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: nht95-4.77OpenTYPE: INTERPRETATION-NHTSA DATE: November 15, 1995 FROM: Richard L. Russell TO: Blane Laubis -- Office of Vehicle Safety Compliance, US Dept. of Transportation TITLE: NONE ATTACHMT: 12/22/95 letter from Samuel J. Dubbin to Richard L. Russell (A43; Std. 108) TEXT: I now have two DOT Approved headlights on my 1956 Jeep and I would like to add two additional Auxiliary Lights to supplement my highbeams. These lights would be wired into the highbeam switch, so that, they can only be used on highbeam and mounted on my bumper below my DOT Approved headlights (36.5" from the ground). My question is . . . are my auxiliary lights required to be DOT approved? Are they required to be SAE approved? And is there any limitation to bulb wattage for auxiliary lights used to supplement the DOT approved headlights while they are on highbeam? I understand that the State of California may have regulations to further define or restrict the use of auxiliary lights. I would appreciate your response to these questions at your earliest convenience. |
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ID: nht95-7.38OpenTYPE: INTERPRETATION-NHTSA DATE: November 15, 1995 FROM: Richard L. Russell TO: Blane Laubis -- Office of Vehicle Safety Compliance, US Dept. of Transportation TITLE: NONE ATTACHMT: 12/22/95 letter from Samuel J. Dubbin to Richard L. Russell (A43; Std. 108) TEXT: I now have two DOT Approved headlights on my 1956 Jeep and I would like to add two additional Auxiliary Lights to supplement my highbeams. These lights would be wired into the highbeam switch, so that, they can only be used on highbeam and mounted on my bumper below my DOT Approved headlights (36.5" from the ground). My question is . . . are my auxiliary lights required to be DOT approved? Are they required to be SAE approved? And is there any limitation to bulb wattage for auxiliary lights used to supplement the DOT approved headlights while they are on highbeam? I understand that the State of California may have regulations to further define or restrict the use of auxiliary lights. I would appreciate your response to these questions at your earliest convenience. |
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ID: 22007.drnOpenMr. Charles E. Carter Dear Mr. Carter: This responds to your August 8, 2000, request for an interpretation whether it is permissible to sell a new 15-passenger van to a college or university for the transport of students. Assuming the college will be using the van to transport college students, the answer is yes. Our statute defines a "schoolbus" as any vehicle that is designed for carrying a driver and more than 10 passengers and which, the National Highway Traffic Safety Administration (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. We do not consider buses sold for the transportation of college-age students to be school buses. I hope this information is helpful. If you have any further questions about NHTSA's programs, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Frank Seales, Jr. ref:VSA#571.3 |
2000 |
ID: 1985-02.46OpenTYPE: INTERPRETATION-NHTSA DATE: 06/24/85 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Dick Kruse -- Secondary School Principals Association TITLE: FMVSS INTERPRETATION TEXT:
Mr. Dick Kruse Secondary School Principals Association 1904 Association Drive Reston, Virginia 22091
This responds to your May 30, 1985 telephone call to this office asking two related questions about our school bus regulations. Your first question asked whether the National Traffic and Motor Vehicle Safety Act prohibits the sale of a used commercial-type bus to a school district for use on school-related events. The answer to your question is no. The Act only applies to the manufacture and sale of new motor vehicles and new motor vehicle equipment. Persons selling a used bus to a school district are not subject to the Act's requirement to sell certified school buses, and a used commercial-type bus, regardless of its model year, may be sold as an activity bus.
Your second question asked whether section 108(a)(1)(A) of the Vehicle Safety Act is applicable to manufacturers and dealers who sell used commercial-type buses to school districts. The answer is no. Section 108(a)(1)(A) prohibits the manufacture and sale of any new motor vehicle or item of motor vehicle equipment that does not conform to applicable motor vehicle safety standards. Therefore, there would be no Federal penalty upon a person selling a used commercial-type bus for school use.
Sincerely, Jeffrey R. Miller Chief Counsel |
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ID: 3198yyOpen c:\temp\interpretations\text\3198yy.txt |
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ID: 3202yyOpen c:\temp\interpretations\text\3202yy.txt |
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ID: nht76-1.48OpenDATE: 02/24/76 FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA TO: file TITLE: FMVSS INTERPRETATION |
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ID: nht75-2.17OpenDATE: 12/04/75 FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA TO: FILE TITLE: FMVSS INTERPRETATION |
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ID: nht72-3.8OpenDATE: 05/10/72 FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA TO: Dockets TITLE: FMVSS INTERPRETATION |
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ID: nht74-1.48OpenDATE: 05/23/74 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: The Flxible Company 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.