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: nht71-2.24OpenDATE: 04/01/71 FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA TO: Good Rumor Corporation TITLE: FMVSS INTERPRETATION TEXT: In your letter of March 2 you petitioned for an amendment of S4.5.6 of Federal Motor Vehicle Safety Standard No. 10 which would eliminate the requirement for an outage indicator on vehicles less than 80 inches in overall width equipped with variable-load turn signal flashers. The Administration has determined that vehicles less than 80 inches in overall width should be provided with a turnsignal outage indication. As a general rule, these vehicles are not subject to the inspections and maintenance that larger vehicles are, and a malfunctioning turn-signal unit is less likely to be discovered in the absence of an outage indication to the driver. Your petition for rulemaking is therefore denied. The Federal motor vehicle safety standards, however, do not prohibit the use of variable-load flashers as replacement equipment for fixed-load flashers. |
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ID: nht71-2.28OpenDATE: 04/20/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Allied Chemical Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 24, 1971, requesting our interpretation of S4.5.2 of Motor Vehicle Safety Standard No. 208. You have asked whether the requirement of S4.5.2 that "all electrical circuits" must be monitored would mean that a bridgewire circuit in an electroexplosive device would have to be monitored. Our answer is that such a circuit must be monitored, although it should be noted that monitoring need not be continous, but may be designed to occur, for example, only when the ignition is in the "start" position. Your letter points out several potential problems with the inclusion of such a bridgewire circuit among the monitored systems. We are giving consideration to the self-monitoring requirement in the light of the comments we have received, with a view to possible amendments that may be found advisable. |
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ID: nht71-2.37OpenDATE: 04/30/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Recreational Vehicle Institute TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 8, 1971, requesting a confirmation of your understanding as to two sections of Standard No. 208, Occupant Crash Protection. You are correct in reading section S4.3 to provide options for trucks and multipurpose passenger vehicles of more than 10,000 pounds GVWR that differ from the options provided under S4.2 for trucks and multipurpose passenger vehicles with a GVWR of 10,000 pounds or less. You are also correct in reading S4.2.2 and S4.2.3 to mean "chassis-mount camper" when the term "vehicles carrying chassis-mount campers" is used. The petitions filed by RVI requesting amendments to Standards No. 208 and 210 are under active consideration and you should expect to receive an answer in the very near future. |
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ID: nht71-2.40OpenDATE: 05/05/71 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Recreational Vehicle Institute, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 1, 1971, requesting our interpretation of the term "provision" as used in the definition of seat belt assembly anchorage in Standard No. 210 (35 F.R. 18116, November 26, 1970). The change from the use of the word "device" in the prior issuance of the rule (35 F.R. 15293) to the use of "provision" in the November 26 issuance was made to avoid any appearance of requiring a specific type of structure. A hole capable of accepting a seat belt assembly's attaching hardware would therefore qualify as an anchorage. It would not, of course, be an anchorage conforming to Standard No. 210 unless it could also withstand the forces specified in that standard. Please advise us if you have further questions on this matter. |
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ID: nht71-2.6OpenDATE: 02/12/71 FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA TO: Koito Manufacturing Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of January 22, 1971, to Mr. Charles A. Baker of this Office concerning questions on paragraph S4.1.1.7 of Federal Motor Vehicle Safety Standard No. 108. "Red" was inadvertently included in paragraph S4.1.1.7 of the amendment to Standard No. 108 published on October 31, 1970. It is anticipated that this paragraph will be further amended in the near future by changing" . . . requirements for Class A red turn signal lamps . . ." to ". . . requirements for Class A turn signal lamps. . ." The answers to your questions are therefore as follows: 1. Amber turn signal lamps shall conform to the minimum candlepower requirements for Class A amber as specified in Table 2 of SAE J575d. 2. There is no maximum candlepower requirement for amber front turn signal lamps. |
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ID: nht71-5.7OpenDATE: 11/26/71 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Crane Carrier Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of November 16, 1971, in which you requested an opinion as to the requirements of Standard No. 208 that will apply to your vehicles after January 1, 1972. It appears from the information you provided that all of your vehicles have gross vehicle weight ratings of more than 10,000 pounds. They will therefore be subject to the requirements of section S4.3 of the standard. Under this section, you may equip them with either of two restraint options - a passive restraint system, or a seat belt that conforms to the Federal seat belt standard (Standard No. 209). The vehicles will also have to have seats that conform to Standard No. 267, and seat belt anchorages that conform to Standard No. 210. Copies of each standard are enclosed for your reference. ENCLS. |
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ID: nht72-1.11OpenDATE: 05/04/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: British Leyland Motors, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 19 calling our attention to Mr. Whitehead's letter of February 8 addressed to Docket No. 70-27. We regret the delay in answering Mr. Whitehead's question. Communications addressed to the docket, which arrive in large volume, are normally filed without reply. We request that letters requesting a reply be addressed to the Administrator, not the docket, so that they will be promptly assigned for action. Mr. Whitehead asked whether a display of "red letters" when the lamp is lit would satisfy the proposed revision of Standard No. 105, and recommended that the words "red lens" be deleted from paragraphs S4.3.2c and S4.7.2d of the proposed amendment to Standard No. 105. The red letters described appear to satisfy the intent of the proposal, and the suggestion for rewording will be considered when the final rule is issued. |
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ID: nht72-1.13OpenDATE: 09/22/72 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Mr. Darrell L. Lindemann TITLE: FMVSS INTERPRETATION TEXT: This is in reference to your letter of September 8, 1972, concerning glare from chrome trim on the hood of your 1971 Ford Torino, which was forwarded to our attention by the National Transportation Safety Board. Federal Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces . . .", regulates the specular gloss of four types of bright metal components in the driver's field of view but does not include chrome trim on the hood of a vehicle. In an effort to extend the scope of this standard to make it more effective in reducing daylight glare, the National Highway Traffic Safety Administration has sponsored four contract investigations dealing with glare. The final report on the last entry will be completed soon. After studying the results of this research. We intend to revise Standard No. 107 to cover other glare-producing areas of the vehicle. |
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ID: nht72-1.39OpenDATE: 03/23/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Nissan Motor Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: In your letter of March 3, 1972, you asked for our interpretation of how a rigid bracket installed on the B-pillar to guide the shoulder belt would be treated under Standard 210. Although the bracket in question does not perform all the functions of the anchorage, in that it would sustain only a fraction of the total force imposed on the anchorage in an accident, it performs a significant anchorage function by controlling the angle at which the shoulder belt crosses the occupant's chest. It is therefore considered a part of the anchorage and must fall within the acceptable range for upper torso anchorage locations specified in Standard 210. If you have information to indicate that the acceptable zone could be extended forward of its present position without lessening the effectiveness of the shoulder belt, we would be most interested in obtaining it for review. |
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ID: nht72-2.33OpenDATE: 02/07/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: K-D Lamp Company TITLE: FMVSS INTERPRETATION TEXT: In your letter of January 20 to Mr. Vinson of this office you ask for an interpretation of paragraph S4.7 "Replacement Equipment" of Motor Vehicle Safety Standard No. 108. Standard No. 108 applies to motor vehicles manufactured on or after January 1, 1972. The standard specifies items with which these vehicles must be equipped. The standard also applies to items manufactured on or after January 1, 1972, intended to replace items required by Standard No. 108 to be original equipment on these vehicles. This replacement equipment must be manufactured to confirm to Standard No. 108 and certified as meeting all applicable Federal motor vehicle safety standards. The standard does not require conformance or certification of items intended as replacement equipment on vehicles manufactured before January 1, 1972. In this circumstance a manufacturer may continue to manufacture replacement equipment that does not meet Standard No. 108. |
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.