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: nht95-1.34OpenTYPE: INTERPRETATION-NHTSA DATE: January 25, 1995 FROM: Fredd Scheys -- President, S.E.C. Carat Inc. TO: Mr. John WOMACK -- NHTSA TITLE: NONE ATTACHMT: Attached to 1/27/95 letter from Philip R. Recht to Fredd Scheys (A43; Sec. 1397 (b)(2); Also attached to letter dated 3/8/93 from John Womack to Fredd Scheys; Also attached to letter dated 11/16/92 from Paul Rice to Scheys TEXT: Dear Mr. Womack, First, I would like to thank you for your information and help on the phone this afternoon. As said on the phone, I send you the following letters; 1 Letter from Mr. Paul Jackson RICE, dated Nov. 16, 1992 2 Letter from you, dated March 8, 1993 Can you, please, confirm that these answers are still valid as of today. This to keep our records for this particular car as complete as possible. Please, take note of the new address, fax and phone numbers. Again, I would like to thank you for your advice and assistance in this for us very important matter. Sincerely, |
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ID: nht94-4.94OpenTYPE: INTERPRETATION-NHTSA DATE: December 6, 1994 FROM: Michael A. Holmes -- Farmington Correctional Center TO: Federico F. Pena -- Secretary of Transportation TITLE: NONE ATTACHMT: Attached to 1/11/95 letter from Philip Recht to Michael A. Holmes (A43; Part 571) TEXT: Dear Sir; I am an inmate at Farmington Correctional center in Farmington Mo. . When I get out of prison I am wanting to start a business constructing cars and light trucks. I want to do this on a small scale. What I would like from you is information on what laws and statutes exist on this class of vehicle. I am trying to use my time to learn what I will need to know. Before I fell, I was going to college on an electronics degree. I paid for my schooling b y being a mechanic for several years. When I get out I am going to move my degree more toward the mechanical engineering side. I know this is a strange request, except I feel that my designs of a hydrogen turbine over electric, will be quit enjoyed on the market. I thank you for your time, and your effort. I would appreciate if you could let me know of receiving this letter. |
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ID: 8557Open Mr. Jim Keizer Dear Mr. Keizer: This responds to your letter of April 13, 1993, requesting information on the legal responsibilities of businesses that repack or replace air bags in automobiles. I am enclosing copies of five letters which address various issues related to replacement or repair of air bags. The January 19, 1990, letter to Ms. Linda L. Conrad addresses the issue of possible legal obligations to repair a deployed air bag following a collision. The May 13, 1991, and June 11, 1991, letters to Mr. Stephen Mamakas address issues specifically related to the repair of deployed air bags. The March 26, 1993, letters to Mr. Steven C. Friedman and Mr. Jay Lee address issues related to retrofit or replacement air bags. I have also enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel Enclosures ref:208 d:5/6/93 |
1993 |
ID: 11526DRNOpen Michael A. Tonelli, Esq. Dear Mr. Tonelli: This responds to your letter to Mr. Charles Gauthier, formerly of this agency, asking whether multipurpose passenger vehicles (MPVs) must meet Federal standards for passenger cars. We have addressed this question in a December 26, 1995 letter to Jane Thorntorn Mastrucci, Esq. A copy of our letter to Ms. Mastrucci is enclosed. You also asked for the current "Federal Motor Vehicle Safety Standards [FMVSSs] regarding student transportation" and a copy of the current Highway Safety Program Guideline No. 17 "Pupil Transportation Safety." Due to the volume of the material, we are unable to provide copies of the school bus FMVSSs. However, they are readily available at Title 49 of the Code of Federal Regulations (CFR) Part 571. For your reference, I have enclosed an information sheet that describes ways to obtain the material. Enclosed is a copy of Guideline No. 17, which is set forth at 23 CFR '1204.4. I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely,
Samuel J. Dubbin Chief Counsel Enclosures ref:vsa#571.3 d:3/4/96
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1996 |
ID: nht87-3.50OpenTYPE: INTERPRETATION-NHTSA DATE: DECEMBER 23, 1987 FROM: CHARLEY ERICKSON -- PRESIDENT - CHARLEY'S OFF ROAD CENTER, INC. TO: ERIKA JONES -- CHIEF COUNSEL, NHTSA TITLE: NONE ATTACHMT: MEMO DATED 6-24-88, FROM ERIKA Z. JONES, TO CHARLEY ERICKSON, STD 302 TEXT: Please accept this letter as our request for an interpretation of SAFETY STANDARD NO. 302. Our company wishes to manufacture a product know as a Bikini sun shade. This product has been on the market for many years by other manufacturers. We wish to use a material known as "Sunbrella", manufactured by Glen Raven (sample enclosed). As you can see, the material is non-fire retardent. We don't feel that this particular product would be applicable under S3A of Standard NO. 302. As you can imagine this product would only be used by the consumer during warm days on vehicles such as Jeeps, Suzuki and Toyota Landcrusiers. Its purpose is to give some shade, but yet allow the vehicle to have an "open" feeling. Our material comes in many different colors and patterns. We wish to market it under the name of CALIFORNIA STRIPER. I have enclosed a few pictures to help you understand the products application. Please respond as soon as possible as spring is just around the corner. |
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ID: nht92-5.33OpenDATE: July 1, 1992 EST FROM: Charles L. Henry, Jr. TO: Paul J. Rice -- Chief Council, NHTSA TITLE: None ATTACHMT: Attached to letter dated 08/17/92 from Paul J. Rice to Charles Henry, Jr. (Std. 101; A39; Std. 108; VSA 108) TEXT: My partner and I will shortly begin marketing an electronic device for automatically shutting down the lighting circuits of an automobile or vehicle after a predetermined time period following the motor shut down. A patent is applied for and we are incorporated. We were advised to have the device cleared by the consumer products safety commission but they say they don't control anything relating to auto safety and referred me to N.A.H.T.S.A. I am told that your organization has no clearance procedures either but was advised that you might provide some sound advice. We are aware that such devices are currently available as optional equipment on higher priced automobiles. Our device accomplishes this "automatic lights-out" function in a different way and will be initially sold to the auto "add-on" market at a reasonable price for do-it-yourselvers or installers. Any advice you can provide will be greatly appreciated. We are trying to take all the steps necessary to protect our corp. and the public. |
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ID: 20032.drnOpenMr. Kevin Nugent Dear Mr. Nugent: This responds to your request for an interpretation whether you may lease a new1999 Chevrolet 12-Passenger Express Van (Model CG1406) to a local school district, when you have a letter indicating that the "primary purpose" of the van would be for "adult education students." Under the available facts, the answer is no. If you decide to sell or lease a new bus to the school district, you must sell or lease only a bus that meets the National Highway Traffic Safety Administration's (NHTSA's) school bus standards. By way of background, NHTSA has the authority, under 49 U.S.C. 30101 et seq. (Chapter 301 or the Act) to regulate the manufacture and sale or lease of new motor vehicles. In 1974, Congress directed NHTSA to issue motor vehicle safety standards on specific aspects of school bus safety and apply those standards to all "school buses." The school bus standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. The Act at 49 U.S.C.30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses - vehicles designed for carrying more than ten (10) persons. For example, a 12-person van that is likely to be used significantly to transport students is a "school bus." If a new large (11 persons or more capacity) van were sold or leased to a school district and used on a regular or long-term basis to transport students, the vehicle must meet NHTSA's school bus standards. However, a one-time or very occasional rental would be permitted, on the grounds that the vehicle would not be used significantly to transport children to and from school and thus would not be a school bus. You enclose a letter from Mr. David W. Pottle, Adult Education Co-ordinator of the Southern Berkshire Regional School District (in Sheffield, Massachusetts) that states that the "primary purpose" for the 12-passenger van lease would be for "transportation of adult education students." Although the primary purpose of the bus may be for adult education, the letter implies that the bus would have a substantial collateral use. The statement that the "primary purpose" is for the transportation of adult education students is not sufficient. For example, if the vehicle were used 51 percent of the time to transport adults and 49 percent of the time to transport students, it would still be a school bus required to meet our school bus safety standards. For more information about the safety features of a school bus, I am enclosing NHTSA's publication: "School Bus Safety: Safe Passage for America's Children." If you have any further questions please feel free to contact Dorothy Nakama at this address or at (202) 366-2992. Sincerely, |
1999 |
ID: 8805johnOpen Mr. James N. Doan Dear Mr. Doan: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You asked whether an automatic vehicle speed control (also known as a cruise control), that you describe as "mounted on the transmission shift lever," must be illuminated. As explained below, the answer is no. S5.3.1 sets requirements concerning controls which must be illuminated. S5.3.1 excludes from the illumination requirements hand operated controls that are mounted on the floor, floor console or steering column. You believe that your proposed control would be considered "mounted on the floor or floor console" and thus excluded from S5.3.1's illumination requirements. We agree that locating the control on the shift lever is similar to locating it on the floor console for the purposes of the illumination requirements. This interpretation is based on agency precedent concerning S5.3.1's exception for controls on steering columns. In the preamble to a final rule of May 4, 1971 (36 FR 8296), NHTSA determined that the exception for controls mounted on the steering column extends to controls mounted on the steering wheel. Since the transmission shift lever bears the same relationship to the floor console as does the steering wheel to the steering column, controls on the transmission shift lever are excepted from S5.3.1's illumination requirements. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel Enclosure ref:101 d:9/21/93 |
1993 |
ID: nht93-6.40OpenDATE: September 21, 1993 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: James N. Doan -- Counsel - Operations, Eaton Corporation TITLE: None ATTACHMT: Attached to letter dated 6/17/93 from James N. Doan to John Womack (OCC-8805) TEXT: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You asked whether an automatic vehicle speed control (also known as a cruise control), that you describe as "mounted on the transmission shift lever," must be illuminated. As explained below, the answer is no. S5.3.1 sets requirements concerning controls which must be illuminated. S5.3.1 excludes from the illumination requirements hand operated controls that are mounted on the floor, floor console or steering column. You believe that your proposed control would be considered "mounted on the floor or floor console" and thus excluded from S5.3.1's illumination requirements. We agree that locating the control on the shift lever is similar to locating it on the floor console for the purposes of the illumination requirements. This interpretation is based on agency precedent concerning S5.3.1's exception for controls on steering columns. In the preamble to a final rule of May 4, 1971 (36 FR 8296), NHTSA determined that the exception for controls mounted on the steering column extends to controls mounted on the steering wheel. Since the transmission shift lever bears the same relationship to the floor console as does the steering wheel to the steering column, controls on the transmission shift lever are excepted from S5.3.1's illumination requirements. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. |
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ID: nht93-3.38OpenDATE: May 6, 1993 FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA TO: Jim Keizer TITLE: None ATTACHMT: Attached to letter dated 4-13-93 from Jim Keizer to NHTSA (OCC 8557); Also attached to letter dated 3-26-93 from John Womack to Jay Lee (Std. 208); Also attached to letter dated 3-26-93 from John Womack to Steven C. Friedman (Std. 208); Also attached to letter dated 6-11-91 from Paul Jackson Rice to Stephen Mamakas (Std. 208); Also attached to letter dated 5-13-91 from Paul Jackson Rice to Stephen Mamakas (Std. 208); Also attached to letter dated 1-19-90 from Stephen P. Wood to Linda L. Conrad (Std. 208) TEXT: This responds to your letter of April 13, 1993, requesting information on the legal responsibilities of businesses that repack or replace air bags in automobiles. I am enclosing copies of five letters which address various issues related to replacement or repair of air bags. The January 19, 1990, letter to Ms. Linda L. Conrad addresses the issue of possible legal obligations to repair a deployed air bag following a collision. The May 13, 1991, and June 11, 1991, letters to Mr. Stephen Mamakas address issues specifically related to the repair of deployed air bags. The March 26, 1993, letters to Mr. Steven C. Friedman and Mr. Jay Lee address issues related to retrofit or replacement air bags. I have also enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. |
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.