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: nht90-2.47OpenTYPE: Interpretation-NHTSA DATE: May 18, 1990 FROM: David W. Holscher -- General Sales Manager, Dreyer & Reinbold, Inc. TO: Taylor Vinson -- Legal Council, NHTSA TITLE: None ATTACHMT: Attached to letter dated 8-31-90 from P.J. Rice to D. Holscher (Std. 108; VSA 108(a)(2); A36) TEXT: I am writing to you from Dreyer & Reinbold Infiniti in Indianapolis, IN. I am General Sales Manager here and one of our customers has requested a factory design rear spoiler on their new Infiniti. The rear spoiler contains a 3rd brake light which will i lluminate during brake application. This would be an addition to the existing rear window brake light. The rear window brake light is not removable because of damage to the interior of the car which would cost a large amount of money to repair. I need something in writing in regard to standard 108 to allow me to understand that by installing this spoiler, I am not violating any federal NHTSA regulations. I had talked on the phone to one of your people and they suggested that I write you for fi nal verification of this fact. Your help is greatly appreciated and you can contact me at this phone number 317-573-0222. Enclosed please find an addressed stamped envelope. |
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ID: nht81-1.13OpenDATE: 02/11/81 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Toyoda Gosei Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT:
Mr. Katsuhiko Yokoi Assistant Manager - Tech. Dept. Toyoda Gosei Co., Ltd. 1, Nagahata, Ochiai, Haruhi-mura Nishikasugai-gun Aichi-pref., 452 JAPAN Dear Mr. Yokoi: The answers to the questions in your letter of January 20, 1982, are "yes" to both questions. 1. The "adjacent layers" referenced in Federal Motor Vehicle Safety Standard (FMVSS) No. 106, paragraphs S7.3.7, are (a) the inner tube and braided layer and (b) the braided layer and outer tube. 2. The adhesion requirements are met if both the tensile strengths measured between (a) the inner tube and braided layer and (b) that between the braided layer and the outer cover are equal to or greater than 8 lbs/inch as determined using the FMVSS No. 106 procedure. It should be noted that the 8 lbs/inch value is an absolute minimum value as indicated in paragraph S8.6.4(a) standard. A copy of FMVSS No. 106 is included for your information. Sincerely, Vernon G. Bloom Safety Standards Engineer Enclosure FMVSS No. 106 |
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ID: nht93-3.31OpenDATE: May 3, 1993 FROM: John Rhein -- Manager, Product Engineering, Fisher-Price, Inc. TO: John Womack -- Chief Council, Chief Council's Office, NHTSA COPYEE: D. Campbell; P. Mitchell; M. Weatherston TITLE: None ATTACHMT: Attached to letter dated 4/14/94 from John Womack to John Rhein (A42; Std. 213) TEXT: Please find this letter to be a request for an official interpretation of the Standard 213 Amendment Docket No. 74-09: Notice 26 (Child Restraint Registration). It has been Fisher-Price's experience that registration cards of the new format are being returned but are sometimes illegible. Because the card does not specify "to print", consumers sometimes fill in the card in a manner which is illegible (please note examples provided). The inability to interpret the consumer information has created problems in our registration recording system. Fisher-Price would like to amend the child restraint registration card to encourage the consumer to PRINT required information. Prior to doing so, we seek NHTSA's concurrence that the existing docket maintains sufficient latitude to allow specified changes. Specifically, we would like to enlarge the consumer address space of the card, specify "(please print)" and use open box spaces as opposed to horizontal lines (please see example provided). Please take our concerns into consideration and inform us whether the Register will allow specified amendments. We feel that these changes will greatly facilitate our registration program. We anxiously await your response. Thank you for your consideration.
(Sample registration cards omitted.) |
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ID: nht73-5.7OpenDATE: 12/05/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: University Club Tower TITLE: FMVSR INTERPRETATION TEXT: I am enclosing a copy of Part 580, Odometer Disclosure Requirements, 49 CFR 580, issued under the authority of D 408 of the Motor Vehicle Information and Cost Savings Act, which like all regulations of this and other Federal agencies is published in the Federal Register. This daily publication can be obtained at a price of $ 45.00 per year from: Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. Interpretation of the regulation to date has established that the odometer disclosure statement can be made in any format which includes the required information. Commercially printed forms, handwritten forms, and forms included in the "buyer's order form" used by dealers have all been approved. The government does not print forms but the regulation includes an example of an acceptable format. If you have further questions, please write again. ENC. |
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ID: nht74-5.9OpenDATE: 01/18/74 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: John W. Davis; House of Representatives TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of December 17, 1973, on behalf of Ms. Judith Davis, who has suggested the incorporation of the Federal odometer form into the bill of sale as a means of reducing paperwork in motor vehicle transactions. Although the Federal odometer disclosure regulation requires the seller to give the buyer several items of information that we consider essential to adequate disclosure, the regulation does not require the use of a separate form. If Ms. Davis is able to include the required information in the bill of sale used by the Rome Auto Auction, she may do so. Information items that are common to the bill of sale and the disclosure statement, such as the model and make of the vehicle, would not have to be stated twice. Enclosures |
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ID: 0322Open Mr. Tom Determan Dear Mr. Determan: This is in reply to your letter of September 2, 1994, to Taylor Vinson of this Office. You have inquired about the mounting height requirements specified in Motor Vehicle Safety Standard No. 108 for side marker lamps and reflex reflectors installed on tank trucks. You understand that "side marker lamps must be mounted at any height above 15" from ground level, and reflex reflectors must be mounted between 15" and 60" from ground level." You are correct. Standard No. 108 (Tables II and IV) specifies that side reflex reflectors on trucks shall be mounted not less than 15 inches nor more than 60 inches above the road surface, and that side marker lamps must be mounted not less than 15 inches above the road surface. This means that side marker lamps may be placed at heights greater than 60 inches. Noting your thought that enforcement personnel are mistakenly applying requirements for trailers to tank trucks of your customers, I would like to say that the requirements are the same for trailers, except that, under Table II which applies to trailers whose overall width is 80 inches or more, the rear side marker lamps are subject to the same 60-inch height limitation as the side reflex reflectors. I hope that this is helpful in resolving your problem. Sincerely,
Philip R. Recht Chief Counsel ref:108 d:12/7/94
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1994 |
ID: nht72-2.6OpenDATE: 11/02/72 FROM: F. ARMSTRONG FOR ROBERT L. CARTER -- NHTSA TO: Pine Ridge Nursery TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of October 11, 1972, regarding the installation of LP gas tanks in a small van to serve as a "recreational vehicle." There is no Federal regulation regarding installation of LP gas tanks on the exterior of recreational vehicles. There is a voluntary standard on recreational vehicles issued by the National Fire Protection Association (NFPA), 60 Batterymarch Street, Boston, Massachusetts 02110. Identified as NFPA Standard No. (Illegible Word). This standard includes requirements for fuel supply systems based on the use of LP gas. You may wish to refer to the standard for safety guidance in installing your system. I appreciate your interest in motor vehicle safety. SINCERELY, PINE RIDGE NURSERY Oct. 11 1972 National Highway Traffic Safety Adm. Dept. of Transportation Gentlemen: I am equipping a small van as a "Recreational Vehicle". I have been told by a commercial builder of these vehicles that a new Federal regulation will become effective Jan. 1, 1973 prohibiting installation of LP gas tanks on the exterior of such vehicles. If he is correct, I will have to revise my plans. Can you inform me if such a regulation exists or will be (Illegible Word)? If I can obtain a copy of the text or pertaient paragraph of such rule (if one exists) I shall take steps to comply. Thank you. Ray Brown. |
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ID: nht67-1.34OpenDATE: 12/13/67 FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA TO: Metropolitan Cycle Association TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of December 4 to Mr. Boaz, Public Information Office, Federal Highway Administration, inquiring about the applicability to motorcycles and scooters of the proposed Department of Transportation-Department of the Treasury customs regulations. The regulations do apply to motorcycles and scooters imported into the United States, but not to similar type vehicles imported into or manufactured in Canada for use in Canada. I am enclosing a copy of the regulations for your information. |
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ID: nht88-1.15OpenTYPE: INTERPRETATION-NHTSA DATE: 01/13/88 FROM: L.F. ROLLIN -- COMMANDER COMMERCIAL AND TECHNICAL SERVICES SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL TO: THOMAS A. COZ -- LAW DEPARTMENT NORTH AMERICAN VAN LINES TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 08/24/89 FROM STEPHEN P. WOOD -- NHTSA TO THOMAS A. COZ -- NORTH AMERICAN VAN LINES; REDBOOK A34; STANDARD 108; LETTER DATED 04/28/89 FROM THOMAS A. COZ -- NORTH AMERICAN VAN LINES TO NHTSA, RE HIGH MOUNTED TRAILER STOP LAMPS/TURN SIGNALS; OCC 3469 TEXT: Dear Mr. Coz: This is in response to your December 30, 1987, letter requesting an "Experimental Devices Permit" for high mounted stop lamp/turn signals which are installed on some North American Van Lines trailers. No experimental device permit is necessary since these supplemental lamps are currently permitted by the California Vehicle Code. However, these lamps are in violation of Federal Motor Vehicle Safety Standard 108 (FMVSS 108). FMVSS 108 specifies mounti ng heights for brake lights (not less than 15 inches nor more than 72 inches) and turn signals (not less than 15 inches nor more than 83 inches) above the level roadway surface. Both the trailer specifications and the trailer picture you provided show t he lamps to be mounted above the mounting heights specified in FMVSS 108. The National Highway Traffic Safety Administration (NHTSA) confirmed that all brake lights and turn signals installed by a manufacturer of vehicles must conform to the FMVSS 108 mounting requirements. NHTSA does not differentiate between required or "su pplemental" lights on trailers. The FMVSS 108 restrictions on mounting do not apply to equipment installed by the owner. If you have any questions, please contact Mr. Ellis Hirst our staff engineer for clarification. Very truly yours, |
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ID: nht89-2.65OpenTYPE: INTERPRETATION-NHTSA DATE: 08/09/89 FROM: T. CHIKADA -- MANAGER, AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT., STANLEY ELECTRIC CO., LTD. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA TITLE: INTERPRETATION OF NEW FMVSS NO. 108 ATTACHMT: ATTACHED TO LETTER DATED 3-15-90 TO T. CHIKADA, STANLEY ELECTRIC CO., LTD., FROM STEPHEN P. WOOD, NHTSA; [A35; STD. 108]; ALSO ATTACHED TO FILE MEMO DATED 7-21-89 TO DOCKET SECTION FROM RICHARD L. VAN IDERSTINE, NHTSA; [85-15-N08-011] TEXT: Please give us your advice on our Interpretation of New FMVSS No. 108. Q1) We think the configuration of each indicator which prescribe in New FMVSS No. 108 S7.7.5.2 a).(1) iii) are as follows. A. Direct reading analog indicator B. Remote reading indicator (Graphics omitted) We would like to know whether our interpretation is correct or not. If it is not correct, what typical configuration will be for each type? Q2) Is protective cover described in S7.7.2 in FMVSS No. 108 equal to the cover to protect spirit level which is one of the component of VHAD? Your prompt reply will be highly appreciated. |
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.