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: aiam2730OpenMr. Bjorn Svendsen, Viking-Mjondalen A/S, Postboks 55, 3051 Mjondalen, Norway; Mr. Bjorn Svendsen Viking-Mjondalen A/S Postboks 55 3051 Mjondalen Norway; Dear Mr. Svendsen: This is in response to your letter of December 19, 1977, asking whethe there are current plans to upgrade the requirements of Part 581, *Bumper Standard*, by increasing the impact test speeds to 7.5 mph.; There are, at present, no plans to increase the test speeds specifie in Part 581. If, at any time in the future, the National Highway Traffic Safety Administration determines that an upgrading of the bumper standard is in order, a Federal Register notice proposing such plans would be issued, providing all interested parties with an opportunity to comment on the suggested provisions. No final rule would be issued without a prior notice of proposed rulemaking.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3796OpenJohn H. Schmidt, P.E., Certification Supervisor, Harley- Davidson Motor Co., Inc., 3700 W. Juneau Avenue, P.O. Box 653, Milwaukee, WI 53201; John H. Schmidt P.E. Certification Supervisor Harley- Davidson Motor Co. Inc. 3700 W. Juneau Avenue P.O. Box 653 Milwaukee WI 53201; Dear Mr. Schmidt: This responds to your February 6, 1984 letter to Roger Fairchild o this office, in which you asked whether your company may include on vehicle certification labels gross vehicle weight rating and gross axle weight rating information expressed in kilograms. The metric units would be used in addition to information expressed in pounds, with the English units appearing first on the label and the metric units following in parenthesis. Our certification regulations (49 CFR Part 567) provide that this information is to be specified in pounds.; The inclusion of metric weight ratings in addition to the English unit specified in our regulation (with the English units appearing first) has previously been approved in an agency interpretation letter, a copy of which is enclosed. Therefore, your proposed certification labels are authorized under the certification regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3797OpenJohn H. Schmidt, P.E., Certification Supervisor, Harley- Davidson Motor Co., Inc., 3700 W. Juneau Avenue, P.O. Box 653, Milwaukee, WI 53201; John H. Schmidt P.E. Certification Supervisor Harley- Davidson Motor Co. Inc. 3700 W. Juneau Avenue P.O. Box 653 Milwaukee WI 53201; Dear Mr. Schmidt: This responds to your February 6, 1984 letter to Roger Fairchild o this office, in which you asked whether your company may include on vehicle certification labels gross vehicle weight rating and gross axle weight rating information expressed in kilograms. The metric units would be used in addition to information expressed in pounds, with the English units appearing first on the label and the metric units following in parenthesis. Our certification regulations (49 CFR Part 567) provide that this information is to be specified in pounds.; The inclusion of metric weight ratings in addition to the English unit specified in our regulation (with the English units appearing first) has previously been approved in an agency interpretation letter, a copy of which is enclosed. Therefore, your proposed certification labels are authorized under the certification regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4305OpenMr. Takashi Shimoda, Chief of Quality Assurance Section, Nichirin Rubber Industrial Co., Ltd., 1118, Sazuchi, Bessho-cho, Himeji-City, 671-02, JAPAN; Mr. Takashi Shimoda Chief of Quality Assurance Section Nichirin Rubber Industrial Co. Ltd. 1118 Sazuchi Bessho-cho Himeji-City 671-02 JAPAN; Dear Mr. Shimoda: This responds to your letter to our office asking two questions abou Federal Motor Vehicle Safety Standard No. 106, *Brake Hoses.* I am pleased to be of assistance.; In your letter, you explain that your company plans to export brak hose assemblies to the United States that are made of resin and other materials. You first ask whether Standard No. 106 applies 'equally' to all brake hoses and assemblies regardless of the materials used in their manufacture. Your understanding is correct. Brake hoses and brake hose assemblies may be made from any material as long as they can meet all applicable performance requirements of the standard.; Your second question concerns the standard's whip resistanc requirement of S5.3.3 and the whip resistance test of S6.3. You ask for confirmation that cracks in the hose specimen are acceptable under S5.3.3 provided that there is no leakage for the hose assembly. Your understanding is correct. S5.3.3 states: 'A hydraulic brake hose assembly shall not rupture when run continuously on a flexing machine for 35 hours (S6.3).' The standard defines 'rupture' as 'any failure that results in separation of a brake hose for its end fitting or in leakage.' The determining factor for the whip resistance requirement is thus the pressure maintained by the system. If there is no pressure loss in the system, the brake hose assembly meets S5.3.3, regardless of the presence of cracks in the hose specimen. Please not, however, that although cracks in themselves do not constitute a failure of S5.3.3, the development of cracks caused by exposure to ozone is important for the ozone resistance requirement of S5.2.10.; Since you are planning to import your products into the United States I am enclosing copies to two procedural rules which apply to all manufacturers subject to the regulations of this agency. The first is 49 CFR Part 566, *Manufacturer Identification.* This rule requires your company to submit its name, address and a brief description of the items of equipment it manufactures to this agency within 30 days after it imports its products into this country.; The other rule is 49 CFR 551, *Procedural Rules.* Subpart D of thi regulation requires all manufacturers headquartered outside of the United States to designate a permanent resident of the United States as the manufacturer's agent for service of all process, notices, orders, and decision. This designation should be mailed to the Chief counsel, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590, and must include the following information:; 1. A certification that the designation of agent is valid in form an binding on the manufacturer under the laws, corporate-by-laws, or other requirements governing the making of the designation at the time and place where it is made,; 2. The full legal name, principal place of business and mailing addres of the manufacturer,; 3. Marks, trade names, or other designations of origin of any of th manufacturer's products which do not bear its name,; 4. A statement that the designation shall remain in effect unti withdrawn or replaced by the manufacturer,; 5. A declaration of acceptance duly signed by the agent appointed which may be an individual, a firm or a United States corporation, and,; 6. The full legal name and address of the designated agent. In addition, the designation must be signed by a person with authorit to appoint the agent. The signer's name and title should be clearly indicated beneath his or her signature.; I hope this information is helpful. Please contact us if you hav further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3265OpenMr. Robert A. Eddy, Manager, Quality Assurance, McCreary Tire & Rubber Company, Indiana, PA 15701; Mr. Robert A. Eddy Manager Quality Assurance McCreary Tire & Rubber Company Indiana PA 15701; Dear Mr. Eddy: This is in response to your letter of March 7, 1980, asking whethe ASTM E501 and E524 tires must be graded in accordance with the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104). You state that these tires are manufactured in limited quantities as standards for traction testing and are not manufactured for general highway use. It is the National Highway Traffic Safety Administration's understanding that these tires are used only on a test trailer designed for use in skid testing.; The UTQG regulation applies to new pneumatic tires for use on passenge cars (49 CFR 575.104(c)(1)). Thus, ASTM E501 and E524, which are manufactured solely for use on a traction test trailer, would not fall within the application of the UTQG Standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3266OpenMr. Robert A. Eddy, Manager, Quality Assurance, McCreary Tire & Rubber Company, Indiana, PA 15701; Mr. Robert A. Eddy Manager Quality Assurance McCreary Tire & Rubber Company Indiana PA 15701; Dear Mr. Eddy: This is in response to your letter of March 7, 1980, asking whethe ASTM E501 and E524 tires must be graded in accordance with the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104). You state that these tires are manufactured in limited quantities as standards for traction testing and are not manufactured for general highway use. It is the National Highway Traffic Safety Administration's understanding that these tires are used only on a test trailer designed for use in skid testing.; The UTQG regulation applies to new pneumatic tires for use on passenge cars (49 CFR 575.104(c)(1)). Thus, ASTM E501 and E524, which are manufactured solely for use on a traction test trailer, would not fall within the application of the UTQG Standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1866OpenMr. George E. Talmage, Bowes Seal Fast Corporation, 5902 East Thirty-Fourth Street, Indianapolis, Indiana 46218; Mr. George E. Talmage Bowes Seal Fast Corporation 5902 East Thirty-Fourth Street Indianapolis Indiana 46218; Dear Mr. Talmage: This is in reply to your letter of March 31, 1975, to Mr. Fred Redle of this agency, asking our comments on apparent hardships involved with brake fluid containers and labels that have been obsoleted by the recent deletion of color coding requirements.; Since the deletion leaves Standard no. 116 without mandatory colo requirements, and does not prohibit the use of any color, you may use such cans as you have in hand, or on order, until the effective date of any new color requirements. However, in the interim, this does not preclude any State from specifying or prohibiting fluid and container label color.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4843OpenMr. Delbert N. Pier Legislation and Compliance Coordinator Hyundai America Technical Center, Inc. 5075 Venture Drive Ann Arbor, MI 48108; Mr. Delbert N. Pier Legislation and Compliance Coordinator Hyundai America Technical Center Inc. 5075 Venture Drive Ann Arbor MI 48108; Dear Mr. Pier: This is in reply to your letter of February 11, l99l asking for an interpretation of Motor Vehicle Safety Standard No. 108. With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked 'whether the bulb fixture can be rotated approximately 11 degrees', and have informed us that this will not change the 'constants . . . or the relationship of the terminals to the constants.' Standard No. 108 does not specify the orientation of replaceable light sources in headlamps, the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector) of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam1190OpenMr. William J. Henrick, The General Tire & Rubber Company,1 General Street, Akron, Ohio 44329; Mr. William J. Henrick The General Tire & Rubber Company 1 General Street Akron Ohio 44329; Dear Mr. Henrick: #By your telegram of July 16, 1973, you requested a interpretation of the passenger car tire standard-- No. 109, which would allow the branding of the information required to be on the sidewall. #As we understand the situation in this case, the tires in question are certified by the manufacturer as complying and have all the required information but the 'DOT' certification is in the wrong location. #In this instance, we have no objection to branding the 'DOT' in the proper location. #We are notifying the Baltimore Customs officials that the tires that do not comply with the standard can be brought into this country by making a box 3 declaration that the merchandise does not conform but will be brought to conformance within 90 days by branding 'DOT' in the proper location. Under the Customs regulations, 19 CFR 12.80, this requires the posting of a bond equal to the value of the merchandise. #Sincerely, Lawrence R. Schneider, Chief Counsel; |
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ID: aiam0385OpenMr. Nathan Sagan, 949 Central Avenue, Albany, NY (sic); Mr. Nathan Sagan 949 Central Avenue Albany NY (sic); Dear Mr. Sagan: This is in further reply to your request made to the Regiona Administrator of the National Highway Traffic Safety Administration concerning the applicability of the Tire Identification and Record Keeping regulation (49 CFR Part 574) to tires on Cushman golf carts.; As we indicated in our letter of June 23, golf carts are not considere to be motor vehicles within the meaning of the regulation or the National Traffic and Motor Vehicle Safety Act. Therefore, the regulation is not applicable to tires sold with or for golf carts.; Sincerely, Lawrence R. Schneider, Acting 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.