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: aiam0043OpenMr. R.L. Donnelly, Corporate Secretary, The Armstrong Rubber Company, 475 Elm Street, West Haven Connecticut 06516; Mr. R.L. Donnelly Corporate Secretary The Armstrong Rubber Company 475 Elm Street West Haven Connecticut 06516; Dear Mr. Donnelly: Mr.Bridwell has asked me to reply to your letter of December 1, 1967 In your letter you raise three questions. The first is:; >>>'(1) We find that in smaller rim diameter molds that it i impossible to place all the branding in the white sidewall side as shown in Figure 1, Page 14 - MVSS No. 109.; In complying with a state requirement, namely V-1, it was necessary t place the stamping above the buffing rib. Permission is requested to place the stamping above the rib in a protected area where it will not be scuffed and destroyed.'<<<; The labeling requirements of Standard No. 109 make it mandatory tha the approved symbol (DOT) and the code mark be between the maximum section width and the bead, other information need only be conspicuously labeled. Additionally, there is no requirement that the information be in one section of the area specified, but rather the entire circumferential area can be used for labeling.; Your second question is: >>>'(2) *Reprocessed Tires* In tire manufacturing sometimes a mold fold will occur in the area o the branding. The area is buffed. If such stamping is removed, will it be necessary to rebrand the tire, or will the use of a label be sufficient? This usually occurs on one side of the tire only.'<<<; Your question concerns new tires that have had the labeling informatio removed by some subsequent manufacturing process. In order to comply with S4.3 of Standard No. 109, the tire will have to be labeled on both sidewalls. Please note however, that S4.3.1 states that 'until August 1, 1968, the labeling requirements of S4.3 may be met by affixing to each tire a label or tag that incorporates all specified information not molded into or onto the tire'.; Your third question is: >>>'(3) *Removal of 'V-1' From Molds* It is our understanding that MVSS Standard No. 109 and 110 prompt th 'VESC' regulation 'V-1' revised. We are also aware that states can impose safety regulations for tires and motor vehicles provided they are higher than the Federal Standard and are for use on the state owned equipment.; We request a statement from the Department of Transportation statin the position the Department will take regarding the 'V-1' requirements.'<<<; Federal motor vehicle safety standards do not require that tires b manufactured without the 'V-1' symbol. Presently, a manufacturer may, at his option, continue the practice of molding tires with the 'V-1' symbol.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam4903OpenMr. Mickey Hale General Sales Manager Jackie Cooper Olds-GMC 900 E. Main, P.O. Box 850239 Yukon, OK 73085; Mr. Mickey Hale General Sales Manager Jackie Cooper Olds-GMC 900 E. Main P.O. Box 850239 Yukon OK 73085; "Dear Mr. Hale: This responds to your letter to Steve Kratzke, ou Deputy Assistant Chief Counsel for Rulemaking, asking what type of safety belt must be installed at rear seating positions in conversion vans. You indicated that these conversions would be made to used 1990 Chevrolet full-sized vans. You intend to install lap/shoulder belts at the front two seating positions and lap-only belts at each of the middle and rear seating positions, and asked if this planned installation would conflict with the safety belt installation requirements set forth in NHTSA's safety standards. The answer is that this planned installation would not conflict with Federal requirements, as explained below. To begin, NHTSA does not classify vehicles as 'vans.' Instead, cargo vans are generally classified as 'trucks,' and passenger vans are generally classified as 'multipurpose passenger vehicles.' S4.2.4 of Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208) requires that trucks and multipurpose passenger vehicles manufactured on or after September 1, 1991 with a gross vehicle weight rating of 10,000 pounds or less be equipped with lap/shoulder belts at front outboard and rear forward-facing outboard seating positions and with either lap/shoulder or lap-only belts at every other designated seating position. Any of these vehicles manufactured before September 1, 1991 are required to be equipped with lap/shoulder belts at front outboard seating positions and with either lap/shoulder or lap-only belts at every other designated seating position. Thus, if your van conversions were new vehicles, your planned safety belt installations would be permissible for van conversions manufactured before September 1, 1991, but impermissible for conversions manufactured after that date. You stated, however, that the van conversions in question would not be new vehicles, but would instead be used 1990 model year vehicles. The National Traffic and Motor Vehicle Safety Act specifies that vehicles must conform with all applicable safety standards up until the first purchase for purposes other than resale. After the first purchase, the vehicle is no longer required by Federal law to conform with all safety standards. However, the Safety Act includes a provision that prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from 'rendering inoperative' any device or element of design installed in or on a vehicle in compliance with an applicable safety standard. This prohibition applies to both new and used vehicles and means that the named commercial entities may not remove safety equipment required by the safety standards, such as seat belts, unless the manufacturer, distributor, dealer, or repair business reasonably believes the vehicle will not be used during the time its compliance with the safety standards has been 'rendered inoperative.' In the case of safety belts, this means that your dealership could remove belts to make repairs or modifications, but must reinstall or replace the belts before returning the vehicle to a customer. NHTSA does not consider it to be a violation of the 'render inoperative' prohibition when a dealer modifies a used vehicle in such a way that the vehicle is equipped with safety belts at every designated seating position and those safety belts are the type that Standard No. 208 permitted to be installed at that seating position in the vehicle when it was new. In this case, your letter states that you would equip the used 1990 conversion vans with lap/shoulder belts at front outboard seating positions and lap-only belts at all other seating positions. This belt installation was permitted by Standard No. 208 for new 1990 multipurpose passenger vehicles. Therefore, your planned installation would not violate the 'render inoperative' prohibition of the Safety Act with respect to the safety belt installation requirements for these vehicles. I hope this information is helpful. If you have any further questions or need some additional information, please feel free to contact Mr. Kratzke at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5611OpenMs. Colleen Grant 6335 W. Newville Avenue Las Vegas, NV 89103; Ms. Colleen Grant 6335 W. Newville Avenue Las Vegas NV 89103; "Dear Ms. Grant: This responds to your letter asking whether your 197 Chevrolet Blazer is 'street-legal.' You stated that an official of the Nevada Department of Motor Vehicles has questioned whether your vehicle is street-legal because it does not have shoulder belts. According to your letter, the vehicle has a fiberglass removable roof, and was originally manufactured with lap belts. You also stated that inquiries at local dealers indicate that General Motors does not make a shoulder belt for this model 'because there is no place to safely mount it.' We assume that you are asking whether your vehicle was originally required to have lap/shoulder belts, because many states require vehicles in use to be equipped with the same kinds of safety belts that were required by the Federal government for the vehicles when new. As discussed below, your vehicle was not originally required to have shoulder belts, but was required to have at least lap belts at each seating position. By way of background information, the National Highway Traffic Safety Administration is authorized to issue safety standards for new motor vehicles and new motor vehicle equipment. One of the standards we have issued is Standard No. 208, Occupant Crash Protection. This standard specifies, among other things, seat belt requirements for new vehicles. Standard No. 208 generally required, for model year 1974 vehicles such as your Blazer, either a lap belt or a lap/shoulder belt at each seating position, at the manufacturer's option. Therefore, your vehicle was not originally required to have shoulder belts. I hope this information is helpful. If you have further questions, please feel free to contact Edward Glancy of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0413OpenMr. T. Nakajima, Senior Engineer, Mitsubishi Motors Corporation, Suite 410 Trowell Building, 24681 Northwestern Highway, Southfield, MI 48075; Mr. T. Nakajima Senior Engineer Mitsubishi Motors Corporation Suite 410 Trowell Building 24681 Northwestern Highway Southfield MI 48075; Dear Mr. Nakajima:#This is in reply to your letter of July 12 inquirin whether the proposed identification of the windshield washing system and hazard warning system controls, depicted on the photographs and overlays you enclosed, would conform with the requirements of Standard No. 101.#Standard No. 101 requires use of the word 'WASH' to identify the washing system control, and the word 'HAZARD' to identify the vehicular hazard warning system control, when these controls are manually operated. Your photographs and overlays indicate that you will use the required words to identify the appropriate controls. In our view, you have understood the requirements correctly.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam4329OpenMr. Farrel L. Krall, Manager, Technical Legislation, Navistar International, 2911 Meyer Road, P. O. Box 1109, Fort Wayne, IN 46801; Mr. Farrel L. Krall Manager Technical Legislation Navistar International 2911 Meyer Road P. O. Box 1109 Fort Wayne IN 46801; Dear Mr. Krall: This responds to your letter asking about Federal Motor Vehicle Safet Standard No. 113, *Hood Latch Systems.* You asked whether a design for a front-opening hood you are considering for production would comply with section S4.2 of the standard. According to your letter, the front-opening hood would be a service access feature integrated into the overall design of a rear opening hood system. The latch system would consist of two separate latches, on each side at the front corner of the access hood. As discussed below, a front-opening hood with two separate latch systems would meet the requirements of section S4.2.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) does not provide 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 ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.; Section S4.2 states: >>>A front opening hood which, in any open position, partially o completely obstructs a driver's forward view through the windshield must be provided with a second latch position on the hood latch system or with a second hood latch system.<<<; You cited an interpretation letter issued in 1972, which stated tha while the agency favors a system in which two completed operations are necessary, a system which employs two latches having a single operation will meet the requirements of the standard. You stated that since your design incorporates two separate latches and requires two complete operations to latch the hood, you believe the system meets both the intent and the legal requirements of the standard.; As discussed in the preamble to the final rule, section S4.2 permit the following types of installations: a single latch system with two positions, two separate primary latch systems, or separate primary and secondary latches. 33 FR 6470-71, April 27, 1968 (copy enclosed). Thus, designs for front-opening hoods with two separate latch systems were specifically contemplated by the agency in establishing section S4.2 and would comply with that requirement.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3116OpenMr. Frank Pepe, Assistant Vice President, Engineering Division, United States Testing Company, Inc., 1415 Park Avenue, Hoboken, NJ 07030; Mr. Frank Pepe Assistant Vice President Engineering Division United States Testing Company Inc. 1415 Park Avenue Hoboken NJ 07030; Dear Mr. Pepe: This responds to your recent letter concerning the testing procedure specified in Safety Standard No. 209, *Seat Belt Assemblies*. Specifically, you ask about the proper sequence of requirements and testing procedures provided in paragraphs S4.3(j), S4.3(k), S5.2(j) and S5.2(k).; Paragraph S4.3(j) provides that a retractor must meet certai requirements when tested in accordance with S5.2(j). Compliance with this paragraph should be determined initially. Then, paragraph S4.3(k) provides that the same retractor must be able to comply with S4.3(j) after being tested in accordance with S5.2(k), except that the retraction force is only required to be 50 percent of its original value. This original value was determined, of course, during the compliance procedure of S5.2(j). Therefore, the first interpretation included in your letter is correct.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4779OpenMr. Heracilio R. Prieto President Easton Inc. Road 870, KM 2.6, Palo Seco Levittown, Puerto Rico 00949; Mr. Heracilio R. Prieto President Easton Inc. Road 870 KM 2.6 Palo Seco Levittown Puerto Rico 00949; "Dear Mr. Prieto: This responds to your letter asking about the markin and labeling requirements in Standard No. 116, Motor Vehicle Brake Fluids (49 CFR 571.116). You asked whether you could comply with the requirement in Standard No. 116 that each brake fluid container be labeled with a 'serial number identifying the packaged lot and date of packaging' by means of a 'label notch coding system,' which you described as a mechanical device which permanently notches a label. Standard No. 116 does not prohibit the use of a label notch coding system provided that it is not susceptible to being torn. However, any label notch coding system must be permanent and unambiguous, and satisfy all other relevant provisions of the standard. Section S5.2 of Standard No. 116 sets forth packaging and labeling requirements for brake fluid containers. Section S5.2.2.2 requires each packager of a brake fluid to include information that is either 'marked' directly on the container or marked on a label that is 'permanently affixed to the container.' Section S5.2.2.2(a)-(g) sets forth the specific information that must appear directly on or be labeled on every brake fluid container. Section S5.2.2.2(d) requires that the container be marked with 'a serial number identifying the packaged lot and date of packaging.' Information about the label notch coding system enclosed with your letter and samples of your notched labels show that you use the system known as 'code-dating,' which uses uniquely spaced notches to represent a code that can be translated into a packaging date by means of a 'Codedge decoder card.' With this number or date represented by notches, the number could be traced by the packager to the packaging date and lot number through its production quality control records. While the 'Codedge' system only identifies the year of manufacturing by means of a single digit, your recent letter indicates that an additional notch will be added to identify the decade.With respect to the label notch coding system, if the notches clearly identified the packaged lot and date of packaging, the combination would be a 'serial number' and would appear to comply with the requirement of S5.2.2.2(d). I would also like to note that section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1407) requires every manufacturer to certify that its products comply with all applicable safety standards. For this reason, this agency has no authority to approve, endorse, or offer assurances of compliance with respect to any system of labeling brake fluid containers. I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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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: aiam3546OpenMr. J. E. Bingham, Senior Test Engineer, British Standards Institution, Maylands Avenue, Hemel Hempstead, Herts HP2 4SQ, England; Mr. J. E. Bingham Senior Test Engineer British Standards Institution Maylands Avenue Hemel Hempstead Herts HP2 4SQ England; Dear Mr. Bingham: This responds to your letter of January 5, 1982, concerning Standar No. 209, *Seat Belt Assemblies*. You are correct that my letter of June 1, 1981, should have referred to S5.1(d) rather than S5.2(d). Likewise, I assume that where you have referred to sections 4.1(d), (e), and (f) in your letter, you mean sections 4.2(d), (e), and (f).; My letter of June 1, 1981, was not meant as a definitive statement o what specific action the agency intends to take on Standard No. 209, but rather to acknowledge that the standard's provision on abrasion needs modification. The notice of proposed rulemaking for this action will allow you and other interested parties to comment on what precise changes you think should be made to the standard. I am placing a copy of your letter with its current suggestions in the public docket.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4283OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Department, Stanley Electric Co. Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of August 4, 1986, with respect to new headlamp and aiming adaptor design. The lens of the headlamp will be titled 60 degrees from vertical. Although this is too extreme an angle for use of mechanical aimers for headlamps, you have developed an adaptor for use with the aimer whereby the new headlamp may be mechanically aimed. You have asked whether mechanical aim using the new adaptor is permissible.; Federal Motor Vehicle Safety Standard No. 108 does prescribe the type of aimers to be used with replaceable bulb headlamps, but not the adapters. As you have noted, the standard does require such headlamps to be capable of mechanical aim by incorporating on the lens face three pads which meet the requirements of the standard's Figure 4. You have informed us that your headlamp design complies with this requirement, and furthermore meets the photometric requirements of Standard No. 108.; However, there are some practical considerations that are important i you intend to market this headlamp. Although providing an aimer adaptor is not required by Standard 108, no adapters for your unique lamp have been provided to service facilities. The only adaptor which exist today are those designed to accommodate sealed beam headlamps, and replaceable bulb headlamps with lens angles up to 50 degree for smaller lamps and 40 degrees for large ones. Neither of these can accommodate the lamp you have proposed.; In summary, the standard does not appear to preclude use of your ne designs, and although not specifically required by the standard, an adaptor should be provided as original vehicle equipment since suitable adapters do not exist in the service community.; Subsequent to August 4, we received your request for confidentia treatment of the letter. We replied that it is our policy that substantive interpretations be made publicly available but informed you that we would be willing to delete all identifying references to you and your company. You replied that this was agreeable to you. However because this headlamp is the subject of SAE Technical paper 870064 *Development of MR (Multi- Reflector Headlamp)* and was discussed at SAE meetings in February 1987, Stanley has waived all considerations of confidentiality through its public disclosure of the matter. Consequently, this letter will be made publicly available.; Sincerely, Erika Z. Jones, Chief Counsel |
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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.