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: aiam3754OpenSherry McBride, The Good Sam Club, P.O. Box 500, Agoura, CA 91301; Sherry McBride The Good Sam Club P.O. Box 500 Agoura CA 91301; Dear Ms. McBride: As requested in your letter of July 8, 1982, please find a copy of th agency's July 1, 1982 letter to Arthur L. Smith of Tempe, Arizona explaining the application of the Federal odometer laws to devices which tow vehicles without the odometer registering the towed mileage. *Motor Vehicle Information and Cost Savings Act* (15 U.S.C. 1981 *et seq.*) and the *Odometer Disclosure Requirements* (49 CFR Part 580).; As we stated in our letter to Mr. Smith, the agency does not hav sufficient information to determine whether any violation of the law has occurred with respect to these particular devices. However, the agency views devices which cause the odometer not to register mileage when the vehicle is towed as prohibited by the Federal odometer laws.; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel |
|
ID: aiam4539OpenMr. Earl Dahl The Goodyear Tire & Rubber Co. Akron, OH 44316-0001; Mr. Earl Dahl The Goodyear Tire & Rubber Co. Akron OH 44316-0001; "Dear Mr. Dahl: This responds to your letter of June 1, 1988, seekin an interpretation of 49 CFR Part 574, Tire Identification and Recordkeeping. Specifically, you asked whether Goodyear could engrave its mold for the Tire Identification Number with a style of characters that was not specifically authorized in the Notes following Figure 1 of 574.5. Note 1 to Figure 1 of Part 574 specifies only four different print types which may be used for the DOT symbol and tire identification number. The style of print that you wish to use is not one of these designated styles. Nevertheless, Note 4 to Figure 1 states that other print types will be permitted if approved by the National Highway Transportation Safety Administration (NHTSA). The agency has examined the print type shown in the diagram attached to your letter and has no objections to your company printing the required information in the print type you submitted. You should be aware that in the final rule establishing Part 574 (35 FR 17257, November 10, 1970), NHTSA explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The print type that you submitted is easily readable and thus satisfies our concerns in that regard. Accordingly, NHTSA approves your print type. Sincerely, Erika Z. Jones Chief Counsel "; |
|
ID: aiam0231OpenMr. Henry C. Hudson, Clements, McClellan and Hawley, 401 Main Street, Mt. Vernon, Indiana 47620; Mr. Henry C. Hudson Clements McClellan and Hawley 401 Main Street Mt. Vernon Indiana 47620; Dear Mr. Hudson: This is in reply to your letter of April 3, 1970, to the Director National Highway Safety Bureau, that has been referred to this office.; The type of information requested under items 1 and 2 of your lette can be extracted, within the limitations of the tests conducted, from the enclosed test result summaries. However, it should be recognized that the scope of the Bureau's testing program is such that valid statistical inferences relating to industry-wide rates for tire defects or failures are not possible with the limited data available.; Prior to the adoption of the labeling requirements in Federal Moto Vehicle Safety Standard No. 109, tires could be identified by manufacturer. This was an industry practice, involving the use of serial number systems and was not required by Government regulation nor war the coding used readily available to the general public.; We trust this and the enclosed publication will answer your questions We will be pleased to answer any additional questions.; Thanks you for your interest in the programs of the National Highwa Safety Bureau.; Sincerely, Francis Armstrong, Director, Office of Compliance, Moto Vehicle Programs; |
|
ID: aiam1460OpenMr. Charles E. Park, President, Intermodal Services, Inc., P.O. Box 111, 4 Lavista - Perimeter Park - Suite 130, Tucker, GA 30084; Mr. Charles E. Park President Intermodal Services Inc. P.O. Box 111 4 Lavista - Perimeter Park - Suite 130 Tucker GA 30084; Dear Mr. Park: This responds to your April 8, 1974, request for a waiver from Standar 121, *Air brake systems*, to permit the manufacturer of semi-trailers which do not comply with the standard after its effective date.; Our authority to enforce standards under S108(a)(1) of the Nationa Traffic and Motor Vehicle Safety Act of 1966 prohibits the sale of a vehicle which does not comply with applicable standards. We are unable to permit by regulation what is prohibited by this section of the law.; We do have under consideration petitions to delay the effective date o Standard 121 as it applies to trailers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3628OpenMs. Joann Stewart, Account Representative, Fowler-Finch, Inc., P.O. 63, New Lebanon Center, NY 12126; Ms. Joann Stewart Account Representative Fowler-Finch Inc. P.O. 63 New Lebanon Center NY 12126; Dear Ms. Stewart: This responds to your recent letter asking whether the automatic bel systems in 1979 and 1980-model Volkswagens qualify as a 'passive restraint system' under Federal Motor Vehicle Safety Standard No. 208, *Occupant Crash Protection*. You need this information to determine if one of your insureds can obtain the discount your company offers for automobiles equipped with passive restraints.; The answer to your question is yes. The Volkswagen automatic bel system qualifies as a passive restraint. The agency has stated that a 'passive restraint' is a system that requires no action by vehicle occupants in order to obtain protection. The Volkswagen passive belt automatically surrounds the vehicle occupant without any action on the occupant's part other than closing the vehicle door (i.e., the occupant does not have to touch the belt system). Therefore, the Volkswagen belts you mentioned in your letter are passive restraints, and whether the systems are offered as standard or optional equipment is irrelevant.; I hope this answers all your questions. If you require any furthe information, please contact Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam0393OpenMr. Frank S. Elliott, Assistant to the Vice-President- Treasurer, Grove Manufacturing Company, Shady Grove, PA 17256; Mr. Frank S. Elliott Assistant to the Vice-President- Treasurer Grove Manufacturing Company Shady Grove PA 17256; Dear Mr. Elliott: This is in reply to your letter of June 22, 1971, regarding the Tir Identification and Record Keeping Regulation (49 CFR 574).; You have asked if Grove Manufacturing Company is a 'Motor Vehicl Manufacturer' within the meaning of section 574.10 of the regulation. As you indicated in your letter, you are the final-stage manufacturer of a truck mounted hydraulic crane, and as such, you are considered the vehicle manufacturer under section 568.3 of Vehicles Manufactured in Two or More Stages (49 CFR 568). As the vehicle manufacturer, you are required to maintain records of the name and address of the first purchaser of your vehicles, for purposes other than resale, along with a record of the tires on the vehicle at the time it is shipped.; Enclosed for convenience are copies of both regulations. For your information, I would direct you to section 568.7 which allow an incomplete vehicle manufacturer to assume all the responsibilities of a manufacturer, this would include the record keeping responsibilities of Part 574.; If we can be of further assistance, please feel free to write. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam0392OpenMr. Frank S. Elliott, Assistant to the Vice-President- Treasurer, Grove Manufacturing Company, Shady Grove, PA 17256; Mr. Frank S. Elliott Assistant to the Vice-President- Treasurer Grove Manufacturing Company Shady Grove PA 17256; Dear Mr. Elliott: This is in reply to your letter of June 22, 1971, regarding the Tir Identification and Record Keeping Regulation (49 CFR 574).; You have asked if Grove Manufacturing Company is a 'Motor Vehicl Manufacturer' within the meaning of section 574.10 of the regulation. As you indicated in your letter, you are the final-stage manufacturer of a truck mounted hydraulic crane, and as such, you are considered the vehicle manufacturer under section 568.3 of Vehicles Manufactured in Two or More Stages (49 CFR 568). As the vehicle manufacturer, you are required to maintain records of the name and address of the first purchaser of your vehicles, for purposes other than resale, along with a record of the tires on the vehicle at the time it is shipped.; Enclosed for convenience are copies of both regulations. For your information, I would direct you to section 568.7 which allow an incomplete vehicle manufacturer to assume all the responsibilities of a manufacturer, this would include the record keeping responsibilities of Part 574.; If we can be of further assistance, please feel free to write. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam0365OpenMr. A. J. Holland, Triplex Safety Glass Co. Ltd., King's North Birmingham B38 8SR, England; Mr. A. J. Holland Triplex Safety Glass Co. Ltd. King's North Birmingham B38 8SR England; Dear Mr. Holland: This is in reply to your letter of May 28, 1971, concerning the markin requirements in the proposed amendment to Standard No. 205, 'Glazing Materials' (Docket No. 71-1, Notice 1). These requirements are only proposed at present, as is their effective date, and do not represent the agency's final decision on the matter. If the agency determines to amend the standard, and before any compliance with new requirements is required, a 'final rule' will be issued that is based on the proposed rule but may differ in some respects from it. The final rule will specify an effective date for these new requirements which, in this instance, will probably be later than the effective date proposed.; You ask whether the effective date of the proposed standard would appl to the manufacture of the glazing, or to the fitting of the material into the vehicle. Standard No. 205 applies to 'glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses', and the effective date of any amendment to this standard refers to the date of manufacture of the glazing material, and not to its fitting into the vehicle.; Your second question, whether we will accept your marking without hyphen between the 'DOT' symbol and your code mark, has been answered in our letter to you of May 26, 1971.; I hope this clarifies the situation. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam1231OpenMr. Kesao Nishiki, Program Supervisor, International Research & Marketing, The Plaza, 2 West 59th Street, New York, NY, 10010; Mr. Kesao Nishiki Program Supervisor International Research & Marketing The Plaza 2 West 59th Street New York NY 10010; Dear Mr. Nishiki: This is in reply to your letter of May 24, 1973, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. We apologize for the delay in answering your letter, but we did not receive your letter of the above date and the copy we later received does not include the diagram that was apparently attached to your original letter.; You ask whether the weather strip assembly 'used for the sealin between the car body and the door panel' must meet the requirements of the standard. We are unable to answer this question without additional information regarding the placement of the weather strip assembly and its attachment, if any, to the door panel. If you would provide us with this information, we will try to give you a prompt reply.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam4121OpenMr. Masaki Ogura, Manager Truck Engineering, MMC Services, Inc., 3000 Town Center, Suite 501, Southfield, MI 48075; Mr. Masaki Ogura Manager Truck Engineering MMC Services Inc. 3000 Town Center Suite 501 Southfield MI 48075; Dear Mr. Ogura: This responds to your request for an interpretation concerning th reservoir strength requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 121, *Air Brake Systems*. You asked how those requirements apply to multi- chamber reservoirs.; By way of background information, the National Highway Traffic Safet Administration does not give approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to certify that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.; The issue raised by your letter concerning the application of FMVSS No 121's reservoir strength requirements to multi-chamber reservoirs appears to be the same issue discussed in a letter of interpretation dated May 23, 1978, addressed to the Johnson Manufacturing Company. As discussed in that letter, only the circumference of the outer reservoir shell is measured, and internal baffles are not stressed by separate compartment-by- compartment testing. We are enclosing a copy of that letter and two *Federal Register* notices cited by the letter. (Please note that an interpretation provided in the earlier of the two notices was withdrawn by the later notice.); Sincerely, Erika Z. Jones, 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.