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: aiam4018OpenNorman Friberg, P.E., Manager, Product Compliance, Volvo Cars of North America, Rockleigh, NJ 07647; Norman Friberg P.E. Manager Product Compliance Volvo Cars of North America Rockleigh NJ 07647; Dear Mr. Friberg: This is to acknowledge receipt of your petition dated June 27, 1985 for a determination that a noncompliance with Federal Motor Vehicle Safety Standard No. 110 is inconsequential as it relates to motor vehicle safety.; Paragraph S4.3 of the standard requires that a specified placard sho the recommended tire size designation. Volvo has provided labels on approximately 3,200 passenger cars which show an incorrect recommended minimum tire size. Thus, these labels state '185/65R15' but the correct information is '185/70R15.' However, Volvo intends to mail correct placards 'to owners of all affected vehicles.'; By providing the corrective placard, Volvo will remedy th noncompliance. Because the noncompliance will no longer exist, the question of whether it has a consequential relationship to safety is moot. The remaining question is the adequacy of the notification which Volvo will provide owners of the affected vehicles. Because the corrective action is such that it may be easily accomplished by the owner (affixing the gummed placard to the car), the agency has concluded that any deviation of the text of the notice from the requirements of 49 CFR Part 577 would be a technical violation only. Therefore, NHTSA does not intend to seek re-notice or civil penalties for such a violation. Consequently, the agency intends no further action on your petition.; The agency's conclusions apply to the facts of this case only and d not necessarily represent the agency's posture in future cases involving forms of notification other than specified by Part 577, for noncompliances.; Our records indicate that Volvo is in technical noncompliance with 4 CFR Part 573, *Defect and Noncompliance Reports*, by failing to file a report within 5 days of its determination of the existence of the noncompliances. We will, however, treat the submission of information in your petition as a Part 573 report. Part 573 also requires 6 quarterly reports on the progress of recall campaigns. In your situation, the campaign will be accomplished in a single mailing. We ask that you furnish the agency with a report of the number of letters sent and the number of letters returned as undeliverable in lieu of the Part 573 quarterly reports.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3227OpenMr. Brian O'Meara, President & General Manager, O'Meara Ford Center, 400 West 104th Avenue, Denver, CO 80234; Mr. Brian O'Meara President & General Manager O'Meara Ford Center 400 West 104th Avenue Denver CO 80234; Dear Mr. O'Meara: This responds to your February 26, 1980, letter asking about the prope certification for a Ford Mustang that has been converted to a convertible. You ask what certification is required before you would be permitted to sell such a vehicle.; The National Highway Traffic Safety Administration requires al manufacturers of motor vehicles to certify that their vehicles comply with Federal safety standards prior to first sale. In the case of the vehicle that you mention, Ford Motor Company would have certified it when it was sold to the company that converted it to a convertible. Ford's certification label is located on the driver's door or pillar post.; The company that converted the vehicle, Tomaso of America, i responsible for putting its own label on the vehicle indicating that as altered the vehicle continues to comply with the applicable Federal safety standards. The requirements for alterers' labels are located in Title 49 of the Code of Federal Regulations, Section 567.7. Tomaso's label should also be located on the vehicle in the same area as Ford's.; If both of the labels are on the vehicle, it is legal for you to sel it. If either of the labels is missing from the vehicle, then the vehicle is not correctly certified and may be in noncompliance with the safety standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2820OpenMr. Wayne C. Parsil, Minnesota Claims Services, 402 South Cedar Lake Road, Minneapolis, Minnesota 55405; Mr. Wayne C. Parsil Minnesota Claims Services 402 South Cedar Lake Road Minneapolis Minnesota 55405; Dear Mr. Parsil: This responds to your inquiry concerning the steering wheel system on 1972 Plymouth Cricket. You ask whether Federal safety standards permitted non-collapsible steering columns on that vehicle model, whether the steering columns met all safety standards, and whether the vehicle manufacturer was exempted from Federal safety standards on the 1972 Plymouth Cricket because of hardship.; Federal Motor Vehicle SAfety Standard No. 203, *Impact Protection fo the Driver from the Steering Control System* (49 CFR 571.203), became effective for all passenger cars manufactured on or after January 1, 1968. Therefore, a 1972 Plymouth Cricket had to meet the performance requirements specified in that standard. I am enclosing a copy of Standard No. 203 for your information, and you should note that the standard does not specifically require 'collapsible steering columns. Rather, the standard limits the force loads that can be imparted by the steering column during a dynamic impact test.; Under Federal motor vehicle safety regulations, manufacturers ar required to determine for themselves that their vehicles are in compliance and to certify the vehicles as being in compliance. The National Highway Traffic Safety Administration only conducts compliance tests on a 'spot-check' basis for purposes of enforcement. Therefore, I cannot tell you whether the particular Plymouth with which you are interested was in fact in compliance with all safety standards. I can tell you that the agency has not made any determinations that the 1972 Plymouth Crickets failed to comply with Safety Standard No. 203.; Regarding your final question, no exemption from Standard No. 203 wa granted for the 1972 Plymouth Cricket.; please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3732OpenMr. David E. Martin, Director, Automotive Safety Engineering, Environmental Activities Staff, General Motors Corporation, General Motors Technical Center, Warren, MI 48090; Mr. David E. Martin Director Automotive Safety Engineering Environmental Activities Staff General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Martin: The Deputy Administrator has asked me to respond to your letter of Jul 18, 1983, concerning an expansion of your current field testing of anti-lacerative windshield glazing supplied by Saint-Gobain Vitrage. The expanded field test would involve the installation of anti-lacerative windshields produced by Libbey-Owens-Ford (LOF) in 550 1984 Buick Century and/or Oldsmobile Cutlass Ciera automobiles. You stated that the vision and abrasion resistance characteristics of the LOF material are similar to the Saint-Gobain material you are using in your current field tests. You also stated that you will closely monitor the test fleet and rectify any problems that may develop.; Under the limited and special circumstances of the field test describe in your letter, the agency would not enforce the abrasion requirement of Safety Standard No. 205, as it now stands, for the LOF anti-lacerative windshields to be used in your proposed field tests. We expect General Motors to keep the agency informed of all the results it obtains from this field test.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3362OpenMr. Mark Lundin, Services Coordinator, Interregional Services Corporation, 2021 East Hennepin Avenue, Minneapolis, MN 55413; Mr. Mark Lundin Services Coordinator Interregional Services Corporation 2021 East Hennepin Avenue Minneapolis MN 55413; Dear Mr. Lundin: This is in response to your letter of September 5, 1980, asking whethe there is a Federal bumper standard applicable to trucks, and who is responsible for installation of the rear bumper on a truck manufactured in two or more stages. You also inquire whether a truck without a rear bumper is considered a completed vehicle for purposes of Federal regulations, and whether a truck with a frame rail extending beyond the rear end of the vehicle body would violate Federal standards.; The Part 581 Bumper Standard (49 CFR Part 581) applies only t passenger motor vehicles other than multipurpose passenger vehicles. Thus, there is no Federal bumper standard applicable to trucks, and Federal regulations do not impose responsibility for bumper installation on any party in the chain of manufacture.; Part 568, Vehicles Manufactured in Two or More Stages, define 'completed vehicle' as a vehicle that requires no further manufacturing operations to perform its intended function, other than the addition of readily attachable components (49 CFR S 568.3). Since the vehicle referred to in your letter apparently is capable of performing its intended function without addition of a bumper, the absence of a bumper would not be relevant in determining the vehicle's final-stage manufacturer for purposes of compliance and certification of compliance with Federal motor vehicle safety standards (49 CFR SS 567.5 and 568.6).; At the present time, there are no Federal standards which prohibit th extension of a frame rail beyond the rear end of a truck body. However, the National Highway Traffic Safety Administration is considering proposal of a regulation which would require protective devices to reduce vehicle penetration under the rear ends of heavy trucks and trailers.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3698OpenMr. N. Cope, Eaton Limited, Truck Components Operations, Engineering Centre, P.O. Box 11, Worsley Road North, Worsley, Manchester, M28 5GJ, England; Mr. N. Cope Eaton Limited Truck Components Operations Engineering Centre P.O. Box 11 Worsley Road North Worsley Manchester M28 5GJ England; Dear Mr. Cope:#This responds to your recent letter asking a questio concerning Safety Standard No. 106, *Brake Hoses*. You note that there is an ambiguity in the formula referenced in paragraph S8.3.2(e) of that standard as set forth in the *Code of Federal Regulations*. Specifically, you ask whether the entire fraction that is specified is multiplied by '100' or whether only the denominator of the fraction is multiplied by '100'.#The correct formula is as follows:#>>>[((W3-W4) - (W1-W2)) / (W1- W2)] X 100<<<#The formula as specified in the *Code of Federal Regulations* should, therefore, include additional brackets around the fraction, separating the fraction from the 'X 100' figure. We will notify the *Federal Register* concerning this error.#I hope this has clarified any misunderstanding you may have had.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam2123OpenMr. J. A. Davies, Realco Services, Inc., 175 West Jackson Blvd., Chicago, IL 60604; Mr. J. A. Davies Realco Services Inc. 175 West Jackson Blvd. Chicago IL 60604; Dear Mr. Davies: This responds to Realco Services' October 10, 1975, question whethe the replacement of the four rails in the sides of a monocoque-type van would qualify as a vehicle assembly operation subject to certification to new vehicle standards, including Standard No. 121, *Air Brake Systems*.; The answer to your question is no. The position of the NHTSA wit regard to the use of used trailer components that was discussed in the Stainless Tank and Equipment interpretation letter applies only to situations in which a new trailer body is installed on used running gear. These limitations do not apply where most of the used body (along with used running gear) is retained, as where one or more rails are replaced in the sides of a used monocoque van.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2573OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Crampton: This responds to the Truck Body and Equipment Association's February 8 1977, petition for rulemaking to amend the definition of 'unloaded vehicle weight' and to add a new definition to 49 CFR Part 571.3 for 'special purpose vehicle.' The National Highway Traffic Safety Administration (NHTSA) denies your requested rulemaking.; Your petition requests an amendment of the term 'unloaded vehicl weight' similar to that proposed by Chrysler's December 20, 1976, petition. Both petitions recommend that, for purposes of barrier crash testing of certain vehicles, the unloaded vehicle weight be the lesser of the weight of a completed comparable model vehicle from which the particular vehicle is derived or 5,500 pounds. Further, you request an additional definition of 'special purpose vehicle' that would distinguish vehicles designed for a specific work function from other vehicles produced from the same chassis. We have determined that the effect of creating such a vehicle category as special purpose vehicle in conjunction with the establishment of arbitrary weights for vehicles when undergoing compliance testing would, in some situations, undermine the effectiveness of the motor vehicle safety standards. Vehicles falling into the category could, according to your suggested scheme, be tested at a weight which differs from their actual weight as equipped.; In the case of Standard No. 301, *Fuel System Integrity*, such a resul would possibly violate Congress' order in the 1974 Amendments to the National Traffic and Motor Vehicle Safety Act (Pub. L. 93-492) that the NHTSA not diminish the level of safety established at that time in the standard.; To allow certain vehicles to be tested at a weight which differs fro their actual weight, would permit the operation of vehicles which, as equipped, could fail the requirements of the standard.; You should note that the agency intends to proceed with the rulemakin to amend the definition of 'unloaded vehicle weight' as recommended in a petition from Chrysler dated November 29, 1976. This amendment will incorporate changes in the definition previously made by the NHTSA through interpretation.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2089OpenMr. Joe Steininger, Tiffin Metal Products, 450 Wall Street, Tiffin, OH 44883; Mr. Joe Steininger Tiffin Metal Products 450 Wall Street Tiffin OH 44883; Dear Mr. Steininger: This is in response to your request for an opinion on the applicabilit of Federal Motor Vehicle Safety Standard 205 to a road grader intended for use in highway construction.; The National Highway Traffic Safety Administration issues safet standards for 'motor vehicles.' Therefore, our regulations apply to a vehicle and its manufacturer only if the vehicle qualifies as a motor vehicle under the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. Section 102(3) of the Act defines motor vehicle as:; >>>any vehicle driven or drawn by mechanical power manufacture primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; Thus, a motor vehicle is a vehicle which the manufacturer expects wil use public highways as part of its intended function.; Tracked and other vehicles incapable of highway travel are not moto vehicles. In addition, vehicles intended and sold solely for off-road use (e.g. aircraft runway vehicles and underground mining vehicles) are not considered vehicles even if operationally capable of highway travel. They would, however, be considered motor vehicles if the manufacturer knew that a substantial proportion of his customers actually would use them on the highway.; Just as clearly, vehicles which use the highway on a necessary an recurring basis to move between work sites are motor vehicles. The primary function of some vehicles is of a mobile, work performing nature and as such their manufacturer contemplates a primary use of the highway. Mobile cranes, drill rigs, and towed equipment such as chippers and pull-type street sweepers are examples in this area. Even if the equipment uses highways infrequently, it is considered a motor vehicle. An exception to this is that occasional use of the highway in the immediate periphery of the work site, as is the case with some farm and construction equipment, would not by itself cause a finding that the vehicle is a motor vehicle. The motor vehicles described above generally qualify as trucks or trailers. As such they are subject to several of the motor vehicle safety standards, and the manufacturer must comply with other regulations in Chapter V of Title 49, code of Federal Regulations.; There are some vehicles which are excepted from the motor vehicl classification despite their use of the highway. Highway maintenance and construction equipment, lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles. This would appear to include road graders whose maximum speed does not exceed 20 miles per hour, if intended for use in highway construction.; From these guidelines you should be able to determine whether a piec of equipment qualifies as a motor vehicle.; Please write again if you are unable to make this determination. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1076OpenMr. R. J. Marini, State of New Jersey, Division of Motor Vehicles, 25 South Montgomery Street, Trenton, NJ 08666; Mr. R. J. Marini State of New Jersey Division of Motor Vehicles 25 South Montgomery Street Trenton NJ 08666; Dear Mr. Marini: This is in response to your letter of March 5, 1973, concerning th recently issued Federal odometer disclosure requirements.; Although we have not had the opportunity to review the revised Ne Jersey certificate of ownership, it appears that New Jersey is proceeding along lines that could make the certificate usable for purposes of compliance with our regulations. We are concerned, however, about the possibility of variance between State and Federal procedures.; The Federal regulation requires the transferor to state the mileage o the odometer at the time of transfer. In addition, if he knows the odometer reading to be wrong, he must so state by indicating that the actual mileage is unknown. Provision for a disclosure of odometer error is essential to the Federal regulation, and it is not clear to us that the New Jersey certificate provides for such a disclosure.; With respect to the older vehicles - those not subject to a revise certificate of ownership - the form attached to your letter will satisfy the Federal requirements. A disclosure statement of this type is required by our regulation to be made upon each transfer of a vehicle. I would hope that all dealers in New Jersey are receiving, and giving, such statements in each motor vehicle transaction.; Sincerely, Lawrence R. Schneider, 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.