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: aiam1444OpenMr. Bruce J. Motyka, 2030 Laura Lane, Des Plaines, Illinois 60018; Mr. Bruce J. Motyka 2030 Laura Lane Des Plaines Illinois 60018; Dear Mr. Motyka: This is in reply to your letter of March 11, 1974, asking fo suggestions regarding problems you have experienced with your pickup truck-camper unit.; It appears from your letter that no violations of Federal requirement have occurred. Motor Vehicle Safety Standard No. 126 and its companion Consumer Information requirement (49 CFR S575.103) about which we wrote to you through Senator Percy's office did not become effective until January 1, 1973, well after the time you bought your vehicle. Moreover, it is not correct to characterize the dealer who sold you the unit as a 'final-stage manufacturer.' Under NHTSA requirements a pickup truck is a completed vehicle, and a person who installs a slide-in camper into the cargo area of a truck does not become a manufacturer. While this is not the case with chassis-mount campers, it is with respect to slide-in campers.; I suggest that if you wish to proceed further you consult an attorney who would be able to best assess your chances of success in civil litigation. The dealer's employee who told you that the 'GVW plate meant nothing' was mistaken. The weight ratings provided on the plate represent the manufacturer's representation of the maximum safe weight of a fully loaded vehicle.; You might wish to examine the labels attached, pursuant to Standard No 126 and 49 CFR S575.103, to later models of both the pickup truck and camper you purchased. It os possible that those models and the ones you purchased are not substantially different. If that is the case the information on the labels can provide an indication of the extent that the weight ratings were exceeded by installation of the camper unit in question.; While I regret we cannot be of further assistance I wish you success i your efforts to solve this problem.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2682OpenMr. Donald H. Carter, 300 W. 11th Street, Reno, Nevada 89503; Mr. Donald H. Carter 300 W. 11th Street Reno Nevada 89503; Dear Mr. Carter: This is in response to your letters of August 24, 1977, and October 8 1977, concerning your Ford F-150 pickup truck.; The November 1976 date on your truck's certification label refers onl to the date of actual manufacture of the vehicle, not its model year. Virtually all manufacturers, including Ford, utilize a model year which does not correspond to the calender year. Typically, for American manufacturers, this model year begins on September 1 of the previous calender year, i.e., model year 1977 began on September 1, 1976. Manufacturers usually begin manufacture of their vehicles as early as July in order to have sufficient vehicles in their showroom by September start of the model year.; All Federal motor vehicle safety standards specify a date on whic their requirements become effective. Thus, the manufacturer must indicate by the certification label that its vehicles are in compliance with all Federal standards in effect on the date of the vehicles' manufacture. Whether a vehicle is marketed as a particular model year vehicle depends upon the manufacturer's own marketing practice. the certification date does not represent the model year date.; Finally, your first letter stated that your vehicle was ordered o November 4, 1976, with a 3 month delivery interval. Every manufacturer produced a large number of vehicles before there are orders for a specific vehicle, and maintains them in various storage locations around the country. When the manufacturer receives and order from a dealership for a specific vehicle, it will first determine whether it already has such a vehicle in stock, and if it does, it will ship that vehicle rather than specially manufacture a new vehicle.; However, if there is no identical vehicle in stock, it wil manufacturer one specifically for that order, which can take from a few days to several months to program into the assembly line and produce. As a dealership has no way to know in advance whether the vehicle it ordered is in stock or will have to be specially manufactured, it will often state a delivery date that anticipates the longest possible delay which would result from special manufacture. There is thus no reason for concern over the fact that your vehicle was manufactured in the same month it was ordered. Either Ford had such a vehicle in stock, or it was able to manufacture one with very little delay.; I hope that this letter has answered your concerns. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2683OpenMr. Donald H. Carter, 300 W. 11th Street, Reno, NV 89503; Mr. Donald H. Carter 300 W. 11th Street Reno NV 89503; Dear Mr. Carter: This is in response to your letters of August 24, 1977, and October 8 1977, concerning your Ford F-150 pickup truck.; The November 1976 date on your truck's certification label refers onl to the date of actual manufacture of the vehicle, not its model year. Virtually all manufacturers, including Ford, utilize a model year which does not correspond to the calendar year. Typically, for American manufacturers, this model year begins on September 1 of the previous calendar year, i.e., model year 1977 began on September 1, 1976. Manufacturers usually begin manufacture of their vehicles as early as July in order to have sufficient vehicles in their showrooms by the September start of the model year.; All Federal motor vehicle safety standards specify a date on whic their requirements become effective. Thus, a manufacturer must indicate by the certification label that its vehicles are in compliance with all Federal standards in effect on the date of the vehicles' manufacture. Whether a vehicle is marketed as a particular model year vehicle depends upon the manufacturer's own marketing practice. The certification date does not represent the model year date.; Finally, your first letter stated that your vehicle was ordered o November 4, 1976, with a 3 month delivery interval. Every manufacturer produces a large number of vehicles before there are orders for a specific vehicle, and maintains them in various storage locations around the country. When the manufacturer receives an order from a dealership for a specific vehicle, it will first determine whether it already has such a vehicle in stock, and if it does, it will ship that vehicle rather than specially manufacture a new vehicle.; However, if there is no identical vehicle in stock, it will manufactur one specifically for that order, which can take from a few days to several months to program into the assembly line and produce. As a dealership has no way to know in advance whether the vehicle it ordered is in stock or will have to be specially manufactured, it will often state a delivery date that anticipates the longest possible delay which would result from special manufacture. There is thus no reason for concern over the fact that your vehicle was manufactured in the same month it was ordered. Either Ford had such a vehicle in stock, or was able to manufacture one with very little delay.; I hope that this letter has answered your concerns. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3196OpenMr. Ted J. Szkolnicki, Supervisor, Mechanical Engineering, Motor Coach Industries, Pembina, ND 58271; Mr. Ted J. Szkolnicki Supervisor Mechanical Engineering Motor Coach Industries Pembina ND 58271; Dear Mr. Szkolnicki: This responds to your December 11, 1979, letter asking whether yo would be permiited to install a valve in your braking system that would prevent air from reaching the front axle brakes when your vehicle is in reverse. You want to make such a modification to prevent brake chatter when your vehicle is in reverse and question whether such a modification would comply with the requirements of Standard No. 121, *Air Brake Systems*.; Sections S5.3.3 and S5.3.4 of the standard establish brake actuatio and release times. In an interpretation of those sections (July 23, 1976), the agency stated that the air pressures of 60 psi and 95 psi were only benchmarks, and that the agency would use either of those values or 70 percent of the maximum pressure in the brake chamber, whichever is lower. You state that this interpretation allows you to install a valve, because the maximum air pressure reaching the front brake chamber when the vehicle is in the reverse gear would be 0 and 70 percent of 0 is 0. Therefore, you suggest that your vehicle would pass the tests in these two sections if tested at 0 psi.; The intent of the July 23 interpretation of the sections was to provid flexibility of designs that incorporate lower air pressures than originally contemplated by the air brake standard. The interpretation was not intended as a device to escape from compliance with the air brake standard by creating a situation where front brakes would be rendered inoperative. Accordingly, the agency limits its July 23, 1976, interpretation to those instances where air brakes are receiving air pressure and are performing as designed to stop the vehicle. Using this limitation on our July 23 interpretation, the NHTSSA concludes that your new brake design would violate the standard and, therefore, will not permit the use of the valve that you recommend.; The brake chatter that you refer to in your letter appears to be problem that occurs only in your vehicles. We have not been made aware of similar problems affecting other manufacturers' vehicles. Accordingly, we must assume that something in your design is creating the chatter problem. We suggest that you alter your brake design in a way that elinates the chatter problem while maintaining the vehicle's compliance with the air brake standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3097OpenMr. 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 responds to your August 30, 1979, letter asking how to comply wit Part 568, *Vehicles Manufactured in Two or More Stages*. That regulation states, in part, that a manufacturer may choose as the date of manufacture of a vehicle, the date of manufacture of the incomplete vehicle, the date of manufacture of the final vehicle, or any date between those two dates. You ask whether this choice is available to manufacturers that manufacture both the incomplete vehicle and the final-stage vehicle. The answer to your question is no.; As you noted in your letter, the National Highway Traffic Safet Administration issued an interpretation in 1974 stating that manufacturers of both incomplete and final-stage vehicles could not choose the date of manufacture of their completed vehicles. Those manufacturers must use only the date of manufacture of the completed vehicle.; The 1974 interpretation stated that manufacturers of both incomplet and final-stage vehicles do not need a choice of manufacture dates. That choice is only appropriate when a manufacturer of a completed vehicle does not have control over the manufacture of the incomplete vehicle. In such cases, a final-stage manufacturer might order an incomplete vehicle which would be constructed prior to the effective date of new safety standards but received after the effective date of such standards. If the incomplete vehicle were not in compliance with the new standards, it might be impossible for the final-stage manufacturer to use it in the construction of a completed vehicle. When a manufacturer is in complete control of both units, however, it can ensure that the incomplete vehicle will comply with the appropriate safety standards that will be in effect on the date of manufacture of the completed vehicle.; Our 1974 interpretation stated that the certification requirement would change as a result of the *Rex Chainbelt* decision. As you are aware, the agency significantly modified its regulations in accordance with that decision. However, the sections relating to the date of manufacture of a vehicle were not changed. Accordingly, our 1974 interpretation of those sections limiting the choice of dates of manufacture for a manufacturer that produce (sic) all stages of a vehicle remains in effect.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5179Open"Dr. Thomas L ckemeyer Dept VER/LB SWF Auto-Electric GmbH"; "Dr. Thomas L ckemeyer Dept VER/LB SWF Auto-Electric GmbH"; "Dear Dr. L ckemeyer: As you have requested, we are responding by FA to your letter of April 28, 1993, to Taylor Vinson of this Office. You have asked two questions with respect to the acceptability of a multiple rear turn signal lamp under Federal Motor Vehicle Safety Standard No. 108, and have enclosed a sketch of the lamp. Your first question is: 'Is it allowed to split the turn signal lamp in two parts with the dimensions given in the sketch . . . where the bigger part (4.5 sq. in.) is on the body of the car. The distance does not exceed 22 in.' Your question indicates that the turn signal lamp array of two lamps that is illustrated in the sketch is intended for installation on passenger cars or other vehicles whose overall width is less than 80 inches. Standard No. 108 incorporates by reference the SAE standard applicable to such vehicles, J588 NOV84. Paragraph 5.1.5.2 of SAE J588 NOV84 permits the use of multiple rear turn signal lamps to meet the photometric requirements of Standard No. 108. When multiple lamps are used to meet the photometric requirements of a rear turn signal lamp, paragraph 5.3.3 of SAE J588 NOV84 requires that the functional lighted lens area of each lamp shall be at least 22 sq. cm, provided the combined area is at least 37.5 sq. cm. Your sketch shows that the functional lighted lens area of one lamp is 23 sq. cm, and of the other, 30 sq. cm, with a combined area of 53 sq. cm. Therefore, Standard No. 108 permits you to use the turn signal lamp array shown in your sketch. Your second question is: 'Is it allowed to use the combination of the two lamps to meet the photometric requirements.' Because the distance between the two adjacent light sources in the array does not exceed 560 mm (the sketch indicates that it is less than 550 mm), paragraph 5.1.5.2 of SAE J588 NOV84 requires that the combination of the lamps be used to meet the photometric requirements for the corresponding number of lighted sections, two in this case. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0357OpenMr. Sidney W. Smith, Director of Engineering, Williamsen Body & Equipment Company, 1925 Indiana Avenue, P. O. Box 1076, Salt Lake City, UT 84111; Mr. Sidney W. Smith Director of Engineering Williamsen Body & Equipment Company 1925 Indiana Avenue P. O. Box 1076 Salt Lake City UT 84111; Dear Mr. Smith: This is in reply to your letter of May 18, 1971, requesting a interpretation of the Tire Identification and Record Keeping Regulation (49 C.F.R. Part 574) as it applies to vehicles manufactured in two or more stages.; The final-stage manufacturer, as a vehicle manufacturer, under sectio 113(f) of the National Traffic and Motor Vehicle Safety Act, is required to keep a record of the name and address of the first purchaser for purposes other than resale, and to maintain a record of the tires shipped on or in the completed vehicle (49 C.F.R. 574.10). Although the final-stage manufacturer may designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .'(49 C.F.R. 568.7). In such a case, the responsibilities for maintaining the records required by the Act and by the Tire Identification and Record Keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final-stage manufacturer will be relieved of all liability for maintaining the records.; Under the Tire Identification and Record Keeping Regulation, th manufacturer is not required to keep a record of tires manufactured before May 22, 1971, but sold after that date. However, where feasible, we recommend that the manufacturer maintain some system whereby he can identify the type of tire on vehicles he sells as well as the purchaser of the vehicle.; For your convenience, we have enclosed copies of the Act with it amendments, the Tire Identification and Record Keeping Regulation, and the Certification Regulation.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam4272OpenMr. Dwight R. Koehler, Product Management, Parker Industries P. O. Box 337589, Omaha, NE 68137; Mr. Dwight R. Koehler Product Management Parker Industries P. O. Box 337589 Omaha NE 68137; Dear Mr. Koehler: This is in reply to your letter of December 9, 1986, with respect t agricultural (grain) transportation vehicles which you manufacture, known in the industry as 'grain buggies.' You have asked whether there are any DOT lighting requirements for these vehicles, and if so, what are they and how might you meet them.; You have described the grain buggies as designed to be towed b agricultural tractors, with a top road speed of 25 to 30 mph. You have also told us that 'the primary use for these trailers will be 'off road' in nature,' although ' there are times when these units will be used on gravel roads and occasionally, highways.'; The requirements of Federal Motor Vehicle Safety Standard No. 10 *Lamps, Reflective Devices, an Associated Equipment apply to various categories of 'motor vehicles.' A 'motor vehicle' is defined as a vehicle driven or drawn by mechanical power and manufactured primarily for use on the public streets, roads, and highways. The manufacturer of a vehicle determines whether his product is a 'motor vehicle' and therefore a vehicle that must comply with all applicable Federal motor vehicle safety standards including Standard No. 108. The National Highway Traffic Safety Administration reserves the right to challenge any determination that appears clearly erroneous. On the basis of the information you have presented us, the grain buggies will be primarily used off the public roads, and use of the public roads will be only incidental (in our experience agricultural equipment uses public road for such limited purposes as crossing from one field to another, and delivery of produce to processing plants). Under these circumstances, we would not consider the grain buggies as 'motor vehicles,' and no Federal requirements would apply to them. They would, however, remain subject to any appropriate requirements of the State in which they are used.; I hope that this answers your questions. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0359OpenMr. Sidney W. Smith, Director of Engineering, Williamsen Body & Equipment Company, 1925 Indiana Avenue, P.O. Box 1076, Salt Lake City, UT 84111; Mr. Sidney W. Smith Director of Engineering Williamsen Body & Equipment Company 1925 Indiana Avenue P.O. Box 1076 Salt Lake City UT 84111; Dear Mr. Smith: This is in reply to your letter of May 18, 1971, requesting a interpretation of the Tire Identification and Record Keeping Regulation (49 C.F.R. Part 574) as it applies to vehicles manufactured in two or more stages.; The final-stage manufacturer, as a vehicle manufacturer, under sectio 113(f) of the National Traffic and Motor Vehicle Safety Act, is required to keep a record of the name and address of the first purchaser for purposes other than resale, and to maintain a record of the tires shipped on or in the completed vehicle (49 C.F.R. 574.10). Although the final-stage manufacturer may designate someone to maintain the records required under section 574.10 of the Tire Identification and Record Keeping Regulation, the legal responsibility for maintaining the records remains with the final-stage manufacturer.; However, the incomplete vehicle manufacturer, or any intermediat manufacturer, may assume 'legal responsibility for all duties and liabilities imposed on manufacturers by (the Act) with respect to the vehicle as finally manufactured . . .' (49 C.F.R. 568.7). In such a case, the responsibilities for maintaining the records required by the Act and by the Tire Identification and Record Keeping Regulation will be assumed by the incomplete vehicle manufacturer, or any intermediate manufacturer, and the final-stage manufacturer will be relieved of all liability for maintaining the records.; Under the Tire Identification and Record Keeping Regulation, th manufacturer is not required to keep a record of tires manufactured before May 22, 1971, but sold after that date. However, where feasible, we recommend that the manufacturer maintain some system whereby he can identify the type of tire on vehicles he sells as well as the purchaser of the vehicle.; For your convenience, we have enclosed copies of the Act with it amendments, the Tire Identification and Record Keeping Regulation, and the Certification Regulation.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam4384OpenMr. Jeffrey A. Crawford, Q.A. Manager, Lyn-Mont Manufacturing Co., P. O. Box 11745, 4208 Clubview Drive, Fort Wayne, Indiana 46860; Mr. Jeffrey A. Crawford Q.A. Manager Lyn-Mont Manufacturing Co. P. O. Box 11745 4208 Clubview Drive Fort Wayne Indiana 46860; Dear Mr. Crawford: This responds to your letter concerning Safety Standard No.. 106 *Brake 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 |
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.