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: aiam3121OpenMr. Jeff Jacobovitz, Federal Trade Commission/PC, 6th & Pennsylvania Avenue, N.W., Washington, DC 20580; Mr. Jeff Jacobovitz Federal Trade Commission/PC 6th & Pennsylvania Avenue N.W. Washington DC 20580; Dear Mr. Jacobovitz: This is in response to your letter of September 11, 1979, askin whether the National Highway Traffic Safety Administration (NHTSA) has adopted the Rubber Manufacturers Association (RMA) definition of mud and snow tire or has made any official statement regarding the validity of that definition. NHTSA has not adopted the RMA definition for use in any agency regulations, relating either to safety standards or to tire quality grading, nor has NHTSA made any official statement regarding the validity of the definition. If I can be of further assistance, do not hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1887OpenMr. R. Wieman, Ohio Hydraulics, 2510 E Sharon Road,Cincinnati, Ohio 45241; Mr. R. Wieman Ohio Hydraulics 2510 E Sharon Road Cincinnati Ohio 45241; Dear Mr. Wieman: #This responds to your letter of March 7, 1975, to Mr Francis Armstrong of this agency, concerning possible changes if Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #On March 4, 1975, the NHTSA proposed a change in the definition of 'brake hose assembly' which would exclude from the standard's requirements certain assemblies made for repair of used vehicles (40 F.R. 8962, copy enclosed.) As proposed, the change would not exclude assemblies made by hose distributors. Several of the comments responding to the proposal have suggested that such distributor-made assemblies also be excluded, #When a final decision is made on this issue, it will be published in the Federal Register. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam0746OpenMr. Kenneth Koehler, Harold Schlintz & Associates, 3752 E. Belmont Avenue, Fresno, CA 93702; Mr. Kenneth Koehler Harold Schlintz & Associates 3752 E. Belmont Avenue Fresno CA 93702; Dear Mr. Koehler: This is in reply to your letter of June 8, 1972, to Robert L. Carter as to whether Federal Motor Vehicle Safety Standard No. 206 is applicable to a White 'Freightliner' which was manufactured on or about December 1, 1970.; The White Freightliner, as illustrated in the picture you enclosed, i a truck tractor, and is classified as a 'truck' under the motor vehicle safety standards. Standard No. 206 became applicable to trucks on January 1, 1972, and would not therefore apply to this truck. No other standards are applicable to the doors or door latches of this vehicle.; The standards do not apply to a vehicle after its first sale to consumer (a used vehicle), and no exemption from the standards is necessary.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0085OpenMr. Ferris M. Smith, Jr., President, Horseless Carriage Corp., 1227 N.E. 9th Avenue, Fort Lauderdale, FL 33304; Mr. Ferris M. Smith Jr. President Horseless Carriage Corp. 1227 N.E. 9th Avenue Fort Lauderdale FL 33304; Dear Mr. Smith: This is in response to your letter of June 11, 1968, concerning th applicability of Federal motor vehicle safety standards to motor vehicles which have a curb weight of 1000 pounds or less.; Your reference to section 255.7 of the Federal motor vehicle safet standards and the present applicability of the standards to motor vehicles 1000 pounds or less curb weight is correct. However, we are enclosing a copy of Advance Notice of Proposed Rule Making, Docket No. 5-1, which was published in the *Federal Register* on October 14, 1967. As you can see from the Advance Notice of Proposed Rule Making, the Administrator is considering adding new standards applicable to motor vehicles of 1000 pounds or less curb weight.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam2251OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to Blue Bird Body Company's March 15, 1976, request fo confirmation that calculation of the material tensile strength of body panels under S6.2(a) of Standard No. 221, *School Bus Body Joint Strength*, is based on the minimum thickness permitted by American Society for Testing and Materials (ASTM) Standard 525 for the thickness specified in ordering the material. This response also reflects the April 1, 1976, meeting held between Blue Bird representatives and National Highway Traffic Safety Administration (NHTSA) personnel at Department of Transportation headquarters.; Under ASTM standards, the thickness of listed materials is permitted t vary from the specified or 'nominal' thickness by a small amount. If the thickness tolerance of a material is specified by the ASTM, the NHTSA bases its determination of thickness on the 'minimum thickness' specified for that material in the 1973 edition of the Annual Book of ASTM Standards. If the thickness tolerance of a material is not specified by the ASTM, the NHTSA uses the minimum thickness permitted by the school bus manufacturer's material specification.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: nht74-4.1OpenDATE: 06/07/74 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Breeze Corporations Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of May 8, 1974, asking whether persons installing on a new vehicle a device called the Breeze Jacknife Control are required to certify the conformity of the vehicle to applicable motor vehicle safety standards. You indicate such a device would ordinarily be installed after the truck leaves the factory. Persons who install components on or otherwise modify completed vehicles before their sale to a purchaser for a purpose other than resale may be vehicle alterers under NHTSA Certification regulations (49 CFR Parts 567, 568), and if so are required to certify that the vehicle as altered conforms to applicable standards by attaching to it a label containing specified information. A label must be attached when the alteration either involves components which are not readily attachable or whose installation renders invalid the vehicle's stated weight ratings. Modifications to a completed vehicle after its purchase for purposes other than resale, however, do not give rise to any certification or labeling requirements. Copies of the Certification regulations and information on obtaining copies of all NHTSA requirements are enclosed. |
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ID: nht87-2.20OpenTYPE: INTERPRETATION-NHTSA DATE: 06/22/87 FROM: ROSE M. TALISMAN -- JOAN AUTOMOTIVE INDUSTRIES TESTING LAB TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION, INC. TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A 32, STANDARD 302; LETTER DATED 06/08/87 FROM ROSE TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG COLE TO STEVE KRANTZKE; LETTER DATED 06/29/87 FROM JONATHAN JA CKSON TO DOUG COLE TEXT: Dear Doug: As I stated earlier correspondence Joan Automotive Industries conducts its flammability testing according to Federal Motor Vehicle Safety Standard No. 302. This includes the use of heat resistant support wires as indicated in paragraph S5.1.3, "A specime n that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals." It is our belief that this method satisfies the requirements of FMVSS 302 testing and is the standard industry procedure for testing automotive bodycloth. Please keep us informed as to what the Department of Transportation's response is to your inquiry. |
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ID: nht91-7.45OpenDATE: December 11, 1991 FROM: Frank J. Sonzala-- Senior Vice President, International Transquip Industries, Inc. TO: Steve Wood -- Chief Council Office, NHTSA COPYEE: D. Carter; J. Frank Haasbeek TITLE: Deceptive Labeling of Spring Brakes ATTACHMT: Attached to letter dated 2/3/92 from Paul Jackson Rice to Frank Sonzala (A39; Std. 121; Std. 106; VSA S 108) TEXT: Mr. Richard Carter of NHTSA told me that I should bring this following information to your attention. It seems that spring brake manufacturers such as Lear Sigler who manufacture the Anchorlok brand spring brake have adopted a practice to add the letters D.O.T. to their chamber housing. Now, this is interpreted by the industry to connote that this type of chamber is D.O.T. approved. We feel that this is misleading and certainly not endorsed by the United States Department of Transportation. I do not know what can be done about this situation but our customers of the I.T.I. Air Brake Chamber, the Air-Mech are asking us to get D.O.T. on our chambers. Of course, we do not intend to participate in deceptive practices. However, we request that your department send my company a letter explaining how D.0.T. should not be on any chamber and if it is, it should not be interpreted as being approved by D.O.T. or NHTSA. If you have any questions or comments please give me a call. I have included a rendering of the "Raised D.0.T" inscription on the Anchorlok spring brake chamber casting. |
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ID: nht94-9.7OpenTYPE: Interpretation-NHTSA DATE: January 10, 1994 FROM: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc. TO: Walter Myers -- Office of Chief Counsel, NHTSA TITLE: Table II Minimum Static; Breaking Energy (inch pounds) D.O.T. 119 ATTACHMT: Attached to letter dated 4/12/94 from John Womack to Adam A. Freund (A42; Std. 119) TEXT: Further to our telephone conversation of this date, please find enclosed a copy of subject matter for your perusal. As we had discussed I believe there is a typo in the highlighted columns marked respectively MOTORCYCLE and ALL 12 INCH OR SMALLER RIM SIZE. If I am correct the first column MOTORCYCLE should show a plunger diameter of 5/16" and the column marked ALL 12 INCH OR SMALLER RIM SIZE should show a plunger diameter of 3/4". I would appreciate your qualifying my interpretation of above subject matter. If my interpretation is incorrect, please advise me how the respective columns should be marked. Standards Testing Laboratories, Inc. would greatly appreciate any expedited consideration you may allow us on this request.
ATTACHMENT (Table omitted.) |
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ID: nht94-1.16OpenTYPE: Interpretation-NHTSA DATE: January 10, 1994 FROM: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc. TO: Walter Myers -- Office of Chief Counsel, NHTSA TITLE: Table II Minimum Static; Breaking Energy (inch pounds) D.O.T. 119 ATTACHMT: Attached to letter dated 4/12/94 from John Womack to Adam A. Freund (A42; Std. 119) TEXT: Further to our telephone conversation of this date, please find enclosed a copy of subject matter for your perusal. As we had discussed I believe there is a typo in the highlighted columns marked respectively MOTORCYCLE and ALL 12 INCH OR SMALLER RIM SI ZE. If I am correct the first column MOTORCYCLE should show a plunger diameter of 5/16" and the column marked ALL 12 INCH OR SMALLER RIM SIZE should show a plunger diameter of 3/4". I would appreciate your qualifying my interpretation of above subject matter. If my interpretation is incorrect, please advise me how the respective columns should be marked. Standards Testing Laboratories, Inc. would greatly appreciate any expedited consideration you may allow us on this request. ATTACHMENT (Table omitted.) |
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.