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: aiam1896OpenHonorable Richard Stone, United States Senate, Washington, DC 20510; Honorable Richard Stone United States Senate Washington DC 20510; Dear Senator Stone: This is in response to your letter of April 3, 1975, requestin information concerning correspondence from Mr. Gurth G. West commenting on a proposed amendment to the Federal bumper standard by urging that recyclability of bumpers be assured.; Although promulgation of rules that have a direct positive impact o the environmental and energy situation is not within the National Highway Traffic Safety Administration's (NHTSA) jurisdiction, the agency gives serious consideration to the effect any of its standards will have on these important areas of concern.; The NHTSA's most recent proposal (March 12, 1975, 40 FR 11598, Docke No. 74-11, Notice 7, Docket No. 73-19, Notice 6) ensures that a wide variety of materials, including metals, could continue to be used in bumper systems.; We greatly appreciate your interest and that of Mr. West in thi matter. You can be sure that his comments will be given every consideration.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam1486OpenMr. J. Baskin, Dave's Tire & Fuel Oil Corp., 284 Bedford Street, Fall River, Massachusetts 02720; Mr. J. Baskin Dave's Tire & Fuel Oil Corp. 284 Bedford Street Fall River Massachusetts 02720; Dear Mr. Baskin: #This is in reply to your letter of March 21 and Apri 22, 1974, in which you ask whether a tire sold as a 'blemish' must be guaranteed for workmanship, material, and road hazards. #There are no Federal requirements that manufacturers guarantee blemish (or non-blemish) tires. Such guarantees are within the discretion of each manufacturer. However, Federal Motor Vehicle Safety Standard No. 109 (49 CFR S 571.109) requires all new passenger car tires to meet minimum safety performance levels for high speed performance, endurance, strength, bead unseating, physical dimensions and treadwear indicators. These requirements apply similarly to both blemish and non-blemish tires. #We have enclosed for your information a copy of the Federal Trade Commission's Tire Advertising and Labeling Guides which contain in Guide 11 requirements for the labeling of blemish tires. #Yours truly, Richard B. Dyson, Assistant chief Counsel; |
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ID: aiam1897OpenHonorable Dante B. Fascell, House of Representatives, Washington, DC 20515; Honorable Dante B. Fascell House of Representatives Washington DC 20515; Dear Mr. Fascell: This is in response to your letter of March 31, 1975, forwardin correspondence from Mr. Gurth G. West commenting on a proposed amendment to the Federal bumper standard by urging that recyclability of bumpers be assured.; Although promulgation of rules that have a direct positive impact o the environmental and energy situation is not within the National Highway Traffic Safety Administration's (NHTSA) jurisdiction, the agency gives serious consideration to the effect any of its standards will have on these important areas of concern.; The NHTSA's most recent proposal (March 12, 1975, 40 F.R. 11598, Docke No. 74-11, Notice 7, Docket No. 73-19, Notice 6) ensures that a wide variety of materials, including metals, could continue to be used in bumper systems.; We greatly appreciate your interest and that of Mr. West in thi matter. You can be sure that his comments will be given every consideration.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam1013OpenMr. F. E. Keith, Keith Motor Company, 4507 East 11th, Tulsa, OK 74112; Mr. F. E. Keith Keith Motor Company 4507 East 11th Tulsa OK 74112; Dear Mr. Keith: This is in reply to your letter of January 30, 1973, concerning th Federal Odometer Disclosure Requirement.; Your questions concerns (sic) the situation in which a person sells vehicle that has had several previous owners. You suggest that, in such a case, the true mileage should be indicated as unknown.; It is our opinion that the language you quote from Section 408(a) o the Act, to the effect that the mileage must be said to be unknown if the odometer reading is known to differ from the actual mileage, does not apply in the situation you describe. A person selling the vehicle in the above situation should not, therefore, indicate that the mileage is unknown, but should rely on the statement by the previous owner.; As you acquire vehicles after March 1, the effective date of th disclosure requirement, you will be obtaining the disclosure statement from each seller. Within a relative (sic) short time, all of the vehicles on your lot will have disclosure statements on which you are entitled to rely in making your disclosure statement upon resale of the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1467OpenMr. James L. Greighton, Maxi-Cab Enterprises, 115G Harvey West Blvd., Santa Cruz, CA 95060; Mr. James L. Greighton Maxi-Cab Enterprises 115G Harvey West Blvd. Santa Cruz CA 95060; Dear Mr. Greighton: This is in reply to your letter of March 18, 1974, asking which Federa requirements apply to the Maxi- Cab, pictures of which you enclose. You describe the Maxi-Cab as a fiberglass shell that fits in the back of compact pickups, and indicate that it has been designed to be used to transport children.; Based on the pictures you have furnished, we have concluded that th Maxi-Cab is a 'pickup cover', which is defined in S4 of Motor Vehicle Safety Standard No. 205, 'Glazing Materials' (49 CFR 571.205), as 'a camper having a roof and sides but without a floor, designed to be mounted on and removable from the cargo area of a truck by the user.'; Since you describe the Maxi-Cab as designed to transport persons, th glazing material used in its construction must conform to Motor Vehicle Safety Standard No. 205. No other Federal requirements administered by this agency apply to it.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0528OpenMr. Satoshi Nishibori, Engineering Representative, Liaison Office In U.S.A., Nissan Motor Company, Ltd., 400 County Avenue, Secaucus, NJ 07094; Mr. Satoshi Nishibori Engineering Representative Liaison Office In U.S.A. Nissan Motor Company Ltd. 400 County Avenue Secaucus NJ 07094; Dear Mr. Nishibori: By letter of December 6, 1971, you have asked our opinion as to ho S6.1 of Standard 208 applies to two hypothetical situations. S6.1 requires that 'all portions of the test device shall be contained within the outer surfaces of the passenger compartment throughout the test.'; Your first situation involves a vehicle in which the impact of th dummy's head causes the windshield to bulge beyond its original location but does not penetrate the windshield. It is our opinion that in this case the vehicle has contained the occupant and would conform to S6.1.; In your second situation, the dummy's head pushes the windshield loos at its base and opens a gap between the windshield and the vehicle. It is our opinion that this drawing also shows the dummy to be satisfactorily contained.; In either situation, however, a manufacturer would have to assur himself that the windshield behavior shown in the drawings would be consistent and would not lead to failure in tests in which the test dummy strikes it in a different manner.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3927OpenMr. R. R. Allison, Assistant Vice President, First American Bank of Virginia, 1970 Chain Bridge Road, McLean, VA 22102; Mr. R. R. Allison Assistant Vice President First American Bank of Virginia 1970 Chain Bridge Road McLean VA 22102; Dear Mr. Allison: This is in response to your letter of March 14, 1985, in which yo asked whether the bank is required to complete the Odometer Mileage Statement form in view of the wording on the Virginia title.; I have reviewed Virginia's Certificate of Title and the odomete mileage disclosure regulation, 49 CFR part 580. The bank should continue to issue its Odometer Mileage Statement when transferring a motor vehicle unless the buyer completely fills out the reverse side of the title, including the application. While the Virginia title meets regulatory requirements concerning the odometer reading, it fails to provide a space for the buyer's address and signature apart from the application. In some instances, a dealer may reassign the title without applying for one in his own name and the above requirements would not be met. The dealer would then be able to assert that he was not informed of the mileage or that the mileage was different from that appearing on the title.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam3312OpenMichael M. Packard, Commissioner, Indiana Bureau of Motor Vehicles, State Office Building, Indianapolis, IN 46204; Michael M. Packard Commissioner Indiana Bureau of Motor Vehicles State Office Building Indianapolis IN 46204; Dear Mr. Packard: This is in response to your letter of May 28, 1980, in which yo requested approval to use Indiana's Certificate of Title as a substitute for the Federal Odometer disclosure form required by 49 CFR Part 580.; Because the Federal odometer requirements that became effective as o January 1, 1978, contain a good deal of wish to include odometer information on their titles to use a shortened form that was adopted by the American Association of Motor Vehicle Administrators (AAMVA). We consider the AAMVA form to include the minimum amount of information necessary for an adequate disclosure. In addition to the information included on the Certificate of Title which you submitted to our office, the following information is also required:; >>>(1) a reference to State or Federal law, (2) a statement that the odometer reading reflects the amount o mileage over 99,999 miles,; (3) a statement that the odometer mileage is not actual, (4) the signature of the buyer.<<< Without these four items the title cannot be used in lieu of a separat Federal form. If this information is included, the National Highway Traffic Safety Administration will approve the title for use in lieu of the Federal form.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0718OpenMr. John E. Wade, Purchasing Manager, Rok-A-Chair Manufacturing Co., Inc., P. O. Box 254, North Central Street, Coffeyville, KS, 67337; Mr. John E. Wade Purchasing Manager Rok-A-Chair Manufacturing Co. Inc. P. O. Box 254 North Central Street Coffeyville KS 67337; Dear Mr. Wade: In reply to your letter of May 9, 1972, I have enclosed a copy of Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' which specifies flammability requirements for materials used in motor vehicles.; The standard applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. Among the recreational vehicles you list, motor homes and chassis-mount campers mounted on new chassis would be included. Mobile homes and travel trailers are not subject to the standard. Slide-in campers and chassis-mount campers that are not mounted on new chassis are not presently subject to the standard, but NHTSA is considering amendments that would bring these camper types within the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0077OpenChester G. Parsons, President, Elgin Sweeper Company, 1300 West Bartlett Road, Elgin, IL 60120; Chester G. Parsons President Elgin Sweeper Company 1300 West Bartlett Road Elgin IL 60120; Dear Mr. Parsons: This is in response to your letter of April 17 requesting eithe confirmation of your opinion that it was 'not the intent of the Federal Motor Vehicle Safety Standards to apply to 'the three wheeled motor street sweeper manufactured by Elgin, or, in the alternative, consideration by the Federal Highway Administration of the establishment of a separate classification for these vehicles.; Three wheeled motor street sweepers are 'motor vehicles' within th meaning of the National Traffic and Motor Vehicle Safety Act of 1966. However, they do not fall into any of the vehicle types defined thus far, to which standards are applicable, and consequently there are no standards applicable to it at this time.; Sincerely, William Haddon, Jr., M.D., Director |
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.