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: aiam2709OpenMr. Terry A. Lowe, Vice President, Lowe Machine Company, State Route #2, Rural Route #3, Oak Harbor, OH 43449; Mr. Terry A. Lowe Vice President Lowe Machine Company State Route #2 Rural Route #3 Oak Harbor OH 43449; Dear Mr. Lowe: This responds to your October 12, 1977, letter asking what regulation apply to you in your capacity as an alterer of motor vehicles. The National Highway Traffic Safety Administration (NHTSA) promulgates safety standards for motor vehicles. The agency requires persons who alter motor vehicles prior to their first purchase for purposes other than resale to attach a label to each vehicle indicating that it continues to comply with all applicable safety standards. Therefore, if the modification that you intend to perform occurs prior to the first purchase of the vehicle for purposes other than resale, you would be required to attach such a label. I am enclosing a copy of Part 567, *Certification* (Volume 49 of the Code of Federal Regulations, Part 567) which addresses the responsibilities of vehicle alterers.; If you modify vehicles after their first purchase for purposes othe than resale, then you need not attach a certification or alterer's label. However, section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) (15 U.S.C. 1381 *et seq*.) prohibits any repair business, dealer, distributor, or manufacturer from rendering inoperative any device or element of design installed on a vehicle in compliance with a safety standard. If your manufacturing operation affected the compliance of any aspect of the vehicle with safety standards in effect on the date of the vehicle's manufacture, you would be in violation of the Act and subject to civil penalties prescribed thereunder.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam2921OpenMr. Dominic S. Piacenza, Franklin Pierce Law Center, 2 White Street, Concord, NH 03301; Mr. Dominic S. Piacenza Franklin Pierce Law Center 2 White Street Concord NH 03301; Dear Mr. Piacenza: This is in response to your letter of November 9, 1978, asking whethe a memorandum of understanding exists between the National Highway Traffic Safety Administration (NHTSA) and the Federal Trade Commission (FTC) concerning the apparent overlapping jurisdiction regarding tire marketing practices created by Section 203 of the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act)(15 U.S.C. 1423). You ask whether NHTSA's jurisdiction extends solely to safety- related issues.; NHTSA's authority is not confined solely to the area of motor vehicl and traffic safety. For example, under the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901) the agency has been given authority over the areas of fuel economy and economic losses to consumers as they relate to automobiles. While the Safety Act is primarily concerned with safety issues, Section 203 of that law does provide NHTSA with limited authority over tire marketing practices. The Uniform Tire Quality Grading Standards (49 CFR 575.104), issued by NHTSA under the authority of Section 203, provide information to consumers in tire performance areas relating to both safety and economic issues.; While the FTC is aware of and supports NHTSA's efforts in the field o tire grading, no memorandum of understanding exists with regard to the scope of NHTSA's activities. Section 205 of the Safety Act (15 U.S.C. 1425) does state that, in the event of conflict between orders or regulations issued under the Safety Act concerning motor vehicle tires and FTC orders or interpretations, the orders or regulations issued under the Safety Act shall prevail.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam2922OpenMr. Dominic S. Piacenza, Franklin Pierce Law Center, 2 White Street, Concord, NH 03301; Mr. Dominic S. Piacenza Franklin Pierce Law Center 2 White Street Concord NH 03301; Dear Mr. Piacenza: This is in response to your letter of November 9, 1978, asking whethe a memorandum of understanding exists between the National Highway Traffic Safety Administration (NHTSA) and the Federal Trade Commission (FTC) concerning the apparent overlapping jurisdiction regarding tire marketing practices created by Section 203 of the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act)(15 U.S.C. 1423). You ask whether NHTSA's jurisdiction extends solely to safety- related issues.; NHTSA's authority is not confined solely to the area of motor vehicl and traffic safety. For example, under the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901) the agency has been given authority over the areas of fuel economy and economic losses to consumers as they relate to automobiles. While the Safety Act is primarily concerned with safety issues, Section 203 of that law does provide NHTSA with limited authority over tire marketing practices. The Uniform Tire Quality Grading Standards (49 CFR 575.104), issued by NHTSA under the authority of Section 203, provide information to consumers in tire performance areas relating to both safety and economic issues.; While the FTC is aware of and supports NHTSA's efforts in the field o tire grading, no memorandum of understanding exists with regard to the scope of NHTSA's activities. Section 205 of the Safety Act (15 U.S.C. 1425) does state that, in the event of conflict between orders or regulations issued under the Safety Act concerning motor vehicle tires and FTC orders or interpretations, the orders or regulations issued under the Safety Act shall prevail.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam1440OpenMr. Kanti Gada, Project Engineer, Great Dane Trailers, Inc., P.O. Box 67, Savannah, GA 31402; Mr. Kanti Gada Project Engineer Great Dane Trailers Inc. P.O. Box 67 Savannah GA 31402; Dear Mr. Gada: This responds to your November 1, 1973, letter and subsequen communication with Mr. Sidney Williams of the NHTSA Handling and Stability Division concerning the conformity of your trailers with Standard 121. You asked particularly about the diversion of service reservoir air for use in the air suspension unit, the location of the service reservoir check valve, and test conditions for extendable platform trailers. This will also acknowledge receipt of your March 14, 1974, petition for longer application and release time for special length trailers.; The NHTSA has not issued any prohibition on the use of service brak system air in auxiliary systems such as windshield wipers and air suspensions. You may tap air from the system as long as the system still meets all the requirements listed - in particular the ability of the reservoir, when pressurized to 90 psi, to release the vehicle's parking brakes at least once.; The check valve may be placed at the isolated tank to protect th trailer service reservoir as specified in S5.2.1.5, as you have detailed it in your schematic drawing.; With regard to extendable platform trailers, they should be certifie in the most adverse configuration. No special configuration has been specified, and the NHTSA is free to test the vehicle at any length at which it is designed to operate.; The Fruehauf Corporation has also petitioned for relief from th application and release time requirement as it applies to extendable trailers. These petitions are under consideration and will be answered when that consideration is complete.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3291OpenW. Brusstar, Legal Staff, General Motors Corp., 14-242 GM Building, Detroit, MI 48202; W. Brusstar Legal Staff General Motors Corp. 14-242 GM Building Detroit MI 48202; Dear Mr. Brusstar: This is in response to your telephone call of May 23, 1980, to Kath DeMeter of my staff concerning odometer information on state certificates of title.; The following states have odometer statements on their motor vehicl titles that are consistatnt (sic) with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted titles to the agency askin for approval but had inacceptable statements. Each was informed that if they supplied certain additional information their titles would be in conformance. We do not know whether that information was included on the titles:; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah Wisconsin<<<; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1 notice, a copy of which is enclosed.; You also asked what the agency policy is with respect to enforcemen actions against transferors of vehicles who complete an odometer statement appearing on a state title that does not satisfy the federal requirements. You specifically requested an interpretation that we would refuse prosecution. Unfortunately we cannot grant the desired interpretation. It is our enforcement policy in those states where the title contains an odometer disclosure statement which complied with the origianl Federal regulation, to decline any enforcement action against an *individual owner* in the course of a *private sale* for executing the form on the state title in lieu of the current federal form.; Sincerely, John Womack, Assistant Chief Counsel |
|
ID: aiam3275OpenMr. Philip J. Carpenter, Administrative Engineer, Miller Tilt-Top Trailer, Inc., 450 S. 992 Street, P.O. Box 14247, Milwaukee, Wisconsin 53214; Mr. Philip J. Carpenter Administrative Engineer Miller Tilt-Top Trailer Inc. 450 S. 992 Street P.O. Box 14247 Milwaukee Wisconsin 53214; Dear Mr. Carpenter: This is in response to your letter of April 2, 1980, in which yo request approval for the vehicle identification numbering (VIN) system Miller Tilt-Top Trailer, Inc., proposes to use to satisfy the requirements of Federal Motor Vehicle Safety Standard 115 (49 CFR 571.115).; The National Highway Traffic Safety Administration does not approve manufacturer's compliance with the safety standard, as manufacturers serve as self-certifiers under the National Traffic and Motor Vehicle Safety Act. However, my office has reviewed your proposed system. Based on our understanding of the information that you have provided, your system apparently complies with Standard No. 115. We would also recommend that when you submit information to the agency pursuant to S6 of the standard, you follow each 'series' designation (4th and 5th characters of the VIN) with the phrase 'rectangular, flat platform trailer and body.'; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam4360OpenMr. Y. Koyama, Niles Parts Company, Ltd., 4-9-16 Higashikojiya, Ota-Ku (144), Tokyo, Japan; Mr. Y. Koyama Niles Parts Company Ltd. 4-9-16 Higashikojiya Ota-Ku (144) Tokyo Japan; Dear Mr. Koyama: We refer to your letter of March 15, 1978, concerning the testing o hazard warning and turn signal operating units (switches) in accordance with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.; The purpose of requiring 3-inch wire leads on any operating unit durin testing is to permit the measurement of any voltage drop across a connector in the circuit. Since the connector is an integral part of your type of operating unit with its 'terminal-direct' connection system, the wire leads are not necessary. We, therefore, interpret the society of Automotive Engineers Standards J589 and J910, covering Hazard Warning and Turn Signal Operating Units respectively, to require 3-inch wire test leads only on those units that are supplied with integral wire leads. During the prescribed tests, voltage measurements on units such as those that you provide shall be made at the electrical contacts on the units.; Sincerely, Michael M. Finkelstein, Acting Associate Administrator fo Rulemaking; |
|
ID: aiam2846OpenMr. Glenn Abbott, Cars & Concepts, Inc., 12500 E. Grand River, Brighton, MI 48116; Mr. Glenn Abbott Cars & Concepts Inc. 12500 E. Grand River Brighton MI 48116; Dear Mr. Abbott: This is in response to your letter dated June 27, 1978, asking whethe fog lamps mounted to the surface of a vehicle bumper are removed prior to testing for compliance with Part 581, *Bumper Standard*.; Vehicles subject to the requirements of Part 581 must comply with th protective criteria of section 581.5(c) (49 CFR 581.5(c)) when tested under the conditions stated in section 581.6 (49 CFR 581.6). The test conditions make no provision for removal of fog lamps prior to testing. As was the case under Federal Motor Vehicle Safety Standard 215, *Exterior Protection*, the Part 581 test procedures provide for removal only of trailer hitches before testing. With the added exception of license plate brackets, excluded from the requirements of Part 581 by interpretation (42 FR 24056, May 12, 1977), other equipment (including fog lamps) attached to the bumper system prior to sale of the vehicle to its first purchaser must meet the damage limitations of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam3226OpenMr. Brian O'Meara, President & General Manager, O'Meara Ford Center, 400 West 104th Avenue, Denver, CO 80234; Mr. Brian O'Meara President & General Manager O'Meara Ford Center 400 West 104th Avenue Denver CO 80234; Dear Mr. O'Meara: This responds to your February 26, 1980, letter asking about the prope certification for a Ford Mustang that has been converted to a convertible. You ask what certification is required before you would be permitted to sell such a vehicle.; The National Highway Traffic Safety Administration requires al manufacturers of motor vehicles to certify that their vehicles comply with Federal safety standards prior to first sale. In the case of the vehicle that you mention, Ford Motor Company would have certified it when it was sold to the company that converted it to a convertible. Ford's certification label is located on the driver's door or pillar post.; The company that converted the vehicle, Tomaso of America, i responsible for putting its own label on the vehicle indicating that as altered the vehicle continues to comply with the applicable Federal safety standards. The requirements for alterers' labels are located in Title 49 of the Code of Federal Regulations, Section 567.7. Tomaso's label should also be located on the vehicle in the same area as Ford's.; If both of the labels are on the vehicle, it is legal for you to sel it. If either of the labels is missing from the vehicle, then the vehicle is not correctly certified and may be in noncompliance with the safety standards.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam3227OpenMr. Brian O'Meara, President & General Manager, O'Meara Ford Center, 400 West 104th Avenue, Denver, CO 80234; Mr. Brian O'Meara President & General Manager O'Meara Ford Center 400 West 104th Avenue Denver CO 80234; Dear Mr. O'Meara: This responds to your February 26, 1980, letter asking about the prope certification for a Ford Mustang that has been converted to a convertible. You ask what certification is required before you would be permitted to sell such a vehicle.; The National Highway Traffic Safety Administration requires al manufacturers of motor vehicles to certify that their vehicles comply with Federal safety standards prior to first sale. In the case of the vehicle that you mention, Ford Motor Company would have certified it when it was sold to the company that converted it to a convertible. Ford's certification label is located on the driver's door or pillar post.; The company that converted the vehicle, Tomaso of America, i responsible for putting its own label on the vehicle indicating that as altered the vehicle continues to comply with the applicable Federal safety standards. The requirements for alterers' labels are located in Title 49 of the Code of Federal Regulations, Section 567.7. Tomaso's label should also be located on the vehicle in the same area as Ford's.; If both of the labels are on the vehicle, it is legal for you to sel it. If either of the labels is missing from the vehicle, then the vehicle is not correctly certified and may be in noncompliance with the safety standards.; Sincerely, Frank Berndt, 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.