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: nht71-3.33OpenDATE: 07/14/71 FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA TO: Airstream Technical Center TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of June 25, 1971, to Mr. Douglas W. Toms, Acting Administrator, National Highway Traffic Safety Administration, concerning lamp locations proposed for your 1972 Airstream trailer. Federal Motor Vehicles Safety Standard No. 108, as amended October 31, 1970 and February 3, 1971, effective January 1, 1972, requires that clearance lamps be mounted to indicate the overall width and as near the top as practicable. Paragraph S4.3.1.5 permits optional mounting height of rear clearance lamps when the rear identification lamps are mounted at the extreme height of a vehicle. The front and rear clearance lamps mounted as shown on your drawing 10033, revision C, do not appear to meet these location requirements. These lamps could be mounted higher than shown and still indicate the overall width of the trailer at locations other than the upper right and left corners, perhaps as high as the front and rear windows. In addition, the side reflex reflectors are to be located as far to the front and rear of the vehicle as practicable. Neither the front nor rear side reflex reflectors shown on the subject drawing appear to meet this requirement. |
|
ID: nht81-1.30OpenDATE: 03/05/81 EST FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL TO: P. SOARDO -- ISTITUTO ELETTROTECNICI NAZIONALE GALILEO FERRARIS TORINO, ITALY COPYEE: AMERICAN ASSOCIATION OF MOTOR VEHICLE ADMINISTRATION TITLE: NOA-30 ATTACHMT: LETTER DATED 11/28/80 FROM P. SOARDO TO NHTSA RE REAPPROVAL OF LIGHTING DEVICES, FEDERAL STANDARD 108 TEXT: Dear Professor Soardo: Your letter of November 28, 1980 has just arrived, in which you asked about State approval of lighting devices. Each State has its own requirements and method of proceeding, and these are independent of U.S. governmental requirements. Therefore, I regret to say, we are unable to answer this question, and it should be asked of the particular State in which you have an interest. However, the American Association of Motor Vehicle Administration may be able to answer this question and we are sending a copy of your letter to it for direct reply. You have also asked what Motor Vehicle Safety Standard No. 108 requires "when a car is no longer manufactured, but... lighting devices are available as spare parts". Standard No. 108 applies not only to motor vehicles but also requires compliance of lighting equipment manufactured to replace lighting equipment originally installed on a motor vehicle pursuant to Standard No. 108. Sincerely, |
|
ID: nht94-4.84OpenTYPE: INTERPRETATION-NHTSA DATE: November 16, 1994 FROM: Yoshiaki Matsui -- Manager, Legal & Homologation Sect., Stanley Electric Co., Ltd. TO: Patrick Boyd -- Office of Rulemaking, NHTSA TITLE: Re: 7% haze requirement for reflectors (Docket No. 93-15; Notice 2) ATTACHMT: ATTACHED TO LETTER DATED 12/7/94 FROM PHILIP R. RECHT TO YOSHIAKI MATSUI (A42; REDBOOK 2; STD. 108) TEXT: We have a question about the applicability of the above requirement for reflex reflector materials. According to the Final Rule issued by the Federal Register of November 2, the amended haze requirement shall be effective on November 1, 1995. Our question is that if this requirement shall be applicable to replacement reflex reflectors or not. For replacement reflex reflectors, two possible cases are in problem. Would you please inform us if the amended haze requirement shall be applicable in each case. First case - Replacement reflex reflectors manufactured after the effective date, but the vehicle to which the reflex reflectors are fitted is no longer manufactured after the effective date. Second case - Replacement reflex reflectors manufactured before the effective date, which may be fitted to a vehicle manufactured before or after the effective date. (In this case, the same type of vehicles are manufactured before and after the effectiv e date continuously.) Your prompt reply will be highly appreciated. |
|
ID: 7379Open Mr. Mark W. Russo Dear Mr. Russo: This responds to your letter of May 27, 1992, to Mr. Charles Gauthier of this agency, which enclosed a copy of R-Bar test data provided by Micho Industries. You requested an "official `review and comment'" regarding the applicability of Safety Standard 222 to the R-Bar Passenger Restraint System and related issues. The National Highway Traffic Safety Administration (NHTSA) has addressed the use of "safety bars" in school buses on several occasions in the past. Enclosed for your information are copies of five NHTSA letters which address this subject and which, we believe, will also address your concerns. The letters are addressed to Mr. Michael F. Hecker of Micho Industries, dated May 14, 1992; Mr. Scott K. Hiler of the C. E. White Company, dated January 31, 1991; Honorable Robert J. Lagomarsino, Member of Congress, dated January 8, 1990; and Mr. Joseph F. Mikoll of Transportation Equipment Corporation, dated March 10, 1989 and November 3, 1988. If, after reviewing the enclosed materials, you still have questions concerning this matter, please feel free to contact Mr. Walter Myers of my staff at this address or at (202) 366- 2992. Sincerely,
Paul Jackson Rice Chief Counsel Enclosures Ref: #222 d:7/l3/92
|
1970 |
ID: nht92-5.20OpenDATE: July 13, 1992 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Mark W. Russo TITLE: None ATTACHMT: Attached to letter dated 5/27/92 from Mark W. Russo to Charles Gauthier (OCC 7379) TEXT: This responds to your letter of May 27, 1992, to Mr. Charles Gauthier of this agency, which enclosed a copy of R-Bar test data provided by Micho Industries. You requested an "official 'review and comment'" regarding the applicability of Safety Standard 222 to the R-Bar Passenger Restraint System and related issues. The National Highway Traffic Safety Administration (NHTSA) has addressed the use of "safety bars" in school buses on several occasions in the past. Enclosed for your information are copies of five NHTSA letters which address this subject and which, we believe, will also address your concerns. The letters are addressed to Mr. Michael F. Hecker of Micho Industries, dated May 14, 1992; Mr. Scott K. Hiler of the C. E. White Company, dated January 31, 1991; Honorable Robert J. Lagomarsino, Member of Congress, dated January 8, 1990; and Mr. Joseph F. Mikoll of Transportation Equipment Corporation, dated March 10, 1989 and November 3, 1988. If, after reviewing the enclosed materials, you still have questions concerning this matter, please feel free to contact Mr. Walter Myers of my staff at this address or at (202) 366-2992. |
|
ID: nht87-1.77OpenTYPE: INTERPRETATION-NHTSA DATE: 05/19/87 FROM: JACK DE NIJS -- DERONDE CASINGS LTD TO: ERICA Z. JONES -- CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: COVERED DOT NUMBERS ON REMANUFACTURED TRUCK CASINGS ATTACHMT: ATTACHED TO LETTER DATED 12/09/88 FROM ERIKA Z. JONES -- NHTSA TO DONALD N. STAHL RE MCCOY TIRE SERVICE CENTER D.A. NO CF696, REDBOOK A33, STANDARD 119, PART 574; UNDATED LETTER FROM JOHN T. FORTH AND DONALD N. STAHL TO ERIKA Z. JONES NHTSA RE MCCOY TIRE SERVICE CENTER D.A. NO CF696, OCC 1749; LETTER DATED 03/01/88 FROM DAVE TAYLOR TO JOHN T. FORTH, EXHIBIT 1; LETTER DATED 07/13/87 FROM ERIKA Z. JONES -- NHTSA TO JACK DENIJS EXHIBIT 2; DRAWING OF TIRE DATED 01/14/88, MODESTO CITY SCHOOLS TIRE INFORMATION, EXHIBIT 3 TEXT: GENTLEMEN, WE ARE IN THE PROCESS OF PURCHASING REMANUFACTURED TRUCK CASINGS FROM A COMPANY IN SWITZERLAND. THE NAME OF THAT COMPANY IS; TYRES RECYCLING SYSTEM S.A. C.H. 6535 GRONO. THESE TRUCK CASINGS HAVE BEEN REBUILT FROM BEAD TO BEAD SO IT DOES NOT SHOW A DOT NUMBER. THE ONLY THING IT SHOWS IS THE SIZE OF THE TIRE, THE NUMBER OF PLY'S AND THAT COMPANIES CODE NUMBER. WHAT WE WOULD LIKE TO KNOW? CAN WE IMPORT THESE CASINGS INTO THE U.S.A. FOR RETREADING OURSELVES AND FOR RESALE TO OTHER RETREADERS FOR RETREADING? A PROMPT RESPONSE WOULD BE APPRECIATED YOURS TRULY, |
|
ID: nht90-2.52OpenTYPE: INTERPRETATION-NHTSA DATE: 05/25/90 FROM: LAWRENCE J. SMITH -- CONGRESS TO: NANCY BRUCE -- LEGISLATIVE LIAISON DEPARTMENT OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/25/90, FROM PAUL JACKSON RICE -- NHTSA TO LAWRENCE J. SMITH -- CONGRESS; A35, VSA 108 [A] [2] [A]; STANDARD 205; LETTER DATED 05/30/90 FROM NANCY L. BRUCE -- DOT TO LAWRENCE J. SMITH -- CONGRESS; NEWSPAPER ARTICLE; U NDATED BY UPI; US SUES 4 AUTO TINTING SHOPS; OCC 4842; NEWSPAPER ARTICLE DATED 03/30/90; BY STEVE MOORE -- BUSINESS MARKETS; LOCAL CRAFTSMAN UNSWAYED BY FEDERAL CIVIL LAWSUITS; NEWSPAPER ARTICLE DATED 03/29/90 BY BRUCE VIELMETTI -- ST PETERSBURG TIMES; U S CRACKS DOWN ON WINDOW TINTERS; NEWSPAPER ARTICLE DATED 03/29/90 FROM JIM LEUSNER -- ORLANDO SENTINEL; US SUES CAR-WINDOW TINTERS - LET THERE BE MORE LIGHT; 1984 FLORIDA AUTO TINT LAW; PRESS RELEASE DATED 03/28/90 BY UNITED STATES ATTORNEY MIDDLE DISTRI CT OF FLORIDA TEXT: I am enclosing a copy of a letter that I have received from Mr. Joel Leitson of Hollywood, Florida. The letter concerns actions being taken against certain window tinting firms. I would like to know under what statutory authority the National Highway Traffic and Safety Administration is acting. In addition, I would appreciate the Department's comments on whether its actions preempt Florida's statutes. Finally, any additional information that you can provide in helping me respond to Mr. Leitson's inquiry would be appreciated. I look forward to your prompt reply. Enc. |
|
ID: 17324.drnOpenMr. Willis Ayres III Dear Mr. Ayres: This responds to your letter asking for information about the use of 15-passenger vans by a potential customer, the Briarcrest Christian School (BCS), to transport school children. In a letter to your dealership, BCS wrote that the "primary usage of this [15-passenger] van will be to provide transportation for Briarcrest personnel who will attend seminars and take other school-related trips." The van will also be used "for various licensed personnel to transport small groups of students to and from select school activities." Because we believe the vehicle will be "used significantly" to transport school children for school activities, if you sell the Briarwood Christian School a new bus, you must sell a bus that meets the Federal motor vehicle safety standards applicable to school buses. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "school bus" as any vehicle that is designed for carrying 11 or more persons and which is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125(a)(1). Therefore, a 15-passenger van that is likely to be used significantly to transport students is a "school bus." The question of whether the buses are likely to be "used significantly" to transport the students is one that the agency finds appropriate to resolve case-by-case, focusing on the intended use of the vehicle. Addressing the situation you have raised, although the letter from BCS states the primary use of the vehicle would be to transport adult BCS personnel, it is clear that BCS intends to use the vehicle on a regular and recurring basis to transport school children for different school events. In our view, such regular use of the vehicle to transport school children for school events would constitute a "significant" use of the vehicle. Therefore, under the facts you have provided, if Chuck Hutton Chevrolet Co. sells the Briarwood Christian School a new bus, it must sell a bus that meets the Federal motor vehicle safety standards applicable to school buses. I hope this information is helpful. I have enclosed a question-and-answer sheet on "Dealers' Questions about Federal School Bus Safety Requirements," and a copy of Highway Safety Program Guideline No. 17, Pupil Transportation Safety. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, |
1998 |
ID: nht71-2.12OpenDATE: 03/09/71 FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA TO: Koito Manufacturing Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 25, 1971, concerning the photometric requirements for amber turn signal lamps. You have correctly interpreted the photometric requirements for amber turn signal lamps as specified in paragrap S4.1.1.7 of Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1972. |
|
ID: nht72-1.30OpenDATE: 06/08/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Michlin Tire Corporation - Technical Division TITLE: FMVSS INTERPRETATION TEXT: In reply to your letter of May 16, 1972, your interpretation is correct that paragraph S4.3.2 of Motor Vehicle Safety Standard No. 109 requires either the manufacturer's name and his assigned code number, or the brand name and the manufacturer's assigned number to be labeled onto the tire. The code number must appear in either case. |
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.