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: nht89-1.36OpenTYPE: INTERPRETATION-NHTSA DATE: 03/13/89 FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA TO: ROBBIE FOLINO-NAZDA -- ATTORNEY-IN-FACT FRITZ COMPANIES, INC. TITLE: NONE ATTACHMT: LETTER DATED 12/19/88 FROM ROBBIE FOLINO NAZDA TO FRANK E. YOUNG -- FDA; OCC 3132 PRODUCT ANIMAL WARNING DEVICE TEXT: Dear Mr. Folino-Nazda: We have received a copy of your letter of December 19, 1988, to Commissioner Young of the Food and Drug Administration, forwarded to us by the Consumer Product Safety Commission. You have asked whether the "vehicle safety device" you described (with sam ples enclosed) are subject to any restrictions which would prevent importation of the device. The device provides an "ultrasonic animal warning." At a speed "over 30 mph air flow produces a high pitch whistle which animals try to avoid." It is designed for owner installation on "bumpers, grills, fenders, mirrors and roofs" of motor vehicles. Bec ause the device is intended solely as an accessory to motor vehicles, it is an item of motor vehicle equipment subject to the jurisdiction of this agency under the National Traffic and Motor Vehicle Safety Act. However, there are no Federal motor vehicle safety standards that apply to this type of equipment. You should also be aware that if the device's manufacturer ("manufacturer" includes both the maker as well as any importer for resale) or this agency were to determine that the device contains a safety-related defect, importers of this foreign-made devic e would be required by the Vehicle Act to recall the device and remedy the defect or replace the device without charge. We are returning your samples to you. Sincerely, |
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ID: nht91-1.3OpenDATE: 01/01/91 EST FROM: Stephen Mamakas -- AIR Inc. TO: To whom it may concern TITLE: None ATTACHMT: Attached to letter dated 5-13-91 from Paul Jackson Rice to Stephen Mamakas (A37; Std. 208; VSA 108(a)(2)(A)) TEXT: We are starting a company which will be repairing deployed air bags. We would like to know what are the Federal Standards we require to comply with. |
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ID: nht93-2.31OpenDATE: March 27, 1993 FROM: Carl W. Ruegg -- President, Carlo International, Inc. TO: Niel Eisner -- Assistant General Council, U.S. Department of Transportation, NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-18-93 from John Womack to Carl W. Ruegg (A41; Part 568; Part 592; VSA 102(3)) TEXT: We intend to ship car parts from the Philippines to the U.S. We need to know the legal definition of a vehicle that comes within the scope of D.O.T. regulations. We assume a part such as fender or other body parts do not. For instance we may wish to ship some parts partially assembled such as chassis and body assembly or perhaps chassis and body plus front & rear axle transmissions. These parts and partial assembly's would be sold as kits for conversion to electric vehicle. |
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ID: nht93-2.32OpenDATE: March 27, 1993 FROM: Carl W. Ruegg -- President, Carlo International, Inc. TO: Niel Eisner -- Assistant General Council, U.S. Department of Transportation, NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-18-93 from John Womack to Carl W. Ruegg (A41; Part 568; Part 591; VSA 102(3)) TEXT: We intend to ship car parts from the Philippines to the U.S. We need to know the legal definition of a vehicle that comes within the scope of D.O.T. regulations. We assume a part such as fender or other body parts do not. For instance we may wish to ship some parts partially assembled such as chassis and body assembly or perhaps chassis and body plus front & rear axle transmissions. These parts and partial assembly's would be sold as kits for conversion to electric vehicle. |
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ID: nht89-1.20OpenTYPE: INTERPRETATION-NHTSA DATE: 02/14/89 FROM: RAYMOND F. BRADY -- RODNEY D. MCGALLIARD TO: NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION OFFICE OF CHIEF COUNSEL TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 03/13/89 FROM ERIKA Z. JONES TO RAYMOND F. BRADY, REDBOOK A33(2), PART 572.3; LETTER DATED 12/16/88 FROM RAYMOND F. BRADY TO NHTSA TEXT: Dear Chief Counsel: I would like to know the status of your response to two letters I sent recently regarding limousines. I have attached copies of the letters, which were mailed on December 16 and 19, 1988. As you can see, one of the letters is a Freedom of Informatio n Act request, which requires your office's response within ten (10) days. Please let me know immediately how soon I can expect your response to these letters. Sincerely, |
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ID: 77-3.15OpenTYPE: INTERPRETATION-NHTSA DATE: 06/30/77 FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA TO: Matt Kolb TITLE: FMVSR INTERPRETATION TEXT: This responds to your April 18, 1977, letter asking whether our regulations pertaining to truck-camper loading apply to trucks designed to haul fifth-wheel trailers. Truck manufacturers are required to supply information pertaining to the cargo weight rating and longitudinal limits for the center of gravity of those vehicles capable of accommodating slide-in campers (Code of Federal Regulations, Volume 49, Part 575.103, Truck-camper loading). Slide-in camper is defined as "a camper having a roof, floor, and sides, designed to be mounted on and removable from the cargo area of a truck by the user." The purpose of this information requirement is to lessen the possibility of vehicle overloading. Since fifth-wheel trailers do not fall within the definition of slide-in camper, the regulations pertaining to truck-camper loading do not apply to vehicles designed to haul these trailers. |
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ID: nht90-2.68OpenTYPE: INTERPRETATION-NHTSA DATE: 06/01/90 FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL TO: PETER KOPANON -- DIRECTOR, REGISTRY OF MOTOR VEHICLE INSPECTION MASSACHUSETTS TITLE: NONE TEXT: This follows up on the recent telephone call from Ms. Fujita of my staff concerning our October 1985 cover letter to you. That letter enclosed a copy of a May 10, 1982 letter from NHTSA to Mr. Martin Chauvin on the applicability of our school bus safety standards to vehicles used by day care centers. As Ms. Fujita informed you, our cover letter mistakingly summarized the Chauvin letter as stating that day care centers are considered to be "schools" within the meaning of the Vehicle Safety Act. The co rrect iteration of the Chauvin letter is that NHTSA has said day care centers are not considered to be schools. I regret any inconvenience caused by our error. Please contact us if you have any questions. |
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ID: nht90-3.10OpenTYPE: Interpretation-NHTSA DATE: July 10, 1990 FROM: John D. Dingell -- Chairman, Subcommittee on Oversight and Investigations, U.S. House of Representatives TO: Jerry R. Curry -- Administrator, NHTSA TITLE: None ATTACHMT: Attached to letter dated 1-9-90 from Mehdi Rowghani to Taylor Vinson; Also attached to letter dated 4-9-90 from Stephen P. Wood to Mehdi Rowghani; Also attached to letter dated 2-15-91 from Paul Jackson Rice to John D. Dingell (A37; Std. 214) TEXT: Enclosed are two letters provided to the Subcommittee regarding the Federal Motor Vehicle Safety Standard No. 214. If the reply of the National Highway Traffic Safety Administration is accurate, it is troubling. I request your review. Does the law now prohibit or prevent its application to replacement parts of foreign and domestic vehicles? If not, could it be interpreted to apply? Please explain. I request your reply within 30 days after receipt of this letter. |
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ID: nht95-7.30OpenTYPE: INTERPRETATION-NHTSA DATE: October 24, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Jonathan P. Reynolds, Esq., -- Cosco, Inc. TITLE: NONE ATTACHMT: ATTACHED TO 9/20/95 LETTER FROM JONATHAN P. REYNOLDS TO DEIRDRE FUJITA TEXT: 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. |
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ID: nht95-4.65OpenTYPE: INTERPRETATION-NHTSA DATE: October 24, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Jonathan P. Reynolds, Esq., -- Cosco, Inc. TITLE: NONE ATTACHMT: ATTACHED TO 9/20/95 LETTER FROM JONATHAN P. REYNOLDS TO DEIRDRE FUJITA TEXT: 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 Exp ress 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. |
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.