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: aiam4413OpenD. F. Landers, PSI Mobile Products Inc., 25 Eldredge, P.O. Box 1183, Mt. Clemens, MI 48043; D. F. Landers PSI Mobile Products Inc. 25 Eldredge P.O. Box 1183 Mt. Clemens MI 48043; Dear Mr. Landers: This is in response to your letter requesting confirmation of a Jul 11, 1983 determination by this agency that your special tow tractor vehicle is exempt from Federal motor vehicle safety standards. You indicate in your letter that you now have three sizes of tow tractors and that your market may expand to include commercial airline use as well as the Department of Defense.; Based on the information you have provided us, we confirm our previou determinations that baggage tow tractors are not subject to the Federal motor vehicle safety standards. The agency has consistently interpreted the definition of motor vehicle as excluding vehicles such as airport runway vehicles that are intended and sold solely for off-road use and are not equipped for highway use. Further, we note that section 571.7(c) of Title 49, Code of Federal Regulations, provides that; >>>No standard applies to a vehicle or item of equipment manufacture for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.<<<; Your vehicles might become subject to the Federal motor vehicle safet standards if there is a material change in the facts regarding the intended or actual use, design or sale of your vehicles. Please remember that compliance with all Federal motor vehicle safety standards is the obligation of each manufacturer of motor vehicles or motor vehicle equipment. We appreciate your continuing efforts at classifying correctly your vehicles.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2040OpenMr. Leonard Barkan, Strick Corporation, U.S. Highway No. 1, Fairless Hills, PA 19030; Mr. Leonard Barkan Strick Corporation U.S. Highway No. 1 Fairless Hills PA 19030; Dear Mr. Barkan: This responds to your July 17, 1975, question whether a used runnin gear assembly can be combined with a new platform to qualify as a 'repaired' trailer that would not have to conform to the requirements for air brake systems on newly-manufactured trailers (Standard No. 121, *Air Brake Systems*). I have enclosed an interpretive letter which should clarify this matter for you. Briefly, the answer is no, if the 'platform' includes the main frame members.; You also asked whether the vehicle must conform to the safety standard if it is assembled for the manufacturer's own use or if it is leased to a third party. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits not only the sale, but also the introduction or delivery for introduction in interstate commerce of vehicles which do not comply with all applicable safety standards in effect on the date of manufacture. Therefore the answer to your question is yes if the vehicle is ever operated on the public streets or highways.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5042OpenMr. R.J. Misorski Director, Maintenance & Repair Maersk Inc. 231 Tyler Street Port Newark, NJ 07114; Mr. R.J. Misorski Director Maintenance & Repair Maersk Inc. 231 Tyler Street Port Newark NJ 07114; "Dear Mr. Misorski: This responds to your letter of August 6, 1992 asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. You write with reference to an amendment that became effective December 1, 1991, requiring a minimum of 12 square inches of lens area for rear stop or turn signals on vehicles over 80 inches wide, regardless of the separation between lamps. You request confirmation of your feeling that 'equipment manufactured prior to December 1, 1991 would be exempt from this ruling', and that 'it only applies to equipment that is manufactured after December 1, 1991.' You have asked for this interpretation to 'ensure compliance with our equipment fleet.' What the amendments require is that multipurpose passenger vehicles, buses, trucks, and trailers whose overall width is 80 inches or more, which are manufactured on and after December 1, 1991, be equipped with stop and turn signal lamps that meet the new requirements. Stop and turn signal lamps which were manufactured prior to that date that do not meet the new requirements are permissible to replace original equipment of the same type on vehicles manufactured before December 1, 1991, but they cannot be used as either original or replacement stop and turn signal lamps on vehicles manufactured on and after December 1, 1991. Furthermore, Standard No. 108 continues to allow manufacture and sale on and after December 1, 1991, of the old type of stop and turn signal lamps for replacement of original equipment on vehicles manufactured prior to December 1, 1991. I hope that this assists you with your compliance question. We shall be pleased to answer any further questions you may have. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1629OpenMr. Phil Hooley, Federal Codes and Standards Engineer, Starcraft Company, 3010 College Avenue, Goshen, IN 46526; Mr. Phil Hooley Federal Codes and Standards Engineer Starcraft Company 3010 College Avenue Goshen IN 46526; Dear Mr. Hooley: This is in reference to your defect notification campaign (NHTSA No 74-0170) concerning some camper trailers which may have incorrect inner wheel bearing grease seals installed.; The letter which you have sent to the owners of the subject trailer does not completely meet the requirements of Part 577 (49 CFR), the Defect Notification regulation. Specifically, your letter does not provide an estimate of the day by which dealers will be supplied with parts and instructions for correcting the defect as required by Part 577.4(e)(1). Your statement that the inspection and repair procedure 'should not take very long,' is too vague to qualify as an estimate of the time reasonably necessary to perform the necessary labor as required by Part 577.4 (e)(1). The second sentence of your letter is also incorrect in that where the vehicle manufacturers are concerned, the defect should be described as existing in the vehicle itself rather than a specific part or component of the vehicle.; Since the discrepancies in your notification letter do not appear t discourage owner response in this case, mailing of a revised letter will not be required. It is, however, expected that all future defect notification campaigns will conform completely with the applicable regulations.; Although it may be desirable to issue a service bulletin as soon a possible, we do not believe that justification exists for delaying the submission of a defect report beyond the five working days time limit specified by Part 573 (49 CFR). It is therefore expected that all future reports will be submitted on a timely basis.; Copies of Part 577 and Part 573 of the regulations are enclosed. Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam2017OpenMr. James R. Greco, Technical Director, National Solid Wastes Management Association, 1730 Rhode Island Avenue, N.W., Washington, DC 20036; Mr. James R. Greco Technical Director National Solid Wastes Management Association 1730 Rhode Island Avenue N.W. Washington DC 20036; Dear Mr. Greco: This responds to the National Solid Wastes Management Association' July 29, 1975, question whether Standard No. 121, *Air Brake Systems*, or other Department of Transportation regulations require a vehicle operator to maintain and not disconnect brake components used in satisfaction of the standard. You state that you are already aware of operator responsibilities to meet the regulations of the Bureau of Motor Carrier Safety and those promulgated by State and local governments.; Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safet Act of 1966 (15 U.S.C. 1397(a)(1)(A)) specifies in part that no person shall sell or introduce in interstate commerce a vehicle which does not comply with applicable standards in effect on the date of manufacture. Section 108(b)(2) provides that S 108(a)(1)(A) does not apply after the first purchase for purposes other than resale. The general effect of these provisions is that the brake system must comply and not be disconnected prior to its first retail sale. Section 108(a)(2)(A) provides that no manufacturer (sic) distributor, dealer, or motor vehicle repair business shall knowingly render inoperative a device installed in compliance with an applicable safety standard. Taken together, these provisions do not require the vehicle operator to maintain or not render inoperative a safety system after the first retail purchase. This agency does not recommend disconnection of elements of a brake system, however, in view of the probable adverse effect on handling not intended by the vehicle designer and engineer.; Other than the regulations of the Bureau of Motor Carrier Safety, o which you are aware, no regulations of the Department of Transportation require the maintainence (sic) or prohibit the disconnection of systems installed in satisfaction of motor vehicle safety standards.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2274OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50, 100 W. Alondra Blvd., Gardena, CA 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill: This is in response to your letter of March 1, 1976, requesting a interpretation of whether the Honda 'MPV' would be classified as a 'multipurpose passenger vehicle' as that term is defined for purposes of the Federal motor vehicle safety standards.; 'Multipurpose passenger vehicle' is defined in 49 CFR Part 571.3(b) as: >>>'a motor vehicle with motive power, except a trailer, designed t carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.'<<<; Your letter states that the Honda 'MPV' is derived from the Honda T 500 light truck, which we assume means that the 'MPV' is constructed on a truck chassis. Further, your drawings indicate that the 'MPV' is of the forward control configuration. Based upon this understanding of your letter and attached drawings, it appears that the Honda 'MPV' qualifies as a multipurpose passenger vehicle.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam2074OpenMr. James P. Walters, High & Walters, P.O. Box 619, Iowa Falls, Iowa 50126; Mr. James P. Walters High & Walters P.O. Box 619 Iowa Falls Iowa 50126; Dear Mr. Walters: This is in response to your August 11, 1975, request for information o regulations concerning the matching of innertube sizes with motorcycle tire sizes. Federal Motor Vehicle Safety Standard No. 119 (copy enclosed) specifies performance and labeling requirements for motorcycle tires manufactured after March 1, 1975. There are no Federal regulations, however, containing requirements for proper matching of tubes with tires.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0875OpenShigemitsu Morita, General Manager, Daicel Ltd., New York Liaison Office, 200 Park Avenue, New York, NY, 10017; Shigemitsu Morita General Manager Daicel Ltd. New York Liaison Office 200 Park Avenue New York NY 10017; Dear Mr. Morita: This is in reply to your letter of September 15, 1972, to Mr. Jerome A Palisi, requesting information concerning the application of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to various components of vehicle occupant compartments made of plastic or plastic and metal.; The components that must meet the requirements of the standard ar listed in paragraph S4.1. Some of the components you have asked about are covered by the standard and others are not. Dashboards and instrument panels are considered to be 'front panels' and are therefore covered. Steering wheels normally are 'designed to absorb energy ... in the event of a crash' and, in that case, are covered. The components not covered specifically are handles of handbrakes, meter housings, steering column covers, console boxes, and handle knobs to open and shut windows. These components, such as console boxes, will nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash.' We cannot identify what you mean by 'change lever knobs' and, therefore, we cannot comment on this component.; You also ask whether finished or unfinished components should be teste according to the procedures described in S5 of the standard, and what kind of specimens should be prepared for plastic components with metal insertions. The standard does not apply to intermediate or unfinished materials, and compliance testing by the Government is carried out with components removed from motor vehicles that have been marketed. Test specimens should be prepared according to S5.2.1 of the standard regardless of the materials that are present in a given component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4047OpenMr. Hisashi Tsujishita, Chief Co-ordinator, Technical Administration Deptartment, Daihatsu Motor Co., Ltd., 1.Daihatsu- Cho, Ikeda City, Osaka Prefecture, JAPAN; Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Deptartment Daihatsu Motor Co. Ltd. 1.Daihatsu- Cho Ikeda City Osaka Prefecture JAPAN; Dear Mr. Tsujishita: This is in further response to your letter of July 15, 1986, in whic you asked a number of questions concerning our standards and regulations. This responds to your question about Part 585, *Automatic Restraint Phase-In Reporting Requirements*. I hope the following discussion answers your question.; You asked about the requirement in Part 585.5(a)(4) of the regulation That section provides that a manufacturer's report 'contain a statement regarding the extent to which the manufacturer has complied with the requirements of S4.1.3 of Standard No. 208.' You explained that you did not understand what that sentence means and asked whether your sample report conformed to the requirement of the regulation.; S4.1.3 of Standard No. 208 provides for the phasing-in of the automati restraint requirement and sets certain percentage of passenger car production requirements that each manufacturer must meet.; The purpose of Part 585.5(a)(4) is to have each manufacturer state t what degree or extent it has met the applicable phase-in requirement. Thus, a statement, such as the one contained in your sample report, which sets out the percentage of your vehicles produced during an applicable reporting period that comply with the automatic restraint phase-in requirements of the standard would meet the requirement of Part 585.5(a)(4).; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1932OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in response to your letter of May 19, 1975, inquiring as to th effect of Federal Motor Vehicle Safety Standard No. 217, *Bus Window Retention and Release*, on a Connecticut law relating to school bus window emergency release.; As you are aware, section 103 (d) of the National Traffic and Moto Vehicle Safety Act of 1966 (15 U.S.C. 1392(d)) provides that no State or political subdivision of a State may promulgate or continue in effect standards applicable to an aspect of motor vehicle or motor vehicle equipment performance which is covered by a Federal motor vehicle safety standard, unless the standards are identical.; Standard No. 217 includes provisions relating to emergency exit forc applications. A differing State specification for emergency release force applications is voided by S103(d) since the Federal standard is intended to cover all aspects of emergency window release performance.; As explained in our November 29, 1974, letter to Mr. Donald L. Gibso (copy enclosed) a Federal standard will preempt any State law that relates to the same aspect of motor vehicle performance yet imposes different requirements. Your responsibility as a manufacturer is to comply with the Federal safety standard. You should note, however, that purchase specifications may be imposed by any person or organization, including a State or municipality, with respect to vehicles purchased for the person or organization's own use. Such specifications are not limited by Federal law, and in the case of governmental bodies are specifically allowed by S103(d), although of course they cannot alter a manufacturer's duty to conform to Federal standards.; Sincerely, James C. Schultz, 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.