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: aiam1075OpenMr. John White, Michelin Tire Corporation, Technical Division, 2500 Marcus Avenue, Lake Success, NY 11040; Mr. John White Michelin Tire Corporation Technical Division 2500 Marcus Avenue Lake Success NY 11040; Dear Mr. White: This is to confirm your conversation with Mr. Schmeltzer of this offic in which he informed you that the Regrooved Tire regulation (49 CFR Part 569) does not prohibit the use of branding to meet its labeling requirements. the language in section 569.9 which requires the word 'regroovable' to be 'molded into or onto' tires designed for regrooving was intended to include any method, such as branding, that would leave the required information sunk into or raised upon the tire surface.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3573OpenMr. Jeff Wimer, P.O. Box 152, Auburn, IN 46706; Mr. Jeff Wimer P.O. Box 152 Auburn IN 46706; Dear Mr. Wimer: This responds to your phone request of June 11, 1982, concernin Federal motor vehicle safety standards that apply to motorcycle sidecars sold as aftermarket motor vehicle equipment.; While there are no 'sidecar' standards, certain of the items o equipment that may be found in sidecars are covered by Federal equipment safety standards. Specifically, brake hoses, lighting equipment, tires, rims, and glazing materials (if provided) would have to comply with Standards Nos. 106, 108, 119, 120 and 205. I have enclosed an information sheet explaining how you can obtain copies of the agency's safety standards.; Because a sidecar itself is an item of motor vehicle equipment, th manufacturer of any sidecar sold in the aftermarket would be responsible for notification and remedy in the event the product was determined to contain a safety-related defect.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3570OpenMr. Jeff Wimer, P.O. Box 152, Auburn, IN 46706; Mr. Jeff Wimer P.O. Box 152 Auburn IN 46706; Dear Mr. Wimer:#This responds to your phone request of June 11, 1982 concerning Federal motor vehicle safety standards that apply to motorcycle sidecars sold as aftermarket motor vehicle equipment.#While there are no 'sidecar' standards, certain of the items of equipment that may be found in sidecars are covered by Federal equipment safety standards. Specifically, brake hoses, lighting equipment, tires, rims, and glazing materials (if provided) would have to comply with Standards Nos. 106, 108, 119, 120 and 205. I have enclosed an information sheet explaining how you can obtain copies of the agency's safety standards.#Because a sidecar itself is an item of motor vehicle equipment, the manufacturer of any sidecar sold in the aftermarket would be responsible for notification and remedy in the event the product was determined to contain a safety-related defect.#If you have any further questions, please let me know.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam3571OpenMr. Jeff Wimer, P.O. Box 152, Auburn, IN 46706; Mr. Jeff Wimer P.O. Box 152 Auburn IN 46706; Dear Mr. Wimer: This responds to your phone request of June 11, 1982, concernin Federal motor vehicle safety standards that apply to motorcycle sidecars sold as aftermarket motor vehicle equipment.; While there are no 'sidecar' standards, certain of the items o equipment that may be found in sidecars are covered by Federal equipment safety standards. Specifically, brake hoses, lighting equipment, tires, rims, and glazing materials (if provided) would have to comply with Standards Nos. 106, 108, 119, 120 and 205. I have enclosed an information sheet explaining how you can obtain copies of the agency's safety standards.; Because a sidecar itself is an item of motor vehicle equipment, th manufacturer of any sidecar sold in the aftermarket would be responsible for notification and remedy in the event the product was determined to contain a safety-related defect.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3572OpenMr. Jeff Wimer, P.O. Box 152, Auburn, IN 46706; Mr. Jeff Wimer P.O. Box 152 Auburn IN 46706; Dear Mr. Wimer: This responds to your phone request of June 11, 1982, concernin Federal motor vehicle safety standards that apply to motorcycle sidecars sold as aftermarket motor vehicle equipment.; While there are no 'sidecar' standards, certain of the items o equipment that may be found in sidecars are covered by Federal equipment safety standards. Specifically, brake hoses, lighting equipment, tires, rims, and glazing materials (if provided) would have to comply with Standards Nos. 106, 108, 119, 120 and 205. I have enclosed an information sheet explaining how you can obtain copies of the agency's safety standards.; Because a sidecar itself is an item of motor vehicle equipment, th manufacturer of any sidecar sold in the aftermarket would be responsible for notification and remedy in the event the product was determined to contain a safety-related defect.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1465OpenMr. Robert E. Langdon III, 2511 West 7th Street, Los Angeles, California 90057; Mr. Robert E. Langdon III 2511 West 7th Street Los Angeles California 90057; Dear Mr. Langdon: This is in reply to your letter of April 12, 1974, asking whethe retreaded tires are required by Motor Vehicle Safety Standard No. 117 to have either a ribbed tread pattern or treadwear indicators.; Standard No. 117 does not have requirements for tread pattern design and thus retreaded tires need not have a ribbed tread design. Each retreaded tire must, however, in accordance with S5.1.1(b) of Standard No. 117, incorporate a treadwear indicator that will provide a visual indication that the tire has worn to a tread depth of 1/16 inch.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2426OpenMs. Valerie Hood, Triplex Safety Glass Co., Eckersall Road Kings Norton, Birmingham B38 8SR, England; Ms. Valerie Hood Triplex Safety Glass Co. Eckersall Road Kings Norton Birmingham B38 8SR England; Dear Ms. Hood: This is in response to your September 8, 1976, letter requestin information concerning the Federal regulations that would be applicable to safety glazing for use in 'slow moving' vehicles. Please excuse our delay in answering your questions. Apparently, your earlier letter of February 5, 1976, was misplaced.; Standard No. 205, *Glazing Materials*, specifies requirements fo glazing materials for use in most motor vehicles and motor vehicle equipment. A glazing manufacturer must certify any glazing that is to be used in a motor vehicle (other than a trailer) as being in compliance with Standard No. 205. 'Motor vehicle' is defined in S 102(3) of the National Traffic and Motor Vehicle Safety Act of 1966. I am enclosing a copy of the agency's opinion of what vehicles qualify as 'motor vehicles' under the definition. Glazing material that is to be used in a vehicle that does not qualify as a 'motor vehicle' does not have to meet the performance requirements of Standard No. 205.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0901OpenMrs. Katherine C. Little, Edgewood Motorcycle Shop, 1711 Pulaski Highway, Edgewood, MD 21040; Mrs. Katherine C. Little Edgewood Motorcycle Shop 1711 Pulaski Highway Edgewood MD 21040; Dear Mrs. Little: This is in reply to your letters of October 10 and 25, 1972, askin whether motorcycle tires designed exclusively for hill climbing or other off-highway use are required to be registered in accordance with NHTSA Tire Identification and Recordkeeping regulations (49 CFR Part 574).; We do not consider the regulations to require such tires to b registered. The NHTSA has determined that motor vehicle tires designed and manufactured exclusively for off-road use are not subject to the Tire Identification requirements.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2414OpenHonorable Leonor K. Sullivan, House of Representatives, Washington, DC 20515; Honorable Leonor K. Sullivan House of Representatives Washington DC 20515; Dear Mrs. Sullivan: This is in response to your September 20, 1976, letter concernin record keeping with respect to new passenger cars that are damaged prior to retail sale.; I would like to clarify the discussion of record requirements in m September 14, 1976, letter to you. While the National Highway Traffic Safety Administration (NHTSA) does not require vehicle manufacturers to create records of safety-related repairs that are made to new motor vehicles prior to sale, we do require the *retention* of all such records that are in fact created by the manufacturer. Through such records, the NHTSA can in many cases trace the history of vehicles suspected of containing safety- related defects. We have not to date found a safety need sufficient to justify further requirements specifically regarding identification of the vehicles in question.; A copy of the record retention regulation, 49 CFR Part 576, is enclose for your convenience.; Sincerely, John W. Snow, Administrator |
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ID: aiam0719OpenMr. H. Foegelle, 420 No. Sacramento Street, Super Mold, Inc., Lodi, CA 95240; Mr. H. Foegelle 420 No. Sacramento Street Super Mold Inc. Lodi CA 95240; Dear Mr. Foegelle: This is in reply to your phone call of June 6, 1972. Under Part 574 the tire identification number may be placed on the side of the top cap area or may be branded into the tire in accordance with the regulation. If the top cap area is used, the number should be as close to the side-wall as is feasible so that the number will remain legible as long as possible. Seetthe (sic) enclosed amendment on this subject (Docket No. 70-12, Notice No. 9).; Sincerely, David Schmeltzer, 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.