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: nht74-1.45OpenDATE: 01/01/74 EST. FROM: E. T. Driver; NHTSA TO: M. L. Higgins TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 8 to Dr. James B. Gregory, Administrator, concerning an interpretation relative to the [Illegible Words]. [Illegible Paragraph]. |
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ID: nht78-3.5OpenDATE: 02/22/78 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Asthi Glass Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your inquiry of January 23, 1978. Speedometer covers on motorcycles are not subject to FMVSS No. 205. |
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ID: nht75-2.2OpenDATE: 12/16/75 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Engineering Services COPYEE: M. I. SCHWIMMER TITLE: FMVSS INTERPRETATION TEXT: In response to your November 24, letter concerning the relationship between Federal Motor Vehicle Safety Standards Nos. 109 and 119, I am enclosing a copy of a prior interpretation letter on the same subject, which was sent to Mr. C. D. McCarty of the B. F. Goodrich Company on October 15, 1975. |
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ID: nht71-4.22OpenDATE: 10/18/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Feldman Engineering and Manufacturing Company Inc. TITLE: FMVSR INTERPRETATION TEXT: The material furnished you by Mr. Peskoe of this office, as listed in your letter of September 28 is complete to date. This will also confirm that the Mini Brute all terrain vehicle is a "motorcycle" for purposes of the Federal motor vehicle safety standards. |
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ID: nht71-2.4OpenDATE: 02/10/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Seiberling Tire & Rubber Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of January 28, 1971, to Mr. Diag concerning Part 574 - Tire Identification and Record Keeping regulations and to confirm that the fourth grouping, data code, may be placed at the end of the tire identification number by means of a separate serial tin and be separated from the third grouping by a space which will not exceed 3/4 of an inch. |
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ID: nht72-5.3OpenDATE: 05/10/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Garsite Products Inc. TITLE: FMVSR INTERPRETATION TEXT: We have received the pictures of the airport refuelers which you manufacture. While these pictures were received after we had mailed our letter of April 17, 1972, to you, they confirm the opinion expressed in that letter that these vehicles are motor vehicles under the National Traffic and Motor Vehicle Safety Act, and are considered to be trucks under the Federal motor vehicle safety standards. |
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ID: 7747Open Mr. Preston Golder Dear Mr. Golder: This responds to your letter of September 14, 1992, asking about the legality under Federal law of your "Auto Neon System", an accessory which reflects a glow from under the vehicle. We answered an inquiry from Mr. Allan Schwartz about a similar device, in a letter dated April 21, 1992. I enclose a copy of our response to Mr. Schwartz for your information. Sincerely,
Paul Jackson Rice Chief Counsel Enclosure ref:108 10/5/92 |
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ID: nht92-4.25OpenDATE: August 25, 1992 FROM: Paul D. Barron -- Professional Technologies International Inc. TO: Paul Jackson Rice -- NHTSA Chief Counsel; Marvin Shaw TITLE: None ATTACHMT: Attached to letter dated 10/22/92 from Paul Jackson Rice to Paul D. Barron (A40; Std. 205) TEXT: Thanks for your help on the possible requirements from NHTSA on our UV Heat Shield product. As I understand it this product can be self certified and needs no certification from the federal government. Please confirm this in formal documentation to me at your earliest convenience. Attachment PRODUCT ANALYSIS SOLAR SHIELD (Text and graphics omitted.) |
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ID: nht71-5.67OpenDATE: 08/23/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: FWD Corporation TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of August 12 asking for a clarification of the effect of the recent firefighting vehicle amendment (36 F.R. 13926) on Federal standards published prior to September 1, 1971 but effective after that date. Specifically you ask whether Standard No. 302 Flammability of Interior Materials, published on January 8, 1971 applies to firefighting vehicles on September 1, 1972, or September 1, 1974. The firefighting vehicle amendment is effective September 1, 1971 and has no effect upon standards or amendments to standards issued before that date. Thus Standard No. 302 applies to firefighting vehicles as of September 1, 1972. Sincerely, |
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ID: nht92-3.26OpenDATE: October 5, 1992 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Preston Golder -- Road Reflectors TITLE: None ATTACHMT: Attached to letter dated 4/21/92 from Paul Jackson Rice to Allan Schwartz (Std. 108) and letter dated 9/14/92 from Preston Golder to Legal Counsel, NHTSA (OCC-7747) TEXT: This responds to your letter of September 14, 1992, asking about the legality under Federal law of your "Auto Neon System", an accessory which reflects a glow from under the vehicle. We answered an inquiry from Mr. Allan Schwartz about a similar device, in a letter dated April 21, 1992. I enclose a copy of our response to Mr. Schwartz for your information. |
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.