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: nht72-5.36OpenDATE: 04/11/72 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Edward L. Adams TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of February 17, 1972, in which you ask for information on safety specifications as they would apply to travel trailers. All trailers manufactured for use on the public roads are required to meet applicable Federal Motor Vehicle Safety Standards (FMVSS) in effect on the date of manufacture. Part 567 of Title 49 of the Code of Federal Regulations requires that a certification label be attached to the left front of the trailer. A specific conformity statement is required, among other things, on the label. A copy of the regulation is enclosed. We do not have information at this time that would add to the article in the St. Louis Post Dispatch. Thank you for your interest in the program of the National Highway Traffic Safety Administration. |
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ID: nht72-6.11OpenDATE: 01/28/72 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Ernest Holmes Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letters of September 15, 1971, and January 10, 1972, requesting that information received by NHTSA pursuant to section 573.5(b) of the Defect Reports regulations (49 CFR Part 573), concerning manufacturers' quarterly production figures be kept confidential pursuant to section 112(e) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1401(e)). Manufacturers' quarterly production figures submitted pursuant to section 573.5(b) will be kept confidential if the manufacturer so requests. This will be true except in those cases where the NHTSA determines that disclosure is necessary to carry out the purposes of the National Traffic and Motor Vehicle Safety Act. In the event it is decided to make public such information the NHTSA will, before release of the information, notify the manufacturer in question. Please accept our apologies for the delay in responding to your letters. |
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ID: nht72-2.30OpenDATE: 03/01/72 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Motor Coach Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 7, 1972, to Mr. Lewis Owen of this Office concerning clarification of the requirements of paragraph S4.7 of Standard No. 108. A label similar to that shown on the enclosure to your letter would meet the certification requirements of paragraph S4.7.2 of Standard No. 108 as specified in the amendment published in the Federal Register on January 12, 1972, (copy enclosed). "Associated equipment" covered by Standard No. 108 includes only that for which requirements are specified in the Standard. The only serviceable item, in addition to the completed assemblies, for which certification is required is a plastic part such as a (Illegible Word), which must meet the requirements of paragraph S4.1.2. The requirement for replacement equipment to conform to Standard No. 108 was applicable to items manufactured on and after January 1, 1972. Certification of items received by your Service Parts Department after January 1, 1972, is therefore acceptable. |
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ID: GF004215OpenGiovanni Nifosi, Engineering Department Manager Dear Mr. Nifosi: This responds to your e-mail of June 14, 2004, to George Feygin of my staff. You ask whether Standard J590b adopted by the Society of Automotive Engineers (SAE) or S5.1.1.20 of the Federal Motor Vehicle Safety Standard (FMVSS) No. 108 specify the motorcycle turn signal lamp voltage drop limit. By way of background, the National Highway Traffic Safety Administration (NHTSA) issues FMVSSs applicable to new motor vehicles and motor vehicle equipment. Chapter 301 of Title 49 of the United States Code, "Motor Vehicle Safety" (49 U.S.C. 30101 et seq.), establishes a "self-certification" process under which all motor vehicle manufacturers, including motorcycle manufacturers, are responsible for certifying that their vehicles meet all applicable Federal motor vehicle safety standards. The Federal standard applicable to lighting equipment on motorcycles is FMVSS No. 108, Lamps, Reflective Devices and Associated Equipment. FMVSS No. 108 incorporates by reference many SAE standards including those regulating turn signal lamps. S5.1.1.19 of FMVSS No. 108 specifically incorporates the voltage drop and durability requirements in SAE J590b, Automotive Turn Signal Flashers (October 1965). However, S5.1.1.20 of FMVSS No. 108 provides an exception to the voltage drop requirement in SAE J590b. Specifically, S5.1.1.20 limits the voltage drop to .8 volts as opposed to .4 or .45 volts specified in SAE J590b. Accordingly, the voltage drop limit in S5.1.1.20 supercedes the voltage drop requirements in SAE J590b. I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992. Sincerely, Jacqueline Glassman ref:108 d.7/19/04 |
2004 |
ID: nht74-4.38OpenDATE: 01/11/74 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Tire Distributors Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of December 19, 1973, concerning a standardized form for tire registration. The National Highway Traffic Safety Administration is aware of the problem that some dealers face in having to complete a multiplicity of tire registeration forms. Therefore, we issued on March 8, 1973, a proposal for a universal registration form such as you have suggested. We have received comments on our proposal from interested parties, and are currently revising it for issuance as a final rule in the spring of this year. As to your specific question, whether you may adopt your own "universal" form, there is nothing in our regulations which would preclude your doing so. While Section 574.7 requires manufacturers, brand name owners, and retreaders to provide a means by which the registration data may be recorded and Section 574.3 requires distributors and dealers to submit the required information to the manufacturers, there is no requirement that the dealers utilize the manufacturers' forms. I have enclosed a copy of our proposed rule concerning universal tire registration forms. You should be aware that the proposal is now going through revisions based on comments received and the final rule may differ in some respects. ENC. |
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ID: nht72-2.41OpenDATE: 02/28/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Dayton Steel Foundry Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 2, 1972, in which you asked whether the temperature range specified in S6.2.6 of Motor Vehicle Safety Standard No. 121 was an initial temperature range or a range applicable throughout the stop. In the new issuance of the standard, published in the February 24, 1972, issue of the Federal Register, the section has been amended to make it clear that the range is the range of initial brake temperature on each stop. |
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ID: nht67-1.26OpenDATE: 12/22/67 FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA TO: General Motors Technical Center TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of November 13, 1967, in which approval of a dynamic inertia load test procedure, as set forth in paragraph s4.3 of Federal Motor Vehicle Safety Standard 206, was requested. This is to advise that the proposed procedure, as outlined in the enclosure to the referenced letter, is approved for the transverse inertia load portion of the standard test requirements. Thank you for your continued cooperation in achievement of our mutual goals in motor vehicle safety. |
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ID: 12200.ztvOpen Mr. Don Weidman Dear Mr. Weidman: This responds to your letter of July 9, 1996, asking for an interpretation of paragraph S7.8.5 of Federal Motor Vehicle Safety Standard No. 108. The sentence that concerns you reads as follows: "When activated in a steady-burning state, headlamps shall not have any styling ornament or other feature, such as a translucent cover or grill, in front of the lens." You ask whether a transparent cover is permissible. No cover of any sort is permissible. The standard is absolute in its prohibition and merely uses translucent covers and grills as examples of items that may not be placed in front of a lens. The reason for the prohibition is to preserve original photometric performance of the headlamps, and to prevent deterioration from interference by grills, or which might occur over time from moisture, scratching, and other environmental factors that can affect headlamp covers, whether translucent or transparent. If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, Samuel J. Dubbin Chief Counsel ref:108 |
1996 |
ID: 9653Open Mr. Michinori Hachiya Dear Mr. Hachiya: This responds to your request for an interpretation of the theft prevention standard (49 CFR part 541) as it would apply to high theft passenger motor vehicles and their replacement parts from model year (MY) 1996 and thereafter. Because the agency has not yet published regulations for MY 1996 high theft lines and thereafter, we are unable to answer your specific questions. As a result of the "Anti Car Theft Act of 1992" (ACTA), certain changes must be made to the theft prevention standard. In its October 25, 1993 semiannual regulatory agenda, NHTSA listed its proposed rulemakings to implement the ACTA. (See 58 FR 56734 et seq.) In a Federal Register document of January 6, 1994 (59 FR 796), NHTSA stated it intended that the new ACTA-mandated procedures apply to high theft lines beginning in MY 1996. As indicated in the October 1993 semiannual agenda, NHTSA will shortly issue a notice of proposed rulemaking to amend the theft prevention standard. We believe the NPRM will address the issues you raise. If the NPRM does not address them, you will be able to discuss any questions you may have in your comments on the rulemaking submitted to NHTSA during the public comment period. If you have any questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:541 d:4/l/94 |
1970 |
ID: nht73-3.18OpenDATE: 01/30/73 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Oshkosh Truck Corporation TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of January 4, 1973, in which you ask for our confirmation of your interpretation of Part 567 and Part 568 of Title 49 of the Code of Federal Regulations that would place the responsibility for certification on the user in those instances where he is the final-stage manufacturer. Paragraph 567.5 of Title 49 of the Code of Federal Regulations Requirements for Manufacturers of Vehicles Manufactured in Two or More Stages, specifies that(Illegible Words) final-stage manufacturer, . . . of a vehicle manufactured in two or more stages shall affix to each vehicle a label . . . ." Therefore, and users who are also manufacturers would be required to affix the label. If you have further questions, we will be pleased to answer them. |
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.