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: aiam3569OpenMr. J. Mack Shively, Grebe, Gross, Jensen & Peek, P.C., 1530 S.W. Taylor Street, Portland, OR 97205; Mr. J. Mack Shively Grebe Gross Jensen & Peek P.C. 1530 S.W. Taylor Street Portland OR 97205; Dear Mr. Shively: This is in response to your letter of May 11, requesting our views a to the applicability of vehicle identification number requirements and certification label requirements to a semi-trailer to be manufactured by Cranston Diversified Industries. This trailer would have three interchangeable sections.; You are correct in your interpretation of the manner in which ou requirements would be applied to the trailers in question. Only one vehicle identification number and one certification label are required. Affixing the label to the left side of the front section would be consistent with our regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1473OpenMr. Ralph N. Lewis, Perkasie Vulkanising Co., Inc., 1419 Route 309, Sellersville, Pennsylvania 18960; Mr. Ralph N. Lewis Perkasie Vulkanising Co. Inc. 1419 Route 309 Sellersville Pennsylvania 18960; Dear Mr. Lewis: This is in reply to your letter of March 25, 1974, asking whether consistently with Federal Motor Vehicle Safety Standard No. 117, maximum permissible load may be labeled in two lines, viz.: MAXIMUM PERMISSIBLE LOAD XXXXXXXX LBS.; You ask further whether there is a maximum height requirement for th lettering used in the label.; Standard No. 117 does not specify labeling format, and the two-lin format you submit conforms to the standard. Paragraphs S6.3.1 and S6.3.2 of Standard No. 117 require all safety labeling, both permanent and affixed, to be at least 0.078 inches in height. No other requirements regarding labeling size are specified.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3567OpenMr. J. Mack Shively, Grebe, Bross, Jensen & Peek, P.C., 1530 S.W. Taylor Street, Portland, OR 97205; Mr. J. Mack Shively Grebe Bross Jensen & Peek P.C. 1530 S.W. Taylor Street Portland OR 97205; Dear Mr. Shively: This is in response to your letter of May 11, requesting our views a to the applicability of vehicle identification number requirements and certification label requirements to a semi-trailer to be manufactured by Cranston Diversified Industries. This trailer would have three interchangeable sections.; You are correct in your interpretation of the manner in which ou requirements would be applied to the trailers in question. Only one vehicle identification number and one certification label are required. Affixing the label to the left side of the front section would be consistent with our regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3568OpenMr. J. Mack Shively, Grebe, Gross, Jensen & Peek, P.C., 1530 S.W. Taylor Street, Portland, OR 97205; Mr. J. Mack Shively Grebe Gross Jensen & Peek P.C. 1530 S.W. Taylor Street Portland OR 97205; Dear Mr. Shively: This is in response to your letter of May 11, requesting our views a to the applicability of vehicle identification number requirements and certification label requirements to a semi-trailer to be manufactured by Cranston Diversified Industries. This trailer would have three interchangeable sections.; You are correct in your interpretation of the manner in which ou requirements would be applied to the trailers in question. Only one vehicle identification number and one certification label are required. Affixing the label to the left side of the front section would be consistent with our regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0850OpenMr. Larry E. Rhude, Bristol Laminating Corporation, P. O. Box 296, Bristol, IN, 46507; Mr. Larry E. Rhude Bristol Laminating Corporation P. O. Box 296 Bristol IN 46507; Dear Mr. Rhude: This is in reply to your letter of July 5, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to countertop materials used in recreational vehicles.; With regard to the specific components you have listed, sink tops vanity tops, and shelves would be considered 'compartment shelves' under paragraph S4.1 of Standard No. 302, and would therefore be subject to the requirements of the Standard. You are correct in assuming that the material used for countertops would be subject to the requirements of the Standard whenever it is used for the manufacture of components enumerated in S4.1.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2101OpenMr. Dudley E. DeWitt, Great Dane TRailers, Inc., P.O. Box 67, Savannah, Georgia 31402; Mr. Dudley E. DeWitt Great Dane TRailers Inc. P.O. Box 67 Savannah Georgia 31402; Dear Mr. DeWitt: #Please forgive the delay in responding to your lette of March 19, 1975, requesting clarification of the relationship between the masking requirement and the brake hose assembly performance requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #On August 1, 1975, the NHTSA issued a notice delaying until March 1, 1976, the effective date of the masking requirement, in order to allow time for public comment in its proposed elimination. Copies of this and a more recent notice are enclosed. #If the standard is amended to eliminate the masking requirement, the issues which you have raised will be mooted. Otherwise, these issues will be dealt with in an upcoming Federal Register notice. #Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam3359OpenMr. J. Joe Ohashi, Assistant Manager, Kippondenso Sales, Inc., 21840 West Nine Mile Road, Southfield, Michigan 48075; Mr. J. Joe Ohashi Assistant Manager Kippondenso Sales Inc. 21840 West Nine Mile Road Southfield Michigan 48075; Dear Mr. Ohashi: This is in response to your letter of July 30, 1980, to Mr. John W Carson regarding the dimensions of pliers referred to in paragraph S5.1 of Federal Motor Vehicle Safety Standard No. 127, Speedometers and odometers.; The requirements for jaws 25.4mm or less as shown in your sketch o slip joint pliers applies to the dimensions labeled 'R.' The requirement for chain nose pliers with a nose length of 45 mm or less as shown in your sketch applies to dimension 'P.' The enclosed print of slip joint and chain nose pliers clarifies these requirements.; Sincerely, George L. Parker, Chief, Crash Avoidance Division, Vehicl Safety Standards; |
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ID: aiam1302OpenMr. Charles Leeds, Bankers Trust Company, 1775 Broadway, New York, NY 10019; Mr. Charles Leeds Bankers Trust Company 1775 Broadway New York NY 10019; Dear Mr. Leeds: This is in reply to your letter of September 17, 1973, which ask whether a bank must make an odometer disclosure statement upon transfer to an auctioneer of a repossessed vehicle in which the bank has only a security interest.; To the extent that the bank is acting in the place of the repossesse owner, and in the absence of any other party available to make a statement, it is our opinion that the bank is acting as transferor and should make the disclosure specified in Part 580. Normally the bank does not know that the odometer is inaccurate and should only fill in the blank with the recorded mileage. The bank could authorize its collection agency to actually make the disclosure.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1174OpenMr. Edward W. Gaylord, Vice President, Gaylord Products, Inc., 1918 Prairie Avenue, Chicago, IL 60616; Mr. Edward W. Gaylord Vice President Gaylord Products Inc. 1918 Prairie Avenue Chicago IL 60616; Dear Mr. Gaylord: This is in reply to your letter of June 26, 1973, to Mr. Vinson of thi office, enclosing the proposed Panther certification label, and asking whether it conforms to our requirements. The label is arranged as a narrow horizontal strip with two lines of type.; The label contains the required statements in the required order, an thus fulfills the requirements.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1175OpenMr. Edward W. Gaylord, Vice President, Gaylord Products, Inc., 1918 Prairie Avenue, Chicago, IL 60616; Mr. Edward W. Gaylord Vice President Gaylord Products Inc. 1918 Prairie Avenue Chicago IL 60616; Dear Mr. Gaylord: This is in reply to your letter of June 26, 1973, to Mr. Vinson of thi office, enclosing the proposed Panther certification label, and asking whether it conforms to our requirements. The label is arranged as a narrow horizontal strip with two lines of type.; The label contains the required statements in the required order, an thus fulfills the requirements.; Sincerely, 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.