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: aiam0872OpenMr. L. A. Ferguson, Project Engineer, Frigiking Division, Cummins Engine Company, Inc., 10858 Harry Hines Boulevard, Dallas, TX, 75220; Mr. L. A. Ferguson Project Engineer Frigiking Division Cummins Engine Company Inc. 10858 Harry Hines Boulevard Dallas TX 75220; Dear Mr. Ferguson: This is in reply to your letter of September 28, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to the plastic air discharge chambers or combination air chamber-unit housings of the air-conditioning units you manufacture for use in motor vehicles. You ask whether this equipment must meet the requirements of the standard.; The portion of an item of a motor vehicle equipment that forms part o a component listed in the standard will normally be subject to the standard. From the photographs of your equipment that you submitted, we would consider an air discharge chamber or combination air chamber-unit housing that forms part of the surface of a front or side panel to be incorporated into the panel and therefore subject to the standard. The air discharge chamber or combination chamber-unit housing of your roof-mounted equipment is not a part of the 'headlining,' and accordingly would not be subject to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0818OpenMr. Louis J. Zsoka, President, Garfield Rubber Products, Inc., 13532 Broadway Avenue, Garfield Heights, OH, 44125; Mr. Louis J. Zsoka President Garfield Rubber Products Inc. 13532 Broadway Avenue Garfield Heights OH 44125; Dear Mr. Zsoka: This is in reply to your letter of July 13, 1972, concerning th applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 302 to your sponge rubber weather-stripping for replacement.; Standard No. 302 does not apply to replacement parts or aftermarke materials. You are correct in your observation that sponge rubber weather-stripping is not included in the list of motor vehicle interior materials to which Standard No. 302 applies.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam1419OpenMr. Merle R. Flagg, Attorney at Law, Flagg, Cooper, Hayner, Miller, Long & Owen, 28th Floor 2001 Bryan Tower, Dallas, TX 75201; Mr. Merle R. Flagg Attorney at Law Flagg Cooper Hayner Miller Long & Owen 28th Floor 2001 Bryan Tower Dallas TX 75201; Dear Mr. Flagg: This is in reply to your letter of January 17, 1974, in which yo enclose a sample of the wording your client intends to use on his certification label, and solicit our comments.; The proposal that would allow an alternative to the required listing o individual axles (Docket No. 73-31, Notice 1) would become effective on the date of publication of the final rule, Consequently, certifiction labels using a single value for identical weight ratings may not be used until that time. The label you submit for approval does conform to the current proposal. However, we are considering requiring the inclusion of tire-size designations on the certification label when the gross axle weight ratings are combined.; We have no objection to the additional information contained on th label on the right of the required information. As we understand it, this will lessen the likelihood of mislabeling by the asembler in the field. It would not be possible for him to use a label that would overrate the trailer.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam0977OpenMr. William M. Hicks, Colson & Hicks, Law Offices, 66 West Flagler Street, Miami, Florida 33130; Mr. William M. Hicks Colson & Hicks Law Offices 66 West Flagler Street Miami Florida 33130; Dear Mr. Hicks: This is in response to your letter of January 25, 1973, which requeste information on Federal Motor Vehicle Safety Standard No. 124, *Accelerator Control Systems*.; This standard was issued by the National Highway Traffic Safet Administration on March 31, 1972. A copy of the standard, including a preamble discussing issues raised in public comments, is enclosed for your review and information.; We appreciate your interest in motor vehicle safety. If we can be o any further service, please let us know.; Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam2946OpenMr. R. C. Back, Director, Government Relations, P.O. Box 520816, Miami, FL 33152; Mr. R. C. Back Director Government Relations P.O. Box 520816 Miami FL 33152; Dear Mr. Back: This is in reply to your letter of January 23, 1979, in which you aske for confirmation of your interpretation that the new restriction on mounting height of rear side marker lamps applies only to trailers and not to trucks.; This confirms your interpretation. As is stated in Table II of Moto Vehicle Safety Standard No. 108, rear side marker lamps are to be mounted above the road surface 'not less than 15 in., and on the rear of trailers not more than 60 in.'; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1933OpenMr. Donald J. Gobeille, Jr., Product Safety Engineer, Volvo of America Corporation, Rockleigh, New Jersey 07647; Mr. Donald J. Gobeille Jr. Product Safety Engineer Volvo of America Corporation Rockleigh New Jersey 07647; Dear Mr. Gobeille: Please forgive the delay in responding to your letter of March 24 1975, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110, *Tire Selection and Rims--Passenger Cars*.; You have inquired whether the placard required by S4.3 of the standar may display information in addition to the items specified in S4.3(a) through (d). The NHTSA has no objection to such placarding, provided that the addition information is set apart from, not placed among, the required items.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam4223OpenMs. Dixie Hawkins, Mid-South Motors, Inc., 2617 Scottsway, Memphis, TN 38115; Ms. Dixie Hawkins Mid-South Motors Inc. 2617 Scottsway Memphis TN 38115; Dear Ms. Hawkins: This is in response to your letter of September 17, 1986, in which yo asked for a determination from the Agency concerning the Tennessee Certificate of Title and the Federal odometer disclosure requirements, 49 C.F.R. Part 580. The Tennessee title cannot be used in lieu of a separate odometer disclosure statement.; The title fails to meet the regulatory requirements because it does no include a space for the buyer's signature. This Agency considers the signature to be essential. It is an acknowledgment that the purchaser is aware of the mileage and prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. Furthermore, the buyer's signature is important to investigative and prosecutorial efforts.; The National Highway Traffic Safety Administration allows the use o the abbreviated disclosure statements such as those which appear on the Tennessee title. Although a shorter disclosure might sacrifice clarity to a degree, the Agency regards this as an acceptable price for gaining the benefits of a combined title and odometer disclosure. When the odometer has been repaired or replaced, the box on the title which should be checked depends on the circumstances surrounding the repair or replacement. If the mileage indicated on the odometer remained the same as before repair or replacement, you should check the box which states:; >>>I hereby certify that to the best of my knowledge the odomete reading as stated above reflects the actual mileage of the vehicle described below.; <<>>I hereby certify that to the best of my knowledge the odomete reading as stated above is not the actual mileage of the vehicle described below, and should not be relied upon.<<<; If you have any questions do not hesitate to call Judith Kaleta a (202) 366-1834.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3694OpenMr. John E. Bennett, Director - Research & Engineering, Truck-Lite Co., Inc., 310 East Elmwood Avenue, Falconer, NY 14733; Mr. John E. Bennett Director - Research & Engineering Truck-Lite Co. Inc. 310 East Elmwood Avenue Falconer NY 14733; Dear Mr. Bennett: This is in response to your letter of April 12, 1983, asking for a interpretation of paragraph S4.6(b) of Motor Vehicle Safety Standard No. 108.; This paragraph states in pertinent part that 'means may be provided t flash...side marker lamps for signalling purposes.' You have first asked whether the rear side marker can be made to flash. You have also asked whether this language may be interpreted as allowing both front and rear side marker lamps to be flashed. The answer to both questions is yes. In the absence of restrictive language, paragraph S4.6 may be interpreted as allowing flashing of either front or rear side marker lamps, or both sets of lamps.; You have also asked whether, where the rear side marker and taillam use the same optical source ('minor filament of a 1157 or similar bulb'), it is acceptable to have an overriding signal visible through the rear side marker lens when the turn signal lamp is actuated. The answer is yes. The standard's prohibition against optical combinations (paragraph S4.1.1) does not preclude this design.; We hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3917OpenMr. Gordon Bonvallet, Manager, Photometric Division, ETL Testing Laboratories, Inc., P.O. Box 2040, Cortland, NY 13045- 2040; Mr. Gordon Bonvallet Manager Photometric Division ETL Testing Laboratories Inc. P.O. Box 2040 Cortland NY 13045- 2040; Dear Mr. Bonvallet: This is in reply to your letter of February 13, 1985, to this Offic asking whether the agency intended to eliminate the maximum allowable value for parking lamp candlepower in the amendments of November 26, 1984 which established Figure 1b.; Thank you for calling this matter to our attention. The amendmen appears to have the effect you ascribe to it, though it was not the agency's intention that it do so. The maximum values of SAE J222 December 1970 are those that should apply, and we shall reinstate them in the near future.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam4300OpenMr. Paul B. Krieger, Director of Marketing, Sky-Top Sunroofs Ltd., 4700 Le Bourget Drive, St. Louis, MO 63134; Mr. Paul B. Krieger Director of Marketing Sky-Top Sunroofs Ltd. 4700 Le Bourget Drive St. Louis MO 63134; Dear Mr. Krieger: This responds to your letter of November 4, 1986, in which yo requested that this agency amend Federal motor vehicle safety standard (FMVSS) 118, *Power Operated Window Systems*.; In your letter, you mentioned an electronic touchpad, known as th DOORMAN keyless entry system, and stated that it is designed to be used by someone outside a vehicle to operate your power sunroof. You requested that this agency amend paragraph S3(c) of the standard, which currently permits the operation of power windows and vehicle exterior, to permit the operation of a sunroof by means of an electronic touchpad system.; There is no need to amend Standard 118 to permit the use of you touchpad since the reference in Standard 118 to power-operated window and partition systems does not include sunroofs. Windows include the typical power windows on the sides of many vehicles and to the power tailgate windows on station wagons. Partitions refer to movable surfaces, such as those found inside some taxicabs and limousines, which separate different portions of the vehicle interior from one another.; Since there is no need to amend Standard 118, we are treating you letter as a request for interpretation and trust that it is fully answered by this response.; Sincerely, Erika Z. Jones, 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.