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 |
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ID: nht91-6.1OpenDATE: September 17, 1991 FROM: Herbert J. Lushan -- Regalite Plastics Corp. TO: Paul Jackson Rice -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 11-20-91 from Paul Jackson Rice to Herbert J. Lushan (A38; Std. 205) TEXT: I am writing you at the suggestion of John Rigby. Regalite Plastic is a manufacturer of Clear Flexible Plastic Sheets that are used in the rear windows of Convertible automobiles and as side and rear windows of Jeep-type vehicles. Our regular clear ULTRALITE window meets and exceeds the ANSI Z26.1-1977 Item 6 test requirements. We have been asked by one of our customers to make a bronze TINTED clear plastic flexible window for the rear and rear sides of their Jeep-type vehicle. This bronze tinted clear will not pass Test #2, Luminous Transmittance Test. Since these Jeep-type vehicles are considered MPV (Multi purpose vehicles) by the manufacturer, I understand that they only have to meet the Item 7 SPECS which eliminates the Test #2 for Luminous Transmittance as a requirement. Please confirm or deny whether my understanding or interpretation is correct so that we may proceed properly. |
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ID: nht90-4.45OpenTYPE: Interpretation-NHTSA DATE: October 15, 1990 FROM: Paul A. Shaw -- Superintendent, Florence County School District Five TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 1-14-91 from Paul J. Rice to Paul A. Shaw (A37; Part 571.3) TEXT: I would like your clarification on the School Bus and Motor Vehicle Safety Act amended by congress in 1974. This amendment directed the National Highway Traffic Safety Administration to issue motor vehicle safety standards on specific aspects of school bus safety and apply those standards to all school buses. Under this federal law, a van designed for eleven or more persons is considered a school bus if it is maintained for transporting students to and from school or school-related events. Does federal law prohibit a school district from using a fifteen-passenger van that does not meet federal safety standards for school buses to transport students to athletic events, extra-curricular activities, and field trips? Our school district purchased a standard, fifteen-passenger, 1990 Dodge van to transport students to various school-related events. Is the use of this van for transporting students to these events violating federal law? If so, please cite the specific s ection of the law pertaining to this. I shall look forward to hearing from you at your earliest convenience. |
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ID: nht76-5.72OpenDATE: 05/26/76 FROM: RONALD W. COOKE TO: JAMES B. GREGORY -- U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/01/75 EST, FROM ROBERT L. CARTER -- NHTSA TO RONALD W. COOKE, N41-42, OPINION FILE, MVSS 301 TEXT: Dear Mr. Gregory: I am writing to you for some clarification on Motor Vehicle Safety Standard No. 301-75 (part 571; s 301-75). This standard spells out original equipment manufacture's responsibilities for designing automobiles against fuel spillage after crash tests. This implicitely means that manufactures of gas caps for OEM customers are required to provide gas caps which conform to the roll-over requirements. My question is, do the Federal Motor Vehicle Standards in any way impose requirements on parts manufacturers who make gas caps for after-market retail outlets to market caps which meet the OEM roll-over specifications? For any company to volentarily follow the practice of meeting the roll-over specifications when others do not, self-imposes a severe marketing penalty because of the additional large number of caps which are needed for complete market coverage. This poses warehouse customer inventory stocking problems. Since some companies are using one cap for the OEM which meets roll-over requirements, and a different cap for the after-market at a decided competative advantage, it is imperative to us that this question of applicability of the Federal Motor Vehicle Safety Standard be answered I await your early reply. Sincerely yours, |
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ID: nht92-4.21OpenDATE: 09/01/92 EST FROM: JULIA WALL -- HEAD, THE TRINITY SCHOOL OF TEXAS TO: DOT ATTACHMT: ATTACHED TO LETTER DATED 11-03-92 FROM PAUL J. RICE TO JULIA WALL (A40; PART 571.3) TEXT: Please send a copy, of the federal law that regulates student transportation in general and as it specifically relates to multiple passenger vans. Thank you for your assistance. The copy should be sent to: |
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ID: nht91-3.17OpenDATE: April 10, 1991 FROM: Chris Lawrence -- Chang & Lawrence TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-10-91 from Paul Jackson Rice to Chris Lawrence (A37; Std. 108; VSA 108(a)(2)) TEXT: Thanks for your response to my letter of January 5 to Dr. Burgett of NHTSA. You responded that rear mounting of the electric sign board would not be permissible--does this mean that you would not object to mounting the board in a side window? Also, what other regulatory bodies need to be consulted before product marketing for a side-mounted sign board can begin? Your assistance is greatly appreciated. |
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ID: nht94-5.42OpenDATE: May 11, 1994 FROM: William L. Blake TO: United States Department of Transportation COPYEE: Lloyd Barker TITLE: Re: 1985 Mercedes Benz, Model 280SL, A "Gray Model" Car ATTACHMT: Attached to Letter Dated 6/9/94 From John Womack to William L. Blake (A42; Part 581; 591; CSA S106 And Letter Dated 4/29/94 From William Blake To U.S. DOT TEXT: Gentlemen: Enclosed please find a copy of mine of April 29, 1994 to which I received no reply whatsoever. Please give me a call upon receipt of this letter and send me a reply in writing at your earliest convenience. Thank you for your cooperation. Yours very truly, Enclosure |
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ID: aiam1508OpenMr. George D. Green, Director of Sales, JacKnife Division, Breeze Corporations, Inc., 700 Liberty Avenue, Union, NJ 07083; Mr. George D. Green Director of Sales JacKnife Division Breeze Corporations Inc. 700 Liberty Avenue Union NJ 07083; Dear Mr. Green: This is in reply to your letter of May 8, 1974, asking whether person installing on a new vehicle a device called the Breeze Jacknife Control are required to certify the conformity of the vehicle to applicable motor vehicle safety standards. You indicate such a device would ordinarily be installed after the truck leaves the factory.; Persons who install components on or otherwise modify complete vehicles before their sale to a purchaser for a purpose other than resale may be vehicle alterers under NHTSA Certification regulations (49 CFR Parts 567, 568), and if so are required to certify that the vehicle as altered conforms to applicable standards by attaching to it a label containing specified information. A label must be attached when the alteration either involves components which are not readily attachable or whose installation renders invalid the vehicle's stated weight ratings. Modifications to a completed vehicle after its purchase for purposes other than resale, however, do not give rise to any certification or labeling requirements.; Copies of the Certification regulations and information on obtainin copies of all NHTSA requirements are enclosed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5613OpenMr. Dennis G. Moore President Sierra Products, Inc. 1113 Greenville Road Livermore, CA 94550; Mr. Dennis G. Moore President Sierra Products Inc. 1113 Greenville Road Livermore CA 94550; Dear Mr. Moore: This responds to your letter of July 31, 1995, wit respect to lens area requirements of amber turn signal lenses. You believe that 'by reducing the minimal area of the Amber Turn Signal light lens from 12 square inches to approximately 8 square inches or 6 square inches the U.S. would have more practical rules for U.S. Exports at no expense to Safety. You ask that, 'If NHTSA's Legal Council feels this error should be corrected through the Petitioning Process, I ask that this writing be considered a `Petition for Change of FMVSS; "108 Request''. Standard No. 108 contains two relevant regulations, on applicable to vehicles whose overall width is less than 80 inches, and one to those whose overall width is 80 inches or more. Under paragraph S5.1.1.26(a), the functional lighted lens area of a single turn signal lamp of either red or amber on a vehicle whose overall width is less than 80 inches shall be not less than 50 square centimeters. This is approximately 8 square inches. Therefore, no rulemaking is required to implement your recommendation. The standard that applies to turn signal lamps on vehicles whose overall width is 80 inches or more is SAE Standard J1395 APR85, incorporated by reference in Standard No. 108. Under its paragraph 5.3.2, the functional lighted lens area of a single turn signal lamp shall be at least 75 square centimeters, or approximately 12 square inches. Therefore, rulemaking is required to implement your recommendation. We are transmitting your letter to our Office of Safety Performance Standards for consideration as a petition for rulemaking to change the minimum lens area requirement for turn signal lamps on large vehicles from 75 to 50 square centimeters. On September 4, 1995, I determined that your letter met our procedural requirements for a petition. Accordingly, the Office of Safety Performance Standards will inform you not later than January 1, 1996, whether your petition has been granted. If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0920OpenMr. R. B. Smith, Finance Manager, Bluefield Mack Trucks, Inc., 536 Bluefield Avenue, Bluefield, West VA 2470l; Mr. R. B. Smith Finance Manager Bluefield Mack Trucks Inc. 536 Bluefield Avenue Bluefield West VA 2470l; Mr. R. B. Smith: This is in reply to your letter of November 17, 1972, requestin information on alteration, and installation of fifth wheels, on new trucks.; Persons who install fifth wheels on new trucks are generally considere to be 'final-stage manufacturers' under NHTSA Certification regulations, and are required to certify that vehicles on which they install the fifth wheel conform to applicable Federal standards. The NHTSA has recently proposed requirements regarding persons who alter completed vehicles, and a copy of this proposal is enclosed.; Copies of NHTSA requirements maybe obtained as indicated on th enclosure, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.' The regulations regarding the certification of motor vehicles are found at Parts 567 and 568 of Title 49 of the Code of Federal Regulations, (Item 1) and of the volume, 'Federal Motor Vehicle Safety Standards and Regulations' (Item 3).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0921OpenMr. R. B. Smith, Finance Manager, Bluefield Mack Trucks, Inc., 536 Bluefield Avenue, Bluefield, West VA 2470l; Mr. R. B. Smith Finance Manager Bluefield Mack Trucks Inc. 536 Bluefield Avenue Bluefield West VA 2470l; Mr. R. B. Smith: This is in reply to your letter of November 17, 1972, requestin information on alteration, and installation of fifth wheels, on new trucks.; Persons who install fifth wheels on new trucks are generally considere to be 'final-stage manufacturers' under NHTSA Certification regulations, and are required to certify that vehicles on which they install the fifth wheel conform to applicable Federal standards. The NHTSA has recently proposed requirements regarding persons who alter completed vehicles, and a copy of this proposal is enclosed.; Copies of NHTSA requirements maybe obtained as indicated on th enclosure, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.' The regulations regarding the certification of motor vehicles are found at Parts 567 and 568 of Title 49 of the Code of Federal Regulations, (Item 1) and of the volume, 'Federal Motor Vehicle Safety Standards and Regulations' (Item 3).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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.