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: aiam1667OpenStephen J. Pollak, Esq., Messrs. Shea & Gardner, 734 Fifteenth Street, N.W., Washington, DC 20005; Stephen J. Pollak Esq. Messrs. Shea & Gardner 734 Fifteenth Street N.W. Washington DC 20005; Dear Mr. Pollak: This is in reply to your letter of November 11, 1974 enclosing a draf of a defect notification letter to be sent on behalf of SINFAC, S.A., to known purchasers of the Solex motor-driven cycle.; These letters meet our requirements and will fulfill SINFAC' obligation under Section 113. Item 1 in the notification letter would read more accurately 'Absence of front and rear turn signals required on vehicles manufactured on or after January 1, 1973.'; Thank you for your cooperation. Upon receipt of a check for $10,000 w shall close our files in this matter.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1547OpenMr. H. Miyazawa, Director, Automotive Lighting, Engineering Department, Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. H. Miyazawa Director Automotive Lighting Engineering Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Miyazawa: This is in reply to your letter of June 27 concerning the location o motorcycle turn signal lamps relative to a combination stop lamp and reflex reflector.; The minimum edge to edge separation distance specified in Table IV o FMVSS No. 108 for motorcycle turn signal lamps is to be measured from the edge of the illuminated surface of both lamps.; The answer to your question 2 is therefore applicable, '2. edge to edg of tail and stop lamp so drawn in sketch C?'; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam0736OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment and Body Distributors Assn., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment and Body Distributors Assn. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of June 9 asking whether pole trailer must be certified.; The answer is no. According to 49 CFR S 567.2(a), only motor vehicle to which one or more Federal motor vehicle safety standards are applicable must be certified. The only Federal standard currently in effect that applies to 'trailers', Standard No. 108, specifically exempts 'pole trailers' from its applicability and therefore pole trailers need not be certified.; Your letter of February 23 regarding clearance lamps and identificatio lamps is still under consideration and we hope to provide a response in the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0737OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment and Body Distributors Assn., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment and Body Distributors Assn. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of June 9 asking whether pole trailer must be certified.; The answer is no. According to 49 CFR S 567.2(a), only motor vehicle to which one or more Federal motor vehicle safety standards are applicable must be certified. The only Federal standard currently in effect that applies to 'trailers', Standard No. 108, specifically exempts 'pole trailers' from its applicability and therefore pole trailers need not be certified.; Your letter of February 23 regarding clearance lamps and identificatio lamps is still under consideration and we hope to provide a response in the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0519OpenMr. Donald R. Meton, Systems Safety Engineer, Oshkosh Truck Corporation, Oshkosh, WI 54901; Mr. Donald R. Meton Systems Safety Engineer Oshkosh Truck Corporation Oshkosh WI 54901; Dear Mr. Meton: This is in reply to your telegram of December 9, 1971, in which yo asked whether the effective dates of Standards 206, 207, 208, and 210 are postponed to January 1, 1974 for firefighting vehicles as a result of the adoption of the effective date provisions of 49 CFR 571.8 (36 F.R. 13926, July 28, 1971).; Our answer is that since all of the amendments making the liste standards applicable to trucks were issued prior to the September 1, 1971 reference date used in 571.8, these standards are effective on the dates established at the time of their issuance. Versions of Standards 208 and 210 became effective for trucks on July 1, 1971, and amended versions of these standards, as well as standards 206 and 207 become effective January 1, 1972.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0051OpenMr. O. Weinreich, Staff Engineer, Bayerische Motoren Werke, c/o Hoffman Motors Corporation, 50 Louis Street, South Hackensack, NJ 07606; Mr. O. Weinreich Staff Engineer Bayerische Motoren Werke c/o Hoffman Motors Corporation 50 Louis Street South Hackensack NJ 07606; Dear Mr. Weinreich: Thank you for your letter of February 21, 1968, to Mr. J. E. Leysath o this Bureau, concerning the use of tubular type bulbs in license plate lamps.; Motor Vehicle Safety Standard No. 108 requires that license plate lamp conform to Society of Automotive Engineers (SAE) Standard J587b. SAE J587b in turn requires that bulbs and bulb sockets conform to SAE Standards J573b and J567b, respectively. Since tubular type bulbs and sockets for these bulbs do not conform to these SAE Standards, their use in license plate lamps would not be permitted under the requirements of Standard No. 108.; Thank you for writing. Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam2079OpenMr. Byron Crampton, Truck Body and Equipment Association, 5530 Wisconsin Avenue, Suite 1210, Washington, DC 20015; Mr. Byron Crampton Truck Body and Equipment Association 5530 Wisconsin Avenue Suite 1210 Washington DC 20015; Dear Mr. Crampton: This responds to your September 8, 1975, question whether trucks tha carry specialized equipment (such as emergency medical equipment, fire fighting apparatus, or mobile power generator equipment), would qualify for exclusion from Standard No. 121, *Air Brake Systems*, if they are geared down or governed so that their speeds attainable in two miles are not more than 45 mph. You state that each vehicle's empty weight is more than 95 percent of its gross vehicle weight rating (GVWR).; The section of Standard No. 121 that lists the vehicles to which th standard applies reads as follows:; >>>S3. *Applicability*. . . . In addition, the standard does not appl to any trailer whose unloaded vehicle weight is not less than 95 percent of its GVWR, or any vehicle that meets any one of criteria (a) through (d) as follows:; . . .(d)(1) A speed attainable in two miles of not more than 45 mph and; (2) An unloaded vehicle weight that is not less than 95 percent of th vehicle GVWR, and; (3) No passenger-carrying capacity. << |
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ID: aiam3277OpenHonorable Samuel S. Stratton, House of Representatives, Washington, D.C. 20515; Honorable Samuel S. Stratton House of Representatives Washington D.C. 20515; Dear Mr. Stratton: This responds to your recent correspondence requesting information o behalf of the Schenectady County Traffic Safety Board. The Safety Board is concerned that many new or converted propane-powered vehicles carry no identification indicating that the vehicles contain propane fuel instead of gasoline. The Safety Board states that this creates a dangerous situation for firemen, policemen or other emergency personnel who respond to accidents involving propane-powered vehicles. You were asked to initiate legislative action to require such identification on these vehicles.; The National Highway Traffic Safety Administration issues safet standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. Therefore, if there were a demonstrated safety need for identification on propane vehicles, the agency would have authority under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, *et seq*.) to require a label or tag as was suggested by the Safety Board. Please inform the Safety Board that it should petition the agency to initiate rulemaking action to establish such a requirement if it has information or evidence indicating that a safety problem does indeed exist. I have enclosed a copy of the regulation which explains what must be included in a Petition for Rulemaking.; The agency has no authority under the Vehicle Safety Act to regulat used motor vehicles and, therefore, could not require an identification label on a used vehicle that is converted to propane fuel. Congress left this jurisdiction to the individual States. Consequently, Congressional action or action at the State level would be required to mandate identification labels on used vehicles.; I am also enclosing a copy of a letter of interpretation the agenc issued last August which discusses the implications under Federal law of installing auxiliary fuel tanks in motor vehicles and of converting vehicles to the use of propane gas. Although not directly related to the Safety Board's concern, it might be of interest.; I hope this has been responsive to your inquiry. If you have an further questions, please contact Hugh Oates of my staff at 2020-426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1360OpenMr. George H. Jones, Manager, Louisiana Independent Tire Dealers Association, 4500 5th Avenue So. No. 307, Birmingham, AL 35212; Mr. George H. Jones Manager Louisiana Independent Tire Dealers Association 4500 5th Avenue So. No. 307 Birmingham AL 35212; Dear Mr. Jones: This is in reply to your letter of November 14, 1973, to Michael Pesko of our Chief Counsel's Office, asking whether dealers must record the name and address of the tire purchaser on the appropriate form at the same time the tire is sold. You indicate that most dealers record the information on their sales tickets and put it on registration forms at some later time, as the press of business allows.; The Tire Identification and Recordkeeping regulations (49 CFR Part 574 do not require dealers to record the information on the registration form at any specific time. The 'scare stories' to which you refer are not true at all. A recent NHTSA investigation of dealer recording practices was intended only to discover whether dealers were writing down the tire ID number and the purchaser's name, and not whether they were recording the information on particular forms.; The Tire Identification regulation (S 574.8(b)) requires th information to be supplied to the manufacturer (or person maintaining the information) every 30 days, unless less than 40 tires are sold (your letter to us incorrectly stated less than 60 tires), in which case the information must be reported when 40 tires are sold or 6 months elapses, whichever occurs first.; I hope this clarifies the situation. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2019OpenMr. Wade H. Barrineau, III, Compact Van Equipment Co., Inc., 5159 E. Shore Drive, Conyers, GA, 30207; Mr. Wade H. Barrineau III Compact Van Equipment Co. Inc. 5159 E. Shore Drive Conyers GA 30207; Dear Mr. Barrineau: This is in response to your letter of July 17, 1975, inquiring as t the regulations to which you may be subject by manufacturing and selling interior shelving, interior safety bulkheads, and roof mounted ladder carriers for Ford Econoline vans.; The National Highway Traffic Safety Administration has issue regulations covering the alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. (49 CFR SS567.7 and 567.8, copy enclosed). Under these regulations, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than 'readily attachable' components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.; From the description of your products, it appears that no specia expertise or tools are required for their installation. They would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that they are 'readily attachable', and that an alterer label is therefore not required when these products are installed.; The only Safety Standard that might apply to your products is Standar No. 302, *Flammability of Interior Materials* (copy enclosed).; In addition, as items of motor vehicle equipment, your products ar subject to the requirements of the National Motor Vehicle and Traffic Safety Act of 1966, as amended, and must therefore be free from safety-related defects.; If you have any further questions, feel free to write again. Sincerely, Frank A. Berndt, 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.