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: aiam2064OpenMr. John H. Elgin, Continental Hydraulic Hose Corp., State Route 182 East, P.O. Box 277, Upper Sandusky, Ohio 43351; Mr. John H. Elgin Continental Hydraulic Hose Corp. State Route 182 East P.O. Box 277 Upper Sandusky Ohio 43351; Dear Mr. Elgin: #This responds to your letter of August 28, 1975 concerning the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #Notice 18 (40 FR 38159, August 27, 1975) amended the standard to facilitate the depletion of inventories of brake hose, end fittings, and assemblies which do not meet certain labeling requirements. With regard to the assembly banding requirement, the amendment merely extends the period during which vehicle manufacturers may use unbanded assemblies which were manufactured before March 1, 1975. There is no change in the requirement that assemblies manufactured on and after that date (other than those assembled and installed by a vehicle manufacturer in vehicles manufactured by him) be labeled with a band as specified in S5.2.4 of the standard. #Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam4387OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Assoc., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Assoc. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: With reference to your phone conversation with Make Peskoe on Septembe 8, I have enclosed a copy of an NHTSA opinion which concludes that a person adding a snow plow to a completed vehicle is not required to certify the vehicle. In such a case, the existing certification label should be left in place. You should note that the opinion also states that if the mounting of the snow plow causes the vehicle not to conform to any applicable motor vehicle safety standard, and the vehicle is not brought back into conformity before sale, the person mounting the plow will be violating section 108(a)(1) of the National Traffic and Motor Vehicle Safety act, and will be subject to civil penalties and other sanctions as prescribed in sections 109 and 110 of the Act.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4386OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Assoc., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Assoc. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: With reference to your phone conversation with Make Peskoe on Septembe 8, I have enclosed a copy of an NHTSA opinion which concludes that a person adding a snow plow to a completed vehicle is not required to certify the vehicle. In such a case, the existing certification label should be left in place. You should note that the opinion also states that if the mounting of the snow plow causes the vehicle not to conform to any applicable motor vehicle safety standard, and the vehicle is not brought back into conformity before sale, the person mounting the plow will be violating section 108(a)(1) of the National Traffic and Motor Vehicle Safety act, and will be subject to civil penalties and other sanctions as prescribed in sections 109 and 110 of the Act.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2347OpenMr. Charles R. Cheatham, General Partner, Moto Villa, Ltd. 1635 Rogers Avenue, San Jose, California 95116; Mr. Charles R. Cheatham General Partner Moto Villa Ltd. 1635 Rogers Avenue San Jose California 95116; Dear Mr. Cheatham: #This is in response to your May 27, 1976, lette concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to brake hose assemblies that you import and contemplate importing for use in motorcycles. #I understand that you presently import brake hose assemblies for use only on off-road, moto- cross motorcycles. These assemblies are not 'motor vehicle equipment' as that term is defined in Section 102(4) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C 1391(4)) (the Act). Therefore, they are not subject to any requirements of Standards No. 106-74. #The other assemblies that you contemplate importing for onroad use, however, are subject to the standard. Your letter indicates that the manufacturer of the assemblies is prepared to affix bands to them, certifying that they meet all the performance requirements of the standard, but that he is not yet able to obtain hose and end fittings that are labeled pursuant to S5.2. The relief that you have requested, however, is found in S12, which Reads as follows: #>>>*Brake hose assemblies manufactured from March 1, 1975, to August 31, 1976*. Notwithstanding any other provision of this standard, a brake hose assembly manufactured during the period from March 1, 1975, to August 31, 1976, shall meet each requirement of this standard, except that the assembly may be constructed of brake hose which meets every requirement of the standard for hose other than the hose labeling requirements of S5.2, S7.2 and S9.1, and the assembly may be constructed of end fittings which meet every requirement of the standard for end fittings other than the end fitting labeling requirements of S5.2, S7.2, and S9.1.<<<#You should note that the critical date for application of this section is the assembly's date of manufacture, rather than that of importation. #Please note further that Section 110(e) of the Act requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United Sates to designate a permanent resident of the United States as his agent upon whom services of all processes, orders, notices, decisions, and requirements may be made. #You state in your letter that the brake system products that you plan to import are manufactured by Gri Me Ca S.P.A In order to comply with section 110 of the Act it is necessary that Gri Me Ca designate an agent in the United States for service of process. There is no requirement in the Act that a motor vehicle Importer, located in the United States, designate an agent. #In order for the designation to be effective, it is necessary that the procedural requirements of 49 CFR 551.45 (enclosed) be fulfilled by the submission of the following information: #1. A certification that the designation is valid in form and binding on the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made, #2. The full legal name, principal place of business and mailing address of the manufacturer of the brake system components, #3. Marks, trade names, or other designations of origin of any of the manufacturer's products which do not bear his name, #4. A statement that the designation shall remain in effect until withdrawn or replaced by the manufacturer, #5. A declaration of acceptance duly signed by the agent appointed, which may be an individual, a firm, or a U.S. corporation, and #6. The full legal name and address of the designated agent. #In addition, the designation must be signed by one with authority to appoint the agent, the signer's name and title should be clearly indicated beneath his signature. #If you have any questions concerning these requirements, please do not hesitate to contact me. #Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam5474OpenMr. Fredd Scheys President S.E.C. Carat, Inc. 1379 Old Railroad Bed Road Madison, AL 35758-9002; Mr. Fredd Scheys President S.E.C. Carat Inc. 1379 Old Railroad Bed Road Madison AL 35758-9002; Dear Mr. Scheys: This responds to your FAX of January 25, 1995, to Joh Womack of this Office asking whether the interpretation letter sent to you on November 16, 1992, and confirmation letter sent you on March 8, 1993, remain valid. This confirms that these letters remain valid. We note that the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) was recodified in July 1994. The correct citation today is 49 U.S.C. Chapter 301 - Motor Vehicle Safety. The first full paragraph of the second page of the November 16, 1992, letter refers to 'Title 15, United States Code, section 1397(b)(2).' Under the recodification, the citation has become 'Title 49 United States Code, section 30122(b)'. Further, the quoted phrase in that paragraph that reads 'knowingly rendering inoperative in whole or in part any device of element of design installed in accordance with a Federal motor vehicle safety standard' has been restated to read 'knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard.' But the meaning remains the same and there is no substantive change in the prohibition. Sincerely, Philip R. Recht Chief Counsel; |
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ID: aiam0512OpenMr. Donald R. Meton, Systems Safety Engineer, Oshkosh Truck Corporation, P.O. Box 560, Oshkosh, WI 54901; Mr. Donald R. Meton Systems Safety Engineer Oshkosh Truck Corporation P.O. Box 560 Oshkosh WI 54901; Dear Mr. Meton: This is in reply to your letter of December 1, 1971, enclosing diagram of a revised 'Vehicle Identification Plate,' and requesting our approval, based on the Certification regulations. Your submission of this revised diagram is in response to our letter to you dated November 10, 1971, wherein we disapproved of an earlier version of the identification plate due to the manner in which the axle manufacturer's ratings of the axles were presented.; In your revised diagram, you refer to the ratings in question as th axle manufacturers 'gross weight ratings.' We believe that this language is still subject to being easily confused with the GAWR required on the Certification label, and we cannot conclude that wording the label in this fashion is consistent with the Certification regulations.; In our letter of November 10 we stated, 'If you wish to provid information based on the vehicle's axle capability, we prefer that it not be represented as a vehicle or axle weight rating, but that it be described as the axle manufacturers rating of the axles.' Thus, in our opinion elimination of the words 'gross weight' from your revised label will eliminate the conflict between your vehicle identification plate and the Certification requirements.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1514OpenMr. Sergio Campanini, Vice President, Marketing, The Berg Manufacturing Company, 333 East Touhy Ave., Des Plaines, IL 60018; Mr. Sergio Campanini Vice President Marketing The Berg Manufacturing Company 333 East Touhy Ave. Des Plaines IL 60018; Dear Mr. Campanini: This responds to your December 21, 1973, letter and subsequen communication with Mr. Sidney Williams of the NHTSA Handling and Stability Division asking if a check valve located at the isolated reservoir (as pictured in your schematic drawing) to protect the trailer service reservoir(s) would comply with S5.2.1.5 of Standard No. 121, *Air brake systems*.; The check valve may be placed at the isolated tank to protect th trailer service reservoir as specified in S5.2.1.5.; It appears from your schematic that a single failure in the servic brake system could cause loss of service brakes on both trailer axles. It should be noted that if this arrangement is used and a significant safety problem results, it would be subject to NHTSA safety defect authority.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1762OpenMr. Donald J. Gobeille,Volvo of America Corporation,Rockleigh, New Jersey 07647; Mr. Donald J. Gobeille Volvo of America Corporation Rockleigh New Jersey 07647; Dear Mr. Gobeille::#Please forgive the delay in responding to you letter of November 19, 1974, which requested an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *brake Hoses*, as applied to short lengths of vacuum brake hose.#To fit the information required by S9.1 of the standard on short lengths of hose, you have suggested a labeling format consisting of the required information presented in two lines,#>>>'each in block capital letters and numerals at least one eighth inch high, placed adjacent to one another and separated by the minimum space necessary to assure clarity. The label would occupy no more than three eighths of an inch on a hose approximately two inches in circumference (5/8 inch OD)'.<<<#Because the two lines would be close enough to prevent confusion with any optional labeling which might appear on the opposite side of the hose, it appears that the format you have described complies with the requirements of S9.1 of Standard No. 106-74. #Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2552OpenMr. David T. Schellhase, P.O. Box 124, Pompano Beach, Florida 33061; Mr. David T. Schellhase P.O. Box 124 Pompano Beach Florida 33061; Dear Mr. Schellhase: This responds to your February 17, 1977, letter inquiring whether yo may inlay whitewall ring on black tires. You state that in the process a groove is cut around the tire and a white compound is inserted into the groove.; Assuming that you are discussing applying this process to new passenge car tires, whether the process is permissible depends upon whether or not it adversely affects the tire's compliance with Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires*, which prescribes performance requirements for all passenger car tires sold in the United States. A copy of the standard is enclosed.; If after using the process the tire will not comply with Standard No 109, the use of the process is prohibited, and its use can result in the imposition of civil penalties of up to $1,000 per tire and of other sanctions as well (15 U.S.C. 1397(a) (1), 1398, 1399). In addition, it is the responsibility of the one who wishes to use the process to determine whether it will cause the tires to fail the standard.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0956OpenMr. L.A. Volberding, Administrative Manager, Kar-Kraft, Inc., 10611 Haggerty Street, Dearborn, Michigan 48126; Mr. L.A. Volberding Administrative Manager Kar-Kraft Inc. 10611 Haggerty Street Dearborn Michigan 48126; Dear Mr. Volberding: "This is in reply to your letter of December 14, 1972, to Mr. Schneide concerning the relationship j of a certain motorcycle fuel control system to Motor Vehicle Safety Standard No. 123. The system you describe incorporates an automatic fuel shutoff feature with a manual reserve control. You asked whether the fuel control system is permissible under Standard No. 123, and if it must be identified in accordance with the standard."; As Mr. Vinson of our staff advised you, Standard No. 123 does no require a fuel control system of a particular design, but if a manual fuel shutoff control is provided, it must be located and operated in the manner specified in Table 1. Since your system does not incorporate a manual shutoff control, it is not covered by the location and operational requirements of the Table. Table 3 does require identification of the 'fuel tank shutoff valve' which covers all valves regardless of the design of the fuel control system. We have no objection to your proposed method of identification.; Yours truly, 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.