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: aiam5243OpenErika Z. Jones, Esq. Mayer, Brown & Platt 2000 Pennsylvania Avenue, N.W. Washington, D.C. 20006-1882; Erika Z. Jones Esq. Mayer Brown & Platt 2000 Pennsylvania Avenue N.W. Washington D.C. 20006-1882; Dear Ms. Jones: This responds to your request for an interpretation o Federal Motor Vehicle Safety Standard No. 213, Child restraint systems. S5.2.3.2(b) of Standard No. 213 specifies a minimum thickness for materials of a certain compression- deflection resistance. You ask whether more than one piece of material may be used to meet the thickness requirement. The answer is yes. S5.2.3.2(b) does not require the material to be of a single piece, and the final rule that incorporated the requirement into Standard No. 213 did not address the issue. 44 FR 72131, December 13, 1979. Accordingly, more than one piece of material may be used. I hope this information is helpful. If you have any further questions, please contact us. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam4489OpenRobert L. Bernard Attorney at Law 12342 Wrenthrope Drive Houston, TX 77031; Robert L. Bernard Attorney at Law 12342 Wrenthrope Drive Houston TX 77031; "Dear Mr. Bernard: This letter responds to your inquiry of August 21 1987, where you asked for this agency's opinion on whether Federal motor vehicle safety standard 115 (49 CFR 571.115) requires a manufacturer's chrome script name on the trunk of vehicles it manufactures. It does not. Standard 115, Vehicle Identification Number- Basic Requirements, directs a vehicle manufacturer to place a discrete vehicle identification number (VIN) on each vehicle it manufactures. Under paragraph S4.5, the VIN for any motor vehicle must appear indelibly on a part of the vehicle other than the glazing, that is not designed to be removed except for repair. Paragraph S4.6 states that the VIN for passenger cars must appear inside the passenger compartment. Title 49 CFR Part 565, VIN-Content Requirements, states that among other things, the VIN's first three characters must identify the vehicle manufacturer. However, neither Standard 115 nor Part 565 require a manufacturer's name plate to appear on the vehicle. I hope you find this information helpful. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam2917OpenMr. Moe Pare, Jr., Cars & Concepts, Inc., 12500 E. Grand River, Brighton, MI 48116; Mr. Moe Pare Jr. Cars & Concepts Inc. 12500 E. Grand River Brighton MI 48116; Dear Mr. Pare: This responds to your December 4, 1978, letter concerning th applicability of Safety Standard No. 205, *Glazing Materials*, to applied windshield tint bands.; I am enclosing copies of two previous letters of interpretation by th agency regarding polyester films that appear to be similar to the product you describe. I think these letters will answer all of your questions. If not, please contact Hugh Oates of my office at 202-426-2992.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1005OpenMr. Konen, Johann und Konen, 53 Bonn-Beul 1, Rosenbach, Ortsteil Putachen, GERMANY; Mr. Konen Johann und Konen 53 Bonn-Beul 1 Rosenbach Ortsteil Putachen GERMANY; Dear Mr. Konen: Your letter of February 1, 1973, concerning warning devices, has bee forwarded to my office for review and response.; The National Highway Traffic Safety Administration does not issu authorization for testing institutes to approve our Federal Motor Vehicle Safety Standards (FMVSS). Each manufacturer must be responsible for assuring that his products meet the standard, and no submittals are to be made to this Administration. However, we are enclosing a list of foreign laboratories who are capable of determining whether warning devices meet the requirements of FMVSS No. 125.; The side length of the warning device should be interpreted as th direct length over the outside radii.; If any further information is necessary, please let us know. Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1448OpenMr. M. Rein,Staff Engineer,Office of O. Weinreich,Director of Engineering,BMW of North America, Inc.,120 Pleasant Avenue,Upper Saddle River, New Jersey 07458; Mr. M. Rein Staff Engineer Office of O. Weinreich Director of Engineering BMW of North America Inc. 120 Pleasant Avenue Upper Saddle River New Jersey 07458; Dear Mr. Rein:#This responds to your March 19, 1974, request fo confirmation that the clamps and check valve that attach a vacuum hose assembly to a brake booster are not subject to Standard No. 106, *Brake hoses*.#A brake hose end fitting is defined as 'a coupler, other than a clamp, designed for attachment to the end of a brake hose.' As described by you, the couplers are the clamps and the check valve is an engine component to which the hose has been attached by the clamp couplers.Therefore your interpretation is correct that the clamps and check valve are not subject to Standard No. 106.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam0729OpenMemorandum to File: Definitions, 571.3(b), Interpretation; Memorandum to File: Definitions 571.3(b) Interpretation; Memorandum from Attorney-Advisor Subject: Fiat Ambulance Guiseppe Carretto, the Fiat lawyer, telephoned me on June 14 to as whether a Fiat 238 truck chassis to which an ambulance body had been mounted would be considered a 'multipurpose passenger vehicle.'; I replied that it would. Z. Taylor Vinson |
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ID: aiam1024OpenMr. R. L. Brown, President, Brown Motor Co., Inc., 1005 S. Main Street, Corbin, KY 40701; Mr. R. L. Brown President Brown Motor Co. Inc. 1005 S. Main Street Corbin KY 40701; Dear Mr. Brown: I am returning herewith copies of two odometer disclosure statement executed by your company on February 15 and 17, 1973. Our regulations require you to submit these statements to each customer, but they do not require you to send us a copy. I suggest that you retain the enclosed copies for your files.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2144OpenMr. Byron A. Crampton, Manager of Engineering Services, 5530 Wisconsin Avenue, Suite 1220, Washington, D.C. 20015; Mr. Byron A. Crampton Manager of Engineering Services 5530 Wisconsin Avenue Suite 1220 Washington D.C. 20015; Dear Mr. Crampton: #In response to your November 24, letter concernin the relationship between Federal Motor Vehicle Safety Standards Nos. 109 and 119, I am enclosing a copy of a prior interpretation letter on the same subject, which was sent to Mr. C.D. McCarthy of the B.F. Goodrich Company on October 15, 1975. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam1582OpenMr. Zenjiro Hase,Toyoda Gosei Co., Ltd.,9, I-chome, Nishiyabushitacho,Nishiku, Nagoya, Japan; Mr. Zenjiro Hase Toyoda Gosei Co. Ltd. 9 I-chome Nishiyabushitacho Nishiku Nagoya Japan; Dear Mr. Hase:#This responds to your August 8, 1974, question whethe the effective date of Standard No. 106-74, *Brake hoses*, is September 1, 1974, for hose (and fittings) and March 1, 1975, for hose assemblies.#Your interpretation is correct. The standard requires conforming hose (and fittings) as of September 1, 1974. It requires conforming assemblies (including the label band) only on March 1, 1975, and thereafter.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2524OpenMr. Dennis J. Mahr, Attorney at Law, 232 Davidson Building, Sioux City, IA 51101; Mr. Dennis J. Mahr Attorney at Law 232 Davidson Building Sioux City IA 51101; Dear Mr. Mahr: Thank you for your letter of February 23, 1977, concerning the For Motor Company's record keeping practices involving a 1967 Mercury Cougar. Because of the legal nature of your inquiry, I am forwarding your letter to the National Highway Traffic Safety Administration's Office of Chief Counsel for reply.; If I can be of further assistance to you, please let me know. Sincerely, William E. Scott, Acting Director, National Center fo Statistics and Analysis, Research and Development; |
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.