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: aiam3486OpenMs. Shirley C. Jennings, President, DeJen Products Co., 26 Belridge Road, New Britain, CT 06053; Ms. Shirley C. Jennings President DeJen Products Co. 26 Belridge Road New Britain CT 06053; Dear Ms. Jennings: This responds to your recent letter to Administrator Peck regarding warning device you have developed called 'Call Safe.' This product is a reflective letter 'H' which is designed to be placed inside the rear window or windshield of a motor vehicle to call for help. You ask the agency to advertise the avialability of your device in its newsletter.; Federal Motor Vehicle Safety Standard No. 125 (49 CFR 571.125 establishes requirements for emergency warning devices. The standard requires waring devices to be of a uniform construction. Emergency warning devices, for purposes of this standard, are devices which alert drivers to the presence of a disabled vehicle. We assume your device is designed to signal for help concerning *any* emergency in the vehicle, and not just to warn approaching drivers of a disabled car. For example, 'Call Safe' could be used by a driver who has suddenly become ill and needs help. If this is true, the agency would conclude that Standard No. 125 does not apply to the 'Call Safe' device and you, therefore, would not be prohibited by the standard from offering this device for sale as motor vehicle equipment.; Regarding your request, the National Highway Traffic Safet Administration does not endorse specific products. Please contact this office if you need further assistance.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam0290OpenMr. Howard R. Moore, Jr., Kelly Springfield Tire Company, Cumberland, MD 21502; Mr. Howard R. Moore Jr. Kelly Springfield Tire Company Cumberland MD 21502; Dear Mr. Moore: This is in reply to your letter of February 2, 1971, concerning Par 574 - Tire Identification and Record Keeping regulations and to confirm that the date code may be placed at the end of the tire identification number by means of a screw as depicted in the sketch attached to your letter.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam1396OpenMr. Jim Lang, President, L and R Enterprises, P.O. Box 2201, Wichita Falls, TX 76307; Mr. Jim Lang President L and R Enterprises P.O. Box 2201 Wichita Falls TX 76307; Dear Mr. Lang: Since the questions raised in your letter of February 15, 1974, ar under the jurisdiction of the National Highway Traffic Safety Administration, Department of Transportation, we have taken the liberty of forwarding it to the General Counsel of that agency.; You can expect to hear directly from that office in the near future. Sincerely, Fred J. Emery, Director of the Federal Register |
|
ID: aiam2755OpenMr. Harold A. Bullock, 1402 Redway Lane, Houston, Texas 77062; Mr. Harold A. Bullock 1402 Redway Lane Houston Texas 77062; Dear Mr. Bullock: This responds to your December 29, 1977, letter asking whether Standar No. 124, *Accelerator Control Systems*, applies to a cruise control device that you manufacture.; In Docket 69-20, Notice 3, to which you refer in your letter, th National Highway Traffic Safety Administration stated that Standard No. 124 contains no requirements for cruise controls. Therefore, the standard does not apply to them. There are no other safety standards applicable to these devices.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam2759OpenGeorge L. Spitzmiller, The Reynolds and Reynolds Company, Corporate Offices, Dayton, OH 45401; George L. Spitzmiller The Reynolds and Reynolds Company Corporate Offices Dayton OH 45401; Dear Mr. Spitzmiller: This is in response to your letter of February 3, 1978, requesting tha the National Highway Traffic Safety Administration review your small Odometer Mileage Statement Form ODOM-1030N, your large Odometer Mileage Statement Form ODOM-105-N, and your Retail Buyers Order. It is our opinion that the forms which you submitted meet the Federal odometer requirements which became effective January 1, 1978. Thank you for your cooperation in preparing the forms.; Sincerely, John Womack, Assistant Chief Counsel |
|
ID: aiam2864OpenMr. Alberto Negro, Fiat, Research & Development - U.S.A. Branch, Parklane Towers West Suite 1210, Dearborn, MI 48126; Mr. Alberto Negro Fiat Research & Development - U.S.A. Branch Parklane Towers West Suite 1210 Dearborn MI 48126; Dear Mr. Negro: This responds to your June 16, 1978, letter asking whether manufacturer is permitted to list on the certification label required by Part 567, *Certification*, the gross axle weight rating (GAWR) in kilograms as well as pounds. The National Highway Traffic Safety Administration has permitted the use of kilograms on the certification label as long as the label continues to list the GAWR in pounds also.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam4293OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letter of March 29, 1972, in which you as whether a Certification label 'which is made of some kind of hard material other than paper and affixed on the required place by using only one rivet and by gluing' will meet the requirements of section 567.4(b) of the Certification regulations.; We would consider such a label to be riveted, and consequently to mee the requirements of section 567.4(b).; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2863OpenMr. Alberto Negro, Fiat, Research & Development - U.S.A. Branch, Parklane Towers West Suite 1210, Dearborn, MI 48126; Mr. Alberto Negro Fiat Research & Development - U.S.A. Branch Parklane Towers West Suite 1210 Dearborn MI 48126; Dear Mr. Negro: This responds to your June 16, 1978, letter asking whether manufacturer is permitted to list on the certification label required by Part 567, *Certification*, the gross axle weight rating (GAWR) in kilograms as well as pounds. The National Highway Traffic Safety Administration has permitted the use of kilograms on the certification label as long as the label continues to list the GAWR in pounds also.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam4291OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letter of March 29, 1972, in which you as whether a Certification label 'which is made of some kind of hard material other than paper and affixed on the required place by using only one rivet and by gluing' will meet the requirements of section 567.4(b) of the Certification regulations.; We would consider such a label to be riveted, and consequently to mee the requirements of section 567.4(b).; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0451OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: In your letter of September 8, 1971, you ask whether final-stag manufacturers may use the new vehicle certification label required as of January 1, 1972, before that date.; Your members may use the new label before January 1, 1972. Since th two vehicle weight ratings are not required until that date, there is no legal objection either to leaving the appropriate space blank, or to typing the phrase 'NOT REQUIRED UNTIL 1/1/72' in the space provided.; 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.