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: aiam0407OpenMr. Louis C. Lundstrom, Director, Automotive Safety Engineering, General Motors Environmental Staff, General Motors Technical Center, Warren, MI, 48090; Mr. Louis C. Lundstrom Director Automotive Safety Engineering General Motors Environmental Staff General Motors Technical Center Warren MI 48090; Dear Mr. Lundstrom: This is in reply to your letter of July 12, 1971, to Mr. Douglas W Toms, Acting Administrator, concerning replacement equipment covered in FMVSS No. 108, effective January 1, 1972.; The requirements for original and replacement equipment in FMVSS No 108 cover those items listed in Tables I and III, namely:>>>; Headlamps, Tail lamps, Stop lamps, License plate lamps, Refle reflectors, Parking lamps, Side marker lamps, Backup lamps, Turn signal lamps,; Turn signal operating units, Turn signal flashers, Vehicular hazar warning signal operating units, Vehicular hazard warning signal flashers, Identification lamps, Clearance lamps, Intermediate side marker lamps, Intermediate reflex reflectors<<<; In addition the requirements cover the following items specified in th text of the standard:>>>; School bus warning lamps, Headlamp beam switching devices, Headlam upper beam indicator lamps, Turn signal pilot indicator lamps, Hazard warning signal pilot indicator lamps, Plastic lenses.<<<; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1561OpenGerhard P. Riechel, Esq.,Volkswagen of America, Inc.,Englewood Cliffs, New jersey 07632; Gerhard P. Riechel Esq. Volkswagen of America Inc. Englewood Cliffs New jersey 07632; Dear Mr. Riechel:#This responds to your July 1, 1974, letter concernin Volkswagen's petition to exempt its pre-bent vacuum hose from some requirements of STandard No. 106-74, *Brake hoses*. You requested that we confirm that an in-line vacuum check valve is not regulated under the standard, and that the standard's use of 'light duty' and 'heavy duty' vacuum hose terminology corresponds to the use of those terms in the SAE Standard J1403a. We respond to the Volkswagen petition in a letter of July 2, 1974, to Mr. J.W. Kennebeck of Volkswagen.#You are correct in your conclusion that an in-line check valve like the value in Volkswagen's pre- bent vacuum line is not a brake hose fitting subject to the requirements of Standard No. 106-74. #The National Highway Traffic Safety Administration tends to make the same distinction between light and heavy duty vacuum hose types as is made by the SAE Standard J1403a, which is based in the thickness of the hose wall. In addition to those sizes listed by the SAE we have added 9/32-inch hose.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam2329OpenMr. David E. Martin, Director, Automotive Safety Engineering, General Motors Corporation, General Motors Technical Center, Warren, Michigan 48090; Mr. David E. Martin Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center Warren Michigan 48090; Dear Mr. Martin: This responds to General Motors Corporation's May 27, 1976, petition t commence rulemaking to amend Standard No. 105-75, *Hydraulic Brake Systems*, in order to return one sentence to the text of S5.1.5.2(a) that was omitted in a September 17, 1975, revision of that section (40 FR 42872). The sentence reads:'However, the maximum control force for the fifth stop in the case of a vehicle manufactured before September 1, 1976, shall be not more than plus 60 pounds of the average control force for the baseline check (but in no case more than 110 pounds).'; The National Highway Traffic Safety Administration considers a petitio to amend the standard to be unnecessary because the omission was inadvertent and did not constitute a substantive change to the requirements of the standard. Therefore, an interpretative amendment to conform the language to that intended will be forthcoming in the near future. Interested persons are notified that the interim control force value has been in effect for all vehicles of 10, 000 pounds gross vehicle weight rating or less despite the omission of the sentence on September 17, 1975.; Thank you for bringing this omission to the attention of the agency. Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0702OpenThe Reverend Norman E. Douglas, Pastor and Student Chaplain, The United Methodist Church, Moland Road, Post Office Box 488, Alfred, NY 14302; The Reverend Norman E. Douglas Pastor and Student Chaplain The United Methodist Church Moland Road Post Office Box 488 Alfred NY 14302; Dear Mr. Douglas: This is in reply to your letter of May 2, 1972, in which you reques information relating to your responsibilities under the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) and the Federal Motor Vehicle Safety Standards (FMVSS) and regulations issued thereunder.; Motor homes are not defined as such under the regulations. They fall i the category of multipurpose passenger vehicle and would be subject to all of the standards that apply to that type vehicle.; I am enclosing the following publications. The answers to you questions can be found therein:; >>>1. The Act 2. December 2, 1971, edition of the Federal Register - Recodification 3. Part 566 of Title 49 of the Code of Federal Regulations Manufacturer Identification; 4. Part 567 - Certification 5. Part 568 - Vehicles Manufactured in Two or More Stages 6. Part 573 - Defect Reports 7. Part 574 - Tire Identification 8. Notice of Publications Change<<< In the event you purchase an incomplete vehicle (chassis) fro Cadillac, they will furnish the documentation as required by part 568. In modifying the chassis you assume the role as an intermediate manufacturer and the recreational vehicle manufacturer becomes the final stage manufacturer. All terms are defined in Part 568.; Federal regulations concerning anti-pollution emission control device are not the responsibility of the Department of Transportation, but of the Environmental Protection Agency. A copy of your inquiry is being furnished to the Director, Division of Certification and Surveillance, Mobile Source Pollution Control Program, 2565 Plymouth Road, Ann Arbor, MI 48105. He will, I am sure, forward such information as he deems appropriate.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam2159OpenHonorable Roy A. Taylor, House of Representatives, Washington, D. C. 20515; Honorable Roy A. Taylor House of Representatives Washington D. C. 20515; Dear Mr. Taylor: This is in reply to your letter of May 21, 1976, forwarding a plea fro Mr. Ralph O. Howard, Executive Vice President of the North Carolina Tire Dealers and Retreaders Association, for help in changing Public Law 91-265, HR 10105, that would permit voluntary registration of tires. The law which became effective May 22, 1971, amended the National Traffic and Motor Vehicle Safety Act of 1966 to require tire manufacturers, including retreaders, to maintain records of the names and addresses of first purchasers. The law also authorized the Secretary of Transportation to prescribe procedures to be followed by distributors and dealers to assist manufacturers in securing the required information. In order to implement the law, our Regulation Part 574 (copy enclosed) specifies that tire dealers shall record the purchaser's name and address at time of sale.; The purpose of tire registration is to enable manufacturers to notif consumers in the event of defective or nonconforming tires. The Congress took steps in amending the Safety Act only after attempts by manufacturers and the National Highway Traffic Safety Administration to inform owners of defective tires proved ineffective. Congressional action would again be necessary to change the law as Mr. Howard's letter requests.; To provide additional orientation pertinent to this subject, we ar enclosing a copy of Secretary Coleman's recent letter to the Honorable C. E. Wiggins.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2580OpenMr. John W. Kourik, 1135 Olivaire Lane, St. Louis, Missouri 63132; Mr. John W. Kourik 1135 Olivaire Lane St. Louis Missouri 63132; Dear Mr. Kourik: This responds to your March 24, 1977, letter asking whether Standar No. 107, *Reflecting Surfaces*, incorporates by reference the SAE Recommended Practice J941 as of November 1965 or as amended through February 1975.; As you note in your letter, Part 571.5 (49 CFR 571.5) of ou regulations establishes guidelines for materials incorporated by reference. That section states that materials which are subject to change, such as the SAE Recommended Practice you mention, are incorporated by reference as they are in effect on the date of adoption of the standard unless otherwise specified. Standard No. 107 refers specifically to the 1965 version of the SAE Recommended Practice. Subsequent amendments of that document by the SAE Technical Committee have no effect upon the Federal Standard.; Thank you for your offer of assistance in amending Standard No. 107 t reflect more recent changes in the SAE Recommended Practice. We Will keep your offer in mind should we determine that a change in the standard is warranted.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3838OpenMr. Christopher Moore, Intec, 23132 La Cadena, Laguna Hills, CA 92653; Mr. Christopher Moore Intec 23132 La Cadena Laguna Hills CA 92653; Dear Mr. Moore: This responds to your April 24, 1984 letter regarding the installatio of a closed circuit television viewing system in new vehicles, as an alternative to rearview mirror systems. The television system provides a view of the area behind the vehicle from a monitor screen placed on or near the dash.; As you note in your letter, Federal Motor Vehicle Safety Standard 11 specifies the use of rearview mirrors to provide improved rearward and side visibility in new motor vehicles. No provision is made for alternative means of compliance such as closed circuit television systems, so such alternative systems are not authorized. However, the closed circuit system could be used as a supplement to a mirror system which meets the requirements of Standard 111.; The only options available to a vehicle manufacturer seeking to use closed circuit system as a replacement for the required mirror system would be to file a petition to amend the standard or a petition for an exemption from the standard. Requirements applicable to these petitions are set forth in Title 49 of the Code of Federal Regulations, Parts 552 and 555, respectively,. These petitions are only granted in the limited circumstances set forth in those regulations.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1391OpenMr. Bernard Belier, U.S. Resident Engineer for Maserati, S.p.A., Officine Alfieri Maserati, S.p.A., Modena, Italy; Mr. Bernard Belier U.S. Resident Engineer for Maserati S.p.A. Officine Alfieri Maserati S.p.A. Modena Italy; Dear Mr. Belier: This is in replay to your letter of January 22, 1974, asking whethe paragraph S4.3.1 of Motor Vehicle Safety Standard No. 108 precludes the mounting of rear lamps in a transparent 'Lexan' panel 'not involved in the driver's rearward vision.'; Paragraph S4.3.1 states in pertinent part that '. . . each lamp . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair . . . .' The 'glazing' referred to is the glazing regulated by Standard No. 205, and refers generally to glazing used in windshields, windows, doors, and interior partitions. Accordingly, Standard No. 108 does not preclude the mounting of rear lamps in the 'Lexan' panel.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2741OpenMrs. Dorinda Givens, Eagle Equipment, Company, P.O. Box 960, Stockton, CA 95202; Mrs. Dorinda Givens Eagle Equipment Company P.O. Box 960 Stockton CA 95202; Dear Mrs. Givens: Our Regional Office in San Francisco has forwarded to us for reply you request for an interpretation of 49 CFR Part 580, Odometer Disclosure Requirements.; The question you raised is who executes the odometer statement when th vehicles are owned by and registered in your name, but turned over to a leasing company who in turn sells the vehicles. Section 408 of the Motor Vehicle Information and Cost Savings Act requires each transferor of a motor vehicle to issue an odometer disclosure statement to each transferee. The transferor is defined in 49 CFR Section 580.3 as 'any person who transfers his ownership in a motor vehicle . . . .' Therefore, you as the owner of the vehicle are required to execute the statement. However, since you never see the vehicles, but rely on the leasing company to sell them for you, you may also rely on the leasing company to act as your agent and execute the odometer statements for you. Since you are the legal owner of the vehicles, it is your responsibility to execute the statements. If you are concerned about the possibility that the leasing company may alter the odometer or make an improper disclosure, you may find it advisable to protect yourself by requiring the leasing company to indemnify you in the event of liability under the Act.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam3214OpenMr. Aldo Fozzati, Fiat Motors of North America, Parklane Towers West, Suite 1210, Dearborn, MI 48126; Mr. Aldo Fozzati Fiat Motors of North America Parklane Towers West Suite 1210 Dearborn MI 48126; Dear Mr. Fozzati: This is in response to your letter of November 15, 1979, requestin that paragraph S8.1.9 of Safety Standard No. 208, *Occupant Crash Protection*, be corrected to change the phrase 'size 11EE shoe' to 'size 11E shoe.' I am sorry for the delay in this response.; Size '11EE' shoes are specified in the standard to allow eas application of the shoes to the test dummy's feet. If the feet of the dummy are of the absolute maximum width allowed by the standard, some size '11E' shoes are very difficult to apply. However, the agency does not believe that use of either '11E' or '11EE' shoes will cause a variation in test results. Therefore, a manufacturer should be safe in using either size. Mr. Radovich was incorrect in his statement that size '11EE' shoes are not available on the market. Size '11EE' shoes can be obtained from the Freeman Shoe Company, the Bostonian Shoe Company and other companies by special order.; For the reason stated above, we do not anticipate amending the standar to specify that shoe size should be '11E'. However, if you have any data or other information indicating that test results can vary between use of size '11E' or size '11EE' shoes, we would certainly appreciate seeing the data.; 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.