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: aiam1184OpenMr. Charles Leeds, 1775 Broadway, New York, NY 10019; Mr. Charles Leeds 1775 Broadway New York NY 10019; Dear Mr. Leeds: This is in reply to your letter of July 12, 1973, concerning th obligations of a bank under the odometer disclosure requirements of Title 49 CFR Part 580, upon its sale of a repossessed vehicle.; If upon its repossession the bank becomes the owner of the vehicle, i is required to make a disclosure statement pursuant to 49 CFR Part 580. The auctioneer does not, as a rule, obtain ownership of a vehicle and would not be required to make the disclosure statement.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0832OpenMr. Tatsuo Kato, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tatsuo Kato Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Kato: This is in reply to your letter of August 29, 1972, regarding sectio S5.3.5 of Motor Vehicle Safety Standard No. 215, Exterior Protection.; The propulsion system is not considered to be out of adjustment if th shift lever moves from 'neutral' to 'drive' during a test impact, so long as the movement does not impair the subsequent operation of the transmission or other parts of the propulsion system.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1366OpenMr. W.G. Milby, Project Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, Georgia 31030; Mr. W.G. Milby Project Engineer Blue Bird Body Company P.O. Box 937 Fort Valley Georgia 31030; Dear Mr. Milby: This is in response to your letter of December 7, 1973, requesting ruling on whether you will be allowed to sell warning flags after January 1, 1974. Federal Motor Vehicle Safety Standard No. 125 prohibits the manufacture and sale of non-conforming warning devices manufactured after January 1, 1974. Thus, you would be allowed to sell such devices, even after January 1st, so long as they were not manufactured after that date.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2383OpenMr. Richard J. Brandewie, Program Manager, B.F. Goodrich Engineered Systems Company, P.O. Box 340, Troy, OH 45373; Mr. Richard J. Brandewie Program Manager B.F. Goodrich Engineered Systems Company P.O. Box 340 Troy OH 45373; Dear Mr. Brandewie: This responds to your July 26, 1976, question whether the 'no lockup requirement of S5.3.1 and S5.3.2 of Standard No. 121, *Air Brake Systems*, requires wheel sensors on both axles of a tandem axle system in those cases where the 'no lockup' performance is provided by means of an antilock system. I have enclosed a detailed discussion of this issue that responded to a similar question from another manufacturer. The response should answer your question.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam2651OpenMs. Jill M. Zick, BURLEY, SMIERTKA, SWANK AND MISKO, Attorneys and Counselors at Law, 2525 West Jefferson, Trenton, MI 48183; Ms. Jill M. Zick BURLEY SMIERTKA SWANK AND MISKO Attorneys and Counselors at Law 2525 West Jefferson Trenton MI 48183; Dear Ms. Zick: This is in reference to your September 6 letter, regarding modificatio of motor vehicles for the handicapped, which was forwarded to this office by the Lansing, Michigan, office of the Federal Highway Administration.; Your letter has been forwarded to the Office of Chief Counsel, Nationa Highway Traffic Safety Administration, Washington, DC. I'm sure you may expect to hear from that office shortly.; Sincerely, Ardella J. Pitts, Highway Safety, Management Specialist |
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ID: aiam0783OpenMr. Julian Asch, Superex of Ramsey, Ltd., P.O. Box 10, Ramsey, New Jersey 07446; Mr. Julian Asch Superex of Ramsey Ltd. P.O. Box 10 Ramsey New Jersey 07446; Dear Mr. Asch: I am writing in response to your letter of May 26 regarding Standar 125, Warning Devices. You state that you are the National distributer of imported warning triangles, and ask whether you are permitted under paragraph S5.1.4(a) to place your name rather than that of the manufacturer on the device. The answer to your question is no: the standard requires that the name of the actual manufacturer, and not that of the distributer, be permanently and legibly marked on the warning device.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1489OpenMr. Andy K. Holen, Purchasing Manager, Weyerhaeuser Company, Tacoma, WA 98401; Mr. Andy K. Holen Purchasing Manager Weyerhaeuser Company Tacoma WA 98401; Dear Mr. Holen: This responds to your April 29, 1974, request to be apprised of th Standard No. 121 requirements concerning air brakes on trucks and trailers.; Standard No. 121, like all Federal motor vehicle safety standards, is manufacturer requirement, not a user requirement. While it places obligations on the vehicle manufacturers to construct their vehicles so that they conform to the standard, it does not place any responsibilities on you as a user of air brake-equipped vehicles.; If you would nevertheless like to examine the current requirements they may be obtained from the Government Printing Office as explained in the enclosed brochure, or from commercial or library sources as part of Chapter V of Title 49 of the Code of Federal Regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1574OpenMr. Eric L. Clabough, 1210 South Walnut Street, Coffeyville, KS, 67337; Mr. Eric L. Clabough 1210 South Walnut Street Coffeyville KS 67337; Dear Mr. Clabough: This is in reply to your recent letter to the Administrator, Nationa Highway Traffic Safety Administration, concerning the placement of front turn signal lamps on fire trucks.; Federal Motor Vehicle Safety Standard No. 108, 'Lamps, Reflectiv Devices, and Associated Equipment' (copy enclosed) requires that front turn signal lamps be located 'at or near the front' and be spaced 'as far apart as practicable.' We would, therefore, have no objection to moving the front turn signal lamps on the fire truck from the side to the front. Locating the lamps on the front could also reduce the chance of damage to them, which might occur if they were located on the side.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2151OpenMr. George H. Schildge, Exec. Vice President, Conti Rubber Products, 4900 Hannover Place, P.O. Box 1638, Fremont, California 94538; Mr. George H. Schildge Exec. Vice President Conti Rubber Products 4900 Hannover Place P.O. Box 1638 Fremont California 94538; Dear Mr. Schildge: This is in response to your October 29, 1975, letter concerning th applicability of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles other than Passenger Cars*, to moped tires.; Mopeds are classified under 49 CFR 571.3 as 'motor-driven cycles', subcategory of 'motorcycles', for the purposes of the National Highway Traffic Safety Administration's regulations. Therefore, tires designed for use on mopeds are tires designed for use on motorcycles and, as such, are subject to Standard No. 119. The NHTSA is considering an amendment of Standard No. 119 which would modify the requirements applicable to such tires, and expects to issue a notice of proposed rulemaking on this subject on the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1861OpenMr. Danny Lanzdorf, Supervising Engineer, Oshkosh Truck Corporation, P.O. Box 2566, Oshkosh, WI 54901; Mr. Danny Lanzdorf Supervising Engineer Oshkosh Truck Corporation P.O. Box 2566 Oshkosh WI 54901; Dear Mr. Lanzdorf: This responds to your March 11, 1975, request for confirmation tha four Oshkosh snowplows qualify for exclusion from Standard No. 121, *Air brake systems*, under criteria set out in S3. You enclose photographs of the vehicles and state that they have all-wheel drive, a maximum attainable speed of 45 mph, and that three of the vehicles have no cargo- carrying capacity. The fourth vehicle has a dump body used for maintenance and construction purposes.; As you describe the vehicles, the first three meet the criteria an would be excluded from the standard. The fourth vehicle has a dump body which qualifies as 'cargo-carrying' and therefore the vehicle does not meet the criteria for exclusion.; 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.