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: GF004235OpenThe Honorable Mike Crapo Dear Senator Crapo: Thank you for your letter regarding a November 18, 2002, final rule on tire safety information issued by the National Highway Traffic Safety Administration (NHTSA) pursuant to the Transportation Recall Enhancement, Accountability and Documentation Act (the TREAD Act).You were concerned that the agency had not responded to petitions for reconsideration of the rule and thus had not addressed questions about the rules application to trailer manufacturers. We are pleased to inform you that on June 3, 2004, NHTSA responded to the petitions for reconsideration of the November 2002 final rule (69 FR 31306). Our response specifically clarified the labeling requirements for trailer manufacturers (the discussion can be found on page 31313 of the document, copy enclosed).This June 2004 final rule should answer all the questions and concerns of the trailer manufacturing industry.We note that the effective date for the final rule on tire safety information has been delayed until September 1, 2005. If you or your constituents have any further questions regarding this rulemaking, you may contact Scott Brenner, Associate Administrator for External Affairs, at (202) 366-2566. Sincerely, Jacqueline Glassman Enclosure |
2004 |
ID: nht93-7.42OpenDATE: October 27, 1993 FROM: Larry R. Lynch -- General Manager, AT&D Corporation TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 3/10/94 from John Womack to Larry R. Lynch (A42; Std. 121) TEXT: I have enclosed data describing a new product developed by our Company for the trucking industry. I am requesting that you peruse the information about the product and advise us as to how the current safety standard might be applicable. Our product has been named the AeroCon System. It was developed from the original concept of typical air deflectors seen on most tractor trailer vehicles. The AeroCon could be referred to as an atypical air deflector/fairing. It incorporates aerodynamic principles to create a stable slipstream and provide aerodynamic braking to the vehicle. By opening doors on the fairing unit, the full force of the relative wind speed is redirected to strike the trailer face, greatly decreasing the stopping distance. The pneumatic power required to actuate the system's doors utilizes the auxiliary air system of the tractor. Should you require additional data or information for your interpretation, please call us at (904) 588-2700 or FAX (904) 588-2701. Our physical address is: One Pasco Center 30435 Commerce Drive San Antonio, Florida 33576 Please return the enclosed materials, upon the completion of your interpretation. Your attention to our request is greatly appreciated. |
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ID: nht92-1.17OpenDATE: 12/18/92 FROM: KENNETH A. GALLO -- HOWREY & SIMON TO: Marion C. Blakey -- Administrator, NHTSA TITLE: MICHO INDUSTRIES AND SAFETY RESEARCH MANUFACTURING, INC. PETITION FOR EXEMPTION ATTACHMT: ATTACHED TO LETTER DATED 2-19-93 FROM JOHN WOMACK TO KENNETH A. GALLO (A40; PART 5SS; VSA 108) TEXT: Pursuant to 15 U.S.C. @ 1397(a)(2)(B) (1982), Micho Industries and Safety Research and Manufacturing, Inc. respectfully submit the enclosed Petition for Exemption. ATTACHMENT 12-18-92 PETITION FOR EXEMPTION REGARDING MICHO INDUSTRIES AND SAFETY RESEARCH AND MANUFACTURING. (TEXT OMITTED.) |
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ID: nht92-8.3OpenDATE: April 3, 1992 FROM: Michael Love -- Manager, Compliance, Porsche Cars North America, Inc. TO: Paul Jackson Rice -- Chief Counsel, NHTSA TITLE: Re: Request for Interpretation - FMVSS 108 ATTACHMT: Attached to letter dated April 27, 1992 from Paul J. Rice to Michael Love (A39; Std. 108) TEXT: On behalf of Dr. Ing. h.c.F. Porsche AG, Porsche Cars North America, Inc. ("Porsche") hereby submits the attached request for interpretation of FMVSS 108. Please contact me at 702/348-3198 if you should have any questions. |
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ID: nht88-3.13OpenTYPE: INTERPRETATION-NHTSA DATE: 08/19/88 FROM: RANDY BLACKMAN -- PER LUX INC TO: NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 08/07/89 FROM STEPHEN P. WOOD -- NHTSA TO RANDY BLACKMAN; REDBOOK A34 [4]; STANDARD 202; STANDARD 302 TEXT: Dear Sir or Madam: Per-Lux is a manufacture of automotive driving and safety lights and other automotive products. An inventor has proposed to us the possibility of manufacturing and distributing a head restraint device for pick-up trucks. Will you please advise me which, if any, Federal Safety standards would directly or indirectly apply to this product. I have enclosed a sketch of the proposed product for your information. Sincerely, |
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ID: 10024Open Mr. John A. Griffiths Dear Mr. Griffiths: This responds to your request for an interpretation 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 ref:102 d:6/8/94
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1994 |
ID: nht89-1.93OpenTYPE: INTERPRETATION-NHTSA DATE: 05/23/89 FROM: LARRY P. EGLEY TO: KATHLEEN DEMETER -- ASST. CHIEF COUNSEL NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33[2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATH LEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/20/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 07/13/88 FROM KATHLEEN DEMETER -- NHTSA TO LARRY P. EGLEY; LETTER DATED 06/23/88 FROM LARRY P. EGLEY TO RALPH HITCHCOCK -- NHTSA; OCC 2256; LETTER DATED 06/20/88 FRO M LEWIS S. BUCHANAN -- EPA TO LARRY P. EGLEY; OCC 2199; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN TEXT: Dear Ms DeMeter: On January 17, 1989, I requested a status report on an invention for which I requested an evaluation. I have received no reply from you. As you see by the attached letter, I cleared this device for evaluation on September 10, 1988. I would appreciate the courtesy of a reply. Thank you. Encl: My letter dated January 17, 1989 |
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ID: 77-1.26OpenTYPE: INTERPRETATION-NHTSA DATE: 02/17/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Lucas Industries North America, Inc. TITLE: FMVSS INTERPRETATION |
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ID: nht93-2.33OpenDATE: March 29, 1993 FROM: Carl W. Ruegg -- President, Carlo International Inc. TO: Taylor Vinson -- Chief Council, U.S. Department of Transporation, NHTSA TITLE: None ATTACHMT: Attached to letter dated 4-13-93 from John Womack to Carl W. Ruegg (A41; Part 591) TEXT: Kindly send us information and regulations regarding the importation of non-conforming vehicles for research, investigation studies, demonstrations. |
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ID: nht95-2.93OpenTYPE: INTERPRETATION-NHTSA DATE: May 23, 1995 FROM: Lance Tunick -- Vehicle Services Consulting, Inc. TO: Orron Kee -- NHTSA TITLE: Re: Request for interpretation of 49 CFR 575.101 ATTACHMT: ATTACHED TO 7/26/95 LETTER FROM JOHN WOMACK TO LANCE TUNICK (REDBOOK 2; PART 575; STD. 105; STD. 135) TEXT: Dear Orron: This is to request that NHTSA clarify how it interprets the requirements of 49 CFR 575.101 (disclosure of vehicle stopping distance) when a manufacturer uses newly promulgated FMVSS 135 to certify its vehicle. The question arises because 575.101(c) refe rs to FMVSS 105, but makes no mention of FMVSS 135. Thank you for your assistance. |
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.