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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| search results table | |
ID: aiam3403OpenMr. James E. Gregory, Gregory Equipment & Manufacturing Co., 1314 17th Street, Fort Madison, IA 52627; Mr. James E. Gregory Gregory Equipment & Manufacturing Co. 1314 17th Street Fort Madison IA 52627; Dear Mr. Gregory: This is in reply to your letter of April 13, 1981, with respect t placement of identification lamps on the boat trailer you wish to manufacture.; You have informed us that the trailers are not built for transportin boats on the highways and your sales sheet reiterates that point: 'These trailers are for in marina use only. Not for over the road use.' Under the National Traffic and Motor Vehicle Safety Act, a vehicle that is not manufactured primarily for use on the public roads is not a vehicle subject to our regulations. From your letter and advertising enclosure, it appears that your intent is to build a vehicle that will be used primarily on private property. Therefore, our lighting requirements would not apply to it.; I hope that this answers your question. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1449OpenMr. R.O. Sornson,Manager,Environmental and Safety Relations, Chrysler Corporation,Detroit, Michigan 48231; Mr. R.O. Sornson Manager Environmental and Safety Relations Chrysler Corporation Detroit Michigan 48231; Dear Mr. Sornson:#This is in response to your March 13, 1974, reques for confirmation that the intake manifold connector and the brake booster check valve used in connecting the engine intake manifold and the vacuum power brake booster are not subject to Standard No. 106, *Brake hoses*.#A brake hose and fitting is defined in Standard 106 as 'a coupler other than a clamp, designed for attachment to the end of a brake hose.' As pictured in your schematic, the couplers are the clamps, and the intake manifold connection and brake booster check valve are engine components to which the brake hose has been attached by clamp couplers. Therefore your interpretation is correct that neither component is subject to Standard 106.#Sincerely,Lawrence R. Schneider,Chief Counsel; |
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ID: aiam3474OpenMr. T. Takano, Chief of Development Dept., Meiji Rubber & Chemical co., Ltd., Kojima Building, 10-2, Nishishinjuku, 1-Chome, Shinjuku-Ku, Tokyo, Japan; Mr. T. Takano Chief of Development Dept. Meiji Rubber & Chemical co. Ltd. Kojima Building 10-2 Nishishinjuku 1-Chome Shinjuku-Ku Tokyo Japan; Dear Mr. Takano: This responds to your recent letter regarding the use of flexible nylo tubes in vacuum braking systems. You ask whether such plastic hoses would qualify as 'vacuum tubing connectors' for purposes of Safety Standard No. 106, *Brake Hoses*.; We recently received a letter asking this identical question from Toka Rubber Industries of Japan. I am enclosing a copy of that letter for your information. I believe that it will answer all of your questions. You will see from the letter that these nylon tubes cannot qualify as 'vacuum tubing connectors' and must comply with the requirements of Safety Standard No. 106.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1019OpenMr. W. S. Magenau, President, Chesapeake Marine Products, Route 456, Deale, MD 20751; Mr. W. S. Magenau President Chesapeake Marine Products Route 456 Deale MD 20751; Dear Mr. Magenau: This is in response to your letter of February 5, 1973, in which yo suggested, with reference to a previous interpretation, that boat trailer assemblers be allowed to use the 'altering distributor' certification of 49 CFR S 567.6, rather than certifying the vehicle as the manufacturer under S 567.4.; The altering distributor label was not designed to deal with assembler of vehicles, but with persons who alter vehicles that have already been completed and assembled. A basic prerequisite to its use is that there be a vehicle that already has been certified. I take it that your suggestion really amounts to requiring the supplier of the unassembled parts to certify the vehicle.; We are unwilling to do this on the basis of our present information. I is true that a boat trailer is among the simplest vehicles on the road, but considering vehicles generally, we must consider a vehicle as a functioning whole, not as a group of parts. There may easily be problems caused by the way in which it is assembled, and we do not consider it reasonable to require a manufacturer of parts, against his will, to take responsibility for the final assembly. Although it is conceivable that such a scheme could work with very simple vehicles, it certainly could cause large problems with more complex ones.; We permit the unassembled parts manufacturer to certify if he wishes Furthermore, the person who assembles the vehicle can require a written commercial warranty that the vehicle will conform if properly assembled, which will protect him in certifying the vehicle. I recommend one of these courses of action as a matter of good business practice.; If the unassembled parts manufacturer does certify the package i accordance with S 567.4(g)(1)(ii), then it would be permissible for a distributor to use S 567.6 where he deviates from the certifier's instructions.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3024OpenMr. Myles Robert Lee, P.O. Box 1344, Gloucester, MA 01930; Mr. Myles Robert Lee P.O. Box 1344 Gloucester MA 01930; Dear Mr. Lee: This responds to your May 12, 1979, letter asking how to determine th correct date of manufacture of your motor home. You indicate that the chassis was constructed in 1977 and the body in 1978. The manufacturer apparently classified the vehicle as a 1978 model.; The National Highway Traffic Safety Administration has a regulatio governing the date of manufacture of vehicles for the application of safety standards. Part 568, *Vehicles Manufactured in Two or More Stages*, of our regulations states that a manufacturer may choose as the date of manufacture of a vehicle the date of manufacture of the chassis, the date of manufacture of the completed vehicle, or any date between those two dates. However, the vehicle must comply with all of the applicable safety standards in effect on the chosen date. Since the body of your vehicle was manufactured in 1978, we assume that the vehicle was completed in 1978. Therefore, the manufacture could legally call your vehicle a 1978 model, at least for the purposes of our safety program.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2265OpenMr. Naoyoshi Suzuki, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Naoyoshi Suzuki Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Suzuki: This responds to your March 15, 1976, question whether a passenger ca is considered a convertible for purposes of compliance with motor vehicle safety standards if its roof includes a 'sun roof' or has two removable sections fitted into the roof over the dashboard front designated seating positions in such a fashion that they do not join each other (Hurst Hatch Roof). You also request confirmation that convertibles are excluded from the requirements of Standard NO. 216, *Roof Crush Resistance*, and are required to meet S4.1.2.3.2 of Standard No. 208, *Occupant Crash Protection*.; The answer to your first question is no. The National Highway Traffi Safety Administration considers a convertible to be a vehicle whose 'A' pillar or windshield peripheral support is not joined with the 'B' pillar (or rear roof support rearward of the 'B' pillar position) by a fixed, rigid structural member. Passenger cars equipped with a 'sun roof' or a 'Hurst Hatch Roof' do not qualify as convertibles, because they have a fixed, rigid structural member in the described location.; With regard to your other question, passenger cars manufactured fro September 1, 1973, to August 31, 1976, inclusive, are required to meet one of three options specified in Standard No. 208. If a manufacturer chooses to meet the third option listed (S4.1.2.3), separate requirements are specified for convertibles in S4.1.2.3.2. Convertibles are excluded form Standard No. 216, although a manufacturer may choose to meet the standard in place of certain requirements of Standard No. 208 that are not presently mandatory.; Yours truly, Stephen Wood, Assistant Chief Counsel |
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ID: aiam0258OpenMr. L. C. Lundstrom, Director, Automotive Safety Engineering, General Motors Technical Center, Warren, MI 48090; Mr. L. C. Lundstrom Director Automotive Safety Engineering General Motors Technical Center Warren MI 48090; Dear Mr. Lundstrom: The Director has asked me to reply to your letter of September 29 1970, concerning the compliance of certain motor vehicles, which General Motors intends to import, with Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components.; Each rear door of these vehicles has, in addition to a 'conventional locking mechanism, a special locking mechanism which is described in your letter as:; >>>'an additional lever located on the rear edge of each door which when placed in its 'lock position', will only allow the door to be opened from outside the vehicle even if the conventional locking knob on the upper portion of the door inside the vehicle is in the unlocked position. The additional lever is covered when the door is closed.'<<<; You ask whether the rear doors on these vehicles comply with S4.1.3 o Standard No. 206, which requires that each door 'shall be equipped with a locking mechanism with an operating means in the interior of the vehicle.; A somewhat similar problem was discussed in the preamble to the Apri 27, 1968 amendment (33 F.R. 6465) to the Standard. As stated there, S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be able to be engaged or disengaged regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism on the doors in questions, therefore, it will not constitute a failure to comply with the standard.; Please write if I can be of any further assistance. Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs; |
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ID: aiam2635OpenMr. Paul F. Bennett, Chief Engineer, Utility Trailer, Manufacturing Co., P.O. Box 1299, City of Industry, CA 91744; Mr. Paul F. Bennett Chief Engineer Utility Trailer Manufacturing Co. P.O. Box 1299 City of Industry CA 91744; Dear Mr. Bennett: This responds to your May 20, 1977, letter asking whether your propose certification labels comply with the requirements of Part 567, *Certification*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approvals of compliance with Federal safety standards or regulations. We will, however, issue an opinion of whether your labels appear to comply with the regulations. The labels you submitted appear to comply with all but one of the requirements of Part 567 and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. On your certification labels, you listed the symbol 'W/' before the rim information. This symbol should be dropped from the label. Further the rim size designation should use the symbol 'x' between the diameter and width. Information supplied on a certification label must be provided in the form detailed in Part 567.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0608OpenMr. Richard F. Hirsch, 762 W. 30 Street, San Pedro, CA 90731; Mr. Richard F. Hirsch 762 W. 30 Street San Pedro CA 90731; Dear Mr. Hirsch: This is in reply to your letter of January 29, 1972, on the subject o test procedures under Standards 207 and 210.; Your questions deal with the general and frequently asked question o whether a manufacturer may devise his own test procedures to determine compliance with a standard. Our answer is that he is free to use whatever method he thinks appropriate to test his product, so long as his method reliably predicts the performance of the product when tested according to the proce- dures set out in the standard.; In answer to your first question, therefore, if testing of seats in mock up accurately indicates their performance in a vehicle, then mock up testing might be an appropriate test method. Our laboratories will be testing the seats in the vehicle. If a failure occurs, a manufacturer must show that he exercised due care in the development and production of the seat. To do this it will be necessary to show, among other things, that the development tests you conducted were, in fact, equivalent to the test procedures of the standard.; The same comment is appropriate in response to your second question. I you apply force through the seatbelt that approximates the combined forces of the belt anchorage test and seat anchorage test, you should take care to be sure that the test is, in fact, equivalent to a test in which the anchorages are tested simultaneously in the manner specified in Standards 207 and 210.; Your third question is whether the test must be conducted wit seatbelts and body locks, and if so, whether this would not be a redundant test of the seatbelt that is already required to conform to Standard 209. Although the response given to your first two questions is also appropriate for the third, there are practical reasons for using the vehicle's belts in the test. If the belt breaks, for example, it may be that your client would want to re-examine the sufficiency of the belt. Under Standard 208, the vehicle manufacturer is required to install a belt that conforms to Standard 209. If the belt fails in our testing under Standard 209, the vehicle manufacturer will have to show that he exercised due care in determining that the belt conformed to the standard. Using the belt in testing for Standard 210 is one way of detecting potentially serious belt problems.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3927OpenMr. R. R. Allison, Assistant Vice President, First American Bank of Virginia, 1970 Chain Bridge Road, McLean, VA 22102; Mr. R. R. Allison Assistant Vice President First American Bank of Virginia 1970 Chain Bridge Road McLean VA 22102; Dear Mr. Allison: This is in response to your letter of March 14, 1985, in which yo asked whether the bank is required to complete the Odometer Mileage Statement form in view of the wording on the Virginia title.; I have reviewed Virginia's Certificate of Title and the odomete mileage disclosure regulation, 49 CFR part 580. The bank should continue to issue its Odometer Mileage Statement when transferring a motor vehicle unless the buyer completely fills out the reverse side of the title, including the application. While the Virginia title meets regulatory requirements concerning the odometer reading, it fails to provide a space for the buyer's address and signature apart from the application. In some instances, a dealer may reassign the title without applying for one in his own name and the above requirements would not be met. The dealer would then be able to assert that he was not informed of the mileage or that the mileage was different from that appearing on the title.; Sincerely, Jeffrey R. Miller, 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.