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: aiam1955OpenMr. Mack Emmons, Emmons Brothers, P.O. Box 186, Meridian, MS, 39301; Mr. Mack Emmons Emmons Brothers P.O. Box 186 Meridian MS 39301; Dear Mr. Emmons: This is in response to your letter of May 1, 1975, concerning Federa Motor Vehicle Safety Standard No. 302, Flammability, and in amplification of your telephone conversation with Mr. Schwartz of my office.; As Mr. Schwartz advised you, Standard No. 302 applies to passenge cars, multipurpose passenger vehicles, trucks, and buses. Thus, the standard would apply to mattresses used in trucks. Further, it has been proposed to extend Standard No. 302 to campers and trailers other than those sold exclusively for the transportation of cargo (copy enclosed). Consequently, as you requested, I have enclosed a copy of Motor Vehicle Safety Standard No. 302, a recent amendment to that standard, and a proposed amendment which may also be of interest to you.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1548OpenLee and Winnie Jones, District Directors, National Campers & Hikers Assoc., Virginia Avenue, Sturgis, Michigan 490091; Lee and Winnie Jones District Directors National Campers & Hikers Assoc. Virginia Avenue Sturgis Michigan 490091; Dear Lee and Winnie Jones: This is in response to your letter of June 27, 1974, objecting to th use of extension mirrors on automobiles when a trailer is not in tow.; Although we fully appreciate the possible dangers inherent in the us of extension mirrors, this agency has no authority to regulate the use of such equipment. The authority that Congress has conferred upon the National Highway Traffic Safety Administration relates to the safe manufacture of motor vehicles and motor vehicle equipment, and not directly to its use. Therefore. unless some showing can be made that the design of the mirrors is dangerous, we have no authority to deal with the problem you describe.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2222OpenMr. Phil Schneider, PTV Project Supervisor, Steam Power Systems, 7617 Convoy Court, San Diego, CA 92111; Mr. Phil Schneider PTV Project Supervisor Steam Power Systems 7617 Convoy Court San Diego CA 92111; Dear Mr. Schneider: This is in response to your letter of January 22, 1976, requestin confirmation that your company's Paratransit Vehicle would be classified as a 'multipurpose passenger vehicle' for purposes of the Federal motor vehicle safety standards and regulations.; Your letter states that the Paratransit Vehicle is designed primaril to carry wheel-chair- confined passengers in a Dial-a-Ride or jitney type of service, and that the vehicle is of the forward control configuration, constructed with a custom chassis-body structure.; Based upon the facts presented in your letter, the description an specifications contained in the attached SAE design paper, and the National Highway Traffic Safety Administration's previous interpretation of the classification, we would conclude that the Paratransit Vehicle does qualify as a 'multipurpose passenger vehicle.'; Please contact us if we can be of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2008OpenMr. Phillip A. Cole, Lommen and Cole P.A., 2850 Metro Drive, Suite 514, Minneapolis, MN 55420; Mr. Phillip A. Cole Lommen and Cole P.A. 2850 Metro Drive Suite 514 Minneapolis MN 55420; Dear Mr. Cole: This is in response to your letter of July 21, 1975, inquiring as t the existence of any Federal safety standards applicable to the manufacture and sale of trailer hitches.; There are currently no Federal safety standards that pertain to traile hitches. Thus, no prescribed testing or inspection need be performed before distribution of these items. You may be interested in knowing, however, that testing for compliance with the Federal bumper standard (Standard No. 215, *Exterior Protection*) permits the removal of any trailer hitches during the required test impacts.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0102OpenMr. R. Debesson, General Secretary, European Tyre and Rim Technical Organisation, 49, Rue Barathon, 03-Montlucon - France; Mr. R. Debesson General Secretary European Tyre and Rim Technical Organisation 49 Rue Barathon 03-Montlucon - France; Dear Mr. Debesson: This is in response to your letter of may 24, requesting (1) a footnot to Table 1-A to provide that equivalent millimeter designations may be marked on tire sizes in addition to the dimension sizes in inches, and (2) a footnote to Table 1-C t to provide that the tire sizes provided in this table can be marked on the tire by giving the millimeter equivalent either before or after the size designation in inches.; We do not consider that Table 1-A of the standard, as presentl written, prohibits equivalent marking in millimeters as long as the conversion from inches to millimeters is exact and the tire meets the size and load carrying requirements shown in Table 1-A.; Similarly, we do not consider that the standard as presently writte prohibits the marking of the tire with equivalent millimeter sizes before or after the marking which gives the size of the tire in inches.; In view of the above, a footnote is not considered necessary. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations |
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ID: aiam1116OpenMr. John E. Huisman, Davies, Gibbs, Strayer, Stoel and Boley, Twenty-Third Floor, 900 S W Fifth Avenue, Portland, OR 97204; Mr. John E. Huisman Davies Gibbs Strayer Stoel and Boley Twenty-Third Floor 900 S W Fifth Avenue Portland OR 97204; Dear Mr. Huisman: This is in reply to your letter of April 10, 1973, concerning th status under the Federal odometer disclosure requirements of a bank which purchases a motor vehicle purchase money security agreement.; You are correct in understanding that the Act does not anticipate tha a bank will be required to give or receive an odometer disclosure statement in conjunction with the sale of a purchase money security agreement. In referring to a 'security interest', in 49 CFR Part 580, we did not intend to create an artificial distinction between States in which the bank holds only an 'interest' and States, such as Oregon, in which the bank actually takes title. It is our opinion that the bank should in neither case be required to execute a disclosure statement, and that the bank's 'ownership' of a vehicle by virtue of its purchase of a purchase money security agreement would not make the bank a transferor or transferee as those terms are employed in 49 CFR Part 580.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1130OpenMs. Mary Deane Dowdy, Virginia-Carolina Auto Auction, Inc., Post Office Box 2244, Danville, VA 24541; Ms. Mary Deane Dowdy Virginia-Carolina Auto Auction Inc. Post Office Box 2244 Danville VA 24541; Dear Ms. Dowdy: This is in response to your letter of May 11, 1973, in which you ask i the federal odometer disclosure statement may be incorporated in the title of an automobile transfered (sic) at auction.; You may include the disclosure statement on the title or other documen which accompanies the transfer so long as it is executed prior to the transfer. In addition to recording the mileage on the title, the statement would have to contain (1) the date of the transfer, (2) transferor's name and current address, (3) vehicle identification or serial number, make, model, year, body-type, last plate number, (4) a statement that actual mileage differs from recorded mileage if such is the case and the transferor knows it, and (5) reference to the Motor Vehicle Information and Cost Savings Act with the statement that incorrect information may result in civil liability under it.; An example of an adequate statement and format is enclosed for you information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0408OpenSSGT S. Jackson-Smith, Box 2708, 513 HQ SQ, APO NY, 09127; SSGT S. Jackson-Smith Box 2708 513 HQ SQ APO NY 09127; Dear SSGT Jackson-Smith: This is in reply to your recent letter inquiring about the mounting o a spare time between headlights of a Volkswagen Camper.; There is no Federal regulation that prohibits the mounting of the spar tire on the front of a vehicle. Federal motor vehicle safety standards apply to new vehicles and regulate manufacturers so as to assure compliance with applicable requirements. The standards do not regulate the vehicle purchaser and owner.; However, in the importation of vehicles into the United States, certai requirements must be met. These requirements are described in the enclosed pamphlet dated October 1969. If your vehicle has been manufactured more recently, up-to-date requirements may be obtained from your Volkswagen dealer.; It is recommended that inquiry be made of the State in which th vehicle will be licensed or driven for applicable laws and regulations in this area.; We appreciate your concern for motor vehicle safety. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0296OpenMr. David J. Humphreys, Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; Mr. David J. Humphreys Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: This is to confirm your interpretation of the Tire Identification an Record Keeping Regulations as expressed in your letter of February 18, 1971.; The vehicle manufacturer is responsible for the retention of records o tires shipped 'in or on' a new vehicle. However, if the vehicle is used to transport extra tires, the manufacturer is not obliged to retain records of those tires, but rather, the vehicle dealer will be responsible for communicating the appropriate information to the tire manufacturer in accordance with either section 574.8 or section 574.9 of Part 574.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2951OpenMr. Hisakazu Murakami, Staff, Safety, Nissan Motor Co., Ltd., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Hisakazu Murakami Staff Safety Nissan Motor Co. Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Murakami: This responds to your January 9, 1979, letter concerning a mistake o the certification labels of approximately 2000 Datsun trucks. You stated that the vehicles, although manufactured in 1979, were incorrectly dated on their certification labels as being manufactured in 1978. You propose to remedy the affected vehicles by crossing out the incorrect date and inserting the correct information.; Your proposed correction is acceptable to the National Highway Traffi Safety Administration. As long as all other information on the certification label is correct, your modification of existing certification labels will comply with the agency's regulations.; Sincerely, Joseph J. Levin, Jr., 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.