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: nht71-2.44OpenDATE: 05/06/71 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Toyo Kogyo Co. Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 6, 1971, requesting an interpretation of section S7 of Standard No. 208, Occupant Crash Protection. Your question concerns the requirement of S7.1.2 that the intersection of the upper torso belt with the lap belt shall be at least 6 inches from the occupant's front vertical centerline. As we understand your question, you have asked whether this 6-inch distance must be achieved by using an inboard belt segment of fixed length, or whether a manual adjusting device may be used that will permit lengthening of the inboard belt segment when the seat is moved forward. It is the intent of section S7.1.2 to require an intersection point that cannot be adjusted so that it is less than 6 inches from a 50th percentile male occupant's centerline. We are considering a possible amendment to the standard to clarify this intent. Please advise us if further explanation is needed. |
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ID: nht72-1.17OpenDATE: 01/26/72 FROM: AUTHOR UNAVAILABLE; David Schmeltzer; NHTSA TO: National Farmers Union Property and Casualty Company TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of January 4, 1972, in which you inquired into the possibility of selling tires that sustained (Illegible Words) damage in a service station fire. In 1969, you were faced with a similar situation and we advised you of the way in which these tires could be sold. In 1970, Safety Standard No. 109 was amended to deal with the problem of tires that had to be reclassified and thus you cannot (Illegible Word) rely upon our comments of three years ago. I have enclosed a copy of the (Illegible Word) on point. The Amendment indicates a policy of (Illegible Word) control over the sale of "farm use only" tires. Since you are reclassifying the tires, you will have to meet the requirements of (Illegible Words) the same manner as a manufacturer. You will also be interested in the Notice of Proposed Rule Making I have enclosed. This proposal would prohibit the sale of tires which can now be sold as reclassified. |
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ID: nht72-1.2OpenDATE: 02/23/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Petro Electric Motors, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in further response to your letter of December 16, 1971, requesting interpretations of several Federal motor vehicle safety standards as they apply to electric vehicles. The engine retardation braking effect of Standard No. 102 applies only to vehicles equipped with automatic transmission, and not to an electric vehicle that has no transmission. Standards Nos. 201 through 204 do not apply to trucks. You have stated that your electric vehicle is designed so that "the rear . . . will normally be used for tools, service equipment, spare parts, etc., as would be required in a service vehicle as used by an electric utility company for going out and making repairs." You have also stated that the back area could be converted to a seating area for two passengers, but that this would be "unusual and occasional." On the basis of this information we have concluded that your vehicle is a "truck" and need not meet Standard Nos. 201-204. |
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ID: nht72-1.31OpenDATE: 02/11/72 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Bandag Incorporated TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of January 15, 1972, asking whether your "treadless" passenger car tire will be considered a new tire under the Federal motor vehicle safety standards. You enclose a diagram and explain that the "treadless" tire is a "brand new . . . tire that we will furnish our dealers and then they will apply a new Bandag tread to the tire and then sell the finished unit." Based upon the description you have provided, we are of the opinion that your treadless tire is a new tire, and consequently subject to Motor Vehicle Safety Standard No. 109. Also, as each dealer applies the tread to the tire, each would be considered a "manufacturer" under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 at seq.), and be responsible for the requirements imposed upon manufacturers by the Act, and a standards and regulations issued pursuant to it. We are pleased to be of assistance. |
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ID: nht72-1.50OpenDATE: 11/28/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Pride Products Co., Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of October 23, 1972, requesting information on the use of sample testing for determining conformity to Motor Vehicle Safety Standard No. 213. You ask if there are sampling provisions to which manufacturers should currently be adhering. There is no specified sampling provision for manufacturers to follow in testing their products for conformity to Standard No. 213. The National Traffic and Motor Vehicle Safety Act requires each item of motor vehicle equipment (for example, each child seat) to conform to the applicable safety standard in effect on its date of manufacture. It is the manufacturer's responsibility to decide what type of testing program is necessary to be reasonably certain that each item complies. The extent of his sampling should depend on such factors as the margin by which typical samples pass the performance requirements, the amount of variation in production that is present, and the degree to which substandard items can be detected by non-destructive techniques. |
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ID: nht72-2.20OpenDATE: 10/02/72 FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA TO: The Grote Manufacturing Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 25 to Mr. Lewis C. Owen of this Office concerning the mounting of front clearance lamps on trucks and buses over 80 inches in width. You are correct in your interpretation that these lamps must be mounted to indicate the overall width of the vehicle and as near the top as practicable. The width and height of the body in relation to that of the cab on a van type truck governs the proper location; therefore, each application must be judged individually. However, you are correct that the proper location should be the top front corners of the body when the height of the body is significantly higher than the cab. Since this name question has been directed to us repeatedly and some manufacturers are installing cab mounted lights and others body mounted lights on quite similar vehicles, we anticipate that this aspect will be addressed in future rulemaking actions. |
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ID: nht72-2.30OpenDATE: 03/01/72 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Motor Coach Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of February 7, 1972, to Mr. Lewis Owen of this Office concerning clarification of the requirements of paragraph S4.7 of Standard No. 108. A label similar to that shown on the enclosure to your letter would meet the certification requirements of paragraph S4.7.2 of Standard No. 108 as specified in the amendment published in the Federal Register on January 12, 1972, (copy enclosed). "Associated equipment" covered by Standard No. 108 includes only that for which requirements are specified in the Standard. The only serviceable item, in addition to the completed assemblies, for which certification is required is a plastic part such as a (Illegible Word), which must meet the requirements of paragraph S4.1.2. The requirement for replacement equipment to conform to Standard No. 108 was applicable to items manufactured on and after January 1, 1972. Certification of items received by your Service Parts Department after January 1, 1972, is therefore acceptable. |
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ID: nht72-2.47OpenDATE: 02/14/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: North Carolina Automotive Wholesalers Association, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of January 19, 1972, concerning brake fluids. A revised Federal Motor Vehicle Safety Standard No. 116, effective March 1, 1972, was published on March 24, 1971 (36 F.R. 11987), based upon a proposal published on September 30, 1970 (35 F.R. 1522O). I enclose a copy of the proposal and the rule for your information: the preambles to these notices explains the relationships between the DOT and SAE terminology in identification of brake fluid. In response to your specific questions, brake fluid must conform to Standard No. 116 at the time it is sold to the ultimate purchaser. This means that the manufacturer is responsible for manufacturing fluid that meets Standard No. 116, and the package and retail seller for insuring that the fluid continues to conform until the time of sale. Brake fluid manufactured before March 1, 1972, may be sold until the supply is exhausted, and no relabeling is necessary. |
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ID: nht72-3.15OpenDATE: 06/12/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Silver-Top Manufacturing Co., Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 26, 1972, inquiring whether you are required to use "laminated safety glass" in the forward-facing window of a pickup cap. You indicate that this window is below the roof line of the cab of the pickup, immediately behind its rear window. Under Federal Motor Vehicle Safety Standard No. 205, "Glaring Materials", (49 CFR 571.205, copy enclosed) windows in campers, pickup caps, pickup canopies, and pickup covers must be manufactured of safety glazing material specified in the standard, Forward-facing windows such as the one you describe must be manufactured of either AS1, AS2, AS3, AS4, or AS5 glazing materials, as those materials are described in the American National Standards Institute Test E26.1-1966. Materials other than "laminated safety glazing" may be used to meet each of these "AS" categories, and we refer you to ANS Test 226.1 for specific requirements. |
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ID: nht72-3.16OpenDATE: 05/08/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Temptation Mfg. Co. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your undated letter, which we received on March 22, 1972, in which you ask what NHTSA requirements are applicable to a truck cover you manufacture, enclosing a picture. The picture appears to show a cover designed for installation over the back of a pickup truck. If this unit is not designed to carry persons when the truck is in motion, there are no requirements applicable to it. If, however, it is designed to transport persons, the glazing materials (glass and plastics) used in it must conform to Motor Vehicle Safety Standard No. 205, "Glazing Materials," (copy enclosed). In addition, the unit must also be certified as conforming to the standard in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act and the enclosed NHTSA notice of November 4, 1967. The ASA Test 226.1-1966 that is incorporated into Standard No. 206 can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10018. |
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.