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: aiam0906OpenMr. Albert Benjamin Kelley, Insurance Institute for Highway Safety, Watergate Six Hundred, Washington, DC 20037; Mr. Albert Benjamin Kelley Insurance Institute for Highway Safety Watergate Six Hundred Washington DC 20037; Dear Mr. Kelley: It is my understanding that you have been given copies of ou compliance test procedure for Standard No. 215, as you requested in your letter of October 2, 1972.; In answer to the remaining questions in your letter, the informatio which we obtain from manufacturers in the course of a compliance investigation is retained in our investigatory files until the investigation is terminated. Upon termination the information is released for public inspection.; Each interpretation of the standard will be placed in th interpretations file ('Redbook') in the docket room as soon as it is sent. Copies will be made available upon request.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1892OpenHonorable Edwin B. Forsythe, House of Representatives, Washington, DC 20515; Honorable Edwin B. Forsythe House of Representatives Washington DC 20515; Dear Mr. Forsythe: This is in response to your letter of March 31, 1975, requestin information concerning correspondence from one of your constituents, Mr. Anthony N. D'Elia, 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 sponsored 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).; Another public hearing was held on April 4, 1975, to allow ora presentation of views on the March 12 notice. The agency is currently examining the information gathered at that proceeding in addition to the written comments that have been submitted. The next step in our rulemaking process will be based on all of the data available.; Your interest and that of Mr. D'Elia is greatly appreciated. Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam2302OpenMr. Earl M. Hoosline, 109 North 'E' Street, Livingston, MT 59047; Mr. Earl M. Hoosline 109 North 'E' Street Livingston MT 59047; Dear Mr. Hoosline: This is in response to your letter of April 11, 1976, requestin information concerning your daughter's purchase of a 1972 Plymouth whose odometer was allegedly rolled back.; The Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513 prohibits alteration of the mileage indicated on an odometer and requires that a written disclosure of a vehicle's mileage be provided by the seller to the purchaser at the time the ownership of a vehicle is transferred. If the correct mileage is unknown, however, the Act requires a statement to that effect to be furnished in written form to the buyer. There is no requirement that these disclosure statements be retained by either the transferor or the transferee.; Violation of any of the above requirements may subject the violated t civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages, whichever is greater. To obtain this remedy, section 409 of the Act provides that a private civil action be instituted in State or Federal court.; If a vehicle has traveled over 100,000 miles and this is not reflecte on the odometer, the odometer disclosure statement should indicate that the mileage registered on the odometer does not reflect the true number of miles the vehicle has driven. If the suggested Federal form is used in making the disclosure, the following statement should be checked:; >>>'I further state that the actual mileage differs from the odomete reading for reasons other than odometer calibration error and that the actual mileage is unknown.'<<<; However, since the actual mileage would be known in the case where th odometer had simply passed the 100,000 mark, the seller should state what the actual mileage is.; For your information, I am forwarding copies of the relevant portion of the Act and the disclosure requirements, in addition to the consumer information pamphlet on odometers.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam0861OpenMr. Paul G. Scully, Vice President, The Grote Manufacturing Company, State Route 7, P. O. Box 766, Madison, IN 47250; Mr. Paul G. Scully Vice President The Grote Manufacturing Company State Route 7 P. O. Box 766 Madison IN 47250; Dear Mr. Scully: This is in reply to your letter of September 25 to Mr. Lewis C. Owen o this Office concerning the mounting of front clearance lamps on trucks and buses over 80 inches in width.; You are correct in your interpretation that these lamps must be mounte to indicate the overall width of the vehicle and as near the top as practicable. The width and height of the body in relation to that of the cab on a van type truck governs the proper location, therefore, each application must be judged individually. However, you are correct that the proper location should be the top front corners of the body when the height of the body is significantly higher than the cab.; Since this same question has been directed to us repeatedly and som manufacturers are installing cab mounted lights and others body mounted lights on quite similar vehicles, we anticipate that this aspect will be addressed in future rulemaking actions.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam4924OpenMr. D. E. Graham Engineering Manager Regulatory, Test & Service Engineering ASC, Incorporated One Sunroof Center Southgate, Michigan 48195; Mr. D. E. Graham Engineering Manager Regulatory Test & Service Engineering ASC Incorporated One Sunroof Center Southgate Michigan 48195; "Dear Mr. Graham: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 118 Power Windows (49 CFR 571.118). As you noted in your letter, the agency published a final rule amending Standard No. 118 in the April 16, 1991, edition of the Federal Register (56 FR 15290). You requested clarification of certain requirements in that final rule. The agency has received several petitions for reconsideration of the final rule amending Standard No. 118. The agency is currently reviewing the merits of each petition. The agency will issue a notice in the Federal Register granting and/or denying the petitions. In that notice, the agency will also address the concerns raised in your request for an interpretation on Standard No. 118. Please let us know if you have any questions about the issues raised in your letter after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. If you need more information on this subject, please feel free to contact Dorothy Nakama of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5565OpenThe Honorable Ken Calvert Member, United States House of Representatives 3400 Central Avenue, Suite 200 Riverside, CA 92506; The Honorable Ken Calvert Member United States House of Representatives 3400 Central Avenue Suite 200 Riverside CA 92506; "Dear Mr. Calvert: Thank you for your letter on behalf of you constituent, Mr. Alexander H. Patnode of Lake Elsinore, concerning an engine stand your constituent purchased from Pep Boys. Mr. Patnode asked for assistance after the engine stand caused the engine to fall, injuring his ankle. As explained below, the National Highway Traffic Safety Administration (NHTSA) considers the engine stand to be 'motor vehicle equipment,' subject to our regulation. NHTSA has authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. 49 U.S.C. section 30102(a)(7) defines 'motor vehicle equipment' in relevant part as: (A) any system, part, or component of a motor vehicle as originally manufactured, (B) any similar part or component manufactured or sold for replacement or improvement of a system, part or component, or as an accessory, or addition to a motor vehicle... (emphasis added) Although an engine stand is not a system, part, or component of a motor vehicle, it would be considered an 'accessory' to a motor vehicle. NHTSA has typically used two criteria in determining whether a product is an 'accessory.' The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. Expected use is determined by considering product advertising, product labeling, the type of store that sells the equipment, and information about how the product is used. The second criterion is whether the product is intended to be purchased or otherwise acquired, and principally used by, ordinary users of motor vehicles. If a product satisfies both criteria, it is deemed an 'accessory.' We have determined the engine stand is an accessory, and thus an item of motor vehicle equipment. Applying the two criteria to the engine stand, (1) the engine stand is intended to be used in the maintenance of motor vehicle engines, and (2) assuming the stand was new when sold to Mr. Patnode, it was intended to be acquired and used by ordinary users of motor vehicles. We have searched our files by computer for reported complaints about engine stands, and for manufacturers' service bulletins and recalls. The search was conducted according to manufacturer (Rally) and equipment type (motor vehicle equipment: jacks, and other). A summary of the search results is enclosed. We found no reported instance of an injury caused by an engine stand, or of a manufacturer's issuing a service bulletin or recall because of an engine stand problem. We will keep a copy of Mr. Patnode's letter in our files on reported complaints. In the future, the letter may be helpful in establishing a pattern of safety-related concerns caused by the type of engine stand that resulted in Mr. Patnode's injury. I hope this information is helpful. If there are any questions, please let me know. Sincerely, John Womack Acting Chief Counsel Enclosure cc: Harleigh Ewell, Esq. Office of the General Counsel Regulatory Affairs Division U.S. Consumer Product Safety Commission Washington, D.C. 20207-0001"; |
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ID: aiam0770OpenMr. G. Doe, Vehicle Safety Manager, Lotus Cars Ltd., Norwich NOR 92W, Wymondham 3411, England; Mr. G. Doe Vehicle Safety Manager Lotus Cars Ltd. Norwich NOR 92W Wymondham 3411 England; Dear Mr. Doe: This is in reply to your letter of June 12, 1972, asking certai questions concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You ask if the standard applies to small components that have a maximu dimension of less than 4 inches, such as control knobs, and if so, how such components are to be tested. The standard applies to those components enumerated in S4.1. Control knobs and switches would not be subject to the standard unless they are 'designed to absorb energy on contact by occupants in the event of a crash.' Such components may be tested using the heat resistant wires that are inserted in the U-shaped frame, as described in paragraph S5.1.3 of the standard. The NHTSA is currently considering an amendment to the standard, however, which would modify the requirements as they apply to small components.; In response to your second question, electrical wiring is not subjec to the standard.; Your third question is, if a headliner is glued to the roof, would th test specimen be taken from a finished vehicle in such a way as to include the exterior paintwork. The answer to this question is no. The application of the standard to headlining (S4.1) does not include the roof to which it is attached, as the roof is not part of the component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2312OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50 -- 100 W. Alondra Blvd., Gardena, CA 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 -- 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill: This is in response to your May 6, 1976, request for confirmation tha the Honda 'MPV' qualifies as a multipurpose passenger vehicle although it is constructed on a 'modified' truck chassis.; In our letter to you of April 30, 1976, we concluded that the Hond 'MPV' would be classified as a multipurpose passenger vehicle, based upon the assumption that the 'MPV' is constructed on a truck chassis. You responded that the 'MPV' is constructed on a 'modified' truck chassis, and questioned whether the National Highway Traffic Safety Administration considered this fact in its previous interpretation.; The reference to 'truck chassis' in the definition of multipurpos passenger vehicle, 49 CFR Part 571.3(b), is intended to include chassis that were designed and developed for trucks, but which have been produced in a version for use in passenger carrying vehicles. According to your letter and drawings of March 1, 1976, the Honda 'MPV' is a passenger version of the Honda TN 500 light truck. Since the modification of the chassis in the production of the 'MPV' does not appear to be so great that the major characteristics of the truck chassis are destroyed, we confirm our previous determination that the Honda 'MPV' qualifies as a multipurpose passenger vehicle.; Sincerely, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam1753OpenMr. William J. Flanagan, Executive Director, New Jersey Turnpike Authority, New Brunswick, New Jersey 08903; Mr. William J. Flanagan Executive Director New Jersey Turnpike Authority New Brunswick New Jersey 08903; Dear Mr. Flanagan: This is in reply to your letter of December 3, 1974, requesting ou view whether the removal of portions of a tie bar in a truck tire, for the purpose of reducing tire noise, is subject to NHTSA's *Regrooved Tire* regulation (49 CFR Part 569). You state that the removal of the tie bar material does not require that the tread be cut to a depth equal to or deeper than the original groove depth.; We concur in your opinion that the partial removal of tire tie ba material is not subject to the *Regrooved Tire* regulations. This practice would not be considered the making of a 'regrooved tire' (49 CFR S569.3(d)) as long as the removal of tie bar material did not extend to the original tread depth. Any removal or renewal of tread that did extend to at least the original tread depth, however, would be considered the making of a 'regrooved tire' and would be subject to the requirements set forth in S569.7 of the regulation.; We are concerned, however, that this opinion may result in th indiscriminate removal of tire bar material from truck tires having varying tread designs. We believe it possible, notwithstanding the absence of regulations prohibiting such removal, that the removal of tie bar material could in some cases induce tread cracking, instability, and otherwise reduce the safe performance of truck tires. Consequently, we believe you should determine, through testing if necessary, that removal of tire tie bar material will not produce adverse results in tire performance before any large-scale project involving venting is implemented. Any such program should also take into account that effects of venting may differ among various tread designs. Finally, tread venting on new tires manufactured after Match 1, 1975, could affect the conformity of those tires to Federal Motor Vehicle Safety Standard No. 119.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1754OpenMr. William J. Flanagan, Executive Director, New Jersey Turnpike Authority, New Brunswick, NJ 08903; Mr. William J. Flanagan Executive Director New Jersey Turnpike Authority New Brunswick NJ 08903; Dear Mr. Flanagan: This is in reply to your letter of December 3, 1974, requesting ou view whether the removal of portions of a tie bar in a truck tire, for the purpose of reducing tire noise, is subject to NHTSA's *Regrooved Tire* regulation (49 CFR Part 569). You state that the removal of the tie bar material does not require that the tread be cut to a depth equal to or deeper than the original groove depth.; We concur in your opinion that the partial removal of tire tie ba material is not subject to the *Regrooved Tire* regulations. This practice would not be considered the making of a 'regrooved tire' (49 CFR S 569.3(d)) as long as the removal of tie bar material did not extend to the original tread depth. Any removal or renewal of tread that did extend to at least the original tread depth, however, would be considered the making of a 'regrooved tire' and would be subject to the requirements set forth in S 569.7 of the regulation.; We are concerned, however, that this opinion may result in th indiscriminate removal of tire tie bar material from truck tires having varying tread designs. We believe it possible, notwithstanding the absence of regulations prohibiting such removal, that the removal of tie bar material could in some cases induce tread cracking, instability, and otherwise reduce the safe performance of truck tires. Consequently, we believe you should determine, through testing if necessary, that removal of tire tie bar material will not produce adverse results in tire performance before any large-scale project involving venting is implemented. Any such program should also take into account that effects of venting may differ among various tread designs. Finally, tread venting on new tires manufactured after March 1, 1975, could affect the conformity of those tires to Federal Motor Vehicle Safety Standard No. 119.; Yours truly, Richard B. Dyson, Acting 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.