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: nht78-3.41OpenDATE: 02/02/78 FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA TO: Minnesota Department of Public Safety TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of November 15, 1977, requesting an exemption from the Federal odometer disclosure regulations which will become effective as of January 1, 1978. We appreciate the efforts of Minnesota to include odometer information on its certificates of title. However, we are not granting any exemptions for States which have not previously had odometer information on their titles. Since the citizens of your State have had to execute separate odometer disclosure statements in the past they will not be placed under any additional burden by this ruling. They will merely continue past practices until such time as Minnesota incorporates the revised odometer format on their titles. |
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ID: 86-1.13OpenTYPE: INTERPRETATION-NHTSA DATE: 01/30/86 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Commander, Naval Safety Center, Naval Air Station, Norfold, VA TITLE: FMVSS INTERPRETATION TEXT:
Commander Naval Safety Center Naval Air Station Norfolk, VA 23511-5796 Ref: 5100 Ser 42/5064 Thank you for your letter of December 5, 1985, following up on a number of phone conversations between your staff and mine, concerning the effective dates of the Federal standard requiring the installation of safety belts in motor vehicles. As requested by your staff, we have prepared the enclosed information sheet to be used as a guide by your security personnel in enforcing the safety belt use requirements on naval installations. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosure |
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ID: nht90-2.82OpenTYPE: Interpretation-NHTSA DATE: June 12, 1990 FROM: Derek Sander, Motores Internacionales, S.A. TO: Tony Llama, DAVENPORT ENTERPRISES TITLE: None ATTACHMT: Attached to letter dated 8-2-90 to T. Llama from P. J. Rice; (A35; Part 591); and letter dated 6-11-90 to S. P. Wood from T. Llama; (OCC 4894) TEXT: The purpose of this letter is to inform you that, according to our conversation, we have decided to ship to your company a "RAF" Van, built in the Soviet Union. Its respective numbers of chassis and engine will be forwarded to you shortly. As we discussed, we would like to have you design and install a dual air conditioning unit for this van. This is a new type of vehicle and there is not one available anywhere in the market. Please let us know the requirements, as well as, the most convenient Port of Entry into the United States. |
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ID: nht93-7.45OpenDATE: October 29, 1993 FROM: Darryl Cobb (Abbeville, GA) TO: Office of Chief Counsel, U.S. Department of Transportation TITLE: None ATTACHMT: Attached to letter dated 4/7/94 from John Womack to Darryl Cobb (A42; Std. 111) TEXT: Enclosed in this letter you will find information on a mirror that I would like to import into this country. My questions are, is there any prohibitions in the law that would keep the mirror from being sold as an AFTER MARKET PRODUCT? Would it be legal for people who sell the mirror to also install them? (I am specifically referring to outside rearview mirror-driver's side of the car.) Finally, will the law allow someone other than the owner of the car to install the mirror? Please send me an interpretation and copy of the law(s) which pertain to my questions. Thank you for your attention.
(Brochure and photos omitted.) |
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ID: nht90-2.17OpenTYPE: Interpretation-NHTSA DATE: April 18, 1990 FROM: Michael O'Donnell TO: Chief Counsel's Office, NHTSA TITLE: Applicable Regulations ATTACHMT: Attached to letter dated 7-18-90 to Michael O'Donnell from Paul Jackson Rice; (A35; VSA 108(a)(2) TEXT: Some time ago, I contacted Ms. Tislghman at telephone #: 1-202-366-2992 inquiring about your departmental regulations regarding non-commercial vehicles. At that time, I was informed that National Highway Transportation Safety Regulations only apply in r egard to the manufacture of New Vehicles and further these regulations only apply in regard to vehicles made/used for commercial application(s). If this is still the case, I would appreciate a letter from you to that effect. If not, please inform me of any regulations applying to a recreational vehicle/house coach. The vehicle is a 1977 school bus conversion and is for personal and family use only, not for any type of commercial operation. I will supply any further information you may require. Thank you for your prompt attention and cooperation. |
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ID: Congressman Tom UdallOpenThe Honorable Tom Udall Member, U.S. House of Representatives 811 Saint Michaels Drive, Suite 104 Santa Fe, New Mexico 87505 Dear Congressman Udall: Thank you for your letter of January 12 on behalf of your constituent, Mr. Lance Tunick, who raised concerns about two requests he submitted to the National Highway Traffic Safety Administration (NHTSA). The first is a request for interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, and the second, a petition requesting that the Morgan Motor Company be temporarily exempted from the advanced air bag requirements. I am pleased to inform you that decisions have been made on both of these requests. On January 18, NHTSA responded to Mr. Tunicks request for interpretation of FMVSS No. 208. On January 30, NHTSA issued a Federal Register notice responding to Morgans petition for exemption. It was published February 2 and appears at page 5099 in volume 72 of the Federal Register. We have enclosed copies of both documents for your convenience. I apologize for the delay in our response to his inquiries. I hope this information is helpful. If you have any questions, please have your staff contact me or Anthony M. Cooke, Chief Counsel, at (202) 366-9511. Sincerely yours, Michael W. Harrington Director of External Affairs Enclosures cc: Washington Office ref:208 d.3/16/07 |
2007 |
ID: nht89-1.79OpenTYPE: INTERPRETATION-NHTSA DATE: 04/20/89 FROM: JIM BOWEN -- VICE-PRESIDENT OF QUALITY, SERVICE & PARTS, GULF STREAM COACH, INC. TO: OFFICE OF CHIEF COUNSEL TITLE: N ATTACHMT: ATTACHED TO LETTER DATED SEPTEMBER 21, 1989 FROM STEPHEN P. WOOD TO JIM BOWEN, GULF STREAM COACH, INC.;[A34; STD. 101] TEXT: I have a question on the N.H.T.S.A. ruling on the instal- lation of a T.V. in the view of the driver of a vehicle. I would like to know if the T.V. has to be off, when the ignition switch is turned on. Your response in writing would be appreciated. Sincerely, |
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ID: nht88-4.17OpenTYPE: INTERPRETATION-NHTSA DATE: 11/26/88 FROM: M. M. YOON -- DIRECTOR, IN-ONE DEVELOPMENT CORP. SEOUL, KOREA TO: STEVE KRATZTE -- OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 03/31/89 FROM ERIKA Z. JONES -- NHTSA TO M. J. YOON, REDBOOK A33 (2), PART 571.3 TEXT: DEAR, MR. KRATZTE WE, IN-ONE DEVELOPMENT CORP., ARE DOING AS RESEARCH AND DEVELOPMENT CENTER OF SSANGYONG MOTOR COMPANY, PROCEEDING TWO PROJECTS WHICH ONE OFF-ROAD VEHICLE AND ONE PASSENGER CAR AND PLANNING TO LAUNCH THE CARS IN U.S.A. THEREFORE, WE WOULD LIKE TO KNOW THE VEHICLE CLASSIFICATIONS (PASSENGER CAR OR MULTIPURPOSE PASSENGER CAR) OF OFF-ROAD VEHICLES PLANNED TO PRODUCT IN THE END OF 1991. FOR YOUR REFERENCE, GENERAL SPECIFICATIONS OF THE VEHICLE ARE AS FOLLOWS. OVERALL LENGTH: 4200 approx. 4250 mm, DRIVE SYSTEM: 4 WHEEL DRIVE (PART TIME) OVERALL WIDTH: 1716 mm, FRAME: LADDER TYPE FRAME HEIGHT (ON GROUND): 1670 approx. 1700 mm WINDSCREEN SLOPE ANGLE: 55 degrees APPROACH ANGLE: 40 degrees DEPARTUER ANGLE: 30 degrees GROUND CLEARANCE (IN LADEN CONDITION): MINIMUM 200 mm (THE SHAPE OF THE VEHICLE LOOKS LIKE PASSENGER CAR; AERODYNAMIC SHAPE) AND, WE ALSO WANT TO KNOW THE CRITERIA FOR VEHICLE TYPE CLASSIFICATIONS. YOU ARE KINDLY REQUESTED TO SENT THE INFORMATIONS, IF AVAILABLE. WE ARE LOOKING FORWARD TO YOUR PROMPT RESPONSE. NOTE). OUR ADDRESS & FAX. NO ARE AS FOLLOWS. ADDRESS: 2nd FLOOR, GUKDONG BUILDING, 3-GA CHUNGMOO-RO, JUNG-GU, SEOUL, KOREA. FAX. NO: 02-277-5321 SINCERELY YOURS |
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ID: 24393.rbmOpenDonald S. Litman, Esq. Dear Mr. Litman: This responds to your question as to whether plastic exterior door handles are prohibited by any Federal motor vehicle safety standards (FMVSSs). The short answer to your question is no, exterior plastic door handles are not prohibited under any of the safety standards. By way of background, the National Highway Traffic Safety Administration (NHTSA) administers a statute requiring that motor vehicles manufactured for sale in the United States or imported into the United States be manufactured so as to reduce the likelihood of motor vehicle crashes and of deaths and injuries when crashes do occur. We refer to that statute as the Vehicle Safety Act. It is codified at 49 U.S.C. 30101, et seq. One of the agencys functions under the Vehicle Safety Act is to issue and enforce FMVSSs. These standards specify safety performance requirements for motor vehicles and/or items of motor vehicle equipment. FMVSS No. 206, Door locks and door retention components, most closely addresses your question regarding exterior door handles. FMVSS No. 206 does not directly regulate either interior or exterior door handles. It does, however, impliedly require both interior and exterior door handles or other release mechanisms in its regulation of door locks (see generally, 49 CFR 571.206, S4.1.3 and S4.4.2). FMVSS No. 206 does not prohibit or require that the door handles or release mechanisms be composed of any particular material. Rather, it specifies performance requirements. Should you require any additional information or assistance, please contact Rebecca MacPherson, of my staff, (202) 366-2992 or at the address given above. Sincerely, |
2002 |
ID: nht94-4.89OpenTYPE: INTERPRETATION-NHTSA DATE: November 28, 1994 FROM: Melinda Dresser -- Manager Contracts/Transportation, Carlin Manufacturing, Inc. TO: Philip R. Recht -- Office of Chief Counsel, NHTSA TITLE: NONE ATTACHMT: Attached to 1/9/95 letter from Philip Recht to Melinda Dresser (A43; Std. 108) TEXT: Carlin Manufacturing, Inc. designs and manufactures mobile kitchens and specialty vehicles for organizations such as Pizza Hut, Burger King, McDonald's, Salvation Army, and California Department of Forestry. We also build units for off-premise caterers, fire fighters, emergency service organizations, and all branches of the armed forces. As a vehicle manufacturer, (license #23791) our vehicles conform to applicable federal and California standards, including, but not limited to, California Department of Motor Vehicles, California Code of Regulations, and National Highway Traffic Safety A dministration. We are currently in the final manufacturing stage for six (6) driveable "Wienermobiles" for Oscar Mayer. Since the outside structure is not a typical configuration, we are asking for a ruling determining the requirements for exterior lighting, as per 49 C.F.R. Part 571 section 108. Please review the attached drawings showing the location of the exterior lighting; including headlights, tailights, side and front markers. Please advise at your earliest convenience, whether our application of exterior lighting for the "Wienermobile" will meet Federal Motor Vehicle Safety Standards and Regulations. Our "Wienermobile" program is on HOLD pending your determination. Since th ree of the Oscar Mayer "Wienermobiles" are scheduled for a nationwide rollout January 1, 1995, your prompt reply to this project will be greatly appreciated. If you should have any questions, please feel to call contact our Project Engineer, Anton Holty, at 209/276-0123, for further clarification. Thanking you in advance, Sincerely, |
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.