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: nht73-6.5OpenDATE: 11/14/73 FROM: E. T. DRIVER -- NHTSA; SIGNATURE BY CHARLES A. BAKER TO: Browning-Ferris Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of October 26 to Mr. J. E. Leysath of this office concerning marker and signal lights on your Mack trucks. Federal Motor Vehicle Safety Standard No. 108 requires that front clearance and identification lamps be located as close as practicable to the top of the vehicle. Mounting these lamps on the top of the vehicles described in your letter does not appear to be practicable because of possible damage to the lamps. If mounting the lamps on the front vertical surface near the top is, in your determination, "as close to the top as practicable," then you have met the requirements of Standard No. 108. Mounting an additional side marker lamp (which you have identified as a corner clearance lamp) on each side of the cab, near the front and top of the cab, would not be prohibited by Standard No. 108. Turn signal lamps and hazard warning signal lamps mounted on the rear of the vehicle may be either red or amber. The color of these lamps was addressed in a Notice of Proposed Rule Making published in the Federal Register on October 25, 1972, (Docket 69-19; Notice 3). It was proposed that amber be eliminated as an optional color for these lamps, but no final decision has been made. |
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ID: nht95-2.89OpenTYPE: INTERPRETATION-NHTSA DATE: May 19, 1995 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Yvonne Roppel -- Liaison Officer, Title and Registration Services, State of Washington, Department of Licensing TITLE: NONE ATTACHMT: ATTACHED TO 3/27/95 LETTER FROM YVONNE ROPPEL TO PHILLIP RECKT (OCC 10223) TEXT: Dear Ms. Roppel: This is in response to your letter of March 27, 1995, in which you requested a written confirmation of the response by Dick Morse, Chief of the Odometer Fraud Staff of the National Highway Traffic Safety Administration ("NHTSA"), to your telephone inquir y concerning the Federal odometer disclosure law. You asked whether the lessor or the lessee is the proper person to sign the original title application and odometer disclosure in a state such as Washington, which shows the lessee as the registered owner on the title and requires the lessee to sign the title application at the dealership. You also noted that in most cases the yearly license renewal is mailed to the lessee, and that the registered owner or lessee is liable in any legal action involving the vehicle. Mr. Morse's response, that the lessee is the person who is responsible for acknowledging receipt of the odometer disclosure when the lessee is considered by the state to be the registered owner of the vehicle, is correct. If you have any further questions about the Federal odometer disclosure law, please write to this office at the above address, or call Eileen Leahy, an attorney on my staff, at 202-366-5263. |
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ID: nht73-4.42OpenDATE: 08/09/73 FROM: AUTHOR UNAVAILABLE; James E. Wilson; NHTSA TO: Truck Trailer Manufacturers Association TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of July 5, 1973, requesting a uniform location for trailer certification labels required by both the Hazardous Materials regulations (49 CFR @ 178.340-10) and NHTSA Certification regulations (49 CFR Part 567). You request that location be specified as the "forward half of the left side of the trailer." NHTSA Certification regulations, as you note, presently provide that the certification label for trailers must be placed on the "forward half of the left side of the vehicle" (49 CFR @ 567.4(d)). This requirement does not distinguish between the frame and the tank shell, and the reference to "vehicle" in the language of the provision is considered inclusive of both. The Certification regulations therefore appear to permit the location of the label that you request. I note, however, that drawings in your letter, those titled "Acceptable Locations of Certification Labels" and "Suggested Locations for Certification Labels", picture as an appropriate label location the front of the vehicle. This location is not permitted by the NHTSA Certification regulations, which clearly call for the label to be affixed to the vehicle "left side". While it is not clear whether you intended to request that the label be permitted to be affixed to the vehicle front, we do not find sufficient justification in your letter to depart from the existing requirements in this regard. |
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ID: nht75-5.12OpenDATE: 05/20/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Austrian Trade Delegation in the United States TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of April 21, 1975, inquiring as to whether voltage regulators are of safety-related significance and therefore subject to the requirements of Public Law 93-492. There are currently no motor vehicle safety standards regulating the performance of voltage regulators. However, under the National Traffic and Motor Vehicle Safety Act as amended (Pub. L. 93-492) the Secretary of Transportation is authorized to make a determination, in appropriate circumstances, that a motor vehicle or item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If he finds that a safety-related defect exists, the manufacturer must notify purchasers of the hazard and recall and remedy the defective vehicles. Therefore, even though voltage regulators are not the subject of a safety standard, they still must be designed so as not to contain safety-related defects. YOURS TRULY, AUSTRIAN TRADE DELEGATION IN THE UNITED STATES Richard D. Dyson Assistant Chief Counsel for Regulations Office of the Chief Counsel National Highway Traffic Safety Administration April 21, 1975 Subject: Interpretation of Public Law 93-492 On April 3, we wrote to you on behalf of the Austrian company Uher AG of Vienna, a manufacturer of electrical automobile components, regarding your opinion as to whether voltage regulators for automobiles are of safety related significance and would therefore be affected by the requirements of Public Law 93-492. We would very much appreciate your comments on this subject and thank you in advance for your kind assistance. Harald Klug Deputy Trade Delegate |
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ID: nht90-2.69OpenTYPE: Interpretation-NHTSA DATE: June 1, 1990 FROM: A. Roger Hirstein -- Industry Development Manager, 3M Commercial Graphics Div. TO: Taylor Vincent -- Legal Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 9-14-90 from P.J. Rice to A.R. Hirstein (A36; Std. 108) TEXT: One of our customers has asked for written verification that our SCOTCHLITE Diamond Grade Reflective Sheeting can be used in a red and white block pattern on the side of a trailer for conspicuity purposes and not be in violation of REG 108. It is our in terpretation that materials such as our SCOTCHLITE Reflective Sheeting can be used in addition to the requirements of REG 108 but not in place of. We would appreciate your review and written direction so we can meet our customer's request. |
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ID: nht73-5.25OpenDATE: 10/14/73 FROM: AUTHOR UNAVAILABLE; E. T. Driver for R. L. Carter; NHTSA TO: R. Debesson - E.T.R.T.O. TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your(Illegible Words) 71, dated September 14, 1973,(Illegible Word) that the(Illegible Words) designation in incorrectly stated in Appendix A of Standard No. 109, Table(Illegible Words) will be changed to(Illegible Words) will make the necessary correction in the next quarterly(Illegible Word) The National Highway Traffic Safety Administration(Illegible Words)(Illegible Lines) on or about October(Illegible Words) April 1, and July 1 of each year. It is anticipated that your(Illegible Words) will be published in the Federal Registra on or about January 1, 1974. The addition of(Illegible Words) designations to the table is accomplished through(Illegible Words) publication in the(Illegible Words)(Illegible Line)(Illegible Lines) pursuant to(Illegible Words) motor vehicle standards will be considered. |
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ID: nht71-1.14OpenDATE: APRIL 16, 1971 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Western Safety Devices Company TITLE: FMVSS INTERPRETATION TEXT: In response to your letter of March 10, 1971, to Mr. Douglas W. Toms, Administrator, National Highway Traffic Safety Administration, concerning Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems; Truck, Buses and Trailers, the following information is offered. 1. Standard No. 121 applies only to new vehicles manufactured on or after January 1, 1973. 2. Federal Motor Vehicle Safety Standard No. 121 does not preclude the use of a dashboard-mounted control for the tractor protection valve. 3. Standardization of a dashboard-mounted control valve is not contemplated at the present time. 4. A petition requesting reconsideration of the requirements for a parking brake control valve in S5.4.6 has been received and is being considered at the present time. The decision in response to this and other petitions will be published in the Federal Register in the near future. |
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ID: nht71-5.2OpenDATE: 11/17/71 FROM: AUTHOR UNAVAILABLE; J. W. Carson for E. T. Driver; NHTSA TO: Chrysler Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of November 4, 1971, to Mr. J. E. Leysath of this Office, concerning the maximum candlepower for taillamps as specified in Federal Motor Vehicle Safety Standard No. 108. Paragraph S5.1 of Standard No. 108 (35 FR, 16840, October 31, 1970) is quoted as follows: "S5.1 SAE Standards and Recommended Practices subreferenced by the SAE Standards and Recommended Practices included in Tables I and III and paragraphs S4.1.4 and S4.5.1 are those published in the 1970 edition of the SAE Handbook." Subreferenced SAE Standard J575, as published in the 1970 edition of the SAE Handbook, is the "d" revision (SAE J575d, August 1967). SAE Standard J575d specifies a maximum of 15 candlepower for a single compartment taillamp, 20 candlepower for a 2-compartment taillamp, and 25 candlepower for a 3-compartment taillamp. These maximum candlepower values are, therefore, applicable requirements under Standard No. 108 (35 FR, 16840, October 31, 1970). |
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ID: 10644Open Mr. Ralph T. Welch Dear Mr. Welch: This responds to your request for an interpretation whether the Federal Motor Vehicle Safety Standards (FMVSS) specify "the type of odometer" placed in a motor vehicle. As explained below, the FMVSS do not so specify. If an odometer is provided, its mileage may be stated in kilometers. Standard No. 101, Controls and displays, specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. Neither Standard No. 101 nor any other FMVSS specifies that an odometer be placed in a motor vehicle or that it register distance in miles, rather than kilometers. However, S5.3.1 (referencing Table 2 "Identification and Illumination of Displays") of Standard No. 101, specifies that if an odometer is provided and the odometer measures mileage in kilometers, the mileage must be stated as "KILOMETERS" or "km." I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely,
Philip R. Recht Chief Counsel ref:101 d:4/10/95
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1995 |
ID: nht90-2.72OpenTYPE: INTERPRETATION-NHTSA DATE: JUNE 3, 1990 FROM: MARGRET SCHMOCK -- ROBERT BOSCH GMBH TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO MARGARET SCHMOCK FROM STEPHEN P. WOOD; (A35; VSA 103(d)) TEXT: Could you please be so kind and answer me some questions about the FVMSS 108 and the CAC Title 13, Article 9. The amended FMVSS 108 says: S7.7.3 When a headlamp system is tested in a laboratory, the range of its vertical aim shall not be less than +/- 4 degrees ... S7.7.4 When a headlamp system is tested in a laboratory, the range of its horizontal aim shall not be less than +/- 2.5 degrees ... CAC says: The range of adjustment from the specified aim the lamp shall be at least +/- 4 degrees in both the vertical and horizontal directions. So my questions are: Does this mean that our headlamps still must have an adjustment range of +/- 4 degrees in horizontal direction, although the FMVSS 108 has been changed? Is it possible that the CAC meanwhile has been amended according to the FMVSS 108? Is it true that the CAC doesn't differ between auxiliary lamps and headlamps (in opposite to the FMVSS 108 that is only valid for headlamps)? Thanking you very much in advance for your actions.
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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.