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: nht68-1.38OpenDATE: 04/30/68 FROM: DAVID A. FAY -- NHTSA OFFICE OF STANDARDS ON ACCIDENT AVOIDANCE MOTOR VEHICLE SAFETY PERFORMANCE SERVICE TO: J.E. MARTENS -- CHIEF AUTOMOTIVE SAFETY ENGINEER AMERICAN MOTORS CORPORATION TITLE: NONE TEXT: Dear Mr. Martens: Thank you for your letter of February 28, 1968, addressed to Mr. George C. Nield, concerning Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces." Motor Vehicle Safety Standard No. 107 specifies reflectivity requirements for only the inside windshield molding itself -- not for the screws or fasteners used to attach the molding. Sincerely, |
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ID: nht88-4.48OpenTYPE: INTERPRETATION-NHTSA DATE: 12/21/88 FROM: HOWARD WOLPE -- MEMBER OF CONGRESS TO: JAMES BURNLEY -- SECRETARY OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 02/23/89 FROM DIANE K. STEED TO HOWARD WOLPE, REDBOOK A33, SECTION 103(D), FMVSS 222; HSPG 17; LETTER DATED 12/12/88 FROM DENNIS D. FURR TO HOWARD WOLPE -- CONGRESS TEXT: Dear Secretary Burnley: Enclosed please find a copy of a letter from one of my constituents, Mr. Dennis Furr. Your consideration of his questions and concerns would be greatly appreciated. Sincerely, ENCLOSURE |
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ID: nht93-4.33OpenDATE: June 14, 1993 FROM: Kenneth E. Ross -- C.P.A. TO: Consumer Coordinator, NHTSA TITLE: None ATTACHMT: Attached to letter dated 8/13/93 (est) from John Womack to Kenneth E. Ross (A41; Std. 108; Std. 111) TEXT: We will soon be introducing a new consumer product which attaches to the back window of an automobile. We believe it is small enough not to block the driver's rear view. Can you tell us: 1) are there any NHTSA rules, standards, guidelines or opinions on the subject? 2) do you have any studies of state or local laws on the subject? |
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ID: nht92-7.20OpenDATE: May 1, 1992 FROM: Ray Wyatt TO: Chief Counsel -- NHTSA TITLE: None ATTACHMT: Attached to letter dated 10/14/92 from Paul Jackson Rice to Ray Wyatt (A40; Part 567; VSA 102) TEXT: I have a race car that was made for racing only, and I would like to do the necessary work to the car to make it street legal. Can you give me information on the requirements I would have to meet? Also, if I am successful at converting the car for street use, would the requirements be different if I wanted to sell the car or others like it? |
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ID: nht94-4.30OpenTYPE: INTERPRETATION-NHTSA DATE: September 16, 1994 FROM: Ricardo Martinez, M.D. -- Administrator, NHTSA; Signature by Christopher A. Hart TO: Doug Bereuter -- U.S. House of Representatives TITLE: NONE ATTACHMT: Attached to letter dated 06/16/94 from Doug Bereuter to Christopher Hart (OCC 10107) TEXT: Thank you for your letters concerning the status of our rulemaking on compressed natural gas fuel containers. I am pleased to enclosed a copy of the final rule that has been issued on this topic. I want to ensure you that one of my principal goals as t he National Highway Traffic Safety Administration's new Administrator is to make the agency's rulemeking process more efficient. |
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ID: nht89-1.8OpenTYPE: INTERPRETATION-NHTSA DATE: 01/30/89 FROM: JAMES R. TOMAINO -- MARKETING MANAGER YOUNGSTOWN RUBBER PRODUCTS CO TO: ERIKA JONES -- CHIEF COUNSEL NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 04/27/89 FROM ERIKA Z. JONES -- NHTSA TO JAMES R. TOMAINO, REDBOOK A33(2); STANDARD 106 TEXT: Dear Ms. Jones: I am submitting to you for review, one air brake hose assembly to determine if our symbol is sufficient for approval. The permanently embossed raised dot has been used on other assemblies by our company for over ten years. We seek now clearance to f abricate air brake assemblies for wholesale and retail sales. Your most prompt attention would be appreciated. Thank you. Sincerely, ENCLOSURE |
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ID: nht91-7.27OpenDATE: December 3, 1991 FROM: Hal Balzak TO: NHTSA, U.S. DOT TITLE: None ATTACHMT: Attached to letter dated 6/11/92 from Paul J. Rice to Hal Balzak (A39; Std. 201; VSA 108(a)(2)(A)) TEXT:
I recently received and reviewed a copy of your Motor Vehicle Safety Standard No. 201. To facilitate my more complete understanding, I need your clarification of two issues. Please forward your response to the following questions. Does your Standard No. 201 apply to: o Passenger cars manufactured between January 1, 1968 and September 1, 1981? o Instrument panels manufactured for replacement of units damaged by collision, exposure to sunlight, etc.? Your prompt response will be greatly appreciated. |
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ID: nht94-4.60OpenTYPE: INTERPRETATION-NHTSA DATE: October 24, 1994 FROM: Mariano Garcia -- Ricca & Whitmire TO: Chief Council, NHTSA TITLE: Re: Whether or not the D.O.T. regulates the manufacturing or certification of Kawasaki "Mule" KAF 450-B1 ATTACHMT: Attached to 1/17/95 letter from Philip Recht to Mariano Garcia (A43; VSA 102(3)) TEXT: To Whom It May Concern: This is to request a brief statement regarding whether or not the above referenced vehicle is covered by D.O.T. Regulations. I attach a brochure for your reference. This vehicle is primarily used as an "off-road" light utility vehicle. Therefore, please state if any regulations apply. I sincerely appreciate your help and response. Sincerely Enclosure: Mule 1000/2510 brochure. (Text omitted. See original document.) |
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ID: nht91-2.14OpenDATE: March 6, 1991 FROM: Anthony J. Lalikos -- Project Engineer, Titeflex Corporation TO: Vernon G. Bloom -- Crash Avoidance Division, DOT TITLE: None ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Nicholas S. Copass (A42; Std. 106), letter dated 9/29/93 from Nicholas S. Copass to David Elias (OCC-9161), and letter dated 3/18/91 from Arthur H. Neill, Jr. to Anthony J. Lalikos TEXT: Enclosed, as per our phone conversation on March 6th, is the information needed to register TITEFLEX Corp. as an approved supplier of bulk brake hose and brake hose assemblies. TITEFLEX CORPORATION shall be identified by the following marking on its products: (GRAPHICS OMITTED) (The TITEFLEX Logo) All Products are manufactured by: TITEFLEX CORPORATION 603 Hendee Street Springfield, Massachusetts 01109 Phone - (413) 739-5631 Please refer any questions or comments to Doug Colby or Tony Lalikos, and please call us when our registration is confirmed. Thank you. |
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ID: 19235.drnOpenMr. Fritz Litchfield Dear Mr. Litchfield: This responds to your December 4, 1998, letter asking whether your motor vehicle rental business may rent 15-person vans to schools. Your letter states that your company rents 15-person vans to schools by the day, and does not sell or lease the vans to schools on a long term basis. The National Highway Traffic Safety Administration (NHTSA) has previously stated that Federal law permits van rental to schools on a one-time or very occasional basis. However, because States have the authority to regulate the use of vehicles, you should contact Wisconsin officials to see if State law would permit the rental of the vans to schools. We have enclosed a copy of a December 18, 1997, letter from us to Congressman Phil English. The letter discusses NHTSA's statutory authority to regulate sales, leases and rentals of buses to schools. If you have questions about Wisconsin State requirements for student transportation, please contact: Mr. Robert Christian I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama at this address or by telephone at (202) 366-2992. Sincerely, |
1999 |
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.