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: aiam0568OpenMr. 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 |
|
ID: aiam1337OpenMr. Mel Aanerud, Manager, Reservation Business Enterprise, Star Route, Box 116, Vineland, MN 56359; Mr. Mel Aanerud Manager Reservation Business Enterprise Star Route Box 116 Vineland MN 56359; Dear Mr. Aanerud: This is in reply to your letter of November 16 concerning a definitio of 'steady burning' lamps.; Our definition of 'steady' is 'regular, uniform, not changed, replace or interrupted, not fluctuating or varying widely.' Stop lamps activated by the Pulsating Safety Brakelite would therefore not be 'steady burning.'; Thank you for your interest in highway safety. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
|
ID: aiam1922OpenMr. Jim Koester, Dairy Equipment Co., P.O. Box 1289, Madison, WI 53701; Mr. Jim Koester Dairy Equipment Co. P.O. Box 1289 Madison WI 53701; Dear Mr. Koester: This responds to Dairy Equipment's April 3, 1975 request for discussion of what constitutes the manufacture of a trailer in cases where used components from an existing vehicle are involved.; In response to a similar request from the Truck Trailer Manufacturer Association, the National Highway Traffic Safety Administration recently prepared a comprehensive discussion of this subject, a copy of which is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1023OpenMr. A. J. Kuzel, General Manager, Jim Whalen Ford, Ind., 1045 East Chicago Street, Elgin, IL 60120; Mr. A. J. Kuzel General Manager Jim Whalen Ford Ind. 1045 East Chicago Street Elgin IL 60120; Dear Mr. Kuzel: This is in response to your letter of February 20, 1973, concerning th use of the dealer plate number on the form required by the Federal Odometer Disclosure Requirements.; Under the Illinois procedure you describe, where the seller retains hi tags and the dealer attaches dealer tags, the number of the dealer tag may be used in the space marked as 'Last Plate Number.'; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1368OpenMr. David C. Keehn, Attorney, Division of Marketing Practices, Bureau of Consumer Protection, Federal Trade Commission, Washington, DC 20580; Mr. David C. Keehn Attorney Division of Marketing Practices Bureau of Consumer Protection Federal Trade Commission Washington DC 20580; Dear Mr. Keehn: Thank you for bringing the Ryder Rental odometer problem to ou attention.; The odometer provisions of the Motor Vehicle Information and Cos Savings Act apply only to tampering that leads to the under-representation of mileage. We recommend that over-representation cases be referred to the State consumer protection office. In this case, of course, Mr. Sharkey registered his complaint there in the first instance.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1635OpenMr. W. M. Griffith, Secretary, Canadian Truck Trailer Manufacturers Association, P.O. Box 294, Kleinburg, Ontario, Canada; Mr. W. M. Griffith Secretary Canadian Truck Trailer Manufacturers Association P.O. Box 294 Kleinburg Ontario Canada; Dear Mr. Griffith: This responds to your October 11, 1974, request for an interpretatio of the application of Standard No. 121, *Air brake systems*, to Canadian-made truck trailers manufactured in Canada following the effective date of the standard and subsequently used in inter-country commerce.; I have enclosed a copy of a letter on this subject to th representative of another Canadian manufacturer, which should answer your question. Please write again if you have further questions.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
|
ID: aiam2289OpenMr. Robert M. Brodkey, President, Intercraft Corporation, P.O. Box 4854, Washington, D.C. 20008; Mr. Robert M. Brodkey President Intercraft Corporation P.O. Box 4854 Washington D.C. 20008; Dear Mr. Brodkey: This is in response to your March 29, 1976, letter concernin regulations applicable to farm tractor tires whose importation is contemplated by one of your clients.; Farm tractors are not 'motor vehicles' as that term is defined in th National traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et Seq.). Accordingly, tires designed exclusively for use on farm tractors are not 'motor vehicle equipment.' Therefore, the importation of such tires and tubes is not subject to Federal motor vehicle safety standards or other regulations issued by the National Highway Traffic Safety Administration. We are unaware of any other regulations of the Department of Transportation concerning such tires.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
|
ID: aiam1886OpenMr. J.E. Kuykendall, Director - Parts Sales, Cummins Sales & Service Inc., 600 Watson Road, P.O. Box 1008, Arlington, Texas 76010; Mr. J.E. Kuykendall Director - Parts Sales Cummins Sales & Service Inc. 600 Watson Road P.O. Box 1008 Arlington Texas 76010; Dear Mr. Kuykendall: #This responds to your letter of March 25, 1975 to Mr. Francis Armstrong of this agency, concerning the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses, as applied to brake hose assemblies. #The labeling requirements for brake hose assemblies became effective on March 1, 1975. On March 4, the NHTSA proposed a change in the definition of 'brake hose assembly' which would exclude certain assemblies from the requirements of the standard (40 F.R. 8962, copy enclosed.) Notice of a final decision on this proposal will be published in the Federal Register. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
|
ID: aiam3691OpenMr. Chuck Howard, President, Safety Alert Company, Inc., 1667 Ninth Street, Santa Monica, CA 90404, 213-452-2728; Mr. Chuck Howard President Safety Alert Company Inc. 1667 Ninth Street Santa Monica CA 90404 213-452-2728; Dear Mr. Howard: Thank you for your letter of May 6, 1983. You note that your Safet Alert device will blink the hazard warning lights four times in five seconds when the accelerator pedal is lifted when the car is moving at 30 mph or more.; We are glad to advise you that this device is not in violation o Federal Motor Vehicle Safety Standard Number 108, Lamps, Reflective Devices, and Associated Equipment - Passenger Cars, Multipurpose Vehicles, Trucks, Trailers, Buses and Motorcycles. For vehicles which predate having the hazard warning control, your device may blink the turn signals on both sides simultaneously.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam2177OpenMr. J. E. Paquette, Director, Burlington Management Service Co., Greensboro, NC 27420; Mr. J. E. Paquette Director Burlington Management Service Co. Greensboro NC 27420; Dear Mr. Paquette: This responds to Burlington Fleet Service's December 9, 1975, questio whether the combination of usable parts from several existing vehicles into one functioning vehicle constitutes the manufacture of a new vehicle subject to applicable motor vehicle safety standards such as Standard No. 121, *Air Brake Systems*.; The answer to your question is no. For an assembly operation t constitute manufacture, there must be a substantial proportion of new or fundamentally rebuilt parts. In this case, no new parts, other than minor materials such as hoses and gaskets, are involved in the assembly. The NHTSA therefore, does not consider the operation to constitute manufacturing subject to the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381 et seq.); Yours truly, 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.