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: nht95-4.61OpenTYPE: INTERPRETATION-NHTSA DATE: October 17, 1995 FROM: Jim Young -- Wheeled Coach TO: John Womack TITLE: FMVSS Compliance ATTACHMT: ATTACHED TO 11/17/95 LETTER FROM Samuel J. Dubbin to Jim Young (A43; Std. 108) TEXT: Wheeled Coach is an Ambulance manufacturer and is in need of a response to the following issues regarding customer specifications for options incorporated into, or in addition to FMVSS lighting. "Brake override circuit for rear facing warning lights." The rear warning lights flash as warning lights until the brakes are applied, at which time they become steady burn. This option is in addition to the standard brake lights. If this is acceptab le, should the lights be required to meet all requirements of stop lights? (ie.; maximum luminous intensity, color, etc...) Brake Enhancer" Standard or additional stop lights are made to flash on/off several times before going steady burn. "Back-up alert strobes" Rear facing high intensity strobe lights that are activated when the gearshift lever is placed into reverse gear. Taillight Flashers" Taillights or brake lights are flashed alternate to backup lights until brakes are applied, at which time they go steady burn. The option at times may be requested to only work of the rear doors on the ambulance are open. |
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ID: nht72-5.44OpenDATE: 06/16/72 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Egger Manufacturing Corporation TITLE: FMVSR INTERPRETATION TEXT: Mr. (Illegible Word) has asked me to reply to your letter of May 25, 1972, in which you request information regarding tire, wheel and axle capacities as set forth in the Code of Federal Regulations. I am enclosing Part 567 of the Code which was amended effective January 1, 1972. The amendments require, among other things, that gross axle weight ratings be applied to the certification label. The capacities of the wheel and tire would be calculated into those ratings by our definition of the term. "'Gross axle weight rating' (GAWR) (Illegible Word) the value specified by the vehicle manufacturer as the loaded weight on a single axle measured at the tire-ground interfaces . . . ." (emphasis added). I am also enclosing the following information that might be of interest to you: 1. Part 566 of Title 49 of the Code of Federal Regulations - Manufacturer Identification 2. Part 568 - Vehicles Manufactured in Two or More Stages 3. Part 573 - Defect Reports 4. Part 574 - Tire Identification 5. Notice of Publications (Illegible Word) 6. National Traffic and Motor Vehicle Safety Act If you have further questions, I will be pleased to answer them. |
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ID: nht95-7.26OpenTYPE: INTERPRETATION-NHTSA DATE: October 17, 1995 FROM: Jim Young -- Wheeled Coach TO: John Womack TITLE: FMVSS Compliance ATTACHMT: ATTACHED TO 11/17/95 LETTER FROM Samuel J. Dubbin to Jim Young (A43; Std. 108) TEXT: Wheeled Coach is an Ambulance manufacturer and is in need of a response to the following issues regarding customer specifications for options incorporated into, or in addition to FMVSS lighting. "Brake override circuit for rear facing warning lights." The rear warning lights flash as warning lights until the brakes are applied, at which time they become steady burn. This option is in addition to the standard brake lights. If this is acceptable, should the lights be required to meet all requirements of stop lights? (ie.; maximum luminous intensity, color, etc...) Brake Enhancer" Standard or additional stop lights are made to flash on/off several times before going steady burn. "Back-up alert strobes" Rear facing high intensity strobe lights that are activated when the gearshift lever is placed into reverse gear. Taillight Flashers" Taillights or brake lights are flashed alternate to backup lights until brakes are applied, at which time they go steady burn. The option at times may be requested to only work of the rear doors on the ambulance are open. |
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ID: nht89-1.22OpenTYPE: INTERPRETATION-NHTSA DATE: 02/17/89 FROM: PAUL WALKER -- SUNQUEST INC PRESIDENT TO: ERIKA Z. JONES -- CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/09/89 FROM ERIKA Z. JONES -- NHTSA TO PAUL WALKER, REDBOOK A33 [4]; INTERP 205; INTERP 302 TEXT: Dear Ms. Jones: A new product has been developed by this company, which we are being strongly encouraged by the U.S. Department of Commerce to export to the Middle East. The product is remote-controlled electronic automobile window shades. This product is targetted in itially to the Saudi Arabian market because of their extreme heat. The window shades protect the interior of the automobile, and automatically roll up when the ignition is turned on. They cannot be lowered while the engine is running. Technological support is provided to us by the Georgia Institute of Technology. Total production for the next two years will be for export only, because of the strong demand created by the extreme heat aforementioned. Saudi Arabia's Standards of Organization require a letter or statement from the appropriate U.S. agency stating that there is no objection to the product in the U.S. market if we export in large quantities. We would be pleased if you could supply this letter or direct us to the appropriate source. Your prompt reply will be greatly appreciated. Sincerely, |
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ID: nht93-5.26OpenTYPE: Interpretation-NHTSA DATE: July 20, 1993 FROM: Calin Moldovean -- Vehicle Technology Engineer, Automotive & Vehicle Technology Division, TUV America, Inc.; Signature by other (illegible) TO: John Womack -- Acting Chief, Counselor of the NHTSA TITLE: None ATTACHMT: Attached to letter dated 8/18/93 from John Womack to Calin Moldovean (A41; Std. 301; Redbook (2)) TEXT: I am in need of information on the legal requirements for the introduction, from Europe, of a new "after market" gas cap to the US market and any NHTSA legal and technical requirements in terms of proofs of compliance. Please send information to the address listed above, to my attention, or reply via Fax. Your help in this matter is greatly appreciated. |
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ID: nht92-3.19OpenDATE: 10/14/92 FROM: MICHAEL J. MOTZKIN, -- PRESIDENT, PIONEER PLUMBING, INC TO: MR. PAUL JACKSON RICE -- OFFICE OF CHIEF COUNSEL ATTACHMT: ATTACHED TO LETTER DATED 12-14-92 FROM PAUL J. RICE TO MICHAEL J. MOTZKIN (A40; STD. 105) TEXT: I am trying to locate any government regulations pertaining to automotive brake drums and brake rotors. Most specifically, is there any government regulation which requires brake drums and brake rotors not be milled passed manufacturers specifications? Secondly, is there any government regulation which requires manufacturers of automotive brake drums and brake rotors to stamp the manufacturers specification on the drum or rotor? Currently I am involved in a legal action in the Small Claims Court and need any documentation or interpretation of the Federal Safety Act of 1964 pertaining to automotive brake drums and brake rotors. To date I have researched these two questions in depth and have been unable to find any documentation. The State of Arizona does not have a vehicle safety inspection program and therefore the information I am lookingfor is not readily available. |
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ID: 1984-3.18OpenTYPE: INTERPRETATION-NHTSA DATE: 08/31/84 FROM: Frank Berndt; NHTSA TO: Kenneth Guthrie -- Guthrie Trailer Sales Inc. TITLE: FMVSS INTERPRETATION trailers; PART 565; S565.4(d)(1) TEXT:
Mr. Kenneth Guthrie Guthrie Trailer Sales, Inc. Box 1026 Great Bend, Kansas 67530
Dear Mr. Guthrie:
This is in response to your recent inquiry to Elizabeth Harrison of this office regarding the change of model year designation on Vehicle Identification Numbers (VIN's) affixed to trailers manufactured by your company. VIN's are required to be affixed under the authority of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) and 49 CFR Part 565. The change of model year designation in the VIN can be made by changing the code letter to F for model year 1985, according to the table in 49 CFR Part 565.4(d)(1). No notification to the agency is required for a change of model year designation.
A copy of 49 CFR Part 565 is enclosed.
Sincerely,
Frank Berndt Chief Counsel Enclosure |
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ID: nht73-5.40OpenDATE: 11/01/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Joan Norton TITLE: FMVSR INTERPRETATION TEXT: I appreciate your taking the time to bring to our attention possible odometer tampering by Southside American, Inc., of Jacksonville, Florida. The Motor Vehicle Information and Cost Savings Act prohibits odometer tampering and provides a remedy in the form of a civil action to be brought by a defrauded party. If it's possible to find the person who bought the car - a search that will probably require the assistance of the state motor vehicle department - he should be advised of the apparent error in the odometer. If he decides to pursue his remedy under the Act, he may have to rely heavily on your testimony, particularly if the oil sticker has been removed. Although a private civil action is the principal remedy under the Act, the Federal government has auxiliary authority to enjoin violations of the Act. You can assist us in the exercise of this authority by forwarding the enclosed copy of this letter to your local consumer affairs office. If they encounter additional instances of apparent violation by Southside, or by other dealers, we could consider the possibility of seeking an injunction. ENC. |
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ID: 77-1.1OpenTYPE: INTERPRETATION-NHTSA DATE: 01/12/77 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Philsco Products Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your December 27, 1976, letter concerning the effect of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, on the auxiliary fuel tanks that you manufacture for pickup trucks. The question you have asked was addressed in my November 10, 1976, letter to Mr. Charles Atkinson. It does not appear that you are in danger of going out of the auxiliary tank business. A copy of that letter is enclosed for your convenience. |
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ID: nht79-4.34OpenDATE: 08/07/79 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Mark Marks TITLE: FMVSS INTERPRETATION TEXT: In response to the request of Ms. Chris Anderson of your office, I have enclosed a copy of a letter which I recently wrote detailing the National Highway Traffic Safety Administration (NHTSA) regulations pertinent to the manufacture of trailers. Please note the reference on page 2 of the letter concerning the "Manufacturer Identification" requirements. These requirements are independent of those pertinent to the Vehicle Identification Number. Under current regulations (49 CFR Part 571.115), manufacturers of trailers are not subject to the Vehicle Identification Number requirements. However, pursuant to recent amendments (see enclosed copy), a manufacturer of trailers will be required to affix a Vehicle Identification Number to every trailer manufactured on or after September 1, 1980. Although, the Vehicle Identification Number will not have to be affixed until this date, certain reports will be required in advance. Any trailer manufacturer who begins production before September 1, 1979, must report to NHTSA by that date the characters that he will include in his Vehicle Identification Numbers to uniquely identify himself, the make and the type of vehicle he produces. A manufacturer beginning production after September 1, 1979, must submit this information at least 60 days before he begins affixing the Vehicle Identification Numbers to vehicles. I hope that this information will be helpful to you and your constituent. I will be happy to answer any further questions that you may have. SINCERELY, Attachment: See 8/31/79 letter from F. Berndt to Vesely Company.
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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.