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: aiam3851OpenMr. David A. White, Senior Safety Engineer, Grumman Olson, 70180 Centerville Road, Sturgis, MI 49091; Mr. David A. White Senior Safety Engineer Grumman Olson 70180 Centerville Road Sturgis MI 49091; Dear Mr. White: This responds to your letter of May 3, 1984, asking about Standard No 101, *Controls and Displays*. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listed in that table. You asked whether the symbols are required to be illuminated or whether it is permissible instead to illuminate the identifying words without illuminating the symbols. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.; By way of background information, I would note that the Nationa Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.; Section S5.2.1 of Standard No. 101 generally requires that 'an hand-operated control listed in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol.' The section states further that '(s)uch a control may, in addition, be identified by the word heating fan, windshield wiper and washer, and defroster system, all are listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.; Section S5.3.1 of Standard No. 101 states: >>>Except for foot-operated controls or hand-operated controls mounte upon the floor, floor console, or steering column, or in the windshield header area, the *identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield....(Emphasis added.)<<<; As discussed above, the identification required by section S5.2.1 fo the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word 'yes' in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated. It is thus not permissible to illuminate the identifying words without also illuminating the symbols.; I would note that your letter does not provide sufficient informatio to determine whether the controls in your proposed design could come within any of Standard No. 101's exceptions to the illumination requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1225OpenMs. Dianne Black, British Leyland Motors, Inc., 600 Willow Tree Road, Leonia, NJ 07605; Ms. Dianne Black British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black: This is in response to your letter of August 21, 1973, in which yo inquire whether British Leyland Motors Inc. may add to the consumer information leaflets for prospective purchasers, required by NHTSA regulations, the consumer information required by the Environmental Protection Agency.; As long as the information required by NHTSA is presented in conformit with 49 CFR 575, we have no objection to the inclusion within the same covers of additional information relative to EPA requirements. This would permit any format which includes EPA information without detracting from the clear and unconditional presentation of tabular information required under S 575.6(a) of Part 575.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1227OpenMs. Dianne Black, British Leyland Motors, Inc., 600 Willow Tree Road, Leonia, NJ 07605; Ms. Dianne Black British Leyland Motors Inc. 600 Willow Tree Road Leonia NJ 07605; Dear Ms. Black: This is in response to your letter of August 21, 1973, in which yo inquire whether British Leyland Motors Inc. may add to the consumer information leaflets for prospective purchasers, required by NHTSA regulations, the consumer information required by the Environmental Protection Agency.; As long as the information required by NHTSA is presented in conformit with 49 CFR 575, we have no objection to the inclusion within the same covers of additional information relative to EPA requirements. This would permit any format which includes EPA information without detracting from the clear and unconditional presentation of tabular information required under S 575.6(a) of Part 575.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3850OpenMr. David A. White, Senior Safety Engineer, Grumman Olson, 70180 Centerville Road, Sturgis, Michigan 49091; Mr. David A. White Senior Safety Engineer Grumman Olson 70180 Centerville Road Sturgis Michigan 49091; Dear Mr. White: This responds to your letter of May 3, 1984, asking about Standard No 101, *Controls and Displays*. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listing in that table. You asked whether the symbols are required to be illuminated or whether its is permissible instead to illuminate the identifying words without illuminating the symbol. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.; By way of background information, I would note that the Nationa Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic an Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.; Section S5.2.1 of Standard No. 101 generally requires that 'an hand-operated control listed in column 1 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol.' The section states further that '(s)uch a control may, in addition, be identified by the word or abbreviation shown in column 2.' The three controls noted above, heating fan, windshield wiper and washer and defroster system, are all listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.; Section S5.3.1 of Standard No. 101 states: >>>Except for foot-operated controls or hand-operated controls mounte upon the floor, floor console, or steering column, or in the windshield header area, the *identification required by S5.2.1* or S5.2.2 of any control listed in column 1 of Table 1 and accompanied by the word 'yes' in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield...[Emphasis added.]<<<; As discussed above, the identification required by section S5.2.1 fo the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word 'yes' in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated It is thus not permissible to illuminate the identifying words without also illuminating the symbols.; I would note that your letter does not provide sufficient informatio to determine whether the controls in you proposed design could come within any of Standard o. 101's exceptions to the illumination requirements.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4173OpenMr. Henry A. Gorry, Guardian Industries, 43043 West Nine Mile Road, Northville, MI 48167; Mr. Henry A. Gorry Guardian Industries 43043 West Nine Mile Road Northville MI 48167; Dear Mr. Gorry: Thank you for your letter to Mr. Edward Jettner, which was referred t my office for reply. You asked a number of questions about the certification requirements of Standard No. 205, *Glazing Materials*. I regret the delay in answering your questions.; You are correct in your understanding that S6.2 of the standar requires a prime glazing material manufacturer to certify each piece of its glazing material which is designed as a component of a specific motor vehicle or camper by placing the marks required by S6.1 of the standard on the glazing and adding the symbol 'DOT' and a manufacturer's code mark assigned by this agency. You are also correct that pursuant to S6.5, each manufacturer or distributor who cuts a section of glazing material for use in a motor vehicle or camper must place the marks required by S6.1 on the glazing and certify the material in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act. Those persons do not have to add the symbol 'DOT' and a manufacturer's code mark to the glazing.; You asked why the standard draws a distinction between glazin materials which are designed as a component of a specific vehicle and glazing materials which are cut from a section of another item of glazing material. As explained by the agency in an interpretation letter of June 10, 1975, to the California Highway patrol, NHTSA's purpose in structuring the marking requirements in this way was to enable us to determine, for purposes of attributing responsibility for compliance, which glazing in a motor vehicle had been manufactured by the prime manufacturer specifically for use in that vehicle, and which glazing had been cut, shaped, or otherwise altered before installation. In an interpretation letter of July 13, 1976, to DuPont, the agency further explained that since issuance of the certification requirements in 1967, those requirements have become more widely understood and uniformly practiced throughout the glazing industry, which has aided the 'traceability' of glazing materials for enforcement purposes. NHTSA also said that it would no longer prohibit the use of the 'DOT' symbol and the prime glazing manufacturer's code number by the distributor or manufacturer who cuts the glazing, if the prime glazing manufacturer grants permission for such use of the code number to the distributor or manufacturer.; You asked if the term 'manufacturer' used in S6.4 and S6.5 of th standard is meant to mean a 'prime glazing manufacturer.' Section 571.3 of our regulations provides that terms defined in section 102 of the National Traffic and Motor Vehicle Safety Act that are used in the Federal Motor Vehicle Safety Standards have the statutory definition assigned to them by the Act. Section 102(5) of the Vehicle Safety Act defines the term 'manufacturer' as 'any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, including any person importing motor vehicles or motor vehicle equipment for resale.' Thus, the term 'manufacturer' used in S6.4 and S6.5 includes both a prime glazing manufacturer and a person that assemblies (sic) or manufactures vehicles or items of motor vehicle equipment.; You also asked about the definition of the term 'distributor.' A discussed above, section 571.3 provides that terms defined in section 102 of the Vehicle Safety Act that are used in the Federal Motor Vehicle Safety Standards have the statutory definition assigned to them by the Act. Section 102(6) of the Vehicle Safety Act defines the term 'distributor' as 'any person primarily engaged in the sale and distribution of motor vehicles or motor vehicle equipment for resale.' You said that you are confused about the need to distinguish between manufacturers and distributors. The purpose of the distinction was to make sure that commercial sellers who cut glazing for use in motor vehicles, but do not otherwise perform a manufacturing process on the glazing, have to comply with the marking and certification requirements. You are correct that a prime glazing manufacturer may also be a distributor, likewise there are distributors who are not prime glazing manufacturers.; You also asked why the term 'camper' is distinguished from the ter 'motor vehicle' in S6 of Standard No. 205. As mentioned previously, Section 571.3 of our regulations provides that terms defined in the Vehicle Safety Act that are used in the Federal Motor Vehicle Safety Standards have the statutory definition assigned to them by the Vehicle Safety Act. Section 102(3) of the Vehicle Safety Act defines 'motor vehicle' as, in part, 'any vehicle driven or drawn by mechanical power....' As a camper has no independent mechanical power and is not drawn, it would not be covered by the definition of 'motor vehicle'. Thus, it was necessary to specifically define the term 'camper' in S4 of Standard No. 205 to make clear that a camper, which is an item of motor vehicle equipment, is covered by Standard No. 205.; Finally, you asked why do S6.2, S6.4, and S6.5 of Standard No. 20 apply to motor vehicles and campers, while S6.3 refers only to motor vehicles and items of motor vehicle equipment. As discussed previously, a camper is considered an item of motor vehicle equipment and thus the requirements of S6.3 would also apply to glazing made by a prime glazing manufacturer for use in a camper. Since the term 'item of motor vehicle equipment' is a more encompassing classification, the requirements of S6.3 apply to other pieces of equipment, such as wind deflectors, made by prime glazing manufacturers.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2316OpenGovernor Raymond P. Shafer, Counselor to the Vice President; Governor Raymond P. Shafer Counselor to the Vice President; SUBJECT: Letter to the Vice President from Mr. James A. Graham President, General Industrial Group, Gulf + Western Manufacturing Company; Attached is a suggested draft reply to Mr. James A. Graham's letter o April 30, 1976, to the Vice President concerning a petition for reconsideration of the Part 581 - bumper standard.; James B. Gregory, Administrator Department of Transportation, *Suggested Reply* Dear Mr. Graham: This is in response to your letter of April 30, 1976, concerning Gulf Western's petition for reconsideration of the recently issued Part 581 bumper standard.; It is the policy of the National Highway Traffic Safety Administratio (NHTSA) to issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Several manufacturers, including Gulf + Western, have filed petitions for reconsideration of the standard in conformance with NHTSA rulemaking procedures (40 CFR 553.35). Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made in your letter.; The NHTSA will give full and thorough consideration to the comments an information submitted by Gulf + Western and the other petitioners. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, |
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ID: aiam2268OpenHonorable Herman E. Talmadge, Chairman, Committee on Agriculture and Forestry, United States Senate, Washington, DC 20590; Honorable Herman E. Talmadge Chairman Committee on Agriculture and Forestry United States Senate Washington DC 20590; Dear Mr. Chairman: This is in response to your letter of April 1, 1976, forwardin correspondence from Mr. James A. Graham concerning the recently issued Part 581 bumper standard.; On March 4, 1976, the National Highway Traffic Safety Administratio (NHTSA) published a Federal bumper standard (41 FR 9346, 49 CFR Part 581) under the authority of Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The standard, effective September 1, 1978, specifies limitations on damage to non-safety related as well as safety-related vehicle components in low-speed collisions. Several manufacturers, including Gulf and Western Manufacturing Company, have filed petitions for reconsideration of the standard in conformance with NHTSA rulemaking procedures (49 CFR 553.35).; It is NHTSA's policy to issue a notice of action taken on petitions fo reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. Since the agency is currently in the process of considering the petitions received, it would not be appropriate for us to comment at this time on the remarks made by Mr. Graham in his letter.; I assure you that Mr. Graham's comments and the information containe in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0589OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH, 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of December 24, 1971, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You ask whether the entire interior of a van-type vehicle that has n divider behind the driver would be considered the passenger compartment. The answer to this question is no. The cargo area of such a vehicle would not be considered a 'vehicle occupant compartment' under S4.1 of Standard No. 302, and materials used in the cargo area need not comply with the standard.; You ask further whether a metal compartment bin or rack such as thos used in a telephone truck for storage must be certified. If the bin is within the passenger compartment, and is installed in the truck before its sale to a consumer, it would be required under S4.1, as a 'compartment shelf' to meet the requirements of the standard. Certification would be the responsibility of the truck manufacturer, however, and not the manufacturer of the compartment. If the bin or rack is not within the passenger compartment, it need not meet the requirements of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2327OpenMr. Kenneth W. Schang, Manager, Vehicle Safety and Noise, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. Kenneth W. Schang Manager Vehicle Safety and Noise American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Schang: This responds to your telephone request of June 17, 1976, fo confirmation that S 575.101 of Part 575, *Consumer Information*, was recently revised to specify vehicle stopping distance information based on stops that may include wheel lockup under the conditions allowed by Standard No. 105-75, *Hydraulic Brake Systems*. You note that the text of S 575.101(c)(5), and the accompanying illustration in Figure 1 of the section, describe the information provided as performance achieved 'without locking the wheels.'; Your interpretation of the requirements of S 575.101 is correct. I amending Part 575 to permit the use of stopping distance data collected in tests for Standard No. 105-75, the agency made all changes it believed necessary to provide for the use of stopping distance information gathered in connection with Standard No. 105-75 (41 FR 1066, January 6, 1976). The reference to 'without locking the wheels' should have been deleted from the text of S 575.101(c)(5) and Figure 1. A correcting amendment will be issued shortly.; The correction of an omission from the text of the first paragraph of 575.101(c) will also be made at that time. In the last sentence of that paragraph, the concluding option (as published in the *Federal Register*) should read 'under the procedures specified in paragraph (d) of this section and the conditions specified in paragraph (e) of this section.'; Sincerely, James B. Gregory, Administrator |
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ID: aiam2325OpenMr. Kenneth W. Schang, Manager, Vehicle Safety and Noise, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. Kenneth W. Schang Manager Vehicle Safety and Noise American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Schang: This responds to your telephone request of June 17, 1976, fo confirmation that S 575.101 of Part 575, *Consumer Information*, was recently revised to specify vehicle stopping distance information based on stops that may include wheel lockup under the conditions allowed by Standard No. 105-75, *Hydraulic Brake Systems*. You note that the text of S 575.101(c)(5), and the accompanying illustration in Figure 1 of the section, describe the information provided as performance achieved 'without locking the wheels.'; Your interpretation of the requirements of S 575.101 is correct. I amending Part 575 to permit the use of stopping distance data collected in tests for Standard No. 105-75, the agency made all changes it believed necessary to provide for the use of stopping distance information gathered in connection with Standard No. 105-75 (41 FR 1066, January 6, 1976). The reference to 'without locking the wheels' should have been deleted from the text of S 575.101(c)(5) and Figure 1. A correcting amendment will be issued shortly.; The correction of an omission from the text of the first paragraph of 575.101(c) will also be made at that time. In the last sentence of that paragraph, the concluding option (as published in the *Federal Register*) should read 'under the procedures specified in paragraph (d) of this section and the conditions specified in paragraph (e) of this section.'; Sincerely, James B. Gregory, Administrator |
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.