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: aiam2253OpenMr. Alvin L. Slayton, Product Reliability Department, American Bosch Electrical Products, P. O. Box 2228, Columbus, MS 39701; Mr. Alvin L. Slayton Product Reliability Department American Bosch Electrical Products P. O. Box 2228 Columbus MS 39701; Dear Mr. Slayton:#This responds to your February 23, 1976, questio whether Standard No. 104, *Windshield Wiping and Washing Systems*, still references SAE J903a as it did in 1969, and whether a future reference to SAE J903b or SAE J903c is anticipated.#The answer to your first question is yes. The answer to your second question is no. A proposed change in Standard No. 104 would be published in the *Federal Register*, and interested persons would be given an opportunity to comment.#Yours truly, Stephen P. Wood, Assistant Chief Counsel; |
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ID: aiam1384OpenMr. Gordon Needleman, Patent Attorney, Dow Corning Corp., Midland, Michigan 48640; Mr. Gordon Needleman Patent Attorney Dow Corning Corp. Midland Michigan 48640; Dear Mr. Needleman: This is in reply to your letter of January 10, 1974, to Mr. Schneider. It is uncertain whether 'sometime in July of 1974 Federal standard will become effective relating to silicone brake fluids' The proposed effective date for DOT 5 fluids if July 1, 1974, but the comments on this rulemaking action are still under consideration and the actual effective date, if the proposal is adopted, will probably be somewhat later.; It is true the S5.4.3 of Standard No. 105a does not require that al reservoir labelling be 'DOT 3.' The letters '*e.g.*' mean 'for example'. If DOT 4 is the recommended fluid the 'DOT 4' would be the appropriate insertion in the required statement; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1385OpenMr. Gordon Needleman, Patent Attorney, Dow Corning Corp., Midland, Michigan 48640; Mr. Gordon Needleman Patent Attorney Dow Corning Corp. Midland Michigan 48640; Dear Mr. Needleman: This is in reply to your letter of January 10, 1974, to Mr. Schneider. It is uncertain whether 'some time in July of 1974 Federal standar will become effective relating to silicone brake fluids.' The proposed effective date for DOT 5 fluids is July 1, 1974, but the comments on this rulemaking action are still under consideration and the actual effective date, if the proposal is adopted, will probably be somewhat later.; It is true that S5.4.3 of Standard No. 105a does not require that al reservoir labeling be 'DOT 3.' The letters '*e.g.*' mean 'for example.' if DOT 4 is the recommended fluid then 'DOT 4' would be the appropriate insertion in the required statement.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3774OpenLarry D. Beall, P.A., 2500 Louisiana Blvd., N.E., Suite 400, Albuquerque, NM 87110; Larry D. Beall P.A. 2500 Louisiana Blvd. N.E. Suite 400 Albuquerque NM 87110; Dear Mr. Beall: This is in response to your letter of October 21, 1983 asking whethe the State of New Mexico has been authorized by the National Highway Traffic Safety Administration (NHTSA) to use a form of document in lieu of the federal odometer disclosure statement.; On April 9, 1982, NHTSA approved New Mexico's odometer disclosur statement for use in lieu of the federal form. Pursuant to your inquiry, however, NHTSA has found that New Mexico is not currently using the approved form. New Mexico's current Certificate of Title does not satisfy the requirements of 49 CFR 580 and, therefore, the Federal odometer disclosure statement must be used.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1145OpenMr. John E. Huisman, Davies, Gibbs, Strayer, Stoel and Boley, Twenty-third Floor, 900 S.W. Fifth Avenue, Portland, OR 97204; Mr. John E. Huisman Davies Gibbs Strayer Stoel and Boley Twenty-third Floor 900 S.W. Fifth Avenue Portland OR 97204; Dear Mr. Huisman: This is in response to your letter request of May 14, 1973, for a interpretation of the NHTSA odometer disclosure regulations, 49 CFR Part 580. You asked how the regulations apply to a bank which finances automobiles by actual purchase of the vehicle and the purchase money security agreement from the dealer, and obtains possession of those vehicles upon default when the bank repossesses them for return to the dealer.; In this situation the bank has full title to, and possession of, th vehicle and must make the odometer disclosure upon transfer to the dealer. Unlike the previous situation where the bank had no knowledge of the vehicle or control over it, the bank physically returns the vehicle in this case and is the actual transferor.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0111OpenJames E. O'Donohoe, Esq., Messrs. O'Donohoe and O'Connor, 26 North Chestnut Avenue, New Hampton, IA 50659; James E. O'Donohoe Esq. Messrs. O'Donohoe and O'Connor 26 North Chestnut Avenue New Hampton IA 50659; Dear Mr. O'Donohoe: In your letter of August 15 you ask for a copy of regulations issue under the National Traffic and Motor Vehicle Safety Act of 1966 which might apply to 'a small refuse- carrying three-wheeled vehicle' which is being designed by one of your clients.; I enclose a copy of all Federal Motor Vehicle Safety Standards whic have been issued to date. You will note in 23 C.F.R. S 255.3(b) that the definitions of 'truck' and 'motorcycle' or 'motor driven cycle' appear to apply to the vehicle you have described. In order to make a definite classification we need more information such as 'a photograph of the vehicle and a technical specification sheet.'; However, if the vehicle is classified as a 'truck', 23 C.F.R. 255.7(a) provides that the Federal Standards will not apply if its curb weight is 1,000 pounds or less. If the vehicle is classified as a 'motorcycle' or 'motor driven cycle', Federal Standard No. 108 effective January 1, 1969, will be the only Standard applicable to this category of vehicle.; If there is any further assistance I can give you I shall be happy t do so.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam1179OpenMr. R. J. Updegraff, Manager, Kysor of Cadillac, 1100 Wright Street, Cadillac, MI 49601; Mr. R. J. Updegraff Manager Kysor of Cadillac 1100 Wright Street Cadillac MI 49601; Dear Mr. Updegraff: This is in reply to your letter of June 22, 1973, concerning th applicability of section S5.1.4, *Pressure gauge*, of Standard No. 121, to an electronic gauge that displays the air pressure under normal conditions only when the driver pushes a switch but that provides continuous display at pressures below 70 p.s.i.; Section S5.1.4 requires a pressure gauge to be 'readily visible.' Use in this context, 'readily visible' means visible whenever the driver wants to see it. It does not mean that the air pressure level should be continuously visible. As we understand your system, the driver could determine the air pressure at any time by pushing the 'air pressure' button. We have concluded that this operation satisfies the intent of S5.1.4 and that your system would be permissable (sic) under that section.; The low pressure warning signal is required by section S5.1.5 and mus be separate from the pressure gauge. You state that you provide a flashing red light and an audible alarm, in addition to providing continuous readout of air pressure below 60 p.s.i. This would appear to conform to S5.1.5.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4507OpenIrving Gingold, Esq. 529 Nassau Road Roosevelt, NY 11575; Irving Gingold Esq. 529 Nassau Road Roosevelt NY 11575; Dear Mr. Gingold: This is in response to your letter of April 27, 1988 asking whether any of the Federal motor vehicle safety standards apply to an airport baggage conveyor. The answer is no. The National Traffic and Motor Vehicle Safety Act of 1966 ('Safety Act', 15 U.S.C. 1381 et seq.), authorizes this agency to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. Conversely, we have no authority to regulate vehicles that are not 'motor vehicles' or equipment that is not 'motor vehicle equipment.' Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a motor vehicle as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. Under this definition, any vehicle intended and sold solely for off-road use is not considered a motor vehicle under the Safety Act, even if it is operationally capable of highway travel. We have long offered 'airport runway vehicles' as an example of vehicles that are not motor vehicles, because they are sold solely for off-road use. NHTSA has specifically stated that an airport baggage trailer is not a motor vehicle, in a July 11, 1983 letter to D.F. Landers. Since the airport baggage conveyor to which you referred in your letter is not a 'motor vehicle,' none of our safety standards or other regulations would apply to the vehicle. We are not aware of any other Federal agency that has established safety standards applicable to airport baggage conveyors. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam1295OpenMr. Tatsuo Kato, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tatsuo Kato Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Kato: This is in reply to your letter of September 25, 1973, asking whethe the fuel spillage measurement specified in Standard No. 301 is an average rate of one ounce per minute (your Item A) or an actual rate. (Your Item B); Your item B is correct. Fuel spillage shall not exceed one ounce pe minute in any one of the fifteen minutes of the observed period.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0868OpenMr. Charles E. Packard, Senior Engineer, Clay Equipment Corporation, Cedar Falls, IA 50613; Mr. Charles E. Packard Senior Engineer Clay Equipment Corporation Cedar Falls IA 50613; Dear Mr. Packard: This is in reply to your letter of September 5, 1972, in which yo enclose a copy of your brochure describing a 'Honey Wagon' and ask what our requirements are.; The 'Honey Wagon' described in your brochure appears to be manufacture primarily for off-road use. The National Traffic and Motor Vehicle Safety Act and the Federal Motor Vehicle Safety Standards do not apply to off-road use vehicles.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, |
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.