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: aiam0805OpenMr. Rex A. Williams, Ryder System, Incorporated, Post Office Box 816, 2701 South Bayshore Drive, Miami, FL 33133; Mr. Rex A. Williams Ryder System Incorporated Post Office Box 816 2701 South Bayshore Drive Miami FL 33133; Dear Mr. Williams: This is in response to your letter of July 20, 1972, concernin regulations governing the mounting of truck bodies and fifth wheels. Persons who perform these operations on new vehicles are generally considered to be final-stage manufacturers under NHTSA regulations and are required to certify that the completed vehicle conforms to all Federal motor vehicle safety standards.; The requirements for certification are codified at Title 49, Code o Federal Regulations, Parts 567, 568. Copies of these and other NHTSA requirements are available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. The material should be ordered under the title, *Federal Motor Vehicle Safety Standards*. The cost, which must be prepaid, is $8.00, which includes amendments for one year. Checks should be payable to the Superintendent of Documents. Regulations regarding the Certification of completed motor vehicles are found at Parts 567 and 568 of the volume.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0802OpenMr. Rex A. Williams, Ryder System, Incorporated, Post Office Box 816, 2701 South Bayshore Drive, Miami, FL 33133; Mr. Rex A. Williams Ryder System Incorporated Post Office Box 816 2701 South Bayshore Drive Miami FL 33133; Dear Mr. Williams: This is in response to your letter of July 20, 1972, concernin regulations governing the mounting of truck bodies and fifth wheels. Persons who perform these operations on new vehicles are generally considered to be final-stage manufacturers under NHTSA regulations and are required to certify that the completed vehicle conforms to all Federal motor vehicle safety standards.; The requirements for certification are codified at Title 49, Code o Federal Regulations, Parts 567, 568. Copies of these and other NHTSA requirements are available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. The material should be ordered under the title, *Federal Motor Vehicle Safety Standards*. The cost, which must be prepaid, is $8.00, which includes amendments for one year. Checks should be payable to the Superintendent of Documents. Regulations regarding the Certification of completed motor vehicles are found at Parts 567 and 568 of the volume.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5175OpenMr. Jim Keizer 1504 Locust Street Hull, IA 51239; Mr. Jim Keizer 1504 Locust Street Hull IA 51239; Dear Mr. Keizer: This responds to your letter of April 13, 1993 requesting information on the legal responsibilities of businesses that repack or replace air bags in automobiles. I am enclosing copies of five letters which address various issues related to replacement or repair of air bags. The January 19, 1990, letter to Ms. Linda L. Conrad addresses the issue of possible legal obligations to repair a deployed air bag following a collision. The May 13, 1991, and June 11, 1991, letters to Mr. Stephen Mamakas address issues specifically related to the repair of deployed air bags. The March 26, 1993, letters to Mr. Steven C. Friedman and Mr. Jay Lee address issues related to retrofit or replacement air bags. I have also enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures; |
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ID: aiam4503OpenMr. Robert Cuzzi Breda Transportation, Inc. 275 Madison Avenue, Suite 1711 New York, NY 10016; Mr. Robert Cuzzi Breda Transportation Inc. 275 Madison Avenue Suite 1711 New York NY 10016; Dear Mr. Cuzzi: This responds to your letter asking whether buses wit a gross vehicle weight rating (GVWR) greater than 10,000 pounds are excluded from coverage under Federal Motor Vehicle Safety Standard No. 301, Fuel System Integrity. I regret the delay in responding to your letter. The answer to your question is yes. Safety Standard No. 301 applies to new passenger cars, multipurpose passenger vehicles, trucks, and buses having a GVWR of 10,000 pounds or less and to all new school buses. The buses you manufacture for sale as municipal transit buses are excluded from Standard No. 301 because their GVWR is greater than the 10,000 pound limit established for the standard. You asked also whether there are any other Federal standards that might apply to the fuel tanks on your transit buses. I have forwarded a copy of your letter to the Federal Highway Administration (FHWA) and the Urban Mass Transit Administration (UMTA) for their direct reply as to the applicability of any FHWA or UMTA regulations to your transit vehicles. You might also contact the Environmental Protection Agency (EPA) to see whether that agency has any requirements affecting the fuel tanks on your buses. The general telephone number for the EPA is (202) 382-2090. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam5231OpenMr. James N. Doan Counsel - Operations Eaton Corporation Eaton Center Cleveland, OH 44114-2584; Mr. James N. Doan Counsel - Operations Eaton Corporation Eaton Center Cleveland OH 44114-2584; Dear Mr. Doan: This responds to your request for an interpretation o Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. You asked whether an automatic vehicle speed control (also known as a cruise control), that you describe as 'mounted on the transmission shift lever,' must be illuminated. As explained below, the answer is no. S5.3.1 sets requirements concerning controls which must be illuminated. S5.3.1 excludes from the illumination requirements hand operated controls that are mounted on the floor, floor console or steering column. You believe that your proposed control would be considered 'mounted on the floor or floor console' and thus excluded from S5.3.1's illumination requirements. We agree that locating the control on the shift lever is similar to locating it on the floor console for the purposes of the illumination requirements. This interpretation is based on agency precedent concerning S5.3.1's exception for controls on steering columns. In the preamble to a final rule of May 4, 1971 (36 FR 8296), NHTSA determined that the exception for controls mounted on the steering column extends to controls mounted on the steering wheel. Since the transmission shift lever bears the same relationship to the floor console as does the steering wheel to the steering column, controls on the transmission shift lever are excepted from S5.3.1's illumination requirements. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure; |
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ID: aiam4832OpenMr. Billy S. Peterson President Automotive Safety Testing, Inc. at TRC of Ohio, Bldg. 20 Rd. 152 & SR 33 East Liberty, OH 43319; Mr. Billy S. Peterson President Automotive Safety Testing Inc. at TRC of Ohio Bldg. 20 Rd. 152 & SR 33 East Liberty OH 43319; Dear Mr. Peterson: This is in reply to your letter of February 7, l99l to the Office of Chief Counsel asking for a clarification of allowable mounting locations and photometric output requirements for tail/stop lamps on passenger cars. One of your clients wishes to mount 'two-part' stop/tail lamps 'so that one lamp is mounted on the fixed quarter panel and a duplicate lamp is mounted on the trunk lid.' Each part of the two-part lamp is a combination tail/stop lamp. You have asked whether the minimum photometric requirements must be met by 'the lamp mounted to the quarter panel or may the portion mounted on the trunk lid count toward the photometric requirements.' Your 'two-part lamp' would be treated as two separate lamps. For purposes of compliance, only one of these two adjacent lamps must be designed to conform to Standard No. 108, and this conformance must be independent of any 'contribution' by the adjacent lamp. Although Standard No. 108 permits either the deck or the body mounted lamp to be the complying lamp, it would be our preference that the body mounted lamp be the one that complies, so that the benefit of a conforming stop/tail lamp would be realized during those occasions when the lid may be raised. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam2818OpenMr. Frank B. Caristia, Christy Electronics, Inc., 51 East 42nd Street, New York NY 10017; Mr. Frank B. Caristia Christy Electronics Inc. 51 East 42nd Street New York NY 10017; Dear Mr. Caristia: We are forwarding your letter of May 31, 1978 to the National Highwa Traffic Safety Administration's Office of Crash Avoidance in Washington D.C. for their review and action.; Sincerely, Irving Rodness, Motor Vehicle Program Specialist |
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ID: aiam0777OpenMr. J. A. Westphal, Senior Staff Engineer, FWD Corporation, Clintonville, WI, 54929; Mr. J. A. Westphal Senior Staff Engineer FWD Corporation Clintonville WI 54929; Dear Mr. Westphal: This is in reply to your letter of July 7, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', as to mattress assemblies.; Paragraph S4.1 of Standard No. 302 lists mattress covers only. Thi does not include the complete mattress assembly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5056OpenMr. Preston Golder Road Reflectors P.O. Box 493 Farmingville, N.Y. 11738; Mr. Preston Golder Road Reflectors P.O. Box 493 Farmingville N.Y. 11738; Dear Mr. Golder: This responds to your letter of September 14, 1992 asking about the legality under Federal law of your 'Auto Neon System', an accessory which reflects a glow from under the vehicle. We answered an inquiry from Mr. Allan Schwartz about a similar device, in a letter dated April 21, 1992. I enclose a copy of our response to Mr. Schwartz for your information. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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ID: aiam1230OpenMr. Richard Kuskin, Multinational Industries, P.O. Box 2263, South Station, Newark, NJ 07114; Mr. Richard Kuskin Multinational Industries P.O. Box 2263 South Station Newark NJ 07114; Dear Mr. Kuskin: This is in reply to your letter of July 12, 1973, concerning gas tan caps. You state that you are considering marketing imported gas tank caps for trucks, and you want to know whether there is a Federal standard to which such caps must conform. The answer is that there is not.; 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.