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: aiam1061OpenMr. R. E. Jones, Product Engineer, The Flxible Co., Loudonville, OH 44842; Mr. R. E. Jones Product Engineer The Flxible Co. Loudonville OH 44842; Dear Mr. Jones: This is in reply to your letter of February 21, 1973, requesting tha you be permitted to affix the Certification label for buses manufactured by your company on the right side of the dash panel, as illustrated in a picture (your serial; B72-4375-2) you have enclosed. As pictured, the label in the location you have chosen is easil readable without moving any part of the vehicle except an outer door, as required by section 567.4(c) of the Certification regulations, and your request that you be permitted to affix the label for these vehicles in that location is hereby approved.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam1060OpenMr. R. E. Jones, Product Engineer, The Flxible Co., Loudonville, OH 44842; Mr. R. E. Jones Product Engineer The Flxible Co. Loudonville OH 44842; Dear Mr. Jones: This is in reply to your letter of February 21, 1973, requesting tha you be permitted to affix the Certification label for buses manufactured by your company on the right side of the dash panel, as illustrated in a picture (your serial; B72-4375-2) you have enclosed. As pictured, the label in the location you have chosen is easil readable without moving any part of the vehicle except an outer door, as required by section 567.4(c) of the Certification regulations, and your request that you be permitted to affix the label for these vehicles in that location is hereby approved.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam3324OpenLes Sander, Illinois New Car and Truck Dealers Association, P.O. Box 3045, Springfield, IL 62704; Les Sander Illinois New Car and Truck Dealers Association P.O. Box 3045 Springfield IL 62704; Dear Mr. Sander: This is in response to your letter of August 1, 1890, in which yo asked whether the Illinois certificate of title may be used in lieu of a separate Federal odometer form. The Illinois title does not contain the signature of the buyer. The National Highway Traffic Safety Administration believes that the buyer's signature is necessary in order to substantiate that he has seen the odometer information and is aware of the mileage that the vehicle has been driven. Without the signature the Illinois title cannot be used in place of the Federal form.; If you have any further questions or if we can be of any assistance please do not hesitate to write.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2926OpenMr. Paul G. Scully, Chairman, SAE Lighting Committee, State Road 7, P.O. Box 766, Madison, IN 47250; Mr. Paul G. Scully Chairman SAE Lighting Committee State Road 7 P.O. Box 766 Madison IN 47250; Dear Mr. Scully: This is in reply to your letter of December 18, 1978, asking for a interpretation of Federal Motor Vehicle Safety Standard No. 108.; The standard was recently amended to establish a ceiling of 60 inche from the roadway surface for the mounting height of rear side marker lamps. You have asked whether it is permissible to mount an additional side marker lamp at the upper rear corner of a trailer whose overall height exceeds 60 inches.; The answer is yes. Such a supplemental lamp would not appear to impai the effectiveness of lighting equipment required by Standard No. 108, within the meaning of the prohibition of S4.1.3 that you mentioned.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0052OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, Post Office Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol Post Office Box 898 Sacramento CA 95804; Dear Mr. Heath: This is in reply to your letters of February 15 and March 8, 1968 concerning application of Federal Motor Vehicle Safety Standard Number 205.; Glazing materials used in campers, pickup canopies, and covers mus conform to the requirements of Federal Motor Vehicle Safety Standard Number 205.; I am enclosing a copy of FHWA Ruling 68-1 published in the *Federa Register*, Volume 33, Number 59 on March 26, 1968, and a copy of the Federal Motor Vehicle Safety Standards (with Amendments and Interpretations through February 15, 1968).; Sincerely, William H. Risteen, Office of Standards on Crash-Injur Reduction, Motor Vehicle Safety Performance Service; |
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ID: aiam0338OpenCharles O. Verrill, Jr. Patton, Blow, Verrill, Brand & Boggs, 1200 Seventeenth Street, N.W., Washington, D.C. 20036; Charles O. Verrill Jr. Patton Blow Verrill Brand & Boggs 1200 Seventeenth Street N.W. Washington D.C. 20036; Dear Mr. Verrill: #This is in reply to your letter of May 3, 1971 requesting an additional interpretation of the Tire Identification and Record Keeping Regulation. #If in fact, the vehicle manufactured is not considered a motor vehicle within the meaning of the Act and the mini-bike interpretation (34 F.R. 15416)(copy enclosed), then Part 574, the Tire Identification and Record Keeping Regulation, and section 113 (15 U.S.C. 1402) will be inapplicable. #Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam0838OpenMr. G. Harrison, General Manager, Protector Africa (Pty.) Ltd., P. O. Box 20, Kempton Park, Transvaal, South Africa; Mr. G. Harrison General Manager Protector Africa (Pty.) Ltd. P. O. Box 20 Kempton Park Transvaal South Africa; Dear Mr. Harrison: This is in reply to your letter of July 31, 1972, in which you reques that your motorcycle helmet be tested by our testing authority. The National Highway Traffic Safety Administration does not provide approval of any item of motor vehicle equipment as conforming to any motor vehicle safety standard. Each item is required to conform, but the basis upon which a manufacturer determines whether his product conforms to a standard is a matter within his own discretion.; We thank you for your compliments and for your comments on the propose standard for motorcycle helmets, which have been placed in the rulemaking docket.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1742OpenFrese Autozubehor, Metallwerk Frese GmbJ(sic), 5672 Leichlingen, Postfach 26; Frese Autozubehor Metallwerk Frese GmbJ(sic) 5672 Leichlingen Postfach 26; Dear Sir: This is in response to your letter of September 26, 1974, requesting a interpretation of the requirement contained in S3.1.2.2 of Standard No. 111, *Rearview Mirrors*.; We interpret paragraph S3.1.2.2 as providing for three sets o test-force directions. The requirement that a mirror in the head impact area deflect or collapse or break away without leaving sharp edges when impacted in a forward direction means that the 90 pounds of force is to be applied in a forward direction in a vertical longitudinal plane, from 45 degrees above to 45 degrees below the horizontal. (See side view sketch). The requirements that the same performance level be met when the mirror is impacted from the sidewall direction creates two additional sets of test-force directions, leftward and rightward in a vertical plane perpendicular to the vertical longitudinal plane. As in the forward impact portion of the requirement, the force must be applied from 45 degrees above to 45 degrees below the horizontal. (See front view sketch).; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1279OpenMr. D. P. Peck, Technical & Safety Manager, Triumph Motors, British Leyland UK Limited, Conley, Coventry, 0V4 9DB, England; Mr. D. P. Peck Technical & Safety Manager Triumph Motors British Leyland UK Limited Conley Coventry 0V4 9DB England; Dear Mr. Peck:#This is in reply to your letter of September 11, 1973 asking whether a console-mounted diagram depicting proper placement of heating controls to activate the defrost mode is a 'symbol' within the meaning of Standard No. 101 and whether it is therefore prohibited.#We do not consider the diagram a symbol since it does not itself identify a control, but depicts only how that control is to be placed in a certain mode. Its use is therefore permitted.#Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam3637OpenDaryll E. Schoen, Chief, Registrar's Bureau, Motor Vehicle Division, Department of Justice, 925 Main, Deer Lodge, MT 59722; Daryll E. Schoen Chief Registrar's Bureau Motor Vehicle Division Department of Justice 925 Main Deer Lodge MT 59722; Dear Mr. Schoen: This is in response to your request for approval of Montana's Odomete Disclosure Statement as it presently appears of (sic) the State Certificate of Title.; The Montana title differs from the Federal requirements as set forth i 49 CFR Part 580 in that it does not contain a statement that the odometer reading reflects the amount of mileage over 99,999 miles. Without this item, the Montana form cannot be used in lieu of a separate Federal form. It would appear that you could provide a separate 'check box' directly under the actual odometer mileage statement on your present form.; If this statement is included, the National Highway Traffic Safet Administration will approve the Montana title.; Sincerely, Frank Berndt, Chief Counsel |
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.