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: aiam3824OpenMr. William Shapiro, Manager, Regulatory Affairs, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro: This is in response to your letter of March 23, 1984, petitioning th Administrator for a temporary exemption from Motor Vehicle Safety Standard No. 213, *Child Restraint Systems*, to allow use of the Volvo Child Safety Seat in 2500 of Volvo's 240/260 series vehicles.; Section 123 of the National Traffic and Motor Vehicle Safety Ac provides authority to exempt only motor vehicles from compliance with any applicable motor vehicle safety standard. This authority does not extend to individual items of motor vehicle equipment. Inasmuch as Standard No. 213 specifies requirements for child seating systems for use in motor vehicles but does not require their installation in them as original equipment, it is considered an equipment standard, rather than a vehicle standard. This means that the agency has no authority to grant your petition for exemption. If you wish to pursue this matter further, you may submit a petition for rulemaking pursuant to 49 CFR Part 552 to amend Standard No. 213 in a manner that would allow the Volvo seat.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1819OpenHonorable Edmund S. Muskie, United States Senate, Washington, DC 20510; Honorable Edmund S. Muskie United States Senate Washington DC 20510; Dear Senator Muskie: I would like to respond to your February 19, 1975, request fo consideration of Mr. R. L. Herman's views on Standard No. 121, *Air brake systems*. Mr. Herman objects that the National Highway Traffic Safety Administration (NHTSA) may have ignored the majority of comments submitted in response to its recent proposal to delay implementation of the standard, that implementation of the standard should be reconsidered by an activity other than the NHTSA, and that the new brake systems may be less safe than existing systems.; Standard No. 121 was issued as a final rule in February 1971. The NHTS realized that the economic situation in the automotive industry this past fall might justify a postponement of the scheduled January 1, 1975, effective date. In the short time available for review of the standard before its effective dates, the NHTSA issued a proposal, received comments, and made its decision.; The NHTSA concluded that net economic benefit would not be derived fro postponement. The decision was based on evaluation of all the comments, including those concerning the standard's immediate short-term impact on the national economic picture. An important factor in this case was the imminence of the standard and the degree to which financial and employment commitments were made.; As you may know, the President has directed (by Executive Order 11821 that each Federal agency consider the inflation impact of its regulatory actions. At the time of the NHTSA decision on December 31, 1974, final criteria and procedures for implementation of the Order were not yet established. The NHTSA did, however, analyze economic effects of its proposal. The NHTSA has publicly committed itself to continue monitoring the effectiveness of its standard in accordance with its statutory mandate and the President's direction, with a view to identifying any modifications that would lower costs while achieving comparable levels of safety.; An independent evaluation of the standard and its implementation by th Office of the Secretary (of the Department) was recently conducted, and this study supports the NHTSA decision. A copy of a letter regarding that evaluation is enclosed, and it discusses in detail Mr. Herman's concern about the field testing of the new braking components.; Thank you for your interest in motor vehicle safety. Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam2736OpenHoward Sturtz, M.D., 1479 Ygnacio Valley Road, Walnut Creek, California 94598; Howard Sturtz M.D. 1479 Ygnacio Valley Road Walnut Creek California 94598; Dear Dr. Sturtz: Mr. Ralph Nader forwarded to me your letter dated November 23, 1977 concerning your difficulty in determining whether your 1977 Ford Econoline van is equipped with an energy absorbing steering column.; Ford Econoline vans are equipped with conventional steering column that are not energy absorbing. Federal Motor Vehicle Safety Standards No. 203, *Steering Control Impact Protection*, and No. 204, *Steering Control Rearward Displacement*, are currently only applicable to passenger cars, so manufacturers are not required to have energy absorbing steering columns on van vehicles. Ford has not voluntarily equipped its vans with such steering systems.; The National Highway Traffic Safety Administration shares your concer in this subject. As a matter of fact, the agency has initiated high priority rulemaking proceedings to extend the applicability of Several passenger car standards, including Standards 203 and 204, to both vans and light trucks.; Please let me know if you would like further information on automotiv safety matters.; Sincerely, Howard J. Dugoff, Deputy Administrator |
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ID: aiam0064OpenMr. Richard T. Tate, T & T Manufacturing Company, Cheetah Coaches, Iola, KS 66749; Mr. Richard T. Tate T & T Manufacturing Company Cheetah Coaches Iola KS 66749; Dear Mr. Tate: Thank you for your letter of December 19, 1967, to the National Highwa Safety Bureau, in which you request information governing vehicle width and safety glass installation requirements on the vehicles you manufacture.; Regarding your question on vehicle width, Safety Standard No. 108 relative to lamps, reflectors and associated equipment, for specified vehicles 80 or more inches wide overall, defines the term 'overall width' as the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rear view mirrors, flexible fender extensions and mud flaps, determined with doors and windows closed and the wheels in the straight ahead position. Therefore, if your vehicle measures less than the Safety Standard No. 108 requires, compliance is not required.; Your question regarding installation of safety glass as specified b Safety Standard No. 205, relative to Glazing Materials, can be answered by directing your attention to Standard No. 205. It specifies adherence by a multi-purpose Passenger Vehicle, a category into which your pick-up campers fall. A copy of the Federal Register, Volume 32, No. 23 and amendment to this regulation, Volume 32, No. 131, is enclosed for your information.; The application of Safety Standard No. 205 to pick-ups, is covered b the enclosed Federal Register, Volume 33, No. 59.; Thank you for your cooperation and response to the Federal Highwa Administration request regarding the certification requirement.; The label sample and information as to its location that you hav provided will be very useful to us, however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with the serial identification system in order that vehicles manufactured (completed) after January 1, 1968, can be identified.; Your interest in the safety program of the Bureau is appreciated. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam2059OpenMr. Y. Toyoda, Manager, Engineering Dept., Bridgestone Tire Company of America, Inc., 2160 West 190th Street, Torrance, California 90509; Mr. Y. Toyoda Manager Engineering Dept. Bridgestone Tire Company of America Inc. 2160 West 190th Street Torrance California 90509; Dear Mr. Toyoda: Please forgive the delay in responding to your letter of May 22, 1975 concerning truck tires which do not conform to Federal Motor Vehicle Safety Standard No. 119 and which are intended for export to Middle Eastern and African countries.; 49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic an Motor Vehicle Safety Act of 1966, as amended, specify that no Federal Motor Vehicle Safety Standards apply to; >>>a motor vehicle or item of motor vehicle equipment intended solel for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.<<<; Therefore, tires which you manufacture for sale directly to a truc manufacturer who will mount then on trucks which will be driven directly to the port of export need not comply with Standard No. 119. When shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. A label need not remain in the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5266OpenMr. Jason Backs Engineering Department Travis Body and Trailer, Inc. 13995 F.M. 529 Houston, TX 77041; Mr. Jason Backs Engineering Department Travis Body and Trailer Inc. 13995 F.M. 529 Houston TX 77041; "Dear Mr. Backs: We have received your FAX of October 19, 1993, t Taylor Vinson of this Office, asking for an interpretation of the trailer conspicuity requirements of Federal Motor Vehicle Safety Standard No. 108 as it applies to a dump trailer manufactured by your company. With respect to the location of the horizontal side conspicuity treatment, you prefer not to place it on the rubrail because 'our present extrusions have raised ridges on the outer surface.' You propose to apply the conspicuity treatment between each side stake, resulting in 58% coverage of the trailer side. The tape is 'in full view' from a point perpendicular to the side of the trailer, but at approximately 30 degrees from perpendicular, the edge of the tape begins to be obstructed by the side stake. You ask for our concurrence that your proposed treatment is in accordance with Standard No. 108. We are pleased to provide our concurrence. The mounting height requirements of Paragraph S5.7.1.4.2 are specified in terms of practicability. The rule was amended on October 6, 1993, to specify a mounting height of 'as close as practicable to not less than 375 mm and not more than 1525 mm above the road surface.' The determination of practicability, in the first instance, is that of the manufacturer certifying compliance with Standard No. 108. NHTSA will not question that determination unless it appears clearly erroneous. Because of raised ridges, you deem the rubrail not as practicable a location as the slightly higher area. Paragraph S5.7.1.4.2 allows discontinuities in the side treatment as long as not less than half the side is covered and the spaces are distributed as evenly as practicable. Although the sheeting itself must meet the performance indicated at the observation angles specified in Figure 29, there are no visibility requirements that apply to it once it is installed on a trailer. This mean that the obscuring of the conspicuity treatment that begins at about 30 degrees from perpendicular under your proposed treatment is not prohibited by Standard No. 108. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0434OpenMr. W. Glenn Pracejus, Manager, Electrical/Electronic Division, Electrical Testing Laboratories, Inc., 2 East End Avenue, New York, NY, 20021; Mr. W. Glenn Pracejus Manager Electrical/Electronic Division Electrical Testing Laboratories Inc. 2 East End Avenue New York NY 20021; Dear Mr. Pracejus: Thank you for your letter of September 8, 1971, concerning the recen amendment of Standard 108 concerning turn signal and hazard warning flashers (36 F.R. 17343, August 28, 1971).; You noted that test-condition temperatures are listed withou tolerances, and asked what tolerance is acceptable for testing.; In the case of motor vehicle safety standards, the testing that manufacturer may perform or have performed on its products is not an end in itself, but is done to enable the manufacturer to certify that the products meet the required performance levels under the specified conditions. Thus, the requirement that a product meet or exceed certain values at 75 degrees F. refers to a legal conclusion that is to be drawn from appropriate testing, and no tolerance is necessary or appropriate in the text of the standard. In practical terms, it is up to the manufacturer to determine what tests will enable him to certify his products as conforming. Normally, this is done by testing his products under slightly more adverse conditions than those specified in the standard. If, for example, higher temperatures constitute more adverse conditions for a flasher, the laboratory should test at a temperature slightly higher than that specified. In sum, the testing should be sufficient to support the *conclusion* that, if tested under the specified conditions, the product would perform as required.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2409OpenMr. Jack B. Schiff, 230 South Bemiston Avenue, Clayton, St. Louis, MO 63105; Mr. Jack B. Schiff 230 South Bemiston Avenue Clayton St. Louis MO 63105; Dear Mr. Schiff: This is to acknowledge receipt of your letter of October 8, 1976 concerning odometer statements issued by auction companies.; As we have indicated in previous letters to you, the statement 'n mileage guarantee' does not conform to section 580.6 of title 49, Code of Federal Regulations, the disclosure form. Therefore, any transferor of a motor vehicle who gives such a statement to his buyer is in violation of the Motor Vehicle Information and Cost Savings Act. This applies equally to all transferors of ownership in motor vehicles, including individuals, dealers, distributors, and auction companies.; At first glance, the odometer disclosure statement issued by Floy Hauhe Auto Auction appears to be in violation of the Federal law because it clearly states that mileage is not guaranteed. However, upon closer inspection, such is not necessarily the case. You will note that their statement says 'warranty and mileage are not guaranteed to be good or correct on any car purchased *thru* this auction.' (Emphasis added) Additionally, it says that 'this sale is solely a transaction between the buying and selling dealer.' This language changes the facts significantly. The vehicle appears not to be as you state in your letter, purchased 'from' the auction company. It was instead purchased *through* the auction, and Floyd Hauhe was not, apparently, a tranferor (sic) of ownership in a motor vehicle as defined in Part 580.3 of title 49.; The responsibilities of an auctioneer with regard to the Federa odometer law vary depending upon the capacity in which he is operating. If the auctioneer is conducting business with both the buyer and seller present, the seller is required to disclose the mileage to the buyer at the time of sale and the auctioneer is essentially a by-stander as far as the Federal requirements are concerned. If the auctioneer buys a vehicle, then auctions it, he becomes the transferor and must disclose the mileage. In this case, the auctioneer would not be permitted to state that mileage was not guaranteed. If the auctioneer is acting as consignee for a seller who is not present and who may have delivered the vehicle from hundreds of miles away, he will have to obtain some assurance from the seller concerning the mileage on the vehicle at the time it left the owner's premises before a disclosure is made. As owner, the seller is ultimately responsible for the disclosure statement, but he may have to rely on his driver or the auctioneer to make out the statement at the auction.; It is unclear from the Floyd Hauhe Auto Auction statement as to th capacity in which they are operating. The language on the fact of the statement appears to indicate that they are not tranferors (sic) and thus are not responsible for issuing odometer statements. If however, they are requested to do so by absent sellers, their form is in violation of the Act because it does not provide the transferor's name, address or signature, and because it states that mileage is not guaranteed.; I hope that this information clarifies your questions. If you have an further questions, please do not hesitate to write.; Sincerely, John Womack Assistant Chief Counsel |
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ID: aiam4924OpenMr. D. E. Graham Engineering Manager Regulatory, Test & Service Engineering ASC, Incorporated One Sunroof Center Southgate, Michigan 48195; Mr. D. E. Graham Engineering Manager Regulatory Test & Service Engineering ASC Incorporated One Sunroof Center Southgate Michigan 48195; "Dear Mr. Graham: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 118 Power Windows (49 CFR 571.118). As you noted in your letter, the agency published a final rule amending Standard No. 118 in the April 16, 1991, edition of the Federal Register (56 FR 15290). You requested clarification of certain requirements in that final rule. The agency has received several petitions for reconsideration of the final rule amending Standard No. 118. The agency is currently reviewing the merits of each petition. The agency will issue a notice in the Federal Register granting and/or denying the petitions. In that notice, the agency will also address the concerns raised in your request for an interpretation on Standard No. 118. Please let us know if you have any questions about the issues raised in your letter after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. If you need more information on this subject, please feel free to contact Dorothy Nakama of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5636Open"M. Guy Dorleans International Regulatory Affairs ManagerValeo 34, rue Saint-Andr 93012 Bobigny Cedex France"; "M. Guy Dorleans International Regulatory Affairs ManagerValeo 34 rue Saint-Andr 93012 Bobigny Cedex France"; Dear M. Dorleans: This responds to your letter of September 29, 1995 with respect to the use of light-emitting diodes (LEDs) to fulfill the lighting requirements of Standard No. 108. You have enclosed a design for a lamp incorporating tail, stop, and rear turn signal functions, the illumination for which will be provided by red LEDs. At night, the LEDs will provide sufficient illumination to meet taillamp photometrics, with increased illumination when the brake pedal is applied, 'so that the sum of the photometrics of the stoplamp and the tail lamp is fulfilled.' When the turn signal is activated, 'all the diodes are energized at full intensity during the on-period of the turn signal and t he sum of the photometrics of the rear turn signal lamp and the tail lamp is then fulfilled . . . .' You ask for 'confirmation that this new lighting combination is correct.' We consider this lamp, as you have more fully described it in your letter, to be an acceptable design for meeting the requirements of Standard No. 108. If you have any questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263). Sincerely, Samuel J. Dubbin Chief Counsel; |
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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.