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: aiam1204OpenMr. Arthur E. Allen, President, SCARTI, 2042 S. Sepulveda, Los Angeles, CA 90025; Mr. Arthur E. Allen President SCARTI 2042 S. Sepulveda Los Angeles CA 90025; Dear Mr. Allen: This is in reply to your letter of July 19, 1973, to the Administrator. The exemption provided vehicles with a curb weight of 1,000 pounds o less will cease to exist as of January 1, 1974, and lightweight vehicles manufactured on or after that date will be required to meet all Federal motor vehicle safety standards applicable to their vehicle category, *e.g.* passenger cars.; Under the circumstances you indicate, you would be the final-stag manufacturer of a vehicle manufactured in two or more stages, under 49 CFR Parts 567 and 568 of our regulations. We refer you specifically to sections 567.5 and 568.6 of those regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1206OpenMr. Arthur E. Allen, President, SCARTI, 2042 S. Sepulveda, Los Angeles, CA 90025; Mr. Arthur E. Allen President SCARTI 2042 S. Sepulveda Los Angeles CA 90025; Dear Mr. Allen: This is in reply to your letter of July 19, 1973, to the Administrator. The exemption provided vehicles with a curb weight of 1,000 pounds o less will cease to exist as of January 1, 1974, and lightweight vehicles manufactured on or after that date will be required to meet all Federal motor vehicle safety standards applicable to their vehicle category, *e.g.* passenger cars.; Under the circumstances you indicate, you would be the final-stag manufacturer of a vehicle manufactured in two or more stages, under 49 CFR Parts 567 and 568 of our regulations. We refer you specifically to sections 567.5 and 568.6 of those regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2457OpenMr. John F. McCuen, Kelsey-Hayes Company, Romulus, Michigan 48174; Mr. John F. McCuen Kelsey-Hayes Company Romulus Michigan 48174; Dear Mr. McCuen: This responds to Kelsey-Hayes' April 21, 1976, question whether moto vehicle rims that are labeled in conformity with the requirements of Standard No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars, May be installed on passenger cars.; The requirements of S5.2 of Standard No. 120 for labeling of rims fo use on multipurpose passenger vehicles, trucks, busses, trailers, and motorcycles do not affect the use of those rims on passenger cars. This situation would change if Standard No. 110, *Tire Selection and Rims*, is modified in the future to prohibit one or more of the items required by S5.2, but such an eventuality is considered to be unlikely.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
|
ID: aiam4377OpenMr. John Scott Hatt, 1215 N. Quinn Street, Apt #2, Arlington, VA 22209; Mr. John Scott Hatt 1215 N. Quinn Street Apt #2 Arlington VA 22209; Dear Mr. Hatt: This is in reply to your letter of June 8, 1987, to this agency askin about the legality of having 'a lighted sign on the side of a car door used for advertising purposes.' You have also asked whether such a sign would be a safety hazard to other drivers.; There is no Federal prohibition against installation of such a sign Its legality would be determined under local laws where a vehicle with a lighted sign would be registered and operated. You might wish to seek the advice of Arlington traffic officials and the Virginia State Police on this subject. It is not possible to say whether such a sign would be a safety hazard. Unlit advertising signs seem permissible in some areas on the sides of buses.; Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam3155OpenMr. Bennie Stine, 1602 Emil Street, Madison, WI 53713; Mr. Bennie Stine 1602 Emil Street Madison WI 53713; Dear Mr. Stine: This responds to your letter asking whether you may remove th electronic antilock device from your vehicle. You state that the vehicle is unsafe with the antilock device in operation.; The National Highway Traffic Safety Administration believes that properly maintained antilock device can increase the safety of heavy duty vehicles. Accordingly, the agency encourages you to make sure that the antilock device on your vehicle is in the proper working order. However, if you want to remove the device, it is perfectly legal to do so. We suggest that you take the vehicle to its manufacturer or a representative of the manufacturer to be sure that the device is correctly removed and that the remaining braking system is properly adjusted.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam5360OpenMr. Nicholas S. Copass Sales Manager Titeflex Industrial Americas 170 Tapley Street Springfield, MA 01104-2893; Mr. Nicholas S. Copass Sales Manager Titeflex Industrial Americas 170 Tapley Street Springfield MA 01104-2893; Dear Mr. Copass: This responds to your letter to Mr. David Elias formerly of this office, concerning the manufacture of hydraulic brake hose assemblies by Titeflex and Russell Performance Products. I regret the delay in responding. We recently responded to a letter from Mr. Jim Davis of Russell about the labeling of the hose assemblies. I have enclosed a copy of that letter for your information. In that letter, we explain that both Titeflex's and Russell's designations need not be marked on the assembly. Instead, since Russell is manufacturing the assemblies and will market the assemblies, Russell's designation must be marked. The designation will identify Russell as the manufacturer of the assembly in the event of a possible noncompliance or defect with the assembly. I hope this information is helpful. If you have any questions, please do not hesitate to call Ms. Deirdre Fujita of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure; |
|
ID: aiam1739OpenMr. Harry J. Warmkessel,Mack Trucks, Inc.,Box M,Allentown, Pennsylvania 18105; Mr. Harry J. Warmkessel Mack Trucks Inc. Box M Allentown Pennsylvania 18105; Dear Mr. Warmkessel:#This responds to the August 1, 1974, request o Mack Trucks, inc., that the painting of brake hose end fittings be permitted under the Federal Motor Vehicle Safety Standards No. 106-74.#In the preamble to amendments to the standard which were published June 28, 1974 (39 FR 24012, Docket No. 1-5, Notice 11), the NHTSA interpreted S5.2.3 as prohibiting the painting of end fittings because required labeling would be obscured.#New information indicates that spray painting of end fittings leaves their labeling visible in most cases and that, in the occasional instance where labeling is obscured, excess paint may be easily scraped off. In addition, painting protects the labeled and fittings against corrosion. Therefore, the NHTSA is changing its interpretation of this section, so that the painting of end fittings will not be considered a violation of the standard.#The issue of masking brake hose labeling will be dealt with in the next Federal Register Notice regarding Standard No. 106-74.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
|
ID: aiam1069OpenMr. Thomas J. Biernat, Biernat Business Forms, 1300 Second Street, N.E., Minneapolis, MN 55413; Mr. Thomas J. Biernat Biernat Business Forms 1300 Second Street N.E. Minneapolis MN 55413; Dear Mr. Biernat: This is in response to your request for information concerning a acceptable form to satisfy the disclosure requirements of the Motor Vehicle Information and Cost Savings Act, Public Law 92-513.; In answer to your first question, the disclosure statement may b incorporated in the sales order form. An example of an adequate format is enclosed for your information.; Second, one copy of the statement is required to be given by th transferor to the transferee. However, good business practice makes advisable a file copy for the transferor's records.; Third, the transferor may receive the original or a copy of th statement.; Fourth, the required information is listed in the enclosed regulation There are no size requirements for the form or type.; Your suggestion to incorporate disclosure statements for both the ne and traded-in vehicles on the same form complies with the requirements if the statements are completed prior to the execution of transfer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1236OpenMr. J.W. Kennebeck, Manager,Safety and Development,Volkswagen of America, Inc.,Englewood Cliffs, New Jersey 07632; Mr. J.W. Kennebeck Manager Safety and Development Volkswagen of America Inc. Englewood Cliffs New Jersey 07632; Dear Mr. Kennebeck:#This is in reply to your letter of August 8, 1973 to Mr. Schneider asking for confirmation of your interpretation of two sections of Standard No. 105a.#You ask first whether S5.3.1 requires that the activation of an indicator lamp upon application of 50 pounds of force be instantaneous, or whether a minimal time lag is permissible. You indicated that in a 'panic stop' there is a time lag of approximately 100 milliseconds between application of 50 pounds of force and lamp activities in the VW system. Since, as you state, it is 'humanly impossible' to discern such a minimal time lag, we consider that the VW system complies with S5.3.1, and that the lamp is activated upon application of 50 pounds of force.#You are also correct in your interpretation if S5.2.1 that the 5-minute requirement applies only to vehicles that do not exceed the limit of traction on a 30 percent grade.#Sincerely,Lawrence R. Schneider,Chief Counsel; |
|
ID: aiam2054OpenMr. K. Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street, West Lyndhurst, NJ 07071; Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in response to your letter of July 30, 1975, in which you aske whether the uniform tire quality grading requirements for furnishing information to prospective purchasers of vehicles apply to prospective purchasers of vehicles other than passenger cars that may be equipped with passenger car tires. This was asked in light of the fact that the tire quality grading rule itself applies to tires manufactured for use on passenger cars.; We do not consider that the requirements of S 575.6(a) and (c) regarding the furnishing of consumer information to motor vehicle buyers and prospective purchasers, apply to the sale of trucks or other non-passenger- car vehicles where uniform tire quality grading information is concerned.; We recognize that the language of the regulation may not be entirel clear in this regard, and are considering an interpretive amendment to clarify it.; 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.