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: 1871yOpen Mr. Bob Sandblom Dear Mr. Sandblom: Thank you for your letter of May l8, l989, addressed to the Department, calling our attention to a dealer practice of placing overlays on the center of highmounted stop lamps. We have received a number of inquiries about this subject, and I enclose a representative response. You are correct that it is not legal for a dealer to create a noncompliance, but you will see from the letter enclosed that the practice is not in and of itself illegal provided that the lamp continues to meet the rather technical requirements of the standard after the overlay is required. We appreciate your interest in motor vehicle safety, and for taking the time to write us. Sincerely,
Stephen P. Wood Acting Chief Counsel Enclosure ref:l08 d:6/l9/89 |
1970 |
ID: nht76-2.36OpenDATE: 11/22/76 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: TYM Industries Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 27, 1976, to the National Highway Traffic Safety Administration, concerning lighting requirements for mopeds. The headlamp must be designed to conform to SAE Standard J584, "Motorcycle and Motor Driven Cycle Headlamps," April 1964. This Standard does not require a sealed beam headlamp, nor is a minimum wattage specified. Obtaining an AAMVA certificate is probably the best way of insuring that a State raises no obstacles to registry of your vehicle. There is no minimum wattage for the taillamp or stop lamp. These two lamps may be combined. There is no Federal requirement for SAE identification; however, most lamps are so identified, because of the requirements in the state of Virginia. |
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ID: 17683.ztvOpenMr. Nick Tysoe Dear Mr. Tysoe: This is in reply to your fax of March 24, 1998, asking for an interpretation of S7.8.5 of Federal Motor Vehicle Safety Standard No. 108. Rolls-Royce is considering a four-lamp headlighting system in which the upper and lower beams would be provided by separate headlamps. You ask if it would be permissible for the lower beam headlamps to be visually/optically aimable and the upper beam headlamps to be mechanically aimable by external means. This is not permissible under Standard No. 108. We interpret Standard No. 108 as requiring identical headlighting systems on both sides of a new vehicle, including their aiming features. I enclose a copy of a letter dated March 10, 1998, that this Office sent to Herr Spingler of Robert Bosch GmbH which explains the agency's views. Sincerely, |
1998 |
ID: nht89-2.6OpenTYPE: INTERPRETATION-NHTSA DATE: 06/16/89 FROM: ROBERT N. LEVIN -- HUDOCK AND LEVIN TO: OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRANSPORTATION SAFETY ADMINISTRATION DEPARTMENT OF TRANSPORTATION TITLE: SUN ROOFS ATTACHMT: ATTACHED TO LETTER DATED 11/01/89 FROM STEPHEN P. WOOD -- NHTSA TO ROBERT N. LEVIN -- HUDOCK AND LEVIN; REDBOOK A34[B]; VSA 108[A][1][A]; VSA 108[A][2][A]; STANDARD 205; STANDARD 216; PART 567.7 TEXT: Dear Sirs: I am writing to request your guidance in a matter just brought to my attention by a client. My client operates an auto repair facility. One of the services that it provides is the installation of sun roofs. I recently discovered one of your regulations, 49 CFR 567.7. Your guidance would be greatly appreciated in discovering whether the labeling requirements apply to sun roof installations and if so what the underlying regulations are concerning safety s tandards. Thank you. Very truly yours, |
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ID: nht93-3.9OpenDATE: April 20, 1993 FROM: Henry Murillo TO: Z. Taylor Vinson -- Office of Chief Counsel, NHTSA TITLE: Re: Green Light System ATTACHMT: Attached to letter dated 6-28-93 from John Womack to Henry Murillo (A41; Std. 108). TEXT: I respectfully ask for an interpretation of the rules concerning new automotive products and specifically regarding my invention entitled "Green Light System". Summary: Two strips of green plastic which are illuminated from behind. One strip is mounted somewhere in the front of the car and the other possibly on top of the cyclops (rear top dash mounted brake light). Purpose: The object is to indicate to a vehicle either in front or behind you that it is safe to pass. All you do is hit the button which could start the unit flashing. Please write your reply to: Henry Murillo 140 Patchogue Ave. Mastic, NY 11950 |
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ID: nht91-3.7OpenDATE: April 1, 1991 FROM: Vel McCaslin -- Director, Grace After School TO: NHTSA, Office of Vehicle Safety Standards TITLE: None ATTACHMT: Attached to letter dated 5-29-91 from Paul Jackson Rice to Vel McCaslin (A37; Part 571.3) TEXT: Please explain or clarify the Motor Vehicle Safety Act of 9166, 49 CFR, CH. V, SUB-PART A-571 to us. If you have any brochure or information pertaining to this law, please sent it to me. We have three 15 Passenger Vans which pick up students from Houston Independent Schools and bring them to our church for an After School Program. They are not painted yellow and we never put more than 15 passengers including driver. We use these vans for what capacity they were built. Are we in non-compliance of any law? Please advise. Thank you for your help in this matter. |
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ID: nht90-3.60OpenTYPE: Interpretation-NHTSA DATE: August 16, 1990 FROM: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: Re Reference: 49 CFR, Part 571.221 School Bus Body Joint Strength ATTACHMT: Attached to letter dated 1-14-91 from Paul J. Rice to Thomas D. Turner (A37; Std. 221); Also attached to undated letter from Frank Berndt to W.G. Milby; Also attached to letter dated 3-18-77 from Frank Berndt to W.G. Milby TEXT: Section S4 of the referenced standard provides the following definition: "Body panel joint" means the area of contact or close proximity between the edges of a body panel and another body component, excluding spaces designed for ventilation or another functional purpose, and excluding doors, windows, and maintenance access pa nels. In an April 26, 1976 letter to Blue Bird (reference N40-30) NHTSA stated: "Your assumption that components located entirely below the level of the floor line are not subject to the standard is correct." The enclosed drawing 1519834 illustrates the joints of a Blue Bird stepwell to the Number 1 and 2 floor sections. Since the stepwell is a space designed for a functional purpose, it is our understanding that it is excluded from the requirements of the s tandard. The fact that the actual joint and all components of the stepwell are located entirely below the level of the floor line also constitutes the basis for exemption from the standard. Based on these facts, it is Blue Bird's interpretation that the joints of the stepwell to the floor sections, as shown in drawing 1519834 are not subject to the joint strength requirements of FMVSS 221. We request your early consideration of this matter and confirmation that our interpretation is correct. Attachment Correspondence Log Wednesday 09/19/90 11:41 am For: BURRILL, Peggy Entry Number: 5110 Date Received: 08/21/90 Correspondence Date: 08/16/90 Entry Type: LTR Received from Company: Blue Bird Person: Thomas D. TurnerRE: Req. interpretation of FMVSS 221 as it pertains to the stepwell. See attached drawing 1519834 Routed to: NCC-20 *** 8/21/90 Follow up date: 10/09/90 Response date: / / Referred to: DG Filed: |
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ID: nht89-2.12OpenTYPE: INTERPRETATION-NHTSA DATE: 06/19/89 FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL TO: BOB SANDBLOM -- BOOKLAND TITLE: NONE ATTACHMT: LETTER DATED 05/18/89 FROM BOB SANDBLOM TO DEPARTMENT OF TRANSPORTATION; OCC 3584; LETTER DATED 09/03/87 FROM ERIKA Z. JONES -- NHTSA TO DAVID M. ROMANSKY; STANDARD 108 TEXT: Dear Mr. Sandblom: Thank you for your letter of May 18, 1989, addressed to the Department, calling our attention to a dealer practice of placing overlays on the center of highmounted stop lamps. We have received a number of inquiries about this subject, and I enclose a representative response. You are correct that it is not legal for a dealer to create a noncompliance, but you will see from the letter enclosed that the practice is not in and of itself illegal provided that the lamp continues to meet the rather technical requirements of the standard after the overlay is required. We appreciate your interest in motor vehicle safety, and for taking the time to write us. Sincerely, ENCLOSURE |
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ID: nht90-1.40OpenTYPE: Interpretation-NHTSA DATE: February 12, 1990 FROM: Johannah Bonewald -- Voskamp Motors., Office Manager TO: Phil Gramm -- U.S. Senator TITLE: None ATTACHMT: Attached to letter dated 5-10-90 To Phil Gramm and From Stephen P. Wood; Also attached to letter dated 0-0-0 To John Cerisano and From Phil Gramm; Also attached to letter dated 1-29-90 To All Ford Rent-A-Car System Members and From W.A. Jacques TEXT: Please find enclosed a copy of a Ford-Rent-A-Car System Bulletin that was sent to Ford dealers last week. As you can see, the bulletin concern the rental of vans to be used to transport students. We have had 15-Passenger rental vans in service for the past 15 years and probably the biggest customer we have are the schools in our area. I cannot understand the reasoning behind this regulation. This vehicle is probably one of the safest means o f transporting students. Any information you can give to me as to the reasoning behind this regulation, or information on who to contact to give us more details would be very much appreciates. Thank you for you help. |
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ID: nht90-1.41OpenTYPE: Interpretation-NHTSA DATE: February 12, 1990 FROM: Johannah Bonewald -- Office Manager., Voskamp Motors TO: Lloyd Bentsen -- U.S. Senator TITLE: None ATTACHMT: Attached to letter dated 5-25-90 To Lloyd Bentsen and From Stephen P. Wood; (A35; VSA 102(14), 108(a)(1)(A), 108(b)(1)); Also attached to letter dated 1-29-90 To All Ford Rent-A-Car System Members and From W.A. Jacqu es; Also attached to letter dated 3-8-90 To Jerry Ralph Curry and From Lloy d Bentsen TEXT: Please find enclosed a copy of a Ford-Rent-A-Car System Bulletin that was sent to Ford dealers last week. As you can see, the bulletin concerns the rental of vans to be used to transport students. We have had a 15-Passenger Rental van in service for the past 15 years and probably the biggest customer we have are the schools in our area. I cannot understand the reasoning behind this regulation. This vehicle is probably one of the safest means of tr ansporting students. Any information you can give to me as to the reasoning behind this regulation, or information on who to contact to give us more details would be very much appreciated. Thank you for your help. |
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.