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: aiam0594OpenMr. Gerald E. Bowman, Chief Executive Officer, Winnebago Industries, Inc., P.O. Box 152, Forest City, IA 50436; Mr. Gerald E. Bowman Chief Executive Officer Winnebago Industries Inc. P.O. Box 152 Forest City IA 50436; Dear Mr. Bowman: We have received your quarterly report pursuant to section 573.5 of th Defect Reports regulations and note that you have marked 'confidential' data submitted concerning a notification campaign conducted on your Model 04 motor home.; The NHTSA does not consider information regarding notificatio campaigns to be confidential under sections 112 or 113 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. SS 1401, 1402), and is making this information public. The only information that we have agreed to keep confidential, if requested, are production figures submitted pursuant to section 573.5(b).; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam5655OpenMr. Kenneth W. Easterling Plan B Engineering, Inc. 26399 The Old Road 14-106 Stevenson Ranch, CA 91381; Mr. Kenneth W. Easterling Plan B Engineering Inc. 26399 The Old Road 14-106 Stevenson Ranch CA 91381; Dear Mr. Easterling: This responds to your letter of November 16, 1995 asking for our opinion of 'G-Lamps', ('proportional deceleration indicator lamps) intended as a rear end collision avoidance device. Your system would flash the stop lamps proportionally to the rate of deceleration. Over the years, the agency has received many requests for interpretations of the laws which it administers as they relate to deceleration warning systems. Our reply has been that it is impermissible to wire the stop lamp system so that it flashes, no matter what the purpose of the flashing. I enclose for your information, as a representative reply, a copy of our letter of July 30, 1993, to Wayne Ferguson of the Virginia Department of Transportation, which fully sets forth our views and interpretations. If you have questions about these matters, you may telephone Taylor Vinson of this office at 202-366-5263. Sincerely, Samuel J. Dubbin Chief Counsel Enclosure; |
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ID: aiam3490OpenMr. James S. Peterson, Consumer Specialist, Dealer License Section, Wisconsin Department of Transportation, P.O. Box 7909, Madison, WS (sic) 53707; Mr. James S. Peterson Consumer Specialist Dealer License Section Wisconsin Department of Transportation P.O. Box 7909 Madison WS (sic) 53707; Dear Mr. Peterson: Thank you for your letter of July 14, 1981, informing the agency that Wisconsin automobile dealership had issued an odometer disclosure statement which included a disclaimer of the company's responsibility for the accuracy of the statement. Specifically, you wanted to know if this practice was a violation of the Federal odometer laws.; Section 408(c) of the Motor Vehicle Information and Cost Savings Ac requires each automobile dealer who purchases a vehicle to obtain a complete odometer disclosure statement from the prior owner. 15 U.S.C. 1988(c). When the vehicle is resold, the dealer certifies the mileage by relying on the disclosure statement received from the prior owner. The Act, therefore, imposes an affirmative duty upon a dealer to obtain a complete odometer disclosure statement from the prior owner.; The Odometer Disclosure Requirements require the owner of a vehicle t disclose to subsequent purchasers the odometer mileage and to certify the accuracy of the odometer reading. 49 CFR 580.1. The regulations establish a specific scheme for the certification of the accuracy of the odometer reading. 49 CFR 580.4(c)(1) - (3). Where a transferor has knowledge that the odometer reading is inaccurate, the regulations require the transferor to certify that the mileage is not accurate and should not be relied upon. However, where the dealer has no reason to believe that the odometer reading is inaccurate, the dealer must certify the accuracy of the odometer reading to the subsequent purchaser. By including an absolute disclaimer on the odometer disclosure statement, the seller fails to certify the accuracy of the odometer reading as required by the Act.; Section 412 of the Act provides that any person who violates an provision of this title shall be subject to civil penalties not to exceed $1,000 for each such violation. 15 U.S.C. 1990(b). Thus, a dealer that includes a disclaimer on an odometer disclosure statement may be subject to civil penalties for failing to properly certify the accuracy of the odometer reading.; Enclosed please find a copy of the letter to the dealership informin it that the disclaimer on the odometer disclosure statement is a violation of the Federal odometer laws.; If you have any further questions, please do not hesitate to write. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3178OpenMr. Glen Brinks, 2110 Magnolia Avenue, Santa Ana, CA 92707; Mr. Glen Brinks 2110 Magnolia Avenue Santa Ana CA 92707; Dear Mr. Brinks: This responds to your recent letter requesting information concernin the Federal safety regulations applicable to motorcycle fuel tanks and motorcycle trailers.; The Federal Motor Vehicle Safety Standard regarding fuel syste integrity, Standard No. 301-75, currently does not apply to motorcycles. Two safety standards would be applicable to the manufacture of motorcycle trailers: Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* and Safety Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars*.; The manufacturer of a trailer, including a motorcycle trailer, woul have to certify the compliance of the trailer to these two safety standards. Part 566 of our regulations, *Manufacturer Identification* (49 CFR 566), specifies information which must be submitted to the NHTSA by manufacturers of motor vehicles, including trailers. Part 567, *Certification* (49 CFR 567), specifies the content and location of the certification label or tag that must be attached to motor vehicles regulated by our standards. I am enclosing an information sheet that explains where you can obtain copies of these safety standards and regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3179OpenMr. Glen Brinks, 2110 Magnolia Avenue, Santa Ana, CA 92707; Mr. Glen Brinks 2110 Magnolia Avenue Santa Ana CA 92707; Dear Mr. Brinks: This responds to your recent letter requesting information concernin the Federal safety regulations applicable to motorcycle fuel tanks and motorcycle trailers.; The Federal Motor Vehicle Safety Standard regarding fuel syste integrity, Standard No. 301-75, currently does not apply to motorcycles. Two safety standards would be applicable to the manufacture of motorcycle trailers: Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* and Safety Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars*.; The manufacturer of a trailer, including a motorcycle trailer, woul have to certify the compliance of the trailer to these two safety standards. Part 566 of our regulations, *Manufacturer Identification* (49 CFR 566), specifies information which must be submitted to the NHTSA by manufacturers of motor vehicles, including trailers. Part 567, *Certification* (49 CFR 567), specifies the content and location of the certification label or tag that must be attached to motor vehicles regulated by our standards. I am enclosing an information sheet that explains where you can obtain copies of these safety standards and regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2033OpenMr. Hidekimi Inoue, Bridgestone Tire Co., Ltd., 350 Fifth Avenue, New York 10001; Mr. Hidekimi Inoue Bridgestone Tire Co. Ltd. 350 Fifth Avenue New York 10001; Dear Mr. Inoue: This responds to your letter of July 14, 1975, concerning th permissibility of placing arrow-shaped markings on tire sidewalls to show the location of the treadwear indicators.; Federal Motor Vehicle Safety Standard No. 109 specifies certai labeling requirements for passenger car tires. Standard No. 119 specifies similar labeling for tires designed for use on vehicles other than passenger cars. Although the arrows which you have described are not required by either of these standards, the National Highway Traffic Safety Administration has no objection to such markings provided that none of the required label information is omitted.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2032OpenMr. Hidekimi Inoue, Bridgestone Tire Co., Ltd., 350 Fifth Avenue, New York 10001; Mr. Hidekimi Inoue Bridgestone Tire Co. Ltd. 350 Fifth Avenue New York 10001; Dear Mr. Inoue: #This responds to your letter of July 14, 1975 concerning the permissibility of placing arrow-shaped markings on the tire sidewalls to show the locations of the treadwear indicators. #Federal Motor Vehicle Safety Standard No. 109 specifies certain labeling requirements for passenger car tires. Standard No. 119 specifies similar labeling for tires designed for use on vehicles other than passenger cars. Although the arrows which you have described are not required by either of these standards, the National Highway Traffic Safety Administration has no objection to such markings provided that none of the required label information is omitted. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam5391OpenMr. John A. Griffiths 510G Bellfield Drive Newport News, VA 23602; Mr. John A. Griffiths 510G Bellfield Drive Newport News VA 23602; Dear Mr. Griffiths: This responds to your request for an interpretatio whether the Federal Motor Vehicle Safety Standards specify for a manual transmission vehicle, a 'neutral safety switch,' or other means to prevent starting of the vehicle unless the clutch is fully depressed. The answer is no. Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect, specifies starter interlocks for automatic transmission vehicles, but not for manual transmission vehicles. (See S3.1.3.) None of the other safety standards specify that motor vehicles include a device of the type you describe, or specify means to prevent starting of a manual transmission vehicle unless the clutch is depressed. 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; |
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ID: aiam3269OpenMr. Barry Breslow, 120 Ryder Avenue, Dix Hills, NY 11746; Mr. Barry Breslow 120 Ryder Avenue Dix Hills NY 11746; Dear Mr. Breslow: This responds to your recent letter asking for information concernin the Federal and State regulations that would be applicable to conversions of gasoline-powered vehicles to run on LP gas. I am enclosing a copy of a letter of interpretation the agency issued last August which discusses the Federal requirements and implications of such conversions. You will have to contact the individual States to find out any requirements they may have, however.; If you have any questions after reviewing the enclosed information feel free to contact Hugh Oates of my staff at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0433OpenMr. Earl R. Buske, President, E. R. Buske Mfg. Co., Inc., Pocahontas, IA, 50574; Mr. Earl R. Buske President E. R. Buske Mfg. Co. Inc. Pocahontas IA 50574; Dear Mr. Buske: Your letter of September 3, 1971, to the Bureau of Motor Carrier Safet concerning the mounting of lamps on a body backplate has been referred to this Office for consideration and reply.; Federal Motor Vehicle Safety Standard No. 108 requires that lamps mee the applicable SAE Standards (including the photometric specifications) when tested as mounted on the vehicle. (See SAE J575c, Paragraph J.) The maximum angle from a line perpendicular to the longitudinal centerline of the vehicle that a lamp can be mounted and meet the applicable requirements depends upon the design and configuration of the lamp. We therefore recommend that you contact the manufacturer of your lamps for this maximum angle information.; Sincerely, E. T. Driver, Office of Operating Systems, Motor Vehicl Programs; |
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.