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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



Displaying 15701 - 15710 of 16490
Interpretations Date

ID: nht71-4.42

Open

DATE: 11/06/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 15, 1971, to Mr. Lewis Owen of this Office concerning the coating of Lexan lenses.

Plastic lenses used in the required lamps are required by Federal Motor Vehicle Safety Standard No. 108 to meet SAE J576, which specifies no loss of surface luster and no surface deterioration. This Agency does not have the authority to "waive" any requirements of a Federal motor vehicle safety standard.

If you believe that motor vehicle safety does not demand requirements of this severity, you may submit a petition asking for an appropriate amendment of Standard No. 108.

ID: nht92-5.13

Open

DATE: July 23, 1992

FROM: Takashi Odaira -- Chief Representative, Emissions & Safety, Isuzu Technical Center of America, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Mr. Sakai

TITLE: FMVSS 214 Side Impact Protection Quasi-static Door Strength Test

ATTACHMT: Attached to letter dated 10/5/92 from Paul Jackson Rice to Takashi Odaira (Std. 214)

TEXT:

The side door strength test procedures specified in FMVSS 214 are not quite clear as they relate to pickup trucks. In the attached sheets, we have described three alternative procedures that Isuzu Motors Limited, Japan, plans to follow.

Isuzu Motors requests your agency's view and/or comment on each of these procedures.

I would appreciate receiving your prompt reply.

(Attachments omitted)

ID: nht90-4.43

Open

TYPE: Interpretation-NHTSA

DATE: October 12, 1990

FROM: A. Kling -- Hamadbik, Ltd.

TO: U.S. Dept of Transport, NHTSA

TITLE: Re: (FMVSS) No. 116

ATTACHMT: Attached to letter dated 3-8-91 from Paul Jackson Rice to A. Kling (A37; Std. 116)

TEXT:

We are enquiring about the abovementioned Safety Standard regarding DOT 3 and DOT 4 brake fluids.

Clause S5.1.14 of the above standard refers to the color of the brake fluid being colorless to amber. We would much appreciate your sending us the color coding range of amber referred to in this clause. We would appreciate your sending us the color cod e and chart used by your department and as designated by the U.S. federal department

We much appreciate your cooperation and thank you in advance

ID: nht93-2.38

Open

DATE: March 30, 1993

FROM: Greg Hixson -- President, Hixson and Netherton Distributing

TO: Office of the Chief Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-16-93 from John Womack to Greg Hixson (A41; Std. 208)

TEXT: Hixson and Netherton Distributing a corporation in Dallas, Texas wishes to import an "Aftermarket Airbag" for automobiles to be sold in the United States.

We have been unable to obtain any specifications, standards or regulations regarding Airbags or importing of such an item.

If your office has any of this information we would certainly appreciate you forwarding it to our office as soon as possible.

We can be reached by phone or by mail at the following:

Hixson and Netherton Distributing P.O. Box 28995 Dallas, Texas 75228 (214) 682-9836

A prompt reply would be very much appreciated.

ID: nht93-4.42

Open

DATE: June 23, 1993

FROM: Gail Lindsey -- Hillsborough County Public Schools, Risk Management & Safety Department, Tampa, Florida

TO: Ron Engles -- Safety Counter Measure Division

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 (est) from John Womack (signature by Kenneth N. Weinstein) to Gail Lindsey (A41; Part 571.3)

TEXT:

This correspondence is a reply to our recent phone conversation concerning the transporting of school children to and from special events in any vehicle other than school buses.

In the past, it has been School Board policy to disallow the use of mini-vans on such events. I am requesting any information on the crash safety standards of such vehicles, or any recommendations that your office may give so that we can make a safe and fair determination on this current policy.

Any assistance you can give will be greatly appreciated.

ID: nht72-3.25

Open

DATE: 06/30/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Harold Schlintz & Associates

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 8, 1972, to Robert L. Carter, as to whether Federal Motor Vehicle Safety Standard No. 206 is applicable to a White "Freightliner" which was manufactured on or about December 1, 1970.

The White Freightliner, as illustrated in the picture you enclosed, is a truck tractor, and is classified as a "truck" under the motor vehicle safety standards. Standard No. 206 became applicable to trucks on January 1, 1972, and would not therefore apply to this truck. No other standards are applicable to the doors or door latches of this vehicle.

The standards do not apply to a vehicle after its first sale to a consumer (a used vehicle), and we exemption from the standards is necessary.

ID: nht92-5.18

Open

DATE: July 14, 1992

FROM: Bill Traylor -- President, Waste Processing Equipment, Inc.

TO: Office of Chief Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9/4/92 from Paul Jackson Rice to Bill Traylor (A39; Part 567)

TEXT:

Enclosed is a blueprint on a private motor coach we are constructing on a WCA Series Volvo GMC Class 8 truck chassis.

Please advise in writing whether or not this vehicle will have to be certified by your administration. If certification is required, please advise as to how and what we do during the construction of the vehicle in order to assure certification.

If you need to discuss this matter by phone, please call me at (205) 638-6355.

A quick response will be appreciated since we are starting construction on or about August 1, 1992.

ID: nht75-1.5

Open

DATE: 04/22/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Kazuhiko Aoki

TITLE: FMVSS INTERPRETATION

TEXT:

APR 22 1975 N40-30 TWH)

Mr. Kazuhiko Aoki 2-3 Nihonbashi Koami-cho 1-chome Chuo-ku/ Toykyo, Japan 103

Dear Mr. Aoki:

This responds to your January 30, 1975, question whether the test procedure of S7.7.1 in Standard No. 105-75, Hydraulic brake systems, refers to the parking brake in the next to the last sentence which states that it "may be necessary to reapply it if the vehicle moves slightly" (emphasis added).

The word "it" refers to the service brake system, and not the parking brake system. This sentence permits application of the service brake only, which has the effect of taking up parking brake system slack due to rotation of the brake shoes and drum prior to bottoming against the anchor pin.

Sincerely,

James C. Schultz Chief Counsel

ID: aiam2598

Open
Mr. Jefferson D. Keith, Executive Vice President, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Jefferson D. Keith
Executive Vice President
National Tire Dealers & Retreaders Association
Inc.
1343 L Street
N.W.
Washington
DC 20005;

Dear Mr. Keith: This is in reference to our letter to you dated September 17, 1976 denying your requested rulemaking on Part 574, *Tire Identification and Recordkeeping*. It has been brought to our attention that you interpret our letter to require that tire dealers actually complete the tire information forms themselves.; Section 158 of the National Traffic and Motor Vehicle Safety Act (th Act) (15 U.S.C. 1381, 1418) requires that; >>>'[e]very manufacturer of motor vehicles and tires shall cause th establishment and maintenance of records of the name and address of the first purchaser of each motor vehicle and tire produced by such manufacturer.... The Secretary may, by rule, specify the records to be established and maintained, and reasonable procedures to be followed by manufacturers in establishing and maintaining such records, including procedures to be followed by distributors and dealers to assist manufacturers to secure the information ....'<<<; This section of the Act, therefore, places the responsibility fo ensuring the establishment of these records upon the manufacturer who may be assisted by the dealer. Part 574 requires dealers to submit first purchaser information to manufacturers. The information that must be supplied to each manufacturer need not be entered on the required form by the dealer. The dealer may present the registration form to the purchaser and allow him to fill in the required information before he takes possession of the tire. Thus, the purchaser would complete the form prior to leaving the store, thereby obviating the need for additional store personnel to complete the forms. It is the dealer's responsibility, however, to ensure that the forms are filled out in their entirety.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam5280

Open
Mr. J. Frank Haasbeek President International Transquip Industries, Inc. 6131 Brookhill Drive Houston, TX 77087-1131; Mr. J. Frank Haasbeek President International Transquip Industries
Inc. 6131 Brookhill Drive Houston
TX 77087-1131;

"Dear Mr. Haasbeek: Thank you for your recent letter to Vice Presiden Gore, concerning a rulemaking related to your product. You believe that this agency has proceeded too slowly in the rulemaking. The Vice President has forwarded your letter to me for a reply. I understand your concern over this issue, but please be assured that this agency is working diligently to reach a final decision concerning this rulemaking. As you know, the notice of proposed rulemaking was published in March of this year, and the agency received a number of conflicting comments. We must carefully assess all of the arguments raised by the commenters before reaching a final decision. We are nearing the completion of that process and expect to announce a final decision in January 1994. I hope this information is helpful and appreciate your patience in this matter. Sincerely, Howard M. Smolkin Acting Administrator ";

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.

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