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: aiam1839OpenMr. H. W. Gerth, Assistant Vice President, Mercedes-Benz of North America, Inc., One Mercedes Drive, Montvale, NJ 07645; Mr. H. W. Gerth Assistant Vice President Mercedes-Benz of North America Inc. One Mercedes Drive Montvale NJ 07645; Dear Mr. Gerth: This is in response to your letter of March 3, 1975, requestin approval of your proposed owner notification letter for your defect notification campaign (NHTSA No. 75-0005) involving the front wheel bearings on some model L1113 trucks.; The letter which you propose sending to owners of the subject vehicle satisfactorily meets the requirements of the National Traffic and Motor Vehicle Safety Act of 1966, as amended. Based on the information provided by you, your plan of notification appears to be adequate.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam1240OpenMr. Pundalik K. Kamath, Senior Safety Engineer, Oshkosh Truck Corporation, P.O. Box 560, Oshkosh, WI 54901; Mr. Pundalik K. Kamath Senior Safety Engineer Oshkosh Truck Corporation P.O. Box 560 Oshkosh WI 54901; Dear Mr. Kamath:This is in reply to your letter of August 6, 1973, i which you inquire whether incomplete vehicles manufactured before the effective date of Motor Vehicle Safety Standard No. 121, 'Air Brake Systems,' (September 1, 1974) must conform to the standard. You ask further whether complete vehicles manufactured from these incomplete vehicles must conform if they are completed after the effective date of the standard.; Incomplete vehicles manufactured before the effective date of Moto Vehicle Safety Standard No. 121 need not conform to that standard, and complete vehicles manufactured from those incomplete vehicles also need not conform to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1603OpenRobert Gonce, Esq., O'Bannon & Gonce, 402 South Pine Street, Florence, Alabama 35630; Robert Gonce Esq. O'Bannon & Gonce 402 South Pine Street Florence Alabama 35630; Dear Mr. Gonce: #In response to your request I have enclosed a copy o Federal Motor vehicle Safety Standard No. 109, new Pneumatic Tires (49 CFR S571.109) as it appears in the current edition of the *Code of Federal Regulations.* #The table listing load and inflation values for the G78-15 tire size designation is Table I-J of Appendix A. Except for the addition of test loads at 16 and 18 psi, the load and inflation information for the G78-15 tire size designation has not changed since the first publication of the information on April 18, 1968 (33 FR 5949), a copy of which is also enclosed. #Yours truly, Richard B. Dyson, Acting Chief Counsel; |
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ID: aiam0256OpenMr. C. L. Hale, Staff Engineer, American Honda Motor Company, Inc., P.O. Box 50, 100 W. Alondra Boulevard, Gardena, CA 90247; Mr. C. L. Hale Staff Engineer American Honda Motor Company Inc. P.O. Box 50 100 W. Alondra Boulevard Gardena CA 90247; Dear Mr. Hale:#Douglas W. Toms has asked me to reply to your letter o September 8 which requests confirmation 'that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour'.#We cannot confirm this interpretation of S3.1.2 of Motor Vehicle Safety Standard No. 102 (Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect). The phrase at vehicle speeds below 25 miles per hour' in that section is inclusive, it means at *all* speeds below 25 miles per hour, and not at *a* speed.#Sincerely, Lawrence R. Schneider, Acting Deputy Chief Counsel; |
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ID: aiam0547OpenMr. Thomas E. Toney, III, Fordyce, Wayne, Hartman, Renard & Stribling, Attorneys and Counselors, 818 Olive Street, Saint Louis, MO 63101; Mr. Thomas E. Toney III Fordyce Wayne Hartman Renard & Stribling Attorneys and Counselors 818 Olive Street Saint Louis MO 63101; Dear Mr. Toney: This is in reply to your letter of October 10, 1972, requestin information on requirements applicable to the trucking industry regarding the reporting of numbers of vehicles produced. You also ask whether a person who adds a fifth wheel to complete a truck is a manufacturer who is subject to the requirements.; Section 573.5(5) of NHTSA 'Defects Reports' regulation (49 CFR Par 573) requires manufacturers of motor vehicles to report, on a quarterly basis, the total number of the manufacturer's vehicles by make, model, and model year, if appropriate, produced or imported during that quarter. This requirement applies to all manufacturers of complete or incomplete motor vehicles, including manufacturers of trucks. A person who adds a fifth wheel to an incomplete vehicle and completes the vehicle is considered to be a manufacturer under section 573.3 of the regulation, and is required to report production figures as part of his quarterly reports.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0553OpenMr. Thomas E. Toney, III, Fordyce, Wayne, Hartman, Renard & Stribling, Attorneys and Counselors, 818 Olive Street, Saint Louis, MO 63101; Mr. Thomas E. Toney III Fordyce Wayne Hartman Renard & Stribling Attorneys and Counselors 818 Olive Street Saint Louis MO 63101; Dear Mr. Toney: This is in reply to your letter of October 10, 1972, requestin information on requirements applicable to the trucking industry regarding the reporting of numbers of vehicles produced. You also ask whether a person who adds a fifth wheel to complete a truck is a manufacturer who is subject to the requirements.; Section 573.5(5) of NHTSA 'Defects Reports' regulation (49 CFR Par 573) requires manufacturers of motor vehicles to report, on a quarterly basis, the total number of the manufacturer's vehicles by make, model, and model year, if appropriate, produced or imported during that quarter. This requirement applies to all manufacturers of complete or incomplete motor vehicles, including manufacturers of trucks. A person who adds a fifth wheel to an incomplete vehicle and completes the vehicle is considered to be a manufacturer under section 573.3 of the regulation, and is required to report production figures as part of his quarterly reports.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0167OpenMr. W. D. Beamer, General Claim Agent, The Cleveland, Columbus, and Cincinnati Highway, Inc., 213 Euclid Avenue, Cleveland, OH 44114; Mr. W. D. Beamer General Claim Agent The Cleveland Columbus and Cincinnati Highway Inc. 213 Euclid Avenue Cleveland OH 44114; Dear Mr. Beamer: Your letter of June 17, 1969, to Mr. Donald Morrison of the Bureau o Motor Carrier Safety, concerning switching arrangements for running lamps, has been transferred to this Office for consideration and reply.; Enclosed for your information is a copy of Federal Motor Vehicle Safet Standard No. 108 on lighting requirements for motor vehicles. This standard is applicable to new vehicles manufactured on or after the effective date of January 1, 1969. Special wiring requirements, such as lamp switching arrangements, are included in paragraphs S3.4 through S3.4.7 of the standard.; We do not completely understand your usage of the term 'runnin lights.' If you are referring only to tail lamps, your attention is invited specifically to paragraph S3.4.3 of the standard which is quoted as follows: 'As a minimum the tail lamps shall be illuminated when the headlamps are illuminated except when the headlamps are being flashed.' The switching arrangements for other 'running lights,' such as clearance lamps and identification lamps, are at the option of the vehicle manufacturer.; Thank you for writing. Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam0948OpenMr. Edward L. Hawes, President, Hawes Industries, Inc., 1651 E. 9 Mile Road, Hazel Park, Michigan 48030; Mr. Edward L. Hawes President Hawes Industries Inc. 1651 E. 9 Mile Road Hazel Park Michigan 48030; Dear Mr. Hawes: This is in response to your letter of December 7, 1972, regardin Standard 125, Warning Devices. I am sorry that you misunderstood our previous letter of November 27, 1972. We believe that the standard clearly permits the manufacture and sale of your device, for the reasons already discussed, and therefore an amendment is unnecessary. If you still have questions on this matter, do not hesitate to call me.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0299OpenMr. Paul A. Tatarski, Manager Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC, 20015; Mr. Paul A. Tatarski Manager Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Tatarski: This is in reply to your letter of February 23, 1971, to Mr. Julian E Leysath of this office requesting an interpretation on the mounting location of rear clearance lamps on slant-sided beverage truck bodies.; Rear clearance lamps mounted on the outermost top corners of the body as indicated on the TBEA diagram, adequately meet the location requirements of Federal Motor Vehicle Safety Standard No. 108.; Sincerely, Roger H. Compton, Director, Office of Operating Systems Motor Vehicle Programs; |
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ID: aiam1553OpenMr. John W. Lolley, Lolley's Inc., Long Hill Road, Gray, ME 04039; Mr. John W. Lolley Lolley's Inc. Long Hill Road Gray ME 04039; Dear Mr. Lolley: Thank you for your letter of July 15, 1974, concerning you responsibilities as a manufacturer.; Since you shorten frames and mount fifth wheels on new trucks, you ar either an intermediate or final stage manufacturer. I have enclosed Parts 566, 567, 568, and 573 for your information. In addition, I have enclosed a form, entitled 'Federal Motor Vehicle Safety Standards and Regulations' that will enable you to obtain these documents.; If you have any questions on the above, please write me or call Mr David Fay, of my staff, on (202) 426-2817.; Sincerely, Roger H. Compton, Director, Engineering Systems Staff, Moto Vehicle Programs; |
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.