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: aiam0929OpenMrs. Katherine C. Little, Edgewood Motorcycle Shop, 1711 Pulaski Highway, Edgewood, MD 21040; Mrs. Katherine C. Little Edgewood Motorcycle Shop 1711 Pulaski Highway Edgewood MD 21040; Dear Mrs. Little: This is in reply to your letter of November 30, 1972, asking if yo have to maintain a record of the tires you sell and register or is it sufficient to mail the requested information to the tire manufacturer or the tire manufacturer's designee.; Under Part 574.8 of the Tire Identification and Record Keepin regulation (49 CFR Part 574) a tire dealer is recorded to submit the required information to the tire manufacturer or his designee but is not required to keep a separate record of the tires sold.; Sincerely, David Schmeltzer, Assistant Chief Counsel |
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ID: aiam0694OpenMr. L. D. Brown, Manager Truck Tank Division, Renick & Mahoney Division, Garsite Products, Inc., 10 E. Grand Boulevard, Deer Park, L.I., NY 11729; Mr. L. D. Brown Manager Truck Tank Division Renick & Mahoney Division Garsite Products Inc. 10 E. Grand Boulevard Deer Park L.I. NY 11729; Dear Mr. Brown: We have received the pictures of the airport refuelers which yo manufacture. While these pictures were received after we had mailed our letter of April 17, 1972, to you, they confirm the opinion expressed in that letter that these vehicles are motor vehicles under the National Traffic and Motor Vehicle Safety Act, and are considered to be trucks under the Federal motor vehicle safety standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1332OpenMr. Adolph Kunasicwicz, 5644 Forest Avenue, Otter Lake, MI 48464; Mr. Adolph Kunasicwicz 5644 Forest Avenue Otter Lake MI 48464; Dear Mr. Kunasicwicz: Your request for information concerning the existence of penalties fo removal of the required certification label from a motor vehicle has been forwarded to us by the Federal Trade Commission.; The National Traffic and Motor Vehicle Safety Act requires that certification label, which under NHTSA regulations includes the name of the manufacturer and the date of manufacture, be permanently affixed to the motor vehicle. Although removal of this label does not carry a criminal penalty of either fine or imprisonment, a civil penalty of up to $1,000 is specified in certain situations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2641OpenMr. Samuel W. Alderson, President, Humanoid Systems, 747 East 223rd Street, Carson, CA 90745; Mr. Samuel W. Alderson President Humanoid Systems 747 East 223rd Street Carson CA 90745; Dear Mr. Alderson: This responds to your June 3, 1977, request for confirmation that 572.7(b) of Part 572, *Anthropomorphic Test Dummy* (49 CFR 572), specifies a minimum time period during which the pendulum used in testing may not reverse direction rather than an exact time.; Your interpretation is correct. The specification that the pendulu 'shall not reverse direction until T=123 ms' means that reverse travel must not occur earlier than 123 milliseconds after chordal displacement begins. The agency believes that this language can be improved and intends to clarify it at the next opportunity.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3244OpenMr. Robert G. Szabo, Van Ness, Feldman & Sutcliffe, Suite 500, 1220 Nineteenth Street, N.W., Washington, D.C. 20036; Mr. Robert G. Szabo Van Ness Feldman & Sutcliffe Suite 500 1220 Nineteenth Street N.W. Washington D.C. 20036; Dear Mr. Szabo: This responds to your recent letter requesting information concernin the legal ramifications of converting motor vehicles fuel systems to operate on both gasoline and compressed gas. I am enclosing a copy of a letter the agency issued last year which discussed the Federal law concerning auxiliary gasoline tanks and the conversion of gasoline-powered vehicles to propane. The discussion in that letter should answer all of your questions. If, however, you require more information, please contact Hugh Oates of my office at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2176OpenMr. Jack Gromer, Timpte, Inc., 5990 N. Washington Street, Denver, CO 80216; Mr. Jack Gromer Timpte Inc. 5990 N. Washington Street Denver CO 80216; Dear Mr. Gromer: This responds to Timpte's December 10, 1975, question whethe modification of a certified trailer prior to retail sale constitutes the manufacture of a vehicle subject to applicable safety standards such as Standard No. 121, *Air Brake Systems*.; The answer to your question is no. From your description, it appear that the proposed modification would be an alteration of a certified vehicle subject to S 567.7 of NHTSA certification regulations (49 CFR S 567.7) (copy enclosed). Under that section, conformity of the vehicle as altered need only be to standards in effect at the time the originally certified trailer was manufactured.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2160OpenMr. Jack Gromer, Timpte, Inc., 5990 N. Washington Street, Denver, CO 80216; Mr. Jack Gromer Timpte Inc. 5990 N. Washington Street Denver CO 80216; Dear Mr. Gromer: This responds to Timpte's December 10, 1975, question whethe modification of a certified trailer prior to retail sale constitutes the manufacture of a vehicle subject to applicable safety standards such as Standard No. 121, *Air Brake Systems*.; The answer to your question is no. From your description, it appear that the proposed modification would be an alteration of a certified vehicle subject to S 567.7 of NHTSA certification regulations (49 CFR S 567.7) (copy enclosed). Under that section, conformity of the vehicle as altered need only be to standards in effect at the time the originally certified trailer was manufactured.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1665OpenMs. Joan M. Markey, Rogers and Wells, 200 Park Avenue, New York, NY 10017; Ms. Joan M. Markey Rogers and Wells 200 Park Avenue New York NY 10017; Dear Ms. Markey: This is in response to the October 22, 1974 letter from Mr. James L Warren inquiring as to the existence of any Federal safety regulations requiring that a warning against welding be affixed to motor vehicle fuel tanks.; This agency has promulgated no regulation requiring manufacturers t affix a label to the fuel tanks of their vehicles warning against welding. A safety standard does exist which establishes performance levels of fuel systems (49 CFR 571.301). However, the standard's requirements focus on the strength and durability of the system and do not include requirements for labeling.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1285OpenWilliam C. Burns, Esq., Schultz, Evans and Burns, P.O. Box 1493, Lafayette Bank and Trust Builidng(sic), Lafayette, Indiana 47902; William C. Burns Esq. Schultz Evans and Burns P.O. Box 1493 Lafayette Bank and Trust Builidng(sic) Lafayette Indiana 47902; Dear Mr. Burns: This is in reply to your letter of September 28, 1973 to Secretar Brinegar, concerning outside rear view mirrors.; The existing standard (No. 111) on *Rearview Mirrors*, is found i Title 49, Code of Federal Regulations S 571.111. Paragraph S3.2 established requirements for outside mirrors. This standard applies to all passenger cars and multipurpose passenger vehicles manufactured since January 1, 1968, and establishes requirements for original equipment mirrors. It does not apply to mirrors manufactured for the aftermarket.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0017OpenMr. Michael Maher President Association of Trial Lawyers of America 1050 31st Street, N.W. Washington, D.C. 20007; Mr. Michael Maher President Association of Trial Lawyers of America 1050 31st Street N.W. Washington D.C. 20007; Dear Mr. Maher: This responds to your letter of April 19, 199 concerning what you consider faulty windshield replacement. You ask that this agency state that the 'render inoperative' provision of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(a)) 'will be applied to replacement of damaged windows.' The agency addressed this issue recently in a letter to Mr. James E. Rooks, Jr., of your staff. For your convenience, I am enclosing a copy of that May 29, 1991 letter. I hope that this information is useful. If you have any further questions, please contact John Rigby of this office at 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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.