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: aiam0743OpenMr. Lewis B. Hastings, Director of Government Relations, Rubber Manufacturers Association, 1346 Connecticut Avenue, N.W., Washington, D.C. 20036; Mr. Lewis B. Hastings Director of Government Relations Rubber Manufacturers Association 1346 Connecticut Avenue N.W. Washington D.C. 20036; Dear Mr. Hastings: #This is in reply to your letter of June 9, 1972 asking whether the National Traffic and Motor Vehicle Safety Act preempts the various States from enforcing the Vehicle Equipment Safety Commission's Regulation V-1 with respect to passenger car tires. #Section 103(d) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392(d)) requires any State law applicable to the same aspect of motor vehicle performance as a Federal motor vehicle safety standard to be identical to the Federal standard. We believe this section, considered in light of Federal Motor Vehicle Safety Standard No. 109, invalidates any State law that requires passenger car tires (except tires procured by a State for its own use) to meet the VESC Regulation V-1, or to be labeled with the V-1 symbol. #Sincerely, Lawrence R. Schneider, Chief Counsel; |
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ID: aiam2075OpenMrs. Helen Ginley, 8706 Orchard Avenue, Brooklyn, OH 44144; Mrs. Helen Ginley 8706 Orchard Avenue Brooklyn OH 44144; Dear Mrs. Ginley: This is in response to your letter asking whether the odomete disclosure statement which you enclosed has been properly completed.; 49 CFR Part 580, *Odometer Disclosure Requirements*, which wa promulgated by the National Highway Traffic Safety Administration (NHTSA) under the authority of section 408 of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513), prescribes the content and proper procedure for executing mileage disclosure statements at the time vehicles are transferred from one owner to another.; The form of the statement provided to you by Tommy Barrett, Inc appears in compliance with the provisions of Part 580. The person who completed the statement, however, failed to disclose the vehicle's last plate number. In order to meet the requirements of section 408 of the Cost Savings Act and Part 580, this information must be disclosed in writing to the vehicle purchaser. Although the transferor's address was not correctly filled in, the form has been stamped with what appears to be an appropriate address.; Failure to fulfill the requirements of the Cost Savings Act may subjec the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages, whichever is greater.; Since the license number may have been inadvertently omitted, I woul suggest that you contact Mr. Barrett and inform him of the deficiency in the statement he provided you. You will probably want him to add the information that is currently missing.; For your information, I have enclosed copies of the relevant portion of the Act and regulation.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1556OpenMr. R.W. Hildebrandt, Group Director of Engineering, Heavy Vehicle Systems Group, The Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R.W. Hildebrandt Group Director of Engineering Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hildebrandt: This responds to Bendix's June 10, 1974, request for interpretation o the Standard No. 121 requirement in S5.5.1 that 'on a vehicle equipped with an antilock system, electrical failure of any part of the antilock system shall not increase the actuation and release times of the service brakes.' You ask whether this language permits use of a separate device that senses electrical failure in the antilock system and automatically reduces pressure to the front brakes as a safety measure. The device would increase brake actuation and release time.; S5.5 is addressed to antilock systems and S5.5.1 mandates that antiloc systems be designed not to interfere with air brake performance if they fail electrically. S5.5.1 does not prohibit separate safety devices which are designed to operate in the event of antilock electrical failure to compensate for that failure. Therefore the Bendix automatic front axle limiting system, as we understand its operation, is not prohibited by S5.5.1 simply because it operates when it senses an antilock electrical failure.; Sincerely, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0979OpenMr. Robert L. Scates, R.R. No. 1, Box 168, Prairie Farm, WI 54762; Mr. Robert L. Scates R.R. No. 1 Box 168 Prairie Farm WI 54762; Dear Mr. Scates: This is in reply to your letter of January 6, 1973, requestin information on requirements regarding the manufacture of truck-mounted campers. You specifically mention requirements dealing with wiring.; There are several Federal requirements applicable to campers. Camper are items of motor vehicle equipment under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) and are required to conform to certain motor vehicle safety standards and regulations. Briefly, each camper must meet requirements applicable to the glazing materials (glass and plastics used in windows, doors, and interior partitions) used in the camper (Federal Motor Vehicle Safety Standard No. 205, 'Glazing Materials', 49 CFR 571.205). Each slide-in camper must, in addition, have affixed to it a label that indicates among other things its loaded weight. (Federal Motor Vehicle Safety Standard No. 126, 'Truck-Camper Loading', 49 CFR 571.126). All campers must also be certified in accordance with Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403) as conforming to applicable standards. Each camper manufacturer must submit certain information concerning his company pursuant to NHTSA regulations, 'Manufacturer Identification' (49 CFR Part 566). You may obtain copies of NHTSA standards and regulations as explained on the enclosure.; We understand that certain states also have requirements, includin requirements for wiring, that apply to campers. Information regarding these requirements should be obtained from State authorities. Trade associations that represent recreational vehicle manufacturers may be of help in obtaining this information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2004OpenMr. John R. Hudson, 1303 Merry Lane, La Marque, TX 77568; Mr. John R. Hudson 1303 Merry Lane La Marque TX 77568; Dear Mr. Hudson: This is in reference to your letter of July 28, 1975, to Corbusie Chevrolet Company of Bryan, Texas concerning that dealer's failure to provide you with an odometer mileage disclosure statement.; As you know, the Motor Vehicle Information and Cost Savings Act (Pub L. 92-513) requires that a written disclosure of a vehicle's correct mileage be provided by the seller to the purchaser at the time ownership of a vehicle is transferred. If the correct mileage is unknown, the Act requires a statement to that effect to be furnished in written form to the buyer. This requirement is not limited to transactions where a dealer is the purchaser. It applies to all type of vehicle transfers, including the one in which you were involved.; In addition, the Act prohibits the alteration of the mileage indicate on an odometer. Violation of this provision and/or the disclosure statement provision may subject the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages whichever is greater. To obtain this remedy, section 409 of the Act provides that a private civil action be instituted in State or Federal court.; We have mailed a letter to Corbusier Chevrolet informing them of th relevant odometer law requirements (copy enclosed). If they fail to disclose the necessary mileage information, please let us know so that we may take additional steps to enforce their compliance with the law.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0978OpenMr. Robert L. Scates, R.R. 1, Box 168, Prairie Farm, Wisconsin 54762; Mr. Robert L. Scates R.R. 1 Box 168 Prairie Farm Wisconsin 54762; Dear Mr. Scates: This is in reply to your letter of January 6, 1973, requestin information on requirements regarding the manufacture of truck-mounted campers. You specifically mention requirements dealing with wiring.; There are several Federal requirements applicable to campers. Camper are items of motor vehicles equipment under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq.*) and are required to conform to certain motor vehicle safety standards and regulations. Briefly, each camper must meet requirements applicable to the glazing materials (glass and plastics used in windows, doors, and interior partition) used in the camper (Federal Motor Vehicle Safety Standard No. 205, 'Glazing Materials', 49 CFR 571.205). each slide-in camper must, in addition, have affixed to it a label that indicates among other things its loaded weight. (Federal Motor Vehicle Safety Standard No. 126, 'Truck-Camper Loading', 49 CFR 571.126). All campers must also be certified in accordance with Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403) as conforming to applicable standards. Each camper manufacturer must submit certain information concerning his company pursuant to NHTSA regulations, 'Manufacturer Identification' (49 CFR Part 566). You may obtain copies of NHTSA standards and regulations as explained on the enclosure.; We understand that certain states also have requirements, includin requirements for wiring, that apply to campers. Information regarding these requirements should be obtained from State authorities. Trade associations that represent recreational vehicle manufacturers may be of help in obtaining this information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2797OpenDonald W. Segraves, Alliance of American Insurers, 20 North Wacker Drive, Chicago, IL 60606; Donald W. Segraves Alliance of American Insurers 20 North Wacker Drive Chicago IL 60606; Dear Mr. Segraves: This is in response to your letter of March 22, 1978, requesting tha the National Highway Traffic Safety Administration (NHTSA) interpret 'primary place of business' under 49 CFR Part 580 to include regional offices and other places of business where companies' records are customarily maintained.; It is our opinion that 'primary place of business' includes, in th case of a business with multiple offices, a regional or local office where transactions involving the subject vehicles took place and the records are maintained, in addition to the home office or headquarters of the business. For example, if a vehicle is repossessed by an insurance company that has its home office in New York, but the regional office in Chicago handled and retained all the paperwork on the repossessed vehicle, then the Chicago office would be the primary place of business for that transaction and the odometer disclosure statements should be retained in the Chicago office. The office that the purchaser dealt with would be the one he would contact if a problem arose at a later time. Therefore, it would be the logical office to maintain the records. If, however, the Chicago office handled the paperwork but upon completion forwarded it to the New York office, the New York office, as the repository for all paperwork, would be the primary place of business and odometer statements, like all other documents should be forwarded to that office. The place of retention, like the manner of retention, must be consistent so that the systematic retrieval is possible.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam3199OpenLieutenant R. C. Dale, Secretary, Commission on Equipment, State of Washington, General Administration Bldg. AX-12, Olympia, WA 98504; Lieutenant R. C. Dale Secretary Commission on Equipment State of Washington General Administration Bldg. AX-12 Olympia WA 98504; Dear Lieutenant Dale: This is in response to your letter of January 24, 1980, asking whethe Federal motor vehicle safety standards prevent the installation of aftermarket trailer hitches in a manner which diminishes the damage resistance performance of the vehicle bumper. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (Safety Act) (15 U.S.C. 1397(a)(2)(A)) provides that,; >>>'No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard,...'<<<; However, Federal motor vehicle safety standard (FMVSS) 215, Exterio Protection, applicable to vehicles manufactured between September 1, 1972, and September 1, 1978, permitted the removal of trailer hitches prior to testing for compliance with the regulation (49 CFR S571.215, S6.1.5). Therefore, installation of a trailer hitch on such a vehicle would not be considered to have rendered the vehicle's bumper system inoperative.; Similarly, the Part 581 bumper standard, which replaced FMVSS No. 21 for vehicles manufactured on or after September 1, 1978, provides for removal of trailer hitches prior to testing (49 CFR S581.6(a)(5)). The installation of a trailer hitch which impairs the damage resistance performance of a bumper is then not prohibited by Federal bumper regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0053OpenMr. Gordon F. Lee, Vice President, Badger Auto Body Company, 415 S. Third Street, Milwaukee, WI 53204; Mr. Gordon F. Lee Vice President Badger Auto Body Company 415 S. Third Street Milwaukee WI 53204; Dear Mr. Lee: Thank you for your cooperation and response to the Federal Highwa Administration request regarding the 'Certification Requirements.'; The information you have provided will be very useful to us, however in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with information as to where your tag will be located on your vehicles and also the serial identification system as requested in order that vehicles manufactured (complete) after January 1, 1968, can be identified.; In regard to your question as to whether there is an exception to th law regarding the placement of the three light markers at the rear of your vehicle because of the limited space on your rear frame, the answer is there is no exception and adherence is required. One possible solution to your problem might be to mount an additional bracket to mount the cluster of lights. This is only a suggestion and you may be able to arrive at a more practical arrangement.; Trusting this information answers your questions. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam4935OpenMr. John H. Heinrich District Director of Customs U.S. Customs Service 300 So. Ferry Street Terminal Island, CA 90731; Mr. John H. Heinrich District Director of Customs U.S. Customs Service 300 So. Ferry Street Terminal Island CA 90731; Re: Case No. 92-2704-00015 Dear Mr. Heinrich: This responds to you letter of December 5, 1991, enclosing a petition for relief from the forfeiture of '200 Spinner Wheel Nuts' seized by the Customs Service as violative of 49 CFR Sec. 571.211. The petitioner expresses the opinion that the wheel nuts should be exempt from DOT regulations, stressing safety considerations and the need to replace worn parts on vehicles manufactured in the l950's. You have also enclosed a copy of the petitioner's own parts list that identifies the wheel nuts as part of a conversion kit, intended to replace disc wheels with wire wheels. Federal Motor Vehicle Safety Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps, 49 CFR 571.211, precludes, for use on passenger cars, wheel nuts that incorporate winged projections. The chrome wheel nuts depicted in the Moss Motors catalogue page which you enclosed (Parts Nos. 200-210 and 200-220) clearly incorporate winged projections, and are the type of wheel nuts that Standard No. 211 addresses and prohibits. As such, they may not be imported for sale in the United States. We have discounted petitioner's safety arguments. This is the first allegation in the nearly 24 years that the standard has been in effect that the spinners are required to replace original equipment, implying that there is no acceptable substitute that would conform with Standard No. 211. In our view, no justification has been shown for granting the petition. Sincerely, Paul Jackson Rice 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.