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: nht89-2.39OpenTYPE: INTERPRETATION-NHTSA DATE: 07/21/89 FROM: RICHARD L. VAN IDERSTINE -- SAFETY STANDARDS ENGINEER, NHTSA TO: DOCKET SECTION; THRU: RALPH HITCHCOCK, DIRECTOR -- OFFICE OF VEHICLE SAFETY STANDARDS; VIA: OFFICE OF CHIEF COUNSEL TITLE: ACTION: SUBMISSION TO DOCKET 85-13, NOTICE 7 AND NOTICE 8, OF A CONGRESSIONAL INQUIRY AND NHTSA'S RESPONSE CONCERNING ULTRAVIOLET EMISSIONS FROM HEADLAMPS ATTACHMT: ATTACHED TO LETTER DATED 3-15-90 TO T. CHIKADA, STANLEY ELECTRIC CO., LTD., FROM STEPHEN P. WOOD, NHTSA; [A35; STD. 108]; ALSO ATTACHED LETTER DATED 8-9-89 TO ERIKA Z. JONES, NHTSA, FROM T. CHIKADA, STANLEY ELECTRIC CO., LTD.; [OCC 3832] TEXT: Please place the attached letters in Docket 85-15; Notice 7 and Notice 8, for Standard No. 108. The attachments concern the potential for ultraviolet light emissions from future headlighting systems such as those using a high intensity discharge, gaseou s discharge, or short arc metal-halide light sources. Attachment (w/10 copies) |
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ID: 77-4.44OpenTYPE: INTERPRETATION-NHTSA DATE: 12/01/77 FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA TO: Texas Automobile Dealers Association TITLE: FMVSR INTERPRETATION TEXT: This responds to your October 5, 1977, letter requesting a further clarification of our interpretation given to you on September 1, 1977, concerning "kit cars." You ask whether there is a requirement to certify the vehicle if it is manufactured using an old chassis. As we stated to you in our first letter, the assembly of such a vehicle is not the manufacture of a new motor vehicle. The certification requirements of Part 567 of our regulations apply only to new motor vehicles or the alteration of previously certified vehicles prior to their first purchase for purposes other than resale. Since your remanufacturing operation constitutes neither the manufacture of a new motor vehicle nor the alteration of a previously certified vehicle, your vehicle would not be required to be certified. |
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ID: nht95-1.15OpenTYPE: INTERPRETATION-NHTSA DATE: January 5, 1995 FROM: J. Gregory Studemeyer TO: NHTSA TITLE: Re: Safety standards for school buses ATTACHMT: ATTACHED TO 6/27/95 LETTER FROM JOHN WOMACK TO J. GREGORY STUDEMEYER (A43; PART 571.3) TEXT: Gentlemen: It is my understanding that passenger vans meeting the definition of "school bus" as defined in the Vehicle Safety Act, must meet certain safety standards. It is further my understanding that these safety standards are implemented by prohibiting manuf acturers and dealers from selling new vehicles which meet the definition of "school bus" to educational institutions. Notwithstanding the fact that the burden of enforcing these standards is placed upon manufacturers and dealers, can you advise as to whether or not your agency or any other federal agency notifies educational institutions of these requirements. |
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ID: nht71-2.46OpenDATE: 05/10/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Westinghouse Air Brake Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of April 30 inquiring whether construction equipment is considered a "motor vehicle" under the National Traffic and Motor Vehicle Safety Act of 1966, and hence whether 49 CFR Part 574 Tire Identification and Recordkeeping would apply to Westinghouse as a manufacturer of motor vehicles. As a general rule, construction equipment is considered "manufactured primarily for use on the public streets, roads, and highways" and hence a "motor vehicle" as that term is defined by section 102(3) of the Act. Thus the Tire Identification regulations would apply to Westinghouse, even though many items of construction equipment do not fall into any defined category of motor vehicles to which the Federal motor vehicle safety standards themselves apply. |
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ID: nht88-2.1OpenTYPE: INTERPRETATION-NHTSA DATE: 04/19/88 FROM: D. BRUCE HENDERSON -- RANGE ROVER TO: OFFICE OF THE CHIEF COUNSEL, NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 10/14/88 FROM ERIKA Z JONES TO N. BOWYER; REDBOOK A32, STANDARD 208, 209; UNDATED LETTER FROM N. BOWYER TO OFFICE OF CHIEF COUNSEL, NHTSA; OCC 1909 TEXT: Dear Sir or Madam, Enclosed is a request for interpretation of Federal Motor Vehicle Safety Standards from Land Rover UK, Ltd., the manufacturer of Range Rover vehicles imported and sold in the U.S. by this company. We would appreciate your response to this request at the earliest possible time. Thank you for your help and attention. Please contact me at the letterhead address and telephone number below if you need any further information about this request. ENCLOSURE |
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ID: nht89-1.41OpenTYPE: INTERPRETATION-NHTSA DATE: 03/17/89 FROM: ROBERT V. POTTER -- SPALDING AND EVENFLO COMPANIES INC TO: NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 07/27/89 FROM STEPHEN P. WOOD -- NHTSA TO ROBERT V. POTTER -- SPALDING AND EVENFLOW CO; REDBOOK A33; STANDARD 213; LETTER DATED 07/31/86 FROM ERIKA Z. JONES -- NHTSA TO K. A. ZIOMEK -- TRW TEXT: Dear Sir or Madam: I am writing to request a formal opinion on whether any National Highway Traffic Safety Administration rule, regulation or requirement addresses the question of how long a manufacturer of child restraint devices, designed for use in motor vehicles, must retain or make available replacement parts for those devices. It is my understanding that there is a regulation requiring the manufacturers of motor vehicles to manufacturer or make available replacement parts for ten years. It is my current understand ing and opinion that those regulations do not apply to child restraint devices, but I would appreciate your opinion on this matter. Very truly yours, |
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ID: nht90-1.97OpenTYPE: INTERPRETATION-NHTSA DATE: 04/02/90 FROM: MANUEL R. GARCIA TO: NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/26/90 FROM PAUL JACKSON RICE -- NHTSA TO MANUEL R. GARCIA; A35; PART 591; PART 592; PART 593; PART 594 TEXT: I am station overseas and work for the US Government in Civil Service. I recently bought a 1974 BMW model 1602 car made overseas. Please send me information on EPA and Safety requirements the car must conform to before being shipped to the USA. Can I wait until the car gets to the states to make the necessary repairs or conversion to meet the EPA and Safety requirements? I would also like the publication that covers the Code of Federal Regulations and the Federal Register. Please send the information to the following address: Manuel R. Garcia PSC Box 1865 APO NY 09406 |
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ID: nht94-2.46OpenTYPE: INTERPRETATION-NHTSA DATE: April 18, 1994 FROM: Robin Liu -- President, Introbusy TO: Stephen Wood -- Transportation Department, NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 6/6/94 From John Womack To Robin Liu (A42; Std. 108; VSA 108(a)(2)A) TEXT: DEAR MR. WOOD: WE ARE GOING TO IMPORT A MERCHANDISE OF STOPPING LAMP FOR AUTOMOBILES. ITS FEATURE AND USAGE ARE AS PER THE ATTACHED SHEETS/PHOTOS. WE WOULD LIKE TO KNOW WHETHER IT MEETS THE REGULATION OF YOUR DEPARTMENT BEFORE WE PLACE ORDERS FOR IMPORTATION. DO WE NEED TO GET ANY OFFICIAL APPROVAL OR TO APPLY ANY LICENSE TO ENSURE THAT INSTALLING THIS PRODUCT IN MOTOR VEHICLE WILL NOT VIOLATE THE REGULATION OF TRANSPORTATION DEPARTMENT? SHOULD YOU NEED FURTHER DETAILS OR CLARIFICATION, PLEASE EITHER WRITE TO US AT THE ADDRESS UNDERNEATH OR CALL/FAX TO US AT (415) 468-3831. WE LOOK FORWARD TO HEARING FROM YOU SOON. SINCERELY YOURS |
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ID: nht71-4.49OpenDATE: 11/16/71 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: The Flxible Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of October 22 asking whether the "hoodlum warning system" requested by the city of Boston (MBTA) would conform to Federal Motor Vehicle Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Paragraph S3.5 of Standard No. 108 permits "normally steadily-burning lights [to] be capable of being individually flashed for signalling purposes" on motor vehicles manufactured before January 1, 1972. Therefore the hoodlum warning system is currently permissible under Standard No. 108. However, a new requirement effective January 1, 1972, would prohibit the installation of this system on vehicles manufactured on or after this date. Paragraph S4.6 of Standard No. 108 states: "Where activated (a) Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall flash; (b) All other lamps shall be steady-burning except that means may be provided to flash headlamps and side marker lamps for signalling purposes." (emphasis added) |
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ID: nht88-2.35OpenTYPE: INTERPRETATION-NHTSA DATE: MAY 31, 1988 FROM: M. ARISAKA -- MANAGER, AUTOMOTIVE LIGHTING, STANLEY ELECTRIC CO., LTD. TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA TITLE: NONE ATTACHMT: MEMO DATED 8-10-88, TO M. ARISAKA, FROM ERIKA Z. JONES-NHTSA, STD 108 TEXT: We would like to know about the installation of an additional Rear Reflex Reflector (RR). We are planning to install the additional Rear RR at the center portion of the rear face of cars in addition to present two Rear RRs required by FMVSS No. 108 Table III. (See attached drawing.) The additional Rear RR will never impair the effectiveness of other lighting equipment required by FMVSS No. 108 Table III. Kindly let us know your advice whether the above mentioned additional Rear RR is allowed or not. We are looking forward to your reply. Present two Rear RRs required by FMVSS No. 108 Table III The Additional rear RR |
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.