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: aiam0730OpenMr. Irving Frank, Frank and Frank, Counselors at Law, 11 Park Place, New York, New York 10007; Mr. Irving Frank Frank and Frank Counselors at Law 11 Park Place New York New York 10007; Dear Mr. Frank: Thank you for your most recent inquiry regarding hood latch systems dated May 26, 1972.; Examination of the 1964 Chevrolet hood latch system reveals that thi system does meet the requirements of Federal Motor Vehicle Safety Standard No. 113, which was effective on January 1, 1969. While, as stated in our correspondence of February 16, 1972, we favor a system in which two complete operations are necessary, a system which employs two latches having a single operation will meet the requirements of the standard. A current review of our Office of Defects Investigation files reveals that no information relative to 1964 Chevrolet hood latching system has been added since our last communication.; Thank you for your inquiry. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2740OpenMr. K. A. Dirkzwager, Driver and Vehicle Services Director, Minnesota Department of Public Safety, Transportation Building, St. Paul, MN 55155; Mr. K. A. Dirkzwager Driver and Vehicle Services Director Minnesota Department of Public Safety Transportation Building St. Paul MN 55155; Dear Mr. Dirkzwager: This is in response to your letter of November 15, 1977, requesting a exemption from the Federal odometer disclosure regulations which will become effective as of January 1, 1978.; We appreciate the efforts of Minnesota to include odometer informatio on its certificates of title. However, we are not granting any exemptions for States which have not previously had odometer information on their titles. Since the citizens of your State have had to execute separate odometer disclosure statements in the past they will not be placed under any additional burden by this ruling. They will merely continue past practices until such time as Minnesota incorporates the revised odometer format on their titles.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam1371OpenMr. Donald T. Fischer, Project Director, Coupling Section, Industrial Division, Aeroquip Corporation, 1225 West Main Street, Van Wert, OH 45891; Mr. Donald T. Fischer Project Director Coupling Section Industrial Division Aeroquip Corporation 1225 West Main Street Van Wert OH 45891; Dear Mr. Fischer: This responds to your request of January 8, 1974, made to Mr. Herlih of this office for an interpretation of S5.1.2.3 of Standard No. 121, *Air brake systems*, as it applies to a check valve which is designed to bleed back no more than 5 psi pressure from the service reservoir toward the source of air pressure.; The check valve described in the specification you enclosed woul satisfy the requirements of S5.1.2.3 as long as there is no air loss in excess of the designed bleed off, and that total air loss never lowers the pressure at any time below the air compressor 'cut in' pressure.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3274OpenMr. Thomas D. Turner, Supervisor, Engineering Services Department, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. Thomas D. Turner Supervisor Engineering Services Department Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Turner: This is in reply to your letter of April 14, 1980, asking for confirmation of your interpretation of Section S4.1.4 of Motor Vehicle Safety Standard No. 108.; This section specifies requirements affecting school bus signal lamp 'when the bus entrance door is opened.' Blue Bird is designing an additional entrance door for its buses and you interpret S4.1.4 as requiring the same operational characteristics for the new door.; We confirm your interpretation that 'entrance door' means any entranc door on the school bus. Obviously the purpose of the requirement is not achieved if it is restricted to the traditional entrance door on the right front side of the bus and excludes any other entrance door.; Thank you for your interest in safety. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4421OpenLawrence C. Bourbeau, Jr., Esq., Assistant General Counsel, Fruehauf Corporation, Law Department, 10900 Harper Avenue, P.O. Box 238, Detroit, MI 48232; Lawrence C. Bourbeau Jr. Esq. Assistant General Counsel Fruehauf Corporation Law Department 10900 Harper Avenue P.O. Box 238 Detroit MI 48232; Dear Mr. Bourbeau: This letter responds to your earlier inquiry where you ask whethe NHTSA would object to your Company's changing 'its model year designation from September 1 to July 1.' I apologize for the delay in responding.; Standard 115, *Vehicle Identification Number-Basic Requirements* directs vehicle manufacturers to place a discrete identifying number (VIN) on each vehicle. Title 49 CFR Part 565, *VIN-Content Requirements*, states that a VIN must include a character indicating the manufacturer's designated model year. Neither Standard 115 nor Part 565 prohibits your company from changing the model year in the manner you suggest. Therefore, such a change does not violate our regulations.; We note that this change apparently concerns model year as a marketin concept. The Federal Trade Commission has published guidelines concerning model year as a commercial concept, and you may wish to contact the Commission for whatever assistance it may provide. I hope you find this information helpful.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4422OpenLawrence C. Bourbeau, Jr., Esq. Assistant General Counsel Fruehauf Corporation, Law Department 10900 Harper Avenue P.O. Box 238 Detroit, MI 48232; Lawrence C. Bourbeau Jr. Esq. Assistant General Counsel Fruehauf Corporation Law Department 10900 Harper Avenue P.O. Box 238 Detroit MI 48232; Dear Mr. Bourbeau: This letter responds to your earlier inquiry wher you ask whether NHTSA would object to your Company's changing 'its model year designation from September 1 to July 1.' I apoligize for the delay in responding. Standard 115, Vehicle Identification Number- Basic Requirements, directs vehicle manufacturers to place a discrete identifying number (VIN) on each vehicle. Title 49 CFR Part 565, VIN- Content Requirements, states that a VIN must include a character indicating the manufacturer's designated model year. Neither Standard 115 nor Part 565 prohibits your company from changing the model year in the manner you suggest. Therefore, such a change does not violate our regulations. We note that this change apparently concerns model year as a marketing concept. The Federal Trade Commission has published guidelines concerning model year as a commercial concept, and you may wish to contact the Commission for whatever assistance it may provide. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam2134OpenMr. Ralph Blake, 3319 W. Osborn Road, Suite A, Phoenix, AZ 85015; Mr. Ralph Blake 3319 W. Osborn Road Suite A Phoenix AZ 85015; Dear Mr. Blake: As you requested in your December 1, 1975, telephone conversation wit Karen Kreshover of this office, I am answering by letter your question as to whether motor vehicle dealers must retain copies of Federal odometer disclosure statements which they either receive or execute.; Section 408(a) of the Motor Vehicle Information and Cost Savings Ac (15 U.S.C. 1988(a)) gives the Secretary of Transportation authority to promulgate rules relating to the execution of statements disclosing odometer mileage on vehicles at the time of their sale. Such rules may, according to the Act, contain requirements prescribing the manner in which the necessary information is disclosed or retained.; Pursuant to the mandate of section 408, the National Highway Traffi Safety Administration promulgated 49 CFR Part 580, *Odometer Disclosure Requirements*. This regulation does not, however, require individuals to retain either copies or originals of odometer disclosure statements that come into their possession. This means that a dealer need not retain statements that are provided to him when he purchases a vehicle, nor must he retain copies of statements executed by him to purchasers of vehicles he sells.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1047OpenMr. Norman E. Salzman, General Manager, The Fairmount Press, P.O. Box 3, Bronx, NY 10453; Mr. Norman E. Salzman General Manager The Fairmount Press P.O. Box 3 Bronx NY 10453; Dear Mr. Salzman: This will serve to confirm the opinion you received by phone on Marc 16, 1973, concerning the content of the disclosure statement required by 49 CFR Part 580, Odometer Disclosure Requirements.; You had previously asked, by letter dated February 28, 1973, whether State odometer disclosure form, such as that required by New York, could be used to satisfy the Federal requirement. Our reply was that it could be used, and you have now asked what information must be added to satisfy the Federal requirements.; As we indicated by phone, the item that must be added to the New Yor form is the reference to the Federal remedy required by section 580.4. This reference consists of two elements: a citation to the Federal law, and a statement that failure to provide accurate information may result in civil liability. Each of these elements is contained in the parenthetical statement that introduces section 580.6, and you may therefore use the section 580.6 statement to conform the New York forms to Federal practice.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2547OpenMr. Dennis J. Mahr, Attorney at Law, 232 Davidson Building, Sioux City, IA 51101; Mr. Dennis J. Mahr Attorney at Law 232 Davidson Building Sioux City IA 51101; Dear Mr. Mahr: This responds to your February 23, 1977, letter asking whether For Motor Company's record keeping practices conform to the regulations of the National Highway Traffic Safety Administration (NHTSA).; Your letter refers to material allegedly destroyed by Ford pertainin to accident and recall information involving headlamp concealment devices in 1967 Mercury Cougars. The NHTSA is unable to ascertain from the information that you have submitted whether or not Ford's record keeping violates our requirements.; The NHTSA implemented on August 20, 1974, a regulation requirin manufacturers to retain for a period of 5 years records generated or acquired after August 15, 1969, concerning motor vehicle malfunctions that may be related to motor vehicle safety (49 CFR 576, *Record Retention*). Since the recall to which you refer occurred prior to this regulation, it is possible that the identified records were generated or acquired prior to the promulgation of the regulation, and therefore, the destruction of these records would not necessarily mean that Part 576 was violated.; The NHTSA has a public file concerning the headlamp concealment device referred to in your letter. This file containing 26 pages of information will be sent to you by our Technical Reference Branch under separate cover.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4224OpenMr. Tom McRedmond, Motor Vehicle Division, 500 Deaderick Street, Nashville, TN 37242; Mr. Tom McRedmond Motor Vehicle Division 500 Deaderick Street Nashville TN 37242; Dear Mr. McRedmond: The National Highway Traffic Safety Administration has been informe that you have been advising dealers that the Tennessee Certificate of Title may be used in lieu of a separate odometer disclosure statement. We have reviewed the title and have determined that it fails to meet the requirements of the Federal odometer disclosure regulation, 49 C.F.R. Part 580.; The Tennessee title cannot be used in lieu of a separate odomete disclosure statement. Although the National Highway Traffic Safety Administration allows the use of the abbreviated disclosure statements as they appear on the title, the title fails to meet the regulatory requirements because it does not 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.; Dealers who do not issue and/or retain a copy of a separate odomete disclosure statement may be liable for civil and criminal penalties. If you have any questions do not hesitate to call Judith Kaleta of my staff at (202) 366-1834.; 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.