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: aiam3218OpenMr. R.W. Fink, Manager/Information Systems, Harley-Davidson Motor Co., Inc., P.O. Box 653, Milwaukee, Wisconsin 53201; Mr. R.W. Fink Manager/Information Systems Harley-Davidson Motor Co. Inc. P.O. Box 653 Milwaukee Wisconsin 53201; Dear Mr. Fink: This is in reply to your letter of January 30, 1980, to Mr. Vinson o this office asking for an opinion whether S5.2.5 of Motor Vehicle Safety Standard No. 123 permits a passenger footboard of the nature you are considering for production.; S5.2.5 requires that 'footrests' be provided that, for passengers, fol rearward and upward when not in use. 'Footrest' is not defined but we view it as a term sufficiently broad to encompass both the round footpegs which predominate in the industry, as well as the footboard you propose to use. From the blueprint that you enclosed, the footboard when folded appears to be well within the permanent vehicle structure, and thus to meet the intent if not the letter of S5.2.5. We therefore see no legal reason why you may not introduce it into production.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1168OpenMr. Bill Howard, Ratliff Motor Company, Post Office Box 400, Live Oak, FL 32060; Mr. Bill Howard Ratliff Motor Company Post Office Box 400 Live Oak FL 32060; Dear Mr. Howard: This is in response to your request for odometer disclosure forms. The Motor Vehicle Information and Cost Savings Act requires disclosur of odometer readings, but the regulations issued to implement the Act do not require you to use a federally printed form to make the disclosure, and the government therefore does not provide such forms. The regulation (Part 580) specifies an adequate format and is enclosed for your information. This format will satisfy federal disclosure requirements throughout the fifty states and permits use of identical forms in all jurisdictions.; The use of a commercially- prepared form is satisfactory if it contain the required information. The document does not have to be separate from other transfer documents, and in the case of a transferor using a bill of sale or other transfer document, the statement may be included within the form. The statement must be executed prior to the transfer. Either the original or a carbon copy may be given to the transferee.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0886OpenMr. Patt Mann, Purchasing and Production, Dalman Enterprises Ltd., P.O. Box 340, Killarney, Manitoba, Canada ROK 1G0; Mr. Patt Mann Purchasing and Production Dalman Enterprises Ltd. P.O. Box 340 Killarney Manitoba Canada ROK 1G0; Dear Mr. Mann: This is in reply to your letter of September 20, 1972, in which yo enclose a brochure describing your feed mover as requested by Mr. Andrew Moss, of my staff.; An examination of the material submitted would seem to indicate tha your classification of the feed mover as farm machinery is valid. We would not, therefore, consider it to be a 'motor vehicle' within the meaning of the National Traffic and Motor Vehicle Safety Act (the Act) based on the information furnished.; In addition to the Act (PL 89-563) and 19 C.F.R. 12.80, that you hav requested, we are also enclosing Part 571 (formerly Part 371) of Title 49 of the Code of Federal Regulations. Of particular interest to you would be the interpretations on mini- bikes that set forth criteria to assist manufacturers in classifying their products insofar as off-road use is concerned.; If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam2038OpenMr. Frank C. Howard, Jr., Flenniken Financial Services, Inc., 515 Market Street, Knoxville, Tennessee 37902; Mr. Frank C. Howard Jr. Flenniken Financial Services Inc. 515 Market Street Knoxville Tennessee 37902; Dear Mr. Howard: This responds to your letter of July 1, 1975, concerning the lega duties of a tire recapping firm which you insure.; For your convenience, I have enclosed a copy of Federal Motor Vehicl Safety Standard No. 117, *Retreaded Pneumatic Tires*. This standard does not specify the testing which a manufacturer of retreaded tires must do, it does specify the criteria which the tires must meet when tested by the National Highway Traffic Safety Administration (NHTSA) for compliance. While the surest way for the retreader to be confident of compliance would be to follow the procedures in every detail, he is not legally obligated to do so. Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, requires him to assure himself that, when tested by the NHTSA according to the procedures set out in the standard, his tires will meet the specified criteria. In addition, he is required to repair or replace without charge a non-complying tire.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0684OpenMr. C. D. Mampe,Technical Assistant,Engineering Liaison,British Leyland Motors, Inc.,500 Willow Tree Road,Leonia,New Jersey 07605; Mr. C. D. Mampe Technical Assistant Engineering Liaison British Leyland Motors Inc. 500 Willow Tree Road Leonia New Jersey 07605; Dear Mr. Mampe:#This is in reply to your letter of April 19 calling ou attention to Mr. Whitehead s letter of February 8 addressed to Docket No. 70-27. We regret the delay in answering Mr. Whitehead s question. Communications address to the docket, which arrive in large volume, are normally filed without reply. We request that letter requesting a reply be addressed to the Administrator, not the docket, so that they will be promptly assigned for action.#Mr. Whitehead asked whether a display of 'red letters' when the lamp is lit would satisfy the proposed revision of Standard No. 105, and recommended that the words 'red lens' be deleted from paragraphs S4.2.2c and S4.7.2d of the proposed amendment to Standard No. 105. The red letters described appear to satisfy the intent of proposal, and the suggestion for rewording will be considered when the final rule is issued.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam1971OpenD. R. Bernard, Esq., Messrs. Bernard & Bernard, 4100 One Shell Plaza, Houston, TX 77002; D. R. Bernard Esq. Messrs. Bernard & Bernard 4100 One Shell Plaza Houston TX 77002; Dear Mr. Bernard: This is in reply to your letter of May 28, 1975, providing furthe information for our determination whether certain 'safety lights' would violate the National Traffic and Motor Vehicle Safety Act of 1966.; There is no Federal prohibition against sale of this accessory in th aftermarket. It would, however, be subject to regulation by the states. For the following reasons, it could not be used as original equipment. Standard No. 108 requires a minimum spacing of 4 inches (edge to edge) between the stop lamps and the rear turn signal lamps and a minimum spacing of 9 inches (centerline to centerline) between the turn signals. The purpose of this spacing is to provide a distinctive indication of the turning direction. A flashing stop lamp located in close proximity to the steady-burning stop lamp required by Standard No. 108 would, in our opinion, impair the effectiveness of the rear turn signal within the meaning of S4.1.3, during a combined braking and turning operation. Such a lamp would also be prohibited by S4.6(b) which, in effect, requires all original equipment stop lamps to be steady burning.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1768OpenMr. F. Maggi,SAIAG, Via Torino 100, 10073 Cirie (Torino) ITALIA; Mr. F. Maggi SAIAG Via Torino 100 10073 Cirie (Torino) ITALIA; Dear Mr. Maggi:#Please forgive the delay in responding to your lette of September 25, 1974, requesting a 'manufacturer designation' for the vacuum brake hose which you manufacture.#S5.2.2(b) of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, was amended on January 29, 1974 (39 FR 3680, Docket No. 1-5, Notice 9), and again on February 26, 1974 (39 FR 7425, Docket No. 1-5, Notice 10).In place of an manufacturer's code number, assigned by the National Highway Traffic Safety Administration, S5.2.2(b) of the standard now requires:#>>>A designation that identifies the manufacturer of the hose assembly, which shall be filed in writing with: Office of Standards Enforcement, 'Brake Hose Identification,' National Highway Traffic Safety Administration, 400 Seventh Street S.W., Washington, D.C. 20590. The marking may consist of a designation other than block capital letters required by S5.2.2.<<<#The designation, 'SAIAG', as depicted in your letter, already satisfies this requirement. This designation is now on file in the Office of Standards Enforcement. Please note that the other required label information must still appear on the hose in block capital letters and numerals at least one-eighth of an inch high.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2772OpenMr. James J. Kearney, Vice President, Baltimore Cycles, Inc., 6020 Eastern Avenue, Baltimore, Maryland 21224; Mr. James J. Kearney Vice President Baltimore Cycles Inc. 6020 Eastern Avenue Baltimore Maryland 21224; Dear Mr. Kearney: This is in reply to your letter of January 12, 1978, asking whether th braking system on your Casal mopeds meets Federal requirements.; Table 1 of Federal Motor Vehicle Safety Standard No. 123, *Motorcycl Controls and Displays*, requires that the control for read brakes on motorcycles shall be located at the right foot control (with the option of the left handlebar permissible for motor driven cycles such as mopeds) and operate by depressing to engage. The rear brake on the Casals moped in operated by 'back peddling, similar to a bicycle.' We understand that this is accomplished by application of force to the right foot pedal.; We have concluded that this system meets the requirements of th standard, since the brake is engaged by depressing the right foot pedal.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2438OpenMr. Arthur C. Mertz, Executive Vice President, National Association of Independent Insurers, 2600 River Road, Des Plaines, IL 60018; Mr. Arthur C. Mertz Executive Vice President National Association of Independent Insurers 2600 River Road Des Plaines IL 60018; Dear Mr. Mertz: This is in response to your letter of September 23, 1976, concernin petitions for reconsideration of 49 CFR Part 581, *Bumper Standard* (41 FR 9346, March 4, 1976).; Your letter indicated opposition to any agency action on petitions fo reconsideration of Part 581 that would reopen the issue of the standard's content. You stated that should a decision be made by the agency to reconsider Part 581, additional public hearings would be in order before any final action was taken on the standard.; I assure you that no substantive revision of Part 581, based upo petitions for reconsideration, would be made without first proposing the change and providing opportunity for interested persons to comment. I cannot project at this time whether a public meeting would be the best forum in which to receive comments should the agency decide to propose an amendment to Part 581. However, you may be confident that the agency would seek and thoroughly consider comments by your organization and all interested persons before taking final action.; Sincerely, John W. Snow, Administrator |
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ID: aiam0278OpenMr. Gerhard P. Riechel, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. Gerhard P. Riechel Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Riechel: In your letter of June 7, 1971, you asked for confirmation of you understanding that under the NHTSA regulation (49 CFR S 553.39) interpreting section 105(a)(1) of the National Traffic and Motor Vehicle Safety Act, a petition for judicial review of Standard No. 208 would be considered timely if filed within 60 days after the publication in the *Federal Register* of the Administrator's decision on any petitions for reconsideration of that standard.; Your understanding is correct. As the standard currently stands, w consider it (that is, the standard as it becomes effective January 1, 1972) a 'single rule', to use your phrase, and the judicial review period will not begin to run until the publication of the decision on any timely-filed petitions for reconsideration of any part of it. If at a future date we wish to sever any portion of the standard for judicial review purposes, and consider it 'final' despite pending action on other portions, we will give explicit notice of that action in the *Federal Register*.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting 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.