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: aiam0283OpenMr. A. Hammerstein, Robert Bosch GMBH, 7000 Stuttgart- Feuerbach, Postfach 400, Germany; Mr. A. Hammerstein Robert Bosch GMBH 7000 Stuttgart- Feuerbach Postfach 400 Germany; Dear Mr. Hammerstein: This is in reply to your letter of December 23, 1970, to the U. S Department of Transportation concerning the time when stop lamps will be required to meet Class A photometrics.; The conflict between the requirements of paragraphs S4.1.1.6 an S4.1.1.7 has already been called to our attention, and will be clarified in an amendment to Standard No. 108 scheduled to be published in the *Federal Register* in the near future.; It was not intended for the stop lamps to meet the Class A photometri values, nor are they required to, until January 1, 1973.; Sincerely, Roger H. Compton, Director, Office of Operating Systems Motor Vehicle Programs; |
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ID: aiam0896OpenMr. Charles P. Madigan, Sunspot Products Company, 25162 Mound Road, Warren, MI, 48091; Mr. Charles P. Madigan Sunspot Products Company 25162 Mound Road Warren MI 48091; Dear Mr. Madigan: This letter is in response to your letter to James H. Wakelin, forme Assistant Secretary of Commerce about the vertical flammability test cabinet used in Federal Motor Vehicle Safety Standards.; Although our Fire Technology Division is active in developing tests t measure the flammability of fabrics, we do not have jurisdiction in the area of motor vehicles. Nevertheless, we are happy to forward a copy of your letter to Mr. Joseph F. Zemaitia, Safety Standards Engineer, Office of Crashworthiness, Motor Vehicle Program, National Highway Traffic Safety Administration, Department of Transportation, Room 5319J, 400 7th Street, S.W., Washington, D.C. 20590.; We hope that this action is helpful to you. Sincerely, F. Karl Willenbrock, Director, Institute for Applie Technology; |
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ID: aiam0847OpenMr. Arthur N. Maupin, C. and M. Company, P. O. Box 1285, Zanesville, OH, 43701; Mr. Arthur N. Maupin C. and M. Company P. O. Box 1285 Zanesville OH 43701; Dear Mr. Maupin: This is in reply to your letter of August 12, 1972, in which you aske which manufacturers are subject to the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 302. You also asked us for permission to include copies of FMVSS No. 302 in your promotional literature, and requested copies of any modification or supplements to the flame test.; Any manufacturer of passenger cars, multipurpose passenger vehicles trucks, or buses manufactured on or after September 1, 1972, is subject to the requirements of the standard. FMVSS No. 302 is a published Federal regulation, and you may reproduce it and distribute it in your promotional literature. I have enclosed a copy of a Notice of Proposed Rule Making, 36 F.R. 9565, which would amend the standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1049OpenMr. Elmer Morgan, Mapother and Morgan, 521 West Market Street, Louisville, KY 40202; Mr. Elmer Morgan Mapother and Morgan 521 West Market Street Louisville KY 40202; Dear Mr. Morgan: This is in response to your question concerning the status o repossessing banks and finance companies as transferors under the odometer disclosure requirements of the Motor Vehicle Information and Cost Savings Act.; Banks and finance companies are obliged to make a disclosure upo resale of a repossessed vehicle. It is advisable to provide a disclosure form to be filled out by the defaulting transferor upon repossession. Should the defaulting transferor refuse to complete the form and the odometer is later found to be in error he may be subject to civil action under the Act.; In any case, if the bank or finance company does not know that th mileage is wrong, they should not state that the mileage is in error. If the repossessor wishes to add a statement that the vehicle has been repossessed or otherwise outside his control, he may do so.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5437Open"M. Guy Dorleans Legal Compliance Department Valeo Vision 34, rue St-Andr 93012 Bobigny Cedex France"; "M. Guy Dorleans Legal Compliance Department Valeo Vision 34 rue St-Andr 93012 Bobigny Cedex France"; Dear M. Dorleans: We have received your letter of July 15, 1994, askin whether certain front lamp designs would be permissible under Federal Motor Vehicle Safety Standard No. 108. In the basic front lamp design, the upper beam photometrics of Figure 17A would be provided by Lamps A and B. You have asked whether it is possible to add Lamp D, 'an auxiliary driving beam.' In this variation 'all three A, B and D filaments would be permanently energized together in high beam mode and table 17a (sic) of FMVSS 108 is then fulfilled.' Lamp D meets the photometric requirements of SAE Standard J581 JUN89 Auxiliary Driving Lamps. The photometrics of Figure 17A apply to two-lamp integral beam or two-lamp combination headlighting systems, and the design in your drawing is that of a four-lamp system, subject to the photometrics of Figure 15A. This configuration is not permissible under Standard No. 108. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0305OpenMr. Thomas S. Pieratt, Executive Secretary, Distributors Association, P.O. Box 11088, Cincinnati, OH 45211; Mr. Thomas S. Pieratt Executive Secretary Distributors Association P.O. Box 11088 Cincinnati OH 45211; Dear Mr. Pieratt: This is in response to your letter of March 1, 1971, in which yo inquired whether a 'crew-cab' truck is classified as a multipurpose passenger vehicle or a truck.; You said in your letter, 'It was our reasoning that the prime purpos of an MPV was to carry passengers, rather than to haul something, and that the addition of a crew cab which would accommodate an additional three persons, onto a chassis-cab which contains a dump body or utility body would not necessarily change the classification.'; The above statement is essentially correct. A crew-cab truck combine the purposes of both a multipurpose passenger vehicle and a truck. Where a vehicle has a significant capability for carrying either persons or cargo, its manufacturer may exercise his own discretion in classifying the vehicle.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0971OpenMr. W. S. Magenau, President, Chesapeake Marine Products, Route 256, Deale, MD 20751; Mr. W. S. Magenau President Chesapeake Marine Products Route 256 Deale MD 20751; Dear Mr. Magenau: This is in reply to your letter of December 18, 1972, requestin information as to how a distributor who assembles a boat trailer may certify the trailer under NHTSA requirements, when the weight ratings for the trailer when assembled differ from those anticipated by the fabricator, due to the distributor's use of components (tires and springs) of a greater weight-carrying capability than those envisioned by the fabricator.; The certification requirements applicable to the manufacture of boa trailers are found at section 567.4, 'Requirements for Manufacturers of Motor Vehicles'. The fabricator may affix the required label to a trailer in certain cases (section 567.4(f)(ii)), but in the case you describe, where the distributor assembles the vehicle in a manner not specifically anticipated by the fabricator, the assembler is the appropriate person, pursuant to S 567.4(g)(1), to certify the vehicle and affix the certification label. The label should state the name of the assembler (the distributor) as the manufacturer and reflect the weight ratings of the vehicle as assembled.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1916OpenMr. Harold Klug, Deputh Trade Delegate, Austrian Trade Delegation in the United States, 845 Third Avenue, 21st Floor, New York, NY 10022; Mr. Harold Klug Deputh Trade Delegate Austrian Trade Delegation in the United States 845 Third Avenue 21st Floor New York NY 10022; Dear Mr. Klug: This is in response to your letter of April 21, 1975, inquiring as t whether voltage regulators are of safety-related significance and therefore subject to the requirements of Pubic Law 93-492.; There are currently no motor vehicle safety standards regulating th performance of voltage regulators. However, under the National Traffic and Motor Vehicle Safety Act as amended (Pub. L. 93-492) the Secretary of Transportation is authorized to make a determination, in appropriate circumstances, that a motor vehicle or item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If he finds that a safety-related defect exists, the manufacturer must notify purchasers of the hazard and recall and remedy the defective vehicles. Therefore, even though voltage regulators are not the subject of a safety standard, they still must be designed so as not to contain safety-related defects.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3698OpenMr. N. Cope, Eaton Limited, Truck Components Operations, Engineering Centre, P.O. Box 11, Worsley Road North, Worsley, Manchester, M28 5GJ, England; Mr. N. Cope Eaton Limited Truck Components Operations Engineering Centre P.O. Box 11 Worsley Road North Worsley Manchester M28 5GJ England; Dear Mr. Cope:#This responds to your recent letter asking a questio concerning Safety Standard No. 106, *Brake Hoses*. You note that there is an ambiguity in the formula referenced in paragraph S8.3.2(e) of that standard as set forth in the *Code of Federal Regulations*. Specifically, you ask whether the entire fraction that is specified is multiplied by '100' or whether only the denominator of the fraction is multiplied by '100'.#The correct formula is as follows:#>>>[((W3-W4) - (W1-W2)) / (W1- W2)] X 100<<<#The formula as specified in the *Code of Federal Regulations* should, therefore, include additional brackets around the fraction, separating the fraction from the 'X 100' figure. We will notify the *Federal Register* concerning this error.#I hope this has clarified any misunderstanding you may have had.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam0972OpenMr. W. S. Magenau, President, Chesapeake Marine Products, Route 256, Deale, MD 20751; Mr. W. S. Magenau President Chesapeake Marine Products Route 256 Deale MD 20751; Dear Mr. Magenau: This is in reply to your letter of December 18, 1972, requestin information as to how a distributor who assembles a boat trailer may certify the trailer under NHTSA requirements, when the weight ratings for the trailer when assembled differ from those anticipated by the fabricator, due to the distributor's use of components (tires and springs) of a greater weight-carrying capability than those envisioned by the fabricator.; The certification requirements applicable to the manufacture of boa trailers are found at section 567.4, 'Requirements for Manufacturers of Motor Vehicles'. The fabricator may affix the required label to a trailer in certain cases (section 567.4(f)(ii)), but in the case you describe, where the distributor assembles the vehicle in a manner not specifically anticipated by the fabricator, the assembler is the appropriate person, pursuant to S 567.4(g)(1), to certify the vehicle and affix the certification label. The label should state the name of the assembler (the distributor) as the manufacturer and reflect the weight ratings of the vehicle as assembled.; Yours truly, Richard B. Dyson, Assistant 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.