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: aiam1070OpenMr. R. K. Ferwerda, President, Great Southern Equipment Company of Tampa, 1023 South 50th Street, Tampa, FL 33619; Mr. R. K. Ferwerda President Great Southern Equipment Company of Tampa 1023 South 50th Street Tampa FL 33619; Dear Mr. Ferwerda: This is in reply to your letter of January 31, 1973, requesting 'a application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks'.; Under NHTSA regulations, the operations you perform appear to make yo a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, 'Manufacturer Identification'.; Copies of NHTSA regulations may be obtained as indicated on th enclosed. 'Where to Obtain Motor Vehicle Safety Standards and Regulations'. We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1071OpenMr. R. K. Ferwerda, President, Great Southern Equipment Company of Tampa, 1023 South 50th Street, Tampa, FL 33619; Mr. R. K. Ferwerda President Great Southern Equipment Company of Tampa 1023 South 50th Street Tampa FL 33619; Dear Mr. Ferwerda: This is in reply to your letter of January 31, 1973, requesting 'a application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks'.; Under NHTSA regulations, the operations you perform appear to make yo a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, 'Manufacturer Identification'.; Copies of NHTSA regulations may be obtained as indicated on th enclosed. 'Where to Obtain Motor Vehicle Safety Standards and Regulations'. We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2665OpenMr. R. W. Hildebrandt, Group Director of Engineering, Bendix Heavy Vehicle Systems Group, The Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hildebrandt Group Director of Engineering Bendix Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hildebrandt: This is to advise you that the National Highway Traffic Safet Administration (NHTSA) has decided to grant The Bendix Corporation's September 14, 1977, petition requesting the revision of the parking brake release requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 121, *Air Brake Systems*. A similar petition was received from Fruehauf Corporation and it is also being granted.; You should understand that our commencement of a rulemaking proceedin does not signify that the rule in question will be issued. A decision to the issuance of the rule will be made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.; You also requested written confirmation that the interpretation o S5.6.3 of FMVSS No. 121 given by NHTSA to Motor Coach Industries, Inc. on April 14, 1976, would pertain to the air/spring parking brake system described in your letter. Your assumption is correct, and this letter constitutes such written confirmation.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2597OpenMr. Francis Levett, Independent Coach Corporation, Box 73, Lawrence, NY 11559; Mr. Francis Levett Independent Coach Corporation Box 73 Lawrence NY 11559; Dear Mr. Levett: This is in further reply to your phone call of May 12, 1977, to Davi Soule regarding the new school buses you ordered last November. You asked whether the buses that will be delivered to you will meet the Federal Motor Vehicle Safety Standards which became effective April 1, 1977.; The applicability of Federal standards is determined by the date o manufacture of the vehicle. For vehicles that are completed by mounting a body on a chassis, the manufacturer can treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*), the date of final completion of the vehicle, or a date between those two dates. Since the chassis of the vehicles you ordered were manufactured prior to April 1, the completed vehicle need not meet the requirements of the new school bus safety standards.; Any arrangements for having your buses meet the new Federa requirements in this instance would have to be made by contract with the Wayne Corporation, builders of your bus bodies.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2436OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P.O. Box 898, Sacramento, California 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P.O. Box 898 Sacramento California 95804; Dear Mr. Commander Heath: This responds to your September 16, 1976, question whether any Federa regulation required that the maximum load rating assigned to a passenger car tire be reduced by approximately 10 percent in calculating its maximum load rating for use on a multipurpose passenger vehicle (MPV), truck, or bus.; The answer to your question is yes. Standard No. 120, *Tire Selectio and Rims for Motor Vehicles Other than Passenger Cars*, became effective September 1, 1976, and provides for the reduced maximum load rating you describe. Section S5.1.2 of the standard provides in part that '[w]hen a tire listed in [the passenger car tire standard] is installed on a multipurpose passenger vehicle, truck, bus, or trailer, the tire's load rating shall be reduced by dividing by 1.10 before calculating the sum [that must at least equal the axle system's gross axle weight rating].' A copy of the standard, with subsequent amendments, is enclosed for your information.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1681OpenFrank Mayer, P. Eng.,Gates Rubber of Canada Ltd,300 Henry Street, P.O. Box 310,Brantford, Ontario N3T 5w1; Frank Mayer P. Eng. Gates Rubber of Canada Ltd 300 Henry Street P.O. Box 310 Brantford Ontario N3T 5w1; Dear Mr. Mayer:#Please forgive the delay in responding to your reques of September 29, 1974, for information on Federal Motor Vehicle Safety Standard No. 106-74, *Brake hoses*. A copy of the standard is enclosed, along with a copy of the most recent amendment. To keep abreast of future changes, please refer to the enclosure, 'Where to Obtain Motor Vehicle Safety Standards and Regulations.' #Please note that the definition of 'brake hose assembly' excludes assemblies containing used components. Thus an assembly consisting of used renewable or reuseable end fitting and new replacement hose, for example, is not subject to the banding pursuant to S5.2.2(a) through (d) as incorporated in S7.2, whether it is destined for newly-manufactured vehicles or for the replacement market. I hope this answers satisfactority (sic.) the questions asked by Mr. A.W. Oswald in his letter of September 25, 1974.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4514OpenMr. J. Mike Callahan Precision Images P.O. Box 5524 Kent, Washington 9803l; Mr. J. Mike Callahan Precision Images P.O. Box 5524 Kent Washington 9803l; Dear Mr. Callahan: This is in reply to your letter of April l4, 1987 to Mr. Vinson of this office with respect to your representation of a company 'that will be selling plastic name plates which would be installed behind the red lens of the third brake light.' You stated that 'these are to be sold to new car dealerships. When the driver of the car steps on the brake the dealer's name lights up.' You ask for letters regarding the legality of the name plates for 24 States. We regret the delay in responding to your request. When Mr. Vinson tried to reach you by phone this week he was told that you had already received a letter, and that the answer was negative. Perhaps that letter came from one of the 24 States listed in your letter. We are unable to advise you of the legality under State laws, but I have enclosed representative interpretation letters of this agency on the legality of similar devices under Federal law. Sincerely, Erika Z. Jones Chief Counsel /; |
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ID: aiam3131OpenMr. Roger E. Maugh, Director, Automotive Safety Office, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. Roger E. Maugh Director Automotive Safety Office Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. Maugh: Re: Distribution of Imported Vehicles Brought Into Conformity Wit Applicable Federal Motor Vehicle Safety Standards; This is in reply to Mr. Eckhold's letter of September 28, 1979, to Mr Vinson of this office asking for our concurrence in Ford's wish to sell 60 1978 model Ford Fiestas on the American market.; According to Mr. Eckhold's letter, 56 of the cars did not comply wit the Federal motor vehicle safety standards at the time they entered the United States for use by Ford in testing and training programs. Ford represents that all these have now been brought into compliance. The four remaining Fiestas conformed at the time of entry but, presumably, because of the execution of the HS-7 importation form, were not certified.; We concur with Ford's opinion that all conforming vehicles may now b sold in the United States. However, since such sales are to first purchasers for purposes other than resale, a certification label must be attached to each that meets the requirements of 49 CFR Part 567.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4934OpenMr. Tony Llama President Davenport Enterprises 301 Almeria Ave., Suite 1 Coral Gables, FL 33134; Mr. Tony Llama President Davenport Enterprises 301 Almeria Ave. Suite 1 Coral Gables FL 33134; Dear Mr. Llama: This responds to your letter of December 13, l99l, wit respect to the permissibility of temporarily importing a Fiat from Brazil that is not in conformance with the Federal motor vehicle safety standards. The purpose of the importation is to design and build an air conditioning system for the car. Upon completion of this work, the Fiat will be exported. You have enclosed a copy of my letter of August 2, 1990, granting permission for the importation of a van manufactured in the Soviet Union for which you had been asked to design an air conditioning system. In that letter, I informed you that it would be appropriate for you to enter the van pursuant to 49 CFR section 591.5(j), under the declaration that the vehicle is being imported solely for the purpose of research, investigations, and studies or demonstrations. Under the circumstances outlined in your letter, we believe that it would be appropriate for you to enter the Brazilian Fiat as well under section 591.5(j). If you have any further questions, we shall be happy to answer them. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam3130OpenMr. Roger E. Maugh, Director, Automotive Safety Office, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. Roger E. Maugh Director Automotive Safety Office Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. Maugh: Re: Distribution of Imported Vehicles Brought Into Conformity Wit Applicable Federal Motor Vehicle Safety Standards; This is in reply to Mr. Eckhold's letter of September 28, 1979, to Mr Vinson of this office asking for our concurrence in Ford's wish to sell 60 1978 model Ford Fiestas on the American market.; According to Mr. Eckhold's letter, 56 of the cars did not comply wit the Federal motor vehicle safety standards at the time they entered the United States for use by Ford in testing and training programs. Ford represents that all these have now been brought into compliance. The four remaining Fiestas conformed at the time of entry but, presumably, because of the execution of the HS-7 importation form, were not certified.; We concur with Ford's opinion that all conforming vehicles may now b sold in the United States. However, since such sales are to first purchasers for purposes other than resale, a certification label must be attached to each that meets the requirements of 49 CFR Part 567.; Sincerely, Frank Berndt, 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.