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: nht68-2.41OpenDATE: 04/30/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Gilbert, Segall and Young TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of April 3, 1968, to Dr. Williams Haddon, Jr., requesting a clarification of the location requirements for license plate lamps as specified by Federal Motor Vehicle Safety Standard No. 108. The installation requirements contained in the SAE Standard that are referenced in Standard No. 108 are enforceable requirements unless specifically excepted by Standard No. 108. With respect to the installation of license plate(Illegible Word), Standard No. 108 provides an exception to the "Installation Recommendation" contained in SAE Standard(Illegible Words) in that Standard No. 108 requires a location(Illegible Word) rear license plate." This exception permits installation of the license plate lamp or lamps at the top, sides or bottom of the license plate, instead of top and sides only as specified by the SAE installation recommendations. Thank you for writing. |
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ID: nht68-3.27OpenDATE: 04/24/68 FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA TO: Fiat Motor Company, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reference to your letter of March 21, 1968, concerning Federal Motor Vehicle Safety Standard No. 202. The standard does not preclude the use of a head restraint which, when not in use, can be fully retracted into the seat back. MOTOR COMPANY, INC. March 21, 1968 March 21, 1968 Robert O'Mahoney Federal Highway Administration With reference to Federal Safety standard 202 issued on Federal Register Vol.33 of February 14, 1968, we would appreciate your confirming to us whether a head restraint which, when not in use, can be fully retracted into the seat back is acceptable. Would you please clarify this to us. Thanking you for your cooperation in this matter, we remain, G. Gabrielli Technical Manager |
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ID: nht68-3.29OpenDATE: 04/24/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Finderne Engine Co., No. 1, Inc. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of April 8, 1968, to the National Highway Safety Bureau, concerning the applicability of lighting requirements to fire trucks. We agree that the front identification lamps might be slightly obscured while the stationary and rotating red and amber lights are flashing. However, when these lights are not flashing, the identification lights would clearly identify a vehicle that is more than 80 inches in overall width. Therefore, identification lights will be required on your fire truck. The same reasoning can be applied to clearance lights and compliance is also required. The enclosed literature may be of additional assistance to you in response to your inquiry. We trust this information will be of assistance to you in your desire to comply with existing safety standards. |
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ID: nht68-3.30OpenDATE: 05/01/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Truck Equipment, Incorporated TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of March 6, 1968, to Mr. Lowell K. Bridwell, Federal Highway Administrator, in which you inquired about certification responsibility for lighting on your truck bodies. Federal Motor Vehicle Safety Standard No. 108 on lighting applies to motor vehicles, not to motor vehicle equipment such as truck bodies. When the body is mounted on the chassis cab, the lighting requirements of Federal Standard No. 108, not certified by the manufacturer, must be fulfilled. Certification must be provided to the dealer when the chassis cab is completed for the dealer. A dealer selling to the final purchaser need not certify, but is responsible for lighting to be in compliance with Federal Standard No. 108, for that part of the lighting (or other standards) which have not been previously certified. Trusting this information answers your questions. |
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ID: nht68-4.5OpenDATE: 08/23/68 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: The Coleman Company, Incorporated TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of August 12, 1968, to Mr. Ed Laysath concerning lighting requirements on camper trailers. The lamps and reflectors shown on your sketch appear to meet the requirements of Standard No. 108 with the exception that a license plate lamp is not indicated. Since no dimensions are specified on your sketch, we can only assume that the locations are as specified in the standard. With respect to the requirements of Standard No. 103, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, 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: nht69-1.2OpenDATE: 08/22/69 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: S. Hoffman, Esq. TITLE: FMVSS INTERPRETATION TEXT: This in further response to your letter of July 14 enclosing an engineering drawing of a hub cap "incorporating a decorative device designed to create an impression of spinning at the center of the wheel during operation of the vehicle", and requesting an interpretation of Federal Motor Vehicle Safety Standard No. 211 with respect thereto. Standard No. 211 specifies the requirement that hub caps, wheel nuts, and wheel discs shall not incorporate winged projections. That in the sole requirement of this Standard. The drawing submitted by you depicta a hub cap which, in our judgment, incorporates a winged projection. The Standard does not regulate vehicle width, and thus your observation that "it would not broaden or extend the front (or top or rear) profile of automobiles . . ." is not a factor to be considered. I enclose the engineering drawing you furnished us. |
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ID: nht70-2.36OpenDATE: 11/24/70 FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA TO: Mercedes-Benz of North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of September 29, 1970, concerning the application of Federal Motor Vehicle Safety Standard No. 206 to the door locks and door retention components on the C-111's gull-wing doors. I appreciate also the design drawings you submitted earlier this month. As Standard 206 presently exists, the door locks and door retention components on the C-111 doors must conform to it. As Rocks and retention components on passenger car side doors that meet the description in the first sentence of S4, they are clearly within the ambit of the standard. The Bureau recognizes that some of the requirements and test procedures in the standard may not be entirely appropriate for side doors of all designs, and is accordingly considering amendments to the standard. If we can be of further assistance, please write. |
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ID: nht71-1.14OpenDATE: APRIL 16, 1971 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Western Safety Devices Company TITLE: FMVSS INTERPRETATION TEXT: In response to your letter of March 10, 1971, to Mr. Douglas W. Toms, Administrator, National Highway Traffic Safety Administration, concerning Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems; Truck, Buses and Trailers, the following information is offered. 1. Standard No. 121 applies only to new vehicles manufactured on or after January 1, 1973. 2. Federal Motor Vehicle Safety Standard No. 121 does not preclude the use of a dashboard-mounted control for the tractor protection valve. 3. Standardization of a dashboard-mounted control valve is not contemplated at the present time. 4. A petition requesting reconsideration of the requirements for a parking brake control valve in S5.4.6 has been received and is being considered at the present time. The decision in response to this and other petitions will be published in the Federal Register in the near future. |
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ID: nht71-1.15OpenDATE: 12/30/71 FROM: Richard B. Dyson; NHTSA TO: Gurley Refining Company TITLE: FMVSS INTERPRETATION TEXT: We have examined the proposed label for "GRC" brake fluid you have submitted to us for comment. Generally, the label appears to meet the requirements of paragraph S5.2.2 of [Illegible Word] Vehicle Safety Standard No. 116 (36 f.r. 11987, June 24, 1971, as amended, 36 F.R. 21594, November 11, [Illegible Date]. The words "or [Illegible Word]" in your conformity statement are redundant; since the standard is a minimum requirement, "conforming to" and "exceeding" it mean exactly the same thing. If the fluid packager is an entity other than Curley, the packager's name or code identification must appear either below Gurley's name or on the bottom of the can. We assume that the required serial number identifying the packaged lot and date of packaging will be stamped either below Curley's name or on the bottom of the can. |
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ID: nht71-1.27OpenDATE: 01/01/71 EST. FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Renault, Incorporated TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of August 4, 1971, to Mr. Clue Ferguson, requesting a clarification of certain sections of Federal Motor Vehicle Safety Standard No. 203 - Occupant Crash Protection, Docket 69-7, Notice 10. It was our intent, under S4.5.3, to permit free substitution of Type 1 or Type 2 passive belts for seat belt assemblies required under S4. The standard specifies in S4.5.3 that a passive belt must conform to the requirements of S7.1 and to certain requirements of Standard No. 209, but it does not specify (Illegible Word) that shoulder belts should be detachable or that they should be non-detachable. The manufacturer may therefore choose either method of shoulder belt attachment. A detachable shoulder belt in a passive belt system must not, however, convert the system from passive to active status. Please advise us if you need additional clarification of this point. |
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.