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: aiam0649OpenMr. Charles R. Matthews, Sr. Safety Engineer, Oshkosh Truck Corporation, P. O. Box 560, Oshkosh, WI 54501; Mr. Charles R. Matthews Sr. Safety Engineer Oshkosh Truck Corporation P. O. Box 560 Oshkosh WI 54501; Dear Mr. Matthews: In your letter of March 13 you ask for an interpretation o certification requirements applicable to remanufactured vehicles.; The National Traffic and Motor Vehicle Safety Act of 1966 and 49 CF Part 567 require only that certification of vehicle conformity be provided prior to the first purchase for purposes other than resale. On the basis of the work that you described as your 'remanufacturing', specifically that the vehicle retains its 'original frame, cab, body, axles, and transmission', we concur in your interpretation that vehicles of this nature are not new vehicles requiring certification of conformity with the Federal motor vehicle safety standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0131OpenMr. Donald S. Mortensen, Baycraft, 225 E. Lockhart, Coos Bay, OR 97420; Mr. Donald S. Mortensen Baycraft 225 E. Lockhart Coos Bay OR 97420; Dear Mr. Mortensen: Your letter of December 2, 1968, to Mr. William L. Hall, concernin safety glazing in canopies, has been referred to me for reply.; FHWA Ruling 68-1 clarified the requirement that slide-in campers mus comply with Standard 205 since they are items of motor vehicle equipment for use in motor vehicles. A copy of FHWA Ruling 68-1 is enclosed.; The same rationale applies to your canopies. Forward facing window must be laminated safety glass meeting the requirements of Test No. 26 of ASA Standard Z26.1-1966, July 15, 1966. Other windows may be AS1, 2, 3, 4, 5, 6, 7, 10, 11, 2-26, or 3-26.; Sincerely, Clue D. Ferguson, Director, Office of Standards o Crash-Injury Reduction, Motor Vehicle Safety Performance Service; |
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ID: aiam0648OpenMr. Vern A. Moultrie, Manager, Manufacturing & Service, Schetky Equipment Corporation, P. O. Box 13365, Portland, OR 97213; Mr. Vern A. Moultrie Manager Manufacturing & Service Schetky Equipment Corporation P. O. Box 13365 Portland OR 97213; Dear Mr. Moultrie: This is in reply to your letter of March 16, 1972, in which you reques clarification of the Certification requirements (49 CFR Part 567). You ask whether certification is necessary, mentioning specifically certification to Motor Vehicle Safety Standard No.108, when you install new dump bodies on used chassis manufactured both before and after January 1, 1968.; The motor vehicle safety standards apply only to new vehicles, an neither compliance with the standards nor 'Certification' is required if you are installing truck bodies on used chassis.; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0652OpenMr. Charles R. Matthews, Sr. Safety Engineer, Oshkosh Truck Corporation, P. O. Box 560, Oshkosh, WI 54501; Mr. Charles R. Matthews Sr. Safety Engineer Oshkosh Truck Corporation P. O. Box 560 Oshkosh WI 54501; Dear Mr. Matthews: In your letter of March 13 you ask for an interpretation o certification requirements applicable to remanufactured vehicles.; The National Traffic and Motor Vehicle Safety Act of 1966 and 49 CF Part 567 require only that certification of vehicle conformity be provided prior to the first purchase for purposes other than resale. On the basis of the work that you described as your 'remanufacturing', specifically that the vehicle retains its 'original frame, cab, body, axles, and transmission', we concur in your interpretation that vehicles of this nature are not new vehicles requiring certification of conformity with the Federal motor vehicle safety standards.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0412OpenMr. 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: aiam2827OpenMs. Lois M. Hebda, Mellon Bank, P.O. Box 360617M, Pittsburgh, PA 15230; Ms. Lois M. Hebda Mellon Bank P.O. Box 360617M Pittsburgh PA 15230; Dear Ms. Hebda: This is in response to your recent telephone conversation with Kath DeMeter of my staff concerning the retention of odometer disclosure statements. The question you raised was in what order the statements should be retained. The two methods you proposed using were alphabetically by the name of the individual or organization to which you transferred the vehicle. 49 CFR requires each dealer or distributor of a motor vehicle to retain the statements 'in an order that is appropriate to his business requirements and that permits systematic retrieval.'; Either method you propose would probably permit systematic retrieva and you may therefore select the method which best suits your business requirements.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam0651OpenMr. Vern A. Moultrie, Manager, Manufacturing & Service, Schetky Equipment Corporation, P. O. Box 13365, Portland, OR 97213; Mr. Vern A. Moultrie Manager Manufacturing & Service Schetky Equipment Corporation P. O. Box 13365 Portland OR 97213; Dear Mr. Moultrie: This is in reply to your letter of March 16, 1972, in which you reques clarification of the Certification requirements (49 CFR Part 567). You ask whether certification is necessary, mentioning specifically certification to Motor Vehicle Safety Standard No.108, when you install new dump bodies on used chassis manufactured both before and after January 1, 1968.; The motor vehicle safety standards apply only to new vehicles, an neither compliance with the standards nor 'Certification' is required if you are installing truck bodies on used chassis.; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3373OpenMr. R. Kawaguchi, Toyo Kogyo USA Office, 23777 Greenfield Road, Suite 462, Southfield, Mi 48075; Mr. R. Kawaguchi Toyo Kogyo USA Office 23777 Greenfield Road Suite 462 Southfield Mi 48075; Dear Mr. Kawaguchi: This is in response to your letter of October 20, 1980, concernin Federal Motor Vehicle Safety Standard No.l 115, Vehicle identification number (49 CFR 571.115).; Your question concerns the submission of horsepower data to the agenc as required by the standard (S4.5.2). On February 25, 1980, the agency published an amendment to Standard No. 115 in the Federal Register (45 FR 12255) which authorized slight variations between the engine horsepower encoded in the vehicle identification number (VIN) and the actual engine horsepower. Except in the case of motorcycles, a variance in horsepower of plus or minus 10 percent was authorized. You wish to know whether the engine horsepower data you submit to the agency should be consistent with the VIN coding, or whether you should submit the precise horsepower.; The information which must be submitted pursuant to S6.3 is tha necessary to decipher the characters contained in the VIN. Consequently, the engine horsepower submitted should represent the horsepower actually encoded in the VIN, whether or not this is the precise horsepower.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2030OpenMr. Robert L. Hunt, Zimmer Homes Corporation, 777 S.W. 12th Avenue, P.O. Box 2127, Pompano Beach, FL 33061; Mr. Robert L. Hunt Zimmer Homes Corporation 777 S.W. 12th Avenue P.O. Box 2127 Pompano Beach FL 33061; Dear Mr. Hunt: This is in response to your letter of August 15, 1975, concerning tir recordkeeping, and in confirmation of your telephone conversation with Mr. Schwartz of this office.; Section 574.10 of 49 CFR Part 574, Tire Identification an Recordkeeping, requires a motor vehicle manufacturer, or its designee, to maintain a record of the tires on each vehicle shipped to a distributor or dealer and the name and address of the first purchaser for purposes other than resale. This record must be kept for at least three years.; I have enclosed a copy of the regulation for your information. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4351OpenMr. David O. Johnson, 135 Karen Drive, Washington, PA 15301; Mr. David O. Johnson 135 Karen Drive Washington PA 15301; Dear Mr. Johnson: This responds to your April 22, 1987, letter asking about the legalit of transporting people in fifth wheel trailers. The National Highway Traffic Safety Administration is responsible for promulgating safety standards for the manufacture and sale of new motor vehicles. The use of a motor vehicle, such as a trailer, is a matter over which we have no jurisdiction.; Because the legality of carrying people in trailers might be governe by State law, we suggest you contact State officials with your questions. Additionally, questions you might have about the operation of interstate motor carriers should be directed to Mr. Tom Kozlowski of the Office of Motor Carrier Standards (Room 3403), Federal Highway Administration, at this address.; Sincerely, Erika Z. Jones, 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.