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: aiam2624OpenMr. Jerry W. McNeil, Director of Engineering, American Trailers, Inc., Box 26568, Oklahoma City, OK 73126; Mr. Jerry W. McNeil Director of Engineering American Trailers Inc. Box 26568 Oklahoma City OK 73126; Dear Mr. McNeil: This responds to your May 25, 1977, letter asking whether two sampl certification labels you submitted comply with the requirements of Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approvals of compliance with Federal safety standards or regulations. The agency will, however, give you an informal opinion as to whether your labels appear to comply with the requirements. The two labels you submitted do not follow the format required by Part 567 for certification labels. Therefore, they do not appear to comply with the requirements. Your method of stating tire and rim sizes differs from that required in Part 567 and Standard No. 120. For example, you state your tire and rim information as follows: '10-20-F-Tires-7.5 Rims at 75 PSI Cold Dual.' By the requirements of Part 567 and Standard No. 120 as they apply to certification labels, this information should read: '10.00-20(F) tires, 20x7.5 rims, at 75 psi cold dual.' Further, the statement after GAWR 'maximum with minimum size tire-rims shown below' should be deleted from the certification label. I am enclosing a copy of Part 567 and Standard No. 120 for your information.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0249OpenMr. James S. Campbell, Engineer, International Manufacturing Company, Building 165 Industrial Park, P. O. Box 347, Benicia, California 94510; Mr. James S. Campbell Engineer International Manufacturing Company Building 165 Industrial Park P. O. Box 347 Benicia California 94510; Dear Mr. Campbell: This is in reply to your letter of August 12 to Mr. Toms requesting a interpretation of Federal Motor Vehicle Safety Standard No. 211 (Wheel Discs, Wheel Nuts, and Hub Caps).; This standard does not prohibit projections per se on wheel equipmen items, it prohibits winged projections. Thus there is no limitation on how far a cylindrical projection, for example, may extend beyond the outer edge of the tire. On the other hand, any winged projection is prohibited, even if recessed.; I hope this answers you question. Sincerely, Rodolfo A. Diaz, Acting Associate Director |
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ID: aiam2274OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50, 100 W. Alondra Blvd., Gardena, CA 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill: This is in response to your letter of March 1, 1976, requesting a interpretation of whether the Honda 'MPV' would be classified as a 'multipurpose passenger vehicle' as that term is defined for purposes of the Federal motor vehicle safety standards.; 'Multipurpose passenger vehicle' is defined in 49 CFR Part 571.3(b) as: >>>'a motor vehicle with motive power, except a trailer, designed t carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.'<<<; Your letter states that the Honda 'MPV' is derived from the Honda T 500 light truck, which we assume means that the 'MPV' is constructed on a truck chassis. Further, your drawings indicate that the 'MPV' is of the forward control configuration. Based upon this understanding of your letter and attached drawings, it appears that the Honda 'MPV' qualifies as a multipurpose passenger vehicle.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam3873OpenMr. M. Leon Hart, State Supervisor of School Transportation, State of Delaware, The Townsend Building, P.O. Box 1402, Dover, DE 19903; Mr. M. Leon Hart State Supervisor of School Transportation State of Delaware The Townsend Building P.O. Box 1402 Dover DE 19903; Dear Mr. Hart: This responds to your letter to the National Highway Traffic Safet Administration (NHTSA) which concerned the Federal Motor Vehicle Safety Standards relating to school bus safety. You asked whether a public or nonpublic school can purchase and use a bus to transport school children to or from school related events if that vehicle does not meet the requirements for school buses established by NHTSA.; There are two Federal laws that have a bearing on your situation. Th first of these is the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563, hereinafter 'the Vehicle Safety Act'), under which our agency issues safety standards applicable to new motor vehicles. In 1974, Congress amended the Vehicle Safety Act to direct us to issue standards on specific aspects of school bus safety, such as emergency exits, seating systems, windows, and body strength. These standards became effective for buses manufactured after April 1, 1977. The second law is the Highway Safety Act of 1966 (Public Law 89-564), under which we have issued highway safety program standards applicable to State highway safety grant programs.; Under the definitions sections of our motor vehicle safety standards 'school bus' is defined as a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events (buses used as common carriers in urban transportation excluded). A 'bus' is defined as a motor vehicle designed for carrying more than 10 persons.; The Vehicle Safety Act prohibits dealers or distributors from sellin new school buses to schools or school districts if those buses do not comply with the Federal school bus safety standards. Any new van which carries 11 persons or more that is sold for purposes that include carrying students to and from school or related events is a school bus, and must comply with the standards for school buses issued by this agency. A dealer or distributor who sells a new non-complying bus to a school or school district is subject to substantial penalties under the Vehicle Safety Act.; You indicated in your letter that the color of the school bus i question is white. The Highway Safety Act, which deals with the safety of vehicle operation through a grant program to the States, specifies requirements for the color, lighting, and other operational criteria for school buses in Highway Safety Program Standard (HSPS) No. 17, *Pupil Transportation Safety*, (23 CFR 1204.4). Among the criteria in this standard are that a school bus should be painted yellow, equipped with special mirrors and lights, and marked 'School Bus.' In the case of a 15-passenger van, classified under the standard as a 'Type II school vehicle,' the identification criteria would have to be met if the van were equipped with school bus lights. If the State law conformed exactly to the standard, and if the bus in question were equipped as a school bus, then it would have to be painted yellow and signed as a school bus.; We wish to stress that HSPS No. 17 would affect the operation of you school buses only to the extent that Delaware has incorporated it into State law. Unlike the Vehicle Safety Act, which gives NHTSA direct regulatory authority over the manufacture and sale of motor vehicles, the Highway Safety Act gives us authority only over the content of the States' highway safety grant programs. Whether the 15-passenger school bus would have to be painted yellow is therefore determined by State law.; Please do not hesitate to contact us if you have further questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2761OpenMr. Donald Beyer, National Service Manager, Vespa of America Corporation, 322 East Grand Avenue, South San Francisco, CA 94080; Mr. Donald Beyer National Service Manager Vespa of America Corporation 322 East Grand Avenue South San Francisco CA 94080; Dear Mr. Beyer: This is in reply to your letter of October 24, 1977, requesting a interpretation whether motorcycles with turn signals are required to have turn signal indicators. You noted that Table 2 of Standard No. 123 does not include a turn signal indicator as a motorcycle display, while there appear to be conflicts within Standard No. 108, S4.5.6 requires an indicator but SAE Standard J588c (incorporated by reference in Standard No. 108) requires an indicator only if turn signal lamps are not readily visible to the driver.; Although S4.5.6 does require each vehicle equipped with a turn signa operating unit to have an illuminated pilot indicator, in my view a manufacturer who eliminated them in reliance upon J588c would not fail to comply with the standard if all signal lamps are readily visible to the driver.; However, we interpret 'readily visible to the driver' to mean visibl to the driver when facing forward in the driving position. Motorcycles are required to have separate turn signal lamps at or near the front, and at or near the rear of the vehicle. If the driver must turn his head to the rear to check the operation of his rear turn signal lamps, then those lamps are not 'readily visible to the driver' and a turn signal indicator must be provided. While Standard No. 123 itself in Table 3 does specify requirements for identification of turn signal 'control and display identification', it does not provide requirements for illumination and operation of the display in Table 2, as you noted.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2331OpenMr. R.G. Clifton, Manager - Tyre Legislation, Dunlop Limited, Tyre Technical Division, Fort Dunlop Birmingham B24 9QT, England; Mr. R.G. Clifton Manager - Tyre Legislation Dunlop Limited Tyre Technical Division Fort Dunlop Birmingham B24 9QT England; Dear Mr. Clifton: This is in response to your letters of March 22 and June 9, 1976 concerning the classification of motor-scooters and the tires designed for them.; >>>'Motorcycle' is defined in 49 CFR Part 571.3 as: a motor vehicle with motive power having a seat or saddle for the us of the rider and designed to travel on not more than three wheels in contact with the ground.; 'Motor-driven cycle' is defined as: a motorcycle with a motor that produces 5 brake horsepower or less.<<< The category of 'motor-driven cycles' includes, but is not limited to motorized bicycles. There is no definition of 'scooter' or 'motor-scooter'. Such a vehicle is a motorcycle and, depending on the brake horsepower of its engine, may also be a motor-driven cycle. In any event, a tire for use on such a vehicle is a motorcycle tire that is subject to all requirements of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars*. The standard does not presently recognize a category of speed-restricted motorcycle tires. However, your letter is being considered in the preparation of the forthcoming Federal Register notice on this subject.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam3170OpenMr. John F. Croonquist, President, Alternative Automotive, Inc., 999 N. Pacific Street, 33-D, Oceanside, CA 92054; Mr. John F. Croonquist President Alternative Automotive Inc. 999 N. Pacific Street 33-D Oceanside CA 92054; Dear Mr. Croonquist: This responds to your November 9, 1979, letter asking whether a vehicl that you plan to produce would be classified as a truck for purposes of applying the Federal motor vehicle safety standards.; In your letter, you state that your vehicle looks somewhat like a Jeep You state further that it is constructed on a Volkswagen truck chassis, carries two passengers, and is designed to transport property. As you know, the agency defines truck to be a vehicle that is designed primarily to transport property or speciality (sic) equipment. Since the vehicle that you plan to manufacture appears to be designed for the transportation of property and since it is constructed on a truck chassis, the agency concludes that it would be a truck for the purposes of applying the safety standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3520OpenH. A. Kendall, Ph.D., Executive Secretary, United Sidecar Association, Inc., 1621 Palomino Lane, Kingwood, TX 77339; H. A. Kendall Ph.D. Executive Secretary United Sidecar Association Inc. 1621 Palomino Lane Kingwood TX 77339; Dear Dr. Kendall: This is in reply to your letter of September 9, 1981, asking severa questions about Federal Motor Vehicle Safety Standard No. 108.; You have asked for a clarification of our position on pulsatin headlamps and stoplamps, commenting that several States have expressed a concern 'that a light of variable intensity may be confused by the citizen as an emergency vehicle which is allowed to have flashing headlights.'; As you have indicated, paragraph S4.6(a) of Standard No. 108 require turn signal lamps, hazard warning signal lamps, and school bus warning lamps to flash when activated, while S4.6(b) requires all other lamps to be steady burning. By 'steady burning,' the standard means a light that is essentially unvarying in intensity. There is, however, an exception in S4.6(b) to the 'steady burning' requirement. Means may be provided 'to flash headlamps and side marker lamps for signalling purposes.' Paragraph S3 of the standard defines 'flash' as meaning 'a cycle of activation and deactivation of a lamp by automatic means....' In our view, a lamp whose intensity varies from a higher output to a lower output would not be 'steady burning' or 'flash' within the meaning of those terms and hence would be prohibited. But if complete deactivation occurs, then the lamp 'flashes.' Installation of flashing lamps under the S4.6(b) exception is not restricted to emergency vehicles. It is permissible under the standard for a motorcycle to have a device which gives the motorcyclist the option of causing a motorcycle headlamp to operate automatically through cycles of activation and deactivation instead of burning steadily.; On the other hand, stop lamps that either flash or are of variabl intensity are not allowed by S4.6(b) of Standard No. 108 since they are not steady-burning while in use.; I hope this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4031OpenRichard Pertz, Esq., Julian & Pertz, P.C., 1629 Oneida Street, Utica, NY 13501; Richard Pertz Esq. Julian & Pertz P.C. 1629 Oneida Street Utica NY 13501; Dear Mr. Pertz: I regret the delay in replying to your letter of July 12, 1985 regarding interpretations of Standard No. 111, *Rearview Mirrors*. You asked whether the agency has issued any interpretations concerning S5.1.2 of the standard. In addition, you asked whether Ford Motor Company had submitted to the National Highway Traffic Safety Administration (NHTSA) any interpretations of paragraph S5.1.2 of Standard No. 111, regarding requirements for mounting inside rearview mirrors in passenger cars.; This agency administers the National Traffic and Motor Vehicle Safet Act of 1966. As part of its responsibilities, this office issues interpretations of safety standards, upon written request. This agency has issued two interpretations of S5.1.2 of Standard No. 111. Copies of these interpretations are enclosed.; In addition, NHTSA's Office of Vehicle Safety Compliance investigate the compliance of different makes of passenger cars with Standard No. 111 between 1977 and 1981. The Ford passenger car models tested were the Ford LTD, Econoline, and Fiesta and the Mercury Zephyr and Cougar. As part of its submission to the agency in these investigations, Ford provided information on its compliance with S5.1.2. The files are available on microfiche from the Technical Reference Office, Room 5108 (202-426-2768) at the address shown above, and the file numbers are CIR Nos. 1708, 2062, 2063, 2064, and 2245.; Your request in your letter of September 3, 1985, for comments by For on notices of proposed rulemaking on Standard No. 111 has been referred to the Docket Section. They will reply directly to you regarding this information.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1233OpenMr. Louis May, President, Sate-lite Mfg. Company, 6545 W. Irving Park Road, Chicago, Illinois 60634; Mr. Louis May President Sate-lite Mfg. Company 6545 W. Irving Park Road Chicago Illinois 60634; Dear Mr. May: This is in response to your petition of July 26, 1973, to modify th water immersion requirements of Standard 125, *Warning devices*, and the grounds that the test is more severe than typical weather conditions. The standard requires immersion of the device for 2 hours in water at a temperature of 100 degrees F. without warpage or separation of the reflective material from the support material.; Your reference to the device as a flare and to its immersion in 5 fee of water for an indefinite period makes it unclear whether you are referring to the standard as it will be effective on January 1, 1974. The final rule balanced the likelihood of water damage against numerous other considerations including cost and reuse. The 2-hour immersion requirement detailed above is intended to ensure that the device is undamaged and reuseable after an exposure to rain during any emergency deployment. In contrast, the 12-hour spray test of Standard No. 108 which you suggest as an alternative is used for reflex reflectors which are permanently mounted on a vehicle and are subject to regular and long exposure to blowing water. That spray test does not adequately simulate the relatively short but severe exposure to which a warning device would be subject in a steady rain. It is in such adverse weather conditions, of course, that the use if the device will be most important.; For these reasons, your petition is denies on the grounds tha preservation and reuse of the device justify the immersion requirement. Thank you for your interest in developing a functional warning device standard.; Sincerely, Robert L. Carter, Associate Administrator, 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.