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: aiam5145OpenMr. Dale E. Dawkins Director Vehicle Compliance and Safety Affairs Chrysler Corporation CIMS 415-03-17 1200 Chrysler Drive Highland Park MI 48288-0857; Mr. Dale E. Dawkins Director Vehicle Compliance and Safety Affairs Chrysler Corporation CIMS 415-03-17 1200 Chrysler Drive Highland Park MI 48288-0857; "Dear Mr. Dawkins: We have received your letter of March 9, 1993 responding to mine of February 18. On December 16, 1992, you informed the agency of the intent of Chrysler Corporation to manufacture 10 Chesapeake Consortium Electric Vehicles (CCEV) under NHTSA Temporary Exemption 92-1. According to your December letter, these vehicles are 'almost identical' to the TEVans for which the agency granted the temporary exemption, except that they will utilize an AC electrical motor, while the ones which were the subject of the exemption petition will be powered by a DC electrical motor. You seek no broader exemption as the combined volumes of CCEVs and TEVans 'will not exceed the maximum units of the petition that was granted.' It appeared that you wished confirmation from NHTSA that the CCEV vehicles are covered by Temporary Exemption 92-1. As I informed you on February 18, in order for the agency to provide this confirmation, we must determine that CCEV and TEVans are essentially the same vehicle and that none of the minor differences between the vehicles affects the findings made by the agency in issuing the TEVan exemption. In granting Chrysler's exemption petition covering three standards, the Administrator first found that the exemption would facilitate the development and field evaluation of a low emission motor vehicle. We do not believe that the change in electrical propulsion from DC to AC affects this finding. The Administrator next found that an exemption from the three standards would not unduly degrade the safety of the vehicle. You stated that ' b ased on our engineering judgement, there is no significant difference between the CCEV or TEVan in terms of overall vehicle safety.' While you may have used the word 'significant' in an excess of caution, it implied that there were differences between CCEV and TEVan and that there was a difference in overall vehicle safety between the CCEV and TEVan, although not an important one from Chrysler's viewpoint. Therefore, we asked you to identify the differences between the vehicles, and of the differences, if any, in the safety between the CCEVs and TEVans that may have led to Chrysler's engineering conclusion. Your letter of March 9 informs us that there are 'no discernable safety differences' between TEVans and CCEVs. It further informs us, as before, that the only difference between the two programs of electric vehicle development is the propulsion motors and transmissions. Therefore, it appears that two vehicles are essentially the same in design and in terms of the level of safety provided, and that it is appropriate to consider the CCEVs covered by the TEVan exemption. We appreciate your calling our attention to this matter. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3924OpenB. Craig Killough, Esq., 14 North Adgers Wharf, Charleston, SC 29401; B. Craig Killough Esq. 14 North Adgers Wharf Charleston SC 29401; Dear Mr. Killough: This is in response to your letter dated March 5, 1985 inquiring as t whether South Carolina has obtained approval under 49 CFR S580.4(f)(1) to eliminate the odometer disclosure requirements of 49 CFR S580.4(d).; Some background information may be helpful. Title IV of the Moto Vehicle Information and Cost Savings Act requires vehicle sellers to make certain odometer disclosures, as specified in our regulations (49 CFR S580.4). The general rule is that all information specified in S580.4(a)-(e) must be included on the disclosure form. However, S580.4(f)(1) provides that, if the disclosure is made on the certificate of title, the information specified in S580.4(d) need not be included. If the state wishes to make other variations in the information disclosed on the title, it must obtain approval from this agency to do so.; This agency has not granted approval to South Carolina for use of an alternative odometer disclosure procedures. Nor, to my knowledge, has South Carolina fully incorporated the information required by 49 CFR S580.4(f)(1) into its certificate of title. Please note, however, that if in the future the state does incorporate into its title the appropriate language contained in the regulation, it need not obtain the approval of this agency in order to use that title in lieu of a separate form.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam5377OpenCONFIDENTIAL ; CONFIDENTIAL ; "Dear CONFIDENTIAL : This responds to your request for a interpretation of Federal Motor Vehicle Safety Standard No. 123, Motorcycle controls and displays. You asked whether footnote 4 of Table 3 of the standard applies to a motorcycle speedometer using a digital display. As explained below, the answer is no. In your letter, you requested that information identifying your company be kept confidential. As explained in the March 25, 1994 letter to you from Heidi L. Coleman, Acting Assistant Chief Counsel for General Law, when confidential treatment is claimed for material submitted to the National Highway Traffic Safety Administration (NHTSA), our confidentiality regulation, 49 C.F.R. 512, requires the submission of a certification stating that the submitter has made a diligent inquiry to ascertain that the information submitted has not been disclosed, or otherwise made public (49 C.F.R. 512.4(e)) and other supporting information (49 C.F.R. 512.4(b)). However, in order to expedite our response to you, I will waive the requirement of the certification contained in 49 C.F.R. 512. Under S5.2.3 of Standard No. 123, if a speedometer is provided, the item shall be identified by 'wording shown in both Column 2 and Column 4' of Table 3 of the standard. Column 4 of Table 3 specifies that a speedometer shall be identified by 'M.P.H.' You believe your speedometer meets this requirement. However, you ask whether footnote 4 of Column 4 applies to a digital display speedometer. Footnote 4 states: M.P.H. increase in a clockwise direction. Major graduations and numerals appear at 10 mph intervals, minor graduations at the 5 mph intervals. The answer to your question is no. Digital displays were not common in 1972, when the footnote 4 specifications were published. The original Standard No. 123 drafters had in mind only dial display speedometers. For these reasons, we interpret the specifications in footnote 4 of Column 4 not to apply to digital display speedometers on motorcycles that provide a reading of numeric vehicle speed. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam4216OpenMr. Toshio Maeda, Executive Vice President & Chief Operating Officer, Nissan Research & Development, Inc., P.O. Box 8650, Ann Arbor, MI 48104; Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Maeda: Thank you for your letter of July 30, 1986, concerning the safety bel contact force provision of the comfort and convenience requirements of Standard No. 208, *Occupant Crash Protection*. You explained that Nissan is concerned about the requirements of S10.6 contained in the final rule published on March 21, 1986. You noted that a sentence contained in the notice of proposed rulemaking was not included in the final rule and asked whether this sentence had been inadvertently omitted.; In addition, you asked the agency to clarify the effect of the omitte sentence on belt systems which have less than 12 inches of webbing stored in the retractor once the belt is placed around the test dummy. You explained that Nissan considers the purpose of the requirement in the omitted sentence to be elimination of belt drag before measuring the belt contact force. You explained that requiring a manufacturer to pull 12 inches of webbing from the retractor before the belt contact test would require redesign of Nissan's belt systems, even though those systems meet the safety belt adjustment requirements of the standard. You asked the agency to provide that a manufacturer can pull the maximum allowable length of the belt stored on the retractor, rather than 12 inches, prior to conducting the belt contact force test.; As explained in the enclosed Federal Register notice, the sentenc contained in the notice of proposed rulemaking was inadvertently omitted from the final rule. NHTSA agrees that the purpose of the belt webbing pull requirement can be adequately met by pulling out the maximum allowable amount of the belt, when the belt has less than 12 inches of available additional webbbing (sic). Pulling the belt in this way will ensure that the belt retractor is working and webbing drag is reduced. Thus, the agency has modified the requirement to provide that prior to measuring the belt contact force the agency will pull out 12 inches of webbing or the maximum amount of webbing available when the maximum amount is less than 12 inches.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1888OpenHonorable Birch Bayh, United States Senate, Washington, DC 20510; Honorable Birch Bayh United States Senate Washington DC 20510; Dear Senator Bayh: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1885OpenHonorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1843OpenHonorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5-mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety- related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1729OpenHonorable Birch Bayh, United States Senate, Washington, DC 20510; Honorable Birch Bayh United States Senate Washington DC 20510; Dear Senator Bayh: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5-mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety- related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2993OpenMr. Michael Petler, Assistant Manager, Safety and Legislation Department, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, California 90670; Mr. Michael Petler Assistant Manager Safety and Legislation Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs California 90670; Dear Mr. Petler: This is in response to your request of March 22, 1979, for a interpretation of Federal Motor Vehicle Safety Standard No. 109. First, I would like to apologize for the delay in responding to your request of September 14, 1978. As was explained to you in a telephone conversation on March 22, your letter and the response thereto was apparently lost when the Chief Counsel's offices were moved. Although we took great care to ensure that something like this would not happen, it seemingly did in this case. I regret this and hope that it has not caused any undue inconvenience for your company.; You asked whether it was permissible under Standard 109 for manufacturer to stamp the maximum permissible inflation pressure of a tire and its maximum load rating on the tire in both English units (pounds and psi) and metric units (kilograms and kPa). S4.3(b) and (c) of the standard specify that each tire shall have permanently molded onto the sidewalls the maximum load rating for the tire. This agency has interpreted this requirement to mean that the information must appear on the sidewalls in the English units, since this is the system of measurement which will be used and understood by most consumers. However, so long as the information appears in English units, there is no reason that it could not also be the additional information does not cause confusion about the required information. By stating not only the pressure and rating values, but also the units of value, your company would avoid causing any such confusion. Therefore, the expression of inflation pressure and load rating in English and metric units as shown in your illustration is permissible under Standard 109.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3706OpenMr. C. J. Johnston, Manager, Product Reliability, The BF Goodrich Company, Tire Group, 500 South Main Street, Akron, OH 44318; Mr. C. J. Johnston Manager Product Reliability The BF Goodrich Company Tire Group 500 South Main Street Akron OH 44318; Dear Mr. Johnston: This is in response to your May 12, 1983 letter regarding the tir sidewall molding requirements of the Uniform Tire Quality Grading Standards. In that letter you indicated that, acting in reliance on statements by a NHTSA employee, your company modified certain new tire molds by deleting the numerical treadwear grade from the sidewall label, but leaving the word 'TREADWEAR' in place. NHTSA subsequently stated, in a letter to Toyo Tire Company, that if the sidewall molded label is modified, both the numerical grade and the word 'TREADWEAR' should be deleted. You also indicated that BF Goodrich is now in the process of modifying the molds again to delete the word 'TREADWEAR'.; In light of your good faith reliance on agency statements and you current efforts to conform to the policy stated in our letter to Toyo Tire Company, NHTSA will take no enforcement action regarding sidewall molding requirements for tires produced through the completion of the mold modification process.; For future reference, please be aware formal interpretations of lega requirements are issued only by this office and only in writing. To obtain an interpretation upon which reliance can be placed for purposes of making business decisions, you should direct a letter of inquiry to the Chief Counsel's Office.; Sincerely, Frank Berndt, Chief Counsel |
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.