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: aiam0845OpenMr. S.G. Jonas, Attorney and Counselor, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. S.G. Jonas Attorney and Counselor American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Jonas: This is in reply to your letter of May 24, 1972, concerning the tes procedures applicable to a passenger car headlamp after the impacts required by Motor Vehicle Safety Standard No. 215.; Your question is whether the requirements of SAE Standard J580a, whic are incorporated in the lighting systems standard, Standard No. 108, are meant to be incorporated into Standard No. 215, and, if so, whether the 'Aiming Adjustment Tests' of SAE J580a are to be performed in a laboratory fixture or on the vehicle.; Our answer is that Standard No. 215, in adopting the headlam adjustment requirements of Standard No. 108, incorporates the requirements of SAE J580. Contrary to your impression, SAE J580 can be conducted either as a bench test or as an on-vehicle test, and as incorporated into Standard No. 215 its aiming adjustment test will be applied as an on-vehicle test. The use of the bench test procedure by our Office of Standards Enforcement in its laboratory procedures manual for Standard No. 108 should not be understood to mean that we consider the bench test to be the only test method under SAE J580a.; Sincerely, Richard B.DDyson (sic), Assistant Chief Counsel |
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ID: aiam1310OpenMr. J.R. Farron,Group Director of Engineering,The Bendix Corporation,Automotive Control,Systems Group,401 Bendix Drive, South Bend, Indiana 46620; Mr. J.R. Farron Group Director of Engineering The Bendix Corporation Automotive Control Systems Group 401 Bendix Drive South Bend Indiana 46620; Dear Mr. Farron:#This replies to your letter of October 17, 1973.#W have studied the comment contained in your letter carefully, and based on your extensive experience, have no reason to believe that your use of tubing made of solid neoprene rubber for the application in question constitutes a safety hazard.#Since there is a limited movement involved, the use of 'tubing' rather than 'hose' is appropriate. The Bureau has not, as yet, established standards other than the general requirements of paragraph 393.43(a) for brake tubing used in applications which do not flex. Use of coiled nylon brake tubing for connections between the requirements for Type 3b nylon tubing set forth in SAE Standard J844.C.#We appreciate your interest in this safety matter and trust the above is responsive to your inquiry.#Sincerely yours,W.R. Fiste, Chief,Regulations Division; |
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ID: aiam0610OpenMr. W. Dershko, Engineering Manager, Motor Coach Industries, Inc., Pembina, ND 58271; Mr. W. Dershko Engineering Manager Motor Coach Industries Inc. Pembina ND 58271; Dear Mr. Dershko: This is in reply to your letter of February 7, 1972, to Mr. Lewis Owe of this Office concerning clarification of the requirements of paragraph S4.7 of Standard No. 108.; A label similar to that shown on the enclosure to your letter woul meet the certification requirements of paragraph S4.7.2 of Standard No. 108 as specified in the amendment published in the *Federal Register* on January 12, 1972, (copy enclosed).; 'Associated equipment' covered by Standard No. 108 includes only tha for which requirements are specified in the Standard. The only serviceable item, in addition to the completed assemblies, for which certification is required is a plastic part such as a lens, which must meet the requirements of paragraph S4.1.2.; The requirement for replacement equipment to conform to Standard No 108 was applicable to items manufactured on and after January 1, 1972. Certification of items received by your Service Parts Department after January 1, 1972, is therefore acceptable.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam2924OpenMr. J. C. Eckhold, Director, Automotive Safety Office, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold Director Automotive Safety Office Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. Eckhold:#This is in response to your letter of August 29 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80. The answers to your specific questions are as follows:#(1) You requested an interpretation that a single telltale which monitors both the oil pressure and coolant temperature gauges could be identified by the word 'Engine.' You indicated that it has been Ford's practice to combine the monitoring of these two functions into a single telltale because the response by the driver to either malfunction is the same. The standard does not require that any of the displays listed in S5.1 be provided or that two or more displays, if provided, be provided separately. It is the interpretation of the NHTSA that the multipurpose telltale which monitors the two functions specified above may be identified by the word 'Engine.'#(2) You asked whether the NHTSA intended that the display identification requirements of FMVSS 208 would be met by use of the symbol required by FMVSS 101-80. The answer is no. However, the agency will issue shortly a notice which will provide for the use of the FMVSS 101-80 symbol for the purposes of that standard and those of FMVSS 208.#(3) You asked that the identification requirements of FMVSS 105-75 be deleted from that standard and those in FMVSS 101-80 be retained. No conflict exists between the two standards. Nevertheless, we will address this issue in the same notice mentioned in the immediately preceding paragraph.#Sincerely, Joseph J. Levin, Jr., Chief Counsel; |
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ID: aiam0681OpenMr. K. Krueger, Technical Development, Liaison Engineer, Volkswagen of America, Inc., Englewood Cliffs, NJ, 07632; Mr. K. Krueger Technical Development Liaison Engineer Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Krueger: In reviewing our response of March 1, 1972, to your letter of Decembe 6, 1971, we have noted that one of our answers contains an error. On page 2, our answer to question 1(b) should read:; >>>'The provisions of S4.3 that you refer to are intended to reflec the performance of samples described in the test procedures of S5. These requirements are intended to provide an exemption for self-extinguishing materials, and not to exempt small samples that are consumed by fire before *one minute* elapses. The standard establishes burn-rate requirements, and manufacturers should keep this in mind in determining whether particular components comply. If your component is such that it is consumed by fire because of its size before the *one-minute* period, then we would expect modifications to the procedure, of a nature described above, to be made in order that a determination of the burn rate of the material is obtained.' (Emphasis added.)<<<; We regret any inconvenience this error may have caused. Yours truly, Richard S. Dyson, Assistant Chief Counsel |
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ID: aiam0734OpenMr. Erwin Strasmich, Vice-President, Ross Matthews Corporation, East Warren Street, Fall River, MA, 02722; Mr. Erwin Strasmich Vice-President Ross Matthews Corporation East Warren Street Fall River MA 02722; Dear Mr. Strasmich: This is in reply to your letter of May 19, asking whether elasti fabric you manufacture must meet the requirements of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials' (49 CFR 571.302). You state that the fabric is under one inch wide, is tunneled and covered in automobile map pockets and similar accessories, and is not exposed in the finished product.; Paragraph S4.1 of Standard No. 302 (copy enclosed) lists the component of motor vehicles that must meet the burn rate requirements. Whether your elastic is required to meet these requirements depends upon whether it is incorporated into any of these enumerated components. We would consider, for example, a map pocket attached to the inside of a vehicle door to be part of a door 'trim panel,' and consequently subject to the standard. If your material is used in any component listed in S4.1, it would be required to meet the standard's requirements when tested as part of the component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3614OpenMr. Shizuo Suzuki, Nissan Motor Co., Ltd., Suite 707, 1919 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Shizuo Suzuki Nissan Motor Co. Ltd. Suite 707 1919 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Suzuki: This is in response to your September 23, 1982, letter regarding th applicability of Federal Motor Vehicle Safety Standard No. 118, *Power-Operated Window Systems*, to power sunroofs. The agency apparently has never previously addressed this question.; Standard 118 specifies requirements only for power-operated window an partition systems. A power sunroof would be considered neither a 'window' nor a 'partition,' and therefore would not be subject to the standard. Our standard was intended to apply to the typical power side windows and the power tailgate windows of station wagons. The reference to 'partitions' in the standard was adopted as part of the July 23, 1970, final rule establishing Standard 118 and was intended to assure that power-operated interior partitions, such as might be used in a taxi or a limousine, would comply.; Although Standard 118 does not apply to power sunroofs, we strongl recommend that safety precautions along the lines of those established in that standard be incorporated in power sunroof designs. It appears possible that the types of accidents which the standard was intended to prevent could also occur as a result of the unsupervised operation of power sunroofs.; If you have any further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2878OpenMr. J. Kawano, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., One Harmon Plaza, Secaucus, NJ 97094; Mr. J. Kawano Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. One Harmon Plaza Secaucus NJ 97094; Dear Mr. Kawano: This is in reply to your letter of September 6, 1978, requesting a interpretation of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*. You referred to the Society of Automotive Engineers (SAE) Standard J571d, referenced in Standard No. 108, which specifies dimensions for rectangular headlamp retaining rings in its Figure 8(B). The table of dimensions in Figure 8 specifies a maximum of 1.52 mm for the 'K' dimension on the drawing, the distance of the forward portion of the retaining ring from the lens surface. You stated that Toyota plans to increase that dimension by an unspecified amount for ornamental purposes.; You further advised that the proposed design would not interfere wit the ability of the headlamps to meet the performance requirements of SAE J580a and b and of the mechanical aiming requirements of SAE J602c.; Since Figure 8(B) of SAE J571d shows that the 'K' dimension shall no exceed 1.52 mm, any greater dimension would not meet the specifications of the standard. However, you may petition for rulemaking to appropriately amend Standard No. 108. We cannot, however, offer any assurance that the standard would be changed in response to your petition.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5319OpenMr. Michinori Hachiya Director, Technical Affairs Nissan North America, Inc. 750 17th Street, N.W. Suite 901 Washington, D.C. 20006-4607; Mr. Michinori Hachiya Director Technical Affairs Nissan North America Inc. 750 17th Street N.W. Suite 901 Washington D.C. 20006-4607; Dear Mr. Hachiya: This responds to your request for an interpretatio of the theft prevention standard (49 CFR part 541) as it would apply to high theft passenger motor vehicles and their replacement parts from model year (MY) 1996 and thereafter. Because the agency has not yet published regulations for MY 1996 high theft lines and thereafter, we are unable to answer your specific questions. As a result of the 'Anti Car Theft Act of 1992' (ACTA), certain changes must be made to the theft prevention standard. In its October 25, 1993 semiannual regulatory agenda, NHTSA listed its proposed rulemakings to implement the ACTA. (See 58 FR 56734 et seq.) In a Federal Register document of January 6, 1994 (59 FR 796), NHTSA stated it intended that the new ACTA-mandated procedures apply to high theft lines beginning in MY 1996. As indicated in the October 1993 semiannual agenda, NHTSA will shortly issue a notice of proposed rulemaking to amend the theft prevention standard. We believe the NPRM will address the issues you raise. If the NPRM does not address them, you will be able to discuss any questions you may have in your comments on the rulemaking submitted to NHTSA during the public comment period. If you have any questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2055OpenMr. John. H. Mueller, The Weatherhead Company, 300 East 131st Street, Cleveland, Ohio 44108; Mr. John. H. Mueller The Weatherhead Company 300 East 131st Street Cleveland Ohio 44108; Dear Mr. Mueller: #This is in response to your letter of July 9, 1975 concerning the banding requirements of Standard No. 106-74. You asked whether the requirements for a band may be avoided in the situation where a hose manufacturer makes a hose assembly to a vehicle manufacturer's 'specified requirements,' under the exception for hoses 'assembled and installed by a vehicle manufacturer.' #The exception in the standard for assemblies made by a vehicle manufacturer cannot be interpreted to apply to those made by a hose manufacturer, as you suggested, so the answer to your question must be no. It is the intent of the standard to distinguish between the two situations you described. #We are presently reviewing the labeling requirements of the brake hose standard in light of your letter and other information. If you wish to present further data and other arguments toward the revocation of the banding requirement, the appropriate form in which to do so would be a petition for rulemaking under Pard 552. #Your truly, Richard B. Dyson, Assistant 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.