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 |
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ID: aiam0709OpenMr. James A. Walsh, President, Armstrong Rubber Company, 500 Sargent Drive, New Haven, Connecticut 06507; Mr. James A. Walsh President Armstrong Rubber Company 500 Sargent Drive New Haven Connecticut 06507; Dear Mr. Walsh: #We are in receipt of your response of October 7, 1971 to CIR 368.1.1, concerning Admiral Belted 78 tires that were branded on one side only. #The Administration considers the act of branding on only one sidewall at a time when the standard required both sidewalls be labeled, to be inexcusable. If similar incidents of overlooking requirements come to our attention we will pursue civil penalties. However, based on the information before us we are closing our files in this case with regard to both civil penalties and defect notification. The Administration reserves the right to reopen this file in the event that further violations of this nature come to its attention. #Sincerely, Francis Armstrong, Director, Office of Standards Enforcement, Motor Vehicle Programs; |
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ID: aiam3221OpenMr. J. Leftrook, Jr., President, G. Mack Industries, Ltd., Suite No. 3, 933 McLeod Avenue, Winnipeg, Manitoba, Canada R2G OY4; Mr. J. Leftrook Jr. President G. Mack Industries Ltd. Suite No. 3 933 McLeod Avenue Winnipeg Manitoba Canada R2G OY4; Dear Mr. Leftrook: This is in reply to your letter of February 18, 1980, asking about th legality in the United States of a lamp with the words 'DON'T PASS' which you are presently manufacturing for school buses in Canada. The lamp is intended for mounting on both the front and rear of the bus.; Such a lamp is not required in this country under Federal law. Its us as original equipment on U.S. school buses would not be prohibited by Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*, since its installation would not appear to impair the effectiveness of required lighting equipment. Its legality would be determined by that of the State in which the bus is registered and operated, and therefore, you should contact the individual State for their opinion in this matter.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0176OpenMr. W. W. King, Vice President, Marketing, Meyer Products, Inc., 18513 Euclid Avenue, Cleveland, OH 44112; Mr. W. W. King Vice President Marketing Meyer Products Inc. 18513 Euclid Avenue Cleveland OH 44112; Dear Mr. King: I regret the delay in responding to your letter of April 23, in whic you provided certain certification information and details on your wheeled spreaders.; The wheeled spreaders attached to a towing vehicle are considered moto vehicles under the National Traffic and Motor Vehicle Safety Act of 1966, and have been categorized as 'trailers'. Federal Motor Vehicle Safety Standard 108 is currently the only standard applicable to trailers, specifically those 80 inches and more in overall width.; This Standard will also apply to trailers of lesser width manufacture after December 31, 1968.; Accordingly Meyer Products is required to certify compliance i accordance with section 114 of the Act. I enclose for your guidance copies of the Act, Federal Standard No. 108, and the certification Notice currently in effect.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam1493OpenMr. G. Meier, Technical Service Manager, Porsche/Audi, 818 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. G. Meier Technical Service Manager Porsche/Audi 818 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Meier: This is in reference to your defect notification campaign (NHTSA No 73-0229) concerning possible fires resulting from a short in the radiator cooling fan in some Audi 100's.; The letter which you have sent to the owners of the involved vehicle does not entirely meet the requirements of 49 CFR Part 577. Specifically, the phrase, 'possible hazard that may exist in your vehicle,' may be construed as a disclaimer since it tends to discourage vehicle owners from having their vehicles corrected and is therefore not permitted. It is, however, permissible to state that the defect may not be present in every vehicle being campaigned if such a statement is applicable.; It will not be necessary to send an additional letter in this instance but all future defect notifications must comply with the applicable regulation. If you desire further information, please contact Messrs. W. J. Reinhart or James Murray at this office (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam1256OpenSekurit-Glas Union GmbH, 5 Koln 1, Postfach 101608; Sekurit-Glas Union GmbH 5 Koln 1 Postfach 101608; Dear Sir: This is in reply to your letter of July 19, 1973, requestin information regarding the marking requirements in FMVSS No. 205 for automobile safety glass.; With respect to your request for a copy of the marking requirements they may be found in paragraph S6. of the enclosed copy of the standard, and in section 6 of American National Standard Z26.1 - 1966. The latter standard can be obtained by writing to the American National Standards Institute, 1430 Broadway, New York, New York 10018.; Information on various State requirements should be obtained from Mr Armond Cardarelli, American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.; You ask whether marking requirements can be met using a specific forma you include in your letter, and refer to 'Approval' and 'Supplemental' markings. It is not clear to us to what you refer, as we prescribe neither 'approval' nor 'supplemental' markings in the standard, and perhaps we will be better able to answer any questions you may have after you have had an opportunity to review the requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1043OpenMr. William J. Bourne, Manager, Transportation Administration, Kraft Foods, 500 Peshtigo Court, Chicago, IL 60690; Mr. William J. Bourne Manager Transportation Administration Kraft Foods 500 Peshtigo Court Chicago IL 60690; Dear Mr. Bourne: This is in response to your letter of February 26, 1973, concerning th Federal Odometer Disclosure Requirements.; With respect to your first question, we confirm your understanding tha a commercial firm trading a vehicle having a gross weight of 16,000 pounds or less is required to give the dealer a disclosure statement.; Your second question concerns the intent of the phrase 'creating security interest,' as used in the definitions of transferee and transferor in section 580.3. The quoted phrase was used to exclude parties to transactions in which liens and similar interests in vehicles are created, but in which the ownership of the vehicle does not change. For example, a bank that lends money for the purchase of a vehicle and that secures its loan by a lien on the vehicle is not a transferee. A dealer who sells a vehicle conveys his ownership and is therefore a transferor, even though he may *also* create a security interest by placing a lien on the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2704OpenMr. Stanley Brajer, Project Engineer, Ellcon National, Inc., P.O. Box 307, Totowa, NJ 07512; Mr. Stanley Brajer Project Engineer Ellcon National Inc. P.O. Box 307 Totowa NJ 07512; Dear Mr. Brajer: This responds to your September 2, 1977, letter concerning th applicability of Standard No. 217, *Bus Window Retention and Release*, to a thermopane driver's window in a bus.; In response to your first question, the window to which you refer i required to comply with the requirements of the standard. The fact that it is a driver's window does not exempt it from the coverage of the standard.; Your second question asks how to test thermopane glazing. According t our enforcement staff, testing of thermopane windows can be conducted using the same criteria used for other window glazing. By following the procedures established in S5.1 of the standard, you should be able to accurately test thermopane glazing.; Sincerely, Joseph J. Levin,Jr., Chief Counsel |
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ID: aiam0086OpenMiss Lucy Wissler, President, Gypsy Campers, 1601 West 190 Street, Gardena, CA 90247; Miss Lucy Wissler President Gypsy Campers 1601 West 190 Street Gardena CA 90247; Dear Miss Wissler: Thank you for your letter of May 29, 1968, in which you state that you camper conversion is not subject to the requirements of the Federal Motor Vehicle Safety Standards.; Please note the requirements for glazing in Federal Motor Vehicl Safety Standard No. 205, contained in our letter to you dated May 24, 1968. Should your modification involve installation of glazing, then these requirements would apply.; Note also Standards No. 103, 106, 107, 111, and 211, which ar applicable to a multi-purpose passenger vehicle. Your conversion of a van to a camper is conversion of a truck to a multi-purpose passenger vehicle, and therefore, requires compliance with applicable standards.; Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam5430OpenMr. Richard J. Quigley 5886-b Fernflat Road Aptos, CA 95003; Mr. Richard J. Quigley 5886-b Fernflat Road Aptos CA 95003; Dear Mr. Quigley: This responds to your request for reconsideration o our July 15, 1994 interpretation letter on Standard No. 218, Motorcycle helmets. In that letter, we stated that a drawing you provided would not meet the requirement in S5.6.1(e) of the standard that motorcycle helmets be labeled with the symbol DOT. You enclosed a new drawing and ask whether it meets S5.6.1(e). The answer is no. The new version of the drawing consists of three figures that you believe constitute the symbol 'DOT.' Your new drawing continues to incorporate a corporate logo in lieu of the letter 'O.' As explained in our July 15, 1994 letter, because the symbol DOT constitutes the manufacturer's certification that the helmet conforms to Standard No. 218, there must be no ambiguity in the symbol. Using the corporate logo in lieu of the letter 'O' introduces ambiguity as to whether the manufacturer has certified the helmet. Thus, the new version of the drawing you provided does not meet S5.6.1(e) of Standard No. 218. I hope this answers your question. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1686OpenMr. Dick Heinrich, Service Manager, Construction Equipment Division, Kyster Company, P. O. Box 289, Kewanee, IL 61443; Mr. Dick Heinrich Service Manager Construction Equipment Division Kyster Company P. O. Box 289 Kewanee IL 61443; Dear Mr. Heinrich: This is in reference to your defect notification campaign (NHTSA No 74-0165) concerning 79 trailers with Standard Forge brake shoes which may be defective.; The letter which you have sent to the purchasers of the subjec vehicles does not contain the precise language which is required by Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter describes the defect as existing in the brake shoe assemblies. Part 577.4(b) requires, however, that vehicle manufacturers describe the defect as existing in the vehicle itself. The reference in Part 577.4(b) to motor vehicle equipment applies only to equipment campaigns where vehicle (sic) are not involved.; Since in our opinion this discrepancy in your notification letter doe not appear to adversely affect the performance of this campaign, mailing of a revised letter will not be required. A copy of Part 577 is enclosed.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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.