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: aiam5016OpenThe Honorable John J. Duncan, Jr. House of Representatives Washington, DC 20515-4202; The Honorable John J. Duncan Jr. House of Representatives Washington DC 20515-4202; Dear Mr. Duncan: Thank you for your letter enclosing correspondenc from your constituent, Mr. Clarence Lowe, an instructor for Campbell County Comprehensive High School, concerning the use of 15-passenger vans to transport school children. Campbell County has been informed by the Tennessee State Department of Education that vans cannot be used to transport children to school or school-related events. In light of school budget constraints, Mr. Lowe would like to use these vehicles for transporting students to off-campus vocational programs. Your letter also enclosed a letter from Ernest Farmer, Tennessee Director of Pupil Transportation, explaining why the State of Tennessee has instructed schools not to use vans to transport school children. I am pleased to have this opportunity to clarify Federal law as it relates to school buses. The National Highway Traffic Safety Administration (NHTSA) has the authority under the National Traffic and Motor Vehicle Safety Act to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles, in order to reduce the number of fatalities and injuries that result from motor vehicle crashes. Under NHTSA's regulations, vans are generally classified as either multipurpose passenger vehicles (MPV's) or buses. The MPV category includes vans which carry 10 persons or less, vans which carry more than 10 persons are buses. Thus, the 15-passenger vans referred to by Mr. Lowe are classified as buses. Under the agency's definitions, a 'school bus' is a type of bus sold for transporting students to and from school or school-related events. All MPV's and buses are required to meet Federal motor vehicle safety standards. However, in the legislative history of the School Bus Safety Amendments of 1974, Congress stated that school transportation should be held to the highest level of safety. Accordingly, NHTSA has issued special Federal motor vehicle safety standards applicable to all new school buses. Like all safety standards, NHTSA's school bus standards impose obligations on the manufacturers and sellers of new motor vehicles, not upon the subsequent users of these vehicles. It is a violation of Federal law for any person to sell any new vehicle that does not comply with all school bus safety standards if the vehicle capacity is more than 10 persons, and if the seller is aware that the purchaser intends to use the vehicle as a school bus. On the other hand, without violating any provision of Federal law, a school may use a vehicle which does not comply with Federal school bus regulations to transport school children. This is so because the individual States, not the Federal government, have authority over the use of vehicles. However, I would like to call your attention to a guideline that NHTSA has issued under the authority of the Highway Safety Act of 1966. That Act authorizes the agency to issue guidelines for states to use in developing their highway safety programs. NHTSA issued Highway Safety Program Guideline 17, Pupil Transportation Safety, to provide recommendations to the states on various operational aspects of their school bus and pupil transportation safety programs. Guideline 17 recommends that any vehicle designed for carrying more than 10 persons which is used as a school bus comply with all safety standards applicable to school buses at the time the vehicle was manufactured. In conclusion, it is not a violation of Federal law for Campbell County to use its 15-passenger vans for transportation of school children, however, use of these vehicles may be restricted by Tennessee law. I must emphasize NHTSA's position that a vehicle meeting Federal school bus regulations is the safest way to transport students. Despite the additional cost of these vehicles, I encourage Campbell County to give its most careful consideration to the possible consequences of transporting students in vehicles that do not comply with these regulations. I hope this information is helpful. Sincerely, Jerry Ralph Curry; |
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ID: aiam3068OpenMr. G. Frinken, Manager, Automotive Engineering Europe, Uniroyal European Tire Development Center, Uniroyal GMBH, Postfach 410, 5100 Aachen 1, West Germany; Mr. G. Frinken Manager Automotive Engineering Europe Uniroyal European Tire Development Center Uniroyal GMBH Postfach 410 5100 Aachen 1 West Germany; Dear Mr. Frinken: This is in response to your letter of July 20, 1979, concerning th Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104). You ask whether it is permissible under the regulation to mold UTQG grades on only one sidewall of a tire and, in the case of a symmetrical black sidewall tire, whether the grades may be molded on the same sidewall as the tire identification number required by 49 CFR 574.5.; The UTQG Standards require that tire grades need be molded on only on sidewall of a tire. Since the regulation presently does not specify the sidewall on which tire grades must be molded, Uniroyal is legally permitted to mold UTQG grades on either sidewall of its tires. However, in order to facilitate consumer access to the grading information, the National Highway Traffic Safety Administration (NHTSA) encourages manufacturers to mold tire grades on the sidewall intended to be visible when the tire is mounted on a vehicle. NHTSA will monitor the placement of tire grades to determine whether further action is necessary to assure the accessibility of the grading information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1055OpenMr. Elmer A. Brown, Registrar, Department of Motor Vehicles, P.O. Box 1319, Sacramento, CA 95806; Mr. Elmer A. Brown Registrar Department of Motor Vehicles P.O. Box 1319 Sacramento CA 95806; Dear Mr. Brown: This is in response to your letter of March 12, 1973, concerning th compliance of a proposed California form with the Federal Odometer Disclosure Requirements, 49 CFR Part 580.; The use of a combination form such as that proposed is acceptable s long as it contains the information required in Part 580. We have reviewed the proposed form and find that it complies with Part 580.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3592OpenMr. Masakatsu Kano, Executive Vice President, MMC Services Inc., 3000 Town Center, Suite 1960, Southfield, MI 48075; Mr. Masakatsu Kano Executive Vice President MMC Services Inc. 3000 Town Center Suite 1960 Southfield MI 48075; Dear Mr. Kano: This responds to your letter of July 15, 1982, concerning th application of Standard No. 201, *Occupant Protection in Interior Impact*, to a passenger 'assist grip' provided in your vehicles. You asked whether the instrument panel impact test of the standard must be conducted both with and without the passenger grip mounted on the instrument panel.; The head impact test should be conducted with the passenger 'assis grip' mounted in place. It should not be necessary to test the panel with the grip removed. Section 5.3.1 of the Standard provides that if an area of the instrument panel is within the head impact zone, it must meet the performance requirements of the standard. In using the term 'instrument panel', the agency intended to include the basic panel and any integral design features of the panel. Your engineering drawing shows that the grip is solidly mounted on top of the panel as an integral part. You state that the grip is a standard design feature on all the vehicles you intend to manufacture. Because the grip is a standard design feature which is securely affixed to the instrument panel, the agency considers it an integral part of the panel. Thus, the performance requirements of the standard would be applicable with the grip mounted in place.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4257OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of November 21, 1986, with reference t the distance between a front turn signal lamp and a lower beam headlamp.; In brief, SAE Standard J588e, incorporated by reference in Standard No 108 requires a minimum separation distance of 4 inches between the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the lower beam headlamp. You have pointed out that a replaceable bulb headlamp does not have a retaining ring, and you have presented two possible substitutes as a measuring point. The first (your Item A) is the outer edge of the headlamp, and the second (your Item B) is the end of the effective area of the reflector. You believe that Item B is the more appropriate.; We concur with your interpretation. Of the two options, the distance t the edge of the effective area of the reflector is the one most similar to the inside diameter of the retaining ring of the lower beam headlamp. The basis for this interpretation is the assumption that the headlamp lens between the outer edge of the headlamp and the edge of the effective area of the reflector is not used for production of the lamp's beam, has no significant luminance, and therefore will not mask the turn signal.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3438OpenMr. R. W. Cheetham, Director of Quality Assurance, The Armstrong Rubber Company, 500 Sargent Drive, New Haven, CT 06507; Mr. R. W. Cheetham Director of Quality Assurance The Armstrong Rubber Company 500 Sargent Drive New Haven CT 06507; Dear Mr. Cheetham: This responds to your recent request for an interpretation of th labeling requirements of Safety Standard No. 119 (49 CFR S571.119). Specifically you asked if the requirements of section S6.5(f), requiring the tire label to show the actual number of plies, and the composition of the ply cord material would be satisfied by the Marking:; >>>'Tread - 2 plies Polyester + 2 Aramid Woven Belts Sidewall - 2 plies Polyester.' <<< It has been a longstanding policy of this agency not to issue advanc approval of labeling information. However, we will state that marking appears to satisfy the requirements of section S6.5(f) if it is slightly modified. Specifically, the reference to 'belts' should be deleted, and the word 'plies' should be substituted.; The purpose of the marking requirements in Standard No. 119 is t ensure that the user of the tire is provided with technical information in a straightforward manner. This information is necessary for the safe use of the tire. Section S6.5(f) of the Standard requires that the marking include only the actual number of *plies* and the composition of the *ply* cord material. To satisfy this requirement, the information for the tread should appear as: 'Tread - 2 plies Polyester + 2 plies Woven Aramid.'; Your desire to represent the ply cords as belts probably represents marketing effort by Armstrong to convince purchasers to buy this particular tire. This agency has no reason to believe that these tires are not outstanding performance tires or to reduce your marketing efforts. However, it is inappropriate to extend this marketing effort to the Federally required markings on the sidewall of the tires.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1405OpenJames B. Steward, Esq., Bridges and Collins, Bridges Building, 701 Teal Lake Avenue, Negaunee, MI 49866; James B. Steward Esq. Bridges and Collins Bridges Building 701 Teal Lake Avenue Negaunee MI 49866; Dear Mr. Steward: In reply to your request of January 30, 1974, I am enclosing a copy o the regulation issued to implement the odometer disclosure requirements of Public Law 92.513.; Although there are a variety of ways to determine whether a vehicle' actual mileage is greater than shown on the odometer, I know of only one method to establish the exact amount by which the indicated mileage has been exceeded: the testimony of a witness who knew the exact mileage on the car at the time the odometer was changed and who knows the accuracy of the odometer's performance after the change.; I would be most interested to learn of the progress of your action. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4607OpenM. Iwase, General Manager Technical Information Dept. Koito Mfg. Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan; M. Iwase General Manager Technical Information Dept. Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimizu-shi Shizuoka-ken Japan; Dear Mr. Iwase: This is in reply to your letter of March 20, l989 asking for an interpretation of Motor Vehicle Safety Standard No. l08 as it applies to the location of the license plate lamp on motor vehicles. You noted the language in Tables II and IV of Standard No. l08 specifying that the lamp is to be located 'at rear license plate, to illuminate the plate from the top or sides,' for vehicles other than motorcycles. The requirement for motorcycles (Table IV) is simply that it be located 'at rear license plate.' You have asked for confirmation that, except on motorcycles, the license plate lamp shall not illuminate the plate from the bottom. Your interpretation is correct. The rationale for the requirement is that in a location other than at the bottom, the license plate lamp is less likely to be obstructed by snow or mud. I hope that this answers your question. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam4312OpenMr. Robert R. Shapro, Vice President, Transportation Specialist, Inc., 512 Cave Road, Nashville, TN 37210; Mr. Robert R. Shapro Vice President Transportation Specialist Inc. 512 Cave Road Nashville TN 37210; Dear Mr. Shapro: This list responds to your request for 'the fact sheet concernin certification as required' by 49 CFR Parts 567 and 568. You describe your company as a 'multistage manufacturer,' and ask how your company can become certified 'to manufacture or alter vehicles in accordance with the code of Federal regulation.' I regret the delay in responding to your request.; First, please be aware that the National Highway Traffic Safet Administration (NHTSA) has authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. The NHTSA does not approve vehicles or equipment, nor do we endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a certification process under which each manufacturer must certify that its product meets agency safety standards, or other applicable standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; As you request, I enclose a copy of 49 CFR Part 567, *Certification* and Part 568, *Vehicles Manufactured in Two or More Stages*. Also, for your information, I enclose an information sheet that may be of interest to you if you are new to motor vehicle and motor vehicle equipment manufacture.; Please note that there is no requirement that a company be 'certified before it can manufacture or alter vehicles. 49 CFR Part 566 does require that if a company begins to manufacture motor vehicles subject to any of the Federal safety standards, it must submit information identifying itself and its products to NHTSA not later than 30 days after it begins manufacture.; I hope you find this information helpful. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1110OpenMr. William Eriksen, Anderson-Alford, Seventh at D Streets, P.O. Box AA, Eureka, CA; Mr. William Eriksen Anderson-Alford Seventh at D Streets P.O. Box AA Eureka CA; Dear Mr. Eriksen: This is in reply to your letter of April 3, 1973, inquiring whethe there are licenses and forms that you must obtain before you may install old truck bodies on new trucks.; Persons who install used truck bodies on new trucks are generall considered to be 'final-stage manufacturers' under NHTSA Certification regulations (49 CFR 567, 568). These regulations require final-stage manufacturers of multi-stage vehicles to certify the conformity of such vehicles to all applicable motor vehicle safety standards. Certification is accomplished by affixing a label to the vehicle. The requirements for both the location and content of the label are contained in the Certification regulations, and you may obtain copies of these regulations as indicated on the enclosed, 'Where to Obtain Motor Vehicle Safety Standards and Regulations'.; There are no licensing requirements, nor specified forms you mus complete before you undertake these manufacturing operations. However, the NHTSA does have requirements, (Part 566, 'Manufacturer Identification', copy enclosed) that require you to submit certain information regarding your company within 30 days after commencing manufacture.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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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.