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: aiam3096OpenNorman Friberg, P.E., Engineer, Regulatory Affairs, Volvo of America Corporation, Rockleigh, New Jersey 07647; Norman Friberg P.E. Engineer Regulatory Affairs Volvo of America Corporation Rockleigh New Jersey 07647; Dear Mr. Friberg: This is in response to your letter of February 5, 1979, and you telephone conversations with Mr. Schwartz of my office.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification Number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree of commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line,' denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; In Volvo's view, the only 'line' it markets in the United States in th '200-series.' Within this line, there are several models differentiated by body style and number of engine cylinders. Each model is offered in several different 'sales versions,' designated by a two- or three-letter suffix. Sales versions differ as to trim, upholstery, and other items which Volvo has designated as cosmetic. It is Volvo's desire not to encode the particular sales versions of the vehicle in its VIN.; Based on the facts presented, it is apparent that each 'sales version could also be designated a 'series' of Volvo desired. Nonetheless, the definition of 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality of the differences between the potential series, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0103OpenMr. R. J. Hart, Bugetta Inc., 3037 Enterprise Avenue, Costa Mesa, CA 92626; Mr. R. J. Hart Bugetta Inc. 3037 Enterprise Avenue Costa Mesa CA 92626; Dear Mr. Hart: With reference to your letter of August 14 and its enclose specification sheet covering the Bugetta, this vehicle appears to be a 'multipurpose passenger vehicle' for purpose of the Federal motor vehicle safety standards since it is constructed with features for occasional off road use.; Your understanding of the applicability of standards to multipurpos passenger vehicles is correct. We concur with your view that compliance with Standard No. 103 (Windshield Defrosting and Defogging) is a meaningless requirement for a vehicle with no top or windows.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam2066OpenMr. Terry Brooks, Transcraft Corp. P.O. Drawer 500, Anna, Illinois 62906; Mr. Terry Brooks Transcraft Corp. P.O. Drawer 500 Anna Illinois 62906; Dear Mr. Brooks: I am writing to confirm your telephone conversation of September 9 1975, with Mark Schwimmer of this agency, Concerning the testing of brake hose assemblies pursuant to Federal Motor Vehicle Safety Standard No. 106-74.; As Mr. Schwimmer explained, the standard does not specify the testin which you must conduct, it does specify the criteria which the assemblies must meet when tested by the National Highway Traffic Safety Administration (NHTSA) for compliance. While the surest way for you to be confident of compliance would be to follow the procedures in every detail, you are not legally obligated to do so. Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), requires you to assure yourself that, when tested by the NHTSA according to the procedures set out in the standard, your assemblies will meet the specified criteria. In addition, you are required to repair or replace without charge noncomplying assemblies. In the event of noncompliance or failure to remedy the noncompliance, the Act specifies a civil penalty not to exceed $1000 for each violation (and not to exceed $800,000 for any related series of violations). the exercise of due care in ensuring that the assemblies comply with the standard is a defence to an action for civil penalties for noncompliance. In such a situation, however, The Act nevertheless requires you to remedy the noncompliance.; If you manufacture brake hose assemblies and install them in vehicle which are also manufactured by you, then those assemblies are exempted by S5.2.4 of the standard from the requirement that assemblies be labeled by means of a band.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0012OpenMr. Stanley L. Dembecki 2303 N. 44th Street, #14-237 Phoenix, AZ 80058; Mr. Stanley L. Dembecki 2303 N. 44th Street #14-237 Phoenix AZ 80058; Dear Mr. Dembecki: This responds to your letter of April 24, 1991 commenting on my letter to you of April 8. In response to your request to review and comment on your video tape of your device, I asked our research and development office to review it. They indicated that although the device has some intuitive appeal, there is no technical basis to show that it would reduce accidents. In fact, our agency sponsored a field test of a similar system that flashed the center highmounted stop lamp. We found no significant difference in accident rates compared to a steady-burning signal. Attached is the abstract page of this study for your information. In closing, I note your comment that 'My l99l Oldsmobile was retrofitted within l5 minutes' with the module causing the center high mounted stop lamp to flash. Since you did not say that you had performed the retrofit, we assume that it 'was retrofitted' by another person. As I advised you on April 8, the center lamp must be steady-burning. Further, the National Traffic and Motor Vehicle Safety Act (specifically Title l5, United States Code, Section 1397(a)(2)(A)) forbids a 'manufacturer, distributor, dealer, or motor vehicle repair business' from rendering inoperative in whole or in part any equipment on a vehicle which has been installed pursuant to a Federal motor vehicle safety standard. We interpret this as forbidding the installation of equipment that would take a vehicle out of compliance with a Federal safety standard, i.e., that converts the steady-burning center lamp into a flashing one. However, the prohibition does not apply to individual owners of vehicles if they are not 'manufacturers, distributors, dealers, and motor vehicle repair businesses' capable of performing the modification themselves. Sincerely Paul Jackson Rice Chief Counsel Enclosure; |
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ID: aiam0800OpenMr. Keitaro Nakajima, Director/General Manager, Toyota Motor Sales, U.S.A., Inc., Factory Representative Office, Lyndhurst Office Park, 1099 Wall Street, West, Lyndhurst, NJ, 07071; Mr. Keitaro Nakajima Director/General Manager Toyota Motor Sales U.S.A. Inc. Factory Representative Office Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of June 27, 1972, asking whether th temporary covers which you intend to use to protect a vehicle's upholstery during shipment and storage in a dealer's yard are permitted despite their nonconformity with Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. You indicate that you plan to take four steps to ensure that the covers are removed by the dealer before delivery to a customer.; While you may follow the procedure you have specified, your first ste (the attachment of a statement to the windshield pursuant to 12.80(b)(2)(iv) of each car stating that the vehicle does not conform to FMVSS No. 302, but will be brought into conformity when the covers are removed by the dealer) appears unnecessary. The NHTSA has determined that such covers will not be subject to the standard and may be installed without affecting the vehicle's conformity, if the manufacturer takes appropriate steps to ensure that the covers are removed before the car is put into use.; Two steps which should be taken to manifest this intent are: (1 placing the covers in the vehicle in such a way that their use after purchase is unlikely, and (2) making adequate provision that the covers are removed before sale to the purchaser. Although you appear to deal adequately with the second step, you should also place the covers in the vehicle in such a way that their use after purchase is unlikely. If Toyota does take these steps, then the temporary covers would not be required to conform to Standard No. 302.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2763OpenB. Ruth Greene, Rohm and Haas Company, Independence Mall West, Philadelphia, PA 19105; B. Ruth Greene Rohm and Haas Company Independence Mall West Philadelphia PA 19105; Dear Ms. Greene: This is in response to your letter of January 27, 1978, requesting tha the National Highway Traffic Safety Administration review the draft of the form with which you propose to satisfy the Federal odometer requirements.; The form you are proposing to use differs from the Federal form in tha the two sets of certifications are combined into an introductory certification with four exceptions. The regulations require the transferor to certify that the odometer reading reflects the actual mileage, reflects the mileage over 99,999 miles, or is not actual. Your form would allow a transferor to execute a disclosure statement without making any of the above certifications. The introductory statement says 'if none of the exception block(s) below is checked, the Seller hereby certifies. . . .' Therefore, by checking the third or fourth box the transferor would be indicating that the exception applies but neither of the introductory statements applies. For this reason we cannot give our approval to use this form as the Federal disclosure form.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2360OpenMr. Arthur J. Laine, Jr., Master Mechanic, Plymouth Fire Department, Plymouth, ME 02360; Mr. Arthur J. Laine Jr. Master Mechanic Plymouth Fire Department Plymouth ME 02360; Dear Mr. Laine: This responds to your June 22, 1976, request to know when Standard No 121, *Air Brake Systems*, became applicable to firefighting vehicles, and whether the date of manufacture of the chassis or the date of manufacture of the completed vehicle is relevant for purposes of the standard's applicability. You also ask whether the chassis manufacture or the final manufacturer who completes the vehicle is responsible for complying with applicable safety standards.; Standard No. 121 applies to firefighting vehicles manufactured on o after June 1, 1976. I have enclosed a copy of the standard, which includes a listing of effective dates in section S3, *Applicability*.; Because most trucks are manufactured in two or more stages, the NHTS has issued a regulation that assigns responsibilities to the incomplete vehicle manufacture, intermediate manufacturers, and the final-stage manufacturer for ensuring conformity of the vehicle with safety standards (Part 568, *Vehicles Manufactured in Two or More Stages* (49 CFR Part 568)). Section 568.6 of this regulation requires that the final-stage manufacturer complete the vehicle in such a manner that it conforms to applicable standards. Section 568.6 does permit the final-stage manufacturer to treat as the time that manufacture is 'completed' for the purposes of certification any date no earlier than the manufacturing date of the complete vehicle and no later than the date of completion of final-stage manufacture. For example, a firefighting vehicle that is completed on a chassis built before June 1, 1976, could be legally completed by a final-stage manufacturer at any future date without conformity to Standard No. 121.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam4623OpenMr. Robert V. Potter, Jr. Spalding & Evenflo Companies, Inc. 5750-A North Hoover Blvd. P.O. Box 30101 Tampa, FL 33630; Mr. Robert V. Potter Jr. Spalding & Evenflo Companies Inc. 5750-A North Hoover Blvd. P.O. Box 30101 Tampa FL 33630; Dear Mr. Potter: This responds to your March 17, 1989, letter askin whether the National Highway Traffic Safety Administration (NHTSA) requires child restraint manufacturers to make spare parts available for their products for a specified amount of time. I regret the delay in responding. NHTSA has addressed the availability issue you raise in a July 31, 1986, letter to Ms. Ziomek of Washington, Michigan, a copy of which is enclosed. As explained in that letter, NHTSA does not specifically require child restraint manufacturers to make replacement parts available for any child restraint. However, manufacturers must be prepared to meet their recall obligations under the National Traffic and Motor Vehicle Safety Act. That law requires that, in the event of a safety-related defect or non-compliance with a safety standard, manufacturers provide a remedy without charge to consumers for eight years after purchase. With regard to your statement about an existing Federal regulation requiring automobile manufacturers to make replacement parts available for 10 years, NHTSA does not have such a requirement. However, automobile manufacturers have the same recall responsibilities described above for safety-related defects and non-compliances. Further, we understand manufacturers commonly follow a voluntary practice of making replacement parts available for vehicle parts likely to become worn or damaged for a 10-year period, which to the best of our knowledge has usually proven adequate to meet general consumer demand. I hope this information is helpful. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure; |
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ID: aiam0351OpenMr. Martin Rothfield, Manager, Quality Assurance, Ideal Corporation, 435 Liberty Avenue, Brooklyn, NY, 11207; Mr. Martin Rothfield Manager Quality Assurance Ideal Corporation 435 Liberty Avenue Brooklyn NY 11207; Dear Mr. Rothfield: In your letter of May 4, 1971, to Francis Armstrong you reques permission to conduct testing of turn signal and hazard warning signal flashers pursuant to SAE Standard J823b, 'Flasher Test Equipment,' April 1968.; Federal Motor Vehicle Safety Standard No. 108 incorporates by referenc SAE Standard J590b, 'Automotive Turn Signal Flashers,' October 1965, and SAE Recommended Practice J945, 'Vehicular Hazard Warning Signal Flasher,' February 1966, both of which specify test circuitry and equipment according to 'SAE J823.' It is my understanding that the major difference between J823 and J823b, which becomes the appropriate sub-referenced standard on January 1, 1972, is the specification in the latter that 'The required voltage tests [for variable-load flashers] with maximum bulb load shall be conducted without readjusting each corresponding power supply voltage, previously set with minimum bulb load.' It appears that J823 was written before variable load flashers were in general use and that this is the reason for omission of this specification from J823. Since J823b includes all the requirements of the presently referenced SAE standard, you may proceed to implement it immediately.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam0782OpenMr. Jacinto Navarro, 1701 E. Frierson Avenue, Tampa, Florida 33610; Mr. Jacinto Navarro 1701 E. Frierson Avenue Tampa Florida 33610; Dear Mr. Navarro: I am writing in response to your letter of July 5, 1972, regardin Standard No. 125, Warning Devices. You ask whether the manufacture of the warning device you propose would be permitted under the standard. As stated in my letter to you dated July 11, 1972, the device must meet the requirements of Standard 125. It appeared from the picture of your device which you submitted that the device would fail to meet a number of these requirements.; You also ask what type of energy the phrase, 'self-contained energ source' refers to. The phrase refers to energy used by a device to provide a warning signal, as contrasted with reflective or luminous devices that utilize exogenous light. Thus the fact that your device utilizes compressed air and contains a magnet does not make it a device with a self-contained energy source within the meaning of Standard 125,; Sincerely, Richard B. Dyson, Assistant 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.