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: nht74-1.19OpenDATE: 09/23/74 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Dexter Axle Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your August 19, 1974, request to be advised of the steps necessary to acquire a manufacturer code number as required by Standards No. 119, New pneumatic tires for vehicles other than passenger cars, and No. 120, Tire selection and rims for motor vehicles other than passenger cars. Standard No. 119 applies to tires-only and it is the responsibility of the tire manufacturer to obtain a code number and label it on his products. As a user of tires, you do not have obligations under this standard. Standard No. 120 is a proposal which applies to rim construction and the selection of the correct rim for the (Illegible Word) equips. As a manufacturer of rims you would have a responsibility to label your products if this proposal becomes an effective regulation. However, we noted in the preamble to that proposal (copy enclosed) that we will not require manufacturer codes until a separate manufacturer code system has been established. I am also enclosing a copy of the most recent proposal on manufacturer codes. Yours truly, ATTACH August 19, 1974 Docket Section NHTSA Re: FMVSS 119 and 120 Dear Sir: Dexter Axle Co. Inc. is a manufacturer of running gear equipment for Mobile Homes and Recreational Vehicles. In our product line are wheels and rims subject to standards 119 and 120. Please advise on the steps we must take to obtain a manufacturers code number as required. Thank you. Very truly yours, DEXTER AXLE COMPANY, INC.; J. A. Brown -- Manager - Engineering Res. & Dev. |
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ID: nht94-2.88OpenTYPE: INTERPRETATION-NHTSA DATE: May 16, 1994 FROM: Alberto Negro -- Chief Executive Officer, Fiat Auto R&D U.S.A. TO: John Womack -- Acting Chief Counsel, United States Department Of Transportation, NHTSA TITLE: Subject: 49 CFR 571.208 S4.5.1 Request For Interpretation ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack To Alberto Negro (A42; Std. 208) TEXT: Dear Mr. Womack: I need to know whether NHTSA allows the advisory information required by 49 CFR 571.208 S4.5.1 to be printed in English and also in one or more foreign languages on the same sun visor label. I look forward to your reply. Sincerely, |
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ID: nht75-5.28OpenDATE: 11/26/75 FROM: AUTHOR UNAVAILABLE; Allan Kam; NHTSA TO: Memorandum to interpretation file TITLE: FMVSR INTERPRETATION TEXT: SUBJECT: TELEPHONE CALL FROM PATRICK RAHER, ESQ. OF HOGAN & HARTSON, ESQS., REPRESENTING MERCEDES-BENZ, ON SEPT. 15, 1975 The subject telephone call was referred to me by Mark Schwimmer. I explained to the caller the status of the UTQGS litigation, the briefing schedule, and the meaning of the stay order. He stated that Mark Schwimmer had read to him the text of Judge Weick's stay order. The caller's questions and my responses were essentially the same as those covered in my August 27, 1975 memorandum in reference to telephone calls from Yokohama Tire Company and Transportation, Inc. |
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ID: nht95-2.85OpenTYPE: INTERPRETATION-NHTSA DATE: May 18, 1995 FROM: Jane L. Dawson -- Specifications Engineer, Thomas Built Buses, Inc. TO: Walter Myers -- Chief Counsel's Office, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO JANE L. DAWSON (A43; STD. 217; REDBOOK 2) TEXT: Dear Mr. Myers, Please provide an interpretation on the following: In the final rule for FMVSS 217, Bus Emergency Exits and Window Retention and Release published in the Federal Register May 9, 1995, what are the location requirements (fore and aft) for emergency windows which may now be used as the first additional eme rgency exit? Your quick response is appreciated. |
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ID: nht67-1.15OpenDATE: 02/27/67 FROM: AUTHOR UNAVAILABLE; William Haddon, Jr. M.D.; NHTSA TO: Edward K. Kennedy, Esq. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 10, 1967. Motor Vehicle Safety Standard No. 105 applies only to new passenger cars manufactured January 1, 1968, or later. Although the National Traffic Safety Agency intends to issue additional standards in the future that apply to items of motor vehicle equipment, most of the initial Motor Vehicle Safety Standards issued January 31, 1967, apply to vehicles only, as the application paragraph of each standard specifies. Please do not hesitate to call upon us if we can be of further service to you. |
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ID: nht72-2.46OpenDATE: 07/18/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Gold Eagle Products Company TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of June 23, 1972 asking if there is any objection to placing the information required by paragraph S5.2.2.2(d) of Standard No.116 on the top of brake fluid containers. Stamping this information on the top of the container would meet the requirements of S5.2.2.2(d) that it be located on the bottom or on the side, underneath the distributor's name and mailing address. However, we are reviewing the matter and if we decide to modify the requirements, the appropriate notices will be published in the Federal Register. |
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ID: nht89-2.74OpenTYPE: INTERPRETATION-NHTSA DATE: AUGUST 17, 1989 FROM: LINDA L. CONRAD -- NIVES FORD, INC. TO: STEVEN WOOD -- CHIEF COUNSEL, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED JANUARY 1, 1990 TO LINDA L. CONRAD, NIVES FORD, INC., FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; VSA 1397(A)(2)(A); STD. 208; VSA 108(A)(1)(A); 108(A)(2)(A); 108(B)(1)] TEXT: We took in on trade a 1989 Chrysler LeBaron that had an air bag. This vehicle was in an accident and the bag has been used. We would like to know if there is any law that says we must replace this bag before we sell this car. We would appreciate a reply as soon as possible. Have a great day! |
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ID: nht94-1.4OpenTYPE: INTERPRETATION-NHTSA DATE: 01/01/94 EST FROM: Luis Carricaburu -- South Steering Specialists TO: Mary L. Versailles -- Office Of The Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 5/5/94 From John Womack To Luis Carricaburu (A42; Std. 208; VSA S108(a)(2)(A) TEXT: I WISH TO THANK YOU IN ADVANCE FOR TAKING THE TIME TO ADRESS MY QUESTION. IS IT ILLEGAL TO BUY OR SELL A SALVAGED AIR BAG FOR THE PURPOSE OF REPAIRING A OTHER PERSONS AUTOMOVILE? DEFINITION OF SALVAGED AIR BAG AS IT IS INTENDED IN ABOVE QUESTION. A AIR BAG FROM A VEHICLE THAT HAS FOR ONE REASON OR A OTHER MADE. ITS WAY TO A AUTOMOTIVE RECYCLING YARD BUTT IS STILL INTACT. THANK YOU FOR YOUR TIME |
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ID: nht67-1.4OpenDATE: 08/22/67 FROM: AUTHOR UNAVAILABLE; William Maddon, Jr., M.D.; NHTSA TO: The Anderson Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of June 30, 1967, to Mr. Bridwell concerning windshield wiper parts. We recognize that it may be difficult to obtain reflectance values from all metal components on the windshield wiper assembly which come into the driver's field of view. For this reason, Motor Vehicle Safety Standard No. 107 includes reflectivity requirements for only the wiper arm and blade. As stated in your letter, the reflectivity of these components may be determined by using flat samples of identical material. Reflectivity requirements for the spring, rivets and other hardware items, which are attached to the wiper arm and blade, are not presently specified in Standard No. 107. |
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ID: nht72-6.27OpenDATE: 06/29/72 FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA TO: Bureau of Customs TITLE: FMVSR INTERPRETATION TEXT: On June 14, 1972, you and Mr. Aubuchon of our Office of Standards Enforcement discussed the proper method of entry under 19 CFR @ 12.60 for incomplete motor vehicles and for chassis. This letter represents our opinion in this matter. A vehicle consisting of a chassis-cab on wheels, or a chassis, intended for completion after entry, should be entered as motor vehicle equipment, and identified on the HS-7 importation form in the box titled Description of Motor Vehicle Equipment. No other homes need be checked or hood required. We understand that you will circularize our opinion, and would approciate your furnishing a copy of such opinion to the Office of Standards Enforcement, Attn: 41-22 Cus. |
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.