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: aiam0027OpenMr. J. Lombard,Commercial Manager,S.I.C.A Peugeot,75 Avenue de la Grande Armee,Paris 16,France; Mr. J. Lombard Commercial Manager S.I.C.A Peugeot 75 Avenue de la Grande Armee Paris 16 France; Dear Mr. Lombard:#Thank you for your letter of April 20, 1967 concerning the clarification of several requirements of Motor Vehicle Safety Standard No. 105.#The bulb for the emergency brake system effectiveness indicator may also be used for the hand brake indicator light. Further, the means for establishing the electrical contact for testing the emergency system indicator bulb may be the hand brake lever.#This clarification is not considered as a change in the requirements of the standard sa issued. All characteristics required for the indicator light must be met.# Sincerely, George C. Nield,Acting Director,Motor Vehicle Safety Performance Service; |
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ID: aiam1551OpenMr. Jack F. Bryson, Manager, Marketing & Industrial Relations, Elgin Sweeper Company, 1300 West Bartlett Road, Elgin, IL 60120; Mr. Jack F. Bryson Manager Marketing & Industrial Relations Elgin Sweeper Company 1300 West Bartlett Road Elgin IL 60120; Dear Mr. Bryson: This is in reply to your letter of June 7, 1974, asking whether NHTS Certification requirements (49 CFR Parts 567, 568) apply to the mounting of a device called the Elgin Eductor on a used truck.; The NHTSA does not consider the Certification requirements to apply t the mounting of a new truck body (based on the information you provide, this includes the Elgin eductor) on a used truck chassis. We consider additions to used chassis to be used vehicles under the National Traffic and Motor Vehicle Safety Act, and no certification is therefore required.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1278OpenMr. Donald Gary Hayes, Robertson Tank Lines Inc., P. O. Box 1505, Houston, TX 77001; Mr. Donald Gary Hayes Robertson Tank Lines Inc. P. O. Box 1505 Houston TX 77001; Dear Mr. Hayes: This is in reply to your letter of August 30, 1973, requesting a DO code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.; Any tires retreaded by and solely for use by Robertson Tank Lines ar exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to any Federal motor vehicle safety standard, you are also not required to place a 'DOT' symbol on them. If you retread passenger car tires, however, you are required to place a 'DOT' symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0146OpenMr. Sam W. Folsom, Jr., Gold Cross Ambulance Service, Inc., 304 Northwest Tenth, Oklahoma City, OK 73103; Mr. Sam W. Folsom Jr. Gold Cross Ambulance Service Inc. 304 Northwest Tenth Oklahoma City OK 73103; Dear Mr. Folsom: This is in reply to your letter of January 18, 1969, to Dr. Willia Haddon, Jr., requesting information on Federal Motor Vehicle Safety Standards (FMVSS) applicable to ambulances.; If the ambulance is built on a passenger car chassis, all of the FMVS applicable to passenger cars would apply. However, if the ambulance is built on a truck chassis, the FMVSS applicable to multi-purpose passenger vehicles would apply. There have been no special exceptions granted for ambulances.; Enclosed for your information and guidance are copies of the Nationa Traffic and Motor Vehicle Safety Act of 1966 and the FMVSS established thereunder.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service; |
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ID: aiam1277OpenMr. Donald Gary Hayes, Robertson Tank Lines Inc., P.O. Box 1505, Houston, Texas 77001; Mr. Donald Gary Hayes Robertson Tank Lines Inc. P.O. Box 1505 Houston Texas 77001; Dear Mr. Hayes: This is in reply to your letter of August 30, 1973, requesting a DO code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.; Any tires retreaded by and solely for use by Robertson Tank Lines ar exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to and Federal motor vehicle safety standard, you are also not required to place a 'DOT' symbol on them. If you retread passenger car tires, however, you are required to place a 'DOT' symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).; Yours truly, Richard B, Dyson, Assistant Chief Counsel |
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ID: aiam0096OpenHerr A. Hammerstein, Robert Bosch GMBH, 700 Stuttgart 1, Germany; Herr A. Hammerstein Robert Bosch GMBH 700 Stuttgart 1 Germany; >>>Ref: A/B GE 3 Hn/Ra<<< Dear Mr. Hammerstein: The Bureau of Customs has forwarded to us for further reply a copy o your letter to them of May 21 asking whether lighting units for passenger cars, which do not conform to the requirements of Federal motor vehicle safety standard 108, may be admitted to the United States after January 1, 1969.; Amended Federal standard No. 108, effective January 1, 1969, specifie lighting requirements for various categories of motor vehicles including passenger cars manufactured on or after that date. It does not specify requirements for individual items of lighting equipment. This means that these individual items, no matter what the date of manufacture, may be imported into the United States after January 1, 1969, because they will have been manufactured on a date when there were no standards in effect applicable to them.; I hope this answers your question. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam1443OpenMr. Dick Umphrey, Director of Marketing, American Bumper Sales Company, 1150 E. Slauson Avenue, Los Angeles, CA 90011; Mr. Dick Umphrey Director of Marketing American Bumper Sales Company 1150 E. Slauson Avenue Los Angeles CA 90011; Dear Mr. Umphrey: This is in reply to your letter of January 29, 1974, concerning th effect of the rules issued under the Motor Vehicle Information and Cost Savings Act upon the manufacture of after-market pickup truck bumpers.; If your sales are confined to the after-market, it is unlikely that an rules issued under the Act will affect you directly. At present, the bumper standard proposed under Title I of the Act would apply only to passenger cars. If other types of vehicles are subsequently included, the rules would affect you only insofar as they may affect the design of the vehicles on which your bumpers would be mounted.; The rule to be issued by February 1, 1975, relates only to insuranc costs and would have little or no effect on your business.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1143OpenMr. Donald W. Taylor, Volvo of America Corp., Rockleigh, New Jersey 07647; Mr. Donald W. Taylor Volvo of America Corp. Rockleigh New Jersey 07647; Dear Mr. Taylor: This is in reply to your letter of May 8, 1973, concerning the inten of section S4.7 of the amendment of Motor Vehicle Safety Standard No. 201 proposed by the notice of September 25, 1970. Although we have recently issued a notice advising the public that we intend to issue a further proposal on this subject before adopting a final rule, we can provide a brief explanation of the intent of Section S4.7.; The principal portions ofthe(sic) 'A' and 'B' pillars to which S4.7 wa directed, are those portions lying above the low line of the vehicle's window. However, the breadth of S4.7 is such that it would also include all contactable areas of the pillars lying below the window line.; You will have further opportunity to comment on the use of forc distributing materials and response to the rulemaking of Standard 201.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0046OpenMr. Roger K. Howsmon, American Quality Coach Corporation, P.O. Box 1348, Blytheville, AR 72315; Mr. Roger K. Howsmon American Quality Coach Corporation P.O. Box 1348 Blytheville AR 72315; Dear Mr. Howsman (sic): Thank you for your letter of January 8, 1968, to the Federal Highwa Administration, requesting regulations relating to motor vehicle safety requirements.; The type of vehicle that you have described appears to be a bu accordingly (sic) to the statutory meaning of Part 255.3, Initial Federal Motor Vehicle Safety Standards. Accordingly, Standards 102, 107, 205 and 209 would be applicable to your vehicles manufactured after January 1, 1968. We invite your attention to Section 114 of Public Law 89-563 and the notice of Certification Requirement.; In addition to the existing Federal Motor Vehicle Safety Standards an Public Law 89-563, we are enclosing information concerning proposed rule making that may affect future regulations.; We trust this information will be of assistance to you. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam3522OpenMr. Thomas J. Hagarty, Halloran, Sage, Phelon & Hagerty, One Financial Plaza, Hartford, CT 06103; Mr. Thomas J. Hagarty Halloran Sage Phelon & Hagerty One Financial Plaza Hartford CT 06103; Dear Mr. Hagarty: This responds to your recent letter asking whether Safety Standard No 301, *Fuel System Integrity*, includes specifications for *fixed* barrier rear-end crash test.; The answer to your question is no. Standard No. 301 specifies rear-end crash test, but the test involves a moving barrier, not a fixed barrier. On August 29, 1970, the agency did propose a fixed barrier rear-end crash test for Standard No. 301 (35 FR 13799). However, that proposal was never made final. Rather, On August 20, 1973, the agency issued another proposal which specified a moving barrier for the rear-end crash test (38 FR 22417). This proposal was finalized and is the rule which is in existence today. I am enclosing copies of these *Federal Register* notices for your information, as well as a copy of Standard No. 301.; I hope this has answered all your questions. Sincerely, Frank Berndt, 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.