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: nht72-1.38OpenDATE: 08/21/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Nissan Motor Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of August 11, 1972, requesting confirmation of your understanding of the phrase "the nearest contact point of the belt with the hardware attaching it to the anchorage", as used in S4.3.1.3 of Motor Vehicle Safety Standard No. 210. You indicate that the buckle in the proposed Nissan belt system is attached to the seat structure by a rigid bracket. The nearest contact point of the belt with the hardware attaching it to the anchorage appears to be correctly shown in each of the drawings attached to your letter. The installation shown in the upper drawing is, as you suggest, the only one of the four that would meet the location requirements of S4.3.1.3. |
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ID: nht72-1.6OpenDATE: 06/13/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: FMC Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of May 25 inquiring about compliance of your planned motorhome with Federal Motor Vehicle Safety Standards Nos. 101 and 104. Standard No. 101 requires certain controls to be illuminated. We interpret this to mean sufficiently illuminated that the control identification, if verbal, can be read, or if pictorial, can be understood. Therefore, illumination from any course is satisfactory as long as the basic requirement of comprehension is met. Standard No. 104 does not describe the type of windshield wiping system that must be used to meet its requirements. It is the manufacturer's responsibility to insure, whatever system is used and whatever configuration of windshield is employed, that the wiped and washed area requirements are met. |
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ID: nht72-1.8OpenDATE: 04/11/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: GGO Group, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 3, 1972, to Mr. Schneider asking whether your Gemini Tow Control System would come under our regulations, and whether you would be considered a brake manufacturer. The Federal motor vehicle safety standard covering vehicle hydraulic brake systems, Standard No. 105, applies only to passenger cars (not directly to equipment manufacturers), and does not cover the hydraulic braking relationship between towing and towed vehicles. For that reason the Gemini system would not be regulated by Standard No. 105. There are no Federal standards applicable to a tow control system per se. We would, however, view you as a "manufacturer," and the product you have described as "motor vehicle equipment," within the remaining of the National Traffic and Motor Vehicle Safety Act of 1965. |
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ID: nht72-2.31OpenDATE: 03/10/72 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Strick Corp. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 21, 1972 asking for reconsideration of the opinion expressed in our letter of October 6, 1971, concerning the location of the rear identification lamp cluster on trailers of your manufacture. You are correct in saying that the requirement that Identification lamps be located" 'as close as practicable to the top of the vehicle' is subject to interpretation and individual judgment." We have expressed our opinion previously, and if you choose to mount your lights below the rear crossmember you should be prepared to demonstrate that this location is "as close as practicable to the top of the vehicle." I enclose a copy of a recent amendment to Standard No. 108 permitting off-center spacing of identification lamps. Perhaps this will alleviate your problem to come extent. |
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ID: nht72-2.38OpenDATE: 08/17/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Ford Motor Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of July 26, 1972, concerning the adjustment of a tractor's fifth wheel under the test conditions proposed in Docket 70-17, Notice 5. You state that it is not possible to load the tractor to its GVWR with the tractor's nonsteerable axles and the trailer's axles at GAWR if the fifth wheel is set in more than one position. If this is the case, and the correct loading can be obtained with the fifth wheel in one position only, then only that position will be used in compliance testing. If more than one position can be used to produce the correct loading, the tractor must conform to the requirements of the standard with the fifth wheel at any such position. |
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ID: nht72-2.50OpenDATE: 05/01/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Labelmaster TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 11, 1972, in which you ask whether four samples which you submit of labels for retreaded tires will meet the requirements of S6.2 and S6.3 of Motor Vehicle Safety Standard No. 117. Each of the labels, with either the appropriate information filled in or clearly indicated by an "X" or other mark will meet the requirements of the standard. In the case of styles "C" and "D", however, either "2-ply" or "4-ply" will have to be deleted by the retreader, as one tire, of course, cannot be both a 2-ply and 4-ply tire. An alternative would be to eliminate the reference to plies, as stating the ply rating by itself is sufficient under the standard. We are pleased to be of assistance. |
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ID: nht72-3.22OpenDATE: 11/15/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Philips Industries Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of October 5, 1972, concerning the manufacture of storm windows for use in recreational vehicles. You refer to our letter to Mr. Bob Sanders of your company (our records show the date of the letter to be July 5) in which we outlined the requirements for glazing materials used in various locations in recreational vehicles, and ask whether storm windows used in these locations must meet the same requirements. The answer is yes. Storm windows for use in motor vehicles must meet the same requirements as other glazing materials, according to their location in the vehicle. I have enclosed a copy of our Response to Petitions for reconsideration concerning the latest amendment to Standard No. 205. |
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ID: nht72-3.25OpenDATE: 06/30/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Harold Schlintz & Associates TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of June 8, 1972, to Robert L. Carter, as to whether Federal Motor Vehicle Safety Standard No. 206 is applicable to a White "Freightliner" which was manufactured on or about December 1, 1970. The White Freightliner, as illustrated in the picture you enclosed, is a truck tractor, and is classified as a "truck" under the motor vehicle safety standards. Standard No. 206 became applicable to trucks on January 1, 1972, and would not therefore apply to this truck. No other standards are applicable to the doors or door latches of this vehicle. The standards do not apply to a vehicle after its first sale to a consumer (a used vehicle), and we exemption from the standards is necessary. |
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ID: nht71-3.39OpenDATE: 07/16/71 FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY RICHARD B. DYSON TO: Toyota Motor Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of May 20, 1971, to Administrator Douglas W. Toms, requesting an interpretation of paragraph S5.2(h) of Federal Motor Vehicle Safety Standard No. 209, and particularly of the sentence containing the phrase ". . . the retractor and webbing shall be suspended vertically . . ." Of the two interpretations you submitted, your interpretation 2 is correct. The retractor-webbing combination is suspended vertically -- there is no restriction on the attitude of the retractor with respect to the webbing. Thus, the retractor may be suspended in the position it will be mounted in the vehicle relative to the webbing when the webbing is in use. Please let us know if we can be of further assistance. |
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ID: nht71-4.18OpenDATE: 10/06/71 FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA TO: Strick Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 21, 1971, to Mr. Douglas Toms, Administrator, National Highway Traffic Safety Administration, requesting an interpretation on the mounting of Identification lamps on your trailers. We hesitate to agree with you that it is not practicable to mount the Identification lamps at the extreme height of the trailer. It would appear to be practicable to mount these lamps at the extreme height, even if a shield were necessary to prevent damage to the lamps during use. If the identification lamps are mounted at the extreme height of the trailer, the clearance lamp mounting height is optional; therefore, clearance lamps could be mounted on the rear crossmember, as shown on your drawing SK-24139. |
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.