. Such a scheme allows a purchaser to search the chain of transactions to determine whether any previous title holder has reduced the mileage. This purpose would be defeated by any change in the scheme which allows a transferor to avoid making a mileage statement or to make an equivocal statement. Accordingly, unless there is a more compelling reason to allow the form of certification you propose, we would recommend against such an amendment.; If you wish to have your proposal considered more formally by th agency you may petition for rulemaking pursuant to the procedures set out at 49 CFR Part 552. We are enclosing a copy of this regulation.; Sincerely, David W. Allen, Assistant Chief Counsel |
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ID: aiam4067OpenMr. Benjamin R. Jackson, Executive Director, Automobile Importers Compliance Association, 1607 New Hampshire Avenue, N.W., Washington, DC 20009; Mr. Benjamin R. Jackson Executive Director Automobile Importers Compliance Association 1607 New Hampshire Avenue N.W. Washington DC 20009; Dear Mr. Jackson: This responds to your letter requesting an interpretation of 49 CF Part 541, *Federal Motor Vehicle Theft Prevention Standard*. Specifically, you noted that section 541.5(d)(2)(iii) requires the original equipment parts on vehicles subject to the theft prevention standard to have the required markings entirely within the target area specified for the part by the original manufacturer of the vehicle. You stated that it was possible that target areas specified by the original manufacturer might be suitable for marking by means of labels, but not suitable for marking by means of inscription. If this situation were to occur, you asked if Part 541 could be interpreted to permit manufacturers that must mark by means of inscription to place those markings outside the target area designated by the original manufacturer. Part 541 cannot be so interpreted.; In the case of inscribed markings, S541.5(d)(2)(iii) specifies that th required markings shall be 'placed entirely within the target area specified by the original manufacturer for that part.' This requirement applies to *all* markings inscribed for the purposes of Part 541, whether done by an original manufacturer or a direct importer.; The policy bases underlying this requirement were explained at lengt in the preamble to the final rule establishing Part 541. *See* 50 FR 43166, at 43172, October 24, 1985. First, it is important that all parts be marked in the same target area so that investigators will know exactly where to look on a part for the required marking. The investigator would be alerted to possible suspicious activity if the marking were outside the target area. Second, the different target areas for original equipment and replacement parts marking are intended to ensure that there will be an adequate separation between the areas where the different types of parts will be marked. This will ensure that a thief cannot obliterate an original equipment part marking and affix a counterfeit replacement part marking directly over the area where the original equipment part marking was located.; Both of these purposes would be undercut if original manufacturers an direct importers were allowed to designate different target areas for marking vehicles in the same line. Accordingly, Part 541 explicitly requires only one target area for the required marking on each part of a covered line.; We do not believe that your concern about inscribing markings on curve surfaces is well- founded. The agency knows of a number of means of inscribing numbers on curved surfaces that would permit direct importers to mark those surfaces within the $15 cost limit set forth in section 604(a)(2) of the Cost Savings Act.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1815OpenMr. A.J. Burgess, Vice President (Technical), Joseph Lucas North America Inc., Two Northfield Plaza, Troy, Michigan 48084; Mr. A.J. Burgess Vice President (Technical) Joseph Lucas North America Inc. Two Northfield Plaza Troy Michigan 48084; "Dear Mr. Burgess: This is in response to your letter o j February 7, 1975, in which you ask whether the control lever/throttle arm of diesel fuel injection equipment is considered part of the pump mechanism or part of the 'linkage,' *i.e.* the accelerator control system, within the meaning of Standard No. 124."; The control lever/throttle is similar to the throttle lever referred t in Docket 69-20, Notice 5 (copy attached). In that notice, we established that the throttle lever is not part of the 'driver-operated accelerator control system', but rather part of the fuel metering device and therefore does not fall within the ambit of Standard No. 124.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2305OpenHonorable William S. Broomfield, House of Representatives, Washington, DC 20515; Honorable William S. Broomfield House of Representatives Washington DC 20515; Dear Mr. Broomfield: This is in response to your letter of May 10, 1976, forwarding petition for reconsideration of the recently issued Part 581 bumper standard from Gulf + Western Manufacturing Company. You indicate your support of the petition and request that you be informed of any action taken by the agency concerning the bumper standard.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. I assure you that Gulf + Western's comments and the information contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*, a copy of which will be sent as requested.; Sincerely, James B. Gregory, Administrator |
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ID: aiam1836OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of February 6, 1975, asking whethe paragraph S5.5.1 of Motor Vehicle Safety Standard No. 217 (49 CFR 571.217) permits the words Emergency Exit' to be placed above the emergency door in a school bus, or whether they must be within six inches of the emergency door release mechanism. You argue that placing the nomenclature above the door provides a more prominent identification of the exit than does placing it within 6 inches of the release mechanism.; We believe the interpretation of S5.5.1 which you suggest i appropriate when applied to rear door emergency exits in school buses. We have not previously considered school buses containing this type of emergency exit labeling to fail to conform to the standard. In addition, our recent proposal regarding school bus emergency exits (39 FR 8569, copy enclosed) would specifically require emergency exit labeling of this type.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2306OpenHonorable Robert P. Griffin, United States Senate, Washington, DC 20510; Honorable Robert P. Griffin United States Senate Washington DC 20510; Dear Senator Griffin: This is in response to your letter of May 6, 1976, forwarding petition from Gulf + Western Manufacturing Company for reconsideration of the bumper standard recently issued as Part 581 of Title 49 Code of Federal Regulations.; A number of requests for our view on the Gulf + Western petition hav been forwarded by members of Congress who have received copies of the Gulf + Western petition accompanied by a letter from Mr. James A. Graham.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Gulf + Western.; I assure you that Gulf + Western's comments and the informatio contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2307OpenHonorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your recent letter forwarding a petition fro Gulf + Western Manufacturing Company for reconsideration of the bumper standard recently issued as Part 581 of Title 49 Code of Federal Regulations.; A number of requests for our view on the Gulf + Western petition hav been forwarded by members of Congress who have received copies of the Gulf + Western petition accompanied by a letter from Mr. James A. Graham.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Gulf + Western.; I assure you that Gulf + Western's comments and the informatio contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2308OpenHonorable William M. Brodhead, House of Representatives, Washington, DC 20515; Honorable William M. Brodhead House of Representatives Washington DC 20515; Dear Mr. Brodhead: This is in response to your letter of May 14, 1976, forwarding petition from Gulf + Western Manufacturing Company for reconsideration of the bumper standard recently issued as Part 581 of Title 49 Code of Federal Regulations.; A number of requests for our view on the Gulf + Western petition hav been forwarded by members of Congress who have received copies of the Gulf + Western petition accompanied by a letter from Mr. James A. Graham.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Gulf + Western.; I assure you that Gulf + Western's comments and the informatio contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, James B. Gregory, Administrator |
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.