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: aiam1592OpenMr. R. Vibart, The Secretary General, Societe de Signalisations Automobiles, SEIMA, 11, Chemin des Merisiers, Villemoisson-sur-Orge (1), France, *AIR MAIL*; Mr. R. Vibart The Secretary General Societe de Signalisations Automobiles SEIMA 11 Chemin des Merisiers Villemoisson-sur-Orge (1) France *AIR MAIL*; Dear Mr. Vibart: This is in response to your letter of July 17, 1974, concerning NHTSA' proposal to apply a manufacturer's identification code to motor vehicle lights.; Motor vehicle lights, including those imported in the United States subject to MVSS No. 108, *Lamps, reflective devices, and associated equipment*, would be required to be marked with a manufacturer's identification code under the NHTSA proposal. Just as all motor vehicle lights must meet the performance requirements of Standard 108, if the proposal is adopted as a final rule they would be required to meet the manufacturer's identification code requirement as well.; Thank you for advising us of your views in this matter. We will tak them into account in formulating further action.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
|
ID: aiam2070OpenMr. John Lomash, United States Testing Co., Inc., 1415 Park Avenue, Hoboken, NJ 07030; Mr. John Lomash United States Testing Co. Inc. 1415 Park Avenue Hoboken NJ 07030; Dear Mr. Lomash: This is in response to your letter of September 11, 1975, in which yo asked whether Standard No. 217 requires a minimum retention or force in pushing out an emergency exit window after activation of the release mechanism.; You should note that the force applications specified in S5.3.2 fo operation of the release mechanism and subsequent extension of the exit by an occupant are maximum requirements. Therefore, a push-out window which only requires enough force to lift the glass and subframe following operation of the release mechanism complies with the requirements of S5.3.2 and S5.4 as long as that force does not exceed the levels specified for the particular reach distance of the release mechanism.; The standard specifies no minimum force requirements for either th operation of the release mechanism or the extension of the exit following release.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
|
ID: aiam1980OpenMr. Ray Hartman, Crown Coach Corporation, 2500 East Twelfth Street, Los Angeles, CA 90021; Mr. Ray Hartman Crown Coach Corporation 2500 East Twelfth Street Los Angeles CA 90021; Dear Mr. Hartman: This is in response to your letter of June 26 in which you request clarification of the definition of 'date of manufacture' as that term is found in Section 567.4 of the certification regulations.; As your vehicles are not manufactured in two or more stages, you ar subject to the requirements of Section 567.4 with respect to certification. Section 567.4(g)(2) specifies the month and year of manufacture as 'the time during which work was completed at the place of main assembly of the vehicle.' This is when the vehicle is finished by you. The vehicle should be certified as meeting all of the Federal motor vehicle safety standards applicable as of that date.; We trust that the above information is of assistance. If you have an further inquiries, please let us know.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3229OpenMr. Victor L. Johnson, Jr., Great Dane Trailers, Inc., P.O. Box 67, Lathrop Avenue, Savannah, Georgia 31402; Mr. Victor L. Johnson Jr. Great Dane Trailers Inc. P.O. Box 67 Lathrop Avenue Savannah Georgia 31402; Dear Mr. Johnson: This is to confirm your telephone conversation with Mr. Schwartz of m office, in which he advised you that the manufacturer identifier referred to in Docket 1-22, Notice 10, was the manufacturer identifier required by S4.5.1 of Federal Motor Vehicle Safety Standard No. 115. Inasmuch(sic) as the Society of Automotive Engineers has already assigned a manufacturer identifier to Great Dane Trailer, Inc., this requirements has been met.; I am forwarding your complete VIN plan to the VIN coordinator a required by S6 of the Standard.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam0878OpenHonorable Douglas W. Toms, Administrator, National Highway Traffic Safety Administration, Department of Transportation, 400 Seventh Street, S. W., Washington, DC 20591; Honorable Douglas W. Toms Administrator National Highway Traffic Safety Administration Department of Transportation 400 Seventh Street S. W. Washington DC 20591; Dear Dr. Toms: We enclose a copy of a Resolution adopted by the 52nd annual conventio of the National Tire Dealers & Retreaders Association, Inc.; Could you inform us, please, of the consideration being given by you Administration to the NTDRA's proposal? Do you think their plan might represent a reasonable compromise between the public interest in tire safety and the obvious interest of tire dealers in lessening their burden of wholly uncompensated Federal paperwork?; With best wishes, Sincerely, Chester H. Smith, Staff Director - General Counsel, Unite States Senate, Select Committee on Small Business; |
|
ID: aiam1773OpenMr. A. B. Kelly,Senior Vice President,Insurance Institute for Highway Safety,Suite 300,600 New Hampshire Avenue, N.W.,Washington, D.C. 20037; Mr. A. B. Kelly Senior Vice President Insurance Institute for Highway Safety Suite 300 600 New Hampshire Avenue N.W. Washington D.C. 20037; Dear Ben:#This is to confirm our understanding with respect to publi meetings to be held on the subject of the Hydraulic Brake Standard No. 105-75.#If any significant changes are to be made in the standard, a notice of proposed rulemaking will be issued. Toward the end of the comment period on that NPRM, the agency will hold a public hearing concerning the contents of the proposal. At that time you will have the opportunity to present your views in full.#Sincerely,Richard B. Dyson,Assistant Chief Counsel; |
|
ID: aiam0094OpenMr.. Francesco Palazzi, 11 Direttore, Associazione Nazionale Fra, Industrie Automobilistiche, 10128 - Torino, Italy; Mr.. Francesco Palazzi 11 Direttore Associazione Nazionale Fra Industrie Automobilistiche 10128 - Torino Italy; Dear mr. Palazzi: Thank you for your letter of June 3 to the National Highway Safet Bureau asking 'whether the solution given in the enclosed drawing N. 591-1559 of Ferrari is in line with the requirements' of Federal motor vehicle safety standard No. 211.; This standard states that 'wheel nuts, hub caps, and wheel discs fo use on passenger cars...shall not incorporate winged projections'. The Ferrari plan appears to incorporate such a projection, even though it is recessed. Accordingly the proposed solution by Ferrari does not meet the requirements of Federal standard No. 211.; Sincerely, Joseph R. O'Gorman, Acting Director |
|
ID: aiam2161OpenMr. Tokio Iinuma,Staff, Safety,Nissan Motor Co., Ltd.,560 Sylvan Avenue,Englewood Cliffs, New Jersey 07632; Mr. Tokio Iinuma Staff Safety Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs New Jersey 07632; Dear Mr. Iinuma:#This responds to Nissan's December 12, 1975, questio whether a manufacturer may comply with the requirements of Standard no. 105-75, *Hydraulic Brake Systems*, For 'a lens labeled in letters' (S5.3.5) by means of painting or otherwise printing the required label directly onto the lens.#The answer to your question is yes. Section S5.3.5's requirement for 'a lens labeled in letters' permits labeling by means of printing directly on the lens itself.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
|
ID: aiam3024OpenMr. Myles Robert Lee, P.O. Box 1344, Gloucester, MA 01930; Mr. Myles Robert Lee P.O. Box 1344 Gloucester MA 01930; Dear Mr. Lee: This responds to your May 12, 1979, letter asking how to determine th correct date of manufacture of your motor home. You indicate that the chassis was constructed in 1977 and the body in 1978. The manufacturer apparently classified the vehicle as a 1978 model.; The National Highway Traffic Safety Administration has a regulatio governing the date of manufacture of vehicles for the application of safety standards. Part 568, *Vehicles Manufactured in Two or More Stages*, of our regulations states that a manufacturer may choose as the date of manufacture of a vehicle the date of manufacture of the chassis, the date of manufacture of the completed vehicle, or any date between those two dates. However, the vehicle must comply with all of the applicable safety standards in effect on the chosen date. Since the body of your vehicle was manufactured in 1978, we assume that the vehicle was completed in 1978. Therefore, the manufacture could legally call your vehicle a 1978 model, at least for the purposes of our safety program.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam2063OpenMr. Andrew W. Brainerd, Brainerd & Bridges, 1 North LaSalle Street, Chicago, Illinois 60602; Mr. Andrew W. Brainerd Brainerd & Bridges 1 North LaSalle Street Chicago Illinois 60602; Dear Mr. Brainerd: #This is in response to the May 26, 1975, petitio of your client, Kugelfischer Georg Schaefer & Co., for an amendment of the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #The National Highway Traffic Safety Administration has granted the petitions of General Motors Corporation and Ford Motor Company to delete the banding requirement. A proceeding respecting the issuance of a notice of proposed rulemaking has been commenced. Because the amendment requested by your client is inconsistent with the deletion of the banding requirement, in the strict sense, that petition is hereby denied. You may find, however, that the change now being developed in our rulemaking proceedings will be satisfactory to your client. #Sincerely, Robert L. Carter, Associate Administrator, 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.