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: aiam0478OpenMr. William B. Whitney, Vice President - Editorial Director, Tire Review, 11 South Forge Street, Akron, Ohio 44304; Mr. William B. Whitney Vice President - Editorial Director Tire Review 11 South Forge Street Akron Ohio 44304; Dear Mr. Whitney: This is in reply to your letters of August 10 and October 6, 1971 concerning the size requirements for retreaded tires as specified in Federal Motor Vehicle Safety Standard No. 117. You letter of August 10 enclosed a draft article that you requested we examine.; I have enclosed a copy of the Administration's action on the petition for reconsideration that were received in response to the standard as published April 17, 1971 (36 F.R. 7315). This action amends the size requirements of S5.1.2 of the standard by allowing a minus 3 per cent deviation from the section width specified in Table 1 of Appendix A of Standard No. 109 in addition to the plus 10 per cent deviation previously allowed. With reference to your draft article, its discussion of the size requirements, apart from the changes made by the amendment, is accurate.; The copies of Appendix A of Standard No. 109 that you were furnished o August 20 have been supplemented, and a copy of the additional material is also enclosed.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2790OpenMr. Moe Pare, Jr., Director of Design, Cars & Concepts, Inc., 12500 E. Grand River, Brighton, MI 48116; Mr. Moe Pare Jr. Director of Design Cars & Concepts Inc. 12500 E. Grand River Brighton MI 48116; Dear Mr. Pare: This responds to your letter of February 16, 1978, asking whether th certification markings required on glazing materials by Safety Standard No. 205 must remain visible from the interior or exterior of a vehicle after installation.; The answer to your question is no. There is nothing in th certification requirements of section S6 of Standard No. 205 that requires the markings to remain visible after installation on the vehicle. As long as the glazing manufacturer has certified and marked his glazing in accordance with the standard and as long as these markings are not removed by the vehicle manufacturer there is no prohibition against covering the markings.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2628OpenMr. Glenn Taylor, President, Bankhead Enterprises, Inc., 1600 Ellsworth Industrial Drive, N.W., Atlanta, GA 30318; Mr. Glenn Taylor President Bankhead Enterprises Inc. 1600 Ellsworth Industrial Drive N.W. Atlanta GA 30318; Dear Mr. Taylor: This responds to your June 7, 1977, question whether the traile portion of an auto transporter must comply with Standard No. 121, *Air Brake Systems*, if it is manufactured after the current September 1, 1977, termination date for the exclusion of auto transporters from the standard.; As stated in a telephone conversation between you and Mr. Herlihy o this office, the current exclusion for auto transporters terminates September 1, 1977, and either portion of an auto transporter manufactured after that date must comply. Recently, the NHTSA proposed extension of the auto transporter exclusion from September 1, 1977, to January 1, 1979 (copy of proposal enclosed). The comment closing period ended July 11, 1977, and the agency hopes to reach a decision on the proposal in the near future.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3524OpenMr. Brian Gill, Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, Gardena, CA 90247; Mr. Brian Gill Manager Certification Department American Honda Motor Co. Inc. P.O. Box 50 Gardena CA 90247; Dear Mr. Gill: This is in reply to your letter of December 11, 1981, asking fo confirmation of your interpretation of paragraph S5.2.5 of Motor Vehicle Safety Standard No. 123, *Motorcycle Controls and Displays*.; Paragraph S5.2.5 requires that 'Each footrest for a passenger othe than an operator shall fold rearward and upward when not in use.' Honda would like to use a 'footboard' instead of a 'footrest'. In folding, the footboard folds upward in a clockwise manner and rearward and Honda believes that this meets Standard No. 123. We consider that the purpose of S5.2.5 is to prevent accidents caused by rigid footrests contacting the ground in a banking turn. The outer edge of the footboard in plan view lies inboard of wider parts of the vehicle such as the engine guard pipe and side bumper. This means that these portions of the motorcycle would contact the ground in an extreme banking turn before the proposed footboard.; The standard specifies no direction of upward motion of the footrest We believe your design complies with the intent of Standard No. 123.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3087OpenMr. Ron Bechtel, Halliburton Services, Drawer 1431, Ducan, Oklahoma 73533; Mr. Ron Bechtel Halliburton Services Drawer 1431 Ducan Oklahoma 73533; Dear Mr. Bechtel: This is in response to your letter of May 1, 1979, requesting a interpretation of the definition of 'incomplete vehicle' contained in Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your subsequent telephone conversations with Mr. Schwartz of my office.; The term 'incomplete vehicle' is defined in S3 of the standard to mea 'an assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attached components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed trailer.; You are correct in saying that most of the components listed in th definition are not meant to be part of a trailer. Consequently, an incomplete Trailer would consist of only those components, such as a frame, listed in the definition which are meant to be part of the completed trailer. The outfitting of an incomplete trailer for a specific purpose would not be sufficient to make Halliburton Serviced responsible for assigning the vehicle identification number.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1177OpenMr. Donald W. Taylor, Engineering Liaison Representative, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. Donald W. Taylor Engineering Liaison Representative Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Taylor: This is in reply to your letter of July 11, 1973, asking for a waive of 49 CFR S575.6(c) with respect to consumer information that Volvo of America would like to supply to prospective purchasers of 500 passenger cars beginning July 30, 1973.; There is no provision in the Consumer Information Regulation empowering the Administrator to waive the 30 day requirement and therefore we are unable to grant this request. We do not view the lack of this authority as unjust, given the purpose of the requirement 'so that there may be an evaluation and dissemination to the public of this information if deemed appropriate' (34F.R.11501).; We received your material on July 12, and the 30 day period will expir on August 11.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2809OpenMr. William Shapiro, Manager, Regulatory Affairs, Product Planning and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. William Shapiro Manager Regulatory Affairs Product Planning and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Shapiro: This is in reply to your letter of May 3, 1978 asking whether there i any legal objection to Volvo's installation of red rear fog lamps on passenger cars it sells in the United States.; As you have noted, 'the only possible objection' to these lamps is th prohibition of S4.1.3 of Motor Vehicle Safety Standard No. 108 against the installation of lamps that impair the effectiveness of lighting equipment mandated by the standard. We have no basis for disagreeing with your opinion that the red 'rear fog lamps do not impair the effectiveness of other lighting equipment.' However, the lamps would be subject to the laws of the individual States.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1178OpenMr. Donald W. Taylor, Engineering Liaison Representative, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. Donald W. Taylor Engineering Liaison Representative Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Taylor: This is in reply to your letter of July 11, 1973, asking for a waive of 49 CFR S575.6(c) with respect to consumer information that Volvo of America would like to supply to prospective purchasers of 500 passenger cars beginning July 30, 1973.; There is no provision in the Consumer Information Regulation empowering the Administrator to waive the 30 day requirement and therefore we are unable to grant this request. We do not view the lack of this authority as unjust, given the purpose of the requirement 'so that there may be an evaluation and dissemination to the public of this information if deemed appropriate' (34F.R.11501).; We received your material on July 12, and the 30 day period will expir on August 11.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0415OpenMr. David A. Phelps, Jr., Group Supervisor, Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Group Supervisor Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps:#This is in reply to your letter of July 7 askin whether paragraph S4.2 of Standard No. 101 requires labeling of 'a heater water valve near the floor in the driver's area.'#As you know, Standard No. 101 requires identification of heating and air conditioning controls that are manually operable and mounted in a location other than on the floor. Your heater water valve is manually operable and not floor mounted, and it is our opinion that Standard No. 101 requires its identification. This agency published an interpretation on May 4, 1971, copy enclosed (see p. 8297), in response to a query from Ford 'whether controls visible to the driver but not in the normal forward line of sight must be identified.' We replied in the affirmative that although controls may be 'designed to be operable by touch, their function is not clear to an operator unfamiliar with the vehicle in which they are installed, and their identification is necessary.' For the same reason paragraph S4.2 of Standard No. 101 requires identification of your heater water valve control.#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam0414OpenMr. David A. Phelps, Jr., Group Supervisor, Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Group Supervisor Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps:#This is in reply to your letter of July 7 askin whether paragraph S4.2 of Standard No. 101 requires labeling of 'a heater water valve near the floor in the driver's area.'#As you know, Standard No. 101 requires identification of heating and air conditioning controls that are manually operable and mounted in a location other than on the floor. Your heater water valve is manually operable and not floor mounted, and it is our opinion that Standard No. 101 requires its identification. This agency published an interpretation on May 4, 1971, copy enclosed (see p. 8297), in response to a query from Ford 'whether controls visible to the driver but not in the normal forward line of sight must be identified.' We replied in the affirmative that although controls may be 'designed to be operable by touch, their function is not clear to an operator unfamiliar with the vehicle in which they are installed, and their identification is necessary.' For the same reason paragraph S4.2 of Standard No. 101 requires identification of your heater water valve control.#Sincerely, Lawrence R. Schneider, 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.