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: aiam3160OpenMr. Edward F. Tannery, Theodore Bargman Company, 129 Industrial Avenue, Coldwater, MI 49036; Mr. Edward F. Tannery Theodore Bargman Company 129 Industrial Avenue Coldwater MI 49036; Dear Mr. Tannery: This responds to your recent letter asking whether doors on aftermarke top covers for American Motors Jeeps would have to comply with Safety Standard No. 206, *Door Locks and Door Retention Components*.; Safety Standard No. 206 applies to passenger cars, trucks an multipurpose passenger vehicles, which would include Jeeps. The standard applies only to completed vehicles, however, and not to aftermarket motor vehicle equipment. Therefore, the doors on aftermarket Jeep top covers would not have to have locks. Further, doors on new Jeep vehicles would also not have to comply with the standard if they are 'designed to be easily attached to or removed from' the vehicle, as provided in section S4 of the standard.; Please contact Hugh Oates of my office if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1819OpenHonorable Edmund S. Muskie, United States Senate, Washington, DC 20510; Honorable Edmund S. Muskie United States Senate Washington DC 20510; Dear Senator Muskie: I would like to respond to your February 19, 1975, request fo consideration of Mr. R. L. Herman's views on Standard No. 121, *Air brake systems*. Mr. Herman objects that the National Highway Traffic Safety Administration (NHTSA) may have ignored the majority of comments submitted in response to its recent proposal to delay implementation of the standard, that implementation of the standard should be reconsidered by an activity other than the NHTSA, and that the new brake systems may be less safe than existing systems.; Standard No. 121 was issued as a final rule in February 1971. The NHTS realized that the economic situation in the automotive industry this past fall might justify a postponement of the scheduled January 1, 1975, effective date. In the short time available for review of the standard before its effective dates, the NHTSA issued a proposal, received comments, and made its decision.; The NHTSA concluded that net economic benefit would not be derived fro postponement. The decision was based on evaluation of all the comments, including those concerning the standard's immediate short-term impact on the national economic picture. An important factor in this case was the imminence of the standard and the degree to which financial and employment commitments were made.; As you may know, the President has directed (by Executive Order 11821 that each Federal agency consider the inflation impact of its regulatory actions. At the time of the NHTSA decision on December 31, 1974, final criteria and procedures for implementation of the Order were not yet established. The NHTSA did, however, analyze economic effects of its proposal. The NHTSA has publicly committed itself to continue monitoring the effectiveness of its standard in accordance with its statutory mandate and the President's direction, with a view to identifying any modifications that would lower costs while achieving comparable levels of safety.; An independent evaluation of the standard and its implementation by th Office of the Secretary (of the Department) was recently conducted, and this study supports the NHTSA decision. A copy of a letter regarding that evaluation is enclosed, and it discusses in detail Mr. Herman's concern about the field testing of the new braking components.; Thank you for your interest in motor vehicle safety. Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam1826OpenHonorable Roman L. Hruska, United States Senate, Washington, DC 20510; Honorable Roman L. Hruska United States Senate Washington DC 20510; Dear Senator Hruska: I would like to respond to your February 19, 1975, request fo consideration of Mr. R. L. Herman's views on Standard No. 121, *Air brake systems*. Mr. Herman objects that the National Highway Traffic Safety Administration (NHTSA) may have ignored the majority of comments submitted in response to its recent proposal to delay implementation of the standard, that implementation of the standard should be reconsidered by an activity other than NHTSA, and that the new brake systems may be less safe than existing systems.; Standard No. 121 was issued as a final rule in February 1971. NHTS realized that the economic situation in the automotive industry this past fall might justify a postponement of the scheduled January 1, 1975, effective date. In the short time available for review of the standard before its effective dates, the NHTSA issued a proposal, received comments, and made its decision.; NHTSA concluded that net economic benefit would not be derived fro postponement. The decision was based on evaluation of all the comments, including those concerning the standard's immediate short-term impact on the national economic picture. An important factor in this case was the imminence of the standard and the degree to which financial and employment commitments were made.; As you may know, the President has directed (by Executive Order 11821 that each Federal agency consider the inflation impact of its regulatory actions. At the time of the NHTSA decision on December 31, 1974, final criteria and procedures for implementation of the Order were not yet established. NHTSA did, however, analyze economic effects of its proposal. NHTSA has committed itself publicly to continue monitoring the effectiveness of its standard in accordance with its statutory mandate and the President's direction, with a view to identifying any modifications that would lower costs while achieving comparable levels of safety.; An independent evaluation of the standard and its implementation by th Office of the Secretary (of the Department) was recently conducted, and this study supports the NHTSA decision. A copy of a letter regarding that evaluation is enclosed, and it discusses in detail Mr. Herman's concern about the field testing of the new braking components.; Thank you for your interest in motor vehicle safety. Sincerely, William T. Coleman, Jr. |
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ID: aiam4726OpenMr. Anthony T. Greenish c/o U.N.D.P. B.P. 2183 Libreville Gabon; Mr. Anthony T. Greenish c/o U.N.D.P. B.P. 2183 Libreville Gabon; "Dear Mr. Greenish: Your letter of February 19, 1990, to the Departmen has been referred to this Office for reply. You are contemplating buying a car in Europe and importing it when you return to the United States in July. You have in mind the BMW 324d and the Honda Accord 1.6 LX, and ask for information 'as to how these cars rate as to motor vehicle safety standards.' BMW does not offer the 324d for sale in the United States, and we assume that the Honda you mentioned was also produced for the European market. This means that these vehicles are not certified as complying with all applicable Federal motor vehicle safety, bumper, and theft prevention standards. Because of the difficulties you would entail in attempting to import an uncertified vehicle, we recommend that you purchase a vehicle certified by its original manufacturer for the American market. As you know, many European manufacturers have a factory delivery program for U.S. tourists. That way you can ensure that your car meets 100% of Federal requirements. If you nevertheless wish to pursue the idea of buying and importing a passenger car not certified by its original manufacturer to meet the Federal motor vehicle safety standards, you should be aware of some recent changes in law. Because of new regulations which were mandated by Congress and became effective January 31, l990, such a vehicle may not be imported unless the National Highway Traffic Safety Administration has determined that that specific model and model year is capable of conversion to meet the standards. Importation of the vehicle is also subject to the requirement that it be imported either by a person who has been approved by this agency as a Registered Importer and will be responsible for converting the vehicle to meet the standards, or by a person who has a contract with a Registered Importer. In either instance, a bond in an amount equal to l50% of the entered value of the vehicle as determined by the U.S. Customs Service must be given to ensure performance of the conversion work. We anticipate that the effect of these stringent regulations will be to convince many prospective importers not to buy vehicles intended for markets other than the United States. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam3697OpenTom Caine, Esq., Law Department, The Goodyear Tire & Rubber Company, Akron, OH 44316; Tom Caine Esq. Law Department The Goodyear Tire & Rubber Company Akron OH 44316; Dear Mr. Caine: This responds to your recent letter in which you asked for a interpretation concerning the status of tires which are manufactured by applying new tread to a new casing. Specifically, you ask whether such tires should be considered retreaded tires or new tires subject to the applicable Federal motor vehicle safety standard.; Any tires manufactured by applying new tread to new casings would b considered new tires rather than retreaded tires, and would be subject to the same requirements as any other new tires.; Standard No. 117, *Retreaded Pneumatic Tires* (49 CFR S 571.117) defines the term 'casing' as follows: 'Casing means a used tire to which additional tread may be attached for the purpose of retreading.' In the situation you described in your letter, the casing is not a used tire. It is simply a new tire which has never had any tread attached to it. That casing would not be considered a used tire until the casing and the new tread attached to it had been used on the highway and the remainder of the tread then buffed off the casing to allow the application of another new tread. Only then could the casing be considered a used tire. With the addition of the new tread, the used tire would become a retreaded one.; I would appreciate it if you would forward any factual information yo have about the proposed importing of new casings to this agency's Office of Vehicle Safety Compliance. This will help us ensure that all imported new casings with new treads attached to them are subjected to the new tire performance tests.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0065OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P. O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P. O. Box 898 Sacramento CA 95804; Dear Commander Heath: Thank you for your letter of January 16, 1968, your referenc 61.A218.A1115, to the National Highway Safety Bureau concerning applicability of Federal Motor Vehicle Safety Standards 108 and 205 to campers.; Your questions along with our corresponding answers are listed below: >>>Question: 1. Do Federal Standards Nos. 108 and 205 apply to campe bodies which are not manufactured as a part of a vehicle but which may be purchased separately and later installed on a pickup truck by its owner?; Answer: The enclosed Notice of Ruling Regarding Campers affirms th applicability of Federal Standard No. 205 to camper bodies. Federal Standard No. 108 is a standard applicable to chassis cabs and to complete motor vehicles.; Question: 2. Do Federal Standards Nos. 108 and 205 apply to camper which are sold by the pickup truck dealer as part of a new vehicle even though the camper body itself is actually a load on the pickup and is designed to be removed from the pickup when the owner decides to transport other types of loads?; Answer: The applicability of Federal Standard No. 205 is covered in th enclosure. Federal Standard No. 108 is a requirement upon the dealer who sells a motor vehicle. If the vehicle is designed for more than one configuration in use, the dealer must provide that both configurations are in compliance with Federal Motor Vehicle Safety Standards.; The enclosed information on the National Traffic and Motor Vehicl Safety Act of 1966 are provided to further assist you.; Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam0066OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Commander Heath: Thank you for your letter of January 16, 1968, your referenc 61.A218.A1115, to the National Highway Safety Bureau concerning applicability of Federal Motor Vehicle Safety Standards 108 and 205 to campers.; Your questions along with our corresponding answers are listed below: >>>Question: 1. Do Federal Standards Nos. 108 and 205 apply to campe bodies which are not manufactured as a part of a vehicle but which may be purchased separately and later installed on a pickup truck by its owner?; Answer: The enclosed Notice of Ruling Regarding Campers affirms th applicability of Federal Standard No. 205 to camper bodies. Federal Standard No. 108 is a standard applicable to chassis cabs and to complete motor vehicles.; Question: 2. Do Federal Standards Nos. 108 and 205 apply to camper which are sold by the pickup truck dealer as part of a new vehicle even though the camper body itself is actually a load on the pickup and is designed to be removed from the pickup when the owner decides to transport other types of loads?; Answer: The applicability of Federal Standard No. 205 is covered in th enclosure. Federal Standard No. 108 is a requirement upon the dealer who sells a motor vehicle. If the vehicle is designed for more than one configuration in use, the dealer must provide that both configurations are in compliance with Federal Motor Vehicle Safety Standards.<<<; The enclosed information on the National Traffic and Motor Vehicl Safety Act of 1966 are provided to further assist you.; Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam4072OpenMr. Lewis Quetel, PMI Inc., 1391 Wright Blvd., Schaumburg, IL 60193; Mr. Lewis Quetel PMI Inc. 1391 Wright Blvd. Schaumburg IL 60193; Dear Mr. Quetel: This is in response to your telephone call on October 22, 1985, t Robert Nelson of this agency asking how our regulations would affect a product you intend to sell. The product, which you call a 'Kumfi-Klip' safety belt comfort device, consists of a plastic device which attaches to the upper torso belt anchorage. A belt user can then pull the webbing through the open wedge and close the wedge to introduce slack into the shoulder portion of the belt.; As background information, let me explain that the agency does not hav the authority to approve or endorse items of motor vehicle equipment, such as your device. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards.; Your particular aftermarket product is not covered by any of our safet belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your product. Those responsibilities are set out in sections 151-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review.; The agency is concerned that a belted occupant could inadvertently us your product to introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of that belt. The instructions you provide with the 'Kumfi-Klip' do warn users not to introduce excessive slack, but the instructions provide no information to guide a user on what is an excessive amount of slack. We encourage you to provide more detailed guidance.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2560OpenMr. 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 Corporation's March 29, 1977, request fo confirmation that the manual adjustment of automatic adjusters is acceptable following the burnish procedures of Standard No. 121, *Air Brake Systems*, at the option of the manufacturer.; The procedure that you recommend is not permitted by any provision o Standard No. 121. The NHTSA would consider some provision to deal with the overadjustment of automatic adjusters upon receipt of technical data showing justification for such action. Based on consideration of the data received and a petition for amendment, the agency could commence a rulemaking proceeding in accordance with established procedures.; I have enclosed a copy of a similar interpretation made to Rockwel International.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0010OpenMr. John E. Calow Sr. Safety Engineer Oshkosh Truck Corporation Chassis Division P. O. Box 2508 2201 Oregon St. Oshkosh, Wisconsin 54903-2508; Mr. John E. Calow Sr. Safety Engineer Oshkosh Truck Corporation Chassis Division P. O. Box 2508 2201 Oregon St. Oshkosh Wisconsin 54903-2508; "Dear Mr. Calow: This responds to your letter concerning th responsibilities of an incomplete vehicle manufacturer under Federal Motor Vehicle Safety Standard No. 115, Vehicle Identification Number--Basic Requirements. In your letter, you explained that Oshkosh provides chassis to final stage manufacturers. You stated that the final stage manufacturers are requesting that Oshkosh provide a duplicate VIN tag with the incomplete vehicle. The additional VIN tag would be affixed by the final stage maufacturer, so that it is readable through the vehicle glazing. You noted that there is a possibility that the final stage manufacturer might place the incorrect VIN tag under the vehicle glazing, and that Oshkosh would have no control of the final stage manufacturer correctly identifying the vehicle. You then asked two questions, which are addressed below. Your first question asked whether it is legal for an incomplete vehicle manufacturer to supply the final stage manufacturer with an additional 'loose' VIN tag. The answer to this question is yes. No provision in Standard No. 115 prohibits the incomplete vehicle manufacturer from providing an extra VIN tag which the final stage manufacturer may affix so that it is visible through the vehicle glazing. Your second question asked about the legal responsibilities of the incomplete vehicle manufacturer if an incorrect VIN tag is affixed to the vehicle by the final stage manufacturer. Except in the situation where an incomplete vehicle manufacturer assumes legal responsibility for all duties and liabilities imposed on manufacturers by the Safety Act (see 49 CFR Part 568.7), which we assume does not apply in your case, an incomplete vehicle manufacturer is not responsible under the Safety Act for the actions of a final stage manufacturer. I hope this satisfactorily responds to your concerns. If there are any further questions, please write to me or contact Dorothy Nakama of my staff at (202) 366-2992. 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.