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: nht94-1.73OpenTYPE: Interpretation-NHTSA DATE: March 9, 1994 FROM: Doug Bereuter -- U.S. House of Representatives TO: Howard Smolkin -- Acting Administrator, NHTSA TITLE: None ATTACHMT: Attached to letter dated 4/12/94 from Christopher A. Hart to Doug Bereuter (A42; Part 303) TEXT: I am writing to convey my continuing intense interest in the National Highway Traffic Safety Administration's rulemaking concerning compressed natural gas vehicle fuel systems and fuel containers. As I have made absolutely clear to you and other Departm ent of Transportation officials, ANY FURTHER DELAYS IN THE COMPLETION OF THE RULEMAKING SIMPLY WILL NOT BE TOLERATED. Every day that goes by without a final rule creates further hardship for Brunswick Corporation and its employees. CLEAR PROGRESS ON TH IS MATTER IS IMPERATIVE! Let me know the status of the rulemaking. |
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ID: nht68-2.19OpenDATE: 06/07/68 FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA TO: Elgin Sweeper Company TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of April 17 requesting either 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 the 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. |
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ID: nht89-2.40OpenTYPE: INTERPRETATION-NHTSA DATE: 07/24/89 FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL TO: GAY M. ARTHUR TITLE: NONE ATTACHMT: LETTER DATED 04/20/89 FROM GAY M. ARTHUR TO TAYLOR VINSON; OCC 3447 TEXT: Dear Ms Arthur: This is in reply to your letter to Taylor Vinson of this Office. You have asked if "detachable, lighted novelty items are legally allowable on passenger cars," specifically "for the exterior roof." You appear to have in mind an item of aftermarket equipment, that is to say, an item which is not original equipment on a car, but one that the vehicle owner purchases during the course of his ownership. There is no restriction under Federal law as to r oof-mounted novelty items if they are installed by the vehicle owner. If they are installed by a manufacturer, distributor, dealer, or motor vehicle repair business, they are permissible as long as they do not render inoperative, in whole or in part, eq uipment that is installed pursuant to a Federal motor vehicle safety standard. For example, if installation of the novelty light affected the wiring and hence the performance of lighting equipment installed on the vehicle by its manufacturer, that would be a "rendering inoperative" within the meaning of the prohibition. Use of the novelty light would be determined by the laws of a State in which it is operated. We are unable to advise you on State laws, and suggest that, for further information, you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. Sincerely, |
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ID: nht93-7.16OpenDATE: October 7, 1993 FROM: Donald E. Schmitz -- Engineering Manager, Featherlite Mfg., Inc. TO: Howard M. Smolkin -- Acting Administrator, NHTSA TITLE: None ATTACHMT: Attached to letter dated 11/16/93 from John Womack to Donald E. Schmitz (OCC-9204) TEXT: This letter addresses the TTMA, September 8, 1993 Recommended Practice on Trailer Conspicuity Systems. Featherlite Trailers will begin applying the conspicuity tape to the trailer's bottom rail as shown in the attached sketches. The bottom rail is the most practicable tape location on our trailers since it provides a smooth, splice free surface and is not closer that 15 inches from the ground. Therefore it is as close as practicable to 49 inches from the ground. Featherlite will assume our interpretation is correct and will begin applying this tape as described above and in the attached sketches unless we receive a response from your office within ten days. |
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ID: 20072.ztvOpenMr. Stephen F. Gund Dear Mr. Gund: This is in reply to your email of May 25, 1999, to Taylor Vinson of this Office. You would like a statement from us "that it is OK for the dealer to disconnect or turn off the daytime running lights" on your Olds Aurora. We are pleased to be responsive to your request. I enclose copies of letters on this subject that we sent to Paul J.M. Angrisano, III, on August 29,1996, and September 30, 1996. This interpretation is still in effect. This interpretation states that a motor vehicle dealer may disconnect daytime running lamps, or install an on/off switch, without violating Federal law. If you have further questions, you may call Mr. Vinson at 202-366-5263. Sincerely, |
1999 |
ID: nht71-2.26OpenDATE: 04/13/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Toyo Kogyo Co. Ltd. TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of March 16, 1971, requesting interpretations of several provisions of the Defect Report Regulations, 49 CFR Part 573. You ask whether a quarterly report containing the information specified 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 submitted 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 sections 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. |
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ID: nht91-4.43OpenDATE: July 8, 1991 FROM: Charles Saunders-White TO: Steve Kratzke -- Office of Chief Counsil, NHTSA TITLE: None ATTACHMT: Attached to letter dated 8-7-91 from Paul Jackson Rice to Charles Saunders-White (A38; VSA 103) TEXT: I am building a 50's style streetrod. I am using an original manufactured body and frame from a 1929 ford roadster. The state of Wisconsin will title this car as a 'Reconstructed Vehicle'. It must conform to all 1929 state and federal laws as to required equipment. I have two questions. First, in 1929 were there any federal standards, laws, or requirements that automobiles must be equipped with: 1) Fenders, 2) Bumpers, 3) hoods, 4) Doors, 5) windshield wipers (powered or manual). My second question is, between 1920 and 1934 were there any federal laws requiring the above items on any autos in addition to my question about 1929 cars? |
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ID: 1985-02.13OpenTYPE: Interpretation-NHTSA DATE: April 11, 1985 FROM: A. Ruiz Thiery -- President, Companhia Nacional de Borrachas, S.A.R.L.; Herminio Pereira -- Managing Director, Companhia Nacional de Borrachas, S.A.R.L. TO: NHTSA TITLE: None TEXT: We hereby designate and appoint the undermentioned corporation as our agent on whom service of all processes, notices, orders, decisions and requirements may be made for us and on our behalf as provided in section 110 (e) of the National Traffic and Motor Safety Act 1966 (80 stat. 718) INTERSCEPTRE TYRES INC. 6830 Roswell Road Suite 1-A ATLANTA, GA 30328. This designation shall remain in effect until withdrawn or replaced by ourselves. Our full legal name is CNB - COMPANHIA NACIONAL DE BORRACHAS, SARL., and our mailing address and principal place of business is RUA AZEVEDO COUTINHO, 39-1, 4100 PORTO, PORTUGAL. Our products bear the brand "CAMAC". We, the undersigned, certify that this designation is legally valid in form and binding under the laws of Portugal, our corporate by-laws and all other requirements covering the making of the designation at the time and place where it is made. We declare acceptance of the above designation for and on behalf of INTERSCEPTRE TYRES INC. J. Holt (President) |
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ID: 9292Open Mr. Herman Myburgh FAX 1-615-459-0289 Dear Mr. Myburgh: This responds to your FAX of November 8, 1993, asking for an interpretation of the conspicuity mounting height requirement of Standard No. 108 as it applies to your curtainsided trailer. You state that there are no retroreflective tapes that can be affixed to the curtain material itself and ask whether the conspicuity material may be placed on the frame rail. The answer is yes. As you note, in that location the material will be located within the range of mounting heights specified in recent amendments to Standard No. 108. For your information, submissions to the docket during the course of this rulemaking indicate that there are conspicuity materials that can be affixed to curtain materials. Some trailer manufacturers may prefer this avenue to compliance. Sincerely,
John Womack Acting Chief Counsel ref:108 d:11/22/93 |
1993 |
ID: nht70-2.36OpenDATE: 11/24/70 FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA TO: Mercedes-Benz of North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of September 29, 1970, concerning the 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 retention components on the C-111 doors must conform to it. As Rocks and retention components on passenger car side doors that meet the description in the first sentence of S4, they are clearly within the ambit 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. |
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.