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: aiam1055OpenMr. Elmer A. Brown, Registrar, Department of Motor Vehicles, P.O. Box 1319, Sacramento, CA 95806; Mr. Elmer A. Brown Registrar Department of Motor Vehicles P.O. Box 1319 Sacramento CA 95806; Dear Mr. Brown: This is in response to your letter of March 12, 1973, concerning th compliance of a proposed California form with the Federal Odometer Disclosure Requirements, 49 CFR Part 580.; The use of a combination form such as that proposed is acceptable s long as it contains the information required in Part 580. We have reviewed the proposed form and find that it complies with Part 580.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2752OpenG. K. Pilz, Manager, Product Compliance, Mercedes-Benz of N.A., One Mercedes Drive, Montvale, NJ 07645; G. K. Pilz Manager Product Compliance Mercedes-Benz of N.A. One Mercedes Drive Montvale NJ 07645; Dear Mr. Pilz: This responds to your February 1, 1978, letter asking whether you certification label complies with the requirements of Part 567, *Certification*.Your certification would state the gross vehicle and axle weight ratings in both pounds and kilograms. In the past, the agency has permitted this approach for the purpose of international harmonization of measurements. Therefore, your proposed label appears to comply with the requirements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4107OpenMr. Wayne Ivie, Manager, Support Section, Oregon Department of Transportation, Motor Vehicles Division, 1905 Lana Avenue N.E., Salem, OR 97314; Mr. Wayne Ivie Manager Support Section Oregon Department of Transportation Motor Vehicles Division 1905 Lana Avenue N.E. Salem OR 97314; Dear Mr. Ivie: Thank you for your letter concerning Oregon's new vehicle code. Yo asked us to review the code and comment on possible Federal preemption of Oregon's laws for motor vehicle equipment. We apologize for the delay in responding to your inquiry.; On March 19, Ms. Hom of my staff explained in a telephone conversatio that this office is unable to undertake a general review of your state vehicle code as you requested. It would be more appropriate if your legal department reviewed your requirements.; Your letter also requested a clarification of our regulatory definitio of a 'bus.' You asked whether we have a definition of a 'bus' separate from definitions for 'school buses' or 'commercial motor buses.' You appeared to question whether privately-owned passenger vans would be classified as buses since Oregon currently considers 15-passenger vans as either 'passenger vehicles' or 'trucks.'; NHTSA's regulatory definitions for motor vehicles, issued for purpose of the Federal motor vehicle safety standards, are set forth at 49 CFR Part 571.3. We define a 'bus' as a motor vehicle, except a trailer, designed for carrying more than 10 persons. This definition would include 15-passenger vans, and would thus apply to both commercial motor coaches and privately-owned 15-passenger vans.; Our definition of a 'bus' is separate from our 'school bus' definition While the latter term incorporates our 'bus' definition, it includes further criteria based on the intended use of the vehicle. Under Part 571.3, a 'school bus' is a bus that is sold for purposes that include carrying students to and from school or related events (excluding common carriers in urban transportation). If a new 15-passenger van were sold for school transportation purposes, it would be considered a 'school bus' and would have to comply with NHTSA's school bus safety standards.; For purposes of understanding the interaction between Federal and stat vehicle definitions, it is important to distinguish NHTSA's motor vehicle safety standards from state safety standards. State motor vehicle safety regulations apply to the sale and use of motor vehicles. Oregon's vehicle definitions are relevant for determining state requirements applicable to the sale and use of particular classes of motor vehicles. On the other hand, our regulations apply to the manufacture and sale of new motor vehicles, and our definitions specify categories of vehicles subject to appropriate Federal motor vehicle safety standards. New vehicles included within particular categories must be certified as complying with the safety standards applying to that vehicle type. The applicability of our safety standards to a vehicle is not altered by the fact that a vehicle type is classified differently under state law. Thus, although Oregon classifies 15-passenger vans as passenger vehicles or trucks, manufacturers of new 15-passenger vans must manufacture those vehicles to Federal safety standards for buses, or school buses if intended for school use.; I hope this information is helpful. Please contact my office if yo have further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3320OpenMr. Dietmar K. Haenchen Administrator Vehicle Regulations Volkswagen of America, Inc. 27621 Parkview Boulevard Warren, Michigan 48092; Mr. Dietmar K. Haenchen Administrator Vehicle Regulations Volkswagen of America Inc. 27621 Parkview Boulevard Warren Michigan 48092; Dear Mr. Haenchen: This is in reply to your letter of April 2, 1980 asking for information of your interpretation of Section 4.31 of Motor Vehicle Safety Standard No. 108. This section states that lamps 'shall be securely mounted on a rigid part of the vehicle...that is not designed to be removed except for repair.' It is your belief that this section would allow a configuration in which back-up lamps and license lamps could be mounted on the deck lid. We concur with this interpretation. The requirement for rigidity is meant to ensure that lamps and reflectors do not sway in the wind on hinges or flexible mud flaps when the vehicle is in motion. The passenger cars you propose to manufacture will normally be operated with the deck lid closed and the lamps in full view on a rigid part of the vehicle as the standard requires. However, placement of a stop lamp and taillamp on a deck lid could be viewed as a defect in performance, and hence a safety related defect requiring notification and remedy. Sincerely Frank Berndt Chief Counsel; |
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ID: aiam2269OpenHonorable Vance Hartke, Chairman, Surface Transportation Subcommittee, Committee on Commerce, United States Senate, Washington, D.C. 20510; Honorable Vance Hartke Chairman Surface Transportation Subcommittee Committee on Commerce United States Senate Washington D.C. 20510; Dear Senator Hartke: This is in response to your letter of March 30, 1976, enclosing letter from Mr. Dennis Oser concerning the effective date of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars.*; Standard No. 119 became effective March 1, 1975, and applies t non-passenger-car tires manufactured on and after that date. From his reference to 'April 1, 1976', Mr. Oser appears to be concerned with the effective dates of 49 CFR 393.75, a regulation issued by the FEderal Highway Administration's Bureau of Motor Carrier Safety (BMCS). That regulation addresses the type of tires with which motor vehicles in use in interstate commerce must be equipped. Accordingly, I have forwarded your letter to the BMCS for further reply.; Sincerely, James B. Gregory, Administrator |
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ID: aiam2523OpenMr. 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 February 8, 1977, letter asking whether a Ne York state requirement mandating the installation of both side emergency doors and rear emergency doors in school buses would mean that both emergency doors would be required to comply with the school bus exit specifications in Standard No. 217, *Bus Window Retention and Release*.; The NHTSA has determined previously that only those exits required b S5.2.3 must meet the requirement specified for school bus emergency exits in Standard No. 217. Paragraph S5.2.3 requires either a rear emergency door or a side emergency door and a rear push out window. The side emergency door to which you refer is installed in addition to a rear emergency door. The presence of the rear emergency door, alone, satisfies the requirements of S5.2.3. Therefore, a side emergency door is not required by the standard and need not meet the specifications for school bus emergency exits. Emergency exits installed in school buses beyond those required in S5.2.3 must comply with regulations applicable to emergency exits in buses other than school buses. These requirements are also detailed in Standard No. 217.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1837OpenMr. Danny J. Lanzdorf, Supervising Engineer, Oshkosh Truck Corporation, P.O. Box 2566, Oshkosh, WI 54901; Mr. Danny J. Lanzdorf Supervising Engineer Oshkosh Truck Corporation P.O. Box 2566 Oshkosh WI 54901; Dear Mr. Lanzdorf: This is in reply to your letter of February 25, 1975, requesting ou review of certain sections of the 'Part 568' document Oshkosh wishes to use for all its vehicles.; We believe you may use a rubber stamp which states, 'Standard No. 12 Not Applicable' over the part of the document regarding conformity with Standard No. 121, for vehicles to which the standard does not apply. We would, however, add the words, 'to this vehicle.'; Your statement in the document regarding Standard No. 116 also conform to the requirements of Part 568.; Finally, you are correct with respect to the language of S 568.4(a)(7) The reference to '(7)' in that section should be '(6)'.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5176OpenSt. F. Steiner Consultant AET Network 2190 3rd Street San Francisco, CA 94107; St. F. Steiner Consultant AET Network 2190 3rd Street San Francisco CA 94107; "Dear Sir or Madam: We have received your 'Dear Mr. Van Orden' lette of May 4, 1993, which was addressed to me. You wish to import 3- and 4-wheeled vehicles from Europe 'for research and exploration', and have asked several questions relating to U.S. laws and D.O.T. requirements. Your first question is: 'Are there any safety standards and regulations for the above mentioned automobiles?' The answer is yes. All 3-wheeled motor vehicles are considered 'motorcycles' for purposes of compliance with the Federal motor vehicle safety standards that apply to motorcycles. Depending upon their configuration, but not upon their weight, 4-wheeled vehicles are either 'passenger cars', 'multipurpose passenger vehicles', 'trucks', or 'buses' for purposes of the safety standards. However, motor vehicles intended solely for purposes of research may be imported without the necessity of conforming them to the safety standards under the terms and conditions that the agency has set out in 49 CFR Part 591. Your second and third questions are whether there is a minimum speed standard regulation or weight limitations for the vehicles you wish to import. The answer is no. However, a motorcycle with 5-horsepower or less is considered a 'motor-driven cycle', and some of the motorcycle standards impose lesser requirements for motor-driven cycles, and motor-driven cycles whose speed attainable in l mile is 30 mph or less. Your fourth question relates to the conversions required to meet U.S. specifications and standards. As indicated previously, no conversion is required when the importation is solely for the purpose of research. If you wish to import vehicles that have been originally manufactured to meet the Federal motor vehicle safety, bumper, and theft prevention standards, the manufacturer will find those standards at 49 CFR Parts 571, 581, and 541, respectively. If you wish to import nonconforming vehicles for conversion after importation, then the agency must determine that the vehicles are eligible for entry pursuant to 49 CFR Part 593, and importation and conversion accomplished through a Registered Importer pursuant to 49 CFR Part 592. Your final question is whether the vehicles will be permitted on highways. This is a question that is not answerable under Federal law. Each State determines the criteria for licensing motor vehicles for use on the roads under its jurisdiction. If a State does not license a vehicle for on-road use (all terrain vehicles, minibikes, golf carts are examples), a basis exists for a manufacturer to determine that its vehicles are not 'motor vehicles.' If a vehicle is not a motor vehicle, i.e. one manufactured primarily for on-road use, then no Federal safety standards apply to it. If you have any further questions about the importation process, you should refer them to Mr. Van Orden at our Office of Vehicle Safety Compliance, Office of Enforcement. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1554OpenMr. Rick Shue,Product Safety Engineer,Volvo of America Corporation,Rockleigh, New Jersey 07647; Mr. Rick Shue Product Safety Engineer Volvo of America Corporation Rockleigh New Jersey 07647; Dear Mr. Shue:#This is in respond to your June 19, 1974,questio whether required hose labeling under Standard No. 106, *Brake hoses*, permits placing some required labeling on each of several hose sections which are joined together in one vacuum brake line to form the required label. You ask how a 2 3/8-inch section could otherwise be labeled.#It is not permitted under S9.1 to label a vacuum brake hose with only part of the required information, whether or not it appears with all other required labeling in the same brake line.#You state that 5 inches is required to place all labeling on vacuum hose. We do not understand why the legend could not be shortened to 2 3/8-inches or less. There is no width requirement for lettering and Notice 11 now permits labeling information to appear in any order on the hose to simplify cutting.#Please write again if we have misunderstood the problem you have posed.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam3354OpenMr. Rodney Ehrlich, Director of Engineering Monon Trailer Division, Evans Transportation Company, 117 North Walnut, P.O. Box 655, Monon, Indiana 47959; Mr. Rodney Ehrlich Director of Engineering Monon Trailer Division Evans Transportation Company 117 North Walnut P.O. Box 655 Monon Indiana 47959; Dear Mr. Ehrlich: This will confirm your telephone conversation with Mr. Frederi Schwartz of my office concerning your proposed compliance scheme for the Federal Motor Vehicle Safety Standard No. 115 - Vehicle identification number.; The National Highway Traffic Safety Administration (NHTSA) does no give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115. This system may be implemented immediately.; 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.