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: nht68-1.28OpenDATE: 01/01/68 EST. FROM: H.M. Jacklin, Jr.; NHTSA TO: Electrical Testing Laboratories, Inc. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letters of July 30, and August 9, 1968, concerning the test of seat belt anchorages which are anchored to a seat. On the question regarding the test method for applying the loads specified in paragraph $3.1.1, Motor Vehicle Safety Standard No. 207, we would agree with your conclusion to apply the loads at the required different points and directions simultaneously. On the question of whether bucket seats with seat belt anchorages attached may be tested separately, the applicable paragraph in SAE J787b is 5.2 rather than 5.1 as stated in your letter. There is no test method specified therein relative to this question and accordingly, test of the bucket seat with seat belt anchorages attached may be tested either separately or in sets. |
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ID: nht69-1.26OpenDATE: 08/27/69 FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA TO: Rubber Manufacturers Association TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your letter of August 1, 1968, to the National Highway Safety Bureau, requesting the addition of test rims for certain tire size designations to Table II of the Federal Motor Vehicle Safety Standard No. 110. With your letter your transmitted data indicating satisfactory completion of the test requirements specified in the Federal Motor Vehicle Safety Standards No. 109 and No. 110. On the basis of this information, your request for the approved equivalent rims is granted. Accordingly, the following approved equivalent rims will be added to Table II of the Federal Motor Vehicle Safety Standard No. 110. Tire Size Designation Alternate Rim E70-14 7JJ E70-15 8JJ G78-14 7JJ E70-15 7JJ |
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ID: nht69-1.31OpenDATE: 01/27/69 FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA TO: Nottingham & Pinto TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of December 26, 1968, and as a follow-up of our meeting of January 9, both concerning your proposal to hot brand the legend "SECOND NOT ADJ." Over part of the brand name "ATLAS FLYORON" tires. Provided the branding of the legend does not make the brand name illegible it would be permissible under the motor vehicle safety standards. Examination of the photos you submitted indicates that no part of the brand name is obliterated and only one letter is affected, although still clearly visible. Therefore, as long as one of the methods of branding shown in the photos is followed, the labeling requirements of standard No. 109 with regard to the brand name will have been met. |
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ID: nht69-2.49OpenDATE: 08/18/69 FROM: AUTHOR UNAVAILABLE; S. K. Booth; NHTSA TO: Cox Trailors Incorporated COPYEE: CENTRAL FILE(2); ANDERS; COMPTON; LEYSATH; NIELD; 512 CHRON; 510A CHRON; INTERPRETATIONS: STD.108; DYSON (2); CC-2921 TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of August 6, 1969, concerning the location of the side marker lamp and reflector on boat trailers manufactured by your company, as discussed by your Mr. Oglesby with Mr. Tyson of this office. Paragraph S3.2.1.4 of Standard 108 states: "On trailers, the amber front side reflex reflectors and amber front side marker lamps may be located as for forward as practicable exclusive of the trailer tongue." The forward location chosen will be satisfactory if you can provide reasonable justification for not placing it farther forward, that is, closer to the base of the trailer tongue. We are pleased to be of assistance. |
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ID: nht69-2.5OpenDATE: 01/24/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: Nissan Motor Corporation in U.S.A. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of December 6, 1968, to Dr. William Haddon, Jr., Director, National Highway Safety Bureau, requesting a clarification of the requirements for a turn signal pilot indicator as specified in Motor Vehicle Safety Standard No. 108. With respect to the turn signal pilot indicator only, you are correct in your interpretation that so long as the indicator is the color green, the diameter circle is more than 3/16 inches, and the driver has a clear and unmistakable indication, it is not necessary to apply other test procedures in order to meet the requirements of Standard No. 108. The above provision in no way excepts turn signal lamps from meeting the requirements of SAR Standard J588d, June 1966. |
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ID: nht70-1.23OpenDATE: 03/04/70 FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA TO: Trelleborg Rubber Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: This will acknowledge your letter of February 4, 1970, to the National Highway Safety Bureau concerning the labeling requirements for motor vehicle tires manufactured prior to August 1, 1968. Federal Motor Vehicle Safety Standard No. 109 requires that all motor vehicle passenger car tires manufactured after January 1, 1968, conform to the requirements as cited. I have enclosed a copy of Standard No. 109 and No. 110 with amendments for your reference. Section 54.3 specifies the labeling requirements. You will note 54.3.1 permits the sale of tires manufactured during the period January 1, 1968, to August 1, 1968, which have a label or tag affixed that incorporates the specified information. Inclusion of information on the invoice does not relieve the manufacturer from affiding the proper labeling on each tire. |
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ID: nht70-2.16OpenDATE: 07/15/70 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Transelex Corporation TITLE: FMVSS INTERPRETATION TEXT: In your letter of July 1 you refer to your superflash 1000 as "device which simply extends the power-handling capability of a conventional thermal flasher which must be used in conjunction with it (to provide its timing) in order to operate". You ask whether this device "could be used in OEM vehicles without meeting any SAE or DOT requirements." This will confirm that Federal Motor Vehicle Safety Standard No. 108 (Lamps, Reflective Devices, and Associated Equipment) does not specify requirements for an auxiliary device such as the superflash 1000, and that it can "be used in OEM vehicles without meeting any SAE or DOT requirements, provided that the thermal flasher used with it" meets standard No. 108. The Superflash 1000, however, would be subject to regulation by the States. |
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ID: nht68-2.3OpenDATE: 06/27/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Department of Education TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of June 4, 1968, to Mr. George C. Nield, concerning the State Board of Education's requirement for school bus warning signal lamps. The warning signal system as described in your letter does not meet the requirements of Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1969. A copy of this Standard is enclosed for your reference. A minimum of four red signal lamps is required and they shall be designed to conform to SAE Standard J887, July, 1964, a copy of which is also enclosed. Four additional amber lamps are permitted. The red and amber system and the red only system shall be installed in accordance with paragraph S3.1.3.2 and S3.1.3.3, respectively, of Standard No. 108. |
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ID: nht68-2.40OpenDATE: 11/13/68 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: NSU Motorenwerke Aktiengesellschaft TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of October 8, 1968, to Mr. Eugene Laskin, Acting Director, Office of Standards Preparation, concerning reflex reflectors. The use of two Class B reflectors combined with the fail lamps on the rear of your vehicles will not impair the effectiveness of the two Class A red reflex reflectors required in Motor Vehicle Safety Standard No. 108. These devices are therefore in accordance with Standard No. 108, including paragraph S3.1.2. Since this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment, 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 Standard No. 108. |
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ID: nht68-2.42OpenDATE: 09/04/68 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Robert Bosch GMBR TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of May 21, 1968, addressing to Mr. Lester D. Johnson, Commissioner of Customs, with a copy to Alan S. Boyd, Secretary of the Department of Transportation, concerning the effect of a joint Customs and Transportation regulation on replacement parts for vehicles manufactured prior to the effective date of Federal Motor Vehicle Safety Standards and particulary replacement white parking lamps. Motor Vehicle Safety Standard No. 108 specifies that the parking lamps on passenger cars, multipurpose passenger vehicles, trucks and buses of less than 80 inches overall width shall be two number, amber in color on all such vehicles manufactured after January 1, 1969. Accordingly, these specifications do not apply to the replacement parts required to keep vehicles already manufactured in safe operating condition. |
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.