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: nht72-4.13OpenDATE: 02/03/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Toyota Motor Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This letter is in response to your inquiry of January 6, 1972, regarding the relationship of Standards No. 208 and No. 216. You interpret Standard 216, paragraph S3. Application, which states that the Standard does not apply to passenger cars "that conform to the rollover test requirements (S5.3) of Standard 208 by means that require no action by vehicle occupants," as follows: 1. From August 15, 1973, the effective date of Standard 216, to August 15, 1977, passenger cars are not required to meet Standard 216 if they conform to the "first option" of Standard 208. 2. For the period of August 15, 1973, through August 14, 1975, passenger cars which are designed to conform to the "second" or proposed "third" option of Standard 208 are not required to meet Standard 216 if they meet the rollover requirements (S5.3) by passive means (when tested under the applicable conditions of S8), even though in Standard 208 the rollover requirement is specified only for "option 1." These interpretations are correct. Please write if we can be of further assistance. |
|
ID: 18049.drnOpenMs. Angela Asher Dear Ms. Asher: As you requested, enclosed is a copy of a May 10, 1982 interpretation letter from Frank Berndt, then National Highway Traffic Safety Administration (NHTSA) Chief Counsel, to Mr. Martin V. Chauvin. The letter discusses whether vehicles used to transport children to or from day care centers and summer camps must meet school bus safety standards. There is no charge for the letter. Please note that the Chauvin letter's issue does not address situations where the day care center or summer camp is picking up or dropping off students at school. I am enclosing a June 1, 1998, letter discussing a dealer's responsibility in leasing new buses to a dance studio that will pick up the children from school "five days a week." In the June 1998 letter, NHTSA explains that the dealer must lease only buses that meet Federal motor vehicle safety standards for school buses. If you wish guidance on a specific situation involving dealers' responsibilities on sales of vehicles to transport school children, I will be glad to provide an interpretation. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, |
1998 |
ID: nht71-4.7OpenDATE: 09/01/71 FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER TO: American Jawa Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of August 17, 1971, inquiring whether tires for use on racing motorcycle are subject to the Tire Identification and Record Keeping regulation (49 C.F.R. 574). The regulation applies to "manufacturers, . . . of new and retreaded tires for use on motor vehicles" and, thus, whether the regulation applies to the tires in question depends on whether they are for use on a "motor vehicle." If the tires are for use on a racing motorcyle (i.e., a motorcycle which is not manufactured primarily for use on the public streets, roads, and highways), the tires are not considered to be manufactured for use on a "motor vehicle" and the regulation does not apply to them. We consider a label such as "For Racing Purposes Only, Not for Highway Use" as evidence of manufacture for off road use. The execution of an HS-7 form is unnecessary when racing tires are imported whether or not they are mounted on a racing motor-cycle. However, should it be necessary to execute an HS-7 form to expedite importation, Box 8 should be used to indicate that the items being imported are not considered to be for use on a motor vehicle and are not items of motor vehicle equipment. |
|
ID: nht88-3.29OpenTYPE: INTERPRETATION-NHTSA DATE: 08/30/88 FROM: SPENCER A. DORBY -- SATE-LITE MFG. CO. TO: JOAN TILGHMAN - NHTSA TITLE: 2166 ATTACHMT: ATTACHED TO LETTER DATED 11/07/88 FROM ERIKA Z JONES TO SPENCER A DARBY, REDBOOK A32, STANDARD 125; LETTER DATED 05/19/88 FROM SPENCER A DARBY TO JOAN TILGHMAN RE REQUEST FOR INTERPRETATION OF FMVSS 1255, OCC-2166 TEXT: Dear Ms. Tilgham: Attached is the drawing we referred to this AM on the phone, showing the recommended diagrams to help insure that Warning Device user will know how to erect the Emergency Warning Triangle properly. As Chairman of the SAE Reflex Devices Subcommittee, I will be including these diagrams (or similar versions) in an updated version of SAE 774, a Recommended Practice document of the Society of Automotive Engineers, in the next approval process due thi s year. Please call if I can be of any further assistance. ON ANY TYPE HIGHWAY VEHICLE USING 1 TRIANGLE Figure 3. ON A NON-DIVIDED HIGHWAY TRUCK USING 3 TRIANGLES Figure 4. ON A DIVIDED HIGHWAY TRUCK USING 3 TRIANGLES Figure 5. RECOMMENDED DIAGRAMS TO BE "PERMANENTLY AND LEGIBLY MARKED" ON THE WARNING DEVICE, AND ALSO ON THE "OPAQUE PROTECTIVE REUSABLE CONTAINER". Sate-lite MFG. CO. CAD TITLE 125 DIAGRAMS TRIA-DIA Drawing Number 880830 |
|
ID: 8746_59Open Mr. Donnell W. Morrison Dear Mr. Morrison: We have received your letter of March 14, 1995 and its attached copy of a letter dated February 14. I am sorry to say that your earlier letter never reached us. You asked whether the mounting height requirements for clearance and identification lamps (Table II of Motor Vehicle Safety Standard No. 108) have been amended to allow their mounting in locations other than "as high as practicable." The requirements have not changed since you were at DOT. The primary requirement is that identification lamps are to be mounted "as close to the top of the vehicle as practicable", and that clearance lamps are mounted "to indicate the overall width of the vehicle . . . as near the top thereof as practicable." The determination of practicability is initially that of the manufacturer, to be made in its certification that the vehicle meets all applicable Federal motor vehicle safety standards. NHTSA will not question that determination unless it appears clearly erroneous. However, when the rear identification lamps are mounted at the extreme height of the vehicle, paragraph S5.3.1.4 states that the rear clearance lamps need not be located as close as practicable to the top of the vehicle. Further, if it is necessary to indicate the overall width of the vehicle, or for protection from damage during normal operation of the vehicle, clearance lamps may be mounted at a location other than on the front and rear and need not be visible at 45 degrees inboard (paragraph S5.3.1.1.1). Sincerely, Philip R. Recht Chief Counsel ref:108 d:4/10/95
|
1995 |
ID: nht88-3.26OpenTYPE: INTERPRETATION-NHTSA DATE: 08/26/88 FROM: RE MORGAN -- MILEAGE TIRE ENGINEERING GOODYEAR TECHNICAL CENTER TO: MARVIN ORNES -- MANAGER, TECHNICAL SUPPORT REGIONAL TRANSPORTATION DISTRICT TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 12/09/88 FROM ERIKA Z. JONES -- NHTSA TO JACK MCCROSKEY AND GLENDA SWANSON LYLE, REDBOOK A33, STANDARD 119; LETTER DATED 09/13/88 FROM JACK MCCROSKEY AND GLENDA SWANSON LYLE TO LARRY COOK -- NHTSA, OCC 2539; LETTER DATE D 09/09/87 FROM R. E. MORGAN TO R. ROGERS RE GOODYEAR MILEAGE TIRES; REF BRUCE RUMAGE PHONE CALL; BOOKLET FROM REGIONAL TRANSPORTATION DISTRICT DATED 12/01/87 EST TEXT: Dear Mr. Ornes: Goodyear supplies basically two type of tires for Intra City Service. City Cruiser DXT and the City Cruiser XT tire. Both are produced in the same mold and have the same number of plies. They both are designed for identical service; but the difference comes in the amount of "Tread Rubber." DXT tires have a total of 1.40 inches of tread rubber and the XT tire has 1.18 inches. Marked on the sidewall of the DXT tire is the Max speed of 35 MPH, and on the XT is 55 MPH. The DXT may be used at higher speeds; but not for sustained operation. Once the tread rubber is worn down for either regrooving or recapping they both become the same tire carcass and may be used for 55 MPH service. Recapping process does not add the extra undertread on the carcass but the regular amount, so the tires will run safely at the 55 MPH speed. Please contact us if more explanation is needed. Sincerely, |
|
ID: nht95-2.26OpenTYPE: INTERPRETATION-NHTSA DATE: April 10, 1995 FROM: Philip R. Recht -- Chief Counsel, NHTSA TO: Donnell W. Morrison TITLE: NONE ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM DONNELL W. MORRISON TO RICARDO MARTINEZ TEXT: Dear Mr. Morrison: We have received your letter of March 14, 1995 and its attached copy of a letter dated February 14. I am sorry to say that your earlier letter never reached us. You asked whether the mounting height requirements for clearance and identification lamps (Table II of Motor Vehicle Safety Standard No. 108) have been amended to allow their mounting in locations other than "as high as practicable." The requirements have not changed since you were at DOT. The primary requirement is that identification lamps are to be mounted "as close to the top of the vehicle as practicable", and that clearance lamps are mounted "to indicate the overall width of t he vehicle . . . . as near the top thereof as practicable." The determination of practicability is initially that of the manufacturer, to be made in its certification that the vehicle meets all applicable Federal motor vehicle safety standards. NHTSA wi ll not question that determination unless it appears clearly erroneous. However, when the rear identification lamps are mounted at the extreme height of the vehicle, paragraph S5.3.1.4 states that the rear clearance lamps need not be located as close as practicable to the top of the vehicle. Further, if it is necessary to i ndicate the overall width of the vehicle, or for protection from damage during normal operation of the vehicle, clearance lamps may be mounted at a location other than on the front and rear and need not be visible at 45 degrees inboard (paragraph S5.3.1. 1.1). |
|
ID: nht68-2.35OpenDATE: 06/04/68 FROM: AUTHOR UNAVAILABLE; william H. Risteen; NHTSA TO: Clauson Manufacturing Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: Your letter of May 20, 1968, to Mr. Bridwell, concerning pickup covers, has been referred to me for reply. Pickup covers which you describe are considered to be in the same category an slide-in campers and are items of motor vehicle equipment for use in motor vehicles. As such pickup covers must meet the requirements of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials-Passenger Cars, Multipurpose Passenger Vehicles, Trucks, Buses and Motorcycles. |
|
ID: nht72-1.10OpenDATE: 10/06/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Minnesota Automotive, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 19, 1972, asking whether the new hydraulic brake safety standard precludes the provision of a device using the service brake pressure to supplement normal parking brake performance. Standard No. 105a does not prohibit the inclusion of such a device as original equipment in a motor vehicle, provided that the vehicle can meet the parking brake system requirements of the standard using the mechanical system alone. |
|
ID: nht73-4.30OpenDATE: 06/26/73 FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA TO: Memorandum to interpretations file TITLE: FMVSR INTERPRETATION TEXT: Gerhard Pilz of Mercedes-Benz of North America telephoned me on June 20, 1973, and stated that because of emission requirements, the 1974 model consumer information provided for acceleration and passing ability will differ between vehicles sold in California and those in the rest of the United States. He asked whether the following format (as I understood it) would be acceptable as a modification of Figure 1: SUMMARY TABLE Low Speed Pass Feet; Seconds (California vehicles Feet; Seconds) I replied that I saw no legal objection to it. |
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.