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: aiam2777OpenMr. Philip P. Friedlander, Jr., Executive Vice President, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, D.C. 20005; Mr. Philip P. Friedlander Jr. Executive Vice President National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Friedlander: This responds to your February 23, 1978, letter asking whether a tub can be installed in a tubeless tire without any adverse effects upon safe operation of that tire. In our January 6, 1978, letter to Mr. Philip Taft of your Association, the National Highway Traffic Safety Administration (NHTSA) indicated that a retreader could not change a tire originally labeled 'tubeless' to a tire labeled 'tube type,' because such an alteration would violate the labeling requirements of Standard No. 117, '*Retreaded Pneumatic Tires - Passenger Cars.*' The NHTSA did not state, as you indicate in your letter, that tubes could not be installed in retreaded tubeless tires.; You ask whether the use if tubes in tubeless tires creates any safet problems. The agency is unaware of safety problems resulting from the use of tubes in tubeless tires. The NHTSA has determined, however, that tubes should not be placed in damaged tubeless tires in lieu of permanent repairs to those tires. This determination applies to those instances where tubes were used in tubeless tires after failure of the tire. In such cases, the tire casing could have been fractured or some other damage to the tire could have been sustained that would cause excessive wear of a tube inserted in the tire. Excessive wear of a tube could cause further tire failure. Therefore, tubes should not be inserted as a permanent repair of a damaged tubeless tire. Nothing in this finding, however, is intended to indicate that tubes in undamaged tubeless tires create safety problems. At this time the agency has no data to support your theory that the use of tubes in undamaged tubeless tires poses a safety problem.; Sincerely, Joan Claybrook |
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ID: aiam0898OpenMr. Donald P. Koch, Insurance Rate Analyst, Division of Insurance, Department of Commerce, State of Alaska, Pouch D - Juneau 99801; Mr. Donald P. Koch Insurance Rate Analyst Division of Insurance Department of Commerce State of Alaska Pouch D - Juneau 99801; Dear Mr. Koch: This is in reply to your letter of October 4, 1972, concerning th possible misuse by automobile insurers of vehicle identification numbers (VIN's) which would be available to them under a proposed amendment to NHTSA 'Defect Reports' regulations (49 CFR Part 573). You believe that the availability of such numbers could be the basis for some companies to refuse to write or to cancel insurance, and suggest that we notify state insurance commissioners of that possibility.; We appreciate your concern over the possible misuse of informatio obtained as a result of NHTSA regulations. However, we have no evidence at this time that such practices are occurring, and we believe it inappropriate, without evidence, to take action which raises the implication of impropriety on the part of the insurance industry. Of course, if we find evidence of misuse of information obtained as a result of NHTSA regulations, we will take steps to remedy the situation.; Your letter and our response have been placed in Docket 69-31, whic concerns the reporting of VIN's. We appreciate your writing to us regarding this matter.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0309OpenMr. Eisuke Niguma, Manager, Export Vehicle Engineering Dept., Toyo Kogyo Co., LTD., 6047 Fuchu-Machi, Aki-Gun, Hiroshima 730- 91, Japan; Mr. Eisuke Niguma Manager Export Vehicle Engineering Dept. Toyo Kogyo Co. LTD. 6047 Fuchu-Machi Aki-Gun Hiroshima 730- 91 Japan; Dear Mr. Niguma: This is in response to your letter of March 16, 1971, requestin interpretations of several provisions of the Defect Report Regulations, 49 CFR Part 573.; You ask whether a quarterly report containing the information specifie by section 573.5(b) concerning quarterly motor vehicle production must be submitted for calendar quarters during which no defect notification campaign is conducted. This interpretation is correct. A quarterly report containing the production figures and such other information as may be required by section 573.5 must be submitted for each calendar quarter.; You ask whether the first quarterly report required to be submitte pursuant to section 573.5 need cover only the period from August 16, 1971 (the effective date of the regulation) to September 30, 1971. This interpretation is correct.; Finally, you ask whether the term 'submit', as used in section 573.4(b) and 573.5(a), means 'send'. This interpretation is generally correct. The requirements in these sections for the submission of the defect information and quarterly reports would be satisfied by mailing the reports so that they are postmarked within the specified period of time. For example, defect information reports that are mailed to NHTSA must be postmarked not more than 5 working days after a defect in a vehicle has been determined to be safety- related. However, hand-delivered defect information reports must be received by NHTSA not more than 5 working days after such determination.; Please write if we can be of further assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0546OpenMr. H. H. Damman, Marketing Administration Manager, Manitowoc Engineering Company, 500 South 16th Street, P. O. Box 70, Manitowoc, WI 54220; Mr. H. H. Damman Marketing Administration Manager Manitowoc Engineering Company 500 South 16th Street P. O. Box 70 Manitowoc WI 54220; Dear Mr. Damman: I apologize for the delay in answering your letter regarding Part 566 Manufacturer Identification and Part 567, Certification. You describe the machines you manufacture and ask whether you are a final-stage manufacturer within the meaning of the regulation and therefore required to submit information regarding your products.; Part 566 and 567 apply to manufacturers of motor vehicles and moto vehicle equipment to which a motor vehicle safety standard applies. 'Motor vehicle' is defined in the National Traffic and Motor Vehicle Safety Act as 'any vehicle driven or drawn by mechanical power for use on the public streets, roads, and highways. ; Since the truck cranes you describe appear from the information yo provide us to have a primary purpose of transporting the cranes on public highways, you are considered a manufacturer of motor vehicles and thus you are covered by Parts 566 and 567. Because you 'mount the crane upperworks and outrigger assemblies to the carrier' you are a final-stage manufacturer as defined in Part 568, Vehicles Manufactured in Two or More Stages, and are required to submit information to us under these regulations. As a manufacturer of motor vehicles you are also required to submit information under Part 573, Defect Reports.; I enclose copies of Parts 566, 567, 568, and 573 for your reference. have also attached a description of Government Printing Office documents services which cover NHTSA rulemaking developments.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0552OpenMr. H. H. Damman, Marketing Administration Manager, Manitowoc Engineering Company, 500 South 16th Street, P. O. Box 70, Manitowoc, WI 54220; Mr. H. H. Damman Marketing Administration Manager Manitowoc Engineering Company 500 South 16th Street P. O. Box 70 Manitowoc WI 54220; Dear Mr. Damman: I apologize for the delay in answering your letter regarding Part 566 Manufacturer Identification and Part 567, Certification. You describe the machines you manufacture and ask whether you are a final-stage manufacturer within the meaning of the regulation and therefore required to submit information regarding your products.; Part 566 and 567 apply to manufacturers of motor vehicles and moto vehicle equipment to which a motor vehicle safety standard applies. 'Motor vehicle' is defined in the National Traffic and Motor Vehicle Safety Act as 'any vehicle driven or drawn by mechanical power for use on the public streets, roads, and highways.`; Since the truck cranes you describe appear from the information yo provide us to have a primary purpose of transporting the cranes on public highways, you are considered a manufacturer of motor vehicles and thus you are covered by Parts 566 and 567. Because you 'mount the crane upperworks and outrigger assemblies to the carrier' you are a final-stage manufacturer as defined in Part 568, Vehicles Manufactured in Two or More Stages, and are required to submit information to us under these regulations. As a manufacturer of motor vehicles you are also required to submit information under Part 573, Defect Reports.; I enclose copies of Parts 566, 567, 568, and 573 for your reference. have also attached a description of Government Printing Office documents services which cover NHTSA rulemaking developments.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1010OpenMr. Harvey M. Klein, Southwest Auto Auction, Inc., 2400 South Central Avenue, Phoenix, AZ 85040; Mr. Harvey M. Klein Southwest Auto Auction Inc. 2400 South Central Avenue Phoenix AZ 85040; Dear Mr. Klein: This is in reply to your letter of February 8, 1973, concerning th Federal Odometer Disclosure Requirements.; Our response to your three questions is as follows: (1) When a title is transferred several times from dealer to dealer each transferor must complete a disclosure form, not just the registered owner.; (2) Where several sales of a vehicle occur before March 1, 1973, and final sale of the same vehicle occurs after that date, only the final sale must have a disclosure form.; (3) If a transferor is not the original owner and does not know tha the indicated mileage is correct, yet does not *know* that the mileage is *incorrect*, he should state the indicated mileage reading without indicating that the mileage is unknown.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3398OpenMr. Seymour S. Weinblatt, Weinblatt & Knee, Counsellors at Law, Five Main Street, P.O. Box 985, Flemington, NJ 08822; Mr. Seymour S. Weinblatt Weinblatt & Knee Counsellors at Law Five Main Street P.O. Box 985 Flemington NJ 08822; Dear Mr. Weinblatt: This responds to your letter of March 5, 1981, in which you requested copy of Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials*. You are apparently trying to determine what types of glazing material may be used in 'caps' installed on truck bodies.; Safety Standard No. 205 specifies performance requirements for glazin materials to be used in motor vehicles and motor vehicle equipment. The standard incorporates by reference the American National Standard 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' Z26.1-1966 (ANSZ26). Copies of both standards are enclosed. ANS Z26 and Standard No. 205 list 13 'Items' or types of glazing that vary in terms of performance tests each item must pass and the locations in which each type of glazing may be used. While the meaning of the word 'cap' as used in your letter is somewhat unclear, we presume you are referring to a 'pickup cover.' A 'pickup cover' is defined in paragraph S4 of Standard No. 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. All 13 items of glazing may be used in pickup covers. However, some items (e.g., Item 6) may not be used in forward-facing windows, and others (e.g., Item 5) may not be used at levels requisite for driving visibility.; Certification and marking requirements for glazing are found i paragraphs S6.4 and S6.5 of Standard No. 205.; We hope you find this information helpful. Please contact this offic if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1303OpenMiss Adaline R. Crocker, 1547 Ala Wai Blvd. #329, Honolulu, HI 96815; Miss Adaline R. Crocker 1547 Ala Wai Blvd. #329 Honolulu HI 96815; Dear Miss Crocker: This is in response to your question about possible violations of th Motor Vehicle Information and Cost Savings Act by an owner who sells his vehicles without knowing for sure if the odometer reading is accurate.; The Act and implementing regulation require you to state the recorde mileage on the odometer, and tell your buyer if you know that the recorded mileage is wrong. It appears from your letter that you have some reason to suspect the validity of the present reading. If on the basis of the facts available to you, you conclude that the reading is probably wrong, you should caution your buyer by indicating on the odometer mileage statement that the true mileage is unknown.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2676OpenMs. Gail Burnette, Koons Leasing Inc., 30 Hillwood Avenue, Falls Church, VA 22046; Ms. Gail Burnette Koons Leasing Inc. 30 Hillwood Avenue Falls Church VA 22046; Dear Ms. Burnette: This responds to your September 12, 1977, telephone request to Roge Tilton of my staff concerning the applicability of the new Federal school bus safety standards to buses used to transport children to and from day care centers.; The National Highway Traffic Safety Administration (NHTSA) ha previously determined that day care center operators may not have been aware that their buses would fall within the ambit of the new standards. Therefore, the NHTSA has temporarily exempted these buses from the requirements. The agency is considering, however, extension of the standards to buses operated by these facilities. I am enclosing a letter in which the agency has detailed its reasons for the temporary exclusion of day care center buses from the new school bus safety standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1233OpenMr. Louis May, President, Sate-lite Mfg. Company, 6545 W. Irving Park Road, Chicago, Illinois 60634; Mr. Louis May President Sate-lite Mfg. Company 6545 W. Irving Park Road Chicago Illinois 60634; Dear Mr. May: This is in response to your petition of July 26, 1973, to modify th water immersion requirements of Standard 125, *Warning devices*, and the grounds that the test is more severe than typical weather conditions. The standard requires immersion of the device for 2 hours in water at a temperature of 100 degrees F. without warpage or separation of the reflective material from the support material.; Your reference to the device as a flare and to its immersion in 5 fee of water for an indefinite period makes it unclear whether you are referring to the standard as it will be effective on January 1, 1974. The final rule balanced the likelihood of water damage against numerous other considerations including cost and reuse. The 2-hour immersion requirement detailed above is intended to ensure that the device is undamaged and reuseable after an exposure to rain during any emergency deployment. In contrast, the 12-hour spray test of Standard No. 108 which you suggest as an alternative is used for reflex reflectors which are permanently mounted on a vehicle and are subject to regular and long exposure to blowing water. That spray test does not adequately simulate the relatively short but severe exposure to which a warning device would be subject in a steady rain. It is in such adverse weather conditions, of course, that the use if the device will be most important.; For these reasons, your petition is denies on the grounds tha preservation and reuse of the device justify the immersion requirement. Thank you for your interest in developing a functional warning device standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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.