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: aiam1880OpenHonorable Glenn English, House of Representatives, Washington, DC 20515; Honorable Glenn English House of Representatives Washington DC 20515; Dear Mr. English: This is in response to your letter of March 25, 1975, requestin information concerning correspondence from Franklin Motor Company commenting on a proposed amendment to the Federal bumper standard by urging that recyclability of bumpers by required.; 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 has examined the environmental and energy ramifications o its proposed bumper standard and is continuing to do so. Our most recent proposal (March 12, 1975, 40 F.R. 11598, Docket 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 your constituents i this matter. You can be sure that their comments will be given every consideration.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam0267OpenMr. G. M. Hespeler, Manager, Government Liaison, Mercedes- Benz of North America, Inc., 158 Linwood Plaza, P.O. Box 318, Fort Lee, NJ 07024; Mr. G. M. Hespeler Manager Government Liaison Mercedes- Benz of North America Inc. 158 Linwood Plaza P.O. Box 318 Fort Lee NJ 07024; Dear Mr. Hespeler: Thank you for your letter of September 29, 1970, concerning th application of Federal Motor Vehicle Safety Standard No. 206 to the door locks and door retention components on the C-111's gull-wing doors. I appreciate also the design drawings you submitted earlier this month.; As Standard 206 presently exists, the door locks and door retentio components on the C-111 doors must conform to it. As locks and retention components on passenger car side doors that meet the description in the first sentence of S4, they are clearly within the ambit (sic) of the standard. The Bureau recognizes that some of the requirements and test procedures in the standard may not be entirely appropriate for side doors of all designs, and is accordingly considering amendments to the standard.; If we can be of further assistance, please write. Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs; |
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ID: aiam0555OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, Ohio 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati Ohio 45202; Dear Mr. Pieratt: This is in reply to your letters of September 25 and October 19, 1972 In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the regulations therefore apply to them.; Your letter of October 19 asks whether a person who installs a fift wheel in a pickup truck is considered a 'remanufacturer.' Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22800, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0893OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letters of September 25 and October 19, 1972 In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (S 573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the regulations therefore apply to them.; Your letter of October 19 asks whether a person who installs a fift wheel in a pickup truck is considered a 'remanufacturer.' Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22600, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.; Yours truly, richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0549OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, Ohio 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati Ohio 45202; Dear Mr. Pieratt: This is in reply to your letters of September 25 and October 19, 1972 In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the regulations therefore apply to them.; Your letter of October 19 asks whether a person who installs a fift wheel in a pickup truck is considered a 'remanufacturer.' Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22800, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2494OpenMr. Jack D. Livingston, Executive Vice-President, Caravan Trailer Rental Co. Ltd., 955 Middlegate Road, Mississauga, Ontario, Canada L4Y3Y4; Mr. Jack D. Livingston Executive Vice-President Caravan Trailer Rental Co. Ltd. 955 Middlegate Road Mississauga Ontario Canada L4Y3Y4; Dear Mr. Livingston: This responds to Caravan Trailer Rental Company's December 22, 1976 question whether trailers manufactured prior to January 1, 1975, may be imported into the United States for sale without being required to conform to Standard No. 121, *Air Brake Systems.*; Standard No. 121 only regulates the manufacture and importation o trailers that are produced on or after January 1, 1975. Standard No. 121's only limitation on the importation and sale of trailers manufactured prior to January 1, 1975, would be that any repair, refurbishment, or other modification of the trailer must not be so significant as to constitute the manufacture of a new vehicle. To qualify as a repair the NHTSA requires that the running gear assembly of the existing trailer be used in the refurbished trailer and that certain other identification and ownership (or leasing) aspects of the existing trailer be continued in the refurbished trailer. I have enclosed a copy of a notice which explains the NHTSA regulations in this area.; You are reminded that a trailer imported into the United States as yo describe must bear a label that states the month and year of manufacture.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2479OpenMr. Eugene C. Kellogg, USM Corporation, P.O. Box 103, Birmingham, MI 48012; Mr. Eugene C. Kellogg USM Corporation P.O. Box 103 Birmingham MI 48012; Dear Mr. Kellogg: This is in response to your letter of December 21, 1976, concerning th effective date of 49 CFR Part 581, *Bumper Standard*.; Part 581 was published on March 4, 1976, pursuant to Title I of th Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). It is scheduled to become effective on September 1, 1978, at which time it will absorb Federal Motor Vehicle Safety Standard No. 215, *Exterior Protection*, the currently effective bumper standard.; There has been no action taken to delay the scheduled implementatio date of the Part 581 bumper standard. If a decision were made to delay the standard's effective date, it would be published in the Federal Register.; National Highway Traffic Safety Administration rulemaking procedure permit the filing of petitions for reconsideration of final rulemaking actions. Such petitions must be filed within 30 days of the date on which the final rule is published and must be either granted or denied by the agency. Petitions for reconsideration of Part 581 were submitted by several manufacturers. The agency is still considering the issues raised in those petitions and has not yet made a decision as to their disposition. The agency response to the petitions for reconsideration will be published in the Federal Register.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam1172OpenMr. Timothy J. Kincaid, Silber, Pickus & Williams, 1505 Investment Plaza, Cleveland, OH 44114; Mr. Timothy J. Kincaid Silber Pickus & Williams 1505 Investment Plaza Cleveland OH 44114; Dear Mr. Kincaid: This is in response to your June 19, 1973, request for samples of th odometer disclosure form described in Part 580, *Odometer Disclosure Requirements*, 49 CFR S 580.6, and for the correct sequence in which to execute the mileage statement and the transfer of ownership.; The Act requires disclosure of odometer readings, but the regulation issued do not require the use of a federally-printed form, and the government therefore does not provide such forms. The use of a commercially-prepared form is satisfactory if it contains the required information, as it appears in the sample format of S 580.6. 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. Either the original or a carbon copy may be given to the transferee.; Section 580.4(a) requires a transferor to furnish the statement 'Befor executing any transfer or ownership document' and include the odometer reading at the time of transfer and the date of transfer. To accomplish this, the statement must precede the transfer and should be executed on the date of transfer to reflect an accurate mileage and date. The date of the statement would then function as the date of transfer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1434OpenMr. P. Oppenheimer,Technical Legislation Manager,Girling Limited,Kings Road,Tyseley Birmingham 11; Mr. P. Oppenheimer Technical Legislation Manager Girling Limited Kings Road Tyseley Birmingham 11; Dear Mr. Oppenheimer:#This responds to Girling's February 22, 1974 petition for abbreviated labeling on short vacuum hose in cases where the 6-inch interval required by s%.2.2 of Standard 106, *Brake hoses*, makes complete labeling impossible.#The National Highway Traffic Safety Administration has modified the labeling requirement of February 26, 1974 (39 FR 7425) by specifying an interval of 'not more than 6 inches' to permit the manufacture and labeling of short hose length without waste. Lettering may be any width so long as it is at least one-eighth of an inch high. your petition, Therefore, is denied as unnecessary.#Sincerely,Robert L. Carter,Associate Administrator,Motor Vehicle Programs; |
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ID: aiam3109OpenMr. C. J. Newman, Vice President, Engineering, The Grote Manufacturing Company, State Rt. 7 - P.O. Box 766, Madison, IN 47250; Mr. C. J. Newman Vice President Engineering The Grote Manufacturing Company State Rt. 7 - P.O. Box 766 Madison IN 47250; Dear Mr. Newman: This is in reply to your letter of August 23, 1979, to the former Chie Counsel Joseph J. Levin, Jr. You have asked whether a double-faced turn signal front side marker lamp 'meets the intent' of Motor Vehicle Safety Standard No. 108, and you enclosed a sample of the lamp for our inspection.; You have quoted paragraph 3.4 of SAE Standard J588e, September 1970 which states 'the flashing signal from a double faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles.' It is not possible to make a definitive statement about your lamp without actually subjecting it to a representative external light source such as the headlamps of a vehicle in proximity to the vehicle to which the lamp is mounted, but its design appears adequate to meet the intent of paragraph 3.4. Any changes in design of the lenses or baffling from that of the sample lamp submitted, however, might transmit more light from external sources and may not meet paragraph 3.4.; We would also like to observe that since the side marker signal use the front and rear lenses of the turn signal in a single compartment a high intensity ratio of turn signal to side marker signal will be needed if the steady burning light from the side marker lamp is not to obscure the darker portion of the turn signal lamp.; 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.