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: nht71-4.19OpenDATE: 10/13/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Blue Bird Body Company TITLE: FMVSR INTERPRETATION TEXT: In your letter of October 4, 1971, you asked whether under our Certification regulations (49 CFR Part 567) tandem axles should be considered as a unit in listing the gross axle weight rating, or should be listed separately with separate ratings. He intend that each axle, including those part of a tandem arrangement, should be listed separately with a GAWR for each. |
|
ID: nht71-4.2OpenDATE: 08/10/71 FROM: AUTHOR UNAVAILABLE; Charles H. Hartman; NHTSA TO: Ford Motor Company TITLE: FMVSS INTERPRETATION TEXT: In the conference that was held on July 23, 1971, between Ford representatives and National Highway Traffic Safety Administration personnel concerning Standard No. 208, Occupant Crash Protection (memorandum dated July 29, 1971, filed in Docket 69-7), your legal counsel raised a question concerning the National Highway Traffic Safety Administration's position with respect to enforcement of the standard. The question raised was whether this agency would consider a motor vehicle not to conform to the standard if the National Highway Traffic Safety Administration tests showed noncompliance, but the manufacturer's analogous tests showed compliance, and the difference in results were due to the use of slightly different anthropomorphic test devices, with both sets of tests assumed to be run in accordance with the prescribed conditions and procedures of the standard. We agree that the question is an important one and that it may arise, because the complexity of the physical variables in crash testing with anthropomorphic devices makes it difficult if not impossible to refine the standard's specifications to the point where all relevant conditions are specified and all permissible variations eliminated. In a case where tests conducted by the NHTSA show noncompliance with a standard, and the manufacturer's tests, valid on their face, appear to give complying results, the NHTSA conducts an inquiry to determine the reason for the differing results. If, after completing such an inquiry, the NHTSA were to conclude that the difference in results was entirely due to differences in the test devices used by each, and further that the manufacturer's tests, including his test devices, were in complete conformity with the standard, then the agency would not consider that particular series of tests to be the basis for a finding of noncompliance against the manufacturer. I hope that this clarifies the matter for you. |
|
ID: nht71-4.20OpenDATE: 10/14/71 FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA TO: Forse Cleanamation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 29, 1971, to Mr. J. E. Leysath of this Office requesting information relative to the lighting requirements applicable to your E - Z Tow towing unit. The E-Z Tow unit is a "motor vehicle" as defined by the National Traffic and Motor Vehicle Safety Act of 1966 since it is a "vehicle . . . drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways." However, since it is designed to "tow" rather than to "carry" property, the E-Z Tow unit is not a "trailer" as defined for purposes of the Federal Motor Vehicle Safety Standards. Since it is an unclassified "motor vehicle," the lighting requirements of Federal Motor Vehicle Safety Standard No. 108 are not applicable; therefore, you need only to comply with the lighting requirements of the States in which you sell or use the unit. |
|
ID: nht71-4.21OpenDATE: 10/15/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Dow Chemical Europe, S.A. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 24 to Francis Amstrong regarding the effective date of the new Federal motor vehicle brake fluid standard, No. 116. The effective date of March 1, 1972, means that any vehicle manufactured on or after that date for sale in the United States must be equipped with brake fluid meeting Motor Vehicle Safety Standard No. 116. |
|
ID: nht71-4.22OpenDATE: 10/18/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Feldman Engineering and Manufacturing Company Inc. TITLE: FMVSR INTERPRETATION TEXT: The material furnished you by Mr. Peskoe of this office, as listed in your letter of September 28 is complete to date. This will also confirm that the Mini Brute all terrain vehicle is a "motorcycle" for purposes of the Federal motor vehicle safety standards. |
|
ID: nht71-4.23OpenDATE: 10/18/71 FROM: AUTHOR UNAVAILABLE; D. W. Toms; NHTSA TO: Blue Bird Body Company TITLE: FMVSS INTERPRETATION TEXT: Secretary Volpe has asked me to reply to your letter of October 18, 1971, concerning the applicability of the National Traffic and Motor Vehicle Safety Act of 1966 in the territories and possessions of the United States. The Act and the Federal motor vehicle safety standards issued thereunder apply in Puerto Rico, the Virgin Islands, the Canal Zone, Guam, and American Samoa. Motor vehicles, including buses, manufactured for sale and imported into those areas must meet all applicable Federal motor vehicle safety standards. Only one standard applicable to buses, No. 103, Windshield Defrosting and Defogging Systems, specifically does not apply to buses manufactured for sale outside the Continental United States. There are no Federal standards applicable to school bus bodies, so that the wooden bodied buses in American Samoa, of which you spoke, are not prohited by the Act. School buses manufactured for sale in Puerto Rico are required, however, to have a warning light system. I HOPE THIS CLARIFIES THE MATTER FOR YOU. |
|
ID: nht71-4.24OpenDATE: 10/14/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: FWD Corporation TITLE: FMVSS INTERPRETATION TEXT: In response to your letter of September 15, 1971, requesting our interpretation of certain motor vehicle safety standards and regulations: 1. Federal Motor Vehicle Safety Standard No. 208, "Occupant Crash Protection," as amended at 36 F.R. 4600 (March 10, 1971). If trucks over 10,000 pounds CV-R are equipped with a seat belt system as in paragraph S4.3.2, the vehicles need not meet the requirements of paragraphs S5 and S6, which apply only when the complete passive protection system option of paragraph S4.3.1 is adopted. Of course, the seat belt system must conform to the seat belt assembly requirements of Federal Motor Vehicle Safety Standard No. 209, "Seat Belt Assemblies." 2. Federal Motor Vehicle Safety Standard No. 206, "Door Locks and Door Retention Components." Your interpretation of the standard's coverage is correct: there are no requirements in the standard for the installation of the latches and hinges. 3. Part 573, "Defect Reports," S6 F.R. 3064 (February 17, 1971). The National Traffic and Motor Vehicle Safety Act and our regulations do not require manufacturers to repair defective motor vehicles. Manufacturers are therefore free to make whatever arrangements for repair of defects they wish. Of course, we hope that in making such arrangements the manufacturers will assume the responsibility of assuring that the repairs are made properly. |
|
ID: nht71-4.25OpenDATE: 10/19/71 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Truck Equipment & Body Distributors Association TITLE: FMVSS INTERPRETATION TEXT: RE: MOTOR VEHICLE SAFETY STANDARD NO. 108 FOR VEHICLES EQUIPPED WITH SNOW PLOWS I appreciate your letter of September 8 and the concern you express about the effectiveness of the Federal motor vehicle safety program. You have asked for a clarification of the opinion in my letter of August 16 that compliance of a vehicle with the Federal lighting standard, No. 108, would be based upon its "as-sold condition", where the vehicle is equipped with a hoist or mounting bracket and the snow plow, etc., is not sold with the vehicle. This opinion means that compliance with Standard No. 108 is determined without the plow attached even though, to use your hypothetical situation, the purchaser may be invited by the dealer to come back tomorrow and pick up your snow plow so we won't have to put the lights on. The legal responsibility of a dealer under section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act of 1966 is limited to ensuring that the vehicle complies at the time of sale. Section 108(b)(1) of the Act terminates compliance responsibility "after the first purchase of [the vehicle] in good faith for purposes other than resale." For this legal reason there is no violation of the Act if, after sale of the vehicle, the purchaser adds equipment (as in the mounting of a snow plow) or removes equipment (e.g., seat belts, head restraints) affecting compliance with Federal standards. A vehicle equipped with a snow plow, however, would still be subject to State and local motor vehicle safety regulations, "after the first purchase of it in good faith for purposes other than resale." I hope this clarifies the matter for you. |
|
ID: nht71-4.26OpenDATE: 10/21/71 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: British Standards Institution TITLE: FMVSS INTERPRETATION TEXT: Your letter of 4 October 1971 encloses drawings of several seat belt buckle installations that show the locations at which you propose to apply the buckle crash forces specified in Standard No. 209. As to each of the buckles depicted, we consider the force lines to be correctly drawn for purposes of the buckle crash test. Please advise us if we can be of further assistance. |
|
ID: nht71-4.27OpenDATE: 10/22/71 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Utility Trailer Manufacturing Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of September 22 asking for clarification of the requirement for spacing of rear identification lamps on trailers, as applicable to your "change number 21-23." Until January 1, 1972, Table II of Federal Motor Vehicle Safety Standard No. 108 requires that the three-lamp cluster be mounted "as close as practicable to the vertical center line." However, beginning January 1, 1972, the center lamp of the three-lamp cluster must be mounted on the vertical center line, and the offset arrangement in change number 21-23 will no longer meet the requirements of Standard No. 108. |
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.