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: aiam2754OpenMr. B. Henderson, Legislative Engineer, NVT Motorcycles Limited, Lynn Lane, Shenstone, Lichfield, Staffordshire WS14 OEA, England; Mr. B. Henderson Legislative Engineer NVT Motorcycles Limited Lynn Lane Shenstone Lichfield Staffordshire WS14 OEA England; Dear Mr. Henderson: This is in reply to your letter of December 15, 1977, asking for a interpretation of S5.1 of Federal Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*. You have asked whether a switch on the right handlebar of moped exported by NVT to the United States may be viewed as the 'supplement engine stop control' that the standard requires.; You have noted that the switch is 'identified as required in Table 3 and that the engine can be stopped by the clutch that is part of the starter arrangement. To answer your question it is necessary to make several assumptions as your letter is not complete enough to allow a definitive response. If the normal or recommended method of stopping the vehicle is through the clutch then the switch may serve as the supplemental engine stop control. If, however, turning the switch to off is the normal or recommended method of stopping the vehicle, it cannot be viewed as a supplemental control.; We assume that the switch is identified as 'engine stop' and no 'ignition' since you refer to it as a means of stopping the vehicle and imply that the clutch arrangement is the only method of starting it. If our assumptions are not correct, please inform us of the correct facts so that we may advise you accordingly.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3396OpenMr. O. Vandewege, President, PolyDyne Engineering, Box 3517, Scottsdale, AZ 85257; Mr. O. Vandewege President PolyDyne Engineering Box 3517 Scottsdale AZ 85257; Dear Mr. Vandwege: This responds to your letter of March 6, 1981, to Joseph Zemaitis Motor Vehicle Program Director, Region IX, regarding Safety Standard No. 125, *Warning Devices*. You wish to obtain approval of your warning device (the 'short stop') for use on trucks and trailers. Your device is a collapsible reflective triangle that is designed to be permanently mounted on the side or rear of a vehicle.; The National Traffic and Motor Vehicle Safety Act of 1966, as amende (the Act), authorizes the National Highway Traffic Safety Administration to issue Federal motor vehicle safety standards which are applicable to motor vehicles or motor vehicle equipment. Safety Standard No. 125, *Warning Devices*, establishes requirements for devices that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle. The rule does not apply to warning devices that are designed to be permanently affixed to the vehicle, and thus does not apply to your device. Hence, it is not necessary for you to obtain the 'approval' of this agency before you may manufacture or sell a 'short stop' or before an owner may use such a warning device on his vehicle.; However, the Federal Highway Administration (FHWA) has promulgated regulation (49 CFR S393.95) regarding the use of emergency equipment on heavy duty trucks and buses that are used in interstate commerce. This standard may prohibit the use of warning devices such as the 'short stop' on certain types of vehicles. Since the FHWA can best address this issue, we have forwarded your letter to that agency's Chief Counsel for response. The address of that office is Room 4213, 400 Seventh Street, S.W., Washington, D.C. 20590.; We hope you find this information helfpul. Please contact this offic if you have any questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2902OpenMr. Walter J. Kulpa, Yankee Metal Products Corp., Norwalk, CT 06852; Mr. Walter J. Kulpa Yankee Metal Products Corp. Norwalk CT 06852; Dear Mr. Kulpa:#This is in response to your letter of September 18 1978, requesting a clarification of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The National Highway Traffic Safety Administration concurs in your interpretation of S5.3.1 that any hand operated control which is mounted on the steering column does not have to meet the illumination requirements of Column 4 of Table 1.#Sincerely, Joseph J. Levin, Jr., Chief Counsel; |
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ID: aiam2904OpenMr. Walter J. Kulpa, Yankee Metal Products Corp., Norwalk, CT 06852; Mr. Walter J. Kulpa Yankee Metal Products Corp. Norwalk CT 06852; Dear Mr. Kulpa:#This is in response to your letter of September 18 1978, requesting a clarification of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. The National Highway Traffic Safety Administration concurs in your interpretation of S5.3.1 that any hand operated control which is mounted on the steering column does not have to meet the illumination requirements of Column 4 of Table 1.#Sincerely, Joseph J. Levin, Jr., Chief Counsel; |
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ID: aiam1003OpenMr. R. O. Sornson, Manager, Environmental & Safety Relations, Chrysler Corporation, Detroit, MI 48231; Mr. R. O. Sornson Manager Environmental & Safety Relations Chrysler Corporation Detroit MI 48231; Dear Mr. Sornson: In response to your letter of November 15, 1972, requestin interpretations of the amendments to Standard No. 108 published on October 7, 1972 (37 FR 21328), I enclose an order of the Administrator responsive to your request.; A correction will be published in the near future reinstating th designation 'S5.1' and changing the designation of paragraph S5.3, adopted on January 4, 1973, to 'S5.2'.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0794OpenMr. Melvin Aanerud, Manager, Mille Lacs Reservation Business Enterprise, Star Route, Vineland, MN 56359; Mr. Melvin Aanerud Manager Mille Lacs Reservation Business Enterprise Star Route Vineland MN 56359; Dear Mr. Aanerud: This is in reply to your letter of July 20 to the Department o Transportation concerning your 'pulsating safety brakelite.'; The performance of your device will be considered as a potentia required or optional feature during future amendments to Federal Motor Vehicle Safety Standard No. 108, 'Lamps, Reflective Devices and Associated Equipment.'; Thank you for your interest in highway safety. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0300OpenMr. Y. Nakajima, Manager, Engineering Department, Koito Manufacturing Co., Ltd., 4-8-3 Takanawa, Minato-Ku, Tokyo, Japan; Mr. Y. Nakajima Manager Engineering Department Koito Manufacturing Co. Ltd. 4-8-3 Takanawa Minato-Ku Tokyo Japan; Dear Mr. Nakajima: This is in reply to your letter of February 25, 1971, concerning th photometric requirements for amber turn signal lamps.; You have correctly interpreted the photometric requirements for ambe turn signal lamps as specified in paragraph S4.1.1.7 of Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1972.; Sincerely, Roger H. Compton, Director, Office of Operating Systems Motor Vehicle Programs; |
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ID: aiam0307OpenMr. Colin Calvert, Marketing Manager, FSC Corporation, 6707 Electronics Drive, Springfield, VA 22151; Mr. Colin Calvert Marketing Manager FSC Corporation 6707 Electronics Drive Springfield VA 22151; Dear Mr. Calvert: Please excuse the delay in responding to your letter of January 14 1971. It was inadvertently misplaced. In your letter you requested that I comment whether your system fulfills the requirements of Part 574, the Tire Identification and Record Keeping Regulation.; I am sure you will appreciate the fact that the Administration canno approve each of the various systems developed. Your system, upon a cursory review, appears adequate, however, the regulation speaks for itself concerning the actual requirements.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0341OpenMrs. Barbara G. Rothschild, 2134 Springdale Drive, Columbus, GA 31906; Mrs. Barbara G. Rothschild 2134 Springdale Drive Columbus GA 31906; Dear Mrs. Rothschild: This is in reply to your letter of April 28, 1971, in which you aske whether modifications to a 'forced-action' belt could make it into a system that would satisfy the passive restraint requirements of Standard No. 208. Although we cannot at this time comment on the changes to which you refer, a passive belt system can be used to satisfy the requirement that protection be provided by means that require no action by vehicle occupants.; As you requested, we have enclosed copies of the Standard as publishe March 10, 1971.; Sincerely, Douglas W. Toms, Acting Administrator |
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ID: aiam0435OpenAlex. Feigelson Company, P. O. Box 432, 500 S. Fourth Street, Beaumont, TX 77704; Alex. Feigelson Company P. O. Box 432 500 S. Fourth Street Beaumont TX 77704; Dear Sir: In response to your letter of August 23, 1971, the NHTSA neithe requires nor provides forms by which manufacturers must submit quarterly reports pursuant to S 573.5 of the Defect Reports regulations (49 CFR Part 573). Manufacturers are free to use any form they wish in submitting the required information. However, a suggested format is enclosed for your guidance.; Please note that the effective date of the regulation has been extende to October 1, 1971. A copy of the *Federal Register* notice extending the date is also enclosed.; Sincerely, Lawrence R. Schneider, 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.