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: nht75-6.40OpenDATE: APRIL 16, 1975 FROM: MR. SICKS; MR. PETZOLDT -- FACHNORMENAUSSCHUSS TO: NHTSA, DOCKET SECTION TITLE: BURNING BEHAVIOUR OF INTERIOR MATERIALS FOR MOTOR VEHICLES ATTACHMT: ATTACHED TO LETTER DATED 5-9-75 TO MR. SICKS FROM RICHARD B. DYSON TEXT: In March 1975 the ISO Central Secretariat has published DRAFT INTERNATIONAL STANDARD ISO/DIS 3795 - Road vehicles - Determination of burning behaviour of interior materials for motor vehicles Please find enclosed the English version of this Draft International Standard. As mentioned in our letter of September 3, 1974 Sub-Committee 16 decided to require in this Draft International Standard the presence of supporting wires in all cases in order to avoid subjective interpretations of sample behaviour by the test personnel. As it is essential that laboratories charged with flammability tests conduct these tests according to the same procedure, we ask you to take into consideration the specifications of ISO/DIS 3795. We would appreciate it very much, if you could modify MVSS 302 so that also this standard requires the presence of supporting wires in all tests. We look forward to receiving your reply. (Attachment Omitted) |
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ID: aiam0777OpenMr. J. A. Westphal, Senior Staff Engineer, FWD Corporation, Clintonville, WI, 54929; Mr. J. A. Westphal Senior Staff Engineer FWD Corporation Clintonville WI 54929; Dear Mr. Westphal: This is in reply to your letter of July 7, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', as to mattress assemblies.; Paragraph S4.1 of Standard No. 302 lists mattress covers only. Thi does not include the complete mattress assembly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0949OpenMr. Gene L. King, Mayfair Bedding Co., 2029 Alum Rock Avenue, San Jose, CA, 95116; Mr. Gene L. King Mayfair Bedding Co. 2029 Alum Rock Avenue San Jose CA 95116; Dear Mr. King: This is in reply to your letter of October 23, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to house boats and tent camp trailers.; Standard No. 302 applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. This does not include house boats or tent camp trailers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: nht89-1.22OpenTYPE: INTERPRETATION-NHTSA DATE: 02/17/89 FROM: PAUL WALKER -- SUNQUEST INC PRESIDENT TO: ERIKA Z. JONES -- CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 06/09/89 FROM ERIKA Z. JONES -- NHTSA TO PAUL WALKER, REDBOOK A33 [4]; INTERP 205; INTERP 302 TEXT: Dear Ms. Jones: A new product has been developed by this company, which we are being strongly encouraged by the U.S. Department of Commerce to export to the Middle East. The product is remote-controlled electronic automobile window shades. This product is targetted in itially to the Saudi Arabian market because of their extreme heat. The window shades protect the interior of the automobile, and automatically roll up when the ignition is turned on. They cannot be lowered while the engine is running. Technological support is provided to us by the Georgia Institute of Technology. Total production for the next two years will be for export only, because of the strong demand created by the extreme heat aforementioned. Saudi Arabia's Standards of Organization require a letter or statement from the appropriate U.S. agency stating that there is no objection to the product in the U.S. market if we export in large quantities. We would be pleased if you could supply this letter or direct us to the appropriate source. Your prompt reply will be greatly appreciated. Sincerely, |
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ID: aiam0859OpenMr. R. C. Rittersporn, Sales Manager, Sealy of the Carolinas, Inc., P.O. Box 1009, Lexington, NC, 27292; Mr. R. C. Rittersporn Sales Manager Sealy of the Carolinas Inc. P.O. Box 1009 Lexington NC 27292; Dear Mr. Rittersporn: This is in reply to your letter of September 22, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'.; You ask whether the Standard applies to slide-in campers. The answer i that it does not. You also ask about the effective date of the Standard. Standard No. 302 was issued on December 9, 1970, and became effective with respect to vehicles manufactured on or after September 1, 1972.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0689OpenMrs. Janet P. Lannan, Office Manager, Coirtex, 4535 North Ravenswood Avenue, Chicago, IL, 60640; Mrs. Janet P. Lannan Office Manager Coirtex 4535 North Ravenswood Avenue Chicago IL 60640; Dear Mrs. Lannan: This is in reply to your letter of April 19, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials' to 'coco fibre' floor mats which you supply to distributors who resell them to dealers for optional placement in cars.; Standard No. 302 does not apply to floor coverings that are no provided with the vehicle by its manufacturer. Consequently, aftermarket floor mats are not subject to its requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2372OpenMr. Don Dekker, Attwood Corporation, Lowell, MI, 49331; Mr. Don Dekker Attwood Corporation Lowell MI 49331; Dear Mr. Dekker: This is in response to your letter of June 23, 1976, in which you as whether Standard No. 302, *Flammability of Interior Materials*, applies to portable toilets.; Standard 302 applies to the motor vehicles listed in Section S3 including the equipment installed in them at the time of sale. Section S4 lists those parts of a motor vehicle that must comply with burn resistance requirements, and a portable toilet is not included. Therefore, it is not subject to the standard. I have enclosed a copy of the standard for your information.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0617OpenMr. Jack Gardner, President, Artcraft - Milwaukee, Inc., 117 West Pittsburgh Avenue, Milwaukee, WI, 53204; Mr. Jack Gardner President Artcraft - Milwaukee Inc. 117 West Pittsburgh Avenue Milwaukee WI 53204; Dear Mr. Gardner: This is in reply to your letter of February 25, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to replacement bus seat covers.; Standard No. 302 does not apply to aftermarket or replacemen materials. It applies only to new vehicles manufactured after September 1, 1972, as of the time of their manufacture, and does not apply to replacement materials used in those vehicles.; We trust this clarifies the situation for you. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2368OpenMs. Susan Soodek, Assistant Director, Government Affairs Department, APAA, 1730 K Street, N.W., Washington, DC, 20006; Ms. Susan Soodek Assistant Director Government Affairs Department APAA 1730 K Street N.W. Washington DC 20006; Dear Ms. Soodek: This is in response to your letter of June 24, 1976, asking whethe Standard No. 302, *Flammability of Interior Materials*, applies to 'slip-on' seat covers manufactured for sale in the aftermarket. Standard No. 302 applies only to vehicles (see S3 of the Standard) and would not apply to replacement seat covers unless they are installed in the vehicle prior to its first sale for purposes other than resale (15 U.S.C. S1397(b)(1)).; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0779OpenMr. Satoshi Nishibori, Engineering Representative, Liaison Office in U.S.A., 560 Sylvan Avenue, Englewood Cliffs, NJ, 07632; Mr. Satoshi Nishibori Engineering Representative Liaison Office in U.S.A. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letter of June 29, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to replacement parts for vehicles manufactured on or after September 1, 1972.; Standard No. 302 does not apply to replacement parts or aftermarke materials irrespective of the date of their manufacture. It applies only to new vehicles manufactured on or after September 1, 1972, and not to the replacement materials used in those vehicles.; 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.