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: aiam2801OpenMr. William N. Whitley, Vice President, Whitley-Whitley Inc., 26000 Chagrin Boulevard, Shaker Heights, Ohio 44122; Mr. William N. Whitley Vice President Whitley-Whitley Inc. 26000 Chagrin Boulevard Shaker Heights Ohio 44122; Dear Mr. Whitley: This is in reply to your letter of January 17, 1978, in which you aske for a definition of the automobile-mounted camping unit illustrated in Design Patent No. 198,497.; The automobile-mounted camping unit would be classified as a 'Slide-i camper' and would be regulated by the Federal Motor Vehicle Safety Standard No. 126, Truck-Camper Loading. We are enclosing a copy of Safety Standard No. 126 and a copy of an amendment dated April 21, 1978. The complete Federal Motor Vehicles Safety Standards (FMVSS) and Regulations may be purchased from the Superintendent of Documents by using the enclosed subscription order form.; Sincerely, Michael M. Finkelstein, Acting Associate Administrator fo Rulemaking; |
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ID: aiam5257OpenJohn B. Walsh Legal Affairs Manager Corporate Attorney American Suzuki Motor Corporation 3251 E. Imperial Highway P.O. Box 1100 Brea, CA 92622-1100; John B. Walsh Legal Affairs Manager Corporate Attorney American Suzuki Motor Corporation 3251 E. Imperial Highway P.O. Box 1100 Brea CA 92622-1100; Dear Mr. Walsh: This acknowledges receipt of your letter dated Octobe 29, 1993 requesting an interpretation of the labeling requirements of the recent final rule mandating the installation of air bags in passenger cars and light trucks (58 FR 46551, September 2, 1993). As you suggested in your letter, we believe it would be appropriate to respond to your request in the notice responding to the petitions for reconsideration of the September 2 final rule. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2311OpenMr. David E. Martin, Director, Automotive Safety Engineering, Environmental Activities Staff, General Motors Corporation, General Motors Technical Center, Warren , MI, 48090; Mr. David E. Martin Director Automotive Safety Engineering Environmental Activities Staff General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Martin: This is in reply to your letter of March 8, 1976, asking for a amendment of S4.1.1.21 of Motor Vehicle Safety Standard No. 108 to allow a plus tolerance of 7.5 percent on maximum wattage requirements for Type 1A and 2A headlamps.; I enclose a copy of an interpretation furnished the General Electri Company which states that such a tolerance is allowed. However, to clarify our intent we plan to amend Standard No. 108 in the near future in the manner that you suggest.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam2146OpenMs. Dianne Black, Liaison Engineer, British Leyland Motors Inc., 600 Willow Tree Road, Leonia, NJ 07605; Ms. Dianne Black Liaison Engineer British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black:#This is in response to your October 20, 1975, lette concerning the status of amendments to Federal Motor Vehicle Safety Standard No. 101, *Control Location, Identification and Illumination*, that were proposed in Notice 10 (Docket 1-18, 38 FR 26940, September 27, 1973).#Although a further proposal on this subject is being considered, no final decision has been made by the National Highway Traffic Safety Administration (NHTSA) concerning action on the outstanding proposal. You should be guided by the standard in its present form. The effective date of any amendments issued by the NHTSA will allow adequate lead time for compliance.#Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam2491OpenMr. Tokio Iinuma, Nissan Motor Co., LTD., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tokio Iinuma Nissan Motor Co. LTD. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Iinuma: This will confirm your November 11, 1976, telephone conversation wit Tad Herlihy of this office, concerning the certification label required by 49 CFR Part 567.; On the vehicles in question, the certification labels mistakenl indicated 1977 as the year of manufacture, even though manufacturing was actually completed in 1976. You proposed correcting this error before sale by crossing out the digits '77' and inserting '76' directly below them.; The National Highway Traffic Safety Administration has no objection t certification labels that have been corrected in this manner, provided that all other requirements of the certification regulation are also met.; Sincerely, Mr. Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0621OpenMr. Ronald B. Stewart, Manager of Product Engineering, Newell Companies, Freeport, IL, 61032; Mr. Ronald B. Stewart Manager of Product Engineering Newell Companies Freeport IL 61032; Dear Mr. Stewart: This is in reply to your letter of February 25, 1972, concerning Moto Vehicle Safety Standard No. 302. In your letter you ask whether the standard applies to drapery hardware and cords, plastic pulleys and carriers, and if so, whether burn rates for these components can be based on the 'Modern Plastics Encyclopedia,' which in turn is based on ASTM Test Method D635.; The standard lists the categories of interior components to which i applies. This list does not include drapery hardware, cords, plastic pulleys, or carriers, and we do not consider the standard to apply to those items.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5428OpenMr. Keith E. Smith Piper & Marbury 2 Penn Center Plaza, Suite 1500 Philadelphia, PA 19102-1715; Mr. Keith E. Smith Piper & Marbury 2 Penn Center Plaza Suite 1500 Philadelphia PA 19102-1715; Dear Mr. Smith: This responds to your letter asking whether th National Highway Traffic Safety Administration (NHTSA) considers automotive and motorcycle braking systems to be 'safety devices.' As explained below, the agency considers such systems to be items of motor vehicle equipment. Please note that neither the National Traffic and Motor Vehicle Safety Act (formerly at 15 U.S.C. 1381 et seq. and recently codified in Title 49 of the U.S. Code) nor the agency's regulations in Title 49 of the Code of Federal Regulations use the phrase 'safety device.' Rather, the statute refers to 'motor vehicles' and 'motor vehicle equipment.' Specifically, motor vehicle equipment is defined, in relevant part, as any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle ... Under this definition, NHTSA would consider an automotive or motorcycle braking system to be an item of motor vehicle equipment. Please note that the Federal motor vehicle safety standards are issued to meet the need for safety. For example, the purpose of Standard No. 105, which regulates hydraulic brake systems of passenger cars and other specified vehicles, is 'to insure safe braking performance under normal and emergency conditions.' See S2 of Standard No. 105. Similarly, the purpose of Standard No. 122, which regulates motorcycle brake systems, is 'to insure safe motorcycle braking performance under normal and emergency conditions.' See S2 of Standard No. 122. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0510OpenMr. Leonard Teich, Eddington Thread Manufacturing Company, Street & Knights Roads, Eddington, PA, 19020; Mr. Leonard Teich Eddington Thread Manufacturing Company Street & Knights Roads Eddington PA 19020; Dear Mr. Teich: This is in reply to your letter of November 9, 1971, inquiring o behalf of the Ford Motor Company to whom you supply synthetic sewing threads, whether there is a specification for the flammability of sewing thread.; Motor Vehicle Safety Standard No. 302, 'Flammability of Interio Materials' (49 CFR 571.302) (copy enclosed), which becomes effective September 1, 1972, establishes minimum requirements for the flammability of certain motor vehicle components which are listed in S4.1 of the standard. Any synthetic or other thread that is used in the manufacture of any of these components must meet the standards requirements when tested as part of the component.; If you have additional questions, please let us know. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1037OpenMr. W. A. Scott, Manger (sic), Tech. Service, Chrysler Leasing Corporation, P.O. Box 1057, Detroit, MI 48231; Mr. W. A. Scott Manger (sic) Tech. Service Chrysler Leasing Corporation P.O. Box 1057 Detroit MI 48231; Dear Mr. Scott: This will serve to confirm the advice given you by telephone on Marc 12, 1973, concerning the obligations of a leasing company under the Federal Odometer Requirements, 49 CFR Part 580.; The situation that concerns you is the transfer from the lessor to th lessee of a vehicle that has been wrecked or stolen while in the lessee's possession. In transfers of this type, the lessee often fails to tell the lessor the mileage on the vehicle, so that the mileage cannot be indicated on the disclosure form. It is our opinion that the lessor in this situation should leave the mileage blank and indicate that the true mileage is unknown.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0071OpenMr. A. Hammerstein, Robert Bosch GMBH, Gruppe Autoelektrik, Entwicklungsleitung, 7000 Stuttgart 1, Postfach 50, Germany, Federal Republic; Mr. A. Hammerstein Robert Bosch GMBH Gruppe Autoelektrik Entwicklungsleitung 7000 Stuttgart 1 Postfach 50 Germany Federal Republic; Dear Mr. Hammerstein: Thank you for your letters of March 7 and May 15, 1968, to Mr. Georg C. Nield, concerning the requirements for motorcycle headlamps as specified in Motor Vehicle Safety Standard No. 108.; On motorcycles, Standard No. 108 permits the use of unsealed headlamp conforming to SAE Standard J584. You will note that this SAE standard does not reference bulb sockets conforming to SAE Standard J567, which is intended to insure functional compatibility between bulb sockets and the bulbs listed in SAE Standard J573. Therefore, the bulbs used in motorcycle headlamps conforming to SAE Standard J584 need not conform to SAE Standard J573.; Thank you for writing. Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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.