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: aiam0445OpenMr. W.R. Kittle, Director, Vehicle Safety and Advance, Quality Control, Chrysler Corporation, P.O. Box 1919, Detroit, MI 48231; Mr. W.R. Kittle Director Vehicle Safety and Advance Quality Control Chrysler Corporation P.O. Box 1919 Detroit MI 48231; Dear Mr. Kittle: This is in reply to your letter of September 10, 1971, concerning th Defects Reports regulations, 49 CFR Part 573. You ask whether S 573.6 (Owner Lists) requires that the list 'show only the latest quarterly status of inspection and defect correction', or whether all prior quarterly lists must also be retained.; Section 573.6 of the regulation requires the owner list to be 'update as of the end of each quarterly reporting period,' with the list being retained for five years after the date on which the defect information report is initially submitted.; We do not consider this section to require all prior quarterly lists t be retained. Therefore if you maintain a list that shows only the latest quarterly status of inspection and defect correction you will be in compliance with the requirements.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4087OpenPaul A. Lester, Esq., Shapiro, Lester & Abramson, P.A., Roland/Continental Plaza, 3250 Mary Street, Miami, FL 33133; Paul A. Lester Esq. Shapiro Lester & Abramson P.A. Roland/Continental Plaza 3250 Mary Street Miami FL 33133; Dear Mr. Lester: This is in response to your request of January 14, 1986, for a rulin that the lessor/seller may issue an odometer disclosure statement to the lessee/buyer at the inception of the lease and not at the time of transfer.; Title IV of the Motor Vehicle Information and Cost Savings Act, 1 U.S.C. SS 1981-1991, directs the Secretary of Transportation to prescribe rules requiring any transferor to give a written disclosure of certain information to the transferee 'in connection with the transfer of ownership.' Transfer of ownership is defined in accordance with State law. Florida law specifies that issuance of the automobile title certificate and license constitutes presumptive ownership of a vehicle. Therefore, the written disclosure is required to be given when the title certificate and license are issued. While the National Highway Traffic Safety Administration has granted exemptions to the regulations promulgated pursuant to the Act, we cannot issue an exemption to any provisions of the Act itself.; In addition to the Federal requirements, the Florida motor vehicl title law states: 'No notary public shall notarize a title transfer until the *seller* properly indicates the odometer reading.' West F.S.A. S 319.22 (emphasis added). Therefore, in addition to your request being prohibited by Federal law, it may also be prohibited under State law.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam5627OpenArthur N. Arschin, Esq. 450 Seventh Avenue, Suite 2803 New York, NY 10123; Arthur N. Arschin Esq. 450 Seventh Avenue Suite 2803 New York NY 10123; Dear Mr. Arschin: This responds to your letter to this agency askin whether the manufacturer identification numbers assigned to the Vee Rubber Company, Ltd. and the Vee Rubber International Company, Ltd. remain valid. The short answer is yes, if the plants remain in production. 49 CFR 574.5 requires each new or newly retreaded tire sold in the United States to have a tire identification number (TIN) labeled by the manufacturer on one sidewall of the tire. The TIN is intended to assist NHTSA to identify the production source of a tire in the event of a defect or noncompliance. The TIN must include a manufacturer identification mark (MIM) issued by NHTSA in accordance with 49 CFR 574.6. NHTSA issues a separate MIM for each plant that currently produces or retreads tires, and a plant can only have one MIM. Once NHTSA issues a MIM, the mark remains in effect as long as the plant to which it applies remains in production. In the event the plant ceases production, the mark assigned to that plant may not be further assigned or otherwise used by the manufacturer or anyone else. If the plant ceases production, NHTSA should be promptly notified so that the mark can be cancelled. With regard to your client rubber companies, the MIMs assigned to Vee Rubber Company, Ltd., YRU for Plant No. 1 and YRV for Plant No. 2, remain in effect if those plants are still in production. The MIMs assigned to Vee Rubber International Company, Ltd., 4A for Plant No. 1 and 5A for Plant No. 2 remain in effect if those plants are still in production. I hope this information is helpful to you. Should you have any questions or need additional information, feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0270OpenMr.Stanley C. Nickell, Attorney at Law, Northeast Kentucky Area Development Council, Inc., Room 102, Courthouse, Greenup, Kentucky 41144; Mr.Stanley C. Nickell Attorney at Law Northeast Kentucky Area Development Council Inc. Room 102 Courthouse Greenup Kentucky 41144; Dear Mr. Nickell: This is in reply to your letter of September 28, 1970, to Mr. Lowell K Bridwell, Administrator, Federal Highway Administration, asking for a definition of 'blemished,' 'second,' and 'farm use only,' which has been referred to this office for reply.; Tire manufacturers are required to certify that their product complie with the Federal Motor Vehicle Safety Standard No. 109, and do so by labeling each tire they certify with the symbol 'DOT.' Tires that are certified by the manufacturer and marked 'seconds' are not necessarily unsafe, as the 'second' may be due to a cosmetic defect not affecting the tire's performance.; Sometimes a tire manufacturer will make a tire that he believes i defective in a way that affects the safety of the tire. Often, that manufacturer will mark the tire 'farm use only' or 'non-highway use' and then sell it. In such instances, he is required to remove the DOT symbol.; We do not have a definition for 'blemished.' We have enclosed a copy of an amendment to the passenger car tir standard (No. 109) that contains the definition for 'non-highway use tires' which is applicable to 'farm use only' and 'tire identification and recordkeeping' which is applicable to 'manufacturer's marks on tires.'; Thank you for your interest in the Motor Vehicle Safety Program. Sincerely, Francis Armstrong, Director, Office of Compliance, Moto Vehicle Programs; |
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ID: aiam5628OpenMr. Lawrence A. Beyer Attorney at Law 674 Lake Road Webster, NY 14580; Mr. Lawrence A. Beyer Attorney at Law 674 Lake Road Webster NY 14580; Dear Mr. Beyer: This responds to your August 28, 1995, 'Petition fo Exemption for Inconsequential Defect or Noncompliance'. You state that 'the noncompliance relates to' 49 CFR Part 592. The effect of an inconsequentiality determination is to relieve a manufacturer of its obligation to notify and remedy when a noncompliance with a Federal motor vehicle safety standard or a safety related defect is determined to exist. The failures you attributed to your client as a registered importer under part 592 do not encompass a failure to bring vehicles into compliance with the Federal motor vehicle safety standards, or the existence of a safety related defect in vehicles that it has imported. Therefore, there is no legal basis for your 'petition'. Please read 49 U.S.C. 30118 and 30120, and 49 CFR Part 556. The proper forum for your arguments is in response to any penalty the agency may propose to impose on your client for its failure to meet the requirements of Part 592. If you have any questions, you may call Taylor Vinson (202-366-5263). Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3206OpenMr. Y. Matsumoto, Vice President, N.S. International, Ltd., 5670 Wilshire Boulevard, Rm. 2540, Los Angeles, California 90036; Mr. Y. Matsumoto Vice President N.S. International Ltd. 5670 Wilshire Boulevard Rm. 2540 Los Angeles California 90036; Dear Mr. Matsumoto: Please accept my apologies for our delay in responding to your inquire of January 14, 1980 and November 30, 1979. Your letters concerned the potential compliance of your company's odometers with the proposed amendments to Federal Motor Vehicle Safety Standard No. 127, *Speedometers and Odometers*, and were accompanied by 4 speedometer/odometer assemblies for use on motorcycles.; The agency is now preparing to issue the final rule concerning th March 22, 1979 notice of proposed rulemaking, but due to Federal law and Department policy we cannot discuss its contents with your at this time. I believe that the final rule which will be published in the near future, will be responsive to your questions. We would be happy to send you a copy as soon as it is published. If after reading it, you have further questions please let me know. Please note that we are returning your speedometer/odometer assemblies under separate cover.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4263OpenMs. Sandra Rogers Werts, 1922-B Greenoaks Road, Columbia, SC 29207; Ms. Sandra Rogers Werts 1922-B Greenoaks Road Columbia SC 29207; Dear Ms. Werts: This is in response to your letter of December 3, 1986, for informatio concerning the Federal odometer regulation, 49 C.F.R. Part 580 - Odometer Disclosure Requirements.; You questioned whether form 400, which you refer to as the Titl Transfer form, and the Affidavit & Notification of Sale of Motor Vehicle comply with the requirements of the Federal regulation. Both forms include the information required to be disclosed with the exception of the certifications set forth in 49 C.F.R. S580.4(d). In August 1977, the National Highway Traffic Safety Administration determined that these certifications were not required when States provided odometer disclosure information on their titles. Shortened disclosure forms were permitted on State titles. 42 Fed. Reg. 38907 (1977). Subsequently, the Agency decided to allow States to use the shortened form on all State documents evidencing ownership of a motor vehicle. 49 Fed. Reg. 784 (1980). Ownership is determined by State law. If, under South Carolina law, the forms evidence ownership of the motor vehicle, then the requirements of the Federal regulation have been met. If, however, the forms do not evidence ownership of the motor vehicle, then the disclosures fail to meet the requirements of 49 C.F.R. S580.4(d).; You also requested a certified copy of a determination made by th Agency in September 1985, concerning South Carolina's title documents. I have enclosed a certified copy of that letter. Please note that the letter discusses which State titles may be used in lieu of a separate disclosure statement and does not address the issue of other documents evidencing ownership.; I hope you find this information helpful. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0629OpenMr. A. T. Wood, CaraVan, Custom Conversions, 7879 Raytheon Road, San Diego, CA 92111; Mr. A. T. Wood CaraVan Custom Conversions 7879 Raytheon Road San Diego CA 92111; Dear Mr. Wood: This is in reply to your letter of February 21, 1972, in which yo request information on how to comply with the Defect Reports regulations (49 CFR Part 573). You state that your company converts vans into campers and other specialized uses, that some of your work is minor in nature, such as installing paneling, floors, or windows, and vents, and ask how to determine when you have developed a 'model' for reporting purposes under the regulations.; The Defect Reports regulations apply to 'manufacturers.' As a genera rule, a person who converts an already complete vehicle will be considered a manufacturer of the converted vehicle if he modifies it in such a way that the vehicle's structure or function is affected, to a significant extent. For example, a person who takes a basic van- type truck and makes extensive interior modifications to provide eating, sleeping, and bathroom facilities--producing what might be called a motor home, although nomenclature is not determinative--would be considered a manufacturer by the NHTSA. By contrast, a person who *only* added a window or some paneling at a customer's request would not be so considered. We recognize that a precise and universal line between these two polar examples is difficult to draw. For purposes of compliance with Part 573, we will accept a reasonable judgment on your part as to where the line should be drawn in your case.; Since your work is done on a custom basis, you may consider the 'make and 'model' language of the regulation as inapplicable to your production.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0073OpenMr. S. J. Fowler, Commercial Officer, Canadian Embassy, 1746 Massachusetts Avenue, NW, Washington, DC 20036; Mr. S. J. Fowler Commercial Officer Canadian Embassy 1746 Massachusetts Avenue NW Washington DC 20036; Dear Mr. Fowler: This is in response to your letters of April 15 and February 15 to Mr B. A. Boaz of the Office of Public Affairs, Federal Highway Administration.; With reference to a Canadian manufacturer of motor buses you have aske 'what safety regulations currently apply to importation of motor buses.' Federal Motor Vehicle Safety Standards Nos. 102, 107, 205, and 209 currently apply to all motor buses, in addition, Standard No. 108 applies to motor buses 80 inches or more in overall width. I enclose a copy of the Standards for your guidance, together with a copy of the regulations governing importation of these vehicles.; You have also asked advice as to placing of lights required, vehicl braking requirements, and propane tank installation for 'tent camper trailers' and 'truck campers' manufactured by Specialites (sic) Capri Limited of Montreal. Standard No. 108 applies to all trailers 80 or more inches in overall width, and specifies the lighting requirements for these vehicles. Thus far it is the only standard applicable to trailers. There are no Federal braking or propane tank installation requirements for these vehicles. The truck camper manufactured by Capri is considered motor vehicle equipment and must conform to the glazing material requirements of Standard No. 205. I enclose a copy of a recent Notice of Ruling Regarding Campers which will be of assistance to Capri.; If there are further questions we shall be glad to answer them, and am sorry for the delay in responding to you.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam1027OpenMr. David J. Humphreys, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; Mr. David J. Humphreys Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: This is in reply to your letter of February 2, 1973, in which you as whether a vehicle designed to provide living accommodations for persons, but also designed to carry more than 10 persons, will be considered a motor home (a multipurpose passenger vehicle) or a bus under the motor vehicle safety standards. You question arises in the context of whether such a vehicle must comply with Standard No. 217, Bus Window Retention and Release.; Based on the definitions of these vehicle types in Part 571 of Titl 49, Code of Federal Regulations, we would consider this vehicle to be a bus. A multipurpose passenger vehicle, in which category a motor home falls (49 CFR 571.205), is limited to being designed to carry 10 persons or less. As the vehicle in question is designed to carry more than 10 persons, it must, under these definitions, be considered a bus.; Moreover, we do not believe there is a legitimate basis to exempt thi vehicle from Standard No. 217. That standard is intended to require vehicles designed to carry more than 10 persons to have specific provisions for the emergency escape of passengers. This purpose is not offset in cases where the vehicle simultaneously provides living accommodations.; We believe this conclusion to be consistent with the exemption provide in Standard 217 for limousines and station wagons. These vehicles, which like the vehicle in question are ordinarily vehicle types other than buses, are exempt because sufficient means of emergency escape are otherwise available. There is no indication that such is the case in the vehicle which is the subject of your letter.; 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.