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: aiam0133OpenMr. Michael Pinto, Nottingham & Pinto, 30 Rockefeller Plaza, New York, New York 10020; Mr. Michael Pinto Nottingham & Pinto 30 Rockefeller Plaza New York New York 10020; Dear Mr. Pinto: #This is in response to your letter of December 26 1968, and as a follow-up of our meeting of January 9, both concerning your proposal to hot brand the legend 'SECOND NOT ADJ.' over part of the brand name 'ATLAS PLYCRON' tires. #Provided the branding of the legend does not make the brand name illegible it would be permissible under the motor vehicle safety standards. Examination of the photos you submitted indicates that no pard of the brand name is obliterated and only one letter is affected, although still clearly visible. Therefore, as long as one of the methods of branding shown in the photos is followed, the labeling requirements of standard No. 109 with regard to the brand name will have been met. #Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel for Regulations; |
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ID: aiam1530OpenMr. K. Nakjima,Director/General Manager,Factory Representative Office,Toyota Motor Sales, U.S.A., Inc.,1099 Wall Street,West Lyndhurst, New Jersey 07071; Mr. K. Nakjima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima:#This responds to your June 11, 1974, request fo approval of Toyota's banding design to meet the requirements of Standard No. 106, *Brake hoses*, for labeling brake hose assemblies.#The NHTSA interprets a band as 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 be easily removed. You should be able to determinate the compliance of your labeling method with the standard. It does appear that the Toyota label does not encircle the assembly and attach to itself. The NHTSA does not approve specific designs in advance, in any case, because the material, installing method, and underlying material can significantly affect the quality of a specific design.#Yours truly,Richard B. Dyson,Assisting Chief Counsel; |
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ID: aiam0536OpenJohann und Konen, 53 Bonn-Beuel 1, Rosenbach 32, Ortsteil Putzen, Germany; Johann und Konen 53 Bonn-Beuel 1 Rosenbach 32 Ortsteil Putzen Germany; Gentlemen: This is in reference to your letter of August 22, 1972, requestin information relative to Federal Motor Vehicle Safety Standard No. 125, 'Warning Devices.'; You state that the width of the reflex reflective material in th Warning Triangle you are concerned with is 1.6732 inches, and inquire whether it is permissible to utilize 'for manufacturing reasons' a non-reflective border around the reflective material which would increase the width of the red reflective section to 1.8504 inches.; Paragraph S5.2.2 of Standard 125 specifies that the width of each o the three sides of the triangular portion of the warning device shall be not less than 2 and not more than 3 inches wide, as depicted in Figure 1. If the required widths specified in S5.2.5 for the red reflex reflective and orange fluorescent materials are met, provision of non-reflective or non-fluorescent 'border' material is permitted, as long as the overall width requirements for the side of the triangle are also met.; I hope this answers your questions. Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0193OpenMr. David A. Phelps, Jr., Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps: Thank you for your letter of December 9, 1969, providing additiona information on the school bus lighting system as described in your previous letter of November 14, 1969.; Paragraph S3.1.2 of Federal Motor Vehicle Safety Standard No. 10 specifies that, 'No additional lamp, reflective device, and associated equipment shall be installed if it impairs the effectiveness of the required equipment.' The system of front stop lamps as described in your letters, i.e., two non-flashing amber lamps of the same size as and located in line with the two red school bus signal lamps, and actuated by the foot brake only, would not appear to impair the effectiveness of the lighting equipment required by Standard No. 108. It should be noted, however, that, while incorporation of this system in school buses would not be precluded by Standard No. 108, the various States may interpose restrictions as to such system. I would suggest, therefore, that you review the applicable State regulations before initiating installation of the system.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam1567OpenMs. Viola Back, 4784 Brookwood Road, Youngstown, OH 44512; Ms. Viola Back 4784 Brookwood Road Youngstown OH 44512; Dear Ms. Beck (sic): This is in response to your letter of July 15, 1974, inquiring as t penalties available for violation of the odometer requirements of the Motor Vehicle Information and Cost Savings Act.; The Act requires, in part, that a written disclosure of a vehicle' recorded mileage be provided by the seller to the purchaser at the time ownership of a vehicle is transferred. If the correct mileage is unknown, the Act requires a statement to that effect to be furnished in written form to the buyer.; Violation of the disclosure requirement may subject the violator t civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages, whichever is greater. To obtain this remedy, section 409 of the Act provides that a private civil action be instituted in State or Federal Court.; There is no provision in the Act specifying that the transferee mus obtain a disclosure statement from his transferor. The obligation to execute this disclosure document lies with the transferor alone.; For your information, I have enclosed relevant portions of the Act an the odometer disclosure requirements.; If you have any further questions, please let us know. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2578OpenMr. Martin Fleischman, Chairman, Video Research Corporation, Interstate Industrial Park, Riviera Beach, Florida 33404; Mr. Martin Fleischman Chairman Video Research Corporation Interstate Industrial Park Riviera Beach Florida 33404; Dear Mr. Fleischman: This is in response to your letter of March 15, 1977, concernin Federal Motor Vehicle Safety Standard no. 114, *Theft Protection*, as it relates to a device you wish to market called 'Remote Auto-Start.'; Standard No. 114, *Theft Protection*, which applies to passenger cars requires that when the key is removed, normal activation of the car's engine and either steering or forward self-mobility of the car is prevented (49 CFR 571.114, S4.1(a) and (b)). According to the material which you forwarded, your device results in the following characteristics which differ from what we consider to be normal activation:; >>>1. The engine deactivates when a door is opened. 2. The steering column and gear shift remains locked until the actua key is inserted.; 3. The logic circuitry deactivates the engine after 15 minutes.<<< Consequently, we have determined that your device does not result in 'normal' activation of the car's engine.; Thus, it appears that the characteristics of the 'Remote Auto-Start system are not in conflict with Standard No. 114.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0633OpenAlberto Negro, Manager, D.C.R.S. USA Office, Fiat Motor Company, Inc., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Alberto Negro Manager D.C.R.S. USA Office Fiat Motor Company Inc. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Negro: This is in reply to your letter of March 3, 1972, concerning multipl audible warning requirements.; The audible warning requirements of Federal Motor Vehicle Safet Standards 114 and 208 can be met with the use of one system rather than two separate ones.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam0171OpenMr. Henry T. Skipper, Jr., Vice-President, Sales, Great Dane trailers, Incorporated, Lathrop Avenue, P.O. Box 1159, Savannah, GA 31402; Mr. Henry T. Skipper Jr. Vice-President Sales Great Dane trailers Incorporated Lathrop Avenue P.O. Box 1159 Savannah GA 31402; Dear Mr. Skipper: This is in reply to your letter of August 4, 1969, in which you aske whether the name of your company may be placed on the certification label affixed to vehicles manufactured by another company.; The question of 'private brand' manufacturing was raised at variou stages of rulemaking in respect to the certification regulations. It was decided that the certification label on a vehicle must show the name of the actual manufacturer. This information is important in the enforcement of standards and regulations under the Act. The Vehicle Safety Act, moreover, places primary responsibility for conformity to the standards, and for certification of conformity, on the manufacturer, and the regulations are designed to implement that intent. You should note, however, that as a distributor of the vehicles in question you share the responsibility for compliance with the standards to the extent of your knowledge, and participate in the certification by passing it along to dealers or other distributors.; We are pleased to be of assistance. Sincerely, Dowell H. Anders, Acting Chief Counsel |
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ID: aiam2047OpenMr. Rex Henger, Bergman & Hicks, Republic National Bank Tower, Dallas, TX 75201; Mr. Rex Henger Bergman & Hicks Republic National Bank Tower Dallas TX 75201; Dear Mr. Henger: This is in response to your letter of September 3, 1975, in which yo inquire as to the existence of regulations concerning vehicle certification.; The National Highway Traffic Safety Administration has promulgate regulations requiring vehicle manufacturers to affix to each vehicle a label stating that the vehicle as completed complies with applicable Federal Motor Vehicle Safety Standards (49 CFR SS 567 and 568). There is no requirement that 'stress capacity' be included in the certification label. However, the label must state the vehicle's gross vehicle weight rating (49 CFR S 567.4(g)(3)) and gross axle weight rating (49 CFR SS 567.4(g)(4) and 571.3). The gross axle weight rating is the value set by the manufacturer as the load- carrying capacity of a single axle system on the vehicle. The statutory basis for these regulations is section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1403).; We hope this information will be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0059OpenMr. Dick Romney, Sales Manager, Utility Body Company, 901 Gilman Street, Berkeley, CA 94710; Mr. Dick Romney Sales Manager Utility Body Company 901 Gilman Street Berkeley CA 94710; Dear Mr. Romney: This is in response to your letter of March 7, 1968 in which you aske if your company, a manufacturer of truck bodies and truck equipment that installs its product on a chassis furnished by a dealer or the ultimate user, its required to certify that 'the completed package, *including the chassis*, meets Standard 108?'; Under the National Traffic and Motor Vehicle Safety Act of 1966, yo are responsible for completing the vehicle so that it meets applicable standards. This means the vehicle should be assembled in a way that will not disturb existing compliance, and that portion of the vehicle you add must comply with any applicable standard.; This is a duty separate from certification. You are required to certif compliance under section 114 of the Act only if you deliver a completed vehicle to a distributor or dealer, and the certification would be as to all standards applicable to the vehicle, including Standard 108.; Sincerely, Robert M. O'Mahoney, Assistant 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.