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: aiam2911OpenMr. O.R. Schmidt, Conco Inc., Mendota, Illinois 61342; Mr. O.R. Schmidt Conco Inc. Mendota Illinois 61342; Dear Mr. Schmidt: This is in response to your letter of October 27, 1978, concerning th application of Motor Vehicle Safety Standard No. 115 to final stage manufacturers and in confirmation of your telephone conversation with Mr. Schwartz of my office.; The National Highway Traffic Safety Administration has amended Standar No. 115 to shift the responsibility for assigning the vehicle identification number for vehicles manufactured in more than one stage from the final stage manufacturer to the incomplete vehicle manufacturer (copy enclosed). We appreciate your desire to comply fully with the standard but, with this recent amendment, compliance will not be required by final stage manufacturers.; In response to your question concerning the 'model year' to be used fo trailers, the calendar year is acceptable as the 'model year.' Should you have any other questions concerning your responsibility for assigning VINs to the trailers you manufacture, please do not hesitate to contact me.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0674OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of March 28, 1972, inquiring whether State or its political subdivisions (in your particular case it is a county) may elect not to conform to any of the motor vehicle safety standards and the Certification regulations. You state that in the particular case in question the county orders new incomplete vehicles, and then transfers an old body onto the new chassis, creating a completed vehicle.; Under the existing regulations, one who transfers a used body onto new chassis is, as you have apparently assumed, a final-stage manufacturer, and is responsible for compliance with applicable standards, and the Certification regulations. There is no exemption in the National Traffic and Motor Vehicle Safety Act, or the standards or certification requirements, for counties or other State governmental units that manufacture completed vehicles. Consequently, the county is responsible in the situation you describe for completing the vehicles in question in such a manner that they conform to all applicable motor vehicle safety standards, and for certifying conformity with the standards in accordance with the certification requirements.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4972OpenD. E. Dawkins, Acting Director Automotive Safety Planning and Compliance Product Strategy and Regulatory Affairs Office Chrysler Corporation CIMS 414-01-22 12000 Chrysler Drive Highland Park, MI 48288-0857; D. E. Dawkins Acting Director Automotive Safety Planning and Compliance Product Strategy and Regulatory Affairs Office Chrysler Corporation CIMS 414-01-22 12000 Chrysler Drive Highland Park MI 48288-0857; "Dear Mr. Dawkins: This responds to the petition dated September 30 1991, that Mr. Kittle submitted on behalf of Chrysler Corporation seeking temporary exemption for the TEVan from several Federal motor vehicle safety standards on the basis that the exemption would facilitate the development and field evaluation of low emission motor vehicles. The petition indicates (page 4) that exemption is sought for four l989 Dodge Caravans, converted to electric power, that 'were manufactured for test and evaluation'. We understand that this conversion occurred after completion of the manufacture of the vans, and that the conversion was performed by a subsidiary of Chrysler. If an exemption is granted, the petition states that 'one or more of the vehicles will be titled and sold for ongoing endurance evaluation.' Finally, we understand that the TEvans are currently in the possession of the Electric Power Research Institute in California for evaluation, and that presumably they are being driven on the public roads. We regret the delay in responding to Mr. Kittle's letter. The petition represents a rare instance in which a manufacturer has petitioned for an exemption for a vehicle whose manufacture has been completed, and which has been in use. The purpose of an exemption is to allow a manufacturer to engage in conduct that would otherwise be prohibited by the National Traffic and Motor Vehicle Safety Act, specifically, the manufacture for sale, sale, offer for sale, or introduction or delivery for introduction, or importation into the United States of a motor vehicle that does not conform to all applicable Federal motor vehicle safety standards, and which does not bear a certification of compliance with those standards. With respect to the four TEVans for which petition has been made, it appears that they have already been introduced into interstate commerce without a certification of compliance (or, if bearing the certification of the original vehicle, a certification that is false and misleading in a material respect, a further violation of the Act). Any exemption by the Administrator could not cover conduct violative of the Act that has already occurred. However, we have concluded that the Administrator may grant an exemption to vehicles, which would apply to conduct that would violate the Act, but which has not occurred. As Chrysler seeks an exemption in order to sell the TEVans, or to offer them for sale, the Administrator's exemption authority may be exercised to permit Chrysler to do so, after the procedural requirements have been followed. The petition meets our requirements for form and content, and a notice requesting public comment is being prepared for publication in the Federal Register. We shall notify you when the Administrator has reached a decision. If you have any questions, you may discuss them with Taylor Vinson of this Office (202-366-5263). Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam2318OpenMs. Dianne Black, Liaison Engineer, British Leyland Motors Inc., 600 Willow Tree Road, Leonia, NJ 07605; Ms. Dianne Black Liaison Engineer British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black:#This is in response to your letter of March 29, 1976 concerning the requirements of Federal Motor Vehicle Safety Standard No. 101, *Control Location, Identification, and Illumination*, for identification of the headlamps and taillamps control.#Your letter presented two symbols specified by the International Standards Organization as alternative for identification of the master lighting switch. One of these appears in Column 4 of Table 1 of the standard and the other does not appear anywhere in the table. The headlamps and taillamps control (master lighting switch) is required by S4.2.1 to be identified with the word 'Lights'. The manufacturer may supplement this identification with a symbol, but only with a symbol that appears in Column 3 or Column 4 of TAble 1. In issuing the amendment to the standard published July 29, 1975 (40 FR 31770, copy enclosed), the National Highway Traffic Safety Administration considered both ISO symbols and decided not to permit the one that does not appear in the table.#Yours truly, Stephen P. Wood, Assistant Chief Counsel; |
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ID: aiam2317OpenMs. Dianne Black, Liaison Engineer, British Leyland Motors Inc., 600 Willow Tree Road, Leonia, NJ 07605; Ms. Dianne Black Liaison Engineer British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black:#This is in response to your letter of March 29, 1976 concerning the requirements of Federal Motor Vehicle Safety Standard No. 101, *Control Location, Identification, and Illumination*, for identification of the headlamps and taillamps control.#Your letter presented two symbols specified by the International Standards Organization as alternatives for identification of the master lighting switch. One of these appears in Column 4 of Table 1 of the standard and the other does not appear anywhere in the table. The headlamps and taillamps control (master lighting switch) is required by S4.2.1 to be identified with the word 'Lights'. The manufacturer may supplement this identification with a symbol, but only with a symbol that appears in Column 3 or Column 4 of Table 1. In issuing the amendment to the standard published July 29, 1975 (40 FR 31770, copy enclosed), the National Highway Traffic Safety Administration considered both ISO symbols and decided not to permit the one that does not appear in the table.#Yours truly, Stephen P. Wood, Assistant Chief Counsel; |
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ID: aiam1761OpenMr. Lee C. Golder,2090 Union Avenue,North Bend, Oregon 97459; Mr. Lee C. Golder 2090 Union Avenue North Bend Oregon 97459; Dear Mr. Golder:#Please forgive the delay on responding to the reques in your letter of October 15, 1974, for information on the applicability of the banding requirements of Federal Motor Vehicle Safety Standards No. 106-74, *Brake Hoses*, to your fleet accounts.#S5.2.4 of Standard No. 106-74, in its present form, requires each fleet owner who makes up brake hose assemblies for his own use to label each assembly with a band ant to file a designation that identified him as the manufacturer of the assembly with the Office of Standards Enforcement. An amendment of this requirement is under active consideration, and the issue will be dealt with a forthcoming notice in the Federal Register.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2252OpenHonorable Mark Andrews, House of Representatives, Washington, DC 20515; Honorable Mark Andrews House of Representatives Washington DC 20515; Dear Mr. Andrews: This is in response to your letter of March 19, 1976, requesting ou comments on an inquiry from one of your constituents, Mr. Pat Milloy, concerning the proper format for disclosure of odometer mileage information in compliance with the Federal odometer disclosure regulation (49 CFR Part 580).; Mr. Milloy states in his letter that a Colorado dealer, orderin odometer disclosure forms, has indicated that the required Federal format has been changed. The format referred to by the Colorado dealer differs from the Federal form which Mr. Milloy and his client, Globe-Gazette Printing Company, believe to still be in force.; The Federal odometer disclosure regulation has not been amended sinc its initial enactment. The format requested by the Colorado dealer (form 'B' enclosed in Mr. Milloy's letter) fails to comply with the current Federal odometer disclosure requirements in several respects. The statement referring to the mileage indicated on the odometer at the time of the vehicle's transfer must be phrased to indicate that the disclosure document was executed at the time of the vehicle's transfer, not at some later time. In addition, the statement must be written in such a manner that it is clear it is to be completed by the transferor alone. To satisfy these criteria the statement should read:; >>>'I, * *, state that the odometer mileage indicated on the vehicl described above, at the time of transfer to * * is as follows:'<<<; The portion of the document provided for disclosure of the odomete mileage and a statement as to its accuracy is also deficient. Instructions are necessary on this part of the form to ensure that it is completed in a consistent manner by all persons. The number of miles indicated on the odometer at the time of the vehicle's transfer need not appear a second time if the form includes the statement recommended above. If the seller wishes, he may indicate on the form that the actual mileage is over 100,000 miles. In addition, the statement concerning the accuracy of the vehicle's reflected mileage must be more complete than the one included in form 'B'. Completion of the disclosure document in accordance with these directions may be accomplished as follows:>>>; '(Where applicable, complete line 1 and/or check line 2:) 1. * *, total cumulative miles (if over 100,000). 2. [ ] I further state that the actual mileage differs from th odometer reading for reasons other than odometer calibration error and that the actual mileage is unknown.'<<<; The odometer regulation's provisions do not require that the transfere sign the statement nor do they make it necessary to have the document notarized. In addition, the date on which the transferor purchased the vehicle need not be provided.; As long as the requirements of the disclosure regulation are satisfied there is no limitation on including additional information in the disclosure statement. Thus, modifying the statement 'B' format to meet the Federal requirements in the manner described above would be sufficient for compliance by the Colorado dealer. The additional information appearing in form 'B' may be retained without affecting compliance.; I hope this letter answers Mr. Milloy's questions concerning th Federal odometer disclosure requirements. If I can be of any further assistance, please do not hesitate to let me know.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2204OpenMr. John L. O'Connell, State of Connecticut, Department of Motor Vehicles, State Street, Wethersfield, CT 06109; Mr. John L. O'Connell State of Connecticut Department of Motor Vehicles State Street Wethersfield CT 06109; Dear Mr. O'Connell: This is in response to your letters of June 24, 1975, and May 30, 1975 regarding Federal Motor Vehicle Safety Standards Nos. 217 and 205. Please excuse our delay in answering your questions.; In your letter of June 24, 1975, you asked whether Standard No. 21 applies to school buses, and if so, whether Connecticut's regulations concerning emergency exits for school buses are in conflict with the Federal standard. By notice published in the Federal Register on January 27, 1976 (41 FR 3871) Federal Motor Vehicle Safety Standard No. 217, *Bus Window Retention and Release*, 49 CFR 571.217, was amended to specify requirements for emergency doors for school buses, pursuant to the provisions of Section 202 of the Motor Vehicle and Safety Amendments of 1974 (Pub. L. 93-492, 88 Stat. 1484, 15 U.S.C. 1392).; Since Standard No. 217, as amended, applies to school buses, effectiv October 26, 1976, any State regulations which differ are voided by S103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1392(d)). The Connecticut regulations are, therefore, preempted by Standard No. 217, since S103(d) requires the State regulations to be identical' to the Federal standard.; It should be noted, however, that while the State of Connecticut ma not issue a regulation which differs from similarly applicable Federal Motor Vehicle Safety Standard requirements, Connecticut (or any of its political subdivisions) may in its own contracts for school bus purchases require more stringent specifications, as long as the Federal minimum requirements are met.; In your letter of May 30, 1975, you asked whether Lucite AR and othe similar rigid plastics are allowed for use as side windows of buses under Standard No. 205, even though S5.1.2.1 does not list the use for Item 12' rigid plastics.; Item 12' is a classification created by the NHTSA for rigid plastic which comply with all tests required of Item 5' rigid plastics as defined in ANS Z26, with the exception of the test for resistance to undiluted denatured alcohol. Paragraph S5.1.2.1, Item 12 - *Rigid plastics*, provides that Item 5' safety plastic materials may be used in motor vehicles *only* in the locations specified, at levels not requisite for driving visibility. These locations include Standee windows in buses' and readily removable windows'. However, there is no provision in S5.1.2.1 which allows the use of Item 12' plastic materials for fixed, side windows in buses.; Standard No. 205 defines readily removable windows in buses having GVWR of more that 10,000 pounds to include pushout windows and windows mounted in emergency exits that can be manually pushed out of their location in the vehicle without the use of tools, whether or not one side remains hinged to the vehicle. Rigid plastics can only be used for side windows in buses if the side window is a readily removable window as defined by S5.1.1.4 or a standee window.; I hope this letter clarifies your questions concerning Standard Nos 217 and 205. Please contact us if we can be of any further assistance.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2210OpenMr. John L. O'Connell, State of Connecticut, Department of Motor Vehicles, State Street, Wethersfield, CT 06109; Mr. John L. O'Connell State of Connecticut Department of Motor Vehicles State Street Wethersfield CT 06109; Dear Mr. O'Connell: This is in response to your letters of June 24, 1975, and May 30, 1975 regarding Federal Motor Vehicle Safety Standards Nos. 217 and 205. Please excuse our delay in answering your questions.; In your letter of June 24, 1975, you asked whether Standard No. 21 applies to school buses, and if so, whether Connecticut's regulations concerning emergency exits for school buses are in conflict with the Federal standard. By notice published in the Federal Register on January 27, 1976 (41 FR 3871) Federal Motor Vehicle Safety Standard No. 217, *Bus Window Retention and Release*, 49 CFR 571.217, was amended to specify requirements for emergency doors for school buses, pursuant to the provisions of Section 202 of the Motor Vehicle and Safety Amendments of 1974 (Pub. L. 93-492, 88 Stat. 1484, 15 U.S.C. 1392).; Since Standard No. 217, as amended, applies to school buses, effectiv October 26, 1976, any State regulations which differ are voided by S103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1392(d)). The Connecticut regulations are, therefore, preempted by Standard No. 217, since S103(d) requires the State regulations to be 'identical' to the Federal standard.; It should be noted, however, that while the State of Connecticut ma not issue a regulation which differs from similarly applicable Federal Motor Vehicle Safety Standard requirements, Connecticut (or any of its political subdivisions) may in its own contracts for school bus purchases require more stringent specifications, as long as the Federal minimum requirements are met.; In your letter of May 30, 1975, you asked whether Lucite AR and othe similar rigid plastics are allowed for use as side windows of buses under Standard No. 205, even though S5.1.2.1 does not list the use for 'Item 12' rigid plastics.; 'Item 12' is a classification created by the NHTSA for rigid plastic which comply with all the tests required of 'Item 5' rigid plastics as defined in ANS Z26, with the exception of the test for resistance to undiluted denatured alcohol. Paragraph S5.1.2.1, Item 12 - *Rigid plastics*, provides that 'Item 5' safety plastic materials may be used in motor vehicles *only* in the locations specified, at levels not requisite for driving visibility. These locations include 'Standee windows in buses' and 'readily removable windows'. However, there is no provision in S5.1.2.1 which allows the use of 'Item 12' plastic materials for fixed, side windows in buses.; Standard No. 205 defines readily removable windows in buses having GVWR of more than 10,000 pounds to include pushout windows and windows mounted in emergency exits that can be manually pushed out of their location in the vehicle without the use of tools, whether or not one side remains hinged to the vehicle. Rigid plastics can only be used for side windows in buses if the side window is a readily removable window as defined by S5.1.1.4 or a standee window.; I hope this letter clarifies your questions concerning Standard Nos 217 and 205. Please contact us if we can be of any further assistance.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5426OpenMr. John G. Klinge Executive Vice President Visibility Lighting Systems P.O. Box 494 Southport, CT 06490; Mr. John G. Klinge Executive Vice President Visibility Lighting Systems P.O. Box 494 Southport CT 06490; "Dear Mr. Klinge: This responds to your inquiry about whether a warnin light device you manufacture would comply with Federal Motor Vehicle Safety Standard No. 125, Warning devices (49 CFR 571.125). Promotional literature accompanying your letter indicates that the 'Lightman' is a flashing, battery operated device that is 3 1/2 inches wide by 1 1/2 inches high. You stated that you plan to market this product as a warning light source for use by truck fleets and commercial auto fleets. I am pleased to have this opportunity to explain our regulations to you. By way of background information, Congress has authorized this agency, the National Highway Traffic Safety Administration (NHTSA), to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. (49 U.S.C. 30101 et seq.) We have exercised this authority to establish Standard No. 125. NHTSA has no authority to approve, certify, or otherwise endorse any commercial product. Instead, Congress has established a self-certification process under which each manufacturer is required to certify that each of its products meets all applicable Federal Motor Vehicle Safety Standard. Please note that Standard No. 125 applies to 'devices, without self-contained energy sources, that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.' (Emphasis added, see section S3 of the standard.) In other words, Standard No. 125 does not apply to warning devices with self-contained energy sources. In previous interpretations, the agency has determined that the phrase 'self-contained energy sources' includes such things as battery powered lights. Accordingly, a warning device which consists of a battery operated flashing light would not be subject to Standard No. 125. In a July 20, 1994 conversation with Mr. Marvin Shaw of my staff, you asked about the use of your product by commercial vehicle operators. Please be aware that NHTSA has the authority to regulate the manufacture but not the use of warning devices. As Mr. Shaw explained, you may wish to contact the Federal Highway Administration (FHWA) which is authorized to regulate some motor vehicle operators and vehicle operations. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Mr. Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack 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.