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: aiam4036OpenEnere H. Levi, Esq., Assistant Attorney General, Office of the Attorney General, American Samoa Government, Pago Pago, American Samoa 96799; Enere H. Levi Esq. Assistant Attorney General Office of the Attorney General American Samoa Government Pago Pago American Samoa 96799; Dear Mr. Levi: Thank you for your letter of September 18, 1985, to Mr. Hal Paris o this agency requesting information on the bumper requirements that apply to small trucks. You also asked about the effect of our standards on vehicles sold in your Territory. Your letter was referred to my office for reply. I hope the following discussion answers your questions.; Under the authority of the National Traffic and Motor Vehicle Safet Act (15 U.S.C. 1381 *et seq*.) and the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901 *et seq*.), we have issued Part 581, *Bumper Standard* (49 CFR Part 581), a copy of which is enclosed. The Part 581 standard applies only to passenger motor vehicles. Section (2)(1) of the Cost Savings Act (15 U.S.C. 1901(1)) defines a 'passenger motor vehicle' as a vehicle designed to carry 12 persons or less, except a motorcycle or a truck not designed primarily as a passenger carrier, but is instead designed primarily to carry cargo. Therefore, under Federal law, a small utility truck may be sold without any rear bumper.; Both the Vehicle Safety Act and the Cost Savings Act apply to moto vehicles manufactured in or imported into the United States. Both Acts define the term 'State' to include American Samoa (15 U.S.C. 1391(8) and 1901(16)). Therefore, the requirements of the Part 581 standard would apply to vehicles sold in American Samoa.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1142OpenMr. David J. Humphreys, RVI Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC, 20006; Mr. David J. Humphreys RVI Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: This is in reply to your letter of April 27, 1973, regarding th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to mattress covers. You ask whether 'mattress covers', listed under Paragraph S4.1 of the standard, includes a cover 'that is used generally to enclose a mattress for cleanliness or sanitary purposes *or* only the ticking which encloses the mattress filling or core *or* both items . . .'; We consider that mattress ticking and a cover enclosing a mattress fo sanitary purposes are both 'mattress covers' within the meaning of the standard, and both items must meet the requirements of the standard.; Thank you for sending us the copy of your memorandum, 'Department o Commerce Standards Issued Under the Flammable Fabrics Act.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2711OpenMr. William C. Warden, Jr., McElwee, Hall & McElwee, 906 B. Street Rear, North Wilkesboro, NC 28659; Mr. William C. Warden Jr. McElwee Hall & McElwee 906 B. Street Rear North Wilkesboro NC 28659; Dear Mr. Warden: This responds to your recent letter asking whether the Holly Farm Service Center would qualify as a 'motor vehicle repair business' as that term is defined in Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1381, et seq.). This is an elaboration of our letter to you of November 8, 1977.; According to your description, the Holly Farms Service Center onl repairs and maintains vehicles owned by Holly Farms, except for an occasional repair as an accommodation to another company whose vehicle has broken down on the premises.; Section 108(a)(2)(A) specifies that 'motor vehicle repair business means; >>>'any person who holds himself out to the public as in the busines of repairing motor vehicles or motor vehicle equipment for compensation.'<<<; Based on your description of the function of the Holly Farms Servic Center, it would not be considered a 'motor vehicle repair business' for purposes of the Vehicle Safety Act. The fact that the Service Center occasionally repairs another company's vehicles does not change our interpretation, provided the Service Center does not hold itself out to the public as being in the business of making such repairs for compensation.; Since the Service Center would not be considered a 'motor vehicl repair business', it could alter the braking systems on Holly Farms' vehicles without violating the 'render inoperative' provisions of Section 108(a)(2)(A).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2848OpenMs. Anna Racanelli, Assistant General Manager, Nippondenso Company, Ltd., 16 Henderson Drive, W. Caldwell, NJ 07006; Ms. Anna Racanelli Assistant General Manager Nippondenso Company Ltd. 16 Henderson Drive W. Caldwell NJ 07006; Dear Ms. Racanelli: This is in reply to your letter of August 10, 1978, to Mr. Vinson o this office requesting confirmation of interpretations of Paragraph S4.7 of Motor Vehicle Safety Standard No. 108.; This confirms your interpretations. Paragraph S2, *Application* states the coverage of the standard: t specified vehicle types 'and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies' i.e. those vehicles manufactured on or after January 1, 1972. The equipment items listed in Tables I and III are required motor vehicle lighting equipment, and any item manufactured as a replacement for one of these items that has been original equipment on 1972 or later model vehicles, must meet Standard No. 108's requirements and be so certified.; Paragraph S4.7 allows certification by means of a DOT symbol placed o the item itself. No specific design or size is required. The manufacturer may certify by other means as well, specifically those set forth for all equipment items covered by a standard, in Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403): 'a label or tag on [the] item or on the outside of a container in which such item is delivered'. We would view an indelible stamp on the container as 'a label' within the meaning of Section 114 if Nippondenso wished to certify by this means.; I have no other suggestions regarding use of the DOT symbol, excep that it should be of a size and in a location sufficient to readily identify the item as meeting Federal requirements, thereby avoiding any possible misunderstanding.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3460OpenMr. Charles Schamblin, Flag-It Signaling Device Co., P.O. Box 1709, Bakersfield, CA 93302; Mr. Charles Schamblin Flag-It Signaling Device Co. P.O. Box 1709 Bakersfield CA 93302; Dear Mr. Schamblin: The National Transportation Safety Board has forwarded for reply you letter of June 10, 1981, asking whether the 'Flag-It Automobile Signaling Device' would be legal to use according to your new regulations . . . .'; Requirements for equipment use are not established by the Federa government but by the individual State in which a vehicle is registered.; Our agency within the Department of Transportation establishes th Federal motor vehicle safety standards which apply to vehicle and equipment manufacturers. Your device consists of reflectors which hang beneath the front and rear bumper. They are not covered by our standard on reflectors (Standard No. 108 *Lamps, Reflective Devices and Associated Equipment*) nor would their installation appear to impair the effectiveness of lighting equipment required by Standard No. 108, which could raise a question as to their legality.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2243OpenMr. Jack Manne, Engineering Department, Almac Plastics Inc., 47-42 37th Street, Long Island City, NY 11101; Mr. Jack Manne Engineering Department Almac Plastics Inc. 47-42 37th Street Long Island City NY 11101; Dear Mr. Manne: This is in reply to your letter of February 26, 1976, to Mr. Guy Hunte of my staff, concerning the use of Lucite AR (plastic) glazing materials in rear windows of buses.; You state that a rubber harness has been designed to allow the plasti glazing to be inserted into the rear window openings of the bus. You further state that once inserted into the rubber harness, the glazing can be easily pushed out and therefore would fall within the definition of readily removable windows. Thus, plastic glazing could be used in such windows.; It is not clear whether the rear bus window you described in you letter would be classified as a readily removable window as defined in Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. However, if the glazing can be pushed out as easily as you say, it is clear that it would not meet the window retention requirements specified in FMVSS No. 217, Bus Window Retention and Release.; Standard No. 205 specifies requirements for glazing and the vehicl locations in which various types of glazing may be used. The standard prohibits the use of plastic glazing in rear windows of buses unless they are readily removable as defined in the standard. However, in response to a petition submitted by General Motors Corporation, we are currently preparing a Notice of Proposed Rule Making (NPRM) that would amend the standard to permit the use of plastic glazing in all bus windows except windshields and windows to the immediate left and right of the driver. We anticipate that this NPRM will be published in the *Federal Register* in the near future.; A copy of Standard No. 205 and Standard No. 217 were previously maile to you. If you have any questions, please do not hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0953OpenFiles; Files; Your memorandum of November 27, 1972, concerning non-tabulated value for tire inflation pressures.; In response to the above-captioned memorandum, we, in coordination wit the Chief Counsel's Office, have concluded that Standard No. 110 does not preclude the use of odd-numbered tire inflation pressures on the placard required by S4.3 of Standard No. 110, and that the standard does not prohibit interpolation of the load values of the Standard No. 109 tables for purposes of compliance testing.; The relevant language of Standard No. 110 is in paragraph S4.3 an S4.3.1:; >>>S4.3 *Placard*. A placard, permanently affixed to the glov compartment door or an equally accessible location, shall display the --; (c) vehicle manufacturer's recommended cold tire inflation pressure fo maximum loaded vehicle weight and, subject to the limitations of S4.3.1, for any other manufacturer-specified vehicle loading condition...; S4.3.1 No inflation pressure other than the maximum permissibl inflation pressure may be specified unless --; (b) The vehicle loading condition for that pressure is specified, and (c) The tire load rating from Table I of S571.109 for the tire at tha pressure is not less than the vehicle load on the tire for that vehicle loading condition.<<<; There is nothing in the standard which specifically required th inflation pressure to be one actually listed (even-numbered) in the Tables of Standard No. 109. While paragraph S4.3.1(c) of Standard NO.(sic) 110, in referring to the load rating found in the table, arguably implies such a requirements, we cannot, without more specific language, read into the standard that recommended inflation pressures must be even-numbered. The mere fact that the specific tire load rating will not be printed in the table, however, does not preclude enforcement of the placard requirement. Because interpolation of values in a table is accepted engineering practice, we conclude that it is reasonable to interpolate such values in the Tables of Standard No. 109, for purposes of enforcing Standard No. 110, where manufacturers have specified odd-numbered inflation pressures.; Elwood T. Driver |
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ID: aiam4666OpenMrs. Tonda Anderson 1134 Ross Avenue St. Paul, MN 55106; Mrs. Tonda Anderson 1134 Ross Avenue St. Paul MN 55106; Dear Mrs. Anderson: Thank you for your letter asking for an explanatio of the legal requirements that would apply to a product you would like to market. Before discussing the substantive issues raised in your letter, I would like to respond to your request that NHTSA not publicly disclose the details of this product. We hereby grant this request. Your letter, which contains the details of this product will not be made available to the public. As Steve Kratzke of my staff explained to you in a telephone conversation on September 19, all of our interpretation letters are available to the public. Thus, this letter will be publicly available. However, I will not discuss any specific features of your product in this letter. Your letter indicated that your proposed product would alter the alignment of the shoulder belt to increase comfort for the person wearing the shoulder belt. This agency has discussed the legal requirements that might apply to devices that realign the shoulder belt in a February 11, 1988 letter to Mr. Roderick Boutin. I have enclosed a copy of that letter for your information. You should also note that your proposed product would be considered 'motor vehicle equipment,' within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966. I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on such manufacturers, and tells how to get copies of the relevant laws and regulations. I hope this information is helpful. If you need any further information or have some questions, please feel free to contact Mr. Kratzke at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures; |
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ID: aiam4966OpenMr. R. Wendell Moore Acting Chief Counsel for Advocacy U.S. Small Business Administration Washington, D.C. 20416; Mr. R. Wendell Moore Acting Chief Counsel for Advocacy U.S. Small Business Administration Washington D.C. 20416; "Dear Mr. Moore: Thank you for your letter concerning a petition fo rulemaking on Federal Motor Vehicle Safety Standard No. 106, Brake Hoses. While your letter did not identify the petitioner by name, your concerns relate to issues raised in Philatron International's petition to the agency. Philatron requested that the National Highway Traffic Safety Administration (NHTSA) remove Standard No. 106's oil resistance requirement for 'air brake tubing.' Philatron believed that there was no safety need for the requirement and that it impeded new developments in technology. The petitioner asked that the agency conduct rulemaking to remove the requirement without first providing notice or seeking public comment. Your letter supports Philatron's petition. Further, it endorses the idea of our issuing an interim final rule which removes the oil resistance requirement from the standard, and then asks us to study the merits of the requirement, pending issuance of a final rule. This agency is, of course, sensitive to the concerns of small businesses and currently is carefully reviewing its regulations pursuant to the President's recent directive. As required by NHTSA's regulation for rulemaking petitions (49 CFR Part 552), we are evaluating Philatron's petition to determine whether there is a reasonable possibility that the requested order would be issued at the conclusion of a rulemaking proceeding. Please note that NHTSA views the issues and facts relevant to the petition as being more involved than the information available to you may suggest. In addition, please note further that, if a proceeding were commenced, it would be a normal notice and comment proceeding as required by the Administrative Procedure Act. We appreciate your interest in this matter and will carefully consider your views as part of the petition evaluation process. Sincerely, Jerry Ralph Curry"; |
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ID: aiam0602OpenMr. Y. Ishii, Manager, Technical Administration Section, Mitsubishi Motors Corporation, 33-8, 5-Chome, Shiba, Minato-Ku, P. O. Box 17, Takanawa, Tokyo, Japan; Mr. Y. Ishii Manager Technical Administration Section Mitsubishi Motors Corporation 33-8 5-Chome Shiba Minato-Ku P. O. Box 17 Takanawa Tokyo Japan; Dear Mr. Ishii: This is in reply to your letter of January 14, 1972, in which you as whether the vibrating paper cone of a cone-type radio speaker is required to meet the performance requirements of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You also ask whether the answer to this question depends upon whether the radio, although factory installed, is optional or standard equipment.; The relevant language of the standard as it is presently worded, i whether the cone is 'an interior material . . . designed to absorb energy on contact by occupants in the event of a crash' (S4.1). Whether or not the cone is within this language depends upon whether in fact it has been designed by the manufacturer for the stated purpose. It is of no consequence, further, whether the radio is standard or optional, if it is installed at the factory or before sale to the consumer. I would add that NHTSA presently has the above quoted language of S4.1 under review, and may modify it in future rulemaking which we expect to issue shortly.; In a conversation of February 4, 1972, it was indicated to Michae Peskoe of my staff that you had additional questions regarding the standard which you would submit to us in writing. You mentioned particularly whether a steering wheel would be subject to the standard. The answer, as in the case of the cone, is whether the manufacturer has designed it to be an energy-absorbing component.; We regret the delay in answering your letter, however, it was ou understanding that you would submit the aforementioned additional questions to us, and we would respond at that time to your letter of January 14. We have not received this additional correspondence from you.; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant 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.