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: 11253petOpen Jonathan P. Reynolds, Esq. Dear Mr. Reynolds: This responds to your letter asking us to confirm that we consider your submission, dated August 3, 1995, as a timely petition for reconsideration of a final rule published July 6, 1995 (Docket No. 74-09, Notice 42). You enclosed a copy of a Federal Express document to show that your submission was received by NHTSA within the time period provided for such petitions under 49 CFR '553.35. The Federal Express document, which shows the signature of an agency employee, supports a finding that your submission was timely filed. NHTSA is processing your submission as a petition for reconsideration of the subject rule. If you have any further questions about your petition, please contact Ms. Deirdre Fujita of my staff at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:553 d:10/24/95 |
1995 |
ID: nht89-2.91OpenTYPE: INTERPRETATION-NHTSA DATE: AUGUST 31, 1989 FROM: J. BRETTSCHNEIDER -- ROBERT BOSCH GMBH TO: RICHARD VAN IDERSTINE -- DOCKET SECTION, NHTSA TITLE: PERFORMANCE OF THE IMPACT TEST ACCORDING SAE J1383 ATTACHMT: ATTACHED TO LETTER DATED 3-29-90 TO J. BRETTSCHNEIDER, ROBERT BOSCH GMBH, FROM STEPHEN P. WOOD, NHTSA. TEXT: According to the above-mentioned SAE Standard (recommended practice), Section 4.10.3, the impact test has to be performed ... along the mechanical axis ... SAE Standard J 579, Section 2.14 defines the mechanical axis as ... perpendicular to the aiming plane through the geometric center of the lens. Now the questions arise - where is the geometric center of a lens without aiming pads? - where is the geometric center of a lens which moreover covers two compartments, one for the lower beam and one for the upper beam? Please give us your advice. Thanking you in advance. |
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ID: nht95-3.53OpenTYPE: INTERPRETATION-NHTSA DATE: July 25, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: David A. Lowell -- Engineering Manager, Bankhead Enterprises, Inc. TITLE: NONE ATTACHMT: ATTACHED TO 6/8/95 LETTER FROM DAVID A. LOWELL TO NHTSA CHIEF COUNSEL (OCC 10978) TEXT: Dear Mr. Lowell: This responds to your letter of June 8, 1995, asking for an interpretation of Motor Vehicle Safety Standard No. 108. Specifically, your company manufactures "stinger steered automobile transport trailers" as defined by 23 CFR 658.5, paragraphs (k) Tractor or Truck Tractor, (m) Automobile Transporters, and (n) Single-steered combination. Your company currently mounts ta illamps, turn signal lamps, and clearance lamps on the back of the truck tractor. It is your understanding of paragraphs S5.1.1.1 and S5.1.1.2 of Standard No. 108 that "these items do not seem to be necessary." For purposes of Standard No. 108, types of motor vehicles are defined by 49 CFR 571.3(b), a regulation of the National Highway Traffic Safety Administration, rather than 23 CFR 658.5, a regulation of the Federal Highway Administration. Under 571.3(b), th e towing portion of your combination vehicle is a "truck", rather than a "truck tractor." A "truck" is defined, in pertinent part, as a motor vehicle "designed primarily for the transportation of property." A "truck tractor" is a "truck designed primaril y for drawing other motor vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn." The photographs you enclosed show that the towing portion of Bankhead's combination vehicle is designed to carry motor vehicles, and may do so without the attachment of the trailer, hence it is a "truck." It is constructed to carry a load other than a part of the trailer, hence it is not a "truck tractor." Accordingly, Bankhead's towing vehicle may not avail itself of the truck tractor lighting options of paragraphs S5.1.1.1 and S5.1.1.2 of Standard No. 108. Your understanding of these sections as they relate to truck tractors meeting the definition of 571.3(b) is generally accurate. However, no provision of Standard No. 108 permits either the elimination or the relocation of taillamps from truck tractors. Because Bankhead's product is operated in interstate commerce, it must also conform to the safety regulations of the Federal Highway Administration (49 CFR part 393). This is to advise you that the Office of Motor Carrier Standards has reviewed this let ter and concurs in it. If you have any further questions, you may refer them to Taylor Vinson of this office (202) 366-2992. |
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ID: nht95-5.32OpenTYPE: INTERPRETATION-NHTSA DATE: July 25, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: David A. Lowell -- Engineering Manager, Bankhead Enterprises, Inc. TITLE: NONE ATTACHMT: ATTACHED TO 6/8/95 LETTER FROM DAVID A. LOWELL TO NHTSA CHIEF COUNSEL (OCC 10978) TEXT: Dear Mr. Lowell: This responds to your letter of June 8, 1995, asking for an interpretation of Motor Vehicle Safety Standard No. 108. Specifically, your company manufactures "stinger steered automobile transport trailers" as defined by 23 CFR 658.5, paragraphs (k) Tractor or Truck Tractor, (m) Automobile Transporters, and (n) Single-steered combination. Your company currently mounts taillamps, turn signal lamps, and clearance lamps on the back of the truck tractor. It is your understanding of paragraphs S5.1.1.1 and S5.1.1.2 of Standard No. 108 that "these items do not seem to be necessary." For purposes of Standard No. 108, types of motor vehicles are defined by 49 CFR 571.3(b), a regulation of the National Highway Traffic Safety Administration, rather than 23 CFR 658.5, a regulation of the Federal Highway Administration. Under 571.3(b), the towing portion of your combination vehicle is a "truck", rather than a "truck tractor." A "truck" is defined, in pertinent part, as a motor vehicle "designed primarily for the transportation of property." A "truck tractor" is a "truck designed primarily for drawing other motor vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn." The photographs you enclosed show that the towing portion of Bankhead's combination vehicle is designed to carry motor vehicles, and may do so without the attachment of the trailer, hence it is a "truck." It is constructed to carry a load other than a part of the trailer, hence it is not a "truck tractor." Accordingly, Bankhead's towing vehicle may not avail itself of the truck tractor lighting options of paragraphs S5.1.1.1 and S5.1.1.2 of Standard No. 108. Your understanding of these sections as they relate to truck tractors meeting the definition of 571.3(b) is generally accurate. However, no provision of Standard No. 108 permits either the elimination or the relocation of taillamps from truck tractors. Because Bankhead's product is operated in interstate commerce, it must also conform to the safety regulations of the Federal Highway Administration (49 CFR part 393). This is to advise you that the Office of Motor Carrier Standards has reviewed this letter and concurs in it. If you have any further questions, you may refer them to Taylor Vinson of this office (202) 366-2992. |
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ID: 0978Open Mr. David A. Lowell Dear Mr. Lowell: This responds to your letter of June 8, 1995, asking for an interpretation of Motor Vehicle Safety Standard No. 108. Specifically, your company manufactures "stinger steered automobile transport trailers" as defined by 23 CFR 658.5, paragraphs (k) Tractor or Truck Tractor, (m) Automobile Transporters, and (n) Single-steered combination. Your company currently mounts taillamps, turn signal lamps, and clearance lamps on the back of the truck tractor. It is your understanding of paragraphs S5.1.1.1 and S5.1.1.2 of Standard No. 108 that "these items do not seem to be necessary." For purposes of Standard No. 108, types of motor vehicles are defined by 49 CFR 571.3(b), a regulation of the National Highway Traffic Safety Administration, rather than 23 CFR 658.5, a regulation of the Federal Highway Administration. Under 571.3(b), the towing portion of your combination vehicle is a "truck", rather than a "truck tractor." A "truck" is defined, in pertinent part, as a motor vehicle "designed primarily for the transportation of property." A "truck tractor" is a "truck designed primarily for drawing other motor vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn." The photographs you enclosed show that the towing portion of Bankhead's combination vehicle is designed to carry motor vehicles, and may do so without the attachment of the trailer, hence it is a "truck." It is constructed to carry a load other than a part of the trailer, hence it is not a "truck tractor." Accordingly, Bankhead's towing vehicle may not avail itself of the truck tractor lighting options of paragraphs S5.1.1.1 and S5.1.1.2 of Standard No. 108. Your understanding of these sections as they relate to truck tractors meeting the definition of 571.3(b) is generally accurate. However, no provision of Standard No. 108 permits either the elimination or the relocation of taillamps from truck tractors.
Because Bankhead's product is operated in interstate commerce, it must also conform to the safety regulations of the Federal Highway Administration (49 CFR part 393). This is to advise you that the Office of Motor Carrier Standards has reviewed this letter and concurs in it. If you have any further questions, you may refer them to Taylor Vinson of this office (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:108 d:7/25/95
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1995 |
ID: 77-2.50OpenTYPE: INTERPRETATION-NHTSA DATE: 06/10/77 FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA TO: Embassy of the Socialist Republic of Romania TITLE: FMVSR INTERPRETATION TEXT: This is to acknowledge receipt of your letter of April 5, 1977, requesting that the Office of the Economic Counselor be designated as the agent for Uzina de Anvelope Danubiana, upon whom process may be served in the United States. Section 551.45 of Title 49 of the Code of Federal Regulations specifies that the agent be a permanent resident of the United States. It may be an individual, firm, or domestic corporation. The Office of the Economic Counsel, as part of the Embassy, cannot be classified as a permanent resident of the United States. It is not a firm or domestic corporation within the meaning of 49 CFR Part 551.45. Therefore, we will have to request that Uzina de Anvelope Danubiana designate another individual as its agent, pursuant to section 110(e) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1399(e)).
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ID: nht95-3.19OpenTYPE: INTERPRETATION-NHTSA DATE: June 17, 1995 FROM: Colleen Grant TO: Office of the Chief Counsel, -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO 9/14/95 LETTER FROM JOHN WOMACK TO COLLEEN GRANT (A43; RED BOOK 2; STD. 208) TEXT: Dear Sir/Ms: An official of the Nevada Department of Motor Vehicles has questioned whether my vehicle is street-legal based on the fact it does not have a shoulder-harness safety restraint system. The vehicle is: 1974 Chevrolet Blazer with: fiberglass removable roof original lap-belts restraint system (still functional) Inquiries at local GM dealers about retro-fitting the vehicle have been non-productive. GM does not make a shoulder harness system for this model because there is no place to safely mount it. In the event of a roll-over, we were told the roof could come apart and thereby lose any restraint system mounted to the roof. My request: Your written opinion as to whether or not this vehicle is street-legal. |
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ID: 9595Open Mr. Don Vierimaa Dear Mr. Vierimaa: This responds to your FAX of January 11, 1994, to Pat Boyd of this agency requesting an interpretation of the trailer conspicuity requirements of Standard No. 108. In the future, please address your requests for interpretations to the Chief Counsel. You have asked "may a manufacturer install a 4 inch (100 mm) wide retrofrelective sheeting instead of 2 inch (50 mm) sheeting on the side of new trailers?" Paragraph S5.7.1.3(d) of Standard No. 108 states that retroreflective sheeting shall have a width of 50 mm (Grade DOT-C2), 75 mm (Grade DOT-C3), or 100 mm (Grade DOT-C4). Paragraph S5.7.1.4.2(a), as amended on October 6, 1993 (58 FR 52021 at 52026), sets forth the requirements for application of retroreflective sheeting to the side of trailers. Without elaboration, it simply identifies it as "a strip of sheeting." This means that the manufacturer of the trailer is permitted his choice of Grade DOT-C2, -C3, or -C4 material. Therefore, a manufacturer may install sheeting that has a width of 100 mm on the side of a trailer. Sincerely,
John Womack Acting Chief Counsel ref:108 d.2/7/94 |
1994 |
ID: nht94-8.27OpenDATE: February 7, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Don Vierimaa -- Truck Trailer Manufacturers Association TITLE: None ATTACHMT: Attached to FAX dated 1/11/94 from Don Vierimaa to Pat Boyd (OCC-9595) TEXT: This responds to your FAX of January 11, 1994, to Pat Boyd of this agency requesting an interpretation of the trailer conspicuity requirements of Standard No. 108. In the future, please address your requests for interpretations to the Chief Counsel. You have asked "may a manufacturer install a 4 inch (100 mm) wide retroreflective sheeting instead of 2 inch (50 mm) sheeting on the side of new trailers?" Paragraph S5.7.1.3(d) of Standard No. 108 states that retroreflective sheeting shall have a width of 50 mm (Grade DOT-C2), 75 mm (Grade DOT-C3), or 100 mm (Grade DOT-C4). Paragraph S5.7.1.4.2(a), as amended on October 6, 1993 (58 FR 52021 at 52026), sets forth the requirements for application of retroreflective sheeting to the side of trailers. Without elaboration, it simply identifies it as "a strip of sheeting." This means that the manufacturer of the trailer is permitted his choice of Grade DOT-C2, -C3, or -C4 material. Therefore, a manufacturer may install sheeting that has a width of 100 mm on the side of a trailer. |
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ID: nht95-2.76OpenTYPE: INTERPRETATION-NHTSA DATE: May 11, 1995 FROM: Dennis T. Snyder, Esq. TO: David Coleman -- NHTSA Administrator TITLE: NONE ATTACHMT: ATTACHED TO 6/14/95 LETTER FROM JOHN WOMACK TO DENNIS T. SNYDER (PART 566) TEXT: Dear Mr. Coleman, I have a client engaged in the manufacture of completed heavy duty dump trucks, vans and road tractors. The client obtains chassis-cabs previously produced by an intermediate manufacturer and adds dump bodies, van bodies or fifth wheels. The uniquen ess of the clients business is that the manufacturing work is performed on used chassis-cabs. For example, a chassis-cab which has been used as a road tractor for an indeterminate period may be manufactured into a dump truck by the removal of the fifth wheel and addition of a dump truck body. The question is whether the client is a "final stage manufacturer" within the meaning of the National Traffic and Motor Vehicle Safety Act and, specifically, Parts 566, 567 and 568 of the regulations. (49 CFR 566, 567 and 568.) Stated another way, is the client relieved of an obligation to perform the certifications which would otherwise be required under Parts 567 and 568 because he is performing his manufacturing operations using used chassis-cabs rather than new ones? |
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.