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 |
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ID: aiam0259OpenMr. Louis C. Lundstrom, Director, Automotive Safety Engineering, General Motors Engineering Staff, General Motors Technical Center, Warren, MI 48090; Mr. Louis C. Lundstrom Director Automotive Safety Engineering General Motors Engineering Staff General Motors Technical Center Warren MI 48090; Dear Mr. Lundstrom: This is in reply to your letter to Mr. Toms of October 15, 1970, i which you asked whether General Motors could provide one consumer information document to fleet purchasers of motor vehicles, rather than putting a booklet in each car as is done in the usual case.; The answer is yes. 49 CFR 575.6(a) requires that the information b provided 'to that purchaser', 'at the time a motor vehicle is delivered' to him. It does not require that the information be in the vehicle, or that there be one booklet per vehicle.; We are pleased to be of assistance. Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs; |
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ID: aiam1292OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50-100 W. Alondra Blvd., Gardena, California 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50-100 W. Alondra Blvd. Gardena California 90247; Dear Mr. Gill: This is in reply to your letter of October 9, 1973, to Mr. Vinson o this office asking whether S5.2.5 of Standard No. 123 requires footrests to fold automatically when not in use.; The standard does not require automatic folding. S5.2.5 states only th direction in which footrests shall retract, so that if they are inadvertently left down when not in use they will fold rearward and upward should the hit an obstacle while the motorcycle is travelling forward.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1339OpenMr. Robert Wood, Hyattsville Auto Glass, 5516 Baltimore Avenue, Hyattsville, MD 20781; Mr. Robert Wood Hyattsville Auto Glass 5516 Baltimore Avenue Hyattsville MD 20781; Dear Mr. Wood: This is in response to your November 29, 1973, request to know i urethane bonding material must be used in the installation of windshields in new motor vehicles not yet sold to a first purchaser for purposes other than resale.; Standard 212, *Windshield mounting*, is a performance standard for ne motor vehicles. We do not require the use of specific bonding materials such as urethane, but only that the vehicle conform to Standard 212, whatever material is used. The New York suit you mentioned may involve a question of due care in the installation of the windshield, separate from the question of meeting a Federal minimum performance standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1838OpenMr. Michael P. Dixon, Route 2, Box 230, East Bend, NC 27018; Mr. Michael P. Dixon Route 2 Box 230 East Bend NC 27018; Dear Mr. Dixon: This is in response to your letter of February 12, 1975, requestin information concerning penalties available for failure to provide an odometer disclosure form upon sale of a vehicle.; As you know, the Motor Vehicle Information and Cost Savings Ac requires that a written disclosure of a vehicle's correct mileage be provided by the seller to the purchaser at the time ownership of a vehicle is transferred. If the correct mileage is unknown, however, the Act requires a statement to that effect to be furnished in written form to the buyer. Violation of any of these requirements may subject the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages, whichever is greater. To obtain this remedy, section 409 of the Act provides that a private civil action be instituted in State or Federal Court.; If you have reason to believe that the odometer mileage was altered b someone other than the person who actually sold you the vehicle, you are not precluded from suing him. The Act does limit your recovery for a violation to your immediate transferor.; Where a vehicle has been rebuilt, the odometer mileage that is relevan for purposes of the Cost Savings Act, is the number of miles the *chassis* has traveled.; I have enclosed the materials you requested. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1226OpenMr. C. J. Goode, British Leyland Uk Limited, Meteor Works, Lode Lane, Solihull, Warwickshire B92 8NW; Mr. C. J. Goode British Leyland Uk Limited Meteor Works Lode Lane Solihull Warwickshire B92 8NW; Dear Mr. Goode: In your letter of July 5, 1973, you express two concerns about th treatment of multipurpose passenger vehicles under the Motor Vehicle Information and Cost Savings Act.; Your first concern is that the standards to be issued under the ac will apply to all passenger motor vehicles, and will include multipurpose passenger vehicles unless the agency expressly exempts them. As we stated in the notice of proposed rulemaking on the new bumper standard, we are proposing to exempt multipurpose passenger vehicles from the initial standard. The continuance of this exemption depends on a variety of considerations, and we would appreciate the benefit of your views on the subject.; Your second concern is that the definition of 'multipurpose passenge vehicle' in the safety standards (49 CFR 571.3(b)) differs from the definition of the same term in the Cost Savings Act. Although the definitions are fundamentally similar, the safety standards definition limits the MPV category to vehicles designed to carry 10 persons or less, while the Cost Savings Act definition includes somewhat larger vehicles, up to a capacity of 12 persons. We do not foresee any problems as a result of this difference, but if problems arise, it would be possible through rulemaking to restrict the applicability of a cost savings standard to MPV's having a capacity of 10 persons.; Sincerely, James B. Gregory, Administrator |
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ID: aiam1687OpenMr. Phillip P. Friedlander, Jr., Director of Communications, National Tire Dealers and Retreaders Association, 1343 L Street, N.W., Washington, D.C. 20005; Mr. Phillip P. Friedlander Jr. Director of Communications National Tire Dealers and Retreaders Association 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Friedlander: In the November 25, 1974, issue of the *NTDRA Dealer News*, an articl entitled 'DOT's NHTSA Issues Final Labeling Requirements Under Standard No. 117,' the recently published permanent labeling amendment to standard No. 117 (39 FR 39882, November 12, 1974) is discussed in terms which imply that these requirements are the only labeling requirements imposed by the standard. Such an interpretation in incorrect. Paragraph S6.3.1 of Standard No. 117 still imposes affixed labeling requirements for certain information items which are not permanently labeled on the finished retread.; You may wish to clarify this in a future *Dealer New* issue. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0760OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Elglewood Cliffs, NJ, 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Elglewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in response to your letter of June 19, 1972, concerning th application of Motor Vehicle Safety Standard No. 302 to interior components, enclosing pictures. Your list includes heater case, defroster hose, heater duct hose, heater fan, console box, shell cover, harness, reclining device cover, meter cover, shift lever boot, foot boots, and knobs.; None of the components you list are enumerated in S4.1 of Standard No 302. Consequently, they are not subject to the standard unless they are, as specified in S4.1, 'other interior materials . . . that are designed to absorb energy on contact by occupants in the event of a crash.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1537OpenMr. J. W. Lawrence, Truck Group, White Motor Corporation, P.O. Box 91555, Cleveland, OH 44101; Mr. J. W. Lawrence Truck Group White Motor Corporation P.O. Box 91555 Cleveland OH 44101; Dear Mr. Lawrence: This responds to your recent request for an interpretation of S5.3.1. of Standard No. 121, *Air brake systems*. That section permits certain vehicles to avoid the stopping distance requirement if their brakes conform to a retardation formula and values found in another section of the standard (S5.4.1).; The language of S5.3.1.2 makes clear that any truck in the describe category need not meet the stopping distance requirements if its brakes satisfy the retardation formula and values of S5.4.1, and therefore none of the exceptions found in S5.4.1 apply to vehicles subject to the requirements of S5.3.1.2.; This interpretation also appears in the preamble to Notice 2 of Docke No. 73-10, and is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0577OpenMr. Terry W. Raney, Lathrop, Koontz, Righter, Clagett, Parker & Norquist, 1550 TenMain Center, P.O. Box 13006, Kansas City, MO 04190; Mr. Terry W. Raney Lathrop Koontz Righter Clagett Parker & Norquist 1550 TenMain Center P.O. Box 13006 Kansas City MO 04190; Dear Mr. Raney: This is in reply to your letter of January 25, 1972, concerning th confidentiality of information on manufacturers' quarterly production figures that is submitted pursuant to section 573.5(b) of the Defect Reports regulations (49 CFR Part 573).; Manufacturers' quarterly production figures submitted pursuant t section 573.5(b) will be kept confidential if the manufacturer so requests. This will be true except in those cases where the NHTSA determines that disclosure is necessary to carry out the purposes of the National Traffic and Motor Vehicle Safety Act.; In the event it is decided to make public such information the NHTS will, before release of the information, notify the manufacturer in question.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5404OpenGeorge W. Sudenga, Esq. Johnson, Sudenga, Latham & Peglow 118 East Main Street, P.O. Box 1180 Marshalltown, IA 50158-1180; George W. Sudenga Esq. Johnson Sudenga Latham & Peglow 118 East Main Street P.O. Box 1180 Marshalltown IA 50158-1180; Dear Mr. Sudenga: This responds to your letter following up on my Ma 18, 1994, letter to your client, Mr. Neil Rowe, about Mr. Rowe's product, the 'Glad Grip.' In my letter, I provided information about the National Highway Traffic Safety Administration's (NHTSA's) requirements for manufacturers of motor vehicle equipment, and explained that NHTSA has not issued a Federal motor vehicle safety standard (FMVSS) applicable to a product such as the Glad Grip. In your followup letter, you indicated we did not answer your request for 'approval of NHTSA in advance of major marketing efforts,' concerning your client's product. I regret that my earlier letter was unclear on the issue of NHTSA 'approval' of motor vehicles or motor vehicle equipment. NHTSA does not approve motor vehicles or items of motor vehicle equipment, nor does the agency endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. As I stated in the earlier letter, the agency has not issued any safety standards for the Glad Grip. Even if there were an applicable FMVSS, NHTSA would not 'approve' the Glad Grip, rather, Mr. Rowe would self-certify his product. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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.