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: aiam1534OpenMr. Frank R. Schubert,Heavy Vehicle Systems Group,The Bendix Corporation,901 Cleveland Street,Elyria, Ohio 44035; Mr. Frank R. Schubert Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria Ohio 44035; Dear Mr. Schubert:#This responds to your April 29, 1974, request fo approval of your banding designs to meet the requirements of Standard No. 106, *Brake hoses*,for labeling brake hose assemblies.#The NHTSA interprets a band a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From these statements, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of any design.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam3901OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of January 11, 1985, to Mr. Vinson o this office, asking for a clarification of certain terminology relating to the definition of a standardized replaceable light source in Motor Vehicle Safety Standard No. 108.; We are aware of the problem underlying your question, i.e., that th standard contemplates testing of the bulb with its base but the photometrics specified are appropriate for the capsule portion alone. Our Rulemaking staff is reviewing this issue. The agency will inform you of the results of that review. If appropriate, the issue will be addressed through an appropriate interpretation or amendment of the standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1835OpenMr. Donald W. Taylor, Volvo of America Corp., Rockleigh, NJ 07647; Mr. Donald W. Taylor Volvo of America Corp. Rockleigh NJ 07647; Dear Mr. Taylor: This responds to Volvo of America Corporations's (sic) March 3, 1975 question whether a braking system which employs air pressure modulated by the vehicle operator to provide the energy used to actuate the brakes is an air brake system subject to Standard No. 121, *Air brake systems*.; The answer to this question is yes. We do not agree that such a syste could qualify as a hydraulic brake system under the definition found in Standard No. 105-75, *Hydraulic brake systems*. That definition requires that a hydraulic brake system employ hydraulic fluid as a medium for transmitting force 'from a service brake control to the service brake', which is not the case in the system you describe. The system in question appears to be what is popularly known as an 'air over hydraulic' system. With regard to such systems, NHTSA has stated in a preamble to the air brake standard: 'It should be noted that the term 'air brake system' as defined in this standard applies to the brake configuration commonly referred to as 'air over hydraulic,' in which failure of either medium can result in complete loss of braking ability.' (36 FR 3817, February 27, 1971).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1132OpenMr. Lawrence D. Beshore, Femco, Inc., P.O. Box 687, 500 North Bypass, McPherson, KS 67460; Mr. Lawrence D. Beshore Femco Inc. P.O. Box 687 500 North Bypass McPherson KS 67460; Dear Mr. Beshore: This is in reply to your letter of April 16, 1973, inquiring whethe any Federal laws apply to your building and installation of a man-lift (pictures of which you enclose) in a completed pick-up truck. You state you understand that if the man-lift is installed on a completed vehicle, you are not considered the final-stage manufacturer.; Based on the information you have provided us, we believe you interpretation to be correct. It does not appear that you have altered the pick-up truck in a way that would make your company responsible for conformity with Federal safety standards or regulations.; The NHTSA has proposed certain requirements for vehicle alterers (cop enclosed). These requirements would very likely apply to you, when effective, if the addition of the man-lift occurs before the purchase of the pick-up truck for a purpose other than resale.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1131OpenMr. Lawrence D. Beshore, Femco, Inc., P.O. Box 687, 500 North Bypass, McPherson, KS 67460; Mr. Lawrence D. Beshore Femco Inc. P.O. Box 687 500 North Bypass McPherson KS 67460; Dear Mr. Beshore: This is in reply to your letter of April 16, 1973, inquiring whethe any Federal laws apply to your building and installation of a man-lift (pictures of which you enclose) in a completed pick-up truck. You state you understand that if the man-lift is installed on a completed vehicle, you are not considered the final-stage manufacturer.; Based on the information you have provided us, we believe you interpretation to be correct. It does not appear that you have altered the pick-up truck in a way that would make your company responsible for conformity with Federal safety standards or regulations.; The NHTSA has proposed certain requirements for vehicle alterers (cop enclosed). These requirements would very likely apply to you, when effective, if the addition of the man-lift occurs before the purchase of the pick-up truck for a purpose other than resale.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3276OpenMr. F.L. Krall, Manager, Technical legislation, International Harvester Company, 2911 Meyer Road, Fort Wayne, Indiana 46803; Mr. F.L. Krall Manager Technical legislation International Harvester Company 2911 Meyer Road Fort Wayne Indiana 46803; Dear Mr. Krall: This is in response to your letter of April 3, 1980, requestin confirmation of the applicability ofS4.4 of Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) solely to light trucks and passenger cars.; Although Standard No. 115 applies to a variety of vehicle types including multipurpose passenger vehicles, the location requirements in S4.4 regarding the placement of the vehicle identification number is of more limited applicability. The section expressly provides that the requirement applies to passenger cars and to trucks with a gross vehicle weight rating (GVWR) of 10,000 pounds or less only. Since Standard No. 115 does not contain any other VIN location requirement, manufacturers of multipurpose passenger vehicles, buses, trailers, incomplete vehicles, and heavy trucks are not limited by that standard in their choice of a VIN location. For definitions of these vehicle types, see 49 CFR 571.3.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4687OpenMr. M. Iwase General Manager Technical Administration Department Koito Mfg. Co. Ltd. Shizuoka Works 500, Kitawaki Shimizu-Shi, Shizuoka-Ken Japan; Mr. M. Iwase General Manager Technical Administration Department Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimizu-Shi Shizuoka-Ken Japan; Dear Mr. Iwase: This is in response to your letter of November 20, l99 with respect to 'interpretation and/or petition' concerning combination headlighting systems. Koito has asked about the permissibility of two or four lamp headlighting systems in which the upper beam would be provided by integral beam headlamps, and the lower beam by replaceable bulb headlamps. The systems you describe would not be permissible under Standard No. 108, which allows only the three types of headlighting systems that you mention. Integral beam headlighting systems must be comprised of integral beam headlamps which, by definition, are headlamps other than sealed beam or replaceable bulb headlamps. Replaceable bulb headlighting systems are those that incorporate the standardized replaceable light sources listed in Standard No. 108. We are transmitting your request to the Office of Rulemaking, for consideration as a petition for rulemaking. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam0130OpenMr. J. Wuddel, Ing., Westfalische Metall Industrie KG, Hueck and Company, 4780 Lippstadt/Westf., Germany; Mr. J. Wuddel Ing. Westfalische Metall Industrie KG Hueck and Company 4780 Lippstadt/Westf. Germany; Dear Mr. Wuddel: Thank you for your letter of February 11, 1969, to Mr. David A. Fay concerning your request for an interpretation on Standard No. 108.; Subsection (d) of Section 103 of the National Traffic and Motor Vehicl Safety Act of 1966 states 'Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item or equipment which is not identical to the Federal standard...'; Since Federal Motor Vehicle Safety Standard No. 108 is now in effect and permits red or amber rear turn signal lamps, the States cannot restrict these lamps to be red only.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam2069OpenMr. Tokio Iinuma, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tokio Iinuma Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Iinuma: This is in response to your letter of September 17, 1975, in which yo ask whether a permanent label affixed to the inside surface of a hubcap would satisfy the requirements of a new proposed paragraph S3.2 of Standard No. 211.; The intent of the proposed labeling requirements, part of a genera identification scheme for motor vehicle equipment manufacturers, is to ensure rapid and efficient identification of the manufacturer of a defective or nonconforming part or vehicle. The placement of an identifying label on the inside of a hubcap would not hinder rapid identification of the manufacturer. Therefore, the National Highway Traffic Safety Administration would consider that a label that is permanently affixed to the inside surface of a hubcap and contains the information specified in proposed paragraph S3.2 of Standard No. 211 would comply with the requirements of S3.2.; We hope this answer is satisfactory. If you have any other questions please contact us.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2610OpenMr. James M. Beach, Director of Engineering, Collins Industries, Inc., P. O. Box 58, Hutchinson, KS 67501; Mr. James M. Beach Director of Engineering Collins Industries Inc. P. O. Box 58 Hutchinson KS 67501; Dear Mr. Beach: This responds to your May 6, 1977, question whether Safety Standard No 301-75, *Fuel System Integrity*, is applicable to all school buses or only to school buses with a GVWR greater than 10,000 pounds.; You are correct in your statement that school buses are included in th broader classification, 'buses', for purposes of the Federal motor vehicle safety standards, unless otherwise specified in a particular standard. Safety Standard No. 301-75 is applicable to passenger cars, and to multipurpose passenger vehicles, trucks and buses that have a GVWR of 10,000 pounds of less, including school buses under 10,000 pounds. The standard is also applicable to larger school buses, and the distinction is made in the standard since the large school buses are the only vehicles having a GVWR greater than 10,000 pounds that are covered by the standard.; Safety Standard No. 301-75 was made applicable to all school buse pursuant to a mandate under the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. 1392(i)(1)(A)).; 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.