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: aiam1081OpenMr. T. Hiramine, Director, Takata Kojyo Co., Ltd., No. 10 Mori Building, 28 Sakuragawa-Cho, Nishikubo, Shiba, Minato-Ku, Tokyo, Japan; Mr. T. Hiramine Director Takata Kojyo Co. Ltd. No. 10 Mori Building 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan; Dear Mr. Hiramine: Thank you for your letter of February 24, 1973, to Mr. Franci Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.; Your first question, referenced to Figure No. 1 of the enclosure wit your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard N0. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.; Your second question, referenced to Figure 2 of the enclosure, relate to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), equivalent hardware' is permissible in lieu of the 7/16 inch bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than on the individual components (bolts).; With respect to your third question, concerning the acceptability o belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in *Ford* v. *NHTSA*, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1080OpenMr. T. Hiramine, Director, Takata Kojyo Co., Ltd., No. 10 Mori Building, 28 Sakuragawa-Cho, Nishikubo, Shiba, Minato-Ku, Tokyo, Japan; Mr. T. Hiramine Director Takata Kojyo Co. Ltd. No. 10 Mori Building 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan; Dear Mr. Hiramine: Thank you for your letter of February 24, 1973, to Mr. Franci Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.; Your first question, referenced to Figure No. 1 of the enclosure wit your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard No. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.; Your second question, referenced to Figure 2 of the enclosure, relate to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), 'equivalent hardware' is permissible in lieu of the 7/16 inch bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than on the individual components (bolts).; With respect to your third question, concerning the acceptability o belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in *Ford* v. *NHTSA*, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars,; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1975OpenMs. Connie R. Gale, Chrysler Corporation, P.O. Box 1919, Detroit, MI 48231; Ms. Connie R. Gale Chrysler Corporation P.O. Box 1919 Detroit MI 48231; Dear Ms. Gale: This is in response to your letter of June 11, 1975, requesting a interpretation of Part 567 with respect to whether or not Chrysler should affix a certification label to an incomplete vehicle prior to shipping the vehicle to an outside vendor for body work.; It appears from your letter that there is some misunderstandin regarding the certification requirements applicable to manufacturers of incomplete vehicles. Section 567.4, to which you refer in your letter, is not applicable to vehicles manufactured in two or more stages. However, Section 567.5(c) provides that if an incomplete vehicle manufacturer assumes legal responsibility for all duties and liabilities imposed by the Act, as provided for in Section 568.7(a), then the incomplete vehicle manufacturer must ensure that a certification label is affixed to the final vehicle with the incomplete vehicle manufacturer's name after the words 'MANUFACTURED BY' or 'MFD BY'. The date to be included on this label must follow the words 'INCOMPLETE VEHICLE MANUFACTURED' or 'INC VEH MFD' and is the '[m]onth and year in which the original manufacturer of the incomplete vehicle performed his last manufacturing operation on the incomplete vehicle . . ..' (Section 567.5(a)(4)). The date as of which the manufacturer certifies that the vehicle conforms to applicable safety standards is any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture. (Section 567.5(a)(7)).; The regulations do not specify a date on which the certification labe must be affixed. However Section 114 of the Traffic Safety Act provides that the label must be on the vehicle at the time of its delivery by the manufacturer to the distributor or dealer.; We trust that the above explanation will provide you with the guidanc that you need. If you have any further questions, please let us know.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam4428OpenMr. Dave Anderson Sales Manager Gist Ornamental Iron Works, Inc. l2l27 Woodside Avenue Lakeside, CA 92040; Mr. Dave Anderson Sales Manager Gist Ornamental Iron Works Inc. l2l27 Woodside Avenue Lakeside CA 92040; Dear Mr. Anderson: This responds to your letter about Federa requirements for trailers. According to your letter, you are in the planning stages of becoming a manufacturer of, and dealer for, automobile trailers. The trailers would hitch to the back of automobiles and be designed to carry cargo. You noted that in response to an earlier inquiry, you received a copy of the handout entitled 'Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' You stated that you are unclear just how this applies to automobile trailers. You asked what you need to do to comply with any applicable Federal regulations, and what regulations apply to trailers of the kind you plan to build. Trailers are considered motor vehicles under Federal law. As a manufacturer of motor vehicles, you would be required to submit identification information to the National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566, Manufacturer Identification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. The procedure is specified in 49 CFR Part 567. The following safety standards apply to trailers: Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, Safety Standard No. 115, Vehicle Identification Number--Basic Requirements, Safety Standard No. ll9, New Pneumatic Tires for Vehicles Other Than Passenger Cars, Safety Standard No. l20, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, trailers with certain braking systems must meet Safety Standard No. l06, Brake Hoses, Safety Standard No. 116, Motor Vehicle Brake Fluids, and Safety Standard No. l2l, Air Brake Systems. All of these safety standards are found in 49 CFR Part 57l. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam3270OpenMr. Woody Fitzmaurice, Supervisor, Pupil Transportation, State of Missouri, P.O. Box 480, Jefferson City, MO 65102; Mr. Woody Fitzmaurice Supervisor Pupil Transportation State of Missouri P.O. Box 480 Jefferson City MO 65102; Dear Mr. Fitzmaurice: This responds to your recent letter asking whether the State o Missouri has authority under Federal law to specify location requirements for fuel tanks on school buses.; Section 103(d) of the National Traffic and Motor Vehicles Safety Act as amended 1974 (15 U.S.C. 1392(d)) preempts, with one exception, State motor vehicle safety standards of general applicability that are not identical to a Federal safety standard governing the same aspect of motor vehicles performance. Thus, Federal Motor Vehicle Safety Standard No. 301, *Fuel System integrity* (49 CFR 571.301), would preempt State requirements of general applicability governing the same aspect of performance as Standard No. 301. The specification of tank location in the Missouri requirements is intended to insure the integrity of the vehicle fuel system and, therefore, would be regarded by the agency as relating to the same aspect of performance as the barrier impact tests of Standard No. 301. In developing the performance requirements of the standard, the agency did not intend to regulate the location of fuel tanks.; The second sentence of section 103(d) of the Act clarifies that th limitation State safety regulations of general applicability does not prevent governmental entities from specifying additional safety features in vehicles purchased for their own use. Thus, the State of Missouri or its political subdivisions such as the Board of Education could specify additional fuel system requirements, such as tank location, in the case of public school buses, but not in the case of commercial buses. The State requirements are not permitted, however, to prevent the school bus or equipment from complying with applicable safety standards. Therefore, the school bus manufacturer would have to comply with Safety Standard No. 301 regardless of the State requirements.; I hope this has answered all of your questions. However, if you requir further information, please contact Hugh Oates of my staff (202-426-2992); Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0032OpenMr. David Busby, Busby and Rivkin, 1001 Connecticut Ave., N.W., Washington, D.C., 20036; Mr. David Busby Busby and Rivkin 1001 Connecticut Ave. N.W. Washington D.C. 20036; Dear Mr. Busby: In your letter of July 13, 1967, you requested clarification of severa issues relating to the location and size of turn signals as specified in the Initial Federal Motor Vehicle Safety Standards. Initial Standard No. 108, entitled, 'Lamps, reflective Devices, and Associated Equipment - Multipurpose Passenger Vehicles, Trucks, Trailers, and Buses, 80 or More Inches Wide Overall,' specifies that turn signal lamps shall conform to Class A of SAE Standard J588d. As stated in the enclosures to your letter, SAE Standard J588d specifies that the optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This requirement of the SAE Standard is addressed to a single lamp with only one bulb. For a combination of lamps, such as that shown on the sketch enclosed with your letter, the intent of this requirement could be met if the optical center produced by the two bulbs is outside the 4-inch limit. The location of this optical center must be determined from laboratory test data, which was not presented in your letter.; *Proposed* Initial Standard No. 112, entitled, 'Lamps, Reflectiv Devices, and Associated Equipment - Passenger Cars, Motorcycles, and Multipurpose Passenger Vehicles, Trucks, Trailers, and Busses of less than 80 Inches Wide Overall,' would permit the use of Class B (SAE J588d) turn signal lamps until January 1, 1969. Under this provision, lamp No. 1 on your sketch would conform to the 4-inch spacing requirement. Combining lamp no. 1 and No. 2 to obtain a Class A Area would again result in the situation previously described with respect to location of the optical center.; Since your letter makes frequent reference to 'cars,' we assume tha you are primarily interested in the requirements of Standard No. 112. In this respect, we would caution you that the requirements specified therein are presently only proposed requirements, and are subject to change prior to issuance of the final standard.; Thank you for your interest in the motor vehicle safety standards. Sincerely yours, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam0668OpenMr. Vernon R. Verjinsky, Street Superintendent, Department of Engineering, 441 West Grand Avenue, Wisconsin Rapids, WI 54494; Mr. Vernon R. Verjinsky Street Superintendent Department of Engineering 441 West Grand Avenue Wisconsin Rapids WI 54494; Dear Mr. Verjinsky: Mr. Carter has asked me to reply to your letter of March 3, 1972, i which you ask who has the responsibility for certification of vehicles manufactured in two or more stages.; Paragraph 567.5(a) of Title 49 of the Code of Federal Regulation states, '. . . Except as provided in paragraphs (b) and (c) of this section, each final-stage manufacturer, as defined in S 568.3 of this chapter, of a vehicle manufactured in two or more stages shall affix to each vehicle a label, of the type and in the manner and form described . . . .' Paragraphs (b) and (c) are concerned with incomplete and intermediate manufacturers who assume legal responsibility for all duties and liabilities imposed by the National Traffic and Motor Vehicle Safety Act of 1966 (the Act), with respect to the vehicle as finally manufactured.; Paragraph 568.3 states, ''Final- stage' manufacturer means a person wh performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle.'; The subject is also dealt with in the Preamble to Part 568 - Vehicle Manufactured in Two or More Stages. ' . . . By its definition, a completed vehicle is one that requires no further manufacturing operations in order to perform its intended function other than the attachments of readily attachable components and minor finishing operations. If a manufacturer installs a component that is not readily attachable, such as a fifth wheel, then he is a final-stage manufacturer even though his contribution to the overall vehicle may appear small . . .; 'In the event that a 'readily attachable component' is a componen regulated by the standards, such as a mirror or a tire, the final-stage manufacturer must assume responsibility and certify the vehicle even though he does not install the particular component. Otherwise, the installer of mirrors and tires would be considered a final-stage manufacturer, a status that he would probably find unacceptable and that would tend to make certification less meaningful . . . .'; I am enclosing Parts 567 and 568 of Title 49 of the Code of Federa Regulations. If you have further questions I will be pleased to answer them.; Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam3746OpenMr. Jeffrey A. Crawford, Q.A. Manager, Lyn-Mont Manufacturing Co., P.O. Box 11745, 4208 Clubview Drive, Fort Wayne, IN 46860; Mr. Jeffrey A. Crawford Q.A. Manager Lyn-Mont Manufacturing Co. P.O. Box 11745 4208 Clubview Drive Fort Wayne IN 46860; Dear Mr. Crawford: This responds to your letter concerning Safety Standard No. 106, *Brak Hoses*. You asked whether certain proposed labeling for brake hose assemblies would meet the labeling requirements of sections S7.2.3 and S7.2.3.1. As discussed below, the answer to your question is no.; By way of background information, this agency does not provid approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its products comply with applicable safety standards. The following opinion is based on the facts provided in your letter.; Sections S7.2.3 and S7.2.3.1 provide two options for the labeling o air brake hose assemblies made with end fittings that are attached by crimping or swaging. Section S7.2.3 states that such assemblies, except those assembled and installed by a vehicle manufacturer in vehicles manufactured by him, shall be labeled by means of a band around the brake hose assembly as specified in that paragraph, or, at the option of the manufacturer, by means of labeling as specified in section S7.2.3.1.; If the first option is chosen, using a band as specified in sectio S7.2.3, the band must include (a) the symbol DOT, and (b) the manufacturer designation. If the second option, specified in section S7.2.3.1, is chosen, the manufacturer designation must be placed on at least one end fitting of the assembly. (These sections also specify other requirements concerning labeling, such as size of letters, which are not relevant to this interpretation.); Your proposed labeling, placing the manufacturer designation on th band and the symbol DOT on the end fitting, would not meet the requirements of either of these options. If the first option is chosen, the symbol DOT must be placed on the band along with the manufacturer designation. If the second option is chosen, the manufacturer designation must be placed on the end fitting.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4964OpenHerrn. Westermann u. Schmidt Hella KG Hueck & Co. Rixbecker Stra e 75 Postfach 2840 4780 Lippstadt Germany; Herrn. Westermann u. Schmidt Hella KG Hueck & Co. Rixbecker Stra e 75 Postfach 2840 4780 Lippstadt Germany; "Gentlemen: This responds to your FAX of December 9, 1991, to Richar Van Iderstine of this agency. You ask for a definition of two and four headlamp systems, stating that formerly 'this definition was done under para. S4.1.1.36, but today there only remains figure 26, which explains the application of photometric requirements with respect to the bulb or bulb combination used.' You have enclosed sketches of three replaceable bulb headlighting systems and ask for confirmation that each is a two or four headlamp system under Standard No. 108. Standard No. 108 has never contained a specific definition of two or four lamp headlamp systems. Paragraph S4.1.1.36 impliedly defined these systems for headlamps incorporating replaceable bulbs by specifying requirements for the upper and lower beams of headlamp systems consisting of two or four lamps, each containing one or two standardized replaceable light sources. When Standard No. 108 was amended to delete S4.1.1.36, these provisions became part of new paragraph S7.5 Replaceable Bulb Headlamp System. Figure 26 Table of Photometric Requirements was added to illustrate photometric requirements for headlighting systems that use combinations of replaceable bulbs listed in S7.6 Standardized Replaceable Light Sources, and as the systems are described in S7.5. The understanding expressed in your drawings of replaceable bulb headlamp systems is correct. A 4-lamp system is one in which each lamp contains one light source, usually HB3 or HB4 light source for a total of two HB3 and HB4 light sources per system. A 2-lamp system is one in which each lamp typically contains a single dual filament light source such as HB1 or HB5, and achieves both a lower beam and an upper beam, alternatively, each lamp may contain two light sources, typically one HB3 and one HB4 light source, each with individual reflectors, but together with a common housing and lens. This lamp achieves both a lower and an upper beam. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1346OpenMr. W. H. Wendelin, Sr., Quality Control Manager, Streamline Division, 1213 West Main Street, Thorntown, IN 46701; Mr. W. H. Wendelin Sr. Quality Control Manager Streamline Division 1213 West Main Street Thorntown IN 46701; Dear Mr. Wendelin: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 41 - 1973 SL, Regency Imperial, and Crown Imperial Travel Trailers. Possibility that the 3/8 inch copper tube lines from the gas manifold to all appliances may have a defect thereby causing gas leakage, which may allow for a possible fire hazard.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *73-0224*. The first quarterly status report for this campaign is required to be submitted by February 5, 1974.; Please refer to the above number in all future correspondenc concerning this campaign.; In addition, the letter which you have sent to the first purchaser does not meet the requirements of 49 CFR Part 577 (copy enclosed) in the following respects. It does not contain the specific statements required by sections 577.4(a) and (b)(1). Your reference to a 'possible' safety hazard, moreover, is not permitted under paragraph 577.4(b)(1). We do not consider your letter to adequately describe the malfunction, as required by sections 577.4(c)(1) and (c)(2). You do not, for example, indicate the effect or possible consequence of an 'improper flare' on a gas line. Nor do you state any precautions the owner can take to reduce the likelihood of the malfunction occurring as required by 577.4(c)(4). Your letter fails completely to evaluate the risk to traffic safety as required by section 577.4(d). Finally, we consider your reference to 'no reported related failures' to be a disclaimer prohibited by section 577.6.; It is necessary for you to revise this letter as we have indicated an to provide this office and the owners with a copy of the revised letter.; Failure to comply with this regulation can result in the imposition o civil penalties and injunctive sanctions.; If you desire further information, please contact Messrs. James Murra or Marx Elliott of this office (202) 426- 2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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.