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: aiam0880OpenMr. Ken J. Brown, Product Engineering Manager, Wayne Corporation, Post Office Box 908, Industries Road, Richmond, IN 47374; Mr. Ken J. Brown Product Engineering Manager Wayne Corporation Post Office Box 908 Industries Road Richmond IN 47374; Dear Mr. Brown: This is in response to your request of August 15, 1972, for a interpretation of Standard 217, Bus Window Retention and Release.; It is true that S5.3.2(a)(3) of the standard presently requires maximum torque of 20 inch-pounds. Your discussion of this requirement as it relates to the rotary mechanism you describe has, however, called our attention to a possible problem in the application of the standard. We are presently considering rulemaking to deal with the questions raised, and will notify you of our disposition of the matter. I regret any inconvenience the resultant delay in answering your question may cause you.; Sincerely, Richard B.Dyson, Assistant Chief Counsel |
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ID: aiam1559OpenBayerische Motoren Werke AG,8 Munchen 40,Postf. 40 02 40,Germany; Bayerische Motoren Werke AG 8 Munchen 40 Postf. 40 02 40 Germany; Gentlemen:#This respond's to BMW's June 20, 1974, question whethe 7/16-inch vacuum tubing may be manufactured and sold although it does not appear in Table V of Standard No. 106-74, and if so, what Table V values would be used in testing it.#Table V established test values for vacuum hose but does not limit the vacuum hose sizes which may be manufactured and sold in conformity with the standard. You are free to utilize 7/16- inch vacuum hose, and the Table V test values for 15/32-inch hose should be used to test 7/16-inch hose.#We are considering the addition of an entry in Table V to cover 7/16-inch hose in the near future.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam1771OpenMr. Paul Utans, 55 Concord Street, Englewood, New Jersey 07631; Mr. Paul Utans 55 Concord Street Englewood New Jersey 07631; Dear Mr. Utans: This is in reply to your letter of January 7, 1975, asking whether Teves brake fluid container label that you enclosed conforms to paragraph S5.2.2.2 of Motor Vehicle Safety Standard No. 116.; With the exceptions noted in your letter (packaged lot identification and date of packing) the label meets our requirements.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2957OpenS. B. Aronson, Pennsylvania Notaries, 625 Stanwix Street, Pittsburgh, PA 15222; S. B. Aronson Pennsylvania Notaries 625 Stanwix Street Pittsburgh PA 15222; Dear Mr. Aronson: This is in response to your letter of January 4, 1979, requesting ou opinion as to whether a rubber stamp which contains the odometer information on the newest Pennsylvania title could be applied to older titles in lieu of having a separate form attached.; There are no legal bars to your recommendation. In fact, the stamp yo recommend makes more sense than a separate form. A separate form can be removed and replaced with another sheet. A stamp cannot be so abused.; We appreciate and support your recommendation. Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam1205OpenMr. Ralph Nader, Mr. Carl E. Nash, 1719 - 19th Street, N.W., Washington, DC 20036; Mr. Ralph Nader Mr. Carl E. Nash 1719 - 19th Street N.W. Washington DC 20036; Dear Messrs. Nader and Nash: This is to acknowledge your letter of July 23, 1973, in which yo protested against the categorization of the Volkswagen 'Thing' as a multipurpose passenger vehicle.; In light of the information you have provided, I have asked my peopl to review the situation and, as soon as they have presented their views to me for my consideration, I will be back in touch with you.; I certainly appreciate your bringing this matter to my attention. Sincerely, James B. Gregory, Administrator |
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ID: aiam0717OpenMr. Harry Fund, Executive Vice-President, Labelmaster, 2447 W. Roosevelt Road, Chicago, Illinois 60608; Mr. Harry Fund Executive Vice-President Labelmaster 2447 W. Roosevelt Road Chicago Illinois 60608; Dear Mr. Fund: This is in response to your letter of May 11, 1972, submitting sampl labels for retreaded tires, the samples which you submit, with the appropriate information properly filled in or clearly indicated by an 'X' or other mark, will meet the requirements of S6.2 and S6.3 of Standard No. 117.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1488OpenPeter J. Pitchess, Sheriff, County of Los Angeles, Office of the Sheriff, Hall of Justice, Los Angeles, CA 90012; Peter J. Pitchess Sheriff County of Los Angeles Office of the Sheriff Hall of Justice Los Angeles CA 90012; Dear Mr. Pitchess: This is in response to your letter of May 2, 1974, requesting th results of the public hearing concerning safety standards for police vehicles held on December 10, 1973, and your petition in this regard.; As you know, that hearing was held in conjunction with an advanc notice of proposed rulemaking issued by this agency. We are in the final stage of analysis of both the public hearing and the comments in response to the advance notice, and will issue our conclusions in the near future. In the interim, all Federal Safety Standards continue to be applicable to police vehicles although you remain free to alter your vehicles after they are delivered to you.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3714OpenMr. Louis Gaia, V.P. Purchasing, Ezon Products, Inc., P.O. Box 18134, Memphis, TN 38118; Mr. Louis Gaia V.P. Purchasing Ezon Products Inc. P.O. Box 18134 Memphis TN 38118; Dear Mr. Gaia: In your letter of June 2, 1983, to the Office of Chief Counsel, yo asked if there were 'any D.O.T. requirements on miniature bulbs?'; We understand your question to refer to bulbs used in lighting device other than headlamps. Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, imposes no performance requirements on individual bulbs used in lighting devices other than those used in replaceable bulb headlamps (an option permissible as of July 1, 1983). Other lighting devices must meet the photometric requirements of the standard with the bulb, chosen by the lighting device manufacturer, installed.; I hope that this answers your question. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0836OpenMr. Jerome G. Abeles, Director, Product Planning & Purchasing, Sealy, Incorporated, 666 North Lake Shore Drive, Chicago, IL, 60611; Mr. Jerome G. Abeles Director Product Planning & Purchasing Sealy Incorporated 666 North Lake Shore Drive Chicago IL 60611; Dear Mr. Abeles: This is in reply to your letter of August 10, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to mattress assemblies.; Paragraph S4.1 of the Standard lists mattress covers only. This doe not include the complete mattress assembly. Accordingly, you are correct in your assumption that only the mattress covers must meet the burn rate requirement of Paragraph S4.3. You are also correct in your assumption that mattress assemblies which are not designed to absorb energy on contact with occupants in crash situations are not subject to the Standard.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1599OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West, Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your letter of August 12, 1974, inquiring as t whether or not a vehicle with unitized construction, developed as a truck and converted to carry passengers may be classified as a multipurpose passenger vehicle.; Your description of the vehicle in question indicates that it doe qualify as a multipurpose passenger vehicle. The reference to 'truck chassis' in the MPV definition was intended to include vehicles that were designed and developed as trucks but have been produced in a version for carrying passengers. Since the delivery van referenced in your letter was developed as a truck, its modification to enable the carrying of passengers places it in the MPV category.; 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.