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: nht95-6.43OpenTYPE: INTERPRETATION-NHTSA DATE: September 18, 1995 FROM: Orlando Ferreira -- Orion Bus Industries Ltd. TO: J. Medlin -- FTA TITLE: Urban Bus, GVWR more than 10,000 LBS For NYCTA ATTACHMT: ATTACHED TO 10/25/95 LETTER FROM JOHN WOMACK TO ORLANDO FERREIRA (A43; REDBOOK 2; STD 101) TEXT: Dear Mr. Medlin, This confirms our phone conversation of this afternoon. The master switch (# 2 on page 12-Drivers side control panel) has 4 positions: Engine stop, Run, Lights and Park. These positions are engraved so that a back light allow liability in might driving conditions. My questions is to comply with FMVSS-101-Controls and Display these positions of the master switch have to be illuminated? If yes, please indicate where this requirement is established? Thank you in advance [Illegible Words] in this matter. (Drawings omitted.) |
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ID: nht95-4.21OpenTYPE: INTERPRETATION-NHTSA DATE: September 18, 1995 FROM: Orlando Ferreira -- Orion Bus Industries Ltd. TO: J. Medlin -- FTA TITLE: Urban Bus, GVWR more than 10,000 LBS For NYCTA ATTACHMT: ATTACHED TO 10/25/95 LETTER FROM JOHN WOMACK TO ORLANDO FERREIRA (A43; REDBOOK 2; STD 101) TEXT: Dear Mr. Medlin, This confirms our phone conversation of this afternoon. The master switch (# 2 on page 12-Drivers side control panel) has 4 positions: Engine stop, Run, Lights and Park. These positions are engraved so that a back light allow liability in might driving conditions. My questions is to comply with FMVSS-101-Controls and Display these positions of the master switch have to be illuminated? If yes, please indicate where this requirement is established? Thank you in advance [Illegible Words] in this matter. (Drawings omitted.) |
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ID: nht72-5.36OpenDATE: 04/11/72 FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA TO: Edward L. Adams TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of February 17, 1972, in which you ask for information on safety specifications as they would apply to travel trailers. All trailers manufactured for use on the public roads are required to meet applicable Federal Motor Vehicle Safety Standards (FMVSS) in effect on the date of manufacture. Part 567 of Title 49 of the Code of Federal Regulations requires that a certification label be attached to the left front of the trailer. A specific conformity statement is required, among other things, on the label. A copy of the regulation is enclosed. We do not have information at this time that would add to the article in the St. Louis Post Dispatch. Thank you for your interest in the program of the National Highway Traffic Safety Administration. |
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ID: 3110yyOpen Mrs. Debby Funk Dear Mrs. Funk: This responds to your letter of July 5, l99l, as a followup to my letter of June 25. You have asked whether "it would be illegal for the owner of a vehicle that has a center highmounted stop lamp to install an additional rear window brake light? (anywhere in the back window?)" The answer is that it would not be illegal under Federal law for a vehicle owner to install an additional stop lamp anywhere in the back window, providing that all modifications were performed by the owner. However, the legality of the modification would still be subject to State law. You have also asked "What is F.M.V.S.S. 108?" That is Federal Motor Vehicle Safety Standard No. l08 Lamps, Reflective Devices and Associated Equipment. It can be found in Title 49 Code of Federal Regulations, as Section 571.108. If you have further questions, please don't hesitate to write. Sincerely,
Paul Jackson Rice Chief Counsel ref:l08#VSA d:7/30/9l |
2009 |
ID: nht94-1.54OpenTYPE: Interpretation-NHTSA DATE: February 14, 1994 FROM: Lawrence A. Beyer -- Attorney at Law TO: Z. Taylor Vinson -- Office of Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 3/7/94 from John Womack to Lawrence A. Beyer (A42; Std. 108) TEXT: This letter requests an opinion letter from your office concerning the re-importation of a certified vehicle. My client wishes to re-import vehicles which were certified by the original manufacturer and purchased in the U.S. These vehicles would then be modified and sent back to the U.S. The vehicles in question are motorcycles which would then have a shell pl aced around it. The frame would be slightly modified and seating lowered to incorporate the design. However, my client would not knowingly render inoperative wholly or in part any device or element of design installed in accordance with the FMVSS. On November 16, 1992, your office issued a letter regarding this matter. Please advise me if this letter is still your interpretation. |
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ID: nht95-3.41OpenTYPE: INTERPRETATION-NHTSA DATE: July 13, 1995 FROM: George E. Walton -- International Manufacturer's Consultants Inc. TO: Mr. John Womack -- Acting Chief Counsel, NHTSA TITLE: Reference: Federal Motor Vehicle Safety Standards No. 205, Glazing Materials - Passenger Cars, Multipurpose Vehicles, Motorcycles, Trucks and Buses. ATTACHMT: ATTACHED TO 08/04/95 LETTER FROM JOHN WOMACK TO GEORGE W. WALTON (REDBOOK 2; STD. 205) TEXT: Dear Mr. Womack: We represent a client who wishes to obtain your written comment on the use of the following glazing material in a motor vehicle: Our client wishes to use laminated "AS-1" Glass for motorcycle windshields. A motorcycle is described as a "Motor Vehicle", and the FMVSS-205 standard indicates by reference in the ANSI Z26.1 standard that "AS-1" glazing for use "Anywhere in a Motor Vehicle". Our client would like to have your written comment prior to producing several thousand motorcycle windshields from AS-1 glazing. Would you kindly address your comment to the undersigned. |
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ID: nht95-5.20OpenTYPE: INTERPRETATION-NHTSA DATE: July 13, 1995 FROM: George E. Walton -- International Manufacturer's Consultants Inc. TO: Mr. John Womack -- Acting Chief Counsel, NHTSA TITLE: Reference: Federal Motor Vehicle Safety Standards No. 205, Glazing Materials - Passenger Cars, Multipurpose Vehicles, Motorcycles, Trucks and Buses. ATTACHMT: ATTACHED TO 08/04/95 LETTER FROM JOHN WOMACK TO GEORGE W. WALTON (REDBOOK 2; STD. 205) TEXT: Dear Mr. Womack: We represent a client who wishes to obtain your written comment on the use of the following glazing material in a motor vehicle: Our client wishes to use laminated "AS-1" Glass for motorcycle windshields. A motorcycle is described as a "Motor Vehicle", and the FMVSS-205 standard indicates by reference in the ANSI Z26.1 standard that "AS-1" glazing for use "Anywhere in a Motor Vehicle". Our client would like to have your written comment prior to producing several thousand motorcycle windshields from AS-1 glazing. Would you kindly address your comment to the undersigned. |
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ID: nht92-6.14OpenDATE: June 8, 1992 FROM: Michael F. Hecker -- Micho Industries TO: Paul Jackson Rice -- Chief Counsel, NHTSA COPYEE: M. Dunn; R. Rogers TITLE: Re: R-BAR Passenger Restraint System ATTACHMT: Attached to letter dated 7/14/92 from Paul J. Rice to Michael F. Hecker (A39; Std. 222) TEXT: I wish to thank you for your response to my letter of March 31, 1992. We understand that the R-BAR, once installed on the seatback, becomes part of the seatback and therefore is subject to the test requirements of F.M.V.S.S. #222. Further, in determining the proper test procedures for this device, in accordance with the stated regulations (CFR 49 571.222 S6.4.) and including Laboratory Procedures #TP-222-01 (re: B. Pretest Procedure, step #6), we understand that since the R-BAR is part of the seatback, and adjustable, that the testing procedures are to be done in its most upright position. Please advise us if this is a proper interpretation of this (S6.4) regulation. Once again, thank you in advance for consideration in this matter. |
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ID: 11044-1Open George E. Walton Dear Mr. Walton: This responds to your July 13, 1995 letter requesting an interpretation regarding the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, "Glazing Materials." You stated in your letter that your client wants to know if Standard No. 205 permits the use of laminated AS-1 glass in motorcycle windshields. The answer to your question is yes. ANSI Z26.1-1977, which has been incorporated by reference into Standard No. 205, explicitly refers to item 1 glazing (defined as including laminated glass) as "Safety Glazing Material for Use Anywhere in Motor Vehicle." Motorcycles are motor vehicles. Therefore, item 1 glazing is permitted in that application. I hope this information is helpful. Please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely,
John Womack Acting Chief Counsel ref:205 d:8/4/95
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1995 |
ID: nht91-5.7Open DATE: July 30, 1991 FROM: Paul Jackson Rice -- Chief Counsel, NHTSA TO: Debby Funk TITLE: None ATTACHMT: Attached to letter dated 7-5-91 from Debby Funk to Paul Jackson Rice TEXT: This responds to your letter of July 5, 1991, as a followup to my letter of June 25. You have asked whether "it would be illegal for the owner of a vehicle that has a center highmounted stop lamp to install an additional rear window brake light? (anywhere in the back window?)" The answer is that it would not be illegal under Federal law for a vehicle owner to install an additional stop lamp anywhere in the back window, providing that all modifications were performed by the owner. However, the legality of the modification would still be subject to State law. You have also asked "What is F.M.V.S.S. 108?" That is Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment. It can be found in Title 49 Code of Federal Regulations, as 571.108. If you have further questions, please don't hesitate to write. |
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.