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: aiam5105OpenMr. Daniel K. Upham President Sys Tek Corporation 444 N. Zachary, Suite 111 Moorpark, CA 93021; Mr. Daniel K. Upham President Sys Tek Corporation 444 N. Zachary Suite 111 Moorpark CA 93021; "Dear Mr. Upham: This responds to your letter of December 9, 1992, wit respect to whether a 'portable lighted message display using L.E.D. technology' is permissible under Federal law. The product would be sold in the aftermarket. As you indicate, ' i t will be either battery powered or it will be powered using the vehicle power source via cigarette lighter or directly to the car's electrical harness.' It will be installed in either the side rear or rear window. We assume that battery-powered devices, and those activated through the cigarette lighter, are so simple that the vehicle owner can install and use the device without resorting to the assistance of others. Under this circumstance, there is no restriction that applies to this device under the laws administered by this agency. Nevertheless, the device may be subject to restrictions imposed by a State in which it is operated. However, if attaching the device to the car's electrical harness is a task that may be performed by a person other than the vehicle owner, a different consideration applies. A manufacturer, dealer, distributor, or motor vehicle repair business may not install the device if it renders inoperative, in whole or in part, any device or element of design installed in accordance with a Federal motor vehicle safety standard. Examples of equipment added pursuant to a Federal standard and that could be affected by the sign board are the stop lamps, both center highmounted and conventional, and the inside rear view mirror. I enclose a copy of an interpretation of the agency dated August 17, 1989, to Mr. Alan S. Eldahr, and call your attention to our views on impairment by message boards expressed on the second page. This letter also provides the address of an organization that you may consult on applicable State laws. Installation of the message board in a side rear window by a manufacturer, distributor, dealer, or motor vehicle repair business would appear permissible. The only required side lighting equipment are front and rear lamps and reflectors, intended to mark the extremities of the vehicles, and we do not believe that their function would be negatively affected by installation of the message board. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam2264OpenMr. G. E. Adams, Technical Manager, Dunlop Limited, Engineering Group, Holbrook Lane Coventry CV6 4AA, England; Mr. G. E. Adams Technical Manager Dunlop Limited Engineering Group Holbrook Lane Coventry CV6 4AA England; Dear Mr. Adams: This is in response to your letter of March 17, 1976, requestin information concerning steps which you, as a manufacturer of wheel equipment which will be offered for importation into the United States, must take in order to comply with all applicable National Highway Traffic Safety Administration regulations.; You should be aware of 49 CFR Part 566, *Manufacturer Identification* and 49 CFR Part 573, *Defect Reports*. In addition, Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars*, may be of interest to you. Copies of these rules and an information sheet entitled 'Where to Obtain Federal Motor Vehicle Safety Standards and Regulations' are enclosed for your convenience.; Section 110(e) of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S 1399(e)) requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United States as his agent, upon whom service of all processes, orders, notices, decisions, and requirements may be made.; The procedural regulations (49 CFR 551.45) for designation of agen pursuant to the Act require that it include:; >>>(1) A certification by its maker that the designation is binding o Dunlop Limited 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 mailin address of Dunlop Limited,; (3) Trade names or other designations of origin of the products o Dunlop Limited that do not bear its legal name,; (4) A provision that the designation of agent remain in effect unti withdrawn or replaced by Dunlop Limited,; (5) A declaration of acceptance duly signed by the agent appointed which may be an individual, a firm, or a U.S. corporation, and; (6) The full legal name and address of the designated agent.<<< A copy of the procedural regulation for designation of agent i enclosed for your convenience.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2175OpenMr. R. D. Coughlin, Vice President, Rol'on America, Inc., Melbourne, FL 32901; Mr. R. D. Coughlin Vice President Rol'on America Inc. Melbourne FL 32901; Dear Mr. Coughlin: This is in response to your letter of December 10, 1975, regarding th applicability of existing Federal regulations to the manufacture of 'Helmate.'; At the present time, there is no regulation pertaining directly to th type of helmet accessory your corporation produces. The general regulation concerning motorcycle helmets is 49 CFR S 571.218, Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets*. This standard establishes minimum performance requirements for helmets designed for use by motorcyclists and other motor vehicle users.; If a manufacturer, distributor, dealer, or motor vehicle repai business were to install 'Helmates' on helmets, the helmets would have to remain in conformity with the requirements of Standard 218. However, persons other than manufacturers, distributors, dealers, and repair businesses may modify products, after purchase by a user, without regard to the requirements of a Federal safety regulation. Thus, if 'Helmate' is mounted on the helmet by an ordinary consumer, safety Standard 218 is inapplicable.; There is some question as to whether motorcycle helmets will still mee the performance requirements of Standard 218, after the 3/8 inch hole required to mount the 'Helmate' is drilled. If it becomes apparent that installing 'Helmate' type helmet accessories causes the performance level of helmets to drop below the requirements of Standard 218, the NHTSA might find it necessary to enact regulations to rectify the situation. Our main concern is to assure that motorcycle helmets afford riders the protection and safety needed.; If I can be of any further assistance, please feel free to write. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2174OpenMr. R. D. Coughlin, Vice President, Rol'on America, Inc., Melbourne, FL 32901; Mr. R. D. Coughlin Vice President Rol'on America Inc. Melbourne FL 32901; Dear Mr. Coughlin: This is in response to your letter of December 10, 1975, regarding th applicability of existing Federal regulations to the manufacture of 'Helmate.'; At the present time, there is no regulation pertaining directly to th type of helmet accessory your corporation produces. The general regulation concerning motorcycle helmets is 49 CFR S 571.218, Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets*. This standard establishes minimum performance requirements for helmets designed for use by motorcyclists and other motor vehicle users.; If a manufacturer, distributor, dealer, or motor vehicle repai business were to install 'Helmates' on helmets, the helmets would have to remain in conformity with the requirements of Standard 218. However, persons other than manufacturers, distributors, dealers, and repair businesses may modify products, after purchase by a user, without regard to the requirements of a Federal safety regulation. Thus, if 'Helmate' is mounted on the helmet by an ordinary consumer, safety Standard 218 is inapplicable.; There is some question as to whether motorcycle helmets will still mee the performance requirements of Standard 218, after the 3/8 inch hole required to mount the 'Helmate' is drilled. If it becomes apparent that installing 'Helmate' type helmet accessories causes the performance level of helmets to drop below the requirements of Standard 218, the NHTSA might find it necessary to enact regulations to rectify the situation. Our main concern is to assure that motorcycle helmets afford riders the protection and safety needed.; If I can be of any further assistance, please feel free to write. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0690OpenMr. J. Hunter, Deputy Group Chief Technologist, British Vita Company Limited, Middleton, Manchester, England; Mr. J. Hunter Deputy Group Chief Technologist British Vita Company Limited Middleton Manchester England; Dear Mr. Hunter: This is in reply to your letter of April 14, 1972, requesting a interpretation as to how 'Cavitex Latex Foam' should be tested for conformity to Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You enclose two drawings illustrating this material, which show that the 14 x 4-inch specimen will contain cavities running from the underside of the material to within 1/2- inch from the top surface of the material. You ask whether the sample to be used for testing pursuant to S5.2.1 of the standard should be cut from the top or bottom of the specimen, and which side of the sample should be exposed to the flame. Your letter indicates that the side of the cushion containing the cavity openings faces the floor of the vehicle, and a continuous flat surface faces the occupant compartment.; We will consider you to have followed the test procedure of S5. of th standard if the 1/2- inch thick test sample is cut from that part of the material nearest to the occupant compartment, and if the surface of that sample exposed to the flame is that which is also closest to the occupant compartment. According to your drawings, you should therefore test a specimen cut from the 'upper face' of the material with the flat surface of that specimen exposed to the flame in the test cabinet.; We thank you for your compliments. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2694OpenMr. Charles W. Jarvis, Secretary, Ford Garage Company, Inc., 109 Warren Street, Glens Falls, NY 12801; Mr. Charles W. Jarvis Secretary Ford Garage Company Inc. 109 Warren Street Glens Falls NY 12801; Dear Mr. Jarvis: This responds to your September 27, 1977, letter asking whether a 1 passenger vehicle designed to transport children to and from a Y.M.C.A. recreation facility would be required to comply with the new Federal school bus safety standards.; The Federal school bus safety standards promulgated under the Moto Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L. 92-492) apply to motor vehicles transporting 10 or more passengers to and from school or related events. The National Highway Traffic Safety Administration (NHTSA) has tentatively concluded that facilities such as Y.M.C.A.s may not have been aware that school bus safety standards might be applicable to vehicles manufactured to transport children to and from these facilities. Accordingly, the agency has temporarily exempted from the requirements buses designed for use by such facilities.; You should note that the NHTSA plans to commence rulemaking that migh require buses used for activities such as those described to comply with the Federal school bus safety standards. The extended application of the standards would only affect buses manufactured after the effective date of the rulemaking action.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4004OpenMr. Larry J. Black, Motorists Insurance Companies, 471 East Broad Street, Columbus, OH 43215-3861; Mr. Larry J. Black Motorists Insurance Companies 471 East Broad Street Columbus OH 43215-3861; Dear Mr. Black: This is in response to your letter of August 2, 1985, in which yo asked for a determination from the Agency concerning your company's use of Motor Vehicle titles to fulfill Federal odometer disclosure requirements.; You proposed photocopying the title, which has the odometer disclosur on the back, and retaining the copy for a four year period. The applicable Federal regulation, 49 CFR Part 580, provides that State titles or other ownership documents may be used as substitutes for the Federal odometer disclosure statement if they contain essentially the same information required by paragraphs (a),(b),(c) and (e) of section 580.4.; I have reviewed State titles contained within *The Original Peck' Title Book*. This book, published by Stephens - Peck, Inc., is revised periodically and supplemented as changes in State title laws occur. To date, the title documents of the following States may be used in lieu of a separate odometer disclosure form:; >>>Delaware, Maryland, Michigan, Minnesota, Nebraska, North Carolina North Dakota, Ohio, Pennsylvania, South Dakota, Virginia, Wyoming<<<; I must qualify this list, however. With regard to the Michigan an Minnesota titles, it is only the initial assignment which meets all disclosure requirements. Reassignments by a licensed dealer do not, as there is no space for the purchaser's signature. Furthermore, when vehicles are transferred in Delaware, Maryland, Nebraska, North Dakota, Ohio, Pennsylvania, Wyoming or Virginia, the title can be used in lieu of a separate odometer disclosure statement only if the purchaser completes all information concerning the application for title. Unless the application is completed, the title will not include the buyer's signature. The National Highway Traffic Safety Administration considers this signature to be essential, because it is an acknowledgement that the purchaser is aware of the mileage. The signature prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title.; If you have any additional questions, do not hesitate to contact Judit Kaleta of my staff at (202) 426-1834.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam0079OpenMr. L. P. Knipe, Vice President - Sales, Ultra, Inc., 101 West Fifth, Hutchinson, KS 67501; Mr. L. P. Knipe Vice President - Sales Ultra Inc. 101 West Fifth Hutchinson KS 67501; Dear Mr. Knipe: Thank you for your letter of February 27, 1968, concernin certification of the Ultra Van Motorhome as a multipurpose vehicle. An examination of the information submitted indicates that the Ultra Van Motorhome would properly be classified as a multipurpose passenger vehicle within the definition contained in Section 255.3(b) 23 CFR, Initial Federal Motor Vehicle Safety Standards.; Section 114 of the National Traffic and Motor Vehicle Safety Act o 1966 requires every manufacturer of a motor vehicle or motor vehicle equipment to furnish certification of compliance with applicable standards. Details of certification were published as a Federal Register, Vol. 32, No. 215 on November 4, 1967. Your attention is invited to the enclosed copies of these documents and the Federal Motor Vehicle Safety Standards.; We trust we have been of assistance to you. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam5378OpenMr. J. L. Steffy Triumph Designs Ltd. Jacknell Road Dodwells Bridge Industrial Estate Hinckley, Leics. LE10 3BS England; Mr. J. L. Steffy Triumph Designs Ltd. Jacknell Road Dodwells Bridge Industrial Estate Hinckley Leics. LE10 3BS England; Dear Mr. Steffy: This responds to your FAX of May 5, 1994, to Taylo Vinson of this Office, requesting an interpretation of Motor Vehicle Safety Standard No. 108. You describe a motorcycle lamp 'which comprises a headlight with high and low beams and 2 symmetrically (sic) flanking front auxillary (sic) lamps possessing low beam (sic) that augment the headlight.' You ask for our comments. Paragraph S5.1.3 of Standard No. 108 permits auxiliary lighting equipment provided that it does not impair the effectiveness of the lighting equipment that is required by Standard No. 108. The vehicle manufacturer's certification of compliance with Standard No. 108 includes certification to S5.1.3 and represents its determination that the supplementary equipment does not impair the effectiveness of other lighting equipment. Unless that determination appears clearly erroneous, NHTSA will not question it. Your letter contains too little information for us to comment further. For example, we do not know whether the candela of the auxiliary lower beam lamps is higher, lower, or the same as the main lower beam of the headlamp. Nor does the letter indicate whether the supplementary lower beam lamps are extinguished when the upper beam is activated. If you have further questions, we shall be pleased to answer them. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1386OpenMiss Charlotte D. Myers, W. E. Myers Estate, Petroleum Equipment, 177 Ferguson Avenue, Burlington, VT 05401; Miss Charlotte D. Myers W. E. Myers Estate Petroleum Equipment 177 Ferguson Avenue Burlington VT 05401; Dear Miss Myers: Your request for information concerning the transfer of cargo tank from one chassis to another has been brought to our attention by the Bureau of Motor Carrier Safety.; The National Traffic and Motor Vehicle Safety Act requires that a labe certifying the compliance of motor vehicles to all applicable safety standards be affixed to a vehicle by its manufacturer. Certification regulations enacted pursuant to the mandate of the Act require the final-stage manufacturer to provide the certification of the vehicle with all applicable standards, based on information concerning the conformity of the chassis furnished by the chassis manufacturer pursuant to our regulations. This means that cargo tank manufacturers who install the tanks on the chassis and so complete the vehicle must certify it as a finished product.; Responding to your specific question, the action of transferring cargo tank from one chassis to another would require a label certifying that the vehicle complies with all applicable safety standards if the chassis was new and had not yet been purchased for purposes other than resale. If the chassis was one which had already been purchased for purposes other than resale, there would be no obligation to recertify the compliance of the vehicle.; 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.