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: aiam3494OpenRichard F. Starkey, Esq., Assistant General Counsel, Fruehauf Corporation, 10900 Harper Avenue, P.O. Box 238, Detroit, MI 48232; Richard F. Starkey Esq. Assistant General Counsel Fruehauf Corporation 10900 Harper Avenue P.O. Box 238 Detroit MI 48232; Dear Mr. Starkey: This responds to your recent letter to Mr. Kratzke of my staf concerning the requirements of Federal Motor Vehicle Safety Standard No. 120 (49 CFR S571.120). Specifically, you asked if retreaded tires could be mounted on new trucks and trailers, and what requirements those tires would have to meet.; Retreaded tires can be mounted on new trucks and trailers withou violating Standard 120. For your information, I have enclosed a copy of a 1978 interpretation concerning Standard 120 which explains that retreaded tires can be mounted on new trucks and trailers in compliance with the standard. The only requirements those tires would have to meet is that the sum of maximum load ratings for the tires would have to be at least equal to the gross axle weight rating of the axle to which they were fitted, as specified in section S5.1.2 of the Standard 120. As explained in the attached letter, there is no requirement that the retread meet the requirements of Standard 119 because those requirements are inapplicable to retreads. Further, there is no requirement that the retreads have the DOT symbol.; If you have any further questions, please contact Mr. Kratzke at (202 426- 2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2226OpenMr. James C. Murphy, Assistant Vice President, National Association of Independent Insurers, 2600 River Road, Des Plaines, Illinois 60018; Mr. James C. Murphy Assistant Vice President National Association of Independent Insurers 2600 River Road Des Plaines Illinois 60018; Dear Mr. Murphy: This is in response to your letter of February 17, 1976, in which yo asked that we reconsider our opinion of January 13 that any State laws regulating the content of vehicle identifications numbers (VIN's) would be preempted by Standard No. 115. Your reason was that the lack of standardization of VIN's caused many problems for insurance companies, State licensing agencies, and traffic enforcement agencies.; I think you might have misunderstood our intention concerning VIN's W agree that non-standardization of them is costly to all concerned, and we are working actively to promulgate a standardizing amendment to Standard 115. We are concerned, moreover, that if the States do not act in a uniform manner in laying down requirements for manufacturers, they might impose severe and unnecessary costs on them (and the public). This, of course, was the reason why Congress inserted the preemption provisions in the Vehicle Safety Act in the first place.; We want very much to have a system that applies not only to all State and all manufacturers, but to all the countries of the world, so that vehicles may move freely without danger of running afoul of identification standards. We have been working closely for several years with the International Standards Organization and the Society of Automotive Engineers to arrive at an acceptable world-wide uniform system. Our development work is finished now, and we expect to be issuing a proposal shortly for such a uniform system. We will appreciate your interest and your help in finalizing our standard in this area.; Sincerely. James B. Gregory, Administrator |
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ID: aiam2705OpenMr. G. Schwarz, Manager, Production Engineering, Motor Coach Industries, Inc., Pembina, ND 58271; Mr. G. Schwarz Manager Production Engineering Motor Coach Industries Inc. Pembina ND 58271; Dear Mr. Schwartz: This in reply to your letter of October 27, 1977, with respect t distribution of a service bulletin on the subject of 'New Generator Control and Low Air Switch Setting.' As your inconsequentiality petition is now pending (Docket No. IP77-14) you have asked whether you may 'hold further actions or procedures on [the] two items [discussed] pending the outcome' of the petition.; The NHTSA does not advise manufacturers to withhold corrective actio while inconsequentiality petitions are pending. That decision must be made by the manufacturer as an independent exercise of its judgment. However, a company that has filed an inconsequentiality petition is not required to notify and remedy pursuant to the National Traffic and Motor Vehicle Safety Act until such time as its petition has been denied. Your service bulletin does not fulfill the requirements of 49 CFR Part 577 and if you issue it now, in the event of the denial of the petition you would be required to notify all owners of vehicles which remain uncorrected.; Yours truly, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5622OpenMr. Saburo Inui, Vice President Toyota Motor Corporate Services of North America, Inc. 1850 M. Street, NW Washington, DC 20036; Mr. Saburo Inui Vice President Toyota Motor Corporate Services of North America Inc. 1850 M. Street NW Washington DC 20036; Dear Mr. Inui: This responds to Toyota's August 22, 1995, lette regarding the test procedures in this agency's June 7, 1995, amendment to Federal Motor Vehicle Safety Standard No. 114 (60 FR 30006). You were concerned that the test procedure seems to say that the service brake should be applied at two different steps during the test procedure, without specifying when the service brake should be released in between those two steps. You suggested a revised procedure that specifies a step for releasing the service brake, and asked if that procedure conforms with the National Highway Traffic Safety Administration's (NHTSA) test requirement. After reviewing the issues raised by your letter, we have concluded that a technical amendment should be issued to clarify the test procedure. We expect to issue such an amendment shortly. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1193OpenMr. Hank Thorp, Hank Thorp Inc., Post Office Box 201. Edison, New Jersey 08817; Mr. Hank Thorp Hank Thorp Inc. Post Office Box 201. Edison New Jersey 08817; Dear Mr. Thorp: This is in response to your letter of July 7, 1973, which asks if th Manufacturer Code proposal (38 FR 14968, June 7, 1973) as it applies to wheel nuts (1) requires all manufacturers, including vehicle manufacturers, to label their products, (2) permits labeling with self-adhesive stickers, and (3) has authorized the issuance of codes at this time. In addition, you requested a clarification of an interpretation of Standard 211, *Wheel nuts*.; The answer to your first question is yes. The labeling requirement apply to foreign and domestic manufacturers of passenger cars and multi-purpose passenger vehicles and to manufacturers of equipment for those vehicles. The term 'manufacturer' includes an importer of vehicles or regulated equipment.; The use of a self-adhesive sticker in satisfaction of the permanent an legible labeling requirement of the proposal is permissible , so long as the information printed thereon is indelible and the label is affixed in such a manner that it cannot be removed without destroying or defacing it.; No codes have been assigned at this time. Assignment will not occu until a decision is reached as to issuance of a final rule.; The small hexagonal nuts which you import and which you describe a serving the same purpose as the small hexagonal nuts which secure factory-mounted, steel wheels to an axle, are not wheel nuts under the standard. The reference to normal coverage by a hub cap or wheel disc is simply descriptive of their location.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0349OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Distributors Association, P.O. Box 11088, Cincinnati, OH 45211; Mr. Thomas S. Pieratt Jr. Executive Secretary Distributors Association P.O. Box 11088 Cincinnati OH 45211; Dear Mr. Pieratt: This is in response to your letter of May 12, 1971, in which yo inquired about the responsibilities, under Parts 567 and 568 of the NHTSA regulations, of a company that sells small trailer chassis in kit form, to persons who assemble them, add bodies, and sell them to users. You discussed the questions by telephone with Richard Dyson of this office on May 21, and this letter confirms the answers that Mr. Dyson gave you then.; Since the unit sold by the company in question is not assembled, it i not an 'incomplete vehicle' within the meaning of Part 568, and the company therefore has no responsibilities under that part to provide information to subsequent purchasers. The person who assembles the kit and adds a body is, of course, a manufacturer, and must certify the complete vehicle under S 567.4 of the Certification regulations. It appears that this certifier would normally rely on the chassis kit seller to provide the basic information concerning the vehicle characteristics, and the assurance that when assembled according to instructions it will conform to applicable motor vehicle safety standards, so that he can responsibly certify the vehicle. We assume that the chassis kit seller would provide this information as a commercial responsibility, although the relationship is not at present governed by NHTSA regulations.; Please let us know if we can be of further assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2862OpenMr. Richard H. Attenhofer, Manager, Tire Technical Relations, Dunlop Tire Company, Box 1109, Buffalo, NY 14240; Mr. Richard H. Attenhofer Manager Tire Technical Relations Dunlop Tire Company Box 1109 Buffalo NY 14240; Dear Mr. Attenhofer: This responds to your August 2, 1978, letter noting two standards o the National Highway Traffic Safety Administration that you consider to be in conflict. You suggest that Part 569, *Regrooved Tires*, conflicts with Standard No. 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars*, in their requirements for the size of the molding of the word 'regroovable'.; Standard No. 119 specifies all of the labeling of tires for moto vehicles other than passenger cars. The size of that required labeling is set at not less than .078 inches. This size provision applies generally to all of the various information required to be labeled on a tire. The information labeled on the tire includes the tire identification number and word 'regroovable' if appropriate. Both of these requirements, however, are subjects of their own regulations. The tire identification number is specifically regulated by Part 574 and regroovable tires are regulated by Part 569. Each of these Parts further specifies the size designation of the information that it requires. For example, Part 569 specifically requires the word 'regroovable' to be in letters .38 to .50 inches in height.; The two standards do not conflict. The size requirement in Part 56 falls within the acceptable size levels of Standard No. 119. Part 569 merely further restricts the size of the word 'regroovable' beyond that specified in Standard No. 119. Accordingly, the two are consistent. To understand both requirements, apply the general size requirements of Standard No. 119 to all information that is not otherwise regulated elsewhere. For information specifically regulated elsewhere, apply the size criteria specified in the applicable regulation.; Sincerely, Joseph J. Levin, Jr. Chief Counsel |
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ID: aiam2859OpenMr. Richard H. Attenhofer, Manager, Tire Technical Relations, Dunlop Tire Company, Box 1109, Buffalo, New York 14240; Mr. Richard H. Attenhofer Manager Tire Technical Relations Dunlop Tire Company Box 1109 Buffalo New York 14240; Dear Mr. Attenhofer: This responds to your August 2, 1978, letter noting two standards o the National Highway Traffic Safety Administration that you consider to be in conflict with Standard No. 119, *new Pneumatic Tires for Vehicles Other Than Passenger Cars,* in their requirements for the size of the molding of the word 'regroovable'.; Standard No. 119 specifies all of the labeling of tires for moto vehicles other than passenger cars. The size of that required labeling is set at not less than .078 inches. This size provision applies generally to all of the various information required to be labeled on a tire. The information label on the tire includes that tire identification number and word 'regroovable' if appropriate. Both of these requirements, however, are subjects of their own regulations. The tire identification number is specifically regulated by Part 574 and regroovable tires are regulated by part 569. Each of these Parts further specifies the size designation of the information that it requires. For example, Part 569 specifically requires the word 'regroovable' to be in letters .38 to .50 inches in height.; The two standards do not conflict. The size requirement in Part 56 falls within the acceptable size levels of Standard No. 119. Part 569 merely further restricts the size of the word 'regroovable' beyond that specified in Standard No. 119. Accordingly, the two are consistent. To understand both requirements, apply the general size requirements of Standard No. 119 to all information that is not otherwise regulated elsewhere. For information specifically regulated elsewhere, apply the size criteria specified in the applicable regulation.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4995OpenMr. Gonshiro Miyoshi Manager, Design Administration Dept. Technical Division Ichikoh Industries, Inc. 80 Itado, Isehara-City Kanagawa, 259-11 Japan; Mr. Gonshiro Miyoshi Manager Design Administration Dept. Technical Division Ichikoh Industries Inc. 80 Itado Isehara-City Kanagawa 259-11 Japan; Dear Mr. Miyoshi: This responds to your letter of April 6, 1992, askin for an interpretation of Standard No. 108. With respect to a headlamp system consisting of two lamps, each containing two light sources, you have asked 'Is it permissible to have the bulb center of the lower beam lower than that of the upper beam (maximum height difference is 10mm) if they are arranged horizontally?' Paragraph S7.5(d)(2) specifies the manner in which 'the lower and upper beams of a headlamp system consisting of two lamps, each containing either one or two light sources, shall be provided . . .' In such headlamps where each light source provides a beam, the lower beam is provided 'by the outboard light source (or upper one if arranged vertically),' and the upper beam is provided 'by the inboard light source (or the lower one if arranged vertically).' Although the standard could be presumed to contemplate that two light sources within a headlamp would be located on the same horizontal or vertical plane, there is no specific requirement for light source placement. Because the difference in the horizontal mounting planes for bulb centers in your design is only 10mm, this difference is not sufficient to conclude that the light sources are vertically arranged, thus requiring that the lower beam bulb center be the 'upper' one, or on a plane that is higher. However, for your design to be permissible, the lower beam in this essentially horizontal array must be provided by the outboard light source in the headlamps as specified in S7.5(d)(2). Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam5274OpenMr. J. C. DeLaney Manager, Technical Programs Motorcycle Industry Council, Inc. 2 Jenner Street, Suite 150 Irvine, CA 92718-3812; Mr. J. C. DeLaney Manager Technical Programs Motorcycle Industry Council Inc. 2 Jenner Street Suite 150 Irvine CA 92718-3812; Dear Mr. DeLaney: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 123, Motorcycle controls and displays. You asked whether a motorcycle side stand complies with Standard No. 123 if the stand passes SAE J1587 Motorcycle Side Stand Retraction Test Procedure. Standard No. 123 specifies at S5.2.4 Stands that: 'A stand shall fold rearward and upward if it contacts the ground when the motorcycle is moving forward.' Neither S5.2.4 nor any other provision of Standard No. 123 incorporates by reference, SAE J1587. Thus, if a motorcycle side stand passes the SAE J1587 test procedure, it does not automatically follow that the side stand complies with Standard No. 123. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack 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.