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: aiam2970OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your February 28, 1979, letter asking about th remanufacturing of vehicles using old chassis and new bodies. In particular, you ask whether these vehicles must comply with the new safety standards.; The remanufacturing operation that you mention need not comply with th new safety standards. Such a remanufactured vehicle may need to comply with the safety standards in effect on the date of manufacture of the used chassis. Otherwise, there might be a rendering inoperative of the compliance of the vehicle with the safety standards. I am enclosing a copy of an interpretation that discusses the remanufacturing issue.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3911OpenMr. M. Iwase, Manager, Technical Administration Dept., Koito Manufacturing Co., Ltd., Shizuoka Works, 500, Kitawaki, Shimizu- shi, Shizuoka-ken, Japan; 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 t 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 tw 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 singl 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, Jeffrey R. Miller, Chief Counsel |
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ID: aiam3032OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your May 21, 1979, letter confirming your discussion with Roger Tilton of my staff relating to the emergency exit requirements of school buses that are constructed with an additional exit door. The additional door is installed so that the vehicle can be better used as a general transit vehicle when not in use for school purposes.; The statements that you make in your letter are, for the most part accurate. However, your third statement which indicates that the additional door could not be marked as an emergency exit is not entirely accurate. Additional emergency exits in school buses, beyond those required by Standard No. 217, *Bus Window Retention and Release*, must comply with the emergency exit requirements applicable to exits in non-school buses. If the door to which you refer is not designed or constructed as an emergency exit but rather is designed as an additional door for the routine loading and unloading of passengers, it need not be labeled as an emergency exit. If on the other hand the door is intended as an emergency exit and is constructed in accordance with the emergency exit requirements for doors in non-school buses, it should be labeled as an emergency exit in accordance with the labeling requirements for exits in non-school buses.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2659OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds t your August 19, 1977, letter asking whether Standar 217, *Bus Window Retention and Release*, allows the identification of the rear emergency door located anywhere on the top half of the door.; The standard in S5.5.3 requires the emergency door identification to b located at the top of or directly above the emergency exit....' The National Highway Traffic Safety Administration interprets this requirement to mean that the emergency door label must be located on the top half of the door or directly above the door. The label location as depicted in the picture you enclosed with your letter appears to comply with the requirements of S5.5.3.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0324OpenLawrence D. Heitsch, Darden, Neef & Heitsch, Attorneys and Counselors, 3066 Penobscot Building, Detroit, MI 48226; Lawrence D. Heitsch Darden Neef & Heitsch Attorneys and Counselors 3066 Penobscot Building Detroit MI 48226; Dear Mr. Heitsch: This is in response to your letter of January 20, 1971, petitioning fo rulemaking pursuant to 49 CFR 553.31, asking that the Tire Identification and Record Keeping Regulation be inapplicable to mobile homes. The points raised in your petition have been thoroughly considered, however, your petition, by copy of this letter, is denied. As you know, many of the points you raised were considered in connection with the interpretation of 'Motor Vehicle' as it refers to trailers, issued March 31, 1970 (35 F.R. 5333) (Copy Enclosed). The interpretation concluded that a mobile home is a motor vehicle within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966, (15 U.S.C. 1381 *et seq*.). As such, mobile home manufacturers are required to comply with the requirements of Part 574,(sic); The burden placed on the mobile home manufacturer by the regulatio does notaappear (sic) unreasonable. The regulation requires that the vehicle manufacturer or his designee maintain a record of the tires shipped on or in its vehicles and maintain the names and addresses of the purchasers of its vehicles. Locating the purchaser should be a comparatively easy task.; Mobile homes are constructed with a view, of course, to thei over-the-road capabilities. The Tire Identification and Record Keeping Regulation should be applicable to mobile homes since it relates directly to one of the instrumentalities for moving a mobile home. Should a tire sold with a mobile home be defective, we consider it essential that the purchaser of the vehicle be notified of this fact.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3576OpenMr. Arnold P. Fuchs, 68 Roslyn Road, Grosse Pointe Shores, MI 48236; Mr. Arnold P. Fuchs 68 Roslyn Road Grosse Pointe Shores MI 48236; Dear Mr. Fuchs: This letter is to confirm your view, expressed in a telephone call wit Edward Glancy of this office, that the requirements of Standard No. 206, *Door Locks and Door Retention Components*, are not applicable to a replacement latch for a truck built in 1969.; The requirements of Standard No. 206 are applicable to passenger cars multipurpose passenger vehicles and trucks. See S2 of that Standard. However, its requirements are not applicable to replacement parts for installation in used vehicles of these types.; Further, the 'render inoperative' provisions of the National Traffi and Motor Vehicle Safety Act are not relevant to the installation of such a latch. Under section 108(a)(2)(A) of that Act, a business such as a garage must make sure that it does not knowingly render inoperative the compliance of a vehicle with any applicable safety standard. With respect to a 1969 truck and Standard No. 206, there is no compliance which could be rendered inoperative since the Standard was never applicable to that truck. That Standard applies only to trucks manufactured on or after January 1, 1972.; I would note that even in the absence of an applicable safety standard the defect provisions of the Act may be applicable. Sections 151 *et seq*. of the Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3461OpenMr. Brian Gill, Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, 100 W. Alondra Blvd., Gardena, California 90247; Mr. Brian Gill Manager Certification Department American Honda Motor Co. Inc. P.O. Box 50 100 W. Alondra Blvd. Gardena California 90247; Dear Mr. Gill: This responds to your letter of July 27, 1981, asking about Federa Motor Vehicle Safety Standard No. 101-80. Your letter asked whether an enclosed sample of a heater control identification plate met the requirements of section S5.2.2 of the standard. Your letter was primarily concerned about whether the color used for the hot extreme would be considered 'red' within the meaning of that section.; The sample heater control identification plate enclosed with you letter identifies the hot an cold extremes of the temperature control by both words and color. At the left of the identification plate is the word 'cold' on a blue background. At the right of the identification plate is the word 'hot' on a background that appears by visual inspection to be orange.; Section S5.2.2 of Standard No. 101-80 states: >>>Identification shall be provided for each function of any automati vehicle speed system control an any heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range. If this identification is not specified in Tables 1 or 2, it *shall be in word form unless color coding is used*. If color coding is used to identify the extreme positions of a temperature control, the hot extreme shall be identified by the color red and the cold extreme by the color blue . . . . [Emphasis added.]<<<; The agency interprets section S5.2.2 to require that the colors red an blue be used to identify the extreme positions of a temperature control only when color is the sole means by which the extreme positions are identified. If the words 'hot' and 'cold' are used to identify the extreme positions, color coding is a voluntary addition and the red and blue color requirements of section S5.2.2 do not apply.; Therefore, since the sample of the heater control identification plat enclosed with your letter identifies the extreme positions of the temperature control with the words 'hot' and 'cold,' it meets the requirements of section S5.2.2 concerning that requirement regardless of whether the color used for the hot extreme would be considered 'red' within the meaning of that section.; As to your question whether the color used for the hot extreme on th sample of the heater control identification plate is red, our visual inspection indicates that the color is orange rather than red. For guidance on the meaning of the color 'red,' we suggest that you refer to 49 CFR S172.407(d). That section, which is part of the Departments of Transportation's regulations concerning hazardous materials, establishes color tolerances for various colors, including red. The section indicates how to obtain copies of the Department's color tolerance charts or where they may be inspected. While the charts are not referenced by Standard No 101-80, they do provide guidance on the tolerances of various colors.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2645OpenMr. James Tydings, Specifications Engineer, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Specifications Engineer Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your August 31, 1977, letter asking whether a New Yor state requirement mandating the installation of both side emergency doors and rear emergency doors in school buses would mean that both emergency doors would be required to comply with the school bus exit specifications in Standard No. 217, *Bus Window Retention and Release*.; The NHTSA has determined previously that only those exits required b S5.2.3 must meet the requirement specified for school bus emergency exits in Standard No. 217. Paragraph S5.2.3 requires either a rear emergency door or a side emergency door and a rear push out window. The side emergency door to which you refer is installed in addition to a rear emergency door. The presence of the rear emergency door, alone, satisfies the requirements of S5.2.3. Therefore, a side emergency door is not required by the standard and need not meet the specifications for school bus emergency exits. Emergency exits installed in school buses beyond those required in S5.2.3 must comply with regulations applicable to emergency exits in buses other than school buses. These requirements are also detailed in Standard No. 217.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5310OpenMr. Joe Miller Product Support Manager Load King Box 427 Elk Point, SD 57025; Mr. Joe Miller Product Support Manager Load King Box 427 Elk Point SD 57025; Dear Mr. Miller: This is in response to your FAX of December 10, 1993 You have informed us that Load King manufactures trailers, selling them to a dealer in Minneapolis who, in turn, sells these trailers to customers/users. You would like the dealer 'to do some finish manufacturing for us.' Specifically, you would like the dealer 'to paint the trailers, install operational decals and place the conspicuity striping.' You ask whether 'primed trailers can be moved without conspicuity striping in this case.' The answer is no. Under the National Traffic and Motor Vehicle Safety Act and its regulations, when a completed motor vehicle is delivered to its dealer, it must be certified as conforming to all applicable Federal motor vehicle safety standards, and it must, in fact, comply with all such standards at the time of delivery. Thus, your trailers are required to be equipped with the conspicuity treatment at the time of shipment since the treatment is a requirement of Motor Vehicle Safety Standard No. 108. The Minneapolis dealer, however, may apply paint and decals since this is not required under Standard No. 108 or any other regulation. Were the trailer one that is manufactured in more than one stage, our regulations would permit the final stage manufacturer to apply the conspicuity treatment since that manufacturer is required to affix the necessary certification of compliance with all standards upon completion of the final stage of manufacture. However, painting and application of the conspicuity treatment are regarded as minor finishing operations that do not rise to the level of being a separate stage of manufacturing, and this exception is not available under the facts that have been presented to us. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1612OpenMr. Mike A. Read,Design Engineer, Spring Division,Borg-Warner Corporation,700 South 25th Avenue,Bellwood, Illinois 60104; Mr. Mike A. Read Design Engineer Spring Division Borg-Warner Corporation 700 South 25th Avenue Bellwood Illinois 60104; Dear Mr. Read:#This is in reply to your letter of September 13, 1974 pointing out discrepancies between our two standards covering motor vehicle hydraulic brake systems, Nos. 105-75 and 122.#We intend to amend Standard No. 122 in the near future to be consistent with Standard No. 105-75.This will clarify that the same interpretation will be given master cylinder reservoir and capacity requirements.#Thank you for pointing this out to us. #Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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.