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 |
|---|---|
ID: aiam3113OpenMs. Mary Ann McClure, Bob Maxant's Illinois Harley-Davidson Sales, Inc., 6510 Roosevelt Road, Oak Park, IL 60304; Ms. Mary Ann McClure Bob Maxant's Illinois Harley-Davidson Sales Inc. 6510 Roosevelt Road Oak Park IL 60304; Dear Ms. McClure: This responds to your letter asking how long you should retain certai records relating to the sale of motorcycles and motorcycle parts.; The National Highway Traffic Safety Administration (NHTSA) has som record retention requirements that apply to manufacturers of motor vehicles and motor vehicle equipment. Dealers are required to aid manufacturers in the maintenance of their records. For example, you must supply manufacturers with information relating to the purchasers of motor vehicles that you sell so that the manufacturer can maintain a list of purchasers.; Dealers are not required by the NHTSA to maintain records on vehicle or equipment they sell. Accordingly, with respect to the records indicated in your letter, you may use your own business judgment as to when to dispose of them.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2418OpenMr. William G. Matthews, III, Division Manager, Universal Imports, 14622 Southlawn Lane, Rockville, Maryland 20850; Mr. William G. Matthews III Division Manager Universal Imports 14622 Southlawn Lane Rockville Maryland 20850; Dear Mr. Matthews: This is in response to your September 13, 1976, letter concerning ' line of racing/rally tires that are not Department of Transportation marked.'; I understand from your recent telephone conversation with Mar Schwimmer of my staff that the tires with which you are concerned are of the following size designations: 165/70 HR 10, 225/60 HR 14, 225/60 HR 13, and 195/70 HR 13.; Section S6 of Federal Motor Vehicle Safety Standard No. 109, *Ne Pneumatic Tires--Passenger Cars*, reads as follows:; >>>S6. *Nonconforming tires*. No tire of a type and size designatio specified in Table I of Appendix A that is designed for use on passenger cars and manufactured on or after October 1, 1972, but does not conform to *all the requirements of this standard*, shall be sold, offered for sale, introduced or delivered for introduction in interstate commerce, or imported into the United States, for any purpose. (emphasis added)<<<; because the size designations of the tires in question all appear i Table I of Appendix A, these tires are subject to the prohibitions of S6 unless they were manufactured before October 1, 1972. 'All the requirements of the standard' include both performance and labeling requirements.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1108OpenCharles E. Smith, Purchasing Manager, Young Windows, Inc., Brook and Colwell Roads, Conshohocken, PA 19428; Charles E. Smith Purchasing Manager Young Windows Inc. Brook and Colwell Roads Conshohocken PA 19428; Dear Mr. Smith: This is in reply to your letter of March 27, 1973, requestin information on requirements for marking glazing materials for use in motor vehicles, and whether you must furnish cleaning instructions for glazing you manufacture.; Your questions regarding marking requirements are similar to thos raised by Mrs. Lewis Cook of your company, in a letter of February 20, 1973. We responded to that letter on April 4, 1973 (a copy is enclosed), and you should have received our response by this time. In that letter we stated that your responsibilities as a manufacturer who cuts glazing materials are to mark that material in conformity with section 6 of ANS Z26.1-1966. We should amplify our response in that letter by stating that if the glazing material as you receive it already contains the required markings, you may use those markings in meeting the requirements.; You indicate your question concerning requirements for cleanin instructions arises from a customer to whom you furnished Rohm and Haas Plexiglas. Paragraph S5.2.1.3 of Standard No. 205 provides that glazing materials designated AS-12 or AS-13 must be labeled (using a label that is removable by hand) with cleaning instructions. If the Rohm and Haas Plexiglas is of either of these glazing designations, it must be so labeled. If it is not, there are no requirements that cleaning instructions be furnished.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2156OpenMr. Alberto Negro, Parklane Towers West, One Parklane Boulevard, Dearborn, MI 48126; Mr. Alberto Negro Parklane Towers West One Parklane Boulevard Dearborn MI 48126; Dear Mr. Negro: This is in response to your letter of November 6, 1975, requesting a interpretation of paragraph S5. of Motor Vehicle Safety Standard No. 219, *Windshield Zone Intrusion*.; You asked whether the standard permits marking or penetration of th protected zone to a depth greater than 1/4 inch, by windshield wipers during a barrier crash test. Please excuse our delay in answering your question.; Paragraph S5. of Standard No. 219 states that 'no part of the vehicl outside the occupant compartment, except windshield molding and *other components designed to be normally in contact with the windshield*, shall penetrate the protected zone template' (emphasis added.) Windshield wipers are 'components designed to be normally in contact with the windshield.' Therefore, Standard No. 219 does allow penetration of the protected zone by windshield wipers during the barrier crash test.; Please note that Standard No. 219 was amended, Docket 74-21, Notice 3 to substitute the term 'daylight opening' for 'windshield opening', and to add the new term to the requirements of paragraph S5. The amendments are effective September 1, 1976, for passenger cars, and September 1, 1977, for multipurpose passenger vehicles, trucks and buses. I am enclosing a copy of the notice for your information.; Please contact us if we can (sic) of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2934OpenMr. Richard D. Phillips, Attorney at Law, P.O. Box 66, Ludowici, GA 31316; Mr. Richard D. Phillips Attorney at Law P.O. Box 66 Ludowici GA 31316; Dear Mr. Phillips: This responds to your December 15, 1978, questions about the status o school buses subject to recall for antilock malfunction now that the 'no lockup' requirement of Standard No. 121, *Air Brake Systems*, has been invalidated in the cases of trucks and trailers. You also ask whether the antilock systems in question must be reconnected, whether the vehicles would thereby be made more or less safe, and what the effect of continued disconnection might be on liability considerations.; I have enclosed the agency's official interpretation of the effect o the invalidation on the operational status of vehicles equipped with antilock. In the case of vehicles subject to recall, we stated that section 154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1414) mandates an 'adequate repair,' and that, in the NHTSA's view, the benefits of 'no lockup' performance mandate the offer of repair and reconnection.; The letter also states that disconnection, consistent with regulation of other authorities and the instructions of the manufacturer, would not violate the Vehicle Safety Act. While the NHTSA finds that the repair would provide desirable 'no lockup' performance, we are unable to counsel you on the Long County Board of Education's liability if the system were not reconnected.; Sincerely, Joseph J. levin, Jr., Chief Counsel |
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ID: aiam0432OpenRoger Levin, Esq., Room 2000, 100 W. Monroe Street, Chicago, IL 60603; Roger Levin Esq. Room 2000 100 W. Monroe Street Chicago IL 60603; Dear Mr. Levin: This is in reply to your letter of July 23, 1971, concerning certai aspects of Motor Vehicle Safety Standard No. 205, 'Glazing Materials.'; You are correct in your statement that Standard No. 205, which has bee in effect since January 1, 1968, and was amended on September 19, 1968 (33 F.R. 14163) and March 1, 1969 (34 F.R. 3688), applies to a manufacturer of automobile sunroofs, 'either in kits for installation by others, or for direct installation by the sunroof manufacturer, in either case after the car has been completed.' To comply with the standard the sunroof material must meet the requirements for either AS1, AS2, AS3, AS4, AS5, AS10, or AS11 glazing material, as specified in ANSI Standard (formerly ASA Standard) Z26.1-1966, July 15, 1966. The 1969 amendment to this standard has not, as you state, been incorporated into Standard No. 205. However, a notice of proposed rulemaking published January 9, 1971 (36 F.R. 326), proposed to include that amendment. This matter is presently under consideration.; You are also correct in stating that a sunroof is an item of moto vehicle equipment, and not a motor vehicle. Certification may be made, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), by the statement you submit, 'Material Certified to Comply with U.S. Motor Vehicle Safety Standard No. 205', followed by the name of the manufacturer.; We are pleased to be of assistance. Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2556OpenHonorable Frank Horton, Chairman, Commission on Federal Paperwork, 1111 Twentieth Street, N.W., Washington, DC 20582; Honorable Frank Horton Chairman Commission on Federal Paperwork 1111 Twentieth Street N.W. Washington DC 20582; Dear Mr. Chairman: This responds to your March 9, 1977, letter requesting a copy of th report prepared by the National Highway Traffic Safety Administration (NHTSA) in response to the Senate Commerce Committee's inquiries concerning the recordkeeping requirements of the tire registration program. I too am interested in reducing the burden upon the public occasioned by unnecessary paperwork. In accordance with your request, I am enclosing a copy of the NHTSA report.; Regarding your comments concerning the viability of a voluntary tir registration technique to replace the present registration program, you should note that the NHTSA has considered the possibility of a voluntary registration procedure similar to the warranty card procedure utilized by appliance manufacturers. Through informal inquiries of appliance manufacturers, the agency discovered that return of warranty cards averages about 50 percent in the case of expensive appliances and falls as low as 10 percent in the case of 10- to 35-dollar items. An entirely separate problem arises with voluntary registration of tires in that the purchaser cannot be expected to distinguish the serial number from other numbers that appear on each tire. More important, the identification number is placed on the side opposite the whitewall on many tires, and it is probable that the purchaser would fail to locate the correct number in the typical situation where the tires are mounted on his vehicle before he sees them.; If I can be of further assistance, please contact me. Sincerely, Brock Adams |
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ID: aiam2131OpenMr. J. C. Eckhold, Director, Automotive Safety Office, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold Director Automotive Safety Office Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. Eckhold: This is in response to your letter of September 24, 1975, in which yo ask whether it is permissible to test certain 1978 vehicles for compliance with Standard No. 301, *Fuel System Integrity*, with open vapor vent tube pressure relief valves.; The Federal motor vehicle safety standards do not specify the test which you must perform. They do specify conditions and procedures under which the National Highway Traffic Safety Administration (NHTSA) will conduct its compliance testing. S7.1.1 and S7.1.2 of Standard No. 301 specify that the vehicle's fuel system shall contain Stoddard solvent rather than fuel and, by implication, that the engine shall not be running. If, as you indicate, one consequence of the engine's not running is that a certain pressure relief valve in the vapor vent tube is closed, then that valve must remain closed during the NHTSA's compliance testing, the existing standard could not be interpreted otherwise. Although in an actual collision any rollover would probably occur immediately after the initial impact, in some accidents vehicle occupants would be trapped for some period of time after rollover. Therefore, we do not consider that this interpretation creates, as you suggest, an artificial condition by subjecting the fuel tank to a potential vapor pressure build-up during preparation for the rollover test.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2516OpenMr. Donald I. Reed, Director of Engineering, Trailer Manufacturers Association, 401 North Michigan Avenue, Chicago, IL 60611; Mr. Donald I. Reed Director of Engineering Trailer Manufacturers Association 401 North Michigan Avenue Chicago IL 60611; Dear Mr. Reed: This is in reply to your letter of December 20, 1976 asking for clarification of the statement in my letter to you dated December 3, 1976, that 'the light emitted by one bulb must not be perceived as performing the function of the other in addition to its design function.'; It is evident from your letter and others that our previou interpretations of the term 'optical combination' have been found to be ambiguous and lacking in the objective criteria that a Federal motor vehicle safety standard must provide. We have reviewed the matter, and now wish to modify our previous interpretation. In our view a lamp is 'optically combined' when the same light source (i.e. bulb) and the same lens area fulfill two or more functions (*e.g.* taillamp and stop lamp, clearance lamp and turn signal lamp). A dual filament bulb would be regarded as the 'same light source'. In determining conformance, the photometric requirements for clearance and taillamp functions, where two bulbs are located in a single compartment, must be met with only the bulb energized that is designed to perform the specific function. But the 15 candlepower maximum under Standard No. 108, however, would be determined with both the taillamp and clearance lamp bulb energized. Further, the lamp must be located to meet requirements for both clearance and taillamps. Our re- interpretation means that the issue of light spill-over from one area of the lamp to another is irrelevant to conformance.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4299OpenMs. Paula J. Redford, Manager, Free Enterprise Company, 5417 Paseo, Kansas City, MO 64110; Ms. Paula J. Redford Manager Free Enterprise Company 5417 Paseo Kansas City MO 64110; Dear Ms. Redford: This responds to your March 12, 1976, request for a listing of Federa motor vehicle safety standards that apply to the manufacture of a fiberglass hardtop for installation on a Jeep. I am assuming that this top is an aftermarket item and is not incorporated by the Jeep Corporation as the vehicle roof of its product.; The only Federal motor vehicle safety standard applicable to this ite of aftermarket motor vehicle equipment is Standard No. 205, *Glazing Materials*, 49 CFR 571.205. Standard No. 205 specifies requirements for glazing materials used in motor vehicles and motor vehicle equipment, including a vehicle top such as you describe. Any glazing material used in the construction of your Jeep top must be certified as being in compliance with Standard No. 205, even though the top itself does not have to be certified. Generally, the prime glazing manufacturer or the glazing fabricator certifies the glazing, so your main concern as manufacturer of the Jeep top is to make certain that you use glazing that has been certified as being in compliance with the standard. If you obtain sheets of glazing from a prime glazing manufacturer and fabricate or mold the glazing yourself, you must mark and certify the glazing as specified in paragraphs S6.4 and S6.5 of Standard No. 205. A copy of the standard is enclosed for your information.; Sincerely, Stephen P. Wood, 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.