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: aiam2514OpenMr. H. Miyazawa, Director, Automotive Lighting, Engineering Department, Stanley Electric Co., Ltd., 2-9-13 Nakameguro, Meguro-Ku, Tokyo 153, Japan; Mr. H. Miyazawa Director Automotive Lighting Engineering Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-Ku Tokyo 153 Japan; Dear Mr. Miyazawa: This is in reply to your letter of February 14, 1977, concerning th symbol 'DOT' as a certification of compliance to FMVSS No. 108.; The symbol 'DOT' is permitted by the Standard to be placed on the ite of equipment in lieu of the certification requirements of Section 114 of the 'National Traffic and Motor Vehicle Safety Act of 1966,' which states, in part '...In the case of an item of motor vehicle equipment such certification may be in the form of a label or tag on such item or on the outside of a container in which such item is delivered...'; DOT' on the individual container does not meet the certificatio requirements. The label or tag must state that the item 'conforms to all applicable Federal motor vehicle safety standards.'; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam0276OpenMr. Howard M. Rensin, Lesser & Leaser, Executive Building, 1030 - 15th Street, N. W., Washington, DC 20005; Mr. Howard M. Rensin Lesser & Leaser Executive Building 1030 - 15th Street N. W. Washington DC 20005; Dear Mr. Rensin: This is in reply to your letter of March 26, 1971, concernin regulations pertaining to automobile windshields.; Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses*, a copy of which is enclosed, specifies the requirements of automotive glazing materials manufactured on or after January 1, 1968. ANSI Standard Z26.1- 1966, incorporated by reference, can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10018, at a cost of $4.00.; The marking of the windshield that you depict in your letter of Marc 26 is not sufficient to identify its manufacturer. However, based on the '63' in the marking and the fact that the windshield shape fit the 1969 Plymouth, it can be hypothesized that the material in question is a laminated windshield of the improved design that has been used in 1966 and later models of U.S. automobiles.; There is not a requirement that windshields of this type completel shatter leaving no jagged fragments upon collision.; Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs; |
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ID: aiam0752OpenMr. Jacinto Navarro, 1701 E. Frierson Avenue, Tampa, Florida 33610; Mr. Jacinto Navarro 1701 E. Frierson Avenue Tampa Florida 33610; Dear Mr. Navarro: I am writing in response to your letter of June 13, 1972, regardin Standard No. 125, Warning Devices. In addition to the final rule (37 F.R. 5038) a copy of which we have already sent to you, a reconsideration and amendment was published in the *Federal Register* on June 22, 1972 (37 F.R. 12323). I enclose a copy of that notice.; You enclose a sketch of a warning device which you have designed, an you ask whether the manufacture of such a device would be permitted under Standard 125. From your drawing the device appears to consist of an 'orange fluorescent colored' balloon to which a triangle of 'reflex-reflective' tape is affixed. The device is inflated and attached to the vehicle roof by a magnet. The device does not have a self-contained energy source, and therefore must meet the shape, size, and performance requirements of Standard 125.; The balloon device as shown in the sketch fails to meet a number of th Standard 125 requirements, including configuration, luminance, (the triangle itself must meet the luminance requirements,) stability, and durability. (See paragraphs S4.2, S4.5, S4.6 and S4.7 of the standard.) accordingly, manufacture of the device as it appears in the drawing would be prohibited by Standard 125.; I hope this answers your questions. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4820OpenThomas R. Mounteer, Esq. Keller & Heckman 1150 17th Street, N.W. Suite 1000 Washington, D. C. 20037; Thomas R. Mounteer Esq. Keller & Heckman 1150 17th Street N.W. Suite 1000 Washington D. C. 20037; Dear Mr. Mounteer: This responds to your letter on behalf of you client, Heritage Motors, that asked whether Heritage, given the nature of its manufacturing process, must assign its own Vehicle Identification Numbers (VINs). I apologize for the delay in this response. As discussed below, since Heritage considers the vehicles it manufactures to be: (l) 'new' vehicles and (2) manufactured in one stage, it must assign its own VINs to the cars. I note that this letter addresses the vehicles Heritage assembles and not the 'kits' which Heritage also sells. According to your letter, Heritage Motors makes replica Mercedes 500K passenger cars, using 1970-1981 Chevrolet Camaros as donor cars. An information brochure accompanying your letter describes the parts that are removed from the Camaros and then reused in the Mercedes replica. Since Heritage uses a new body, engine, transmission, and many other new or remanufactured parts, you have considered the completed vehicle to be a 'new' motor vehicle. Moreover, Heritage manufactures the vehicles in one stage. Under section S4.l of Federal Motor Vehicle Safety Standard No. ll5, Vehicle Identification Number--Basic Requirements, each vehicle manufactured in one stage must have a VIN that is assigned by the manufacturer. Heritage must therefore assign its own VIN numbers to the cars it manufactures. I hope this information is helpful. If you have any additional questions, please feel free to contact Ms. Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam1201OpenMr. Charles J. Calvin, Managing Director, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin Managing Director Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: This is in reply to your letter of July 5, 1973, requesting a unifor location for trailer certifications labels required by both the Hazardous Materials regulations (49 CFR S 178.340-10) and NHTSA Certification regulations (49 CFR Part 567). You request that location be specified as the 'forward half of the left side of the trailer.'; NHTSA Certification regulations, as you note, presently provide tha the certification label for trailers must be placed on the 'forward half of the left side of the vehicle' (49 CFR S 567.4(d)). This requirement does not distinguish between the frame and the tank shell, and the reference to 'vehicle' in the language of the provision is considered inclusion of both. The Certification regulations therefore appear to permit the location of the label that you request.; I note, however, the drawings in your letter, those titled 'Acceptabl Locations of Certification Labels' and 'Suggested Locations for Certification Labels', picture as an appropriate label location the front of the vehicle.; This location is not permitted by the NHTSA Certification regulations which clearly call for the label to be affixed to the vehicle 'left side'. While it is not clear whether you intended to request that the label be permitted to be affixed to the vehicle front, we do not find sufficient justification in your letter to depart from the existing requirements in this regard.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs; |
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ID: aiam1199OpenMr. Charles J. Calvin, Managing Director, Truck Trailer Manufacturers Association, 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Charles J. Calvin Managing Director Truck Trailer Manufacturers Association 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Calvin: This is in reply to your letter of July 5, 1973, requesting a unifor location for trailer certifications labels required by both the Hazardous Materials regulations (49 CFR S 178.340-10) and NHTSA Certification regulations (49 CFR Part 567). You request that location be specified as the 'forward half of the left side of the trailer.'; NHTSA Certification regulations, as you note, presently provide tha the certification label for trailers must be placed on the 'forward half of the left side of the vehicle' (49 CFR S 567.4(d)). This requirement does not distinguish between the frame and the tank shell, and the reference to 'vehicle' in the language of the provision is considered inclusion of both. The Certification regulations therefore appear to permit the location of the label that you request.; I note, however, the drawings in your letter, those titled 'Acceptabl Locations of Certification Labels' and 'Suggested Locations for Certification Labels', picture as an appropriate label location the front of the vehicle.; This location is not permitted by the NHTSA Certification regulations which clearly call for the label to be affixed to the vehicle 'left side'. While it is not clear whether you intended to request that the label be permitted to be affixed to the vehicle front, we do not find sufficient justification in your letter to depart from the existing requirements in this regard.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs; |
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ID: aiam0312OpenMr. John L. MacLaren, General Manager, Western Safety Devices Company, 4041 Hollis Street, Emeryville, CA 94608; Mr. John L. MacLaren General Manager Western Safety Devices Company 4041 Hollis Street Emeryville CA 94608; Dear Mr. MacLaren: In response to your letter of March 10, 1971, to Mr. Douglas W. Toms Administrator, National Highway Traffic Safety Administration, concerning Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems, Trucks, Buses and Trailers, the following information is offered.; >>>1. Standard No. 121 applies only to new vehicles manufactured on o after January 1, 1973.; 2. Federal Motor Vehicle Safety Standard No. 121 does not preclude th use of a dashboard-mounted control for the tractor protection valve.; 3. Standardization of a dashboard- mounted control valve is no contemplated at the present time.; 4. A petition requesting reconsideration of the requirements for parking brake control valve in S5.4.6 has been received and is being considered at the present time. The decision in response to this and other petitions will be published in the *Federal Register* in the near future.<<<; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1466OpenMr. Earl V. Gordon, Manager of Engineering, The Adams & Westlake Company, 1025 North Michigan Street, Elkhart, IN 46514; Mr. Earl V. Gordon Manager of Engineering The Adams & Westlake Company 1025 North Michigan Street Elkhart IN 46514; Dear Mr. Gordon: This is in reply to your letter of March 13, 1974, asking whethe S5.3.2. of Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release,' permits the use of more than one release mechanism on any one opening if each mechanism requires a separate motion to release.; Standard No. 217 does not prohibit the use of more than one separat release mechanism for a single opening. However, S5.3.2 does limit to two the number of total force applications, and this limits the number of separate release mechanisms to two. If two release mechanisms are used, each must be operated by only one force application, and one of these force applications must differ by 90 degrees to 180 degrees from the direction of the initial push-out motion of the emergency exit.; Of course, in using this configuration, the other requirement pertaining to emergency exits and release mechanisms in Standard No. 217 must also be met.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0483OpenMr. R. O. Sornson, Manager, Environmental and Safety Relations Department, Chrysler Corporation, P O Box 1919, Detroit, MI, 48231; Mr. R. O. Sornson Manager Environmental and Safety Relations Department Chrysler Corporation P O Box 1919 Detroit MI 48231; Dear Mr. Sornson: This is in reply to your letter of November 4, 1971, to Mr. J. E Leysath of this Office, concerning the maximum candlepower for taillamps as specified in Federal Motor Vehicle Safety Standard No. 108.; Paragraph S5.1 of Standard No. 108 (35 FR, 16840, October 31, 1970) i quoted as follows:; >>>'S5.1 SAE Standards and Recommended Practices subreferenced by th SAE Standards and Recommended Practices included in Tables I and III and paragraphs S4.1.4 and S4.5.1 are those published in the 1970 edition of the SAE Handbook.'<<<; Subreferenced SAE Standard J575, as published in the 1970 edition o the SAE Handbook, is the 'd' revision (SAE J575*d*, August 1967). SAE Standard J575d specifies a maximum of 15 candlepower for a single compartment taillamp, 20 candlepower for a 2-compartment taillamp, and 25 candlepower for a 3- compartment taillamp. These maximum candlepower values are, therefore, applicable requirements under Standard No. 108 (35 FR, 16840, October 31, 1970).; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0996OpenMr. J.C. Tim Scates, First National Bank Building, 621 Seventeenth Street, Twenty-third Floor, Denver, CO 80202; Mr. J.C. Tim Scates First National Bank Building 621 Seventeenth Street Twenty-third Floor Denver CO 80202; Dear Mr. Scates:This is in reply to your letter of January 25, 1973 concerning the procedures to be followed by your client in the event that a defaulting vehicle owner refuses to disclose the mileage when his vehicle is repossessed.; The Federal Odometer Disclosure Requirements were issued in final for on January 23, 1973, and become effective March 1, 1973. After March 1, your client will be obliged to make a disclosure statement upon resale of the vehicle. If he cannot obtain a statement from the defaulting owner, he will have to advise the buyer of the deficiency in order to protect himself from liability in the event the odometer is found to be wrong. Our regulation does not address this situation directly, but it would appear that the disclosure statement you propose conforms to the basic outline and would afford protection from civil liability under the Act.; Yours 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.