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: aiam2953OpenMr. 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 |
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ID: aiam3553OpenJerry Manzagol, Director, New Mexico Transportation Department, Motor Vehicle Division, Manuel Lujan Senior Building, Santa Fe, NM 87503; Jerry Manzagol Director New Mexico Transportation Department Motor Vehicle Division Manuel Lujan Senior Building Santa Fe NM 87503; Dear Mr. Manzagol: This is in response to your letter of March 10, 1982, requesting th approval of the revised New Mexico odometer disclosure for use in lieu of the Federal odometer disclosure statement. In October 1981 you submitted New Mexico's proposed odometer disclosure statement to the agency for approval for use in lieu of the separate Federal odometer form. The agency reviewed the form and determined that it could not be substituted for the Federal form unless the third alternate certification was rephrased to comport with the requirements of the Federal odometer law and the transferee's signature was added.; The agency has reviewed New Mexico's revised odometer disclosur statement and has now determined that it can be substituted for use in lieu of the Federal odometer disclosure statement.; If you have any further questions, please do not hesitate to write. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5355OpenHerr Tilman Spingler Robert Bosch GmbH Automotive Equipment Div. 2 Postfach 13 42 D-72703 Reutlingen Germany; Herr Tilman Spingler Robert Bosch GmbH Automotive Equipment Div. 2 Postfach 13 42 D-72703 Reutlingen Germany; Dear Mr. Spingler: This responds to your letter of March 25, 1994 asking for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to integral beam headlighting systems. You reference a letter of this office to Toyota in which we permit location of the light source control module outside the headlamp housing but permanently attached to it by a cable. You have asked whether there are 'requirements for this cable concerning indivisibility and integration . . . .' There are no such requirements for the cable in Standard No. 108, and the headlamp manufacturer may adopt the construction that it has determined is most suitable for its design. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam1232OpenMr. Gino D'Angelo, Director of State Police, Fiscal Management, New York State Police, Albany, NY 12226; Mr. Gino D'Angelo Director of State Police Fiscal Management New York State Police Albany NY 12226; Dear Mr. D'Angelo: This is in reply to your letter on August 20, 1973, asking that la enforcement vehicles be excluded from a Federal prohibition against headlight flashers.; There is no such prohibition. While paragraph S4.6(b) of Federal Moto Vehicle Safety Standard No. 108 requires headlamps to be steady-burning in use, it also specifically states that 'means may be provided to flash [automatically] headlamps . . . for signalling purposes.' Therefore, manufacturers are not prohibited from equipping vehicles with headlamp flasher units upon customer request.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0160OpenHonorable Jacob K. Javits, United States Senate, Washington, D.C. 20510; Honorable Jacob K. Javits United States Senate Washington D.C. 20510; Dear Senator Javits: #This is in further reply to your transmitta memorandum and attached letter from Mr. Robert W. Muller, New York, New York, inquiring about consumer information on passenger car tires. #The Department of Transportation does not presently have a publication which would guide the consumer in selecting tires most suitable to his needs. #To provide the consumer with an indication of the performance characteristics of tires, the Federal Highway Administration is obtaining research data and has established Docket 25, Uniform Tire Quality Grading System - Passenger Cars. A copy of the notice from the Federal Register is enclosed. #As soon as a meaningful system of tire quality grading can be developed to assist the public, it will be made available. #Sincerely, Robert Brenner, Acting Director; |
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ID: aiam0333OpenMr. G. M. Hespeler, Manager, Government Liaison, Mercedes- Benz of North America, Inc., 158 Linwood Plaza, P.O. Box 318, Fort Lee, NJ, 07024; Mr. G. M. Hespeler Manager Government Liaison Mercedes- Benz of North America Inc. 158 Linwood Plaza P.O. Box 318 Fort Lee NJ 07024; Dear Mr. Hespeler: This is in reply to your letter of May 3 asking for confirmation o your understanding with Mr. Vinson of my staff that the 'optical horn' lighting feature is not prohibited by paragraph S4.6(b) of Motor Vehicle Safety Standard No. 108.; Paragraph S4.6(b) which states in part that 'means may be provided t flash headlamps . . . for signaling purposes' allows the use of an automatic device for headlamp flashing, and it follows that a non-automatic system, such as the 'optical horn' incorporates, is also permissible.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam1086OpenMr. E.J. Wagner, American Retreaders' Association, Inc., P.O. Box 17203, Louisville, Kentucky 40217; Mr. E.J. Wagner American Retreaders' Association Inc. P.O. Box 17203 Louisville Kentucky 40217; Dear Mr. Wagner: This is in reply to your letter of March 20, 1973, in which you as whether, if a retreaded tire cannot meet the dimensional requirements for its original casing size, it can be considered as and labeled with a smaller size, if it meets the dimensional requirements for the smaller size.; S5.1.4 of Standard No. 117 prohibits a retread tire from having a siz designation, maximum load rating, or maximum inflation pressure greater than that originally specified on the casing. It does not prohibit a retreaded tire from having a smaller size than its casing, as long as the retreaded tire meets all the requirements for its labeled Size designation.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1275OpenMr. David J. Humphreys, Paulson and Humphreys, 1140 Connecticut Avenue, NW., Washington, DC 20036; Mr. David J. Humphreys Paulson and Humphreys 1140 Connecticut Avenue NW. Washington DC 20036; Dear Mr. Humphreys: This is in reply to your communication of September 20, 1973 requesting our review of a sample owner notification letter, regarding a safety related defect in certain Apache Camping Trailers, for purposes of conformity to 49 CFR Part 577, Defect Notification.; We believe the reference in the first sentence of the second paragraph that a defect *may* exist, to be inconsistent with the regulation. This statement is apparently intended to meet the requirement of Section 577.4(b). This subsection, however, requires a particular statement and does not permit the use of 'may' or similar expression. The statement required is not solely one of fact, but rather one of law, and the opening sentence of Section 577.4(b) shows clearly that the statement is required where the defect potentially exists in the vehicles or equipment in question. We also believe your references in other parts of the letter to 'possible defect' suffer from the same deficiency.; In other respects, we believe your notification letter conforms to Par 577.; Sincerely yours, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0413OpenMr. T. Nakajima, Senior Engineer, Mitsubishi Motors Corporation, Suite 410 Trowell Building, 24681 Northwestern Highway, Southfield, MI 48075; Mr. T. Nakajima Senior Engineer Mitsubishi Motors Corporation Suite 410 Trowell Building 24681 Northwestern Highway Southfield MI 48075; Dear Mr. Nakajima:#This is in reply to your letter of July 12 inquirin whether the proposed identification of the windshield washing system and hazard warning system controls, depicted on the photographs and overlays you enclosed, would conform with the requirements of Standard No. 101.#Standard No. 101 requires use of the word 'WASH' to identify the washing system control, and the word 'HAZARD' to identify the vehicular hazard warning system control, when these controls are manually operated. Your photographs and overlays indicate that you will use the required words to identify the appropriate controls. In our view, you have understood the requirements correctly.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam2254OpenMr. Raymond Oleisky, Operations Manager, Trans-continental Tire Sales, Inc., 9 Fourth Street, S.W., Osseo, Minnesota 55369; Mr. Raymond Oleisky Operations Manager Trans-continental Tire Sales Inc. 9 Fourth Street S.W. Osseo Minnesota 55369; Dear Mr. Oleisky: I am writing to confirm your March 19, 1976, telephone conversatio with Mark Schwimmer of this office concerning Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*.; Standard No. 119 requires that the symbol 'DOT' appear on the sidewal of a non-passenger car tire, as a certification that the tire meets all of the standard's performance and labeling requirements. Assuming that the tire in question does meet those requirements and is so certified, there is no prohibition in the standard against additional labeling such as 'Blem' or 'A.B.O.' I hope this clarifies the status of your tires.; Sincerely, Frank A. Berndt, Acting 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.