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: nht94-3.72OpenTYPE: INTERPRETATION-NHTSA DATE: July 15, 1994 FROM: Thomas L. Wright, Coordinator, Technical Support, State of New Jersey, Dept. of Law and Public Safety TO: Robert Hellmuth -- Office of Vehicle Safety Compliance, NHTSA TITLE: None ATTACHMT: ATTACHED TO LETTER DATED 10/27/94 FROM PHILIP R. RECHT TO THOMAS L. WRIGHT (A42; STD. 108; REDBOOK 2) TEXT: The New Jersey Division of Motor Vehicles performs a periodic safety inspection on all gasoline powered vehicles. Part of this inspection includes a check of the headlights. I am writing to request an opinion on the application of brush guards installe d forward of headlight units on Range Rover all-terrain vehicle models. The units are depicted installed in new car brochures supplied by the Range Rover dealerships. I would appreciate a determination as to whether this device placed across the headlight face is a violation of Part 108. Please respond to me by writing to New Jersey Division of Motor Vehicles, CN 177, Trenton, New Jersey 08666. Thank you for your attention to this matter. |
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ID: nht67-1.16OpenDATE: 06/19/67 FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA TO: S.I.C.A. Peugeot TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of April 20, 1967, concerning the clarification of several requirements of Motor Vehicle Safety Standard No. 105. The bulb for the emergency brake system effectiveness indicator may also be used for the hand brake indicator light. Further, the means for establishing the electrical contact for testing the emergency system indicator bulb may be the hand brake lever. This clarification is not considered as a change in the requirements of the standard as issued. All characteristics required for the indicator light must be met. |
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ID: nht94-3.56OpenTYPE: Interpretation-NHTSA DATE: July 5, 1994 FROM: Sally O'Cordan -- Legal Assistant, Ashley, Hannula & Halom TO: Office of Chief Council, NHTSA TITLE: Travel Trailer Standards ATTACHMT: Attached to letter dated 8/26/94 from John Womack to Sally O'Cordan (A42; Std. 205) TEXT: We are investigating an accident where an individual was severely injured by the glass of a travel trailer. Does your office have any federal motor vehicle safety standards regarding the type of glass used in travel trailer windows? If not, do you know of any place where these might be regulated? Any information you can provide to us will be appreciated. If you have any questions, please feel free to call me at 1-800-477-7056. |
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ID: nht93-4.26OpenDATE: June 7, 1993 FROM: K. Aubrey Hottell -- Smith and Robson, Inc. TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 7/21/93 from John Womack to K. Aubrey Hottell (A41; Std. 208) and letter dated 1/19/90 from Stephen P. Wood to Linda L. Conrad (Std. 208) TEXT: This letter is to request a Letter of Interpretation regarding air bag replacement, air bag indicator light functioning, and any requirements or recommendations for indicator lights to be functional upon resale of a vehicle. As I understand, once an air bag is discharged, an indicator light will illuminate to show that the bag needs replacement. Please send this to me at the address above. Thank you, in advance, for your assistance. |
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ID: nht90-2.80OpenTYPE: Interpretation-NHTSA DATE: June 11, 1990 FROM: Terry Rowe -- President, Show Trucks U.S.A., Inc. TO: Office of the Chief Council TITLE: None ATTACHMT: Attached to letter dated 3-7-91 from Paul Jackson Rice to Terry Rowe (A37; VSA 114, Part 567) TEXT: I would like an opinion letter from your office as to the status of our activities here at Show Trucks U.S.A., Inc. The information contained in 49 CFR 567 "Certification" is a little vague as to whether we are vehicle alters or not. I have enclosed a copy of the different upfitting packages that we do for your consideration. Thank you for your time, if you need any further information please call me at 1-800-552-9127. I will be happy to answer any questions you might have. |
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ID: 77-4.27OpenTYPE: INTERPRETATION-NHTSA DATE: 11/03/77 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Chief Counsel TITLE: FMVSS INTERPRETATION TEXT: One bus manufacturer, Recreational Vehicles, Inc., is currently manufacturing buses from one model vehicle (GMC-RV) that uses a knock-out rear window for the rear emergency exit. The rear window has a ring inserted in the rubber seal that allows the window to fall out or be easily pushed out after the ring is pulled outward (see attached pictures of converted GMC-RV). Section 5.4, FMVSS No. 217, does not address the performance requirements of this type of window for meeting the performance requirements of a rear emergency exit. We request an interpretation regarding the applicability of this type of knock-out rear window for meeting the performance requirements of a rear emergency exit. ATTACH. (Graphics omitted) |
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ID: nht68-3.16OpenDATE: 02/07/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: American Quality Coach Corporation TITLE: FMVSR INTERPRETATION TEXT: Thank you for your letter of January 8, 1968, to the Federal Highway Administration, requesting regulations relating to motor vehicle safety requirements. The type of vehicle that you have described appears to be a bus accordingly to the statutory meaning of Part 255.3, Initial Federal Motor Vehicle Safety Standards. Accordingly, Standards 102, 107, 205 and 209 would be applicable to your vehicles manufactured after January 1, 1968. We invite your attention to Section 114 of Public Law 89-563 and the notice of Certification Requirement. In addition to the existing Federal Motor Vehicle Safety Standards and Public Law 89-563, we are enclosing information concerning proposed rule making that may affect future regulations. We trust this information will be of assistance to you. |
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ID: nht88-3.76OpenTYPE: INTERPRETATION-NHTSA DATE: OCTOBER 21, 1988 FROM: BRADLEY J. BAKER -- PRESIDENT, CLASSIC MANUFACTURING, INC. TO: TAYLOR VINSON -- LEGAL COUNCIL, U.S. DEPT. OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO AUGUST 31, 1989 LETTER FROM STEPHEN P. WOOD, NHTSA, TO BRADLEY J. BAKER, CLASSIC MANUFACTURING, INC.; [A34; STD. 108] TEXT: Our company currently manufactures a Recreational car dolly used to tow a vehicle behind motorhomes. It is also used by car dealerships to retrieve cars and trucks. We have a question regarding the 3 bar light cluster on the back of this unit. Is it a necessity? So far, we have to guess at our interpretation of the Federal laws. We don't know if this is considered a motor vehicle under FMVSS 108; 49 CFR 571.108. The National Truck Equipment Association could not answer this question and recommended we write to you. We would appreciate your opinion on this matter. I can be reached at the following address: Classic Manufacturing, Inc. 21900 W. U.S. 12 Sturgis, Mi 49091 Attn: Brad Baker (616) 651-9319 Fax No.(616) 651-2921 Thank you for your help in advance Sincerely |
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ID: nht93-2.10OpenDATE: March 8, 1993 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Fredd Scheys -- President S.C.C. CARAT Inc. TITLE: NONE ATTACHMT: Attached to 1/27/95 letter from Philip R. Recht to Fredd Scheys (A43; Sec. 1397(b)(2); Also attached to 1/25/95 fax from Fredd Scheys to John Womack; Also attached to 11/16/92 letter from Paul Rice to Fredd Scheys TEXT: Dear Mr. Scheys: This responds to your FAX of March 2, 1993, to Taylor Vinson of this Office. You have heard that Paul Jackson Rice is no longer Chief Counsel of this agency and you request confirmation that his letter to you of November 16, 1992, remains valid. The opinion rendered you approximately 4 months ago remains unchanged and valid. For your information, once an interpretation has been issued by this Office, it remains in effect regardless of who may be Chief Counsel. Generally, an interpretation is affected only if the statute or regulation upon which it is based is amended. The interpretation furnished you was based upon the National Traffic and Motor Vehicle Safety Act and 49 CFR Part 567. Neither the Act nor Part 567 has been amended since November. Sincerely, |
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ID: nht87-3.39OpenTYPE: INTERPRETATION-NHTSA DATE: 12/08/87 FROM: STEVE ZLOTKIN -- CEO OVERLAND PARTS INC TO: ERIKA Z. JONES -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 09/12/88 FROM ERIKA Z JONES TO STEVE ZLOTKIN; REDBOOK A32, STANDARD 205 TEXT: Dear Ms. Jones: We are importers of automotive products including automotive glass. We have need to import a windshield which fits the 1953 to 1967 Volkswagen transporter or "bus" which is a multipurpose vehicle. Our supplier does not have laminated windshields for that model but does have non-laminated windshields. Thus, the question is, (can we legally import and sell non-laminated windshields for that model since the United States windshield standards were not adopted until 1968)? Because it might concern you I will add that it would be impossible to install one of these windshields into a 1968 or later vehicle. There is a great physical difference in size on the later model. If need be we would be willing to placard or sticker each windshield notifying the customer that it is not laminated, or that it is restricted to use on certain year buses if the entire span of 1953 to 1967 is not permissible. I would appreciate your opinion. |
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.