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 |
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ID: nht90-1.61OpenTYPE: INTERPRETATION-NHTSA DATE: MARCH 5, 1990 FROM: R. W. SCHREYER -- SR. SALES ENGINEER, TRANSPORTATION MANUFACTURING CORP. TO: HARRY THOMPSON -- U.S. DEPARTMENT OF TRANSPORTATION, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO R. W. SCHREYER FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 12-11-89 TO FRANK BERNDT FROM JOE DABROWSKI, LETTER DATED 3-22-89 TO KEITH A. MCDOWELL FROM ERIKA Z. JONES, AND LETTER DATED 3-25-77 TO ROBERT B. KURRE, WAYNE CORPORATION, FROM FRANK BERNDT. TEXT: Mr. Max Montgomery (State of Nevada, Dept. of Prisons) will, be procuring some prison coaches. He will be specing a Type I lap belt for passengers. Since there is no Federal Safety Standard requiring this, can you provide direction on what course of ac tion we should take. (i.e. Do we design to FMVSS Section 571.210?) Also, please clarify test procedure in Section 571.210. Do all seats in the coach have to be tested simultaneously or can a single seat be tested at one time? If you have any questions, please give me a call at (505) 347-2011 extension 7511. Thank you. |
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ID: nht90-2.14OpenTYPE: INTERPRETATION-NHTSA DATE: April 10, 1990 FROM: Lawrence A. Beyer -- Attorney for Petitioner TO: Z. Taylor Vinson; Stephen P. Wood -- Acting Chief Counsel, NHTSA TITLE: Request for ruling submitted on behalf of Cantab Motors ATTACHMT: Attached to letter dated 7-11-90 to Lawrence A. Beyer from Paul J. Rice; (A35; Part 591) TEXT: This letter requests official notification by DOT that Cantab Motors is considered to be a manufacturer by your agency. We have filed the required documents several months ago. As you may recall, Cantab Motors imports Morgan built non-functional vehicles as parts, which do not have a functional fuel delivery or storage system. Cantab manufactures a propane system for these and completes the compliance with all applicable FMVSS on each vehicle. Please be reminded that ISIS Motors received such an opinion letter from your office on July 10, 1986 (Addressed to their counsel B. Lew). We would appreciate it if we could receive a similar letter. Please process the request for exemption as soon as possible, since my client cannot remain in business without having vehicles to sell. |
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ID: 1985-01.49OpenTYPE: INTERPRETATION-NHTSA DATE: 03/15/85 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Mr. M. Iwase TITLE: FMVSS INTERPRETATION TEXT:
March 15, 1985 Mr. M. Iwase Manager, Technical Administration Dept. Koito Manufacturing Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan Dear Mr. Iwase: This is in reply to your letter of February 1, 1985, with reference to the compliance with Motor Vehicle Safety Standard No. 108 of a proposed motorcycle headlamp design. In the design shown in your letter a single housing would contain two dual-filament bulbs, each with an independently aimed reflector. You have stated that the headlamp can comply with the photometric requirements of Sae J584 when either compartment is lit, and that the assembly will meet all other requirements of J584. A dual bulb arrangement in a single housing is considered a single headlamp, and therefore its compliance will be judged when both compartments are lit to provide either the upper or lower beam. Assuming that when both compartments are lit the combined candlepower at individual test points does not exceed the maxima imposed by J584 for those test points, your design appears to comply with Standard No. 108. Sincerely, Original Signed By Jeffrey R. Miller Chief Counsel |
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ID: nht87-2.80OpenTYPE: INTERPRETATION-NHTSA DATE: 08/28/87 FROM: S. T. MESSINA, -- NJ DEPT OF TRANSPORTATION TO: TERRY K. BROCK -- COONS MANUFACTURING INC. TITLE: COONS MANUFACTURING INC. DIAMOND VIP BUS 25 PASSENGER MC 157-87 ATTACHMT: ATTACHED TO LETTER DATED 06/30/88 FROM ERIKA Z JONES TO TERRY K BROCK; RED BOOK A32, STANDARD 217; LETTER DATED 09/09/87 FROM TERRY K. BROCK TO STEVE KRATZKE RE CLARIFICATION OF FMVSS CODE 217, OCC-1009; LETTER DATED 08/20/87 FROM TERRY K. BROC K TO SEBASTIAN MESSINA TEXT: Dear Mr. Brock, This is in reply to your letter of August 20, 1987 pertaining to emergency escape areas. Parts 393.61, 393.62 and 393.63 of the Federal Motor Carrier Safety Regulations require that emergency exits comply with Federal Motor Vehicle Safety Standard 217. The escape areas are to be through windows of a push out type. The ordinary opening o f a window for ventilation should not be included due to possible jamming. The front entrance door cannot be considered since the intent of the regulations is to provide emergency escape through push out windows and roof escape hatches. I hope that we have been of assistance. |
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ID: nht76-2.50OpenDATE: 02/09/76 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Gillig Brothers School Bus Co. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your request for information concerning methods of ensuring the compliance of school buses with the barrier crash test requirements of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity. Standard No. 301-75, while establishing minimum performance levels, does not specify any particular design requirements for school bus fuel systems. A manufacturer is free to design his vehicles in the manner that he believes most appropriate to ensure compliance. To this end, you may find helpful information in a study by Dynamic Science entitled School Bus Safety Improvement Program. The NHTSA cannot assure you, however, that following the suggestions contained in the study will guarantee that your school buses will comply with the standard. The study is filed in the NHTSA's public docket as document number 75-03-GR1. Copies may be obtained by writing to: Technical Reference Branch National Highway Traffic Safety Administration Room 5108 400 Seventh Street, S.W. Washington, D.C. 20590 You should refer to the following publication numbers: HS 801-615, -616, and -617. |
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ID: 1985-03.40OpenTYPE: INTERPRETATION-NHTSA DATE: 09/06/85 FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA TO: Mr. T. Chikada TITLE: FMVSS INTERPRETATION TEXT:
September 6, 1985 Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13, Nakamegura, Meguro-Ku Tokyo 153, Japan Dear Mr. Chikada: This is in response to your letter of June 27, 1985, to the former Chief Counsel of this agency, Frank Berndt, asking for an interpretation regarding Figure 4-1 of Motor Vehicle Safety Standard No. 108. With reference to a two-lamp system headlamp with two reflectors, you have asked which of three specified Points should be regarded as the "center of aiming pattern" within the meaning of Figure 4-1. The answer is Point B, of the center of the bulb for the lower beam. NHTSA provided a clarification of this in the final rule permitting two-bulb replaceable bulb headlighting systems, published on May 22, 1985. I enclose a copy for your information. In it, the agency remarked that "NHTSA expects the aiming pads to be located on the optical axis of the lower beam portion of the headlamp when only one light source is used for the lower beam." Sincerely, Original Signed By Jeffrey R. Miller Chief Counsel Enclosure |
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ID: 86-2.21OpenTYPE: INTERPRETATION-NHTSA DATE: 04/15/86 FROM: FRANCISCO DEETAN -- FRG INDUSTRIAL CORPORATION TO: NHTSA TITLE: HS 7 FORM APPLICATION APPROVAL FOR REAR WINDOW 3RD STOP LIGHT ATTACHMT: ATTACHED TO LETTER DATED 07/23/86 EST, TO FRANCISCO DEETAN FROM ERIKA Z. JONES, REDBOOK A29(3); STANDARD 108 TEXT: Dear Sirs, Concerning our importation of rear window 3rd stop light which meets requirement for a high mounted brake light: Our company have prepared a trial order for more or less Three Thousand Dollars worth of rear window 3rd stop light importation, but before the letter of credit is opened we would like to get your approval for the products we will import, So, please inform and assist us in getting your HS-7 permit in compliance with FMVSS 108 requirement; Enclosed is our brochure and proform invoice copy from our supplier aboard, in case your good office need the sample test of the rear window 3rd stop light which we wish to import, please urgent inform us and indicate whom we should send it to, we will send you a sample immediately upon we receive you advise. Thank you in advance for you kind co-operation, we remain, Very Truly Yours, |
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ID: nht81-2.39OpenDATE: 06/25/81 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Japan Automobile Tire Manufacturers Association, Inc. TITLE: FMVSS INTERPRETATION TEXT: This responds to your recent request for an interpretation of the labeling requirements of Safety Standard No. 109 (49 CFR @ 571.109). Specifically, your association wants to know if Standard 109 permits tire manufacturers to include the letters "H," "S," or "V," as appropriate, in the tire size designation required to appear on the sidewall of passenger car tires by S4.3(a) of the Standard. Such labeling is permitted by Standard 109. The speed rating symbols ("H," "S," or "V") established by the European Tyre and Rim Technical Organization, indicate that a tire is an acceptable high-speed tire. This permits, for example, a knowledgeable purchaser of tires for emergency vehicles to know that these tires are suitable for the higher operational speeds necessary for those vehicles. Use of these symbols in the size designation would not likely confuse the less sophisticated consumer, or otherwise defeat the purpose of the labeling information. Accordingly, use of these symbols is permitted under Standard 109. If you have any further questions, or need further information on this matter, please feel free to contact Steve Kratzke of my staff (202-426-2992). |
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ID: nht80-1.7OpenDATE: 01/25/80 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Grumman Flexible Corp. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. In a telephone conversation with Ms. Debra Weiner of my office, you asked whether section S5.2.2 of the standard would apply to the windshield wiper controls which Grumman Flexible intends to install in its transit buses. As I understand your description, there are to be separate controls for the left and right windshield wipers and each control will allow for operation of the wiper over a continuous range of speeds. The answer to your question is no. Section S5.2.2 of Standard 101-80 provides that: Identification shall be provided for each function of any automatic vehicle speed system control and any heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range. (emphasis added). The function identification requirements are not applicable since their applicability is expressly limited to speed controls and to heating and air conditioning controls. The applicability of the extreme position identification requirements is similarly limited since "such controls" refers back to those controls already identified in S5.2.2. |
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ID: nht73-6.14OpenDATE: 04/10/73 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Robins Davis & Lyons TITLE: FMVSS INTERPRETATION TEXT: (Ilegible Text) ROBINS. DAVIS & LYONS March 16, 1973 United States Department of Transportation Federal Highway Administration National Highway Safety Bureau Washington, D. C. Attn: Office of Performance Analysis Re: Roste v Ford Our File: S72-0534 Gentlemen: Our office represents a woman who was badly burned in an automobile accident when the Ford Cortina, in which she was a passenger, exploded upon rear-end impact with another automobile. I am interested in knowing whether or not there have been promulgated any Federal standards or regulations pertaining to the safety of gasoline tanks, appurtenances thereto, fuel tank filler hoses and connections, or the need for a protective fire wall between the fuel tank compartment and the rear of the automobile. If you can refer me to any information pertaining to these questions or send to me copies of the appropriate data, I would be most appreciative. We will, of course, reimburse you for any costs incurred. Thank you. Very truly yours, John F. Eisberg |
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.