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: aiam0950OpenMr. R. H. Dobson, Industrial Fibers Division, Marketing--Technical, E. I. Du Pont De Nemours & Company, Wilmington, DE, 19898; Mr. R. H. Dobson Industrial Fibers Division Marketing--Technical E. I. Du Pont De Nemours & Company Wilmington DE 19898; Dear Mr. Dobson: This is in reply to your letter of December 7, 1972, to Mr. James S Gilky concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' and its possible application to infant restraint harnesses.; Standard No. 302 does not apply to aftermarket materials or components it applies only to those original components or materials of new vehicles specified in Paragraph S4.1 of the standard. Since an infant restraint harness is an aftermarket item of motor vehicle equipment, it is not subject to the requirements of the standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0425OpenMr. 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 August 12 asking for a clarificatio of the effect of the recent firefighting vehicle amendment (36 F.R. 13926) on Federal standards published prior to September 1, 1971, but effective after that date.; Specifically you ask whether Standard No. 302, *Flammability o Interior Materials*, published on January 8, 1971, applies to firefighting vehicles on September 1, 1972, or September 1, 1974.; The firefighting vehicle amendment is effective September 1, 1971, an has no effect upon standards or amendments to standards issued before that date. Thus Standard No. 302 applies to firefighting vehicles as of September 1, 1972.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3465OpenMs. Fran Anderson, Jellybean Express, 5131 Franklin Blvd., Sacramento, CA 95820; Ms. Fran Anderson Jellybean Express 5131 Franklin Blvd. Sacramento CA 95820; Dear Ms. Anderson: This responds to your letter of September 9, 1981, concerning th Federal flammability requirements applicable to seat covers for child restraints. As explained below, if the seat cover is sold as an item of original equipment on a child restraint system, it must meet the flammability requirements of Safety Standard No. 213, *Child Restraint Systems*. If the seat cover is sold as an item of aftermarket equipment, it is not covered by the standard. However, we would urge you to consider voluntarily complying with the standard.; Standard No. 213, *Child Restraint Systems* (49 CFR 571.213), set performance requirements for child restraints as pieces of motor vehicle equipment. Section 5.7 of the standard system shall conform to the requirements of S4 of Safety Standard No. 302 (S571.302).' Standard No. 302, *Flammability of Interior Materials*, provides that when tested under specified conditions, a material may not have a burn rate of more than 4 inches per minute (copy enclosed). Thus, if your seat cover is sold as a component on a new child restraint, that child restraint must comply with the requirements of S5.7 of Standard No. 213. Under the National Traffic and Motor Vehicle Safety Act (the Act, 15 U.S.C. 1392 *et seq*., copy enclosed), manufacturers have the responsibility of certifying that they comply with all applicable standards. The agency does not grant prior approval or conduct tests to support a manufacturer's certification. Therefore, I am returning the sample of your seat cover.; Although Standard No. 213 only covers the manufacture of items o original equipment in child restraints, sale of your seat cover as an item of aftermarket equipment is indirectly affected by Section 108(a)(2)(A) of the Act. That section provides:; >>>No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard....<<<; Thus, none of the persons mentioned could not (sic) knowingly instal your seat cover on a used child restraint if it renders inoperative the restraint system's compliance with Standard No. 213. However, the prohibitions of the Act and the standard do not cover sale of your cover as an aftermarket device nor its installation solely by the vehicle or equipment owner.; Regardless of whether your seat cover must comply with Standard No 213, as a manufacturer of motor vehicle equipment you have defect responsibilities under sections 151 *et seq*. of the Act. Those sections provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of safety-related defects in their products and remedy those defects free of charge. If your covers are highly flammable, this could be regarded as a safety- related defect.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3464OpenMs. Fran Anderson, Jellybean Express, 5131 Franklin Blvd., Sacramento, CA 95820; Ms. Fran Anderson Jellybean Express 5131 Franklin Blvd. Sacramento CA 95820; Dear Ms. Anderson: This responds to your letter of September 9, 1981, concerning th Federal flammability requirements applicable to seat covers for child restraints. As explained below, if the seat cover is sold as an item of original equipment on a child restraint system, it must meet the flammability requirements of Safety Standard No. 213, *Child Restraint Systems*. If the seat cover is sold as an item of aftermarket equipment, it is not covered by the standard. However, we would urge you to consider voluntarily complying with the standard.; Standard No. 213, *Child Restraint Systems* (49 CFR 571.213), set performance requirements for child restraints as pieces of motor vehicle equipment. Section 5.7 of the standard provides that, 'Each material used in a child restraint system shall conform to the requirements of S4 of Safety Standard No. 302 (S571.302.)' Standard No. 302, *Flammability of Interior Materials*, provides that when tested under specified conditions, material may not have a burn rate of more than 4 inches per minute (copy enclosed). Thus, if your seat cover is sold as a component on a new child restraint, that child restraint must comply with the requirements of S5.7 of Standard No. 213. Under the National Traffic and Motor Vehicle Safety Act (the Act, 15 U.S.C. 1392 *et seq*., copy enclosed), manufacturers have the responsibility of certifying that they comply with all applicable standards. The agency does not grant prior approval or conduct tests to support a manufacturer's certification. Therefore, I am returning the sample of your seat cover.; Although Standard No. 213 only covers the manufacture of items o original equipment in child restraints, sale of your seat cover as an item of aftermarket equipment is indirectly affected by Section 108(a)(2)(A) of the Act. That section provides:; >>>No manufacturer, distributor, dealer or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard....<<<; Thus, none of the persons mentioned could not (sic) knowingly instal your seat cover on a used child restraint if it renders inoperative the restraint system's compliance with Standard No. 213. However, the prohibitions of the Act and the standard do not cover sale of your cover as an aftermarket device nor its installation solely by the vehicle or equipment owner.; Regardless of whether your seat cover must comply with Standard No 213, as a manufacturer of motor vehicle equipment you have defect responsibilities under sections 151 *et seq*. of the Act. Those sections provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of safety-related defects in their products and remedy those defects free of charge. If your covers are highly flammable, this could be regarded as a safety- related defect.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0657OpenAnil Chudgar, Project Engineer, Synthetic Products Department, Imperial Eastman Corporation, 1440 North 24th Street, Manitowoc, WI, 54220; Anil Chudgar Project Engineer Synthetic Products Department Imperial Eastman Corporation 1440 North 24th Street Manitowoc WI 54220; Dear Mr. Chudgar: Thank you for your letter of March 16, 1972, to Miss Grace Robinson inquiring about the possible noncompliance of air brake tubing and hose with Federal Motor Vehicle Standard No. 302.; A copy of Standard No. 302 is enclosed for your information. Paragrap S4.1 lists the materials applicable to this standard. Air brake tubing and air brake hose are not included in the requirements for flammability performance. We trust this information will answer your questions, but if further information is needed, please do not hesitate to contact this office.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam1270OpenMr. R.A.C. Dandy, British Standards Institution, Hemel Hempstead Centre, Maylands Avenue, Hemel Hempstead, Herts HP2 4SQ; Mr. R.A.C. Dandy British Standards Institution Hemel Hempstead Centre Maylands Avenue Hemel Hempstead Herts HP2 4SQ; Dear Mr. Dandy: This is in reply to your letter of August 20, 1973, which we receive September 17, 1973, concerning the application of Standard No. 302, 'Flammability of Interior Materials,' to seat belt assemblies.; You ask whether components of the seat belt assembly such as plasti buckle covers must meet the requirements of the standard as well as the belt itself. Standard No. 302 applies to all enumerated interior materials, not just 'textile materials or sheet materials.' Since plastic buckle covers are considered part of the seat belt, they must meet the standard's requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: 20014.ztvOpenMr. Joel Sacher Dear Mr. Sacher: We have received your letter of May 11, 1999, asking for a temporary exemption for "a small number of Italjet scooters" from one requirement of Federal Motor Vehicle Safety Standard No. 123 Motorcycle Controls and Displays. I am sorry to inform you that the petition does not meet our procedural requirements, and we request that you revise and resubmit it in accordance with the following comments. Our regulation, 49 CFR 555.5(b)(3), requires that a petition
Italjet U.S.A. appears to be petitioning on behalf of Italjet S.p.A. If our assumption is correct, please provide the identifying information for Italjet S.p.A. that the regulation requires. If Italjet U.S.A. is a wholly-owned subsidiary of Italjet S.p.A., we ask that you confirm this as well. If Italjet U.S.A. is not a wholly-owned subsidiary of Italjet S.p.A., we would like to have a copy of the authorization from Italjet S.p.A. to you to petition on its behalf. In order that any possible exemption be limited in scope, please inform us of the model name or number of the vehicle for which you are requesting exemption. Finally, we call your attention to 49 CFR 555.5(b)(2) which requires that temporary exemption petitions be filed in three copies; we received only one copy. When we have this information, we shall be pleased to consider your request. Sincerely, |
1999 |
ID: aiam1217OpenMr. Brian Gill, American Honda Motor Co., Inc., P. O. Box 50, 100 W. Alondra Blvd., Gardena, CA, 90247; Mr. Brian Gill American Honda Motor Co. Inc. P. O. Box 50 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill: This is in reply to your letter of July 6, 1973, regarding th applicability of Standard No. 302 to a label that Honda wants to place on the driver's side sun visor to inform occupants about the seat belt interlock system.; The applicability of the standard depends on whether the label i attached in such a way as to form a permanent part of the sun visor. You state that Honda's label is 'easily removable and obviously not part of the sun visor.' If the label meets these criteria, we would not consider it to be a part of the visor. It would therefore not be subject to Standard No. 302.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0760OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Elglewood Cliffs, NJ, 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Elglewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in response to your letter of June 19, 1972, concerning th application of Motor Vehicle Safety Standard No. 302 to interior components, enclosing pictures. Your list includes heater case, defroster hose, heater duct hose, heater fan, console box, shell cover, harness, reclining device cover, meter cover, shift lever boot, foot boots, and knobs.; None of the components you list are enumerated in S4.1 of Standard No 302. Consequently, they are not subject to the standard unless they are, as specified in S4.1, 'other interior materials . . . that are designed to absorb energy on contact by occupants in the event of a crash.'; Yours truly, Richard B. Dyson, Assistant 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 |
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.