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: nht71-5.26OpenDATE: 12/17/71 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Maxim Motor Division COPYEE: STAN HARANSKY TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter concerning the requirements of Federal Motor Vehicle Safety Standard 206. Your letter(Illegible Word) forwarded to us November 10, 1971, by Mr. Stan Haransky. Associate Director of the Truck Body and Equipment Association, Inc. You ask whether the standard would prohibit the manufacture of fire trucks without side doors on the cabs. According to your letter, the trucks are built without side doors in order to allow firemen to enter and exit the cabs quickly during emergencies. Standard 206 does not require that any type of motor vehicle be equipped with side doors. The standard requires only that if a vehicle subject to it has hinged or sliding side doors, they must conform with the standard's performance requirements for hinges, locks and latches. Please write if I can be of any further assistance. |
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ID: nht72-4.11OpenDATE: 06/02/72 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Nissan Motor Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of May 9, 1972, in which you again raise the problem of where to place the seat in tests for which Standard 208 specifies that the seat is to be at the midway position but the seat track has no adjustment position that coincides with the midway point. Our reply of March 2, 1972, stated that when the midway point is exactly halfway between two adjustment notches, the seat should be placed in the rear notch. You are correct in pointing out that if the notches were on the upper seat rail the seat would be moved forward if these instructions were followed. It was our intent to specify rearward seat movement in each case in which the midway point on the track fell exactly between two notches. In Case (2) of your letter, therefore, it will be our practise to move the seat rearward from the position shown in red until the next notch is reached. |
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ID: nht72-6.23OpenDATE: 11/14/72 FROM: AUTHOR UNAVAILABLE; D. W. Toms; NHTSA TO: National Committee on Uniform Traffic Laws and Ordinances TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of October 4, 1972, asking among other things, whether the National Traffic and Motor Vehicle Safety Act preempts the recent California law requiring motorcycles made on or after January 1, 1972, to be wired so that their headlamps are lit whenever the engines are running. In light of the answer to this question, it is not necessary to deal with the other ones. It is the opinion of this agency that the California law in question is presented in accordance with section 103(d) of the Act, 15 U.S.C. 1392(d), and is therefore void. Standard No. 108. 49 CFR @ 571.108, establishes requirements for motorcycle headlighting, along with special wiring requirements for motorcycles and other vehicles. It is our position, therefore, that the California requirement is within the scope of the aspects of performance covered by Standard No. 108. Since it is not identical to a federal requirement, it is rendered void by operation of the Act. |
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ID: nht73-3.45OpenDATE: 03/23/73 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Seminole Trailer Manufacturing Corp. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of March 6, 1973 to this agency asking whether it is permissible under Standard No. 108 to locate boat trailer identification lamps on the first crossmember forward of the rearmost crossmember. You believe that the identification lamps will have a longer life span in this location. The general locational requirement that a lamp be "on the front" or "on the rear" was never intended to specify that it be at the extreme front or rear of a vehicle. Clearance and identification lamps required to be "on the front" are generally mounted on a truck cab or body, for instance. Therefore your proposed location is acceptable to meet the requirements of Table II of the Standard. However, identification lamps, wherever located, must meet the visibility requirements of paragraph S4.3.1.1, and if they do not meet them in your proposed location the trailer will not comply with Standard No. 108. |
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ID: 0186Open M. Guy Dorleans Dear M. Dorleans: We have received your letter of July 15, 1994, asking whether certain front lamp designs would be permissible under Federal Motor Vehicle Safety Standard No. 108. In the basic front lamp design, the upper beam photometrics of Figure 17A would be provided by Lamps A and B. You have asked whether it is possible to add Lamp D, "an auxiliary driving beam." In this variation "all three A, B and D filaments would be permanently energized together in high beam mode and table 17a (sic) of FMVSS 108 is then fulfilled." Lamp D meets the photometric requirements of SAE Standard J581 JUN89 Auxiliary Driving Lamps. The photometrics of Figure 17A apply to two-lamp integral beam or two-lamp combination headlighting systems, and the design in your drawing is that of a four-lamp system, subject to the photometrics of Figure 15A. This configuration is not permissible under Standard No. 108. Sincerely,
John Womack Acting Chief Counsel ref:108 d:8/31/94
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1994 |
ID: 10858Open Mr. Lance Tunick Dear Mr. Tunick: This responds to your FAX of April 19, 1995, requesting clarification of an April 3, 1995, letter from this office. You asked for verification that the "seat belt anchorages in the following scenario are exempt from the location requirement of Standard No. 210: A vehicle with 2 front seating positions that is fitted with an air bag and manual three- point seat belt at each position, and such restraint meets the frontal crash protection requirements of S5.1 of Standard No. 208 with the air bags alone and with the belts and air bags together, but the belts alone are not crash tested under FMVSS 208." Your understanding is correct. I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely,
John Womack Acting Chief Counsel ref:208 d:5/9/95
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1995 |
ID: 1984-3.18OpenTYPE: INTERPRETATION-NHTSA DATE: 08/31/84 FROM: Frank Berndt; NHTSA TO: Kenneth Guthrie -- Guthrie Trailer Sales Inc. TITLE: FMVSS INTERPRETATION trailers; PART 565; S565.4(d)(1) TEXT:
Mr. Kenneth Guthrie Guthrie Trailer Sales, Inc. Box 1026 Great Bend, Kansas 67530
Dear Mr. Guthrie:
This is in response to your recent inquiry to Elizabeth Harrison of this office regarding the change of model year designation on Vehicle Identification Numbers (VIN's) affixed to trailers manufactured by your company. VIN's are required to be affixed under the authority of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) and 49 CFR Part 565. The change of model year designation in the VIN can be made by changing the code letter to F for model year 1985, according to the table in 49 CFR Part 565.4(d)(1). No notification to the agency is required for a change of model year designation.
A copy of 49 CFR Part 565 is enclosed.
Sincerely,
Frank Berndt Chief Counsel Enclosure |
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ID: nht76-2.1OpenDATE: 05/04/76 FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA TO: FILE TITLE: FMVSS INTERPRETATION TEXT: SUBJECT: TELEPHONE CONVERSATION CONCERNING STANDARD NO. 120, TIRE SELECTION AND RIMS FOR MOTOR VEHICLES OTHER THAN PASSENGER CARS On April 20, 1976, I received a telephone call from Mr. John McCuen, an attorney for Kelsey-Hayes (313 941-2000). He asked the following questions concerning Federal Motor Vehicle Safety Standard No. 120: 1. "Is use of the 'DOT' symbol permitted on rims manufactured before the August 1, 1976, effective date for the standard's rim marking requirements?" I replied that the agency's present position is as it has been in the past, namely, that such use is not permitted. I added that this interpretation is being reevaluated. 2. "Some rims are capable of being used on passenger cars as well as on multipurpose passenger vehicles. Is it permissible to label such rims pursuant to Standard No. 120, even though some might then be mounted on passenger cars?" I requested that Mr. McCuen send in a request for a written interpretation of that aspect of the standard. 3. "May rims manufactured before August 1, 1976, be sold in the replacement market after that date?" I replied that they may. |
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ID: nht88-3.28OpenTYPE: INTERPRETATION-NHTSA DATE: 08/30/88 FROM: ERNIE J. BUNNELL -- PACIFIC T-TOPS INC. TO: TAYLOR VINSON -- LEGAL COUNCIL US DEPT. OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/03/88 FROM ERIKA Z JONES TO ERNIE J. BUNNELL; REDBOOK A32, STANDARD 108 TEXT: Dear Taylor, I was refered to you by the Department of Transportation regarding FMVSS #108 and the following: The Department of Transportation guidelines for aftermarket and OEM rear spoilers which when mounted on the deck lid of a car obstruct the high mounted stoplamp. Enclosed you will see (2) versions of rear spoilers (A) and (B): A) It is designed to be at or below the rear brake light using the 5 degrees measurement as a guide. B) It is designed to go over the horizontal intensity of the light. We have been advised that the attachment does not need to comply with the ruling. However, we would like to know what the requirements are so that we can comply if possible. If you need any additional information regarding this, please contact me. I shall look forward to hearing from you. |
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ID: nht88-3.76OpenTYPE: INTERPRETATION-NHTSA DATE: OCTOBER 21, 1988 FROM: BRADLEY J. BAKER -- PRESIDENT, CLASSIC MANUFACTURING, INC. TO: TAYLOR VINSON -- LEGAL COUNCIL, U.S. DEPT. OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO AUGUST 31, 1989 LETTER FROM STEPHEN P. WOOD, NHTSA, TO BRADLEY J. BAKER, CLASSIC MANUFACTURING, INC.; [A34; STD. 108] TEXT: Our company currently manufactures a Recreational car dolly used to tow a vehicle behind motorhomes. It is also used by car dealerships to retrieve cars and trucks. We have a question regarding the 3 bar light cluster on the back of this unit. Is it a necessity? So far, we have to guess at our interpretation of the Federal laws. We don't know if this is considered a motor vehicle under FMVSS 108; 49 CFR 571.108. The National Truck Equipment Association could not answer this question and recommended we write to you. We would appreciate your opinion on this matter. I can be reached at the following address: Classic Manufacturing, Inc. 21900 W. U.S. 12 Sturgis, Mi 49091 Attn: Brad Baker (616) 651-9319 Fax No.(616) 651-2921 Thank you for your help in advance Sincerely |
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.