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: 1984-1.38OpenTYPE: INTERPRETATION-NHTSA DATE: 04/08/84 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Mr. Troy C. Martin TITLE: FMVSS INTERPRETATION |
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ID: nht87-3.44OpenTYPE: INTERPRETATION-NHTSA DATE: 12/11/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Mr. Scott Muirhead TITLE: FMVSS INTERPRETATION |
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ID: 77-4.1OpenTYPE: INTERPRETATION-NHTSA DATE: 09/03/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: State Department of Education - Virginia TITLE: FMVSS INTERPRETATION |
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ID: 1984-1.4OpenTYPE: INTERPRETATION-NHTSA DATE: 01/26/84 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Ms. Margaret Moore Oba TITLE: FMVSS INTERPRETATION |
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ID: 1983-3.11OpenTYPE: INTERPRETATION-NHTSA DATE: 10/17/83 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Sebring Air Terminal PAR=LOCATION TITLE: FMVSR INTERPRETATION |
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ID: 77-2.25OpenTYPE: INTERPRETATION-NHTSA DATE: 05/01/77 EST FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA TO: Department of Education - New Jersey TITLE: FMVSS INTERPRETATION |
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ID: 19401b.drnOpenMr. W. Grey Perry Dear Mr. Perry: This responds to your January 7, 1999, request for information regarding sales or leases of rental vehicles by dealers to schools and day care centers for occasional use. We assume that the vehicles you ask about are new "buses," i.e., they are designed for carrying more than 10 persons, including the driver, and that they do not meet Federal school bus standards. The short answer is that Federal law permits the lease of such a bus to transport school children on a one-time or very occasional basis. However, the sale or lease is not lawful if a significant use of the bus is to transport school children to or from school or school-related activities. Further, because States have the authority to regulate the use of vehicles under State law, you should review the law of North Carolina to see if it addresses a lease of the bus. By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue and enforce Federal motor vehicle safety standards applicable to new motor vehicles. Our statute at 49 U.S.C. 30112 requires any person selling or leasing a new vehicle to sell or lease a vehicle that meets all applicable standards. Accordingly, persons selling or leasing a new "school bus" must sell or lease a vehicle that meets the safety standards applicable to school buses. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, NHTSA decides, is likely to be "used significantly" to transport "preprimary, primary, and secondary" students to or from school or related events. 49 U.S.C. 30125. By regulation, the capacity threshold for school buses corresponds to that of buses -- vehicles designed for carrying more than ten (10) persons. For example, a 15-person van that is likely to be used significantly to transport students is a "school bus." If the new large (11 persons or more capacity) van were sold or leased to a school and used on a regular or long-term basis to transport students, the vehicle must meet NHTSA's school bus standards. Conventional 15-person vans are not certified as doing so, and thus new 15-person vans cannot be sold or leased under circumstances where they are likely to be used to carry students on a regular basis. However, a one-time or very occasional rental would be permitted, on the grounds that the vehicle would not be used significantly to transport children to and from school and would thus not be a school bus. I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, |
1999 |
ID: nht72-3.13OpenDATE: 04/03/72 FROM: Robert L. Carter; NHTSA TO: Fabrica Pisana S.P.A. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of March 10, 1972, concerning marking of your glazing materials intended for the American market. The marking you propose to use satisfied the requirements of Standard No. 205, Glazing Materials. |
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ID: nht72-6.5OpenDATE: 06/14/72 FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA TO: Memorandum to interpretations file TITLE: FMVSR INTERPRETATION TEXT: SUBJECT: FIAT AMBULANCE Giuseppe Carretto, the Fiat lawyer, telephone me on June 14 to ask 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. |
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ID: nht75-4.50OpenDATE: 12/03/75 FROM: AUTHOR UNAVAILABLE; MaRK Schwimmer; NHTSA TO: For Interpretation file TITLE: FMVSR INTERPRETATION TEXT: On December 1, 1975, I received a telephone call from Mr. Nakajima of Bridgestone Tire Co. (213-320-6030) concerning the meaning of the March 1, 1975, effective date of Standard No. 119. He wanted confirmation that tires, for vehicles other than passenger cars, that were manufactured before that date are not subject to the standard's labeling requirements. I explained that his understanding was correct, citing 49 CFR @ 571.7. |
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.