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: aiam1990OpenMr. Manuel M. Ellenbogen, Supervisor, Export Sales & Licensing, International-Automotive, The Budd Company, 2450 Hunting Park Avenue, Philadelphia, PA 19132; Mr. Manuel M. Ellenbogen Supervisor Export Sales & Licensing International-Automotive The Budd Company 2450 Hunting Park Avenue Philadelphia PA 19132; Dear Mr. Ellenbogen: This is in response to your letter of July 8, 1975, asking whic standards might be affected by the mounting of a tail lamp in the elastic skin of a bumper.; Motor Vehicle Safety Standard No. 215, *Exterior Protection* prescribes barrier and pendulum impact tests to which vehicles must be subjected without incurring certain types of damage. Included in the list of safety systems that must remain undamaged are lamps and reflective devices. S5.3.1 of Standard 215 states that each lamp or reflective device, except license plate lamps, must remain free of cracks and comply with the applicable visibility requirements of S4.3.1.1 of Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; The manufacturer should be aware that placement of a tail lamp in th elastic skin of a bumper might expose it to damage during Standard 215 compliance testing.; For your information, I have enclosed copies of the current Standar No. 215, the proposed Part 580 bumper damageability standard, and Standard No. 108.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1796OpenMr. Paul Utans, 55 Concord Street, Englewood, New Jersey 07631; Mr. Paul Utans 55 Concord Street Englewood New Jersey 07631; Dear Mr. Utans: This responds to your January 19, 1975 question whether S5.4.3 o Standard No. 105-75, *Hydraulic brake systems*, permits a brake fluid warning statement on a filler cap to be partially obscured by a locking component placed over it, and whether the statement in association with the recommended type of brake fluid.; The answer to both of your questions is no. Section S5.4.3(b) require that the statement be 'located so as to be visible by direct view'. This requirement prohibits an arrangement which would obscure any part of the statement, as would the design described in the drawings which accompany your letter. Section S5.4.3(b) permits a location within 4 inches of the brake fluid reservoir filler plug or cap to accommodate arrangements which do not permit use of the filler cap as a location.; The content of the brake fluid warning statement required by S5.4.3 i specified in every respect other than designation of the recommended type of brake fluid. However, S5.4.3 does limit the permissible designation to 'the recommended type of brake fluid as specified in 49 CFR S571.116' and sets out an example of 'DOT 3'. These criteria do not permit the addition of an automobile manufacturer's name. Such a recommendation could, of course, appear separately in the vehicle's owner's manual.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2618OpenMr. Gustavo R.. Lima, Vice-President, Algus Enterprises, Inc., P. O. Box 520576, Miami, Florida 33152; Mr. Gustavo R.. Lima Vice-President Algus Enterprises Inc. P. O. Box 520576 Miami Florida 33152; Dear Mr. Lima: This responds to your June 27, 1977, letter asking whether tires tha you export for use on agricultural vehicles are required by the National Highway Traffic Safety Administration (NHTSA) to be labeled with the letters DOT.; The answer to your question is no, unless the tires can also be used o vehicles other than agricultural vehicles. If the tires can be so used, they must be marked with the DOT symbol and meet any Federal requirements applicable to them.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0688OpenMr. Lee S. Richards, Lee Equipment, Incorporated, 38 Old Route 6, Carmel, NY 10512; Mr. Lee S. Richards Lee Equipment Incorporated 38 Old Route 6 Carmel NY 10512; Dear Mr. Richards: This is in reply to your letter of April 11, 1972, to our New Yor office, that has been referred to me.; Paragraph 568.3 of Title 49 of the Code of Federal Regulations states ''Final stage' manufacturer means a person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle.'; The subject is also dealt with in the Preamble to Part 568 '. . .Th definitions by which the regulation establishes the categories of 'incompete (sic) vehicle,' 'completed vehicle,' and the three categories of vehicle manufactures provide a framework within which each *may categorize himself* and his products. Of necessity, the definitions are broad and may not clearly define individual situations . . . . In the usual case, it will be possible for the affected manufacturers to *reach agreement between themselves* as to their respective obligations . . . .' (emphasis added); In the event that the matter is in dispute between yourself and th tank installer we would be inclined, based on the information in hand, to rule that the tank installer is the final stage manufacturer inasmuch as the equipment that you install would be 'readily attachable.'; Your obligations as a manufacturer would be the same whether the tan you install on the new chassis is new or used.; I trust this will answer your questions. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam2500OpenMr. David F. Berry, Director, Quality Control & Special Products, Birmingham Manufacturing Company, Inc., P.O. Drawer 289, Springville, AL 35146; Mr. David F. Berry Director Quality Control & Special Products Birmingham Manufacturing Company Inc. P.O. Drawer 289 Springville AL 35146; Dear Mr. Berry: This responds to Birmingham Manufacturing Company's June 15, 1976 request to know the certification responsibilities of a manufacturer of low-bed trailers (of the removable goose-neck design) that provides the purchaser with the bed, suspension, and axle portions of the trailer without the gooseneck or the tires and rims. I apologize for our delay in answering.; The portion of the trailer you describe constitutes an 'incomplet vehicle' as that term is described in Part 568 of our regulations (Part 568 -- Vehicles Manufactured in Two or More Stages):; >>>S 568.3 *Definitions*. 'Incomplete vehicle' means an assemblage consisting, as a minimum, o frame and chassis structure, power train, steering system, suspension system, and brake system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle.; << |
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ID: aiam2756OpenMr. Brian Gill, Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, 100 W Alondra Blvd, Gardena, California 90247; Mr. Brian Gill Manager Certification Department American Honda Motor Co. Inc. P.O. Box 50 100 W Alondra Blvd Gardena California 90247; Dear Mr. Gill: This is in reply to your letter of January 20, 1978, asking for a interpretation of the requirements in Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*, for motorcycle headlamp upper-lower beam switches.; Standard No. 123 requires this control to be pushed 'up' for the uppe beam and 'down' for the lower beam. You have stated with respect to the design which you submitted that 'when the lower beam is on, the control surface is parallel to the housing. To switch to the high beam the top of the control is pushed ... to switch to the lower beam the bottom of the control is pushed.' You asked if this design is within the scope of the operation described in Standard No. 123.; It appears from your description that up and down motions of the thum operate the upper and lower beams respectively and that the design conforms to Standard No. 123's requirements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0658OpenMr. Joseph Mazzafro, Manager Production Engineering, Strick Corporation, U.S. Highway No. 1, Fairless Hills, PA 19030; Mr. Joseph Mazzafro Manager Production Engineering Strick Corporation U.S. Highway No. 1 Fairless Hills PA 19030; Dear Mr. Mazzafro: This is in reply to your letter of February 25, 1972, enclosing sampl certification labels and requesting our review and comments. The labels you have submitted follow correspondence to you from NHTSA dated February 18, 1972, wherein we disapproved an earlier format you wished to use. Your revised label consists of multiple listings using punched holes and overlays to indicate appropriate information.; We do consider your revised label to be completely consistent with th Certification regulations (Part 567) in that the information is still presented in a way that is somewhat (and we might add unnecessarily) confusing. This confusion occurs because you do not fully delete information that is inapplicable to the vehicle in question. For example, regarding GVWR and GAWR in samples 2 and 3, you do not delete the entire number (leaving the zeroes and the suffix, lbs.) and it is not clear, in our view, whether the figures have been deleted or whether the label is disfigured. We believe the entire figure should be deleted where it is not applicable. Similarly, in the case of month and year, and vehicle number, all the information you wish to omit should be completely deleted. This would require deletion of all months other than the month of manufacture and all numbers other than the vehicle number.; Finally, in using an overlay (sample 4), the overlay should be done i such a manner that the label does not give the appearance of having been tampered with.; We trust this clarifies the situation. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam1991OpenMr. E. Cooper Lipshield, Manager Research and Development, Orscheln Lever Sales Company, 1177 N. Morley Street, Moberly, MO 65270; Mr. E. Cooper Lipshield Manager Research and Development Orscheln Lever Sales Company 1177 N. Morley Street Moberly MO 65270; Dear Mr. Lipshield: This is in response to your letter of July 10, 1975, in which yo request a copy of the proposed rule dealing with tilt cab vehicle latch systems (Docket No. 69-27), which was referred to this office by the Docket Section.; Notice 1 of Docket 69-27 was published as an advance notice of propose rulemaking on October 22, 1969 (34 FR 17115). On January 25, 1972, a notice was published suspending rulemaking on 69-27 and proving that no regulation would be issued without additional notice and opportunity for comment (37 FR 1120). There has been no further action taken on tilt cab vehicle latch systems since that date.; If we can be of any further assistance, please let us know. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2667OpenMessrs. George Schwarz and T. Szkolniki, Supervisors, Production and Mechanical Engineering, Motor Coach Industries, Inc., Pembina, ND 58271; Messrs. George Schwarz and T. Szkolniki Supervisors Production and Mechanical Engineering Motor Coach Industries Inc. Pembina ND 58271; Gentlemen: This will acknowledge receipt of the petition by Motor Coac Industries, dated July 22, 1977, for a determination that an apparent noncompliance with Motor Vehicle Safety Standard No. 121 is inconsequential as it relates to motor vehicle safety.; We are preparing a notice for publication in the *Federal Register requesting public comment on your petition and you will be notified in due course as to its disposition. The notice will not include reference to the fact that the 'continuous warning' signal required by S5.1.5 of Standard No. 121 is an automatic flashing light on MCI vehicles. It is the opinion of this office that either an automatic flashing light or a continuous light will provide a 'continuous warning' within the intent of the Standard.; Yours truly, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1101OpenLouis A. Sisler, Esq., General Counsel, ADC Marketing, Inc., 4410 Executive West, Fort Wayne, IN 46808; Louis A. Sisler Esq. General Counsel ADC Marketing Inc. 4410 Executive West Fort Wayne IN 46808; Dear Mr. Sisler: This is in reply to your letter of March 29, 1973, to Mr. Schneide asking for a clarification that the Front Brake Light Adapter you describe 'does not fall within the provisions of Motor Vehicle Safety Standard No. 108.' The adapter, as we understand it, connects the stop lamps with the front turn signal lamps so that when the brakes are applied, the front turn signal lamps are activated in a steady-burning state, indicating that the vehicle is decelerating or has come to a halt.; In our opinion, use of the adapter as original equipment on a vehicl might be precluded by paragraph S4.1.3 of Standard No. 108 prohibiting devices that impair the effectiveness of the equipment required by the standard. The front turn signal lamp is a lamp that flashes in operation to indicate to oncoming drivers, or pedestrians, that the vehicle is preparing to turn, or that a potential hazard exists ahead (when the system is activated as a hazard warning system). Accordingly, when the brake pedal is applied, if the adapter overrides the flashing effect of the front signal lamps it would impair their effectiveness, and be prohibited by Standard No. 108.; The adapter would be permissible as original equipment, however provided that the signals still flash when the brakes are applied, but a State would not be preempted from regulating it. Nothing in the standard precludes aftermarket sale of the adapter, but its use also would be subject to regulation by the individual States.; 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.