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: aiam2551OpenMr. David E. Martin, Director, Automotive Safety Engineering, General Motors Technical Center, General Motors Corporation, Warren, Michigan 48090; Mr. David E. Martin Director Automotive Safety Engineering General Motors Technical Center General Motors Corporation Warren Michigan 48090; Dear Mr. Martin: This responds to your February 16, 1977, question whether Safet Standard No. 105-75, *Hydraulic Brake Systems*, preempts the parking brake requirements specified in New York's school bus brake system regulations.; Safety Standard No. 105-75 (49 CFR 571.105-75) becomes effective Apri 1, 1977, for school buses and establishes requirements for the service and parking brake systems on these vehicles. The standard includes a static test requirement for parking brake systems (grade-holding capability) and a dynamic test requirement for service brake systems (emergency stopping capability). The New York brake system regulations include a static test requirement and also a dynamic test requirement for parking brake systems. You ask whether Standard No. 105-75 is preemptive of New York's dynamic test requirement for parking brakes.; Section 103(d) of the National Traffic and Motor Vehicle Safety Act (1 U.SC. S 1392 (d)) provides that no State or political subdivision of a State may promulgate or continue in effect standards applicable to an aspect of motor vehicle or motor vehicle equipment performance which is covered by a Federal motor vehicle safety standard, unless the standards are identical.; As noted, Standard No. 105-75 includes requirements for the parkin brake control aspect of braking performance. The Federal requirements must be regarded as conclusive with regard to this aspect of performance in order to maintain the uniformity necessary in a Federal regulatory scheme. It is the agency's opinion, therefore, that Standard No. 105-75 is preemptive of the nonidentical aspects of New York's school bus parking brake requirements.; However the second sentence of S 103(d) clarifies that the limitatio on State safety regulations of general applicability does not preempt governmental entities from specifying additional safety features in vehicles purchased for their own use if such requirements impose a higher standard of performance. Thus, the State of New York may specify these additional parking brake requirements for public school buses. The second sentence of S 103(d) does not permit governmental entities to specify safety features that prevent the vehicle or equipment from complying with applicable safety standards.A school bus manufacturer must continue to comply with all aspects of Standard No. 105-75. A school bus manufacturer, therefore, would have to meet the force requirements specified in Standard No. 105-75 for engagement of the parking brake, even for school buses intended for new York's own use.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5294OpenMr. James M. Keitges President Native American Motorcycle Co. P.O. Box 4287 Omaha, NE 68104; Mr. James M. Keitges President Native American Motorcycle Co. P.O. Box 4287 Omaha NE 68104; "Dear Mr. Keitges: This is in reply to your letter of January 14, 1994 in which you ask to be provided the statement 'that once the company has complied with all Federal NHTSA statutes, regulations, and standards, then the company has also complied with the State and Local requirements as applicable to NHTSA.' It is not possible to provide you with a statement in this form. We are unaware of any State and local requirements that are literally 'applicable to NHTSA.' However, there may be state and local laws that require compliance with the Federal motor vehicle safety standards, issued by NHTSA, in order for vehicles to be sold or registered for use on state and local roads. We believe it likely that this is your concern, and we will take this opportunity to explain the relationship between Federal and State or local requirements. Section 103(d) of the National Traffic and Motor Vehicle Safety Act (l5 U.S.C. 1392(d)), in effect, allows a State or a political subdivision of a State to enact a safety standard covering the same aspect of performance as a NHTSA Federal motor vehicle safety standard if it is identical to the NHTSA standard. A State or local standard cannot impose a higher level of performance than a NHTSA standard, except for vehicles procured for use by the State or the political subdivision. Further, a State or a subdivision is specifically permitted to enforce its own identical safety standard. Finally, State or local standards are permitted in areas of performance where there is no NHTSA standard, such as horns and fog lamps. Section 114 of the Act (15 U.S.C. 1403) requires each motor vehicle to bear its manufacturer's permanently affixed certification of compliance with all applicable Federal motor vehicle safety standards. This certification raises the presumption that the vehicle, in fact, conforms with those standards. If a State or local law is worded so as to require compliance with all Federal motor vehicle safety standards as a condition of vehicle sale or registration, then the manufacturer's certification should be accepted as fulfilling this State or local requirement. We believe, however, that in spite of the certification, a vehicle could be rejected as not in conformance with Federal requirements within the meaning of State or local law if the nonconformance was manifest on its face (e.g., failure of a new passenger car to be equipped with a center highmounted stop lamp) in spite of the facts that a State cannot enforce a Federal standard, and that neither the manufacturer nor NHTSA may have made a formal determination of noncompliance. If the State or local law is worded so as to require compliance with all State or local requirements as a condition of sale or registration, the manufacturer's certification may be accepted as indicating compliance with all identical State or local requirements if the governing authority so chooses, but obviously the certification could not cover compliance with State or local requirements in areas not covered by the Federal safety standards. We hope that this explanation is useful to you, and will be glad to answer any further questions you may have. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0096OpenHerr A. Hammerstein, Robert Bosch GMBH, 700 Stuttgart 1, Germany; Herr A. Hammerstein Robert Bosch GMBH 700 Stuttgart 1 Germany; >>>Ref: A/B GE 3 Hn/Ra<<< Dear Mr. Hammerstein: The Bureau of Customs has forwarded to us for further reply a copy o your letter to them of May 21 asking whether lighting units for passenger cars, which do not conform to the requirements of Federal motor vehicle safety standard 108, may be admitted to the United States after January 1, 1969.; Amended Federal standard No. 108, effective January 1, 1969, specifie lighting requirements for various categories of motor vehicles including passenger cars manufactured on or after that date. It does not specify requirements for individual items of lighting equipment. This means that these individual items, no matter what the date of manufacture, may be imported into the United States after January 1, 1969, because they will have been manufactured on a date when there were no standards in effect applicable to them.; I hope this answers your question. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam3710OpenMr. Wayne T. Halbleib, Assistant Attorney General, Office of the Attorney General, Supreme Court Building, 101 North Eighth Street, Richmond, VA 23219; Mr. Wayne T. Halbleib Assistant Attorney General Office of the Attorney General Supreme Court Building 101 North Eighth Street Richmond VA 23219; Dear Mr. Halbleib: This is in response to your letter of May 25, 1983 in which you aske whether the provisions on the back of Virginia's Certificate of Title are sufficient to satisfy the odometer mileage disclosure requirements contained in 49 CFR Part 580. The provisions are sufficient. Virginia's certificate of Title may therefore be used in lieu of a separate Federal odometer statement.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2802OpenMr. Marsh Pottorff, Potts Motorcycle Company, 717 4th, Pueblo, CO 81001; Mr. Marsh Pottorff Potts Motorcycle Company 717 4th Pueblo CO 81001; Dear Mr. Pottorff: This responds to your February 11, 1978, letter asking whether a devic manufactured by you which is designed to tow motorcycles behind a motor vehicle would be considered a trailer.; The term trailer is defined in Part 571.3 of Volume 49 of the Code o Federal Regulations to mean 'a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle.' Since your device falls within the ambit of this definition, it is considered a trailer and must comply with all of the Federal motor vehicle safety standards applicable to that vehicle type.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4485OpenMr. A. L. Bragg Laboratory Manager Truck-Lite Co., Inc. 310 East Elmwood Avenue Falconer, NY 14733; Mr. A. L. Bragg Laboratory Manager Truck-Lite Co. Inc. 310 East Elmwood Avenue Falconer NY 14733; Dear Mr. Bragg: This is in reply to your letter of June 22, l988, t Mr. Vinson of this Office asking for an interpretation of Motor Vehicle Safety Standard No. 108. It is your understanding that for purposes of measuring the effective projected illuminated area of a lens, the reflex area, if any, must be subtracted from the total lens area. Your company manufactures a combination lamp which 'has four square inches of reflector area and eight square inches of stop, tail and turn area.' You have asked if you may advise your customers that this lamp may be used on vehicles whose overall width is 80 inches or more: 'A) Singularly (that is one on each side of the vehicle in the rear) as a stop, turn, tail and reflex reflector? B) In combination of two's or three's (on each side of the rear of the vehicle), provided that the lamps are separated by at least twenty-two inches?' Your understanding is correct, that the effective projected illuminated lens area must be determined without reference to any reflex reflector that may be combined with it. If the turn signal function in your lamp is met by one compartment, your lamp is acceptable under 'A).' But if the turn signal function is met by more than one compartment, your lamp would not be acceptable as the area of each compartment is less than l2 square inches. With regard to 'B),' the lamps could be used in combinations of twos and threes if they are mounted more than 22 inches apart but could not be used if mounted closer than 22 inches. You also asked about the relationship to paragraph S4.1.1.7. This paragraph covers replacement equipment only, without reference to its location on a vehicle. It applies only to turn signal lamps intended to replace original equipment turn signal lamps on vehicles manufactured in accordance with SAE Standard J588d, June l966. The current original equipment requirement is SAE Standard J588e September l970. You should be aware that the Truck Safety Equipment Institute has petitioned for rulemaking the effect of which would be to extend the l2-inch requirement to lamps used on all wide vehicles without reference to the 22-inch spacing. At present the agency is reviewing this petition. I hope that this answers your questions. Sincerely, Erika Z. Jones Chief Counsel /; |
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ID: aiam3340OpenMr. Kenneth R. Brownstein, PACCAR, Inc., P.O. Box 1518, Bellevue, Washington 98009; Mr. Kenneth R. Brownstein PACCAR Inc. P.O. Box 1518 Bellevue Washington 98009; Dear Mr. Brownstein: This is in response to your letter forwarding your firm's vehicl identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115, *Vehicle Identification Number*.; The National Highway Traffic Safety Administration does not giv advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1687OpenMr. Phillip P. Friedlander, Jr., Director of Communications, National Tire Dealers and Retreaders Association, 1343 L Street, N.W., Washington, D.C. 20005; Mr. Phillip P. Friedlander Jr. Director of Communications National Tire Dealers and Retreaders Association 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Friedlander: In the November 25, 1974, issue of the *NTDRA Dealer News*, an articl entitled 'DOT's NHTSA Issues Final Labeling Requirements Under Standard No. 117,' the recently published permanent labeling amendment to standard No. 117 (39 FR 39882, November 12, 1974) is discussed in terms which imply that these requirements are the only labeling requirements imposed by the standard. Such an interpretation in incorrect. Paragraph S6.3.1 of Standard No. 117 still imposes affixed labeling requirements for certain information items which are not permanently labeled on the finished retread.; You may wish to clarify this in a future *Dealer New* issue. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0995OpenMrs. Arlene I. Lehto, Lehto's National Rubber Stamp and Printing, 901 East 7th Street, Duluth, MN 55805; Mrs. Arlene I. Lehto Lehto's National Rubber Stamp and Printing 901 East 7th Street Duluth MN 55805; Dear Mrs. Lehto:This is in reply to your letter of January 27, 1973 concerning the content of the odometer disclosure statement required by Federal regulations, pursuant to Public Law 92-513.; I am enclosing a copy of the regulation as published January 3, 1973 As you will note, section 580.6 describes the form to be used for disclosure. If disclosure is made on a document that contains the information necessary to identify the transferor and the vehicle, the form can be shortened by omitting the information boxes and the space for the transferor's address. Although we would not object to shortening the text of the statement somewhat, it must contain information specified in 580.4(b) and (c).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1957OpenHonorable G. William Whitehurst, House of Representatives, Washington, DC 20515; Honorable G. William Whitehurst House of Representatives Washington DC 20515; Dear Mr. Whitehurst: A reply to your inquiry of June 5, 1975, concerning grade labellin regulations for new passenger car tires was transmitted to you on June 13 by Mr. James H. Cromwell of the Department of Transportation. Mr. Cromwell also referred your inquiry to me for additional comments.; As you are undoubtedly aware, the original impetus for th establishment of a uniform quality grading system for motor vehicle tires was provided by the National Traffic and Motor Vehicle Safety Act of 1966, which established this agency. The Congress, cognizant of the problems which beset the consumer when he attempts to make an informed choice of motor vehicle tires based on the relative merits of tire brands, included a specific Section 203 in the aforementioned Safety Act of 1966 which states that, 'In order to assist the consumer to make an informed choice in the purchase of motor vehicle tires . . .the Secretary shall . . . prescribe by order, and publish in the 'Federal Register*, a uniform quality grading system for motor vehicle tires.'; The benefits of such a system, while difficult to quantify, represen an enormous potential since some 200,000,000 motor vehicle tires are produced per year and are presently sold to consumers without adequate quantitative measures of their performance. It is expected that, by facilitating increased and more meaningful competition, the quality grading information will enable the tire consumer to obtain more value per dollar than he has in the past. The rule will enable the consumer to judge relative tire performance from a simple grading system, and thereby select a tire which provides him with the optimum solution to his driving needs.; For your review and information, I am enclosing a copy of the Unifor Tire Quality Grading Standards (UTQGS) which was issued in the *Federal Register* dated May 28, 1975. The rule provides quantitative grading measures for three important tire properties -- i.e., treadwear, traction, and temperature resistance.; I trust the above information satisfies your needs. Should you have an further questions, I shall be glad to attempt to provide answers.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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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.