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: aiam5607OpenMilford R. Bennett, Director Safety Affairs and Safety & Restraints Center General Motors Corporation 30200 Mound Road Warren, Michigan 48090-9010; Milford R. Bennett Director Safety Affairs and Safety & Restraints Center General Motors Corporation 30200 Mound Road Warren Michigan 48090-9010; Dear Mr. Bennett: This responds to General Motors' (GM's) May 19, 199 letter asking whether a sunshade device is permitted under the 70 percent light transmissibility requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. You describe the device as a screen-like device that is stowed in the back panel shelf area below the rear window and that can be electrically raised and lowered by a driver operated switch. The light transmissibility through the combination of the rear window and the raised sunshade is less than 70 percent. The short answer to your question is that the device is permitted. Although you note earlier agency interpretations stating that windows with sunshades must still comply with Standard No. 205, you believe that the standard does not apply to your device. You state that those interpretations were distinguishable because the other shading devices were attached to the window, while your device is not. You are correct in your assertion that installation of your sunshade would not cause a noncompliance with Standard No. 205. The purpose of the 70 percent light transmissibility requirements in Standard No. 205 is to ensure that the driver can see 70 percent of the incident light through the windows that are requisite for driving visibility, under all conditions of lighting. However, the test procedures do not incorporate an in-vehicle test. Instead, they contemplate testing only the glazing itself. Your mesh screen sunshade need not comply with the standard (because it does not meet the definition of glazing) or in combination with the rear window (because it is not attached). Although our standards do not prohibit this device, we have some safety-related concerns with its use in inappropriate situations. NHTSA hopes that GM plans to take steps to minimize the likelihood that the sunshade will be raised in such situations. I hope this information is helpful. If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam4915OpenWilliam Engel, Assistant Chief Covington Fire Department 100 E. Robbins St. Covington, KY 41011; William Engel Assistant Chief Covington Fire Department 100 E. Robbins St. Covington KY 41011; "Dear Mr. Engel: This responds to your letter asking whether Federa Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components, requires door locks on fire trucks. Safety Standard No. 206, which applies to all passenger cars, multipurpose passenger vehicles and trucks, does not exclude fire trucks. Thus, new fire trucks are covered by the standard's general requirement that 'components on any side door leading directly into a compartment that contains one or more seating accommmodations shall conform to this standard.' S4 Standard No. 206 does not apply, however, to certain types of doors which are often found on fire trucks. Since your letter did not provide any details about the design of the specific doors to which you refer, I am unable to determine whether any of the doors on those fire trucks would be subject to Standard No. 206's requirements. For your information, I have enclosed two letters from this office which discuss the applicability of Standard No. 206 to specific doors on fire trucks in more detail. The two letters are an August 13, 1980 letter to Mr. Steenbock and a February 11, 1988 letter to Ms. Salvio. The National Highway Traffic Safety Administration has not adopted any amendments to Standard No. 206 that affect the accuracy of the information contained in these letters. I have also enclosed a current copy of Standard No. 206. I hope this information is helpful. Please contact Elizabeth Barbour of my staff at this address or by telephone at (202) 366-2992 if you have further questions. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam0055OpenMr. Dick Romney, Sales Manager, Utility Body Company, 901 Gilman Street, Berkeley, CA 94710; Mr. Dick Romney Sales Manager Utility Body Company 901 Gilman Street Berkeley CA 94710; Dear Mr. Romney: Thank you for your letter of March 6, 1968, to Mr. George C. Nield concerning the additional clearance lamps and reflectors that you have been requested to install on vehicles shipped to Hawaii.; Referring to the drawing attached to your letter, the use of clearanc lamps as shown does not appear to impair the effectiveness of the lighting equipment required by Motor Vehicle Safety Standard No. 108, provided (1) the two lamps on front of the body are *amber* in color, and (2) the lamp on the rear of the body is red in color. Also, use of the amber reflex reflector on front of the body would not appear to impair the effectiveness of the required equipment. Paragraph S3.1.2 of the Standard states: 'No additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment.' This requirement applies to all applicable vehicles, including those owned by a State.; On your drawing, it appears that you have inadvertently indicated a re color for the clearance lamps on the front of the body. Use of red lamps at the locations shown would impair the effectiveness of the required equipment, since red lamps are used, in accordance with the standard, to designate the rear of the vehicle.; With respect to the requirements of Standard No. 108, I must point ou that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the Standard.; Thank you for writing. Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance; |
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ID: aiam2068OpenMr. Tokio Iinuma, 560 Sylvan Avenue, P. O. Box 1606, Englewood Cliffs, NJ 07632; Mr. Tokio Iinuma 560 Sylvan Avenue P. O. Box 1606 Englewood Cliffs NJ 07632; Dear Mr. Iinuma: This is in response to your letter of August 27, 1975, requesting a interpretation of Standard No. 219 with respect to certain of your test results.; The primary purpose of Standard No. 219 is to protect vehicle occupant from impact with vehicle parts that have penetrated into the passenger compartment through the windshield during a crash. The inner surface of the windshield is the area of interface between the windshield and the passenger compartment. Therefore, the standard is designed to ensure that nothing penetrates into the passenger compartment by precluding penetration of the inner surface of the windshield below the protected zone in a crash test.; In Case 1, although the windshield below the protected zone wa cracked, nothing penetrated the inner surface of the windshield. therefore, it would appear that the windshield is in compliance with S5 of Standard No. 219.; Similarly, in case 2, it appears that the object did not penetrate th inner surface of the windshield, although the windshield was deformed. Therefore, it would appear that the vehicle is also in compliance.; We hope this information is of assistance. Please contact us if yo have any further questions.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5257OpenJohn B. Walsh Legal Affairs Manager Corporate Attorney American Suzuki Motor Corporation 3251 E. Imperial Highway P.O. Box 1100 Brea, CA 92622-1100; John B. Walsh Legal Affairs Manager Corporate Attorney American Suzuki Motor Corporation 3251 E. Imperial Highway P.O. Box 1100 Brea CA 92622-1100; Dear Mr. Walsh: This acknowledges receipt of your letter dated Octobe 29, 1993 requesting an interpretation of the labeling requirements of the recent final rule mandating the installation of air bags in passenger cars and light trucks (58 FR 46551, September 2, 1993). As you suggested in your letter, we believe it would be appropriate to respond to your request in the notice responding to the petitions for reconsideration of the September 2 final rule. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2592OpenMr. James M. Beach, Director of Engineering, Collins Industries, Inc., P. O. Box 58, Hutchinson, KS 67501; Mr. James M. Beach Director of Engineering Collins Industries Inc. P. O. Box 58 Hutchinson KS 67501; Dear Mr. Beach: This responds to your April 28, 1977, letter in which you ask severa questions concerning Standard No. 222, *School Bus Passenger Seating and Crash Protection*, and the definition of school bus.; You first ask whether the seat spacing requirements found in S5.2.1 o the standard are applicable to buses with gross vehicle weight ratings (GVWR) equal to or less than 10,000 pounds. Buses in this weight classification do not have to comply with the mandatory seat spacing requirements. Since these buses are equipped with seat belts, the mandatory seat spacing is not necessary to provide adequate occupant crash protection.; Your second question concerns those areas required to meet the hea protection zone requirements. You ask whether the window frame, window supporting structure, and window glass are included within the head protection zone requirements. The NHTSA issued an amendment of the standard (Notice 6, 41 FR 28506) in an attempt to clarify those portions of the bus subject to the head protection zone requirements. In this notice (copy enclosed), we stated that the sidewall, window and door structures were never intended to be included within the zone and are not subject to the requirements for head protection. However, the roof structure, if it falls within the zone, is subject to the requirements. If you need further information to determine the portions of your bus that would be included within the head protection zone requirements, I suggest that you send the agency sketches of your bus interior depicting those areas of concern.; Concerning seat orientation, you question whether the requirement fo forward facing seats found in S5.1 of the standard applies to buses with GVWR's of 10,000 pounds or less. S5(b) of the standard lists the paragraphs of the standard applicable to buses in the above-mentioned weight classification. S5(b) does not refer to S5.1 which contains the requirement for forward facing seats. This omission was an oversight that occurred during the drafting of the regulation. The agency intended that seats in all school buses be forward facing, unless designed for handicapped or convalescent passengers as permitted in Notice 6. This intent is obvious since, as you note, we require these seats to comply with forward and rearward performance requirements. The NHTSA will soon issue an amendment of the standard to correct this omission.; Your final question concerns the definition of school bus whic excludes common carriers in urban transportation. Your interpretation of this exclusion is correct. These buses are permitted to transport children to and from school but need not comply with the school bus construction standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3229OpenMr. Victor L. Johnson, Jr., Great Dane Trailers, Inc., P.O. Box 67, Lathrop Avenue, Savannah, Georgia 31402; Mr. Victor L. Johnson Jr. Great Dane Trailers Inc. P.O. Box 67 Lathrop Avenue Savannah Georgia 31402; Dear Mr. Johnson: This is to confirm your telephone conversation with Mr. Schwartz of m office, in which he advised you that the manufacturer identifier referred to in Docket 1-22, Notice 10, was the manufacturer identifier required by S4.5.1 of Federal Motor Vehicle Safety Standard No. 115. Inasmuch(sic) as the Society of Automotive Engineers has already assigned a manufacturer identifier to Great Dane Trailer, Inc., this requirements has been met.; I am forwarding your complete VIN plan to the VIN coordinator a required by S6 of the Standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1214OpenMr. Gil W. Bellamy, Administrator, Oregon Traffic Safety Commission, Room 313 Highway Building, Salem OR 97310; Mr. Gil W. Bellamy Administrator Oregon Traffic Safety Commission Room 313 Highway Building Salem OR 97310; Dear Mr. Bellamy: Thank you for your letter of July 23, 1973, enclosing an amende version of Oregon House Bill 2721.; We note that Section 2 of the Bill no longer requires a mandator green- yellow-red rear mounted lighting system but specifies that it may be used on an optional basis, in accordance with the suggestions in Mr. Wilson's letter of July 20, 1973. In order to avoid preemption under the National Traffic and Motor Vehicle Safety Act, ORS 483.412(3)(b) [Section 3] should be similarly amended to substitute 'may' for 'shall' so that all references to a mandatory system are removed from the Bill.; Sincerely, James B. Gregory, Administrator |
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ID: aiam4016OpenThe Honorable Malcolm Wallop, United States Senate, Washington, DC 20510; The Honorable Malcolm Wallop United States Senate Washington DC 20510; Dear Senator Wallop: Thank you for your letter to Secretary Dole requesting clarification o the regulations pertaining to school bus identification. Your letter has been referred to our agency for reply, since we administer the school bus regulations.; You explained that several of your constituents are concerned that ou regulations prohibit identifying nine-passenger vehicles that carry children to and from school as school buses. You suggested that school bus identification should be allowed as an added safety measure to alert other drivers to the nature of the vehicle.; I appreciate this opportunity to respond to your concerns. In brief our regulations do not prohibit States from identifying smaller school vehicles as 'school buses.' States have the discretion to choose to identify nine-passenger school vehicles as school buses if the States wish to include such a requirement in their highway safety programs.; We have two sets of regulations, issued under separate Acts o Congress, that apply to school buses. The first of these, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966, includes the motor vehicle safety standards applying to the manufacture and sale of new school buses. The second set of regulations, issued under the Highway Safety Act of 1966, provides guidelines to the States for their highway safety programs. One of these program standards provides recommended procedures for the identification of school vehicles.; Under the requirements of the Vehicle Safety Act, motor vehicl manufacturers must certify that their vehicles comply with all applicable motor vehicle safety standards. The applicability of our motor vehicle safety standards to a particular vehicle depends, in part, on the classification of that vehicle. Under Federal law, school vehicles carrying 10 or more passengers are 'school buses' which must meet our school bus safety standards. The demarcation between school vehicles carrying 10 or more passengers and those carrying fewer than 10 is thus pertinent for the purpose of determining the classification of a vehicle, and the applicability of our school bus safety standards. Nine- passenger van-type school vehicles are not considered 'school buses' under our regulations, but are classified as 'multipurpose passenger vehicles' (MPV's). While MPV's must be certified as meeting the safety standards for MPV's, they may also be voluntarily manufactured to meet the requirements for school buses as long as the vehicle continues to comply with our standards for MPV's.; I wish to emphasize that our safety standards for school buses ar performance standards which apply only to the manufacture and sale of new school buses. They do not govern the manner in which a school bus is identified or marked. Under the Highway Safety Act, we issued Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed), which contains recommendations for the identification, operation, and maintenance of school vehicles. However, the implementation of Program Standard No. 17 is a matter for the States to decide, and State law would determine the operational requirements, such as those for school bus identification, that school vehicles must meet.; I hope this information is helpful. Please feel free to contact thi agency if you have any further questions.; Sincerely, Diane K. Steed |
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ID: aiam3679OpenMr. K. Inoue, National Technical Service Manager, Toyo Tire Corporation, Compton, CA 90221; Mr. K. Inoue National Technical Service Manager Toyo Tire Corporation Compton CA 90221; Dear Mr. Inoue: This responds to your February 16, 1983, letter to Joseph Innes of thi agency regarding permissible methods for displaying Uniform Tire Quality Grading (UTQG) information on the sidewall of tires. Your first proposed alternative would delete the treadwear grade number, but not the word 'TREADWEAR' itself, from the format established in Option 3 of Figure 1, 49 CFR 575.104. The second proposed alternative would delete both the word 'TREADWEAR' and the numerical grade from the format specified in Option 3, Figure 1. Your proposed alternatives would be used only on tires produced in molds manufactured before August 8, 1983.; In the agency's February 7, 1983, notice suspending the treadwea portion of the UTQGS, tires produced in molds manufactured prior to August 8 were required to display UTQG information on tire sidewalls in one of the formats specified in Figure 1 or in Figure 6 of 49 CFR 575.104. Your first proposed alternative is clearly different from each of the permitted formats. The permitted formats require either that the word 'TREADWEAR' must appear next to the treadwear grade on the tire, or neither the word nor the numerical grade must appear. Your first alternative could confuse tire purchasers, since the display format could be interpreted as attributing the grade which appears after the work (sic) 'TRACTION' to both the treadwear and traction performance of the tire. Therefore, your first proposed alternative would not be permitted under 49 CFR 575.104.; Your second proposed alternative is quite similar to one permitte format, Option 3 in Figure 6. The only difference between your second alternative and Option 3 is that the traction information is centered in the format in Option 3, while it is slightly off-center in your alternative. Your second alternative should in no way be misleading to tire purchasers, however. Further, nothing in our regulations specifies precise centering of the traction information.; Any inconsistency between your proposed format and the permitted one i so small that the agency would, as a matter of prosecutorial discretion, make no attempt to enforce the UTQGS format requirement when your second alternative is used.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, 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.