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: aiam1591OpenMr. David E. Martin,Director, Automotive Safety Engineering,General Motors Corporation,General Motors Technical Center,Warren, Michigan 48090; Mr. David E. Martin Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center Warren Michigan 48090; Dear Mr. Martin:#This responds to your letter of August 14, 1974 requesting an interpretation of Motor Vehicle Safety Standard No. 106-74, *Brake Hoses* (Docket 1-5, Notice 11, published on June 28, 1974), regarding its applicability to specific hydraulic brake booster hoses used in General Motors products.#As indicated in notice11, it is the National Highway Traffic Safety Administration's (NHTSA) intention to exempt from the requirements of the standard hydraulic booster lines subject to a different working environment than brake hose, pending development of special performance requirements for such lines. General Motors' interpretation that the hydraulic booster hoses used in the systems described in your August 14 letter are exempted from the standard requirements is correct. The system described in your Attachment A is considered to incorporate an accumulator integral with the brake booster assembly. Hence all of the hoses run between the power steering pump and the accumulator (either directly or via the power steering gear) and are accordingly exempted per Notice 11 preamble. The hoses used in the system described in your Attachment B are exempted by virtue of the provision of redundant booster poser by the independent electro-hydraulic pump.#a future amendment to FMVSS 106 to eliminate ambiguity in respect to the standard's applicability to hydraulic booster hoses is currently under consideration. Any such amendment will be consistent with the present interpretation.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam1668OpenMr. Max L. Hill, Camping Trailer Division, Coleman Company, Incorporated, P. O. Box 111, Somerset, PA 15501; Mr. Max L. Hill Camping Trailer Division Coleman Company Incorporated P. O. Box 111 Somerset PA 15501; Dear Mr. Hill: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 1,100 - 1975 Valley Forg camping trailers with McCreary tires size 5.70-8 which may experience tread delamination.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74- 0206*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject vehicle does not contain the precise language which is required by Part 577 (49 CFR), the Defect Notification regulation. A copy of this regulation is enclosed. Specifically, the second sentence of your letter describes the defect as existing in the tires, where it should have described the defect as existing in the vehicle itself. The reference to 'item of motor vehicle equipment' in Part 577 applies only to equipment campaigns where vehicles are not involved.; Since this discrepancy in your notification letter does not appear t discourage owner response, mailing of a revised letter will not be required. It is hoped that these comments will assist you in the event that another defect notification campaign becomes necessary at some time in the future.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam0904OpenMr. Newel W. Hunter, Public Relations Department, American Plywood Association, 1119 A Street, Tacoma, WA 98401; Mr. Newel W. Hunter Public Relations Department American Plywood Association 1119 A Street Tacoma WA 98401; Dear Mr. Hunter: This is in response to your letter of October 25, 1972, in which yo ask whether there are any NHTSA requirements applicable to 'do-it-yourself' plans for camper trailers.; Certain Federal requirements are applicable to the camper trailer which will be built based on your plans. These are Federal Motor Vehicle Safety Standard No. 108, 'Lamps, Reflective Devices, and Associated Equipment' (49 CFR 571.108). Requirements which we expect to issue in the near future will apply to the tires with which such trailers are equipped (proposed Standards Nos. 119 and 120). Moreover, manufacturers of these trailers are required by NHTSA 'Certification' regulations (49 CFR Part 567) to certify the trailer's conformity with the motor vehicle safety standards. These requirements apply to the finished trailer itself, and not to the plans for it, but the plans should include steps that will cause the finished trailer to conform to all applicable requirements.; I have enclosed directions on how you may obtain copies of NHTS requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2742OpenMr. John Bonita, Jerome Avenue Dealers Association, 217 Broadway, Bronx, NY 10007; Mr. John Bonita Jerome Avenue Dealers Association 217 Broadway Bronx NY 10007; Dear Mr. Bonita: This is in response to your letter of December 1, 1977, requestin information on the Federal odometer disclosure law.; You asked whether an employee has the authority to sign an odomete disclosure statement relating to the purchase of vehicles sold dealer to dealer. Section 580.4 of Title 49, Code of Federal Regulations, requires each transferor of a motor vehicle to furnish to the transferee a written statement of the mileage traveled by the vehicle. 'Transferor' is defined as 'any person who transfers his ownership in a motor vehicle by sale, gift, or any means other than by creation of a security interest.' In a dealer-to-dealer transaction, as in all other transactions, the owner of the vehicle is responsible for signing the disclosure statement. He may assign that responsibility to an employee or representative. The transferor, however, as the owner of the vehicle, nevertheless remains liable for the actions of his employee.; You also raised the question in your telephone call of January 18, wit Kathy DeMeter of my staff, whether in a wholesale transaction all vehicles could be listed on one invoice as long as separate disclosure statements are issued for each. The National Highway Traffic Safety Administration is concerned with the issuance of correct mileage statements for each vehicle and does not have any objection to all the vehicles being listed in one invoice.; The sample 'Odometer Statement' which you enclosed with your lette meets all of the requirements of the Federal regulation. Thank you for your cooperation in preparing the revised statements.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam1696OpenMr. Harold Dvorachek,Product Engineer,The Berg Manufacturing Company,333 East Touhy Avenue,Des Plaines, Illinois 60018; Mr. Harold Dvorachek Product Engineer The Berg Manufacturing Company 333 East Touhy Avenue Des Plaines Illinois 60018; Dear Mr. Dvorachek:#This responds to your letter of October 25, 1974 requesting an interpretation of Standard No. 106-74, *Brake hoses*, as it applies to the labeling of air brake hose end fittings which use sacrificial sleeves.#>>>S7.2 states:#In the case of an end fitting intended for use in a reuseable assembly, 'AI' or 'AII' shall indicate use with Type I or type II hose respectively.<<<#Since an end fitting which uses a sacrificial sleeve is defined by S4 to be a permanently attached end fitting, it does not fall into the classification 'End fitting[s] intended for use in a reuseable assembly.' Therefore, it must be labeled with the designation 'A' rather than any of the following: 'AI', 'AII', 'AI-AII'.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2122OpenHonorable John P. Murtha, House of Representatives, Washington, DC 20515; Honorable John P. Murtha House of Representatives Washington DC 20515; Dear Mr. Murtha: This responds to your November 5, 1975, request for the criteri necessary for construction of testing equipment used to demonstrate compliance with Standard No. 121, *Air Brake Systems*.; The motor vehicle safety standards, including Standard No. 121, ar established as requirements that vehicles must be capable of meeting if tested by the National Highway Traffic Safety Administration (NHTSA). However, the standards are not developed as demonstration procedures that detail methods a manufacturer would use to establish that its products comply. The development of actual test protocols to determine that products conform to the requirements is the responsibility of the regulated industry and the associated industries that service them.; Thus the Thiele Corporation, as a manufacturer of air-braked vehicles may choose whatever test method gives it an adequate basis for certification that its products comply (15 U.S.C. S 1397(a)). Test equipment has been developed by several commercial sources, and Thiele can choose proper systems by consulting with the manufacturers of the brake components it uses. As for specifications for a test track, actual road tests are not necessary to establish compliance with Standard No. 121 where other reasonable means, such as engineering calculations coupled with laboratory tests, can be used to the same effect. Supplier warranties and instructions are one of the primary means by which small assemblers ascertain that their products conform.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4202OpenMr. Skip Maraney, National Star Route Mail Contractor Association, 324 East Capitol Street, Washington, DC 20003; Mr. Skip Maraney National Star Route Mail Contractor Association 324 East Capitol Street Washington DC 20003; Dear Mr. Maraney: This responds to your telephone inquiry about whether our regulation would prohibit the installation of a right hand drive steering system in a motor vehicle. We do not have any standards that prohibit the use of a right hand drive steering system. We have, however, issued two safety standards (Standard Nos. 203 and 204) that set performance requirements which apply to any steering system, whether left or right hand drive, installed in new passenger cars and light trucks, buses, and multipurpose passenger vehicles. A copy of each of these standards is enclosed.; You also asked about the agency's regulations on the importation o motor vehicles. I have enclosed a copy of a publication, 'Instructions Handbook for Complying with Regulations on Imported Vehicles,' which will provide you with information about our importation regulations.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0068OpenMr. William Lagerquist,Vice President,Minnesota Automotive, Inc.,502 Patterson Avenue,.Mankato,Minnesota 56001; Mr. William Lagerquist Vice President Minnesota Automotive Inc. 502 Patterson Avenue .Mankato Minnesota 56001; Dear Mr. Lagerquist:#Thank you for your letter of April 1, 1968, to th Motor Vehicle Safety Performance Service, concerning compliance with the Federal Motor Vehicle Safety Standard No. 105.#Basically, when a car dealer modifies a conforming vehicle, he then assumes responsibility for the vehicle s compliance to all applicable standards if that vehicle is distributed to a purchaser for purposes other than resale. Specifically, if a car dealer installs the Model 7900 Driver Training Brake on a conforming vehicle that he sells, than compliance to the Federal Motor Vehicle Safety Standard No. 105, as well as other applicable standards, is required. in the case where the dealer owns and loans the vehicle with the installed Model 7900, we would hope that he would again comply.#The enclosed ,literature may be of additional assistance to you in response to your inquiry.#Sincerely,Joseph R. O Groman,Acting Director,Office of Performance Analysis,Motor Vehicle Safety Performance Service; |
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ID: aiam2389OpenMr. William R. Rodger, Vice President, Advanced Programs, Rockwell International, 2135 West Maple Road, Troy, MI 48084; Mr. William R. Rodger Vice President Advanced Programs Rockwell International 2135 West Maple Road Troy MI 48084; Dear Mr. Rodger: This responds to Rockwell International's February 23, 1976, reques for confirmation that the deactivation of automatic adjusters is acceptable during burnish procedures of Standard No. 121, *Air Brake Systems*, at the option of the manufacturer.; The procedure that you recommend is not permitted by any provision o Standard No. 121. The NHTSA would consider some provision to deal with the overadjustment of automatic adjusters upon receipt of technical data showing justification for such action. Based on consideration of the data received and a petition for amendment, the agency could commence a rulemaking proceeding in accordance with established procedures.; It should be noted that the option in FMVSS 105-75 that you describ requires that the automatic adjusters be deactivated for the entire test sequence, not just the burnish procedure.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2118OpenMr. LeRoy E. Mueller, President, Wisconsin Trailer Co., Inc., Richfield, WI 53076; Mr. LeRoy E. Mueller President Wisconsin Trailer Co. Inc. Richfield WI 53076; Dear Mr. Mueller: The Federal Highway Administration's Bureau of Motor Carrier Safety ha forwarded to the National Highway Traffic Safety Administration (NHTSA) your September 17, 1975, petition to establish a ruling that trailers with a gross vehicle weight rating (GVWR) of 50 tons or less are required to establish load-carrying capacity at a speed of 50 mph. Heavier trailers would be required to display signs of their maximum rated speed if less than 50 mph.; The NHTSA has already issued a ruling in this area, a copy of which i enclosed for your information. It requires that the Gross Axle Weight Rating (GAWR) and GVWR on the vehicle certification plate be calculated on the basis of the vehicle's maximum attainable speed, or 60 mph, whichever is lower.; The NHTSA is also considering rulemaking to amend the definition o GAWR in conformity with this interpretation. Your letter will be considered as a comment on this rulemaking.; Sincerely, Frank Berndt, Acting 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.