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: aiam2719OpenMr. Paul Jones, Kentucky Department of Education, Frankfurt, KY 40601; Mr. Paul Jones Kentucky Department of Education Frankfurt KY 40601; Dear Mr. Jones: This responds to your oral request to Roger Tilton of my staf concerning the applicability of the new Federal school bus safety standards to vans transporting 10 or more school children to or from school or related events.; The National Highway Traffic Safety Administration (NHTSA) promulgate safety standards applicable to all school buses. School bus is defined in Part 571.3 of our regulations (Volume 49 of the Code of Federal Regulations, Part 571.3) to mean a bus sold or introduced in interstate commerce for purposes that include carrying students to and from school or related events. In turn, bus is defined as 'a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons.' More than 10 person means 10 passengers or more plus a driver. Accordingly, any vehicle sold or introduced in interstate commerce to transport school children which carries 10 or more passengers to or from school or related events must comply with all of the new Federal school bus requirements. This includes vans which fall within that passenger capacity.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2611OpenHonorable Joseph L. Fisher, 19 East Market Street, Leesburg, VA 22075; Honorable Joseph L. Fisher 19 East Market Street Leesburg VA 22075; Dear Mr. Fisher: This responds to your February 16, 1977, letter asking whether day car centers are required to purchase buses manufactured in conformance with the school bus safety standards.; The National Highway Traffic Safety Administration has decided that th inclusion of day care centers within the definition of 'school', for purposes of applying the school bus safety standards, would be inappropriate at this time. After careful deliberation, the agency has concluded that since the school bus safety standards do not specifically refer to day care centers, cay care center operators may not have been aware of the possibility that vehicles they use might be subject to school bus safety requirements. Therefore, persons interested in that issue may not have fully participated in our earlier rulemaking on the subject.; In accordance with accepted rulemaking procedures, the agency intend to issue a proposal to extend the coverage of the school bus standards to buses purchased by day care centers. This proposal will provide an opportunity for persons interested in the operation of these facilities to comment upon the advisability of extending the school bus safety standards to their vehicles.; I appreciate your interest in this issue and apologize for an inconvenience caused to your constituent by the length of time required to make this decision.; Sincerely, Joan Claybrook |
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ID: aiam0106OpenMr. H.J.T. Young, Ontario Department of Transport, Parliament Building, Toronto 2, Canada; Mr. H.J.T. Young Ontario Department of Transport Parliament Building Toronto 2 Canada; Dear Mr. Young: This is in confirmation of our telephone conversation of August 26 1968, and in reply to your letter of July 22, 1968, in which you inquire as to the meaning of 'manufacturer' in the Tire Standard, No. 109, particularly in light of the practice of concealing the identity of the real maker of the tires.; The term 'manufacturer' employed in the labeling requirements sectio of that standard, by the rule set forth in 23 C.F.R. S255.3, is used in the meaning defined in section 102 of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. S1391:; >>>'Manufacturer means any person engaged in the manufacturing o assembling of motor venicles(sic) or motor vehicle equipment, including any person importing motor vehicles or motor vehicles equipment for resale.'<<<; The clear implication of this definition is that we are to be concerne with the company that is the actual maker of the tires in question, not retail outlets, suppliers who are not manufacturers, or other parties who may misleadingly appear to be the manufacturer.; We are not aware of any situation where the ownership or control of th tire manufacturing operation is so fragmented as to leave the relevant identity of the manufacturer unclear, within the meaning of the above. If such a case is brought to our attention, we will deal with it in its own facts.; We are happy to be of assistance. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam1732OpenMr. Eugene Hindin, President, Gindy Mfg. Corporation, Downingtown, PA 19335; Mr. Eugene Hindin President Gindy Mfg. Corporation Downingtown PA 19335; Dear Mr. Hindin: This responds to your November 25, 1974, request for our approval o Gindy's plans to establish the date of completion of manufacture of highway trailers for purposes of compliance with Standard No. 121, *Air brake systems*, which became effective January 1, 1975.; Unfortunately there is no simple formula for a determination in advanc that a trailer is complete. For example, your determination that a vehicle is roadworthy does not establish that it is complete.; We set out what we believe are straightforward criteria in a recen letter to a person concerned with essentially the same problem as you. A copy is enclosed. It can be seen that painting, and the installation of decals, tires, or rims can be accomplished after the date of manufacture. As for special lining arrangements, or the mounting of refrigerator units, this requires a determination by you of whether the trailer is substantially complete without these fixtures.; We do appreciate your efforts to meet the requirements of the standar in good faith, as evidenced by your timely request for guidance and submission of plans. Thank you for your interest in motor vehicle safety.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam3695OpenMr. Thomas D. Turner, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. Thomas D. Turner Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Turner: This is in response to your letter of March 10, 1983, with respect to school bus warning light system that you wish to offer in response to your understanding of Utah Senate Bill No. 70. This system would allow the school bus operator to activate only the rear warning lamps when stopping on a divided highway where no traffic is approaching from the front in an adjacent traffic lane.; In our opinion, the Utah bill (copy attached) does not require such system, and a system of this nature is not allowed by Motor Vehicle Safety Standard No. 108. The pertinent portion of Senate Bill No. 70 reads: 'The driver of a vehicle upon a divided highway or upon a highway with roadways separated by a painted median in excess of 12 feet of width need not stop upon meeting or passing a school bus which is on the other roadway.' (Sec. 2) The bill contains no reference to the number or kinds of lights that a school bus may operate in this traffic situation. As paragraph S4.1.4(b)(ii) of Standard No. 108 requires activation of lighting systems, without qualification, we interpret it as precluding a system that is capable of partial operation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3678OpenMr. T. J. Brown, Mohawk Rubber Company, Roanoke, VA 24017; Mr. T. J. Brown Mohawk Rubber Company Roanoke VA 24017; Dear Mr. Brown: This is in response to your March 28, 1983, letter to Roger Fairchil of this office, requesting confirmation of your understanding of the effective dates for the recent suspension of treadwear grading under this agency's Uniform Tire Quality Grading Standards.; Your understanding of the effective dates is correct. Tires produced i molds manufactured on or after August 8, 1983, must have the new grading format which excludes treadwear information. Tires produced in molds manufactured before that date may either use the new format as soon as feasible, to minimize the dissemination of misleading information with regard to tire treadwear.; With regard to labels, the requirement that such labels must contai information regarding treadwear grades was suspended effective February 7, 1983. The preamble to the final rule states that manufacturers will be permitted to exhaust inventories of labels which were in existence as of the date of the suspension. Thereafter, manufacturers should begin using labels without treadwear information.; If you have further questions on this matter, please feel free t contact us.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3760OpenMr. Steve Lampeas, 117 Aldershot Lane, Manhasset, NY 11030; Mr. Steve Lampeas 117 Aldershot Lane Manhasset NY 11030; Dear Mr. Lampeas: This is in reply to your letter of October 13, 1983, concerning th legality under Federal laws of your patented device, the 'Trunk Truck.' It appears from the material you enclosed that the device extends in twin booms from the rear of the car, and that a stop lamp or taillamp is mounted at the end of each boom (you refer to it as a 'natural extension' of these lamps).; Under the National Traffic and Motor Vehicle Safety Act, no perso (except the vehicle owner) may modify a vehicle so that equipment that is on the vehicle pursuant to a Federal motor vehicle safety standard is 'rendered inoperative in whole or in part.' Therefore, you must assure yourself that all requirements of Federal Motor Vehicle Safety Standard No. 108 continue to be met with respect to rear lighting. This would include not only the lamps at the end of the booms, but those remaining on the car. In addition to stop lamps and taillamps, rear lighting includes, (sic) turn signal lamps, back up lamps, and license plate lamps. As on other load-bearing vehicles, such as boat trailers, these lamps should continue to be visible even with a load installed.; You should also ask the States whether such a device is legal. State have jurisdiction over the use of motor vehicles within their borders.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4778OpenMs. Carol Zeitlow Manager, Engineering Services Oshkosh Truck Corporation P.O. Box 2566 Oshkosh, WI 54903-2566; Ms. Carol Zeitlow Manager Engineering Services Oshkosh Truck Corporation P.O. Box 2566 Oshkosh WI 54903-2566; Dear Ms. Zeitlow: This is in reply to your letter of August 1, 1990, t Taylor Vinson of this Office, with respect to Motor Vehicle Safety Standard No. 108. You ask for confirmation that 'the hazard warning light should always over-ride the stop lamp' when they are 'together on a vehicle.' I am pleased to provide that confirmation. Under the relevant SAE materials on stop lamps that are incorporated by rference in Standard No. 108, when a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on if the turn signal is flashing. Because the hazard warning system operates through the turn signal lamps, the stop signal cannot be turned on in an optically combined lamp if the hazard system is in use. You have also noted that in your version of Standard No. 108, no reference is made to SAE Standard J1395. It was not until May 15 of this year that Standard No. 108 was amended to incorporate SAE J1395 (with an effective date of December 1, 1990). I enclose a copy of that amendment for your information. If you have any further questions, we shall be pleased to answer them. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0240OpenMr. A. J. Macho, Administrative Assistant, Holan, Division of the Ohio Brass Company, 4100 W. 150th Street, Cleveland, OH 44135; Mr. A. J. Macho Administrative Assistant Holan Division of the Ohio Brass Company 4100 W. 150th Street Cleveland OH 44135; Dear Mr. Macho: This is in reply to your letter of May 11, 1970, in which you aske four questions concerning the application of Standard 206 to your products, with reference to several illustrations and drawings that you enclosed.; >>>1. 'It is our opinion that hinge, latch and inside door lock on cre compartment must comply with requirements of FMVSS No. 206. Is this correct?'; Answer: Yes. 2. 'Is inside door lock required in this type utility cre compartment.'; Answer: Yes, since it is a 'hinged door', and not a 'cargo-type door' within the meaning of the standard, so that the requirement of S4.1.3 applies.; 3. 'It is our opinion that FMVSS No. 206 does not apply to materia compartment door latches illustrated in Exhibit 1. Is this correct?; Answer: Yes. Material compartment doors are not covered. 4. 'It is our opinion that hinges, latch and inside door lock on th rear doors illustrated in Exhibit 4 do *not* come under FMVSS No. 206. Is this correct?'; Answer: Yes. The requirements of the standard apply only to sid doors.<<<; We are pleased to be of assistance. Sincerely, Rodolfo Diaz, Acting Associate Director, Motor Vehicl Programs; |
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ID: aiam4430OpenRobert L. Ripley, President Knaack Manufacturing Co. 420 East Terra Cotta Avenue Crystal Lake, IL 60014; Robert L. Ripley President Knaack Manufacturing Co. 420 East Terra Cotta Avenue Crystal Lake IL 60014; Dear Mr. Ripley: This is a response to your letter asking this agenc to review three product catalogs you submitted with your letter, and tell you whether your company is required to furnish information pursuant to 49 CFR Part 566, Manufacturer Identification. Based on the information you supplied with your letter, your company is required to file information under Part 566 for the warning devices shown in one of the catalogs, but not for any of the other items shown in the three catalogs. As specified in the Application section of Part 566 (/566.3), Part 566 applies to (1) all manufacturers of motor vehicles and (2) manufacturers of motor vehicle equipment, other than tires, to which a safety standard applies. The only item advertised in the three catalogs that is motor vehicle equipment to which a safety standard applies is the 'Safety Reflector Kit' shown on page 6 of the catalog entitled 'weather guard For Full-Size and Mini Vans.' These devices are subject to Standard 125, Warning Devices (49 CFR /571.125). Accordingly, your company, as the manufacturer of these devices, must furnish the information specified in /566.5 within the time period specified in /566.6. I hope you find this information helpful. If you have further questions, please contact Joan F. Tilghman of my staff at (202) 366-2992. Sincerely, Erika Z. Jones 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.