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: nht94-2.54OpenTYPE: INTERPRETATION-NHTSA DATE: April 21, 1994 FROM: Fred Carr -- Engineer, Utilimaster TO: John Womack -- Acting Chief Council, NHTSA TITLE: None ATTACHMT: Attached To Letter Dated 5/16/94 From John Womack To Fred Carr (A42; Std. 211) TEXT: Dear Mr. Womack, Please inform us as to whether Standard 571.211 applies to Motor Vehicle equipment relating to light duty, medium duty, and heavy duty trucks or truck manufacturers. Respectfully yours, |
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ID: nht90-2.92OpenTYPE: Interpretation-NHTSA DATE: June 22, 1990 FROM: Ed McCarron -- Western Star Trucks Inc. TO: Dee Fujita -- Chief Counsel's Office, NHTSA TITLE: FMVSS 302 Burn Test ATTACHMT: Attached to letter dated 6-29-90 to E. McCarron from P. J. Rice; (A35; Std. 302) TEXT: As per our conversation, below is a sketch (cross section). This shows the corner of a cushion, specifically a mattress. (Graphics omitted See illustration on original. 1) cover 2) foam 3) foam backing 4) fill 5) corner reinforcement 6) fill backing (at corners) Can you please recommend how this would be tested. |
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ID: nht89-3.43OpenTYPE: INTERPRETATION-NHTSA DATE: 11/21/89 FROM: MICHAEL S. KMIECIK TO: NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 05/30/90, DN A35 STD 215, FROM STEPHEN P. WOOD -- NHTSA TO MICHAEL S. KMIECIK; Alpha I GTO, Ferrari on Rice (article omitted) TEXT: I would like to purchase several of these kits and produce a few cars for resale. I need an interpretation of Safety Standard 581. If Datsun is produced before Sept. 1, 1976 are used does this kit meet the requirements of Safety Standard 215. Also cou ld you please send me a copy of Safety Standard 215 and Safety Standard 108. |
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ID: nht89-1.76OpenTYPE: INTERPRETATION-NHTSA DATE: APRIL 18, 1989 FROM: WILLIAM SHAPIRO -- MGR., PRODUCT COMPLIANCE, VOLVO CARS OF NORTH AMERICA TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA TITLE: REQUEST FOR INTERPRETATION, OUR LETTER JULY 11,1988 ATTACHMT: ATTACHED TO LETTER DATED 4-16-90 TO WILLIAM SHAPIRO FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 7-11-88 TO ERIKA Z. JONES FROM WILLIAM SHAPIRO. TEXT: Enclosed is a copy of our July 11, 1988 letter re: FMVSS 210. We would appreciate your reply as soon as possible because our engineering department is awaiting an answer. Thank you for your attention. Enc. |
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ID: nht88-1.90OpenTYPE: INTERPRETATION-NHTSA DATE: 04/08/88 FROM: STRAHAN, DANA -- CITY OF ORANGE WATER DEPARTMENT TO: RALPH HITCHOCK TITLE: NONE ATTACHMT: DECEMBER 20, 1988 LETTER FROM JONES TO STRAHAN TEXT: Pls send copy of regulations that are applicable to the GVWR labeling on trucks to Mr. Dana Strahan (Phone 714-532-0356)City of Orange Water Department P.O. Box 449 Orange, Ca 92666-1591 They have modified a vehicle(s) to increase its GVWR above that on the original label, and would like to relabel it (i.e., label says 10,000 lbs, new GVWR is higher). They are concerned about liability which may arise due to the mis labeling. |
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ID: nht87-1.31OpenTYPE: INTERPRETATION-NHTSA DATE: 02/12/87 FROM: BRUCE W. SMITH -- PRESIDENT UNIT CORPORATION TO: JONES -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/04/87 TO BRUCE W SMITH FROM ERIKA Z JONES, REDBOOK A30(2) STANDARD 213, VSA 103 OCC - 211 TEXT: Dear Mrs. Jones Unit Corporation would like to have your office's recommendation on one of our new products. Talking to a member of your staff we found out that our product will fall under a law called General Defect Responsibility. We would also like this verified. I hope this report gives you enough information on our final product to give us a recommendation. If you have any questions or suggestions please contact me. Sincerely, |
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ID: nht91-5.12OpenDATE: August 1, 1991 FROM: Thomas R. Steinhagen -- Director of Marketing, Custom Accessories, Inc. TO: Dee Fujita -- Chief Counsel Office, NHTSA TITLE: Re: NHTSA 571.107 Standard; Reflecting Surfaces ATTACHMT: Attached to letter dated 9-3-91 from Paul Jackson Rice to Thomas R. Steinhagen (A38; Std. 107; VSA 108(a)(2)(A)) TEXT: Custom Accessories, Inc. is an automotive aftermarket accessory manufacturer. Our products are sold at retail, to the end consumer. We do not manufacturer any products for OEM use. One of our products is a wiper blade assembly. We would like your official ruling as to whether aftermarket manufactured wiper blades are covered by NHTSA Standard 571.107; Reflecting Surfaces. Your immediate response will be most appreciated. |
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ID: nht95-5.6OpenTYPE: INTERPRETATION-NHTSA DATE: December 20, 1995 FROM: Charles E. Grassley -- United States Senator TO: Thomas D. Larson -- Administrator, Federal Highway Administration TITLE: NONE ATTACHMT: 1/29/96 letter from Carol Stroebel to Charles E. Grassley (A44; Std. 208); 12/11/95 letter from Samuel J. Dubbin to Dorothy Jean Arnold; 9/24/95 letter from Dorothy J. Arnold to NHTSA Office of Chief Counsel TEXT: I have been contacted by Dr. D. Jean Arnold who is disabled and would like to have the air bag from her car legally removed. I would appreciate any information you could provide pertaining to this matter. Please mark your return correspondence to the attention of Dawn Latham when responding to my office. Thank you for your attention to my request. |
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ID: nht93-5.44OpenTYPE: Interpretation-NHTSA DATE: August 2, 1993 FROM: Jane L. Dawson -- Specifications Engineer, Thomas Built Buses, Inc. TO: Charlie Hott -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 2/14/94 from John Womack to Jane L. Dawson (A42; Std. 111) TEXT: As a follow-up to our recent phone conversation, please provide a written response to the following questions concerning FMVSS 111: Are we required to certify that the mirror system HAS THE ABILITY to be adjusted for viewing of the cylinders by a 25th percentile female or to certify that the mirror system HAS BEEN adjusted? Are the outside rearview mirrors required to view the area STRAIGHT DOWN from the mirrors and 200' rearward? Thanks for your cooperation. |
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ID: nht91-1.28OpenDATE: January 24, 1991 FROM: Samuel Yk Lau -- Kenwo Industries Ltd. TO: NHTSA TITLE: None ATTACHMT: Attached to letter dated 2-22-91 from Paul Jackson Rice to Samuel Yk Lau (A37; Std. 108) TEXT: We are manufacturer of "Additional Brake Lamps" and are planning to export this product to the U.S.A. The "Additional Brake lamp" is the add-on lamp which is usually mounted near the rear windshield of a private car and it turns on when the brake pedal is pushed. The product we manufacture now consists of light bulb, LED and red transparant plastic filter plate. We would like to ask of there are regulations, standards or approval for this kind of product. Does this product need to have any certificate or approval before it can be sold or installed? We will be very grateful if your department can give me the answers. |
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.