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: aiam3380OpenMr. Eric C. Oppenheim, Esq., Corporate Attorney, Kux Manufacturing Company, 12675 Burt Road, Detroit, MI =48223; Mr. Eric C. Oppenheim Esq. Corporate Attorney Kux Manufacturing Company 12675 Burt Road Detroit MI =48223; Dear Mr. Oppenheim: This is in reply to your letter of November 23, 1980 asking whether an Federal regulation 'prohibits the use of reflective red markings on the front of vehicles.'; The Federal Motor Carrier Safety Regulation administered by the Federa Highway Administration of the Department of Transportation impliedly prohibit the use of red reflectors on the front of vehicles subject to its jurisdiction by requiring that all reflectors, other than those at the rear, be amber in color (49 CFR 393.26(d)). The common contract, private or exempt carriers covered by this requirement are found in 49 U.S.C. 303.; The Federal motor vehicle safety standard on vehicle lighting (49 CF 571.108) applicable to the manufacture of all motor vehicles contains a general prohibition (paragraph S4.1.3) against installation of reflective devices that impair the effectiveness of required lighting equipment. Because of the generally accepted lighting coding of amber to the front and red to the rear, we would view installation of red reflective material on the front of a vehicle as prohibited by S4.1.3.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5321OpenEric T. Stewart, Engineering Manager Mid Bus 3555 St. Johns Road P.O. Box 1985 Lima, OH 45802-1985; Eric T. Stewart Engineering Manager Mid Bus 3555 St. Johns Road P.O. Box 1985 Lima OH 45802-1985; Dear Mr. Stewart: This responds to your letter of March 17, 1994 regarding a final rule published November 2, 1992 (57 FR 49413) amending Standard No. 217, Bus Emergency Exits and Window Retention and Release. You requested clarification of the width requirement in S5.5.3(c) for retroreflective tape. You are correct that there was a discrepancy concerning the size of the tape caused by the metric conversion in the final rule. Enclosed is a copy of a July 7, 1993 letter to Mr. Thomas D. Turner of the Blue Bird Body Company which discusses this issue. As explained in that letter, we plan to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. Until the correction is issued, we will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape. I hope you find this information helpful. If you have any other questions, please contact us at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam1064OpenMr. Bruce E. Roberts, President, Yuma Tire & Recapping, Inc., Route 3, Gate City, Virginia 24251; Mr. Bruce E. Roberts President Yuma Tire & Recapping Inc. Route 3 Gate City Virginia 24251; Dear Mr. Roberts: This is in reply to your letter of February 28, 1973, requesting detailed explanation of what you must do to conform to Motor Vehicle Safety Standard No. 117, 'Retreaded Pneumatic Tires'. You also ask whether there are record keeping requirements, such as to maintain the name and address of customers to whom tires are sold.; There are specific requirements for retreaders and their dealers t record and maintain the name and address of each tire purchaser. This is done through the use of a code number molded or branded onto each tire. These requirements (49 CFR Part 574, copy enclosed) have been in effect since May 22, 1971.; We have enclosed a copy of Standard No. 117. We regret that we canno provide a detailed explanation of these requirements as you request. We refer you to either private counsel or to one of the many associations of retreaders whom we understand can assist you in implementing the standard. If after reading the standard you have questions of a specific nature regarding its provisions, we will respond to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1068OpenMr. Bruce E. Roberts, President, Yuma Tire & Recapping, Inc., Route 3, Gate City, VA 24251; Mr. Bruce E. Roberts President Yuma Tire & Recapping Inc. Route 3 Gate City VA 24251; Dear Mr. Roberts: This is in reply to your letter of February 28, 1973, requesting detailed explanation of what you must do to conform to Motor Vehicle Safety Standard No. 117, 'Retreaded Pneumatic Tires'. You also ask whether there are record keeping requirements, such as to maintain the name and address of customers to whom tires are sold.; There are specific requirements for retreaders and their dealers t record and maintain the name and address of each tire purchaser. This is done through the use of a code number molded or branded onto each tire. These requirements (49 CFR Part 574, copy enclosed) have been in effect since May 22, 1971.; We have enclosed a copy of Standard No. 117. We regret that we canno provide a detailed explanation of these requirements as you request. We refer you to either private counsel or to one of the many associations of retreaders whom we understand can assist you in implementing the standard. If after reading the standard you have questions of a specific nature regarding its provisions, we will respond to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3689OpenMr. James E. Benson, Sales Manager, Boschung Company, Inc., 530 Armory Drive, South Holland, IL 60473; Mr. James E. Benson Sales Manager Boschung Company Inc. 530 Armory Drive South Holland IL 60473; Dear Mr. Benson: This is in reply to your letter of March 23, 1983, asking whether stop lamp is required on a Boschung vehicle which has a top speed of 16 mph. You also asked for a copy of the 'Rules for Manufacturer Standard Specs.'; The agency does not consider a vehicle, which cannot exceed 20 mph an has an abnormal configuration, to be a motor vehicle. These vehicles, typically, are highway maintenance and construction equipment, lane stripers, self-propelled pavers, sod handler, fork lift, and other similar vehicles. It would not appear, therefore, that the low-speed Boschung is a 'motor vehicle.' The question of whether it is required to have a stop lamp, therefore, is dependent upon the laws of the municipality in which it is operated.; I assume the 'Rules' you wish are the Federal motor vehicle safet standards. You should write the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402, enclosing a check for $8, and ask for 'Title 49 Code of Federal Regulations Parts 400 to 999.' The safety standards are at Part 571, and you will find all other regulations in the 500 series which apply to motor vehicles and their manufacturers.; If you have any further questions, we shall be happy to answer them. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0447OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Distributors Association, 602 Main Street, Cincinnati, OH, 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: In your letter of September 23, 1971, you asked whether Standard No 302, Flammability of Interior Materials, applied to materials in the passenger compartments of vehicles.; The answer is yes. The standard, as stated in S4.1, applies t 'components of vehicle occupant compartments' only.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1478OpenJohn F. McCuen, Esq., Kelsey-Hayes Company, Romulus, MI; John F. McCuen Esq. Kelsey-Hayes Company Romulus MI; Dear Mr. McCuen: This will acknowledge receipt of Kelsey- Hayes' petition to ad 'after-stop' to the description of the temperature range in S6.1.8.1 of Standard No. 121 and S7.4.2.1.2 of Standard No. 105a.; The temperature range is in fact intended to describe the after-sto temperature of the brakes, and the language of the sections will be clarified in the future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1351OpenMs. Deborah A. Henderson, Crisp & Henderson, Attorneys at Law, 119 West Third Street, Post Office Box 91, Greenville, North Carolina 27834; Ms. Deborah A. Henderson Crisp & Henderson Attorneys at Law 119 West Third Street Post Office Box 91 Greenville North Carolina 27834; Dear Ms. Henderson: This is in reply to your letter of November 19, 1973, inquiring whethe there are Federal or State regulations that contain labeling requirements for rubber used in retreaded tires.; There are to our knowledge no Federal regulations that either establis quality levels or require labeling for rubber used in retreaded tires.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0325OpenJacob P. Billig, Esq., Suite 400, 1108 Sixteenth Street, N.W., Washington, DC, 20036; Jacob P. Billig Esq. Suite 400 1108 Sixteenth Street N.W. Washington DC 20036; Dear Mr. Billig: In response to your letter of April 16, 1971, it is our opinion tha the placement of the 2 1/4-inch-wide orange reflex reflector striping material on motor vehicles, in the manner shown in Exhibit A of your letter, would not impair the effectiveness of lamps, reflective devices, and associated equipment required by Federal Motor Vehicle Safety Standard No. 108, and would not be prohibited by that standard.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0405OpenMr. Charles A. Slater, Jr., Vice President - Engineering, Peterson Manufacturing Company, 4515 East 75th Terrace, Kansas City, MO, 64132; Mr. Charles A. Slater Jr. Vice President - Engineering Peterson Manufacturing Company 4515 East 75th Terrace Kansas City MO 64132; Dear Mr. Slater: In reply to your letter of July 9, you are correct in assuming 'it wil still be permissible to illuminate motorcycle license plates from the bottom even after January 1, 1973.'; The installation requirements of Standard No. 108, as set out in SA Standard 587d, License Plate Lamps, March 1969, do not apply to motorcycles and motor driven cycles.; Sincerely, Lawrence R. Schneider, 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.