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: aiam0598OpenMr. John Hall, Dayton Steel Foundry Company, P.O. Box 1022, Dayton, OH 45401; Mr. John Hall Dayton Steel Foundry Company P.O. Box 1022 Dayton OH 45401; Dear Mr. Hall: This is in reply to your letter of February 2, 1972, in which you aske whether the temperature range specified in S6.2.6 of Motor Vehicle Safety Standard No. 121 was an initial temperature range or a range applicable throughout the stop.; In the new issuance of the standard, published in the February 24 1972, issue of the *Federal Register*, the section has been amended to make it clear that the range is the range of initial brake temperature on each stop.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2010OpenMr. F. A. McNiel, 611 Bouldin Avenue, Austin, TX 78704; Mr. F. A. McNiel 611 Bouldin Avenue Austin TX 78704; Dear Mr. McNiel: On May 12, 1975, you petitioned the National Highway Traffic Safet Administration for rulemaking to amend Standard No. 108 to provide 'A means that will hasten the illumination of a vehicles conventional stop warning lamps at any time that a 'panic' or any other exceptionally sudden stop is made, but wherein the said means will not affect the normal functioning of the vehicles lighting system at any other time.'; We have given thoughtful consideration to your petition. It appears t us that the system you prefer would indicate only that the accelerator pedal had been released suddenly, and not that a sudden or 'panic' stop was being made. In our view, a sudden release of the accelerator does not necessarily mean that a panic stop is in progress. Conversely, all sudden stops are not necessarily accompanied by a sudden release of the accelerator. In short, the presumed benefit of the system appears speculative, and no data have been submitted demonstrating that the signaling system would enhance highway safety. For these reasons your petition must be denied.; Standard No. 108 would not preclude the sale of your deceleratio warning device in the aftermarket, subject to regulation by the individual States.; We appreciate your interest in motor vehicle safety. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam4725OpenMr. Charles M.A. Saedt 9940 Springfield Drive Ellicott City, MD 21043; Mr. Charles M.A. Saedt 9940 Springfield Drive Ellicott City MD 21043; Dear Mr. Saedt: This is in reply to your letter of April 8, l990, wit respect to your intended exportation of a Volkswagen manufactured to conform to European specifications. You are a member of the Dutch armed forces, and you will be in the United States until June 1991. You understand that you will need to get an exemption when you import the car into the United States. As Taylor Vinson of this Office explained to you on April 10, at the port of entry you will be required to execute a Form HS-7, a declaration form covering the importation of your car into the United States. It appears that you are eligible to mark Box 12, and to import the vehicle under the declaration that you are a member of the armed forces of a foreign country on assignment in the United States. You must attach a copy of your official orders to this form. When this is done, there should be no problem in importing your car. You also represent by marking Box 12 that you are importing the vehicle for your own personal use and on a temporary basis, that you will not sell the vehicle to any person in the United States, and that you will export the vehicle upon departing the United States at the conclusion of your tour of duty. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam0958OpenMr. H. Kropp, Robert Bosch GMBH, Unternehmensbereich Kraftfahrzeugausrustung, Entwicklungskoordination, 7 Stuttgard 30, Postfach 400, Germany; Mr. H. Kropp Robert Bosch GMBH Unternehmensbereich Kraftfahrzeugausrustung Entwicklungskoordination 7 Stuttgard 30 Postfach 400 Germany; Dear Mr. Kropp: This is in response to your letter of November 28, 1972, regarding th applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 302, 'Flammability of Interior Materials', to battery boxes which are installed in vehicle occupant compartments.; The components that must meet the requirements of the standard ar listed in Paragraph S4.1. However, components not listed specifically in Paragraph S4.1, such as battery boxes, will nevertheless be covered to the extent that they are made of materials 'that are designed to absorb energy on contact by occupants in the event of a crash'.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam4339OpenThe Honorable Bill Schuette, U.S. House of Representatives, P.O. Box 631, Midland, MI 48640; The Honorable Bill Schuette U.S. House of Representatives P.O. Box 631 Midland MI 48640; Dear Mr. Schuette: Thank you for your June 4, 1987, letter on behalf of your constituent Mr. Dale Lighthill of Owosso. Mr. Lighthill owns a semi-trailer which he has converted into a trailer home. He wishes to know whether there is any law which prohibits him from carrying persons in his travel trailer.; Our agency is responsible for promulgating safety standards for th manufacture and sale of new motor vehicles. We have no jurisdiction over the use of motor vehicles and thus have no regulation prohibiting Mr. Lighthill from carrying people in his travel home trailer. However, many states have enacted provisions in their vehicle codes for occupying moving trailers. Some states prohibit persons from occupying a moving trailer or operating a motor vehicle which is towing an occupied trailer, and some permit occupying a moving trailer only under certain circumstances. I am certain that the officials of the states your constituent plans to visit will be happy to provide information on their laws for transporting persons in moving trailers. In addition, Mr. Lighthill might find it helpful to contact the American Association of Motor Vehicle Administrators (AAMVA) for general information on state requirements. The AAMVA may be reached at: Suite 910, 1201 Connecticut Avenue, N.W., Washington, D.C., 20036. Telephone: (202) 296-1955.; Thank you for contacting our office. Please contact me if you or you constituent have any questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3459OpenRodney Spotts, Collection Supervisor, Ford Motor Credit Company, P.O. Box 1578, Columbia, SC 29202; Rodney Spotts Collection Supervisor Ford Motor Credit Company P.O. Box 1578 Columbia SC 29202; Dear Mr. Spotts: This letter is in response to your correspondence of May 14, 1981, t the agency concerning whether the affidavit used for repossessed motor vehicles in South Carolina has been approved by the agency for use in lieu of the Federal disclosure statement. We regret the delay in responding.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the certificate of title or other statedocuments which evidence ownership, if these documents contain essentially the same information required by the Federal odometer disclosure statement. If the inforamtion contained in the state documents varies from that required by the Federal form, the state must obtain; |
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ID: aiam1266OpenMr. John H. Mueller, Manager, Engineering Standards, The Weatherhead Company, 300 East 131st Street, Cleveland, OH, 44108; Mr. John H. Mueller Manager Engineering Standards The Weatherhead Company 300 East 131st Street Cleveland OH 44108; Dear Mr. Mueller: This is in reply to your letter of August 16, 1973, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to nylon tubing used in the interior of a motor vehicle.; The components that must meet the requirements of the standard ar listed in Paragraph S4.1. Nylon tubing is not listed in Paragraph S4.1 and normally will not be subject to the standard's requirements. However, materials may nevertheless be covered to the extent that they are 'designed to absorb energy on contact by occupants in the event of a crash,' or to the extent that they form part of a component listed under Paragraph S4.1.; Yours truly, Richard B. Dyson, Assistant Chief Counsel. |
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ID: aiam0518OpenMr. T. A. Branson, Ambassador Trailers, P. O. Box 2522, Muscle Shoals, Al, 35660; Mr. T. A. Branson Ambassador Trailers P. O. Box 2522 Muscle Shoals Al 35660; Dear Mr. Branson: This is in reply to your letter of November 4, 1971, to the Departmen of Transportation, concerning lighting requirements on your boat trailers.; A copy of Federal Motor Vehicle Safety Standard No. 108, 'Lamps Reflective Devices and Associated Equipment' is enclosed for your information. The location of the lamps and reflectors shown on your drawing appears to meet the requirements of Standard No. 108, providing they are mounted to meet the height requirements.; Since the width of your trailer is more than 80 inches, front and rea clearance lamps and rear identification lamps are also required as specified in Table I and located as specified in Table II. Combination front and rear clearance lamps are allowed in paragraph S4.1.1.9.; There are no other requirements for trailers specified in the Federa Motor Vehicle Safety Standards.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0975OpenMr. F. S. Murley, Administrative Engineer, Oshkosh Truck Corporation, Post Office Box 560, Oshkosh, WI 54901; Mr. F. S. Murley Administrative Engineer Oshkosh Truck Corporation Post Office Box 560 Oshkosh WI 54901; Dear Mr. Murley: This is in reply to your letter of January 4, 1973, in which you as for our confirmation of your interpretation of Part 567 and Part 568 of Title 49 of the Code of Federal Regulations that would place the responsibility for certification on the user in those instances where he is the final-stage manufacturer.; Paragraph 567.5 of Title 49 of the Code of Federal Regulations Requirements for Manufacturers of Vehicles Manufactured in Two or More Stages, specifies that '. . . each final-stage manufacturer, . . . of a vehicle manufactured in two or more stages shall affix to each vehicle a label . . . .' Therefore, end users who are also manufacturers would be required to affix the label.; If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam0116OpenMarti, O'Cara, Dalton and Bruckner, 303 Lincoln Building, Lincoln, NE 68508; Marti O'Cara Dalton and Bruckner 303 Lincoln Building Lincoln NE 68508; Attention: Mr. Warren K. Dalton Gentlemen: Your letter of September 16, 1968, addressed to Mr. George C. Nield o the National Highway Safety Bureau has been forwarded to my office for reply.; From the brief description presented in your letter, it would appea that the proposed Cushman motor vehicle would be considered a 'passenger car' under the definitions included in the Federal Motor Vehicle Safety Standards. At the present time, the standards do not apply to vehicles of 1,000 pounds or less curb weight. However, we are presently contemplating amendment of the Standards to include such vehicles in the near future as presented in the Advance Notice of Proposed Rule Making published October 14, 1967. The rated horsepower of the engine is not relevant in determining applicability of the standards.; Enclosed is a copy of the Advance Notice of Proposed Rule Making fo your perusal.; Sincerely, Eugene B. Laskin, Acting Director, Office of Standard Preparation, Motor Vehicle Safety Performance Service; |
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.