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 |
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ID: aiam2693OpenMr. John W. Kourik, Chief Engineer, Wagner Electric Corporation, 11444 Lackland Road, St. Louis, MO 63141; Mr. John W. Kourik Chief Engineer Wagner Electric Corporation 11444 Lackland Road St. Louis MO 63141; Dear Mr. Kourik: This responds to Wagner Electric Corporation's October 26, 1977 request for confirmation that S5.6.4 of Standard No. 121, *Air Brake Systems*, does not prohibit the use of a two-valve sequential means to release the parking brakes on a towed vehicle.; I have enclosed for your information an interpretation that addresse this question, stating that a two-valve sequential release is permissible under S5.6.4.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0654OpenMr. Italo De Gregori, Fabbrica Pisana S.p.A., Direzione Commerciale, Servizio Tecnico Commerciale, E Controllo Qualita, Via E. Romagnoli 6, 20146 Milano, Italy; Mr. Italo De Gregori Fabbrica Pisana S.p.A. Direzione Commerciale Servizio Tecnico Commerciale E Controllo Qualita Via E. Romagnoli 6 20146 Milano Italy; Dear Mr. De Gregori: Thank you for your letter of March 10, 1972, concerning marking of you glazing materials intended for the American market.; The marking you propose to use satisfies the requirements of Standar No. 205, *Glazing Materials*.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam0634OpenMr. Thomas S. Pieratt, Jr., Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: I have enclosed our reply to Mr. Grace of White River Distributors Inc., whose letter you forwarded to us on March 10, 1972, and request that you forward our response to him. His letter to us contains no return address, and we are consequently unable to write to him directly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0915OpenMr. Pundalik K. Kamath, Senior Safety Engineer, Oshkosh Truck Corporation, Post Office Box 560, Oshkosh, WI 54901; Mr. Pundalik K. Kamath Senior Safety Engineer Oshkosh Truck Corporation Post Office Box 560 Oshkosh WI 54901; Dear Mr. Kamath:#In your letter of November 28, 1972, you ask about th applicability of Federal Motor Vehicle Safety Standard No. 101 to a wiper for the 'right-hand window'.#The control location, identification, and illumination requirements of Standard No. 101 apply only to windshield wiping systems, and not to those that may be provided for side or rear windows.#Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam1296OpenThomas N. O'Leary, Esq.,Messrs. Pain & Julian,1940 East Camelback,Phoenix, Arizona 85016; Thomas N. O'Leary Esq. Messrs. Pain & Julian 1940 East Camelback Phoenix Arizona 85016; Dear Mr. O'Leary:#In your letter of October 8, 1973, to the Departmen of Transportation you ask whether it is true that DOT requires trailer braking system to have stainless steel conduits rather than copper ones.#Neither the Federal motor vehicle safety standards nor the regulations of the Bureau if Motor Carrier Safety contain such a requirement, and we are unaware of any Federal regulation of this nature.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam1192OpenMr. R. Kesler, Kesler Precision Optics, 444 N. Norton Ave., Los Angeles, Calif. 90004; Mr. R. Kesler Kesler Precision Optics 444 N. Norton Ave. Los Angeles Calif. 90004; Dear Mr. Kesler: Thank you for your letter of July 12, 1973, enclosing an accessor passenger car mirror that you feel is a detriment to motor vehicle safety.; Since the unit incorporates to convex mirrors it does not comply wit the requirements of Standard No. 111 *Rearview Mirrors* for original equipment on passenger cars and multipurpose passenger vehicles. However, the Standard does not cover aftermarket items such as the unit you sent, and its sale is therefore not prohibited under Federal Regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3669OpenMr. Jack Fazio, Quality Assurance Manager, Safetee Glass Division, Chromalloy, 250 King Manor Drive, King of Prussia, PA 19406; Mr. Jack Fazio Quality Assurance Manager Safetee Glass Division Chromalloy 250 King Manor Drive King of Prussia PA 19406; Dear Mr. Fazio: This responds to your recent letter asking whether it is necessary fo your company to obtain a new glazing DOT number when it transfers production of some of its safety glazing materials to a new plant location.; It is not necessary for you to obtain a new DOT number since the statu of your company is not changing. You indicate that this change only represents a move of production operation from one facility to another. We will note your additional address on our records and nothing further is required.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0417OpenMr. Hal H. Newell, Manager-Government Relations, Eaton Corporation, Government Relations Office, Suite 838 Pennsylvania Building, 425-13th Street, N.W., Washington, DC 20004; Mr. Hal H. Newell Manager-Government Relations Eaton Corporation Government Relations Office Suite 838 Pennsylvania Building 425-13th Street N.W. Washington DC 20004; Dear Mr. Newell:#In your letter of July 22 you ask if Standard No. 101 as amended, requires the illumination of controls on after market auto and truck air conditioners.#Standard No. 101 does not apply to after market equipment items. It requires that vehicles meet control location, identification, and illumination requirements at the time of sale to the first purchaser for purposes other than resale, and places compliance responsibility upon the vehicle's manufacturer, distributor, and dealer.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam0416OpenMr. Hal H. Newell, Manager-Government Relations, Eaton Corporation, Government Relations Office, Suite 838 Pennsylvania Building, 425-13th Street, N.W., Washington, DC 20004; Mr. Hal H. Newell Manager-Government Relations Eaton Corporation Government Relations Office Suite 838 Pennsylvania Building 425-13th Street N.W. Washington DC 20004; Dear Mr. Newell:#In your letter of July 22 you ask if Standard No. 101 as amended, requires the illumination of controls on after market auto and truck air conditioners.#Standard No. 101 does not apply to after market equipment items. It requires that vehicles meet control location, identification, and illumination requirements at the time of sale to the first purchaser for purposes other than resale, and places compliance responsibility upon the vehicle's manufacturer, distributor, and dealer.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: nht87-1.89OpenTYPE: INTERPRETATION-NHTSA DATE: 06/04/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Jerry Flynn Tucker -- Attorney at Law TITLE: FMVSS INTERPRETATION TEXT: Mr. Jerry Flynn Tucker Attorney at Law P.O. Box 24, Courthouse Square Ashville, Alabama 335953 Your letter to the Society of Automotive Engineers (SAE) was referred to me for reply. Your letter informs SAE that a second trailer manufacturer, Nix Enterprises, Inc., is using the WMI Code designation SAE assigned to your client, Omni Trailers, Inc. Y ou asked SAE to take whatever action it could to prevent the continued misuse of your client's WMI Code. Under Federal motor vehicle safety standard 115, 49 CFR 571.115, (Standard 115), a motor vehicle manufacturer must assign a 17-character Vehicle Identification Number (VIN) to each vehicle it manufactures. The first three VIN characters must, among other things, uniquely identify the vehicle manufacturer. Among the primary reasons for the VIN designation are to facilitate vehicle notice and recall campaigns where a vehicle proves to be defective; and to aid persons investigating motor vehicle theft or a ccidents. The National Highway Traffic Safety Administration (NHTSA), an agency of the United States Department of Transportation, is responsible for motor vehicle safety standards, and contracts wit SAE to coordinate the assignment of manufacturer identifiers. Un der 49 CFR S565.5(b), Reporting Requirements, a manufacturer or its agent must submit its unique identifier to SAE at least 60 days before using its identifier. Apparently, Nix Enterprises fail to follow proper procedures for obtaining the WMI Code desig nation. NHTSA considers this failure to be the kind of error that can have adverse safety consequences because it could impair both Omni's and Nix's ability to conduct recall campaigns, and further impair the agency's ability to monitor any such campaign. I shal l refer this matter to the NHTSA office of Enforcement for appropriate action. Sincerely, Erika Z. Jones Chief Counsel
Society of Automotive Engineers 400 Commonwealth Drive Warrendale, PA 15096 Re: Omni Trailers, Inc., WMI Code 10Z Dear Sir: It has been brought to your attention that Omni Trailers, Inc.'s WMI Code 10Z is being improperly used by another company. Enclosed are documents to support this claim. The State of Georgia which issued the title to this trailer, has been placed on notic e of the improper use of Omni's WMI Code, to no avail. At this time we ask that you take any action, which you are authorized, to prevent the continued use of Omni's WMI Code and remove any trailer which carries an Omni Code from the road, which has been issued by anyone but Omni. If you cannot act upon this matter, please inform us as to what action this office may take to prevent the same. Sincerely, Jerry F. Tucker December 14, 1983 Mr. Gerald Tucker Omni Trailers, Inc P.O. Box 537 Springville, AL 35146 Dear Mr. Tucker: This letter confirms our telephone conversation of November 28, 1983 regarding the assignment of a World Manufacturer (Maker) Identifier (WMI) Code. As the agent of the NHTSA for the assignment of manufacture identifiers pursuant to S4.5.1 of FMVSS 115, we hereby confirm the following code: Omni Trailers, Inc. P. O. Box 537 Springville, AL 35146 United States |
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.