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: aiam2757OpenMr. R. C. Evans, Vice President, O Sullivan Corporation, P.O. Box 603, Winchester, VA 22601; Mr. R. C. Evans Vice President O Sullivan Corporation P.O. Box 603 Winchester VA 22601; Dear Mr. Evans: This is in reply to your letter of February 3, 1978, to Mr. Guy Hunte of my staff, requesting assignment of a DOT' code number for purposes of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, *Glazing Materials*. You state that you supply vinyl plastic sheeting to your customer who, in turn, laminates and polishes this sheeting for use as glazing in the rear window opening of convertibles.; Under paragraph S6 of FMVSS No. 205 (a copy was previously mailed t you), the assignment of a code number is restricted to prime glazing material manufacturers. Prime glazing material manufacturers are those who either fabricate, laminate, or temper the glazing material. Since you merely supply the material to your customer who then laminates and polishes it for use as glazing, you are not considered the prime manufacturer and assignment of a code number to you is not appropriate. Your customer is the prime manufacturer in this case and it is his responsibility to certify that his glazing meets the requirements by the means specified in FMVSS No. 205.; If I can be of further help, do not hesitate to contact me. Sincerely, E. T. Driver, Acting Associate Administrator for Rulemaking |
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ID: GF001832OpenMr. E. Paul Daniels Dear Mr. Daniels: This responds to your letter dated January 26, 2005, asking whether S6.4 of Federal Motor Vehicle Safety Standard (FMVSS) No. 119 permits a motorcycle tire treadwear indicator height of greater that 0.8 mm.You asked about the possibility of raising it by as much as 0.6 mm, i.e., to 1.4 mm on new molds. By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements. The Federal standard applicable to your question is FMVSS No. 119, New pneumatic tires for vehicles other than passenger cars.The relevant portion of that standard reads as follows:
The treadwear indicator requirement in S6.4 sets forth a specific standardized treadwear indicator height.A higher treadwear indicator is not permitted.We note that if the treadwear indicator height were raised to 1.4 mm, consumers would not be able to visually determine when the tire wore to a depth of 0.8 mm. We further note that in a document published on January 30, 1996, the agency denied a petition for rulemaking from Herzlich Consulting, Inc. to increase the treadwear indicator height requirement for passenger car tires (see 61 FR 2991).The agency explained that the treadwear indicator height limit was based on a long-standing industry practice, and that NHTSA adopted this industry practice. I hope you find this information helpful.If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992. Sincerely, Jacqueline Glassman ref:119 |
2005 |
ID: nht92-7.15OpenDATE: May 6, 1992 FROM: Kevin B. Brown -- Manager, Fleet Services, EG&G Idaho, Inc. TO: NHTSA TITLE: VEHICLES PURCHASED FOR THE IDAHO NATIONAL ENGINEERING LABORATORY (INEL) THROUGH THE GENERAL SERVICES ADMINISTRATION (GSA) - KBB-09-92 ATTACHMT: Attached to letter dated 9/4/92 from Paul Jackson Rice to Kevin B. Brown (A39; Part 567) TEXT: EG&G Idaho, Inc. is the prime contractor for the Department of Energy, Idaho Field Office (DOE-ID) to procure and maintain all government-owned vehicles at the Idaho National Engineering Laboratory (INEL). Vehicles are procured for DOE-ID through the General Services Administration (GSA). Occasionally truck chassis are purchased through GSA for subsequent mounting of service bodies to be used for official government business. Our inquiry is to the 49 CFR 567 requirements for intermediate or final stage manufacture vehicle labeling. We would not be constituted as a merchant, or the first purchaser for resale. The mounting body would be in accordance to the original equipment manufacturer of the vehicle, or the vehicle recommended by the body manufacturer. Following the service life of the vehicle, it may be excessed to another Federal or State agency, or sold to the public. All vehicles assigned to the INEL are maintained to the manufacturer's specifications and to the Federal Motor Vehicle Safety Standards. A description of vehicles for subsequent mounting of service bodies are provided below: New truck chassis or existing used; installing service bodies, dump bodies, van bodies, and related accessories. Trucks range in size from 8,500 pounds gross vehicle weight (GVW) to 48,000 pounds GVW. Based on the above information, would EG&G Idaho need to be certified to install intermediate or final stage labels per 49 CFR 567? Please send your response to the following address: Mr. Kevin B. Brown EG&G Idaho, Inc. P. 0. Box 1625 Idaho Falls, ID 83415-4103 If you should need additional information, please contact me at (208) 526-2075. |
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ID: 77-2.16OpenTYPE: INTERPRETATION-NHTSA DATE: 04/19/77 FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA TO: Irene Glessner TITLE: FMVSR INTERPRETATION TEXT: This responds to your March 21, 1977, letter asking whether a tire dealer is required to record the serial numbers of the tires he sells. The National Highway Traffic Safety Administration (NHTSA) promulgates regulations pertaining to tires. One of these regulations, Part 574, Tire Identification and Recordkeeping, requires tire dealers and distributors to obtain information when the tire is sold and to forward that information to the tire manufacturer. I am enclosing a copy of this regulation for your information. In @ 574.7 of the regulation you will find the exact information for which a tire dealer is responsible. A tire dealer would not be responsible for the ultimate recall of tires. The information which a dealer submits to a manufacturer enables the manufacturer to undertake recalls. Failure to record and submit the information to a manufacturer would be a violation of Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966 (as amended) (15 U.S.C. 1381, 1397). Each violation is punishable by a civil penalty of $ 1,000 up to a maximum of $ 800,000 for a series of violations (15 U.S.C. 1398). SINCERELY, March 21, 1977 The Chairman National Transportation Safety Board Dear Sir: I am very much interested in finding out about the law (if there is one) that requires a tire dealer to record the serial numbers of the tires that he sells. If I am not writing to the correct government agency, will you please tell me where to direct my inquiry? I want to find out if there is a specific penalty or fine that can be levied against a tire dealer if he has not recorded the serial numbers of tires he sells, and at a later time there is some conflict or a recall pertaining to the sale of those tires. Thank you for your assistance. Irene Glessner |
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ID: nht75-5.32OpenDATE: 07/11/75 FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA TO: Pennsylvania Independent Automobile Dealers Association TITLE: FMVSR INTERPRETATION TEXT: You letter of April 21, 1975, to the Federal Trade Commission concerning the validity of an enclosed odometer disclosure form has been forwarded to this office for reply. The odometer mileage disclosure portion of the East End Motors' sales contract does not satisfy the requirements of the odometer disclosure regulation (49 CFR Part 580). In order to fulfill the requirements, the following information must be added: the vehicle identification number, the vehicle's last plate number, the vehicle transferor's address, the date of the disclosure statement, a reference to the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513) and the liability it imposes, and a statement, if applicable, that the vehicle's actual mileage differs from the odometer reading for reasons other than odometer calibration error and the actual mileage is unknown. Failure to include all of the above information on the odometer disclosure statement executed at the time ownership of a vehicle is transferred constitutes a violation of section 408 of the Cost Savings Act and may make the violator liable in the amount of $ 1,500 or treble damages. For your information I have enclosed copies of the relevant portions of the Act and the disclosure requirements. You will note that @ 580 of the regulation contains a sample odometer mileage statement. Incorporation of this format into a sales contract would satisfy the Federal requirements. |
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ID: nht79-4.23OpenDATE: 10/22/79 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Uniroyal GmbH TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of October 12, 1979, asking whether the character height of 5/32nds of an inch, stated in the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104, Figure 1), is considered by the National Highway Traffic Safety Administration (NHTSA) to specify the only acceptable height for UTQG sidewall molding, or whether the agency interprets this measurement as a minimum value. The specification of 5/32nds of an inch tire sidewall characters was intended by NHTSA to establish a minimum requirement to assure readability of the UTQG information presented. The agency has no objection to the use of characters of a height greater than 5/32nds of an inch, so long as all characters used to convey UTQG information are of the same height. |
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ID: 77-1.47OpenTYPE: INTERPRETATION-NHTSA DATE: 03/17/77 FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA TO: Lucas Industries North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your February 4, 1977, question whether Safety Standard No. 116, Motor Vehicle Brake Fluids, permits DOT 3 and DOT 4 brake fluids to be colored "fluorescent yellow." The answer to your question is yes. Paragraph S5.1.14 of Standard No. 116 specifies that DOT 3 and DOT 4 fluids manufactured on or after September 1, 1978, shall be "colorless to amber." The agency interprets this color range to include any "yellow," whether or not fluorescent. Although not required, we consider fluorescence to be an added safety factor since it would facilitate the detection of leaks in the braking system. Sincerely, ATTACH. Office of the Chief Counsel -- National Highway Traffic Safety Administration Dear Sir Federal Motor Vehicle Safety Standard No. 116 - Brake Fluids Girling Limited manufactures motor vehicle brakes in the United Kingdom and also markets brake fluid. Girling Limited, like ourselves, is a subsidiary of Lucas Industries Limited of England. Girling products enter this country as original equipment on imported vehicles and, also, we import and market their products. We wish to know whether "fluorescent yellow" is an acceptable color for DOT 3 and DOT 4 motor vehicle brake fluids. The definition of clear-to-amber does not make this apparent. Yours truly LUCAS INDUSTRIES NORTH AMERICA INC; A J Burgess -- Vice President (Technical) cc: F Redler, NHTSA |
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ID: 1984-2.10OpenTYPE: INTERPRETATION-NHTSA DATE: 06/18/84 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: John C. Bobak -- President, Crest Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: John G. Bobak President Crest Industries, Inc. 3841 13th Street Wyandotte, MI 48192 This responds to your letter of May 9, 1984, regarding the application of Federal motor vehicle safety standard No. 212, Windshield retention and standard No. 216, Roof crush resistance to aftermarket windshield adhesives. Your specific question concerned a statement made by Kent Industries that its urethane windshield adhesive "meets and exceeds" those two standards.
You are correct in your understanding that Standards Nos. 212 and 216 only apply to newly manufactured motor vehicles. The standard establish a certain level of performance for those vehicles and do not set specifications for such individual vehicle components as windshield adhesive. In addition, neither of these standards apply to item of motor vehicle equipment, such as windshield adhesive, sold as aftermarket products.
If you have any further questions please let me know. Sincerely Original Signed By Frank Berndt Chief Counsel LETTER FROM JOHN G. BOBAK IS NOT LEGIBLE. |
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ID: nht73-2.23OpenDATE: 03/26/73 FROM: Francis Armstrong; Francis Armstrong; Office of Standards Enforcement TO: File TITLE: FMVSS Interpretation TEXT:
March 26, 1973 Close-out of Investigatory File, CIR 584 N41-21RGa; CIR 584 Director, Office of Standards Enforcement File The Investigatory File, CIR 584, has been closed out inasmuch as the manufacturer utilitzed a driver test dummy during his certification tests. This alternate certification technique is permissible by FMVSS No. 204. A maximum rearward dynamic horizontal displacement of 5.1 inches was obtained on the standards enforcement Checker test vehicle, NHTSA No. 71518, during a 29.3 mph frontal barrier impact. This maximum displacement was only 0.1 inch greater than the maximum allowable and which occurred late (124 msec.) during the collision interval. The manufacturer's submitted data indicated that their test dummy impacted the steering control early (approximately 55 msec.) in the vehicle impact phase and thereby would restrict the steering control rearward displacement. It is therefore, concluded that the NHTSA vehicle would have met the performance requirements of FMVSS No. 204 if the alternate driver dummy technique had been utilized in the test. Francis Armstrong |
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ID: nht89-1.11OpenTYPE: INTERPRETATION-NHTSA DATE: 02/01/89 FROM: LES SCHREINER -- FRESIA ENGINEERING INC. TO: CHIEF COUNCIL, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 04/03/89 FROM ERIKA Z. JONES -- NHTSA, TO LESS SCHREINER, REDBOOK A33 (2), VSA 102 (3) TEXT: Gentlemen: Our company is a wholly owned subsidiary of an Italian corporation wishing to market its product in the United States. Future plans include U.S. manufacture as demand increases. The potential market for our products is both off road cliental (e.g., air ports) and public road organizations such as city, county, and state highway departments. Plans also include bidding on contract from various U.S. Government and military branches. It is for this reason we wish to clarify whether our products fall unde r Title 49, Section 571 compliance requirements or are exempt under the act. Technical data on our equipment is included for your review, however, should additional information be required, we would be pleased to provide same. Fresia would also be interested in any approval procedure or testing process NHTSA would administer tha t would establish our equipment on any QPL (Qualified Product List) program. We appreciate your time and consideration and look forward to your response. Best regards, (Enclosure omitted.) |
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.