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: nht94-8.50OpenDATE: January 19, 1994 FROM: Donald F. Lett -- Lett Electronics Co. TO: Department of Transportation -- NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 5/18/94 From John Womack To Donald Lett (A42; Std. 109; Std. 110; Part 575.104) TEXT: Dear Sir, I was directed to your department by Mr. Duane Perrin to resolve any legal responsibility, if any, for the following question; Is there any pre-necessary authorization needed to modify an existing passenger tire, for instance a 215-70-R15 blackwall radial tire? Proposed Modification Grind down the existing sidewall 1/8 to 3/16 inch deep by 2 1/2" wide. Then vulcanizing white rubber into this recess making a 2 1/2" whitewall radial tire out of a previously D.O.T. approved radial blackwall tire. Thereupon we would merchandise this tire Nation wide to a specific classic car buff of the 1955-1960 era. Your kind attention to this matter would be greatly appreciate. Thank you, |
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ID: 1983-1.30OpenTYPE: INTERPRETATION-NHTSA DATE: 03/21/83 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Chromalloy -- Jack Fazio, Quality Assurance Manager, Safetee Glass Division TITLE: FMVSS INTERPRETATION TEXT:
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 for 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 necessary for you to obtain a new DOT number since the status 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,
Original Signed By Frank Berndt Chief Counsel |
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ID: nht93-2.47OpenDATE: April 8, 1993 FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA TO: Jane L. Dawson -- Specifications Engineer, Thomas Built Buses, Inc. TITLE: None ATTACHMT: Attached to letter dated 3-5-93 from Jane L. Dawson to Walter Myers (OCC 8418) TEXT: This responds to your letter of March 5, 1993 asking if an exterior handle is required for emergency exit windows under the recent final rule amending Standard No. 217, BUS WINDOW RETENTION AND RELEASE (November 2, 1992; 57 FR 49413). As explained below, the answer is no. The final rule added a new section S5.3.3.2 to Standard No. 217 which reads: each school bus emergency exit window shall allow manual release of the exit by a single person, FROM INSIDE THE PASSENGER COMPARTMENT (emphasis added). Thus, unlike doors and roof exits, a release mechanism is not required on the outside of emergency exit windows. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. |
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ID: nht73-1.45OpenDATE: 02/05/73 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Mr. Harvey E. Schock, Jr. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your memo of January 18, 1973, concerning glazing materials. I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 205,Glazing Materials. Certification of conformance to Standard No. 205 is self-certification. No approval by the Federal Government is required. If you are not aware of State approvals, you may want to contact Mr. Armand Cardarelli of the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036. If I can be of further service, please do not hesitate to ask. Sincerely, Enclosure No Control M E M O FROM: Harvey E. Schock, Jr. To The Associate Administrator Motor Vehicle Programs National Highway Safety Administration January 18, 1973. RE:FR Docket 73-644 Prime Glazing Material Manufacturer Codes Gentlemen: I would appreciate information on the requirements and procedures for the certifying that glazing materials conform to Motor Vehicle Safety Standard No 205 "Glazing Materials" I would appreciate a copy of the Standard and any additional information on this subject. Thank you for your cooperation. |
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ID: nht76-4.37OpenDATE: 03/19/76 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Werner Incorporated TITLE: FMVSS INTERPRETATION |
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ID: nht74-2.4OpenDATE: 05/19/74 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Alfa Romeo, Inc. TITLE: FMVSS INTERPRETATION |
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ID: nht75-3.15OpenDATE: 05/04/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Gerard Inc. TITLE: FMVSR INTERPRETATION |
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ID: nht73-2.13OpenDATE: 12/12/73 FROM: AUTHOR UNAVAILABLE; Mark I. Schwimmer; NHTSA TO: To interpretations file TITLE: FMVSR INTERPRETATION |
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ID: nht75-2.16OpenDATE: 07/15/75 FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA TO: Volkswagen of America, Inc. TITLE: FMVSS INTERPRETATION |
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ID: nht76-4.4OpenDATE: 03/01/76 EST FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: ICI United States, Inc. TITLE: FMVSS INTERPRETATION |
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.