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: aiam0537OpenMr. Bruce K. Thomas, Harbaugh and Thomas, State National Bank and Plaza, 1603 Orrington Avenue, Evanston, Illinois 60201; Mr. Bruce K. Thomas Harbaugh and Thomas State National Bank and Plaza 1603 Orrington Avenue Evanston Illinois 60201; Dear Mr. Thomas: This is in response to your letter of October 11, 1972, as to th status of your petition for amendment of Standard 125, Warning Devices, of April 28, 1972. A notice dealing with a number of petitions for reconsideration of Standard 125, including your request regarding the fluorescent material, is presently in preparation, and will be published shortly.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2845OpenMr. Martin P. Ronsen, President, Euro-Tire, Inc., 1275 Bloomfield Avenue, Fairfield, NJ 07006; Mr. Martin P. Ronsen President Euro-Tire Inc. 1275 Bloomfield Avenue Fairfield NJ 07006; Dear Mr. Ronsen: This responds to your June 1, 1978, letter asking whether it i acceptable for you as a tire distributor to use your own tire registration form as long as it complies with the requirements of Part 574, *Tire Identification and Recordkeeping*.; Part 574.7 of the Code of Federal Regulations (CFR) provides that dealer of tires may supply his own form on which to record information specified in paragraphs (a)(1), (a)(2) and (a)(3), as long as the form contains the required information, conforms in size and is similar in format to the 'Universal Format' form set forth in Figure 3 of that part. The form designed by Euro-Tire appears to meet the requirements of Part 574. Accordingly, it is acceptable for use in fulfilling the tire recordkeeping requirements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam2076OpenMr. Douglas S. McClenahan, President, Charter Arms Corporation, 430 Sniffens Lane, Stratford, CT 06497; Mr. Douglas S. McClenahan President Charter Arms Corporation 430 Sniffens Lane Stratford CT 06497; Dear Mr. McClenahan: This is in response to your letter of September 16, 1975, inquirin whether approval from the Federal Government is necessary before selling motorcycles manufactured by you.; No approval is necessary in order to market your motorcycles. However you should be aware of the regulations governing manufacturer identification and vehicle certification. Each manufacturer who begins to manufacture motor vehicles must submit certain information to the National Highway Traffic Safety Administration describing the type of motor vehicle manufactured (49 CFR Part 566, copy enclosed). In addition, each vehicle must be certified as being in compliance with all applicable Federal Motor Vehicle Safety Standards in effect at the time of manufacture (49 CFR Part 567, copy enclosed).; If you have any further questions, please contact us. Sincerely, Frank A. Berndt, Acting Chief Counsel |
|
ID: aiam0785OpenMr. Philip Ralston, Aero Precision Inc., 3608 Stone Avenue, Colorado Springs, CO 80907; Mr. Philip Ralston Aero Precision Inc. 3608 Stone Avenue Colorado Springs CO 80907; Dear Mr. Ralston: This is in reply to your letter of July 5, 1972, concerning th applicability of Standard No. 215, Exterior Protection, to the bumpers you manufacture for pickup trucks.; Standard No. 215 does not apply to vehicles other than passenger cars so that pickup trucks equipped with your bumper would not have to conform.; We do not have the facilities to conduct product evaluation tests o the type you have in mind. We are enclosing a copy of the standard, however, for your review. The test procedures are set out in sections S6 and S7.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0550OpenMr. William S. Magenau, President, Chespeake Marine Products, Route 256, Deale, MD 20751; Mr. William S. Magenau President Chespeake Marine Products Route 256 Deale MD 20751; Dear Mr. Magenau: In your letter of September 21, 1972, you ask, 'are there any 'partia built' certification standards which would govern our operation as a boat trailer distributor?'; I enclose a copy of 49 CFR Part 567, *Certification*, and Part 568 *Vehicles Manufactured in Two or More Stages*, for your review as to their applicability to your operations. They apply to manufacturers who initiate or complete the manufacture of motor vehicles. They do not, however, impose an obligation upon a distributor of boat trailers who does not alter the vehicles he receives from a manufacture in a manner that affects compliance with applicable standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0214OpenMr. C. J. Newman, Director of Engineering, The Grote Manufacturing Company, State Route 7, P. O. Box 766 N. M. S., Madison, IN 47250; Mr. C. J. Newman Director of Engineering The Grote Manufacturing Company State Route 7 P. O. Box 766 N. M. S. Madison IN 47250; Dear Mr. Newman: Thank you for your letter of February 19, 1970, to Mr. Julian E Leysath of this Office asking for suggestions on lighting equipment for a trailer manufactured by Toter, Inc.; This will confirm your understanding that the Toter is considered trailer under the Federal Motor Vehicle Safety Standards, and not a dolly. Since the manufacturer is responsible for compliance with Federal Standard No. 108 (Lamps, Reflective Devices, and Associated Equipment) I am unable to provide specific suggestions or recommendations for lighting the vehicle in question.; Sincerely, Rodolfo A. Diaz, Acting Director, Motor Vehicle Safet Performance Service; |
|
ID: aiam0544OpenMr. William S. Magenau, President, Chespeake Marine Products, Route 256, Deale, MD 20751; Mr. William S. Magenau President Chespeake Marine Products Route 256 Deale MD 20751; Dear Mr. Magenau: In your letter of September 21, 1972, you ask, 'are there any 'partia built' certification standards which would govern our operation as a boat trailer distributor?'; I enclose a copy of 49 CFR Part 567, *Certification*, and Part 568 *Vehicles Manufactured in Two or More Stages*, for your review as to their applicability to your operations. They apply to manufacturers who initiate or complete the manufacture of motor vehicles. They do not, however, impose an obligation upon a distributor of boat trailers who does not alter the vehicles he receives from a manufacture in a manner that affects compliance with applicable standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0751OpenMr. Barry Kulik, 114 West 30th Street, New York, NY 10001; Mr. Barry Kulik 114 West 30th Street New York NY 10001; Dear Mr. Kulik: This is in reply to your letter of May 14, 1972, to Mr. Armstron asking whether combination turn signal and hazard warning signal flashers conforming to Federal requirements effective January 1, 1973, may be installed in vehicles manufactured before that date.; The answer is yes. Motor Vehicle Safety Standard No. 108 was amended o December 28, 1971 to allow use of flashers manufactured to conform with Standard No. 108a. I enclose a copy of the amendment for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1146OpenMr. Louis C. Lundstrom,Executive Director,Environmental Activities Staff,General Motors Corporation,General Motors Technical Center,Warren, Michigan 48090; Mr. Louis C. Lundstrom Executive Director Environmental Activities Staff General Motors Corporation General Motors Technical Center Warren Michigan 48090; Dear Mr. Lundstrom:#This is in reply to your letter of may 11, 1973 asking for confirmation of your interpretation of paragraph S7.9 of Standard No. 105a in term of General Motors' air vacuum power brake.#Your interpretation is correct. Your system with its 'two separate and independent energy sources in the power head...is equivalents to two entirely duplicate systems', and disconnection of one source at a time would be the correct test procedure under S7.9, provided the requirements of S5.1.3 are satisfactorily met under both conditions.#Sincerely,James E. Wilson,Associate Administrator,Traffic Safety Programs; |
|
ID: aiam0452OpenMr. K. Nakajima, General Manager, Toyota Motor Company, Ltd., Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, NJ, 07071; Mr. K. Nakajima General Manager Toyota Motor Company Ltd. Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: In response to your letter of September 28, 1971, regarding th application of F.M.V.S.S. No. 302, 'Flammability of Interior Materials', to items which are not designed to be energy absorbing, such as the defroster nozzle and hose or the transmission shift lever boot, the Administration has found that your interpretation of the standard is correct: the phrase 'any other interior material' in paragraph S4.1 does not cover components of the occupant compartment which are not designed to absorb energy on contact with occupants in crash situations.; Sincerely, Lawrence R. Schneider, 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.