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: aiam2187OpenMr. J. A. Hogan, Gibson, Darden and Hotchkiss, 912 City National Building, Wichita Falls, TX 76301; Mr. J. A. Hogan Gibson Darden and Hotchkiss 912 City National Building Wichita Falls TX 76301; Dear Mr. Hogan: As you requested in your letter of December 30, 1975, I am forwardin to you a copy of the odometer disclosure regulation (49 CFR Part 580) promulgated pursuant to section 408 of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513).; The regulation does not require that disclosure documents be retained Thus, any individual who maintains a copy of an odometer disclosure statement, does so of his own accord. There is nothing in the odometer law or regulation that would prevent a person from making disclosure statements available to interested parties. However, neither does the law demand that such documents be made public.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam0995OpenMrs. Arlene I. Lehto, Lehto's National Rubber Stamp and Printing, 901 East 7th Street, Duluth, MN 55805; Mrs. Arlene I. Lehto Lehto's National Rubber Stamp and Printing 901 East 7th Street Duluth MN 55805; Dear Mrs. Lehto:This is in reply to your letter of January 27, 1973 concerning the content of the odometer disclosure statement required by Federal regulations, pursuant to Public Law 92-513.; I am enclosing a copy of the regulation as published January 3, 1973 As you will note, section 580.6 describes the form to be used for disclosure. If disclosure is made on a document that contains the information necessary to identify the transferor and the vehicle, the form can be shortened by omitting the information boxes and the space for the transferor's address. Although we would not object to shortening the text of the statement somewhat, it must contain information specified in 580.4(b) and (c).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1347OpenMr. Peter J. Sferrazza, Staff Counsel, 811 North First Avenue, Wausau, WI 54401; Mr. Peter J. Sferrazza Staff Counsel 811 North First Avenue Wausau WI 54401; Dear Mr. Sferrazza: In response to your request of November 28, 1973, I have enclosed copy of Part 580, *Odometer Disclosure Requirements*, 49 CFR Part 580, which was issued under the authority of the Motor Vehicle Information and Cost Savings Act of 1972, 15 U.S.C. S 1988.; The transferor must disclose the mileage as it is recorded on th odometer, and in addition that he knows that reading to be inaccurate if such is the case. This means that a transferor would check the box indicating that the reading does not reflect the mileage, if he knew that the vehicle had traveled more than 100,000 miles. The buyer would then be on notice to ask why the reading was not accurate and to be told that the vehicle had more than 100,000 miles on it.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3501OpenMr. Robert A. McDevitt, Avis Car Leasing, P.O. Box 117, Carle Place, NY 11514; Mr. Robert A. McDevitt Avis Car Leasing P.O. Box 117 Carle Place NY 11514; Dear Mr. McDevitt: This is in response to your letter of November 17, 1981, asking whethe the federal odometer disclosure forms may be put onto microfilm and the original hard copy destroyed. You indicated that if hard copy was later needed, it could be reproduced from the microfilm.; Section 580.7 of Title 49 of the Code of Federal Regulations has th following provision:; >>>The statement may be reproduced (e.g., photocopies or put o microfilm) as long as no information or identifying marks such as signatures are lost in the reproduction.<<<; The purpose of this provision is to allow dealers and distributors t conserve storage space by condensing the retained documents. The original documents could then be destroyed, provided the copies contained the same information as the originals.; If you have any further questions, please do not hesitate to write. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2439OpenMr. Pao-Yeh Hu, Manager, TYM Industries Co., Ltd., No. 2-26, Yeng Hang, Yongkang, Tainan-Hsian, Taiwan; Mr. Pao-Yeh Hu Manager TYM Industries Co. Ltd. No. 2-26 Yeng Hang Yongkang Tainan-Hsian Taiwan; Dear Mr. He: This is in reply to your letter of September 27, 1976, to the Nationa Highway Traffic Safety Administration, concerning lighting requirements for mopeds.; The headlamp must be designed to conform to SAE Standard J584 'Motorcycle and Motor Driven Cycle Headlamps,' April 1964. This Standard does not require a sealed beam headlamp, nor is a minimum wattage specified. Obtaining an AAMVA certificate is probably the best way of insuring that a State raises no obstacles to registry of your vehicle.; There is no minimum wattage for the taillamp or stop lamp. These tw lamps may be combined. There is no Federal requirement for SAE identification, however, most lamps are so identified, because of the requirements in the state of Virginia.; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam1264OpenMr. J.C. Barford, President, JCB Plastics, Ltd., 655 Garrison Road, Fort Erie, Ontario; Mr. J.C. Barford President JCB Plastics Ltd. 655 Garrison Road Fort Erie Ontario; Dear Mr. Barford: This is in reply to your letter of August 22, 1973, asking whether th American National Standards Institute (ANSI) Standard Z90.1-1971 will apply to the manufacture of helmets until the March 1, 1974 effective date of Standard No. 218, 'Motorcycle Helmets.'; The Z90.1-1971 Standard is not a Federal Motor Vehicle Safety Standar and, therefore, could only apply to helmets manufactured or sold in those States that have adopted it, and then only until the effective date of the Federal standard. For information regarding Ontario's requirements for the manufacture of helmets, I suggest you contact the Ontario Bureau of Motor Vehicles. As you indicate, any U.S. State or local requirements for the design or performance of motorcycle helmets, that have a bearing on safety, will have to be identical to the requirements of the Federal standard when it becomes effective.; I have enclosed a copy of Standard No. 218 pursuant to your request. Yours Truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1267OpenMr. J.C. Barford, President, JCB Plastics, Ltd., 655 Garrison Road, Fort Erie, Ontario; Mr. J.C. Barford President JCB Plastics Ltd. 655 Garrison Road Fort Erie Ontario; Dear Mr. Barford: This is in reply to your letter of August 22, 1973, asking whether th American National Standards Institute (ANSI) Standard Z90.1-1971 will apply to the manufacture of helmets until the March 1, 1974 effective date of Standard No. 218, 'Motorcycle Helmets.'; The Z90.1-1971 Standard is not a Federal Motor Vehicle Safety Standar and, therefore, could only apply to helmets manufactured or sold in those States that have adopted it, and then only until the effective date of the Federal standard. For information regarding Ontario's requirements for the manufacture of helmets, I suggest you contact the Ontario Bureau of Motor Vehicles. As you indicate, any U.S. State or local requirements for the design or performance of motorcycle helmets, that have a bearing on safety, will have to be identical to the requirements of the Federal standard when it becomes effective.; I have enclosed a copy of Standard No. 218 pursuant to your request. Yours Truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5107OpenMr. Curtis J. Crist Product Development US Marine P.O. Box 9029 Everett, WA 98206; Mr. Curtis J. Crist Product Development US Marine P.O. Box 9029 Everett WA 98206; Dear Mr. Crist: This responds to your letter of December 10, 1992, i which you ask for confirmation that the provisions of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108 relating to front side marker lamps for boat trailers remain unchanged from interpretations provided by this Office in 1976 and 1977. I am pleased to confirm that these requirements remain the same. Paragraph S4.3.1.3, however, was renumbered S5.3.1.3 several years ago. You have also asked as to what action you must take for elimination of the requirement for rear identification lamps on boat trailers 80 or more inches in overall width. You may file a petition for rulemaking requesting this change. I enclose a copy of 49 CFR Part 552, the regulation governing these petitions, which will advise you as to these procedures. Section 552.4 sets forth the information that the petition should contain, and the address to which it must be sent. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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ID: aiam5029OpenMr. Mark W. Russo 1480 West Macopin Road West Milford, NJ 07480; Mr. Mark W. Russo 1480 West Macopin Road West Milford NJ 07480; Dear Mr. Russo: This responds to your letter of May 27, 1992, to Mr Charles Gauthier of this agency, which enclosed a copy of R-Bar test data provided by Micho Industries. You requested an 'official `review and comment'' regarding the applicability of Safety Standard 222 to the R-Bar Passenger Restraint System and related issues. The National Highway Traffic Safety Administration (NHTSA) has addressed the use of 'safety bars' in school buses on several occasions in the past. Enclosed for your information are copies of five NHTSA letters which address this subject and which, we believe, will also address your concerns. The letters are addressed to Mr. Michael F. Hecker of Micho Industries, dated May 14, 1992, Mr. Scott K. Hiler of the C. E. White Company, dated January 31, 1991, Honorable Robert J. Lagomarsino, Member of Congress, dated January 8, 1990, and Mr. Joseph F. Mikoll of Transportation Equipment Corporation, dated March 10, 1989 and November 3, 1988. If, after reviewing the enclosed materials, you still have questions concerning this matter, please feel free to contact Mr. Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures; |
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ID: aiam0569OpenMr. K. Nakajima, Director/General Manager, Toyota Motor Company, Ltd., Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Toyota Motor Company Ltd. Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This letter is in response to your inquiry of January 6, 1972 regarding the relationship of Standards No. 208 and No. 216.; You interpret Standard 216, paragraph *S3. Application*, which state that the Standard does not apply to passenger cars 'that conform to the rollover test requirements (S5.3) of Standard 208 by means that require no action by vehicle occupants,' as follows:; >>>1. From August 15, 1973, the effective date of Standard 216, t August 15, 1977, passenger cars are not required to meet Standard 216 if they conform to the 'first option' of Standard 208.; 2. For the period of August 15, 1973, through August 14, 1975 passenger cars which are designed to conform to the 'second' or proposed 'third' option of Standard 208 are not required to meet Standard 216 if they meet the rollover requirements (S5.3) by passive means (when tested under the applicable conditions of S8), even though in Standard 208 the rollover requirement is specified only for 'option 1.'<<<; These interpretations are correct. Please write if we can be of furthe assistance.; Sincerely yours, Richard B. Dyson, Assistant 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.