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: aiam1355OpenContinental Rubber Products, Inc., Minue Street, Carteret, New Jersey 07008; Continental Rubber Products Inc. Minue Street Carteret New Jersey 07008; Gentlemen: at the request of Continental Tire Company by letter of November 27 1973 (90316 - Ga/MAB/Sc), we are forwarding our response to their questions through you. They asked to know the lettering height to be used in compliance with the labeling requirements of Motor Vehicle Safety Standard No. 119.; The National HIghway Traffic Safety Administration is presentl considering the lettering height to be used for labeling required by Standard 119. Our decision as to lettering size will appear in the *Federal Register* as soon as possible after it has been made.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1042OpenMr. John W. Griffin, Sr., 109 Lakemont Drive, Augusta, GA; Mr. John W. Griffin Sr. 109 Lakemont Drive Augusta GA; Dear Mr. Griffin: This is in response to your letter of February 27, 1973, concerning th effective date of the new Federal odometer law.; The provisions of the law (Public Law 92- 513) went into effect o January 18, 1973, with the exception of the disclosure requirements, which were implemented by regulations adopted by this agency effective March 1, 1973.; The regional office of the National Highway Traffic Safet Administration nearest to you is in Atlanta. The address is Lawrence E. Thompson, Regional Administrator, NHTSA, Suite 400, 1720 Peachtree Road, N.W., Atlanta (sic) Georgia 30309.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0350OpenMr. Lawrence Petterson, Hicks Oil Company, 215 1/2 East Main Street, Pipestone, MN 56164; Mr. Lawrence Petterson Hicks Oil Company 215 1/2 East Main Street Pipestone MN 56164; Dear Mr. Petterson: This is in reply to your letter of April 28, 1971. Under Part 574, th 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 sidewall as is feasible so that the number will remain legible as long as possible. See the enclosed amendment on this subject (Docket No. 70-12, Notice No. 9).; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam0208OpenMr. W. B. Colquhoun, Executive Vice-President, Norton Villiers Corporation, North Way, Andover, Hampshire, England; Mr. W. B. Colquhoun Executive Vice-President Norton Villiers Corporation North Way Andover Hampshire England; Dear Mr. Colquhoun: Thank you for your letter of January 22, 1970, enclosing ten copies o the Consumer Information for motorcycles produced by Norton Villiers Corporation.; Your submittal has on its face eliminated the problems that were calle to your attention in our letter of January 9. The form in which the information is presented deviates, however, from the form prescribed by the regulations, sections 375.101 and 106. The most significant deviation is the omission of the explanatory statements that are required for both types of information. The figures included with each section of the regulations should be followed closely in your presentation of the information to purchasers.; Please let us know if we can be of further assistance. Sincerely, Douglas W. Toms, Director |
|
ID: aiam0207OpenMr. W. B. Colquhoun, Executive Vice-President, Norton Villiers Corporation, North Way, Andover, Hampshire, England; Mr. W. B. Colquhoun Executive Vice-President Norton Villiers Corporation North Way Andover Hampshire England; Dear Mr. Colquhoun: Thank you for your letter of January 22, 1970, enclosing ten copies o the Consumer Information for motorcycles produced by Norton Villiers Corporation.; Your submittal has on its face eliminated the problems that were calle to your attention in our letter of January 9. The form in which the information is presented deviates, however, from the form prescribed by the regulations, sections 375.101 and 106. The most significant deviation is the omission of the explanatory statements that are required for both types of information. The figures included with each section of the regulations should be followed closely in your presentation of the information to purchasers.; Please let us know if we can be of further assistance. Sincerely, Douglas W. Toms, Director |
|
ID: aiam1764OpenMr. Toshihiko Sotohara,Nichirin Rubber Industrial Co.,1118, Sazuchi, Bessho,Himejim, Japan; Mr. Toshihiko Sotohara Nichirin Rubber Industrial Co. 1118 Sazuchi Bessho Himejim Japan; Dear Mr. Sotohara:#Please forgive the delay in responding to you letter of November 22, 1974, requesting confirmation of your interpretation that Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, does not require you to label the brake hose and brake hose assemblies which you manufacture with a DUNS manufacturer's code number.#Your interpretation is correct. S5.2.2, S5.2.3, and S5.2.4 of Standard No. 106-74 were amended on January 29, 1974, (39 FR 3680, Docket No. 1-5, Notice 9) to no longer require a manufacturer's code number. A designation identifying you as the manufacturer is required, however. The designation, 'NCRN', as described in your letter, already satisfied this requirement. This designation is now on file in the Office of Standards Enforcement.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
|
ID: aiam3129OpenMr. H.A. Ritzenthaler, VDO-ARGO Instruments Inc., 980 Brooke Road, P.O. Box 2630, Winchester, Virginia 22601; Mr. H.A. Ritzenthaler VDO-ARGO Instruments Inc. 980 Brooke Road P.O. Box 2630 Winchester Virginia 22601; Dear Mr. Ritzenthaler: This is in response to your letter of January 25, 1979, in which yo stated your interpretation of Federal Motor Vehicle Safety Standard 127, *Speedometers and Odometers*, and asked that we advise you if action taken in accordance with this interpretation would place your company in violation of the standard. This letter is to confirm that your interpretation is correct.; According to your interpretation of Safety Standard 127, thos provisions which become effective for new motor vehicles on September 1, 1979 and September 1, 1980 are not applicable to speedometers and replacement parts produced for use in motor vehicles manufactured before those dates. This is correct because Safety Standard 127 is a vehicle standard and an equipment standard which applies to passenger cars, multipurpose passenger vehicles, trucks, motorcycles, and buses manufactured after the standard's effective dates and to speedometer and odometers for use in such vehicles. (Section 3, Safety Standard 127).; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam0575OpenMr. W. M. Self, Marketing Manager, Downs-Clark, P.O. Box 1386, Brownwood, TX 76801; Mr. W. M. Self Marketing Manager Downs-Clark P.O. Box 1386 Brownwood TX 76801; Dear Mr. Self: This is in reply to your letter of December 30, 1971, concernin whether you must comply with the Certification regulations (49 CFR Part 567) in cases where you 're-barrel' or 're-deck' trailers. You describe these processes as installing a new tank (re-barreling) or platform deck (re- decking) on a used trailer under construction furnished by your customer, which includes axles, tires, wheels, springs, hangers, and internal brake assemblies, in serviceable condition.; You are not required to certify these vehicles as they are manufacture on used chassis and are considered by this agency to be used vehicles under section 108(b)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1397(b)(1)).; We are pleased to be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1282OpenMr. Jerry R. Freed, 3115 Prairie, Elkhart, IN 46514; Mr. Jerry R. Freed 3115 Prairie Elkhart IN 46514; Dear Mr. Freed: Your letter of September 24, 1973 has been referred to the Region Office of the National Highway Traffic Safety Administration, by the Federal Trade Commission.; Enclosed is a copy of Title IV of the Motor Vehicle Information an Cost Savings Act, Public Law 92-513. This information should provide you and your counsel with adequate information to resolve your problem. If, after having gone over the law, you still have technical questions regarding this law, please forward them to Lawrence R. Schneider, Chief Counsel, N40-30, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590. I am forwarding a copy of your letter to Mr. Schneider's office for appropriate action.; If this office can be of further assistance to you in the future please let us know.; Sincerely, Gordon G. Lindquist, Regional Administrator |
|
ID: aiam0574OpenMr. W. M. Self, Marketing Manager, Downs-Clark, P.O. Box 1386, Brownwood, TX 76801; Mr. W. M. Self Marketing Manager Downs-Clark P.O. Box 1386 Brownwood TX 76801; Dear Mr. Self: This is in reply to your letter of December 30, 1971, concernin whether you must comply with the Certification regulations (49 CFR Part 567) in cases where you 're-barrel' or 're-deck' trailers. You describe these processes as installing a new tank (re-barreling) or platform deck (re- decking) on a used trailer under construction furnished by your customer, which includes axles, tires, wheels, springs, hangers, and internal brake assemblies, in serviceable condition.; You are not required to certify these vehicles as they are manufacture on used chassis and are considered by this agency to be used vehicles under section 108(b)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1397(b)(1)).; We are pleased to be of assistance. 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.