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: 14836.ztvOpen Mr. Paul G. Scully Dear Mr. Scully: We have received your letter of April 8, 1997, bringing to our attention the possibility that certain trailer manufacturers may not be mounting identification and clearance lamps "as close to the top as practicable" as required by Federal Motor Vehicle Safety Standard No. 108. You sent copies of this letter to representatives of the Office of Safety Performance Standards and the Office of Vehicle Safety Compliance as well. Representatives of these Offices and mine have met to consider your letter. We appreciate your informing us about this matter, and we shall look into it further. Sincerely, |
1997 |
ID: nht73-5.9OpenDATE: 10/10/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Lear Siegler Inc. TITLE: FMVSR INTERPRETATION TEXT: This is to acknowledge receipt of your petition for reconsideration of September 16, 1973, concerning Motor Vehicle Safety Standard No. 218, "Motorcycle Helmets." One of your requests was to extend the 30-day "comment period". This 30-day period for petitions for reconsideration is not a comment period, but is specified under NHTSA regulations at 49 CFR Part 553.35. Because of the relationship of these petitions to judicial review of a standard, the NHTSA generally does not extend this petition period. The NHTSA is considering your petition on this subject, and a substantive response will be published in the Federal Register. |
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ID: nht75-6.43OpenDATE: 10/17/75 FROM: JOHN B. WHITE -- ENGINEERING MANAGER, TECHNICAL INFORMATION DEPT., MICHELIN TIRE CORPORATION TO: MR. SCHWIMMER -- OFFICE OF THE CHIEF COUNSEL, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11-10-75 TO JOHN B. WHITE FROM FRANK A. BERNDT. TEXT: This is in regard to our telephone conversation of yesterday concerning truck tires brought into the U.S.A. to be mounted on vehicles which are to be exported outside the U.S.A. Please verify that tires imported for this purpose need not conform to FMVSS 119, Pneumatic Tires for Vehicles other than Passenger Cars or Part 574, Tire Identification and Record Keeping. This decision affects a current tire shipment, so therefore we would appreciate your prompt reply. Thank you. |
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ID: 1985-01.4OpenTYPE: INTERPRETATION-NHTSA DATE: 01/03/85 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: The Honorable Robert S. Walker TITLE: FMVSA INTERPRETATION TEXT:
Jan. 3, l985 The Honorable Robert S. Walker House of Representatives Washington, D.C. 20515
Dear Mr. Walker: This is in further response to your letter on behalf of your constituent, Mr. Curtis L. Rohm, the Superintendent of Schools n the Solanco School District. We have recently replied to Mr. Rohm by letter dated December 28, l984. Enclosed you will find a copy of our response to Mr. Rohm and your constituents correspondence. If you have further questions, please do not hesitate to contact my office.
Sincerely, Frank Berndt, Chief Counsel Enclosures |
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ID: nht68-2.21OpenDATE: 06/07/68 FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA TO: Von Hamm-Young Mercantile Inc. TITLE: FMVSR INTERPRETATION TEXT: Thank you for your letters of February 19, 1968, and April 1, 1968, to the National Highway Safety Bureau, regarding your wish to import a Nissen President passenger car which you state does not conform to all applicable Federal Motor Vehicle Safety Standards. A passenger car which does not conform to the Federal standards may enter the United States under one of the seven situations set forth in @ 12.80(b)(2) of the enclosed regulations. If it is impossible to conform the President either before or after entry, you could import a non-conforming example if it were manufactured before January 1, 1968, or if it were manufactured after that date and used solely as a static display. |
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ID: nht88-3.54OpenTYPE: INTERPRETATION-NHTSA DATE: SEPT. 17, 1988 FROM: MARK JANSEN -- CHEVY DUTY PICKUP PARTS TO: TAYLOR VINSON -- LEGAL COUNSEL, NHTSA ATTACHMT: UNDATED LETTER TO MARK JENSEN, CHEVY DUTY PICKUP PARTS, FROM ERIKA Z. JONES, NHTSA TEXT: I own and operate a small parts store specializing in parts for 1947-1966 Chevrolet and GMC pickup trucks. I have many requests for parklamp and taillamp lenses for these pickups that are not currently available. I would like to have these lenses reman ufactured and am requesting information concerning requirements and restrictions before proceeding. These will be reproduced exactly like the original lenses, which I assume would have been approved by the D.O.T. Must the reproduction lenses also be supplied to the D.O.T. for approval? If so, how is this accomplished? Is there a charge for this serv ice? Will be anxiously awaiting your reply. |
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ID: 86-3.37OpenTYPE: INTERPRETATION-NHTSA DATE: 05/30/86 FROM: RICHARD E BOND -- HOLIDAY RAMBLER CORPORATION TO: ADMINISTRATOR NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 12/24/86 TO RICHARD E BOND, FROM ERIKA Z. JONES, REDBOOK A29, PART 565 TEXT: Gentlemen: I have a simple question which does not seem to be addressed by the regulations. It is based on the following facts: Corporation manufactures vehicle X for several years. Corporation then separates the portion of its company which manufactures these vehicles into a separate, wholly-owned subsidiary corporation. Subsidiary corporation will continue to manufacture vehicle X. Question: Is the Society of Automotive Engineers authorized to transfer the WMI code that was being used by Corporation for vehicle X to subsidiary corporation for vehicle X? Thank you in advance for your assistance. Sincerely yours, |
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ID: 2862oOpen Mr. M. Arisaka
Dear Mr. Arisaka: This is in reply to your letter of June l0, 1988, describing a "flash to pass" headlighting feature and asking whether it is permissible under Federal Motor Vehicle Safety Standard No. l08. Enclosed is a copy of the agency's letter of June 17, 1987, to MMC Services, Inc. commenting on a similar device. The fact that Stanley's passing beam would project through an amber lens rather than a clear, or noncolored one, does not affect this interpretation. The address of the American Association of Motor Vehicle Administrators is now 4600 Wilson Boulevard, Arlington, Va. 33203. Sincerely,
Erika Z. Jones Chief Counsel /Enclosure ref:108 d:6/30/88 |
1988 |
ID: 3004yyOpen Mr. Michael Maher Dear Mr. Maher: This responds to your letter of April 19, 1991 concerning what you consider faulty windshield replacement. You ask that this agency state that the "render inoperative" provision of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(a)) "will be applied to replacement of damaged windows." The agency addressed this issue recently in a letter to Mr. James E. Rooks, Jr., of your staff. For your convenience, I am enclosing a copy of that May 29, 1991 letter. I hope that this information is useful. If you have any further questions, please contact John Rigby of this office at 366-2992. Sincerely,
Paul Jackson Rice Chief Counsel Enclosure ref:212#VSA 6/5/9l |
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ID: nht71-4.37OpenDATE: 11/02/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: REBCO TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of October 24, 1971, concerning the retention of records of the names and addresses of first purchasers of retread tires that you manufactured prior to October 13, 1971, the date you went out of the retread business. Under the Tire Identification and Record Keeping Regulation you are required to maintain the names of first purchasers three years from the time the sale is reported to you or your designee. Therefore, as to those tires manufactured between May 22, 1971 and the date you went out of business, October 24, 1971, you are required to maintain, or have maintained for you the names and addresses of the first purchasers for three years after this information is recorded by you or your designee. |
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.