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: nht93-6.36OpenDATE: September 15, 1993 FROM: Jack McIntyre -- V.Pres., Tie Tech Inc. TO: John Womack -- Office of Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 11/23/93 from Jack Womack to Jack McIntyre (A41; Std. 209; Std. 222) and letter dated 8/18/93 from Jack McIntyre to John Womack TEXT: I am writing in reference to my letter of August 18, 1993, concerning the requirements included in Federal Motor Vehicle Safety Standard 222, S5.4.2., and would like to cancel my petition, and ask for an interpretation of this standard. Thank you for taking this matter into consideration. A reply at your earliest convenience would be appreciated. |
|
ID: nht93-1.9OpenDATE: January 14, 1993 FROM: Jay Lee -- President, Pacific Agritrade Inc. TO: Jackson Rice -- NHTSA, Department of Transportation TITLE: None ATTACHMT: Attached to letter dated 3-26-93 from John Womack to Jay Lee (A40; Std. 208; VSA 108(a)(2)(A)) TEXT: We would like to import air bags for cars and light trucks from Korea. This air bag can be installed very easily and we are interested in having this product tested by your department. Please advise us on what procedures we need to take to have this product tested and approximately how long it will take. We are also interested in knowing what we can claim after we pass your tests. |
|
ID: nht71-4.50OpenDATE: 11/17/71 FROM: AUTHOR UNAVAILABLE; J. W. Carson for E. T. Driver; NHTSA TO: Halfpenny, Hahn & Roche TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letters of October 18, 1971, and November 1, 1971, to Mr. Douglas Toms, Administrator, National Highway Traffic Safety Administration, concerning the "Panic-Stop" signal system from Donel Corporation. You are correct in your interpretation that Federal Motor Vehicle Safety Standard No. 108 is not applicable to the "Panic-Stop" system when this system is not installed on motor vehicles as original equipment. The motor vehicle laws and regulations of the individual States, are, however, applicable to the "Panic-Stop" system when sold and used as aftermarket equipment. |
|
ID: nht87-2.29OpenTYPE: INTERPRETATION-NHTSA DATE: 06/30/87 FROM: CHRISTINE COTTLE -- OFFICE ADMINISTRATOR, CLASSIC AUTO ACCESSORIES TO: ERIKA JONES -- CHIEF COURIER, NHTSA TITLE: NONE ATTACHMT: MEMO DATED 10-15-87, FROM ERIKA Z. JONES, TO CHRISTINE COTTLE, VSA 102(4), VSA 108 (A)(2)(A) TEXT: We are interested in obtaining information regarding any federal regulations that may apply to or restrict the use of items which might be suspended from the centered rear view mirror in an automobile or truck. Specifically we are anxious to avoid liability for any obstruction of vision which might occur as the result of the use of such items. I refer to such decorations as hanging dice, air fresheners, etc. Any information you can give me would be most appreciated. |
|
ID: 1985-03.48OpenTYPE: INTERPRETATION-NHTSA DATE: 09/25/85 FROM: Jerome J. Abt -- Trim-Line of West Wisconsin TO: Taylor Vinson -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/12/86 FROM ERIKA Z. JONES -- NHTSA TO JEROME J. ABT TEXT: Dear Mr. Vinson; I am writing in regard to the new Federal regulation requiring stop-lamps on all new cars. My business is the sale and installation of aftermarket auto trim and accesories to new and used car dealers. One of our most popular items in recent years has been flush mount luggage racks on the trunk lids of sedans. Because they are very low profile, these racks do not obstruct the the stop-lamps. My problem is this: several of my best customers for this product are concerned that by installing these racks on the 1986 models, we might be encouraging someone to use them to carry a piece of luggage. It's our feeling that this is a trim item, but the fact is that someone could use it. These particular dealers have refused to buy anymore of these racks from me until we can determine if we are opening ourselves up to some kind of liability, should the stop-lamp be obstructed by luggage placed on this rack and a rear-end collision occur. Now, we realize that the possibility may be remote of such a problem, but none the less, we feel the concern is legitimate considering the litigation-crazy world we live in. We need to know if, legally, we could be held responsible for any such problems. I would very much appreciate any insight you can give me on this matter. This item represents a substantial part of our sales and we need to know where we stand so that we can make an adjustment if needed, as soon as possible. Thank You Very Much For Your Help, |
|
ID: nht90-1.26OpenTYPE: INTERPRETATION-NHTSA DATE: January 26, 1990 FROM: Pat Crahan -- Director, U-Haul International TO: A. L. Burgett -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 7-9-90 to Pat Crahan from Paul J. Rice; A35; Std. 115 TEXT: I had the pleasure of hearing you speak and meeting you during the AAMVA Engineering and Vehicle Inspection workshop at Lake Buena Vista, Florida in December. I was particularly interested in the portion of your talk relating to VIN requirements for trailers. As I recall you stressed that a seventeen digit VIN was required even if a person made a trailer himself and sold it; however if it was not sold the VIN was not required. I asked you if U-Haul was required to have the seventeen digit VIN on our trailers since we make them ourselves and they are never sold? You asked that I write to you, which is the reason for this letter.
LPDS 1989 |
|
ID: nht73-2.43OpenDATE: 12/14/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Peter J. Sferazza; Staff Council TITLE: FMVSR INTERPRETATION TEXT: In response to your request of November 28, 1973, I have enclosed a copy of Part 580, Odometer Disclosure Requirements, 49 CFR Part 580, which was issued under the authority of the Motor Vehicle Information and Cost Savings Act of 1972, 15 U.S.C. @ 1988. The transferor must disclose the mileage as it is recorded on the odometer, and in addition that he knows that reading to be inaccurate if such is the case. This means that a transferor would check the box indicating that the reading does not reflect the mileage, if he knew that the vehicle had traveled more than 100,000 miles. The buyer would then be on notice to ask why the reading was not accurate and to be told that the vehicle had more than 100,000 miles on it. Enclosure |
|
ID: 13720.mlsOpen Mr. Gunnar Almen Dear Mr. Almen: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 105, Hydraulic Brake Systems (49 CFR 571.105). You stated that as the national testing agency for vehicles imported into Sweden, you need to know U.S. regulations for asbestos free brake linings. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized under Title 49, Chapter 301 of the U.S. Code to issue FMVSSs that set performance requirements for new motor vehicles and new items of motor vehicle equipment. NHTSA does not approve or certify any vehicles or items of equipment, as is the practice in Europe. Instead, Chapter 301 establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency has used this authority to issue FMVSS No. 105, which specifies requirements for hydraulic service brake and associated parking brake systems. This Standard does not contain any provision requiring or prohibiting asbestos free brake linings. While most brake linings are asbestos free, some brake linings sold in the aftermarket have asbestos. Please note that the United States Environmental Protection Agency (EPA) has issued rules prohibiting the use of asbestos brakes. We have forwarded your letter to Mr. Mike Matthiesen, Chemical Management Division, Office of Pollution Prevention and Toxics, EPA, 401 M Street, SW, Washington DC 20460. He should be able to explain how EPA's rules apply to asbestos brakes. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely,
Chemical Management Division Office of Pollution Prevention and Toxics, EPA, 401 M Street, SW, Washington DC 20460 ref:105 |
1997 |
ID: 2634oOpen Lawrence C. Bourbeau, Jr., Esq. Dear Mr. Bourbeau: This letter responds to your earlier inquiry where you ask whether NHTSA would object to your Company's changing "its model year designation from September 1 to July 1." I apoligize for the delay in responding. Standard 115, Vehicle Identification Number- Basic Requirements, directs vehicle manufacturers to place a discrete identifying number (VIN) on each vehicle. Title 49 CFR Part 565, VIN- Content Requirements, states that a VIN must include a character indicating the manufacturer's designated model year. Neither Standard 115 nor Part 565 prohibits your company from changing the model year in the manner you suggest. Therefore, such a change does not violate our regulations. We note that this change apparently concerns model year as a marketing concept. The Federal Trade Commission has published guidelines concerning model year as a commercial concept, and you may wish to contact the Commission for whatever assistance it may provide. I hope you find this information helpful. Sincerely,
Erika Z. Jones Chief Counsel ref:115 d:12/22/87 |
1987 |
ID: 1983-1.49OpenTYPE: INTERPRETATION-NHTSA DATE: 05/03/83 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Teledyne Continental Motors -- T.A. Eschbaugh, General Products Division TITLE: FMVSS INTERPRETATION ATTACHMT: 2/8/83 letter from Frank Berndt to Talbot Engineers Inc. TEXT:
Mr. T. A. Eschbaugh Teledyne Continental Motors General Products Division 76 Getty Street Muskegon, Michigan 49442
Dear Mr. Eschbaugh:
This responds to your letter of March 22, 1983, asking whether any Federal motor vehicle safety standard (FMVSS) specifies wiped area requirements for multipurpose passenger vehicles, trucks and buses. The answer to your question is no.
FMVSS No. 104, Windshield Wiping and Washing Systems, specifies requirements for windshield wiping and washing systems. As discussed in an enclosed letter of interpretation, while the standard applies to passenger cars, multipurpose passenger vehicles, trucks and buses, the standard's wiped area requirements only apply to passenger cars. Neither FMVSS No. 104 nor any other Federal motor vehicle safety standard specifies wiped area requirements for multipurpose passenger vehicles, trucks and buses.
Sincerely,
Frank Berndt Chief Counsel
(Enclosure omitted here.)
22 March, 1983
Chief Counsel for Legal Interpretation, NHTSA Subject: Clarification of Federal Motor Vehicle Safety Standard Requirement 104 Re: Title 49 Code of Federal Regulations 571.104 Paragraph S.2 and S.4.1.2
Dear Sir:
Paragraph S.2 of the above cited reference states that Requirement 104 applies to passenger cars, multipurpose passenger vehicles, trucks and buses. Paragraph S.4.1.2 specifies wiped area requirements for passenger cars. Multipurpose passenger vehicles, trucks and buses are not mentioned in Paragraph S.4.1.2. Question: Are wiped area requirements for multipurpose passenger vehicles, trucks and buses specified by FMVSS requirement? If these requirements are specified, what are the appropriate references?
Very truly yours,
TELEDYNE CONTINENTAL MOTORS General Products Division
T. A. Eschbaugh
TAE/js cc: Messrs. A. Saporito, E. Blackburne, R. Schuler, T. Schwallie |
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.