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: aiam0572OpenMr. Bob Lockwood, Enterprise Sky Park, Tarmac Road, Redding, California 96001; Mr. Bob Lockwood Enterprise Sky Park Tarmac Road Redding California 96001; Dear Mr. Lockwood: This is in reply to your letter of January 20, 1972, regardin standards for retreaded automobile and truck tires.; Federal motor vehicle safety standards do not apply to aircraft o aircraft equipment.; Standard No. 117 entitles 'Retreaded Pneumatic Tires - Passenger Cars, does not apply to the retreading of aircraft tires and does not supersede Advisory Circular 43.13-1. A copy of the standard is enclosed.; We do not have a safety standard for retreaded truck tires at thi time.; Thank you for your inquiry. Sincerely, E.T. Driver, Director, Office of Operating systems, Moto Vehicle Programs; |
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ID: aiam0425OpenMr. 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 August 12 asking for a clarificatio of the effect of the recent firefighting vehicle amendment (36 F.R. 13926) on Federal standards published prior to September 1, 1971, but effective after that date.; Specifically you ask whether Standard No. 302, *Flammability o Interior Materials*, published on January 8, 1971, applies to firefighting vehicles on September 1, 1972, or September 1, 1974.; The firefighting vehicle amendment is effective September 1, 1971, an has no effect upon standards or amendments to standards issued before that date. Thus Standard No. 302 applies to firefighting vehicles as of September 1, 1972.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2207OpenMr. Arlen E. Riggs, Legal Manager, Peterbilt Motors Company, 38801 Cherry Street, P.O. Box 404, Newark, CA, 94560; Mr. Arlen E. Riggs Legal Manager Peterbilt Motors Company 38801 Cherry Street P.O. Box 404 Newark CA 94560; Dear Mr. Riggs: This is in reply to your letter of February 6, 1976, asking whether i would violate Standard No. 108 to wire truck tractors to permit 'the customers to activate the truck trailer tail lamps when the tractor marker lamps are activated rather than when the headlamps are activated.'; S4.5.3 of Standard No. 108 which requires the tail lamps to b illuminated when the headlamps are activated applies only to single motor vehicles and not combinations thereof. Therefore we confirm your understanding that the wiring circuitry you propose to install will not violate Standard No. 108.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1436OpenMr. E. T. Linkous, Western Auto Associate Store, Kenale Shopping Cener(sic), Sanford, North Carolina 27330; Mr. E. T. Linkous Western Auto Associate Store Kenale Shopping Cener(sic) Sanford North Carolina 27330; Dear Mr. Linkous: This responds to your request for information on Standard 119, *Ne pneumatic tires for vehicles other than passenger cars,* and on a 'Petition No.2' concerning exemption of 'Mopeds' from the motor cycle regulatory category.; Standard 119 applies to tires, not vehicles, and therefore it regulate only the manufacturer of the tire, not a retailer of vehicles like yourself.; The 'Petition No. 2' to which you refer was files by Mr. Robert Smit of Ohio Bikes, 631 Broad Street, Columbus, Ohio 43215, asking for a redefinition of 'motorcycle' to exclude Moped-type vehicles, and a change in the lighting standard to exclude Moped-type vehicles from he present motorcycle requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1375OpenMr. Joshua E. Bruner, Rogue Racing, 1858 East 3rd Street, Tempe, AZ 85281; Mr. Joshua E. Bruner Rogue Racing 1858 East 3rd Street Tempe AZ 85281; Dear Mr. Bruner: Dr. Gregory asked me to respond to your January 3, 1974, letter askin whether the National Highway Traffic Safety Administration proposal to modify the definition of Multipurpose Passenger Vehicle would affect importation of The Thing.; The proposed modification would reclassify vehicles like The Thing a passenger vehicles, but it would not prohibit their importation. Volkswagen would have to incorporate several additional safety features in The Thing to meet the higher standards for passenger cars.; We have not made a final decision on the proposed redefinition Volkswagen as the manufacturer of The Thing might be able to give you a better evaluation of The Thing's future than we have at present.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1333OpenMr. Charles R. Mosley, Chief of Police, Cleveland Police Department, Cleveland, MS 38732; Mr. Charles R. Mosley Chief of Police Cleveland Police Department Cleveland MS 38732; Dear Mr. Mosley: Your correspondence of October 17, 1973, on the subject of approval fo motorcycle helmets has been forwarded to this office for reply.; I am enclosing, for your information, a copy of Federal Motor Vehicl Safety Standard No. 218, which establishes requirements for motorcycle helmets effective March 1, 1974. The requirements of this standard will take precedence over other standards which cover like aspects of safety, pursuant to the National Traffic and Motor Vehicle Safety Act of 1966. There will be no list of 'approved' helmets, since all helmets manufactured for sale in the United States on or after the effective date must be certified to meet all requirements of the standard.; I trust the foregoing will be helpful. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0470OpenMr. James A. Skinner, REBCO, 8000 Branch Avenue, Clinton, MD 20735; Mr. James A. Skinner REBCO 8000 Branch Avenue Clinton MD 20735; Dear Mr. Skinner: This is in reply to your letter of October 24, 1971, concerning th retention of records of the names and addresses of first purchasers of retread tires that you manufactured prior to October 13, 1971, the date you went out of the retread business.; Under the Tire Identification and Record Keeping Regulation you ar required to maintain the names of first purchasers three years from the time the sale is reported to you or your designee. Therefore, as to those tires manufactured between May 22, 1971 and the date you went out of business, October 24, 1971, you are required to maintain, or have maintained for you the names and addresses of the first purchasers for three years after this information is recorded by you or your designee.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4540OpenMr. Mamoru Arisaka Manager, Automotive Lighting Homologation Sect. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, JAPAN; Mr. Mamoru Arisaka Manager Automotive Lighting Homologation Sect. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 JAPAN; Dear Mr. Arisaka: This is in reply to your letter of July 7, 1988, wit respect to a motorcycle lighting device called the 'rolling headlamp.' The headlamp is designed to have its vertical plane always perpendicular to the ground regardless of the inclination of the motorcycle. You have asked whether such a device is legally permissible. Motor Vehicle Safety Standard No. 108 does not prohibit alteration of the mounting angle of a headlamp. Although paragraph S4.3.1 requires each lamp to 'be securely mounted on a rigid part of the vehicle,' your lamp appears to be 'securely mounted' even if it is able to rotate. I hope this answers your question. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam1335OpenMr. Charles R. Mosley, Chief of Police, Cleveland Police Department, Cleveland, MS 38732; Mr. Charles R. Mosley Chief of Police Cleveland Police Department Cleveland MS 38732; Dear Mr. Mosley: Your correspondence of October 17, 1973, on the subject of approval fo motorcycle helmets has been forwarded to this office for reply.; I am enclosing, for your information, a copy of Federal Motor Vehicl Safety Standard No. 218, which establishes requirements for motorcycle helmets effective March 1, 1974. The requirements of this standard will take precedence over other standards which cover like aspects of safety, pursuant to the National Traffic and Motor Vehicle Safety Act of 1966. There will be no list of 'approved' helmets, since all helmets manufactured for sale in the United States on or after the effective date must be certified to meet all requirements of the standard.; I trust the foregoing will be helpful. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2700OpenMr. David R. Sapp, Assistant General Counsel, Texas Automobile Dealers Association, 1108 Lavaca, P.O. Box 1028, Austin, TX 78767; Mr. David R. Sapp Assistant General Counsel Texas Automobile Dealers Association 1108 Lavaca P.O. Box 1028 Austin TX 78767; Dear Mr. Sapp: This responds to your October 5, 1977, letter requesting a furthe clarification of our interpretation given to you on September 1, 1977, concerning 'kit cars.'; You ask whether there is a requirement to certify the vehicle if it i manufactured using an old chassis. As we stated to you in our first letter, the assembly of such a vehicle is not the manufacture of a new motor vehicle. The certification requirements of Part 567 of our regulations apply only to new motor vehicles or the alteration of previously certified vehicles prior to their first purchase for purposes other than resale. Since your remanufacturing operation constitutes neither the manufacture of a new motor vehicle nor the alteration of a previously certified vehicle, your vehicle would not be required to be certified.; Sincerely, Joseph J. Levin, Jr., 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.