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: nht71-5.18OpenDATE: 12/09/71 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Volkswagen of America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of August 26, 1971, in which you asked our opinion on how to position a 50th percentile 6-year-old child in determine the conformity of a seat belt warning system to S7.3.1(c) of Standard No. 208. Our opinion is that the child should be positioned with his back against the back of the seat and his head upright, in the posture in which he would be held by the seat belt if it were buckled around him as specified in S7.1. This is the position that will be used in our tests for conformity to S7.3.1(c). The language that you cite from S8.1.11(b) of the standard ("normal upright(Illegible Words) to the positioning of test devices during the dynamic tests specified in S4 and S5, but is not applicable to the belt adjustment and warning system requirements of S7. The position that we intend to use under S7.3.1(c) is therefore not based on any definition of normal upright sitting posture." |
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ID: nht71-5.50OpenDATE: 07/01/71 EST FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Volkswagen of America, Inc. TITLE: FMVSS INTERPRETATION TEXT: In your letter of June 7, 1971, you asked for confirmation of your understanding that under the NHTSA regulation (49 CFR @ 553.39) interpreting section 105(a)(1) of the National Traffic and Motor Vehicle Safety Act, a petition for judicial review of Standard No. 208 would be considered timely if filed within 60 days after the publication in the Federal Register of the Administrator's decision on any petitions for reconsideration of that standard. Your understanding is correct. As the standard currently stands, we consider it (that is, the standard as it becomes effective January 1, 1972) a "single rule", to use your phrase, and the judicial review period will not begin to run until the publication of the decision on any timely-filed petitions for reconsideration of any part of it. If at a future date we wish to sever any portion of the standard for judicial review purposes, and consider it "final" despite pending action on other portions, we will give explicit notice of that action in the Federal Register. We are pleased to be of assistance. |
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ID: nht71-5.58OpenDATE: 04/30/71 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Rolls-Royce Limited TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 14, 1971, in which you repeat Rolls Royce's requests for interpretation of Standards No. 207 and 208. The request for interpretation of the seat adjustment requirement of Standard No. 207 was initially made in your petition for reconsideration of that standard. Our response to the petitions on Standard No. 207 was published or April 20, 1971. Your petition was denied to the extent that it requested that the requirement be amended to permit 2 inches of travel. However, it is recognized that continuously adjustable seats may have a certain small amount of travel that would not be harmful, and the notice accordingly indicates that they are considered to remain in their adjusted position despite such motion. We expect that you have by now received our reply to your questions on Standard No. 208. Your inquiry first reached us through your Washington counsel and we accordingly sent our reply by the same route. Please advise us if further clarification is needed. |
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ID: nht71-5.62OpenDATE: 11/11/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Tire Review TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of August 10 and October 6, 1971, concerning the size requirements for retreaded tires as specified in Federal Motor Vehicle Safety Standard No. 117. Your letter of August 10 enclosed a draft article that you requested we examine. I have enclosed a copy of the Administration's action on the petitions for reconsideration that were received in response to the standard as published April 17, 1971 (36 F.S. 7315). This action amends the size requirements of 25.12 of the standard by allowing a minus 3 per cent deviation from the section width specified in Table 1 of Appendix A of Standard No. 109 in addition to the plus 10 per cent deviation previously allowed. With reference to your draft article, its discussion of the size requirements, apart from the changes made by the amendments, is accurate. The copies of Appendix A or Standard No. 109 that you were furnished on August 20 have been supplemented, and a copy of the additional material is also enclosed. WE ARE PLEASED TO BE OF ASSISTANCE. ENCLS. |
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ID: nht72-4.2OpenDATE: 01/28/72 FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA TO: Docket 69-7 TITLE: FMVSS INTERPRETATION TEXT: SUBJECT: CONVERSATION WITH VOLKS WAGEN REPRESENTATIVE On Tuesday, January 25, 1972, I received a telephone call from Joseph Kennebeck of Volkswagen of America, Inc., concerning the determination of "rated cargo and luggage capacity weight" under section S8.1.1(a) of Standard 208. Volkswagen determines its cargo and luggage capacity by multiplying the number of designated seating positions by the average occupant weight and subtracting this weight from the gross vehicle weight rating. His question was whether the cargo weight determined in this fashion would be the cargo weight used in those tests in which some seating positions are not occupied. In particular, the third option available to passenger cars between January 1, 1972, and August 15, 1973, provides for a test with occupants only at the front outboard positions, (S4.1.1.3.1), and he asked whether the cargo weight would be as indicated above or some larger weight. I informed him that Volkswagen could use the cargo capacity as determined with a fully occupied vehicle for all tests in which the vehicle is less than fully occupied, as in S4.1.1.3.1. |
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ID: nht73-3.30OpenDATE: 02/20/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Canadian Pittsburgh Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of December 22, 1972, which was forwarded to us by the Department of Transport of Canada, requesting assignment of a manufacturer's code number for glazing materials you manufacturer. In your letter you indicate that the glazing in question is purchased in stock sheets, and then out to the customer's requirements. The assignment of Code number is limited to what NHTSA has called "prime glazing material manufacturers" and this group includes only those who "fabricate, lauinate, or tamper the glazing material." As your function appears to be only that of cutting the material to size, we would not consider you, at least with respect to this material, to be a prime glazing material manufacturer. Consequently, a code number assignment would be improper. The labeling requirements which you would be subject to, if this glazing as cut by you is to be imported into the United States, are those requirements specified in S6.4 and S6.5 of Motor Vehicle Safety Standard No. 203, copy enclosed. |
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ID: nht73-3.38OpenDATE: 03/05/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Volkswagen of America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of February 26, 1973, in which you asked a question concerning the relationship of the seat belt interlock and warning system required by Standard No. 208. You asked whether the informative warning system, required by S7.3.5.4 to operate when the driver turned the ignition to "start" position and "the operation of the seatbelt systems required by S7.4.1 to start the engine has not been performed", is required to operate when the driver turn the ignition to start under the "free start" provisions of S7.4.3. The answer is no. The "start" warning of S7.3.5.4 is only required to operate when a seatbelt operation "required to start the engine" has not been performed. When the engine is free to start under S7.4.3, the warning is not required. Of course, if the driver puts the vehicle in gear, the warning must sound under the provisions of S7.3.1 if the required seatbelt operations have not been performed. |
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ID: nht73-4.22OpenDATE: 05/23/73 FROM: AUTHOR UNAVAILABLE; Claude S. Brinegar; NHTSA TO: National Motor Vehicle Safety Advisory Council TITLE: FMVSS INTERPRETATION TEXT: In response to the March 15 resolution of the National Motor Vehicle Safety Advisory Council urging removal of the legal barriers to the introduction of passive restraint systems, I can report that the Department has taken a major step in the direction the Council urges. The proposed test dummy regulation, published April 2, is intended to permit manufacturers to produce vehicles with passive restraint systems under either of the passive options available before passive restraints become mandatory. Upon adoption of the proposed regulation and of the corresponding amendment to Standard 208, the first barrier addressed in the Council's resolution will be removed. The Council's second concern is with the seat belt installation laws of the States. It would be unfortunate if these laws interfere with the evaluation of fully passive restraint systems. The Department will take such steps as seem advisable to remove any legal obstruction to the manufacture and use of vehicles with fully passive systems. We expect to announce our position on this point shortly. |
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ID: nht73-4.38OpenDATE: 07/30/73 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Glen Tillotson TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of July 6, 1973, concerning problems that you foresee for your company under Federal Motor Vehicle Safety Standard No. 121. The primary problem you describe is the need to test brakes on vehicles that you produce in very small quantities. The standards promulgated by this agency under the National Traffic and Motor Vehicle Safety Act do not impose a mandatory level of testing on regulated manufacturers. If we purchase a manufacturer's product, test it, and find that it fails an applicable standard, to avoid liability for noncompliance, the manufacturer must then establish that he exercised due care in assuring himself that the product conformed to the standard. The most common method by which manufacturers assess their product's conformity with a standard is by testing the products in accordance with the procedures of the standard. A manufacturer may, however, contract to have this testing done by an outside laboratory, may rely on adequate information provided him by a supplier, or use other reasonable means to make sure that his products comply. |
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ID: nht73-5.2OpenDATE: 08/30/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Multinational Industries TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of July 12, 1973, concerning gas tank caps. You state that you are considering marketing imported gas tank caps for trucks, and you want to know whether there is a Federal standard to which such caps must conform. The answer is that there is not. Multinational Industries July 12, 1973 National Highway Traffic Safety Administration Attention: Chief Counsel, Lawrence Schneider We are considering the marketing of Gas Tank caps manufactured in Japan for use on trucks in the United States. As there may be some problems importing these items, I would like your opinion on the following questions: Is there any current Federal Standard to which gas tank caps must conform? If so, how is such compliance established? Must the gas tank cap bear any symbols mentioning this compliance? If so, please be specific. Thank you for your valuable time. Richard Kuskin, President |
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.