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: aiam2031OpenMr. Jack Johnson, 8400 East Slauson Avenue, Pico Rivera, CA 90660; Mr. Jack Johnson 8400 East Slauson Avenue Pico Rivera CA 90660; Dear Mr. Johnson: This responds to Motac's August 7, 1975, request for a determinatio that two platform trailers which are designed with a primary cargo-carrying surface which is less than 40 inches above the ground would qualify for exclusion from the requirements of Standard No. 121, *Air Brake Systems*, if manufactured before September 1, 1976.; I have enclosed a copy of the amendment to Standard No. 121 whic excludes heavy hauler trailers from the requirements of the standard until September 1, 1976. You should note that the '40-inch cargo-carrying surface' criterion is measured in the unloaded condition, and that the body must not be equipped with sidewalls unless they are easily removable.; There is no requirement that the vehicle be designed for a certain typ of cargo such as heavy machinery. Therefore your semi-trailers may qualify for the exclusion if they meet the criteria listed in the definition of heavy hauler trailer.; Sincerely, James B. Gregory, Administrator |
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ID: aiam1301OpenClyde M. Weaver, Esq., Moore, Weaver, Moore & Bradberry, 13185 Warwick Boulevard, P.O. Box 2228, Newport News, VA 23602; Clyde M. Weaver Esq. Moore Weaver Moore & Bradberry 13185 Warwick Boulevard P.O. Box 2228 Newport News VA 23602; Dear Mr. Weaver: Your letter to Secretary Brinegar of October 8, 1973, has been referre to me for reply.; A copy of Part 580, *Odometer Disclosure Requirements*, is enclosed This disclosure regulation became effective March 1, 1973, and we assume that the August 1972 date in your letter actually refers to an August 1973 sale which would be subject to the regulation.; Title 15 U.S.C. S 1939 provides a remedy for a violation of the Ac made with intent to defraud. A discrepancy between the odometer reading and the disclosure statement could be the result of error, or misunderstanding of the requirement, and by itself, would not establish an intent to defraud.; We are unfamiliar with the facts in the case you mentioned, and th above statement should not be construed as an opinion or evaluation of the merits of that case.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0826OpenMr. Gorou Utsunomiya, Chief, Liaison Engineer In U.S.A., Toyo Kogyo Co., Ltd., Detroit Office, 23777 Greenfield Road, Suite 462, Southfield, MI 48075; Mr. Gorou Utsunomiya Chief Liaison Engineer In U.S.A. Toyo Kogyo Co. Ltd. Detroit Office 23777 Greenfield Road Suite 462 Southfield MI 48075; Dear Mr. Utsunomiya: This is in reply to your letter of August 8, 1972, on the subject o the location of the anchorages for passive belt systems. We understand from your letter that you are considering using a door-mounted anchorage for your system, but we are uncertain as to the nature of your difficulties with Standard No. 210.; The standard does not prohibit door-mounted anchorages. If an anchorag can be placed on the door so that it directs the belt across the occupant at the angle specified in the standard, and if it also meets the strength requirements, then it would be considered to conform to the standard. It may be that the anchorage you are considering fails to provide the correct belt angle.; At this time there is no exemption provided for passive belts from th belt angle requirements of Standard No. 210. If you wish to petition for rulemaking to amend the requirements for passive belts, you should accompany your petition with full information concerning the system and the advantages of the proposed anchorage locations.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1076OpenMr. R. J. Marini, State of New Jersey, Division of Motor Vehicles, 25 South Montgomery Street, Trenton, NJ 08666; Mr. R. J. Marini State of New Jersey Division of Motor Vehicles 25 South Montgomery Street Trenton NJ 08666; Dear Mr. Marini: This is in response to your letter of March 5, 1973, concerning th recently issued Federal odometer disclosure requirements.; Although we have not had the opportunity to review the revised Ne Jersey certificate of ownership, it appears that New Jersey is proceeding along lines that could make the certificate usable for purposes of compliance with our regulations. We are concerned, however, about the possibility of variance between State and Federal procedures.; The Federal regulation requires the transferor to state the mileage o the odometer at the time of transfer. In addition, if he knows the odometer reading to be wrong, he must so state by indicating that the actual mileage is unknown. Provision for a disclosure of odometer error is essential to the Federal regulation, and it is not clear to us that the New Jersey certificate provides for such a disclosure.; With respect to the older vehicles - those not subject to a revise certificate of ownership - the form attached to your letter will satisfy the Federal requirements. A disclosure statement of this type is required by our regulation to be made upon each transfer of a vehicle. I would hope that all dealers in New Jersey are receiving, and giving, such statements in each motor vehicle transaction.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0970OpenMr. Bernard W. Weber, Executive Vice President, Wesbar Corporation, Box 577, West Bend, WI 53095; Mr. Bernard W. Weber Executive Vice President Wesbar Corporation Box 577 West Bend WI 53095; Dear Mr. Weber: This is in reply to your letter of January 3, 1973, to Mr. Schneide concerning Motor Vehicle Safety Standard No. 108.; Your first question is whether the standard requires items of lightin equipment to be marked according to SAE Standard J759a. The answer is no. A manufacturer, at his option, may mark equipment items with the symbol DOT as a certification of compliance with Standard No. 108. Standard No. 108 neither prohibits nor requires other marking of equipment. The NHTSA proposed in 1972 that equipment be marked in a manner somewhat similar to J759a but no definitive action has been taken on the proposal.; You also asked whether a clearance lamp could be mounted at 45 degree to serve the functions of both a clearance and side marker lamp, and whether it must bear the SAE designation 'PC' indicating its combination function. Your understanding is correct, that a combination lamp mounted at 45 degrees is permissible if it is successfully tested at that mounting angle for conformance to both clearance and side marker requirements. The designation 'PC' is not a current requirement of Standard No. 108 but has been proposed as the required marking symbol in the rulemaking action referred to earlier.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2198OpenMr. Hal H. Newell, Eaton Corporation, Government Relations Office, 815 Connecticut Avenue, N.W., Washington, DC 20006; Mr. Hal H. Newell Eaton Corporation Government Relations Office 815 Connecticut Avenue N.W. Washington DC 20006; Dear Mr. Newell: This responds to Eaton Corporation's January 21, 1976, question whether the Ninth Circuit Court of Appeals stay of Standard No. 121, *Air Brake Systems*, eliminated all requirements of the standard for the period of the stay, whether complying vehicles built prior to the stay may be modified so they do not comply, and whether non-complying vehicles built during the stay would have to be retrofitted upon reinstatement of the standard. Your other questions are no longer relevant in view of the recent reinstatement of the standard by the Supreme Court.; The NHTSA has interpreted the stay to have had the effect, nationwide of voiding the standard's force and effect as a whole during the period of January 16 through January 29, 1976.; Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safet Act prohibits the sale of a vehicle unless it is in conformity with applicable standards in effect on the date of its manufacture. Therefore, a vehicle manufactured in conformity with Standard No. 121 prior to January 16, 1976, would have to conform to the standard when sold. Non-complying vehicles built during the stay would not be required to be retrofitted under this provision, because the standard was not in effect on the date of manufacture.; Sincerely,, James B. Gregory, Administrator |
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ID: aiam1588OpenMr. Richard D. Henderson, Private Truck Council of America, Inc., 1101 Seventeenth Street, N.W., Washington, DC 20036; Mr. Richard D. Henderson Private Truck Council of America Inc. 1101 Seventeenth Street N.W. Washington DC 20036; Dear Mr. Henderson: This is in reply to your letters of July 25 and August 26, 1974 requesting inforamtion on NHTSA regulations applicable to regrooved tires.; You ask whether companies leasing trucks to other companies may equi the trucks with regrooved tires, and what tire standards apply.; The recent court decision regarding regrooved tires (*NAMBO* v *Volpe*, 483 F. 2d 1294 (D.C. Cir. 1973), *Cert*. *denied*,--U.S.--(1974)) held that under the National Traffic and Motor Vehicle Safety Act the NHTSA could permit only the sale of regrooved tires. Consequently, the leasing of regrooved tires is not prohibited, as is any other introduction of them into interstate commerce other than by a sale. The NHTSA recently amended its regrooved tire regulations to conform to this Court opinion.; We do not construe the opinion to prohibit the leasing of truck equipped with regrooved tires. The regulation applies only to the manner in which the tires themselves are obtained.; The standards applicable to regrooved tires are found in the Regroove Tire regulations (49 CFR Part 569). Regroovable tires manufactured after March 1, 1975, must also conform to Motor Vehicle Safety Standard No. 119.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1587OpenMr. Richard D. Henderson, Private Truck Council of America, Inc., 1101 Seventeenth Street, N.W., Washington, D.C. 20036; Mr. Richard D. Henderson Private Truck Council of America Inc. 1101 Seventeenth Street N.W. Washington D.C. 20036; Dear Mr. Henderson: This is in reply to your letters of July 25 and August 26, 1974 requesting information on NHTSA regulations applicable to regrooved tires.; You ask whether companies leasing trucks to other companies may equi the trucks with regrooved tires, and what tire standards apply.; The recent court decision regarding regrooved tires (*NAMBO* v *Volpe*, 483 F. 2d 1294 (D.C. Cir. 1973), *Cert.* *denied*,-- U.S.--(1974)) held that under the National Traffic and Motor Vehicle Safety Act the NHTSA could permit only the sale of regrooved tires. Consequently, the leasing of regrooved tires is now prohibited, as is any other introduction of them into interstate commerce other than by a sale. The NHTSA recently amended its regrooved tire regulations to conform to this Court opinion.; We do not construe the opinion to prohibit the leasing of truck equipped with regrooved tires. The regulation applies only to the manner in which the tires themselves are obtained.; The standards applicable to regrooved tires are fund in the Regroove Tire regulations (49 CFR Prt 569). Regroovable tires manufactured after March 1, 1975, must also conform to Motor Vehicle Safety Standard No. 119.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam3205OpenMr. F. Michael Petler, Suzuki Motor Co., Ltd., 13767 Freeway Drive, Santa Fe Springs, California 90670; Mr. F. Michael Petler Suzuki Motor Co. Ltd. 13767 Freeway Drive Santa Fe Springs California 90670; Dear Mr. Petler: This is in response to your letter of February 7, 1980, asking whethe a partial vehicle identification number (VIN) may be stamped into the frame of the Suzuki motorcycles under the certification label.; The answer is yes. The use of identifying numbers other than the VIN i allowed if the numbers cannot be confused with the VIN. In the situation you described, the identification number would be hidden from view by the certification label. Since the label is required to be riveted or permanently affixed to the vehicle (Part 567 of Title 49, Code of Federal Regulation), the hidden identifying number is not likely to become visible during the life of the vehicle. Therefore, there appears to be no chance that the number would be confused with the VIN.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2664OpenMr. Noel C. Ice, Cantey, Hanger, Gooch, Munn & Collins, 1800 First National Bank Building, Fort Worth, TX 76102; Mr. Noel C. Ice Cantey Hanger Gooch Munn & Collins 1800 First National Bank Building Fort Worth TX 76102; Dear Mr. Ice: This responds to your August 9, 1977, letter asking whether a alterer's responsibility for ensuring the compliance of a vehicle with Federal safety standards, as required in Part 567, *Certification*, extends only to those aspects of performance that could have been affected by the alteration or whether it extends to the compliance of the entire vehicle with all Federal standards.; The intent of the alteration regulation is to make vehicle alterer responsible for the continued compliance of the vehicles they modify. Therefore, an alterer would be held responsible for any noncompliance of a vehicle caused by his alterations. The National Highway Traffic Safety Administration would not hold the alterer liable for noncompliances in a vehicle that were the responsibility of the original vehicle manufacturer and not affected by the alterer's conduct.; Sincerely, Joseph J. Levin, Jr., 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.