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: aiam4720OpenMr. Patrick S. Baran I.D.E.A. 2340 W. Belmont Chicago, IL 60618; Mr. Patrick S. Baran I.D.E.A. 2340 W. Belmont Chicago IL 60618; Dear Mr. Baran: This is in reply to your letter to Taylor Vinson o this Office, with respect to 'D.O.T. guidelines for tail light brightness' with respect to a 'brake light for the back of a motor cycle helmet.' I regret the delay in responding. The Department has no authority to 'approve' or 'disapprove' items of equipment, but we can provide guidance on the relationship of equipment to the Federal motor vehicle safety standards. I enclose a copy of a l982 interpretation with respect to a similar device, a headlamp intended for installation on a motorcycle helmet. It also represents our views with respect to your device. I enclose also a copy of SAE Standard J586c Stop Lamps, which our Rulemaking office promised you. We note that you use the term 'tail light' and 'brake light' interchangeably. In seeking State guidance you should be clear as to whether your device indicates the presence of the cyclist (taillamp), or the application of the brakes of the motorcycle (stop lamp), or both. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure; |
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ID: aiam2604OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and equipment Association, Inc., 5530 Wisconsin Avenue, N.W., Washington, D.C. 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and equipment Association Inc. 5530 Wisconsin Avenue N.W. Washington D.C. 20015; Dear Mr. Crampton: This responds to your April 6, 1977, letter asking whether two propose labels satisfy the requirements for certification and information labels found in 49 CFR Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicles safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with NHTSA regulations. From the illustrations you present, it appears that you have closely followed the format suggested in our regulations, and therefore, the labels seem to comply with the agency's requirements. Section S5.3(b) of Standard No. 120 permits the use of both labels when affixed in accordance with Part 567.4(b)-(f).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2609OpenMr. Byron A. Crampton, Manager of Engineering Services, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, N.W., Washington, DC 20015; Mr. Byron A. Crampton Manager of Engineering Services Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue N.W. Washington DC 20015; Dear Mr. Crampton: This responds to your April 6, 1977, letter asking whether two propose labels satisfy the requirements for certification and information labels found in 49 CFR Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with NHTSA regulations. From the illustrations you present, it appears that you have closely followed the format suggested in our regulations, and therefore, the labels seem to comply with the agency's requirements. Section S5.3(b) of Standard No. 120 permits the use of both labels when affixed in accordance with Part 567.4(b)- (f).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3515OpenMr. James S. Nasby, Director of Engineering, Pathfinder Auto Lamp Company, 6201 W. Howard Street, Niles, IL 60648; Mr. James S. Nasby Director of Engineering Pathfinder Auto Lamp Company 6201 W. Howard Street Niles IL 60648; Dear Mr. Nasby: This responds to your November 25, 1981, letter to Roger Tilton of thi Office regarding the applicability of vehicle identification number (VIN) requirements to trailer kits manufactured by your company.; It is our view that these trailer kits must comply with the VI requirements of FMVSS 115. Your kits contain all components necessary to assembly a complete trailer, and are advertised as capable of being readily assembled with simple tools such as screwdrivers and wrenches. We see no relevant basis for distinguishing between such kits and completed trailers for purposes of determining the applicability of FMVSS 115.; While the VIN requirements do provide anti-theft benefits, they als are important to this agency in administering the defect recall program as well as to State motor vehicle departments and insurance companies. Further, even if this agency exempted trailer kits from VIN requirements, purchasers of your kits would likely face difficulties when they attempt to register their trailers with the States. We expect most states to soon begin checking VIN's as part of the vehicle registration process, and vehicles without a VIN or with a nonconforming identification number might face rejection by the state motor vehicle departments notwithstanding a technical exemption from NHTSA. We feel that in the long run, the best and simplest solution is for vehicle manufacturers to assign a VIN which meets the requirements of FMVSS 115.; Should you still wish to seek an exemption from the standard procedures for obtaining exemptions are set forth in Title 49 of the Code of Federal Regulations, Part 555, a copy of which is enclosed. Such exemptions are available for not more than three years.; You should also be aware that certification labels must contain bot the month and year of a vehicle's manufacture. See 49 CFR 567.5(b)(5). The copy of the label you sent us contains only the year of manufacture.; If you have further questions on this matter, feel free to contact u again.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2553OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of March 29, 1977, asking two question about the use of strobe lamps on school buses.; Your first question is whether it is 'legal to install strobe typ warning lamps on school buses?' The answer is yes provided such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887 'School Bus Red Signal Lamps.'; You also reference 'certification from our vendor. . . that his syste meets FMVSS if installed according to his instructions.' You have asked if this letter from your vendor is 'adequate documentation upon which we could certify that a bus with such a system meets FMVSS 108?' In an earlier opinion letter on this subject (to Yankee Metal Products Corporation of April 12, 1976) we opined opinion by a professional engineer indicating compliance of a strobe lamp design with SAE J887 provided a basis upon which Yankee could certify that its system meets Standard No. 108. Since you did not enclose the letter from your vendor we cannot comment upon it. However the National Traffic and Motor Vehicle Safety Act requires that a manufacturer exercise due care in insuring that its certification is not false and misleading in a material respect, and you should exercise the same care in this instance that you do with respect to insuring compliance of other items of lighting devices with which your buses are equipped.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam2835OpenMs. Janine M. Schulte, North Central Tank Repair, Box 300, Holdingford, MN 56340; Ms. Janine M. Schulte North Central Tank Repair Box 300 Holdingford MN 56340; Dear Ms. Schulte: This responds to your January 30, 1978, letter asking whether you ar permitted to mount temporarily a body on a vehicle when you know that the body is of a greater load carrying capacity than is appropriate for the vehicle's gross vehicle weight rating (GVWR). You indicate that some other manufacture would finish the mounting process and certify the vehicle for compliance with the Federal motor vehicle safety standards.; The National Highway Traffic Safety Administration (NHTSA) ha indicated on many occasions that vehicle overloading poses a serious safety problem for the affected vehicle, in particular, and the motoring public in general. Accordingly, the agency has stated its determination to hold manufacturers responsible for vehicles that they manufacture which will exceed their GVWR's when fully loaded with their intended cargo. The NHTSA considers such overloading to constitute a safety-related defect.; In the operation that you are considering, you would be considered a intermediate vehicle manufacturer. As such, you would be required to comply with all of the requirements in Part 568, *Vehicles Manufactured in Two or More Stages*, that apply to intermediate manufacturers. The NHTSA would consider you to be partially responsible for the construction of a vehicle that when loaded with its intended cargo will exceed its GVWR. Possible agency action might include a mandatory recall and remedy and civil penalties of up to $1,000 per vehicle.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4035OpenMr. Daniel J. Wacek, Quality Control Supervisor, Viracon, Inc., 800 Park Drive, Owatonna, MN 55060; Mr. Daniel J. Wacek Quality Control Supervisor Viracon Inc. 800 Park Drive Owatonna MN 55060; Dear Mr. Wacek: Thank you for your letter of September 30, 1985, to Stephen Oesch of m staff concerning the application of Standard No. 205, Glazing Materials, to a street sweeper.; As with all of our safety standards, Standard No. 205 applies only t vehicles classified as motor vehicles by the National Traffic and Motor Vehicle Safety Act. Section 102(3) of the Vehicle Safety Act defines the term 'motor vehicle' as 'any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.'; There are some vehicles which are excepted from this classificatio despite their use on the highway. Vehicles such as highway lane strippers, self-propelled asphalt pavers, and other vehicles which have a low maximum speed capability and whose unusual configuration distinguishes them from the traffic flow are not considered motor vehicles. Enclosed is a copy of an information sheet prepared by the agency which discusses additional factors we consider in determining whether a vehicle meets the statutory definition of 'motor vehicle.' In your phone conversation of October 25, 1985, with Mr. Oesch you explained that you currently do not have definite information on the configuration, speed capability and other design characteristics of the street sweeper. We cannot provide you with an answer about whether we would consider the sweeper to be a motor vehicle without that information.; I hope this background information is of assistance to you. We would b glad to provide you with a specific interpretation concerning your vehicle after we receive more information about its design characteristics.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2533OpenMr. John O. Bohmer, President, Bohmer - Reed, Inc., Motorhome Conversions, Brooten, MN 56316; Mr. John O. Bohmer President Bohmer - Reed Inc. Motorhome Conversions Brooten MN 56316; Dear Mr. Bohmer: This responds to your February 25, 1977, letter asking whether you motor home conversions make you a manufacturer or an alterer for purposes of compliance with the regulations of the National Highway Traffic Safety Administration (NHTSA).; In your conversion of motor homes, you install used bodies on ne chassis. The NHTSA considers the mounting of a used body on a new chassis to be the manufacture of a new motor vehicle that requires certification. This makes you a manufacturer rather than an alterer. The rules for certification are found in Part 567, *Certification*, and Part 568, *Vehicles Manufactured in Two or More Stages*. I have enclosed copies of these regulations for your information.; Your second question asks whether the converted vehicle must compl with Standard No. 302, *Flammability of Interior Materials*, even though the original body was manufactured prior to the effective date of the standard. Vehicles must comply with all standards in effect on the date of their manufacture. For vehicles that you complete by mounting a body on a new chassis, you are permitted to treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in Part 568), the date of final completion of the vehicle, or a date between those dates. Therefore, it appears that the vehicle you manufacture would be required to comply with Standard No. 302.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2531OpenMr. John O. Bohmer, President, Bohmer - Reed, Inc., Motorhome Conversions, Brooten, MN, 56316; Mr. John O. Bohmer President Bohmer - Reed Inc. Motorhome Conversions Brooten MN 56316; Dear Mr. Bohmer: This responds to your February 25, 1977, letter asking whether you motor home conversions make you a manufacturer or an alterer for purposes of compliance with the regulations of the National Highway Traffic Safety Administration (NHTSA).; In your conversion of motor homes, you install used bodies on ne chassis. The NHTSA considers the mounting of a used body on a new chassis to be the manufacture of a new motor vehicle that requires certification. This makes you a manufacturer rather than an alterer. The rules for certification are found in Part 567, *Certification*, and Part 568, *Vehicles Manufacturer in Two or More Stages*. I have enclosed copies of these regulations for your information.; Your second question asks whether the converted vehicle must compl with Standard No. 302, *Flammability of Interior Materials*, even though the original body was manufactured prior to the effective date of the standard. Vehicles must comply with all standards in effect on the date of their manufacture. For vehicles that you complete by mounting a body on a new chassis, you are permitted to treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in Part 568), the date of final completion of the vehicle, or a date between those two dates. Therefore, it appears that the vehicle you manufacture would be required to comply with Standard No. 302.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2532OpenMr. John O. Bohmer, President, Bohmer - Reed, Inc., Motorhome Conversions, Brooten, MN 56316; Mr. John O. Bohmer President Bohmer - Reed Inc. Motorhome Conversions Brooten MN 56316; Dear Mr. Bohmer: This responds to your February 25, 1977, letter asking whether you motor home conversions make you a manufacturer or an alterer for purposes of compliance with the regulations of the National Highway Traffic Safety Administration (NHTSA).; In your conversion of motor homes, you install used bodies on ne chassis. The NHTSA considers the mounting of a used body on a new chassis to be the manufacture of a new motor vehicle that requires certification. This makes you a manufacturer rather than an alterer. The rules for certification are found in Part 567, *Certification*, and Part 568, *Vehicles Manufactured in Two or More Stages*. I have enclosed copies of these regulations for your information.; Your second question asks whether the converted vehicle must compl with Standard No. 302, *Flammability of Interior Materials*, even though the original body was manufactured prior to the effective date of the standard. Vehicles must comply with all standards in effect on the date of their manufacture. For vehicles that you complete by mounting a body on a new chassis, you are permitted to treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in Part 568), the date of final completion of the vehicle, or a date between those two dates. Therefore, it appears that the vehicle you manufacture would be required to comply with Standard No. 302.; Sincerely, Frank Berndt, 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.