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: nht72-5.25OpenDATE: 12/01/72 EST. FROM: Robert L. Carter; signature by Elwood T. Driver TO: Hatch Imports Inc. TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of December 5, 1972, concerning approvals required by the Federal Government regarding the sale of safety glazing materials. No approval by the Federal Government is required. Certification of conformance to Federal Motor Vehicle Safety Standard No. 205 is self-certification. I am enclosing a copy of Standard No. 205 and Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966. If you are not aware of State approvals, you may want to contact Mr. Armand Cardarelli, of the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W. Washington, D.C. 20036. If we can be of further service, please do not hesitate to ask. |
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ID: nht78-3.34OpenDATE: 04/03/78 FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA TO: Alloy Trailers Inc. TITLE: FMVSR INTERPRETATION TEXT: This responds to your February 10, 1978, question whether a trailer is considered newly manufactured under section 571.7(f) of NHTSA regulations if new materials are used except for four running gear assemblies that come from the front and rear of two wrecked trailers and are welded together to form the front and rear tandems of the reassembled full trailer. It is our understanding that the axles, wheels, braking and suspension components would be taken from the existing trailers, the identity of one of the existig trailers would be continued in the reassembled trailer, and the two existing trailers would be owned or leased by the user of the reassembled trailer. Assuming that this understanding of the facts is correct, the NHTSA would consider the reassembled trailer to be not newly manufactured under 49 CFR 571.7(f) for purposes of the Act, implementing regulations, and the safety standards. |
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ID: nht94-6.26OpenDATE: 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: nht91-6.50OpenDATE: November 1, 1991 FROM: Tadoru Yamamoto -- General Manager, Technical Administration Division, Hino Motors Ltd. TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: Questions on the Interpretation of FMVSS 113 "Hood & Latch System" ATTACHMT: Attached to letter dated 1/13/92 from Paul Jackson Rice to Tadoru Yamamoto (A39; Std. 113) TEXT: Hino Motors, Ltd. is a Japanese manufacturer of heavy duty diesel trucks & buses. We export some kinds of trucks & buses to the United States. We are now developing new model vehicles (cab-over type) which have a front panel. In designing the front panel, we have some questions on the interpretation of FMVSS 113 "Hood & Latch System." It will be greatly appreciated if you would answer the attached questionnaire by Nov. 20, 1991 at the latest. If possible, we would like to receive your answer by facsimile. Our FAX No. is 011-81-0425-86-5006. I'm looking forward to your reply. |
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ID: nht72-4.40OpenDATE: 06/21/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Pennsylvania Recreational Vehicle and Camping Association TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of April 9 to Mr. Schneider asking whether mobile homes and modular homes which have (Illegible Words) can be exempt from (Illegible Word) and (Illegible Word) requirements. It is my understanding that a mobile home is a structure which may be, and generally is, used more than once, from site to site, on its own wheels. Accordingly as determined several years ago that mobile homes are "motor vehicles" under its National Traffic and Motor Vehicle Safety Act of 1966, however infrequent their use of the public roads. As motor vehicles, they must (Illegible Word) certification labels that specify (Illegible Words) ratings. If a modular home on wheels uses the public roads "only for the (Illegible Word) trip to the (Illegible Word) lot," on your letter states, (Illegible Word) is planned on a permanent foundation, we would not consider it a "motor vehicle." |
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ID: nht94-2.51OpenTYPE: INTERPRETATION-NHTSA DATE: April 20, 1994 FROM: Doug Bereuter -- Member Of Congress, U.S. House Of Representatives TO: Christopher Hart -- Acting Administrator, NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 5/10/94 From Christopher Hart To Doug Bereuter (A42; Std. 303) And 1/1/94 (EST) Letter From Christopher Hart To Doug Bereuter TEXT: Dear Mr. Hart: I recently received your response to my earlier letter regarding the long-delayed National Highway Traffic Safety Administration's rulemaking concerning compressed natural gas vehicle fuel systems and fuel containers. In your letter, you mention that th e final rule is being prepared and will be sent to the Office of Management and Budget (OMB) for review. I want to know as soon as the rule is sent to OMB so that I can impress upon them the importance of this matter. It is also critical that you infor m OMB of the need for a prompt review. This rule cannot be allowed to languish on someone's desk while Brunswick and its employees continue to suffer due to the lack of a final rule. |
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ID: nht72-1.31OpenDATE: 02/11/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Bandag Incorporated TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of January 15, 1972, asking whether your "treadless" passenger car tire will be considered a new tire under the Federal motor vehicle safety standards. You enclose a diagram and explain that the "treadless" tire is a "brand new . . . tire that we will furnish our dealers and then they will apply a new Bandag tread to the tire and then sell the finished unit." Based upon the description you have provided, we are of the opinion that your treadless tire is a new tire, and consequently subject to Motor Vehicle Safety Standard No. 109. Also, as each dealer applies the tread to the tire, each would be considered a "manufacturer" under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 at seq.), and be responsible for the requirements imposed upon manufacturers by the Act, and a standards and regulations issued pursuant to it. We are pleased to be of assistance. |
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ID: nht90-1.55OpenTYPE: Interpretation-NHTSA DATE: February 22, 1990 FROM: Dave Baker -- School Bus Inspector TO: Bev Wilson TITLE: Re Buses other than School Buses ATTACHMT: Attached to a copy of a portion of the Minnesota Statutes (text omitted); Also attached to letter dated 3-18-88 from R.C. Rost to Chief Council, NHTSA; Also attached to letter dated 8-26-88 from E.L. Jones to R.C. Rost; Also attached to letter dated 9-7-90 from P.J. Rice to D.L. Giles (A36; Std. 108; VSA 103(d)); Also attached to letter dated 3-14-90 from D.L. Giles to S.P. Wood; Also attached to letter dated 3-8-90 from D.L. Giles to D. Baker; Also attached to memo dated 3-6-90 from B. Wilson to D. Giles TEXT: I hope this helps you understand whats going on. You will have to remove those lights you have on your bus. If you have any more questions - contact me at 389-1172 in Mankato. Box 4187, Mankato, MN 56001. Thanks Attached is a copy of a portion of the Minnesota Statutes (text omitted). |
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ID: nht94-4.75OpenTYPE: INTERPRETATION-NHTSA DATE: November 2, 1994 FROM: John Sheppard -- Sales and Marketing Manager, Reflexite Canada, Inc. TO: Chief Council, NHTSA TITLE: None ATTACHMT: ATTACHED TO LETTER DATED 12/7/94 FROM PHILIP R. RECHT TO JOHN SHEPPARD (A42; REDBOOK 2; STD. 108) TEXT: As a manufacturer of retro-reflective sheeting that meets the requirements for "DOT-C2" material as specified in N.H.T.S.A.'s final rule, 49 CFR, Part 57, Docket #80-9, we request an official ruling on the following proposal. Use of the material outlined below, (sample enclosed) on the rear of vehicles currently required to meet the requirements of the aforementioned regulation. Material: - Reflexite Conspicuity Material, - Alternating red and silver strips oriented at a 45 degrees angle to the edge of the roll. - Widths of rolls to be either 6" or 8". - Rolls will not have "DOT-C2" marking. The specific question is as follows: Could the above mentioned material be applied to the lower edge of the vehicle's rear doors as a compliant substitute for the 2" "block pattern" material currently being used? This alternative would have a great deal more retro-reflective surface are a. Your attention to this request would be greatly appreciated. |
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ID: 12582.mlsOpen Mr. Michael C. Horan Dear Mr. Horan: This responds to your inquiry asking whether there were Federal safety laws in 1968 or 1969 pertinent to side-mounted exhaust systems known as "heat shields" on passenger cars. You state that a Wisconsin State trooper ticketed you for not having the original-equipment heat shield. Although the National Highway Traffic Safety Administration (NHTSA) is authorized to regulate the safety of newly manufactured motor vehicles and motor vehicle equipment by issuing Federal motor vehicle safety standards, it has never issued any Federal motor vehicle safety standard or other regulation applicable to heat shields. Thus, Federal regulations neither require nor prohibit them. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel ref:mis d.11/21/96 |
1996 |
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.