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 |
|---|---|
ID: aiam2015OpenA.J. DiMaggio, Firestone Tire & Rubber Company, 1200 Firestone Parkway, Akron, Ohio 44317; A.J. DiMaggio Firestone Tire & Rubber Company 1200 Firestone Parkway Akron Ohio 44317; Dear Mr. DiMaggio: I am writing to confirm the interpretation of Federal Motor Vehicl Safety Standard No. 119, *New pneumatic tires for vehicles other than passenger cars, which was given to you by Mark Schwimmer on April 16, 1975.; Your letter of February 26, 1975, explained that: >>>(i) Firestone would produce 100 tires in size D50C-16.5 for use o one of the prototype vehicles in the Urban Mass Transit Administration's Trans-Bus program,; (ii) these tires would be certified as being in compliance wit Standard No. 119, and (iii) D50C-16.5 is a new size, not appearing in any existing tire and rim organization publication.<<<; In such cases, S5.1(a) of the standard requires tire and rim matchin information to be furnished to dealers of the manufacturer's tires. Your letter suggested that, because Firestone does not expect the tire to be sold through any dealers, this requirement would be inapplicable. As Mr. Schwimmer explained, that interpretation is incorrect. S5.1 of Standard No. 119 applies to all new bus tires, including prototypes manufactured for prototype vehicles. Therefore, you must furnish the matching information to all dealers of Firestone non-passenger-car tires.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3392OpenRoy M. Trantham - General Manager, Armstrong Ford, Estate Golden Rock, P.O. Box 339, Christiansted, St. Croix, United States Virgin Islands; Roy M. Trantham - General Manager Armstrong Ford Estate Golden Rock P.O. Box 339 Christiansted St. Croix United States Virgin Islands; Dear Mr. Trantham: This is in response to your letter of October 7, 1980, requestin information on the Federal odometer disclosure requirements.; The National Highway Traffic Safety Adminstration does not print form for the disclosure of odometer information. In states that are using their titles in lieu of the separate Federal form, the states provide the forms. In other states dealers generally have their own forms printed and individuals either use a dealer's form or simply write out the information on a sheet of paper.; I have enclosed a copy of the Federal regulations detailing the Federa odometer disclosure requirements. You may adopt that format or alter it to meet your specific needs as long as all of the information in it is included.; If you have any further questions, please do not hesitate to write. Sincerely, Shirley Ransom, Trial Attorney |
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ID: aiam0857OpenMr. Bob Rauscher, Product Engineer, The Gates Rubber Company, Galesburg, IL, 61401; Mr. Bob Rauscher Product Engineer The Gates Rubber Company Galesburg IL 61401; Dear Mr. Rauscher: This is in reply to your letter of August 1, 1972, requesting a interpretation in regard to the application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to hoses used in engine compartments and to hoses used in engine compartments that would also 'lead through the firewall into the passenger compartment'.; Hoses are not included in the list of motor vehicle interior component (Section S4.1) to which the Standard applies, and therefore they are not covered by the Standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0882OpenMr. Masaru Yotsuzuka, Takeda U.S.A., Inc., 400 Park Avenue, New York, NY, 10022; Mr. Masaru Yotsuzuka Takeda U.S.A. Inc. 400 Park Avenue New York NY 10022; Dear Mr. Yotsuzuka: Thank you for your letter of October 13, 1972, regarding Federal Moto Vehicle Safety Standard (FMVSS) No. 302.; It is correct that this standard has been in effect since September 1 1972.; The statute requires each item of motor vehicle equipment (in thi case, components specified in paragraphs S4.1 and S4.2 of FMVSS No. 302) that is produced, to conform to the applicable standards. The standard does not specify the means for sampling, and vehicle manufacturers are not restricted in their manner of testing for certification.; This agency does not publish guidelines on testing beyond the standar itself, however, Docket No. 3-3 contains a considerable amount of information and data on this standard from manufacturers, suppliers, and the interested public. This information is in the public record and may be examined during working hours in Room 5221, Docket Section, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0980OpenMr. Michael J. Long, Minister (Commercial), Embassy of Australia, 1601 Massachusetts Avenue, N.W., Washington, DC 20036; Mr. Michael J. Long Minister (Commercial) Embassy of Australia 1601 Massachusetts Avenue N.W. Washington DC 20036; Dear Mr. Long: This is in reply to your letter of January 30, 1973, concerning acryli headlamp covers.; Federal Motor Vehicle Safety Standard No. 108 incorporates Society o Automotive Engineers (SAE) Standard J580a, which prohibits the use of acrylic headlamp covers as original equipment. The requirements of SAE Standard J580a have also been incorporated in a number of State regulations, which are applicable to vehicles in use. Copies of Standard No. 108 and SAE Standard J580a are enclosed for your information.; A Notice of Proposed Rule Making (Docket 69-19, Notice 3) on Standar No. 108 was issued on October 16, 1972. This Notice includes a provision for optional use of headlamp covers which conform to certain performance requirements. Such requirements are specified in paragraph S7.9 of the Notice (copy enclosed). Acrylic Industries Pty. Ltd. may be interested in commenting on this *proposed* revision of Standard No. 108. The closing date for comments is April 18, 1973.; If you have any questions on the enclosed documents, please do no hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0830OpenMr. Robert Craig, Kennedy, Holland, Delaey and Svoboda, Attorneys at Law, Suite 1900, One First National Center, Omaha, Nebraska 68102; Mr. Robert Craig Kennedy Holland Delaey and Svoboda Attorneys at Law Suite 1900 One First National Center Omaha Nebraska 68102; Dear Mr. Craig: Your letter dated July 27, 1972, to the Department of Commerce regarding information pertaining to the National Traffic and Motor Vehicle Safety Act of 1966, initial standards, was referred to this office for reply.; The National Traffic and Motor Vehicle Safety Act of 1966, i establishing the legislative basis for the Federal Motor Vehicle Safety Standards, required that the initial standards, to the maximum extent possible, be based on existing safety standards. An Advance Notice of Proposed Rule Making, soliciting suggestions, opinions, and proposals for consideration in promulgating the initial standards, was published in the *Federal Register* on October 8, 1966. Paragraph S3.3(d) of the Initial Motor Vehicle Safety Standard No. 201 was published in the *Federal Register* on July 15, 1966, (31 F.R. 9628), after consideration of the comments received in response to the Advance Notice. I have enclosed a copy of Standard No. 515/3a.; Thank you for your letter. Your interest in automotive safety i appreciated.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0798OpenMr. Thomas L. Schroeder, Thoroughbred Homes, Inc., P.O. Box 1728, Valdoeta, GA 31601; Mr. Thomas L. Schroeder Thoroughbred Homes Inc. P.O. Box 1728 Valdoeta GA 31601; Dear Mr. Schroeder: This is in response to your inquiry of July 26, 1972, concerning th application of defect reporting requirements to mobile home manufacturers.; Although mobile homes are not specifically mentioned in the Nationa Traffic and Motor Vehicle Safety Act, they are considered to be motor vehicles subject to the Act. Because of their unique characteristics, mobile homes have been categorized as a separate vehicle type, 'mobile structure trailer,' under the motor vehicle safety standards 49 CFR Part 581. 'Mobile structure trailer' is defined in section 571.3 of that part.; The Defect Reports regulations (49 CFR Part 573) apply to manufacturer of all types of motor vehicles, including mobile structure trailers. They require manufacturers to report the number of vehicles manufactured during each calendar quarter. The description of the regulation's requirements in the article you enclosed is somewhat incomplete and accordingly we have enclosed a copy of the regulation for your guidance.; There are no specific forms which we require to be used in th submission of the specified information. Copies of acceptable formats you may wish to use, however, are also enclosed.; Yours truly, Richard B. Dyson |
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ID: aiam0315OpenMr. Warren M. Barnett, c/o Barnett Sales and Service, 3710 Oxford Boulevard, Maplewood, MO 63143; Mr. Warren M. Barnett c/o Barnett Sales and Service 3710 Oxford Boulevard Maplewood MO 63143; Dear Mr. Barnett: This is in reply to your letter of February 23, 1971, requesting advic on the acceptability of your regrooving pattern for regrooved tires.; Enclosed is a copy of the Rules and Regulations on regrooved an regroovable tires as it appears in the *Federal Register* published January 24, 1969, under Section 369.7(a)(3) Requirements, 'After regrooving, the new grooves generated into the tread material and any residual original molded tread groove which is at or below the new regrooved groove depth, shall have a minimum of 90 linear inches of tread edges per linear foot of tire circumference.'; There are no measurements on your drawings to assist us in determinin if your zig-zag grooves and the three circumferencial grooves measure 90 linear inches. Three *straight* circumferential grooves would only provide approximately 72 linear inches.; The use of lateral cuts should substantially increase the tread edg measurements, providing the lateral cuts are from shoulder to shoulder to allow unobstructed fluid escape passages as required in Section 369.7(a)(5); Thank you for your interest in tire safety. Francis Armstrong, Director, Office of Standards Enforcement, Moto Vehicle Programs; |
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ID: aiam1399OpenMr. Robert W. Borgert, Spartan Design Inc., 24151 Telegraph Road, Southfield, MI, 48075; Mr. Robert W. Borgert Spartan Design Inc. 24151 Telegraph Road Southfield MI 48075; Dear Mr. Borgert: This is in reply to your letter of January 21, 1974 asking for ou comments on your defect notification letter.; In describing the defect (your third paragraph) as required by Sectio 577.4(c), you should state specifically that the placement of the lamps fails to conform to Federal Motor Vehicle Safety Standard No. 108, and indicate, in general terms, what is the appropriate location. In addition, section 577.4(c) requires the inclusion of precautions the purchaser can take. We believe one precaution that should be included where a lighting problem is concerned is to recommend that night driving be limited as much as possible.; When we have received a corrected copy, we will close our files in thi matter.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1403OpenMr. Robert W. Borgert, Spartan Design Inc., 24151 Telegraph Road, Southfield, MI 48075; Mr. Robert W. Borgert Spartan Design Inc. 24151 Telegraph Road Southfield MI 48075; Dear Mr. Borgert: This is in reply to your letter of January 21, 1974, asking for ou comments on your defect notification letter.; In describing the defect (your third paragraph) as required by Sectio 577.4(c), you should state specifically that the placement of the lamps fails to conform to Federal Motor Vehicle Safety Standard No. 108, and indicate, in general terms, what is the appropriate location. In addition, section 577.4(c) requires the inclusion of precautions the purchaser can take. We believe one precaution that should be included where a lighting problem is concerned is to recommend that night driving be limited as much as possible.; When we have received a corrected copy, we will close our files in thi matter.; Sincerely, Lawrence R. Schneider, 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.