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: aiam1453OpenMr. Erik Sundelin, Tire Department, Trellaborgs Gummifabriks Aktiebolag, S-23101 Trelleborg-Sweden; Mr. Erik Sundelin Tire Department Trellaborgs Gummifabriks Aktiebolag S-23101 Trelleborg-Sweden; Dear Mr. Sundelin: This responds to your February 20, 1974 request for a determination o whether two of your motorcycle treadwear indicator designs conform to the S6.4 requirements of Standard 119 *New pneumatic tires for vehicles other than passenger cars.*; The treadwear indicator requirements have been amended by deleting al of the portio of S6.4 that begins 'The indicators shall, as a minimum'. this means that the manufacturer determines for himself the location and design of the six treadwear indicators requires (three in the case of motorcycle tires). He must assure himself that when the indicator is reached, the tread at that point o the tire is worn to a depth of on-sixteenth of an inch (or one-thirty-second of an inch in the case of motorcycle tires).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0847OpenMr. Arthur N. Maupin, C. and M. Company, P. O. Box 1285, Zanesville, OH, 43701; Mr. Arthur N. Maupin C. and M. Company P. O. Box 1285 Zanesville OH 43701; Dear Mr. Maupin: This is in reply to your letter of August 12, 1972, in which you aske which manufacturers are subject to the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 302. You also asked us for permission to include copies of FMVSS No. 302 in your promotional literature, and requested copies of any modification or supplements to the flame test.; Any manufacturer of passenger cars, multipurpose passenger vehicles trucks, or buses manufactured on or after September 1, 1972, is subject to the requirements of the standard. FMVSS No. 302 is a published Federal regulation, and you may reproduce it and distribute it in your promotional literature. I have enclosed a copy of a Notice of Proposed Rule Making, 36 F.R. 9565, which would amend the standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0028OpenMr. L.L. Willis, Vice President - Engineering, Thermo King Corporation, 314 West 90th Street, Minneapolis, Minnesota 55420; Mr. L.L. Willis Vice President - Engineering Thermo King Corporation 314 West 90th Street Minneapolis Minnesota 55420; Dear Mr. Willis: Thank you for your letter of July 11, 1967, regarding the applicabilit of the Federal Motor Vehicle Safety Standards to accessories which are purchased for installation after procurement of the car, and in particular, Safety Standard No. 201.; Standard No. 201, 'Occupant Protection in Interior Impact -- Passenge Cars,' applies only to vehicles as originally equipped and does not apply to accessories such as 'after market' auto air conditioners. However, the public would certainly benefit from the maximum degree of conformance that may be feasible on after market installations.; It is sincerely regretted that a written response to your first reques was not received by you and trust that you were not inconvenienced.; Sincerely yours, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam2151OpenMr. George H. Schildge, Exec. Vice President, Conti Rubber Products, 4900 Hannover Place, P.O. Box 1638, Fremont, California 94538; Mr. George H. Schildge Exec. Vice President Conti Rubber Products 4900 Hannover Place P.O. Box 1638 Fremont California 94538; Dear Mr. Schildge: This is in response to your October 29, 1975, letter concerning th applicability of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles other than Passenger Cars*, to moped tires.; Mopeds are classified under 49 CFR 571.3 as 'motor-driven cycles', subcategory of 'motorcycles', for the purposes of the National Highway Traffic Safety Administration's regulations. Therefore, tires designed for use on mopeds are tires designed for use on motorcycles and, as such, are subject to Standard No. 119. The NHTSA is considering an amendment of Standard No. 119 which would modify the requirements applicable to such tires, and expects to issue a notice of proposed rulemaking on this subject on the near future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2690OpenMr. Robert W. Locke, Manager RV Sales, Indiana Mills and Manufacturing, Inc., 120 W. Main Street, Carmel, IN 46032; Mr. Robert W. Locke Manager RV Sales Indiana Mills and Manufacturing Inc. 120 W. Main Street Carmel IN 46032; Dear Mr. Locke: This is in response to your letter of October 4, 1977, to Mr. Franci Armstrong of our Office of Standards Enforcement, in which you asked whether our regulations require seat belts in fifth wheel vehicles.; Our seat belt requirements are specified in Federal Motor Vehicl Safety Standard No. 208 (49 CFR 571.208), which applies to passenger cars, multipurpose passenger vehicles, trucks and buses. I am assuming that by fifth wheel vehicle you mean a towed vehicle attached to the towing vehicle by means of a fifth wheel. If I am correct in this assumption, these vehicles would be classified as trailers, which are not subject to Standard No. 208. There would therefore be no Federal requirement for seat belts in these vehicles.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1999OpenMr. Terrell T. Coleman, Codes and Standards Coordinator, Holiday Rambler Corporation, 311 Indiana Avenue, Wakarusa, Indiana 46573; Mr. Terrell T. Coleman Codes and Standards Coordinator Holiday Rambler Corporation 311 Indiana Avenue Wakarusa Indiana 46573; Dear Mr. Coleman: I am writing in response to your letter of June 23, 1975, whic inquired about the status of proposed Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The NHTSA expects to issue Standard No. 120 in the near future. It wil not become effective September 1, 1975. An effective date which allows adequate lead time for manufacturers to prepare for compliance will be specified in a *Federal Register* notice when the rule is issued. Your second question, concerning the responsibility for providing GAWR and GVWR information for motor homes manufactured by you with chassis supplied by other manufacturers, will also be answered in that notice.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1234OpenMs. Dianne Black, Engineering Liaison Assistant, British Leyland Motors, Inc., 600 Willow Tree Road, Leonia, NJ, 07605; Ms. Dianne Black Engineering Liaison Assistant British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black: This is in reply to your letter or July 18, 1973, regarding th applicability of Standard No. 302, 'Flammability of Interior Materials,' to a temporary sunvisor sleeve British Leyland plans for each of its 1974 model cars, to inform occupants about the seat belt interlock system.; The applicability of Standard No. 302 depends on whether th instruction sleeve is attached in such a way as to appear as a permanent part of the sunvisor or some other interior component covered by the standard. If the instruction sleeve is easily removable, is obviously not part of the sunvisor, and is clearly intended to be removed by the owner, we would not consider the sunvisor sleeve to be subject to the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3160OpenMr. Edward F. Tannery, Theodore Bargman Company, 129 Industrial Avenue, Coldwater, MI 49036; Mr. Edward F. Tannery Theodore Bargman Company 129 Industrial Avenue Coldwater MI 49036; Dear Mr. Tannery: This responds to your recent letter asking whether doors on aftermarke top covers for American Motors Jeeps would have to comply with Safety Standard No. 206, *Door Locks and Door Retention Components*.; Safety Standard No. 206 applies to passenger cars, trucks an multipurpose passenger vehicles, which would include Jeeps. The standard applies only to completed vehicles, however, and not to aftermarket motor vehicle equipment. Therefore, the doors on aftermarket Jeep top covers would not have to have locks. Further, doors on new Jeep vehicles would also not have to comply with the standard if they are 'designed to be easily attached to or removed from' the vehicle, as provided in section S4 of the standard.; Please contact Hugh Oates of my office if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2680OpenMr. Jerry McNeil, American Trailers, Inc., 1500 Exchange Avenue, Box 26568, Oklahoma City, Oklahoma 73126; Mr. Jerry McNeil American Trailers Inc. 1500 Exchange Avenue Box 26568 Oklahoma City Oklahoma 73126; Dear Mr. McNeil: This responds to your July 20, 1977, letter asking whether you certification labels comply with Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; As stated to you in an earlier letter, the National Highway Traffi Safety Administration does not issue approvals of compliance with Federal safety standards or regulations.The agency will, however, give you an informal opinion as to whether your labels appear to comply with the requirements. The agency has determined that the two labels that you submitted do not follow the format established in the regulations and, therefore, do not comply with the requirements. If 'R' denoted radial ply and 'F' denoted load range, the tire designation should be 10.00 R 20(F).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1207OpenMr. Robert B. Hirsch, Adams Rite Products, Inc., 540 West Chevy Chase Drive, Glendale, CA 91209; Mr. Robert B. Hirsch Adams Rite Products Inc. 540 West Chevy Chase Drive Glendale CA 91209; Dear Mr. Hirsch: This is in response to your July 25, 1973, request for copies of th Federal regulations concerning door locks and latches.; Federal Standard 206, *Door Locks and Door Retention Components*, i enclosed. It regulates passenger cars, multipurpose passenger vehicles, and trucks. These categories include ambulances and 'motor homes', which are self-propelled units with sleeping accommodations, generally constructed on a light truck chassis. Most other 'mobile homes' are not self- propelled and they qualify as trailers, which are not subject to this standard.; For your information, paragraph 9.1.2 of *Ambulance Design Criteria has also been enclosed. This publication specifies the criteria which an ambulance must meet to qualify for Federal funding under the Highway Safety Program S 402.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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.