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: aiam3642OpenMr. Mike M. Simovich, Champ Corporation, El Monte, CA 91733; Mr. Mike M. Simovich Champ Corporation El Monte CA 91733; Dear Mr. Simovich: This is in response to your March 23, 1983, letter to Roger Fairchil of this office, regarding the applicability of Federal Motor Vehicle Safety Standard No. 115 (Vehicle Identification Number) to construction type forklift trucks. As you state in your letter, these vehicles are principally designed to operate on a construction site, such as by lifting building materials to upper levels in a building project. The trucks would apparently remain at construction sites for two to twelve months, then move to the next job site. Some models of the trucks have special equipment to facilitate being towed between job sites. While all models presumably could be driven between job sites, none are capable of achieving open highway speeds.; Standard 115 applies only to vehicles manufactured 'primarily for us on the public streets, roads, and highways.' NHTSA has interpreted this language to exclude mobile construction equipment which use the highways only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental, not the primary purpose for which the vehicle was manufactured. Based on the information provided in your letter, your fork-lift trucks would therefore not be subject to Standard 115.; You should be aware that this interpretation applies only to Federa requirements, individual States may establish their own numbering requirements for vehicles outside this agency's jurisdiction (e.g., off-road vehicles). Thus, even though Federal requirements do not apply, it may be that State requirements do apply to your fork-lift trucks.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam1531OpenMr. Rick Shue,Product Safety Engineer,Product Engineering and Development,Volvo of America Corporation,Rockleigh, New Jersey 07647; Mr. Rick Shue Product Safety Engineer Product Engineering and Development Volvo of America Corporation Rockleigh New Jersey 07647; Dear Mr. Shue:#This responds to your April 26,1974 question whethe labeling information on hose installed in vehicles must remain legible after the vehicle is painted, and what 'permanently labeled' means in S5.2.2.#The answer of the question of painting over label information will be answered in our upcoming notice in response to petitions for reconsideration of the amendments we have made to the standard.#'Permanently labeled' means affixed in such a manner that it is not easily removable, and is reasonably designed to remain affixed and legible for the normal life of the component.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
|
ID: aiam0601OpenMr. R. W. Bond, Project Engineer, K D Lamp Company, 1910 Elm Street, Cincinnati, OH, 45210; Mr. R. W. Bond Project Engineer K D Lamp Company 1910 Elm Street Cincinnati OH 45210; Dear Mr. Bond: This is in reply to your letters of December 2, 1971, and February 11 1972, concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether the standard is applicable to interior lighting of any material, either plastic or otherwise. Under the present language of the standard, interior lighting would only be subject to it if the manufacturer has, as specified in S4.1 of the standard, designed it to 'absorb energy on contact by occupants in the event of a crash.' The NHTSA is presently reviewing the necessity of this requirement, and it may be revised in the near future.; We regret the delay in responding to your letter. Your truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1053OpenMr. J. L. Foster, Office Manager, The Procter and Gamble Distributing Company, Post Office Box 60114, New Orleans, LA 70160; Mr. J. L. Foster Office Manager The Procter and Gamble Distributing Company Post Office Box 60114 New Orleans LA 70160; Dear Mr. Foster: This is in response to your request for odometer disclosure form applicable to the State of Florida. The letter appears to be a blanket request for forms from all the states in which you do business.; The Motor Vehicle Information and Cost Savings Act and the accompanyin regulations were purposely made flexible and simple to permit the states and affected transferors maximum latitude in conforming to the Act. In fact, the States have no duties under the Act. Many of the States that you have contacted will probably indicate that no changes will be made to their laws and regulations. Some states may change their Title forms or their disclosure forms to accomodate (sic) the federal statement.; It is the transferor's responsibility to make the required disclosur and again maximum latitude is permitted. No federally-printed form is required nor is one available. A transferor may write his own form, make use of a state form which conveys the same information, or use one of the commercially printed forms now available. So far as the federal requirements are concerned you may use an identical form in all the states. An example of an acceptable format is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0659OpenMr. Edward L. Adams, Route 4, Union Hill, Carbondale, IL 62901; Mr. Edward L. Adams Route 4 Union Hill Carbondale IL 62901; Dear Mr. Adams: This is in reply to your letter of February 17, 1972, in which you as for information on safety specifications as they would apply to travel trailers.; All trailers manufactured for use on the public roads are required t meet applicable Federal Motor Vehicle Safety Standards (FMVSS) in effect on the date of manufacture. Part 567 of Title 49 of the Code of Federal Regulations requires that a certification label be attached to the left front of the trailer. A specific conformity statement is required, among other things, on the label. A copy of the regulation is enclosed.; We do not have information at this time that would add to the articl in the St. Louis Post Dispatch.; Thank you for your interest in the program of the National Highwa Traffic Safety Administration.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
|
ID: aiam0661OpenMr. Edward L. Adams, Route 4, Union Hill, Carbondale, IL 62901; Mr. Edward L. Adams Route 4 Union Hill Carbondale IL 62901; Dear Mr. Adams: This is in reply to your letter of February 17, 1972, in which you as for information on safety specifications as they would apply to travel trailers.; All trailers manufactured for use on the public roads are required t meet applicable Federal Motor Vehicle Safety Standards (FMVSS) in effect on the date of manufacture. Part 567 of Title 49 of the Code of Federal Regulations requires that a certification label be attached to the left front of the trailer. A specific conformity statement is required, among other things, on the label. A copy of the regulation is enclosed.; We do not have information at this time that would add to the articl in the St. Louis Post Dispatch.; Thank you for your interest in the program of the National Highwa Traffic Safety Administration.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
|
ID: aiam1319OpenMr. Allan H. Berger, Director of Equipment Services, Browning-Ferris Industries, Inc., Fannin Bank Building, P.O. Box 3151, Houston, TX 77001; Mr. Allan H. Berger Director of Equipment Services Browning-Ferris Industries Inc. Fannin Bank Building P.O. Box 3151 Houston TX 77001; Dear Mr. Berger: This is in reply to your letter of October 26 to Mr. J.E. Leysath o this office concerning marker and signal lights on your Mack trucks.; Federal Motor Vehicle Safety Standard No. 108 requires that fron clearance and identification lamps be located as close as practicable to the top of the vehicle. Mounting these lamps *on* the top of the vehicles described in your letter does not appear to be practicable because of possible damage to the lamps. If mounting the lamps on the front vertical surface near the top is, in your determination, 'as close to the top as practicable,' then you have met the requirements of Standard No. 108. Mounting an additional side marker lamp (which you have identified as a corner clearance lamp) on each side of the cab, near the front and top of the cab, would not be prohibited by Standard No. 108.; Turn signal lamps and hazard warning signal lamps mounted on the rea of the vehicle may be either red or amber. The color of these lamps was addressed in a Notice of Proposed Rule Making published in the *Federal Register* on October 25, 1972, (Docket 69-19, Notice 3). It was proposed that amber be eliminated as an optional color for these lamps, but no final decision has been made.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
|
ID: aiam4417OpenMr. Robert R. Aronson, President, Electric Fuel propulsion Corp., 366 W. Eight Mile Road, Detroit, MI 48220; Mr. Robert R. Aronson President Electric Fuel propulsion Corp. 366 W. Eight Mile Road Detroit MI 48220; Dear Mr. Aronson: This is in reply to your letter of November 26, 1973, inquiring abou the applicability of Standard No. 301 to your vehicles' gasoline-powered water heaters.; Standard No. 301 was promulgated in order to reduce the incidence o deaths and injuries resulting from fuel-related fires. The standard seeks to accomplish this end by specifying performance requirements which must be met by a motor vehicle's fuel system. Although the fuel systems primarily regulated by the standard are those which propel the vehicle, nothing in the standard limits its application to those systems. A fuel system which powers another aspect of the vehicle's operation, such as the gasoline- powered Stewart Warner Water Heater, is susceptible to the same hazards as the more commonly encountered fuel system, and thus they must be regulated in the same manner in order to fulfill the purposes of Standard No. 301.; Yours Truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2206OpenHoward A. Heffron, Esq., 1700 Pennsylvania Avenue, N.W., Washington, DC, 20006; Howard A. Heffron Esq. 1700 Pennsylvania Avenue N.W. Washington DC 20006; Dear Mr. Heffron: This is in reply to your letter of February 13, 1976, asking for confirmation of your understanding that Motor Vehicle Safety Standard No. 108 does not apply to lighting equipment intended as replacement equipment on motor vehicles manufactured before January 1, 1972.; You are correct in your interpretation. The effective date of Standar No. 108 in its current form is January 1, 1972. Therefore, the term 'any vehicle to which this standard applies' contained in S4.7.1 means a motor vehicle manufactured on or after January 1, 1972, and school bus signal lamps intended as replacements for similar lamps on pre-1972 buses are not required to conform to Standard No. 108. This also means, of course, that the manufacturer has no obligation to certify conformance to all applicable Federal motor vehicle safety standards. As motor vehicle equipment, however, its manufacturer would be subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act in the event of the determination of a safety related defect.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0038OpenMr. H. F. Barr, Vice President, General Motors Technical Center, Warren, MI 48090; Mr. H. F. Barr Vice President General Motors Technical Center Warren MI 48090; Dear Mr. Barr: Thank you for your letter of November 13, 1967, in which approval of dynamic inertia load test procedure, as set forth in paragraph S4.3 of Federal Motor Vehicle Safety Standard No. 206, was requested.; This is to advise that the proposed procedure, as outlined in th enclosure to the referenced letter, is approved for the transverse inertia load portion of the standard test requirements.; Thank you for your continued cooperation in achievement of our mutua goals in motor vehicle safety.; Sincerely, William Haddon, Jr., M.D., Director |
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.