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: aiam1487OpenMr. P. K. Kamath, Sr. Safety Engineer, Oshkosh Truck Corporation, P.O. Box 560, Oshkosh, WI 54901; Mr. P. K. Kamath Sr. Safety Engineer Oshkosh Truck Corporation P.O. Box 560 Oshkosh WI 54901; Dear Mr. Kamath: This is in reply to your letter of March 27, 1974, in which you as whether a final-stage manufacturer who mounts a used body on a new chassis is required to certify the conformity of the completed vehicle in accordance with 49 CFR Parts 567, 568.; The answer is yes. A person who mounts a used body on a new chassis i a final-stage manufacturer and is required to certify the conformity of the completed vehicle. The NHTSA has interpreted the Certification requirement as applying to any complete vehicle manufactured using a new incomplete vehicle (chassis) whether or not the body to be installed is new or used.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1999OpenMr. Terrell T. Coleman, Codes and Standards Coordinator, Holiday Rambler Corporation, 311 Indiana Avenue, Wakarusa, Indiana 46573; Mr. Terrell T. Coleman Codes and Standards Coordinator Holiday Rambler Corporation 311 Indiana Avenue Wakarusa Indiana 46573; Dear Mr. Coleman: I am writing in response to your letter of June 23, 1975, whic inquired about the status of proposed Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The NHTSA expects to issue Standard No. 120 in the near future. It wil not become effective September 1, 1975. An effective date which allows adequate lead time for manufacturers to prepare for compliance will be specified in a *Federal Register* notice when the rule is issued. Your second question, concerning the responsibility for providing GAWR and GVWR information for motor homes manufactured by you with chassis supplied by other manufacturers, will also be answered in that notice.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1255OpenMr. J. T. Monk, Director of Engineering, Taylor Machine Works, Inc. P.O. Box 150, Louisville, MS 39339; Mr. J. T. Monk Director of Engineering Taylor Machine Works Inc. P.O. Box 150 Louisville MS 39339; Dear Mr. Monk: This is in reply to your letter of August 6, 1973, in which you as whether a sample certification label you enclosed will conform to NHTSA Certification regulations (49 CFR Part 567). We assume from the weight ratings specified in the sample that the trailer is a semitrailer.; As we indicated to you in our letter of June 26, 1973, the regulation do not provide for the listing of inflation pressure with the tire size designation, and the inflation pressure you have included should not appear in its present location on the label. You may, if you wish, include it following all the required information.; Apart from this item, a label similar to that you have submitted affixed in both an appropriate manner and location, will conform to Part 567.; We are happy to have been of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1253OpenMr. J. T. Monk, Director of Engineering, Taylor Machine Works, Inc. P.O. Box 150, Louisville, MS 39339; Mr. J. T. Monk Director of Engineering Taylor Machine Works Inc. P.O. Box 150 Louisville MS 39339; Dear Mr. Monk: This is in reply to your letter of August 6, 1973, in which you as whether a sample certification label you enclosed will conform to NHTSA Certification regulations (49 CFR Part 567). We assume from the weight ratings specified in the sample that the trailer is a semitrailer.; As we indicated to you in our letter of June 26, 1973, the regulation do not provide for the listing of inflation pressure with the tire size designation, and the inflation pressure you have included should not appear in its present location on the label. You may, if you wish, include it following all the required information.; Apart from this item, a label similar to that you have submitted affixed in both an appropriate manner and location, will conform to Part 567.; We are happy to have been of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0889OpenMr. Dwight A. Warren, Personnel Aide - Safety, Personnel Department, 500 Municipal Building, 251 West Washington, Phoenix, AZ 85003; Mr. Dwight A. Warren Personnel Aide - Safety Personnel Department 500 Municipal Building 251 West Washington Phoenix AZ 85003; Dear Mr. Warren: Your letter of September 18, 1972, to our Regional Administrator i Region IX, was referred to this office for a direct reply.; The information you desire is contained in the enclosed copy of Federa Motor Vehicle safety Standard (FMVSS) No. 215, Exterior Protection.; The standard applies to new vehicles manufactured for sale in th United States. It is my understanding that push-bar type bumpers are installed after the vehicles have been purchased from the manufacturer. This type of installation is not in conflict with the requirements of FMVSS No. 215.; Thank you for your interest in motor vehicle safety, and if we can b of further assistance, please let us know.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0328OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co. Ltd., Liaison Office in U.S.A., 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 400 County Avenue Secaucus NJ 07094; Re: Interpretation of Motor Vehicle *Safety Standard No. 101*#Dear Mr Mizuno:#In your letter of April 27 you ask whether it is permissible to use the words 'emergency throttle' to identify the hand throttle which Standard No. 101 requires to be identified by the word 'throttle' alone.#In our opinion the use of identifying words or symbols in addition to those required or permitted by Standard No. 101 is permissible as long as the additional words or symbols do not conflict with those required or permitted. We see no such conflict in this instance and confirm your belief 'that this wording can be used.'#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam4165OpenMr. M. Arisaka, Manager, Automotive Lighting, Engineering Control Department, Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. M. Arisaka Manager Automotive Lighting Engineering Control Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Arisaka: This is in reply to your letter of June 18, 1986, in which you as whether it is permissible to leave an inoperative center high-mounted stop lamp installed in a vehicle when an operative one is mounted on a spoiler at the rear of the car.; We assume that the new lamp fully complies with the requirements o Motor Vehicle Safety Standard No. 108 for center high-mounted stop lamps. Our answer is that it is permissible to leave the inoperative lamp in place since its function has been assumed by a conforming lamp. We have no regulations that would either prohibit or require the removal of an inoperative lamp.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0327OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co. Ltd., Liaison Office in U.S.A., 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 400 County Avenue Secaucus NJ 07094; Re: Interpretation of Motor Vehicle *Safety Standard No. 101*#Dear Mr Mizuno:#In your letter of April 27 you ask whether it is permissible to use the words 'emergency throttle' to identify the hand throttle which Standard No. 101 requires to be identified by the word 'throttle' alone.#In our opinion the use of identifying words or symbols in addition to those required or permitted by Standard No. 101 is permissible as long as the additional words or symbols do not conflict with those required or permitted. We see no such conflict in this instance and confirm your belief 'that this wording can be used.'#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam2912OpenMr. R.W. Fink, AMF Incorporated, 3700 W. Juneau Avenue, P.O. Box 653, Milwaukee, Wisconsin 53201; Mr. R.W. Fink AMF Incorporated 3700 W. Juneau Avenue P.O. Box 653 Milwaukee Wisconsin 53201; Dear Mr. Fink: This is in reply to your letter of November 7, 1978, concerning th lettering permissible under Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your conversation with Mr. Schwartz of my office.; Paragraph S4.3.1 of the standard provides that the type face utilize for the vehicle identification number shall consist of capital, san serif characters. Although the '1' in the 'posident' type face which you propose to use has a slight serif at the top, the type face would still be considered sans serif. Consequently, there is no bar to utilizing 'posident' if you desire.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1287OpenMr. Erik Sundelin, Trelleborgs Gummifabriks Aktiebolag Fack, S-231 01 TRELLEBORG/Sweden; Mr. Erik Sundelin Trelleborgs Gummifabriks Aktiebolag Fack S-231 01 TRELLEBORG/Sweden; Dear Mr. Sundelin: #This is in reply to your letter of August 22, 1973 responding to our reply of June 26, 1973, to your letter of May 28, 1973. We informed you in the June 26 letter that labeling a passenger car tire, 'Max Load 1200 Lbs. At 36 psi,' would not be consistent with Motor Vehicle Safety Standard No. 109 because this label does not make it clear that 36 psi is the maximum permissible inflation pressure. In your letter of August 22 you state that you have already manufactured tires labeled in this manner, and ask whether such tires may be imported into the United States in their present form. #The answer to this question is no. As we have determined that this labeling does not conform to Standard No. 109, the tires in question cannot be imported into the United States unless the labeling is modified to conform the standard. #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.