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
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ID: aiam2324OpenMr. Jack Roadman, Box 9971, Pittsburgh, PA 15233; Mr. Jack Roadman Box 9971 Pittsburgh PA 15233; Dear Mr. Roadman: This is in response to your letters of February 26 and March 8, 1976 concerning the certification of a truck that you wish to build with a chassis that you have purchased from International Harvester. You have indicated that the chassis did not include an engine, transmission, or radiator. You installed a diesel engine, transmission, and a new driveshaft, and made various modifications to the chassis. You have had difficulties in persuading a body manufacturer to install a truck body.; The source of your difficulties appears to be a misunderstanding of th requirements of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) and the accompanying certification regulations. Pursuant to the Act, the National Highway Traffic Safety Administration has issued Federal motor vehicle safety standards. These standards apply to completed motor vehicles and to certain items of motor vehicle equipment (e.g., brake hoses, tires). The manufacturer of a motor vehicle or an item of equipment to which a standard applies is required by Section 114 of the Act to certify that his product complies with all applicable Federal motor vehicle safety standards.; 'Incomplete vehicle' is defined in 49 CFR Part 568, *Vehicle Manufactured in Two or More Stages*, as:; >>>an assemblage consisting, as a minimum, of frame and chassi structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle.<<<; An incomplete vehicle is, strictly speaking, an item of motor vehicl equipment. There are no Federal motor vehicle safety standards that apply directly to these particular equipment items, and thus there is presently no certification requirement for incomplete vehicles. The manufacturer of an incomplete vehicle is required by Part 568, however, to furnish an 'incomplete vehicle document'. This document, which is described in S 568.4, must indicate the conformity status of the incomplete vehicle with respect to each standard that applies to the vehicles into which it may be completed.; The chassis that you bought from International Harvester (IH) was a item of motor vehicle equipment to which no standards apply. Therefore, IH was not required to furnish you with a certification of compliance. Further, the chassis was not an incomplete vehicle because it lacked an engine and transmission. Therefore, IH was not required to furnish an incomplete vehicle document. Becuase (sic) of your operations on the chassis, you are the manufacturer of an incomplete vehicle. You, therefore, are the person required to furnish an incomplete vehicle document.; Your letter also indicated a concern thay (sic) you were not given 'certificate of origin' by International Harvester when you purchased the chassis. Federal law does not require the issuance of a certificate of origin. Unless you intended to refer to the Section 114 'certification' discussed above, I assume that you have in mind a document that would be the subject of Pennsylvania state law.; Copies of the Act and the certification regulations are enclosed fo your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam0319OpenMr. S. Ashimori, Managing Director, Ashimori Industry Company, Ltd., 15, 4 chrome (sic) Yokobori, Higashi-ku, Osaka, Japan; Mr. S. Ashimori Managing Director Ashimori Industry Company Ltd. 15 4 chrome (sic) Yokobori Higashi-ku Osaka Japan; Dear Mr. Ashimori: Thank you for your letter of April 1, 1971, regarding self-fastenin seat belt systems.; Any system which requires no action by vehicle occupants can be used t meet the appropriate options of Federal Motor Vehicle Safety Standard No. 208 - Occupant Crash Protection. 'No action,' in this case, means that no action is permitted by vehicle occupants other than would be required if the protective system were not present in the vehicle.; We have received a number of petitions for reconsideration o clarification of Notice 9, particularly in reference to the role of a passive (no action) safety belt system as it relates to the requirements for Type 1 or Type 2 seat belt installations prior to August 15, 1975. We are now in the process of resolving the petitions received, and our final decisions in response to the petitions will be issued in the *Federal Register* as soon as possible.; Your interest in our motor vehicle safety programs is most appreciated. Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs; |
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ID: aiam3866OpenMr. Brian Gill, Senior Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, Gardena, CA 90247; Mr. Brian Gill Senior Manager Certification Department American Honda Motor Co. Inc. P.O. Box 50 Gardena CA 90247; Dear Mr. Gill: This is in response to your letter of May 25, 1984, asking for a interpretation of Motor Vehicle Safety Standard No. 108. Table IV specifies that the minimum horizontal separation distance '(centerline to centerline of lamp)' for rear turn signal lamps on motorcycles is 9 inches. You have asked whether the 'centerline' refers to the distance between the lens centers, between the centers of the effective projected luminous areas, or between the bulb centers.; You asked for confirmation of your belief that the prope interpretation is found in the referenced SAE Standard, J588e, which contains the language 'Optical axes (filament centers),' implying that the correct distance is that between the 'bulb centers' as you term it.; We find no direct correlation between the phrases 'centerline t centerline of lamps' and 'optical axis (filament center).' The lamp is a device emitting light whereas 'optical axis (filament center)' does not refer to the lamp but only to a portion of its light-producing component. As that phrase is used in SAE J588e, it defines the method of measuring distances between bulbs in multi-compartment lamps for the purpose of testing for photometric requirements (paragraph 3.1), or in measuring the separation of the turn signal from the headlamp (paragraph 4.2, where, incidentally, it is expressed as the distance between filament and a lamp component, the retaining ring).; Taken literally, 'centerline to centerline of lamps' in our view mean the distance between lens centers. In the response to petitions for reconsideration of the center high-mounted stoplamp amendment (May 17, 1984), the question was asked whether the 'center' of the lamp was its geometric center, its optical center, or the center of the bulb filament. The agency replied that the center of the lamp is the geometric center. Since the purpose of the minimum separation requirement is to insure that the turn signal is perceived as such, we believe that the correct interpretation of 'centerline to centerline' is a measurement from the geometric center of one lamp to the geometric center of the other lamp. The geometric center would be synonymous with the term 'geometric centroid of lens' as used in SAE J1221 *Headlamp-Turn Signal Spacing*.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2774OpenMr. Philip A. Hutchinson, Jr., Volkswagen of America, 475 L'Enfant Plaza, S.W., Suite 2450, Washington, DC 20024; Mr. Philip A. Hutchinson Jr. Volkswagen of America 475 L'Enfant Plaza S.W. Suite 2450 Washington DC 20024; Dear Mr. Hutchinson: This responds to your January 30, 1978, request for confirmation tha no requirement in S 581.5(c) of the Part 581 *Bumper Standard* limits damage to the supporting ribs inside a plastic bumper face bar component or to the bumper face bar reinforcement component of the bumper system that lies within and reinforces the bumper face bar itself. You also requested confirmation that bumper 'end cuffs' are part of a bumper face bar if they are impacted by the impact ridge of the pendulum test device.; As we understand your description of the bumper reinforcement, it i not a bumper face bar, an exterior surface of the vehicle, or one of the other regulated portions of the vehicle. Therefore, it would not be regulated by the standard.; Internal deformation or cracking of the bumper face bar component doe not violate the provisions of S 581.5(3) as long as the dent and set requirements of (c)(11) are otherwise met.; 'Bumper face bar' is defined in S4 as 'any component of the bumpe system that contacts the impact ridge of the pendulum test device.' Protective ends or cuffs on a steel bumper face bar are considered components of the bumper system and, if contacted by the impact ridge of the pendulum test device, qualify under the definition as a portion of the bumper face bar subject to the same damageability limits as the rest of the bumper face bar.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0749OpenMr. John Forbes, Research Associate, Consumer Research Center, College of Business Administration, University of Puerto Rico, Rio Piedras, Puerto Rico 00931; Mr. John Forbes Research Associate Consumer Research Center College of Business Administration University of Puerto Rico Rio Piedras Puerto Rico 00931; Dear Mr. Forbes: This is in reply to your letter of June 9, 1972, raising certai questions concerning the National Traffic and Motor Vehicle Safety Act, and the Defect Reports regulations (49 CFR Part 573).; You ask whether the amendments made by sections 4(a) and (c) of Publi Law 91-265 took effect on November 28, 1970 or later. Section 4(d) of that law specified, as you note, that these sections take effect 180 days after the enactment of the Act, unless the Secretary of Transportation determined that a later date was in the public interest. No such determination was made, and the sections took effect 180 days after the Act's enactment. However, our computation shows that 180 days after May 22 is November 18, not November 28.; You ask if Owners Lists (49 CFR 573.6), including vehicl identification numbers, can be obtained by NHTSA and transmitted to your organization. The NHTSA would not consider it appropriate to require manufacturers to submit owner's (sic) lists to it for purposes not involved in the enforcement of the National Traffic and Motor Vehicle Safety Act. We would not consider the study you wish to perform to be within this purpose.; You also ask if we can furnish you copies of Quarterly Reports (49 CF 573.5) at least as they relate to cars sold in Puerto Rico. Quarterly reports submitted by manufacturers, except for the production figures submitted pursuant to section 573.5(b), are considered to be public documents and are available for public inspection. Due to the large number of reports we receive, however, we can furnish copies only if the precise reports desired are specified. The reports do not disclose the geographical location of the vehicles involved.; With reference to your request for the latest version of the leaflet 'Motor Vehicle Safety Defect Recall Campaigns,' I have enclosed the volume which provides information for the complete year 1971, and a new volume dealing with January-March 1972.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1508OpenMr. George D. Green, Director of Sales, JacKnife Division, Breeze Corporations, Inc., 700 Liberty Avenue, Union, NJ 07083; Mr. George D. Green Director of Sales JacKnife Division Breeze Corporations Inc. 700 Liberty Avenue Union NJ 07083; Dear Mr. Green: This is in reply to your letter of May 8, 1974, asking whether person installing on a new vehicle a device called the Breeze Jacknife Control are required to certify the conformity of the vehicle to applicable motor vehicle safety standards. You indicate such a device would ordinarily be installed after the truck leaves the factory.; Persons who install components on or otherwise modify complete vehicles before their sale to a purchaser for a purpose other than resale may be vehicle alterers under NHTSA Certification regulations (49 CFR Parts 567, 568), and if so are required to certify that the vehicle as altered conforms to applicable standards by attaching to it a label containing specified information. A label must be attached when the alteration either involves components which are not readily attachable or whose installation renders invalid the vehicle's stated weight ratings. Modifications to a completed vehicle after its purchase for purposes other than resale, however, do not give rise to any certification or labeling requirements.; Copies of the Certification regulations and information on obtainin copies of all NHTSA requirements are enclosed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3535OpenLawrence W. Gebhardt, Gebhardt & Smith, Suite 1544, The World Trade Center, Baltimore, MD 21202; Lawrence W. Gebhardt Gebhardt & Smith Suite 1544 The World Trade Center Baltimore MD 21202; Dear Mr. Gebhardt: This is in response to your letter of November 30, 1981, in which yo raised several questions concerning the application of the exemption for dealer-to-dealer transfers of new cars. We are sorry for the delay in responding. Specifically you wanted to know if a dealer transferring a new vehicle with fifty miles registered on the odometer to another dealer was required to issue an odometer disclosure statement. You also requested that the agency provide you with cases subsequent to *Lair v. Lewis Service Center*, 428 F. Supp. 778 (D.Neb. 1977) which address the enforceability of the exemptions to Title IV of the Motor Vehicle Information and Cost Savings Act ('Act') (15 U.S.C. 1981 *et seq.*); Purchasers of motor vehicles rely heavily on the odometer reading as a index of the condition and value of the vehicle. The purpose of the Federal odometer laws is to establish certain safeguards against odometer tampering and to provide purchasers of motor vehicles an accurate statement of the mileage traveled by a motor vehicle. Section 408 of the Act requires that each transferor of a motor vehicle furnish to the transferee a written statement certifying the accuracy of the mileage. 15 U.S.C. 1988. The Odometer Disclosure Requirements specifically detail the information that must be disclosed. 49 CFR 580.4. However, the agency has determined that the exemption of certain transactions and vehicles is consistent with the purposes and scope of the Act. 49 CFR 580.5.; 49 CFR 580.5(b) exempts all transfers of a new vehicle prior to th first transfer to a customer who actually plans to use the vehicle from the Odometer Disclosure Requirements. The exemption applies to the dealer-to-dealer transfer of new vehicles regardless of the odometer reading. However, the exemption does not preclude a dealer from requiring the transferring dealer to certify the accuracy of the mileage.; The exemption is consistent with the purpose and scope of the Federa odometer laws. It is customary for dealers to transfer new vehicles to other dealers who plan to immediately resell the vehicle to a customer. Generally, the frequency of odometer fraud in these transactions is minimal. Indeed, prior to the transfer of a vehicle to a consumer, the odometer reading should only reflect the mileage accumulated while the vehicle is being demonstrated to a potential buyer or driven a short distance, which might be occasioned by a typical dealer-to-dealer transfer. We are unable to establish by issuing an opinion letter what the limit of such mileage incidental to the sale of a new car should be. If a dealer doubts the accuracy of the odometer reading, he can readily inspect the car for evidence of odometer tampering. In the absence of such evidence, the first dealer to sell the vehicle to a non-resale purchaser should be free to certify the mileage as accurate. The agency therefore views the issuance of odometer disclosure statements in such dealer-to-dealer transactions as unnecessarily burdensome on dealers.; In addition to *Lair v. Lewis Service Center*, the agency has knowledg of one other case *Romeri Trucking, Inc. v. Boise Kenworth Sale*, No. 80-1252 (D. Iowa, February 11, 1981), that addresses the issue of the enforceability of 49 CFR 580.5(a)(1). To date the agency has not issued a formal opinion on either case.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1158OpenMr. James W. Livsey, The Southern Connecticut Gas Co., 880 Broad Street, Bridgeport, Connecticut 06609; Mr. James W. Livsey The Southern Connecticut Gas Co. 880 Broad Street Bridgeport Connecticut 06609; Dear Mr. Livsey: This is in reply to your letter to Mr. David Snyder of this agenc regarding information on tests performed on recapped tires, specifically, data comparing failure characteristics of retreaded tires with those of new tires.; The NHTSA does not presently have test data of the specific type yo request. We are attempting to obtain that data through research contracts with outside parties, and results of that research, when they are received, will be placed in the rulemaking docket regarding retreaded tires. Other test data for retreaded tires have been placed in this docket (Docket No. 1-8), which is open for public inspection at NHTSA headquarters, 400 7th Street, S.W., Washington, D.C.; Certain studies have been conducted on the failure rates of tires, an some comparative data have been complied. One volume with which we are familiar summarizes studies which provided information of this type. It is, Brenner and Harvey, Tire Use Survey, the Physical Condition, Use and Performance of Passenger Car Tires in the United States of America, NBS Technical Note 528, (National Bureau of Standards U.S. Department of Commerce). Copies are available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402. It should be ordered by SD Catalog No. C13.46:528, prepaid, at 60 a copy.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3165OpenMr. E. M. Ryan, Ward Industries, Inc., P.O. Box 849, Highway 65 South, Conway, AR 72032; Mr. E. M. Ryan Ward Industries Inc. P.O. Box 849 Highway 65 South Conway AR 72032; Dear Mr. Ryan: This responds to your October 8, 1979, letter asking whether your ne bus design will comply with Standard No. 217, *Bus Window Retention and Release*. The window exit that you plan to install in the bus would slide open rather than push out and would be operated by a squeeze-type force application that is parallel to the horizontal centerline of the bus.; Standard No. 217 requires buses to be equipped with emergency exit that comply with a variety of requirements. In the case of window exits, the force application for opening them depends upon the location of the release mechanism. For example, the required force application in the high force access region, according to the standard (S5.3.2), is straight and perpendicular to the exit surface.; In applying the above requirement to your vehicle, it appears that you bus would not comply with the standard. From the pictures that you enclosed with your letter, it appears that your release mechanism falls in the high force access region. If so, the force application for opening the exit is in the incorrect direction as specified by the standard. Further, your bus would use window exits that slide open rather than push out. Although, sliding emergency exits are not prohibited by the standard, they must comply with all of the standard's requirements. Also, they must be capable of complying when the non-exit half of the window is either open or closed. The agency prefers the use of push-out emergency exits, because they are less likely to 'bind up' during a side impact than sliding emergency exits.; The standard was written in its present form to provide uniformity o emergency exits in buses. A uniform exit system can help prevent confusion during accidents and facilitate emergency exit of vehicles. The vehicle that you plan to build would be unlike other buses now in operation with respect to emergency exits. The NHTSA does not think that this would be desirable or in the interest of safety.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3470OpenDick Sorensen, Brekhus Buick-International, Box 1357, Rapid City, SC 57701; Dick Sorensen Brekhus Buick-International Box 1357 Rapid City SC 57701; Dear Mr. Sorensen: This is in response to your letter of September 10, 1981, in which yo requested information on the Federal odometer disclosure requirements and specifically on their applicability to trucks with a gross vehicle weight rating (GVWR) of over 16,000 pounds. I have enclosed a copy of Title IV of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1981 et seq.) which sets forth the Federal law pertaining to odometers. Section 404 of the Act prohibits any person from altering the odometer of any motor vehicle including trucks of more than 16,000 pounds GVWR.; I have also enclosed a copy of the odometer disclosure requirements (4 CFR Part 580). I have highlighted in red the exemption that applies to large trucks. The agency found that purchasers of these trucks do not rely on the odometer as an indicator of their mileage and, therefore, exempted them from the disclosure requirements. Before you decide whether or not to issue odometer disclosure statements for these trucks, I would like to alert you to the fact that at least one court has held that the agency exceeded its authority in fashioning this exemption and has declared it void. *Lair v. Lewis Service Center*, 428 F.Supp. 778 (D.Neb. 1977). The holding is not binding on any other court and the agency believes the exemption is valid. Nevertheless, you should be aware that should the issue arise again, another court could take a similar view.; I hope that this information is useful to you. If you have any furthe questions, please do not hesitate to write.; Sincerely, John Womack, Assistant 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.