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 |
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ID: aiam4643OpenMr. Michael E. Kastner National Truck Equipment Association--Washington Office 1350 New York Avenue, N.W., Suite 800 Washington, D.C. 20005-4797; Mr. Michael E. Kastner National Truck Equipment Association--Washington Office 1350 New York Avenue N.W. Suite 800 Washington D.C. 20005-4797; Dear Mr. Kastner: Thank you for your letter to Secretary Skinne concerning the National Highway Traffic Safety Administration's (NHTSA's) actions to extend certain Federal Motor Vehicle Safety Standards (FMVSS's) to light trucks and vans. The Secretary has asked me to reply. Your letter was especially concerned with NHTSA's November 1987 amendment to FMVSS 204, Steering Control Rearward Displacement, and our denial of NTEA's petition for reconsideration of that rule. I regret that I am unable to respond to your comments at this time. As you know, the Department and NTEA are presently involved in litigation concerning those actions. In view of the litigation, we feel it would be inappropriate to address your comments in this letter. We appreciate your interest in informing the Department of your views. I can assure you that Secretary Skinner is actively interested in each of the letters he receives regarding NHTSA's mission to improve motor vehicle safety. Let me assure you also that the potential impacts on small businesses is one of our concerns in each of our rulemaking actions. A copy of your letter, and this response, will be placed in NHTSA's docket section. Sincerely, Jeffrey R. Miller Acting Administrator; |
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ID: aiam0675OpenMr. Satoshi Nishibori,Engineering Representative,Nissan Motor Co., Ltd.,Liaison Office in U.S.A.,560 Sylvan Avenue,Englewood Cliffs, New Jersey 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 560 Sylvan Avenue Englewood Cliffs New Jersey 07632; Dear Mr. Nishibori:#This is in reply to your letter if April 5 to Mr Schneider asking for an interpretation of Standard No. 106.#You ask whether it is permissible to use a rubber protector on a brake hose which masks in part the identification marking required by Standard No. 106. SAE Standard J40b, *Automotive Brake Hoses*, incorporated by reference in Standard n0.106, requires hose marking to be permanent in nature. Therefor, use of this protector is permissible, provided that its rubbing effect, if any, does not obliterate in time the required marking. #You have also asked whether you may conduct the whip test with the rubber protector removed. We have no objection to this method of conducting the whip test. Standard No. 106 is silent as to how the test may be conducted. Paragraph S5.7.4 of our proposal to amend Standard No. 106 (Docket No. 1-5, Notice 7, 35 F.R. 5855, March 30, 1971) represents our view that 'protective armor' should be removed for the fatigue test, and you may interpret this as including the rubber protectors also.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam2632OpenMr. William F. Cox, President, Cox Trailers, Inc., Grifton, NC 28530; Mr. William F. Cox President Cox Trailers Inc. Grifton NC 28530; Dear Mr. Cox: This is in reply to your letter of July 7, 1977, informing us of you wish to relocate combination stop, tail, turn signal and side marker lamps 'to the upper rear fender' of the boat trailers that you manufacture. You have asked whether this location complies with the requirements of Standard No. 108.; I am sorry that we cannot give you the interpretation you seek Standard No. 108 requires that rear side marker lamps be mounted 'as far to the rear as practicable,' and stop, tail, and turn signal lamps must be mounted 'on the rear.' Even though, in your opinion, at your planned fender location 'the lights will pass all of the required photometric and visibility requirements', when the trailer is carrying a boat the lamps are more likely to be visible 'on the rear.' (sic) as the standard requires.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2637OpenMr. John B. White, Engineering Manager, Technical Information Dept., Michelin Tire Corporation, New Hyde Park P.O., P.O. Box 3467, New York 11040; Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation New Hyde Park P.O. P.O. Box 3467 New York 11040; Dear Mr. White: This responds to your June 7, 1977, letter asking who must mark a ri in accordance with the requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, in those cases where the rim is manufactured by one manufacturer and then supplied to a wheel manufacturer who welds the rim to a disk making a completed wheel.; The National Traffic Safety Administration has determined that the ri marking must be undertaken by the rim manufacturer. The rim manufacturer is best able to supply the required rim information and undertake the certification required by S5.2 of the standard. The subsequent addition of the disc to the rim should not alter the information marked on the rim.; Sincerely, Joseph J., Levin, Jr., Chief Counsel |
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ID: aiam1621OpenMr A.J. Burgess,Vice President (Technical),Joseph Lucas North America Inc.,Two Northfield Plaza,Troy, Michigan 48084; Mr A.J. Burgess Vice President (Technical) Joseph Lucas North America Inc. Two Northfield Plaza Troy Michigan 48084; Dear Mr Burgess:#This responds to your letter of September 30,1974 enclosing sample brake hose assemblies and requesting approval of Girling's labeling and banding techniques to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, for labeling brake hoses and 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 easily be removed. From this discussion, 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 specific design.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam0173OpenStanley Hoffman, Esq., Attorney at Law, 270 Park Avenue, New York, New York 10017; Stanley Hoffman Esq. Attorney at Law 270 Park Avenue New York New York 10017; Dear Mr. Hoffman: This in further response to your letter of July 14 enclosing a engineering drawing of a hub cap 'incorporating a decorative device designed to create an impression of spinning at the center of the wheel during operation of the vehicle', and requesting an interpretation of Federal Motor Vehicle Safety Standard No. 211 with respect thereto.; Standard No. 211 specifies the requirement that hub caps, wheel nuts and wheel discs shall not incorporate winged projections. that is the sole requirement of this Standard. The drawing submitted by you depicts a hub cap which, in our judgement, incorporates a winged projection. The Standard does not regulate vehicle width, and thus your observation that 'it would not broaden or extend the front (or top or rear) profile of automobiles...' is not a factor to be considered.; I enclose (sic) the engineering drawing you furnished us. Sincerely, Lawrence R. Schneider, Acting Assistant Chief Counsel fo Regulations; |
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ID: aiam1096OpenMiss C. A. McGonigle, Senior Import Specialist, District Director of Customs, Terminal Island, California 90731; Miss C. A. McGonigle Senior Import Specialist District Director of Customs Terminal Island California 90731; Dear Miss McGonigle: This is in reply to your letter of March 15, 1973, to Mr. Armstron asking 'whether a hub cap with a wing type attachment is subject to Standard 211.'; Standard No. 211 prohibits wheel discs, wheel nuts, and hub caps tha incorporate winged projections. The item that you enclosed appears to be a wheel spinner which, when attached to a wheel disc or hub cap would create an assembly incorporating a winged projection in violation of Standard No. 211. The item itself is not literally prohibited by the standard, but it evidently has no function apart from this end use. I am therefore of the opinion, if the same source is separately shipping spinners and wheel disc/hub caps to which the spinner may be attached, that these items may be refused entry into the United States.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0573OpenMr. R. W. Ward, Chief Engineer, K-D Lamp Company, 1910 Elm Street, Cincinnati, OH 45210; Mr. R. W. Ward Chief Engineer K-D Lamp Company 1910 Elm Street Cincinnati OH 45210; Dear Mr. Ward: In your letter of January 20 to Mr. Vinson of this office you ask fo an interpretation of paragraph S4.7 'Replacement Equipment' of Motor Vehicle Safety Standard No. 108.; Standard No. 108 applies to motor vehicles manufactured on or afte January 1, 1972. The standard specifies items with which these vehicles must be equipped. The standard also applies to items manufactured on or after January 1, 1972, intended to replace items required by Standard No. 108 to be original equipment on these vehicles. This replacement equipment must be manufactured to conform to Standard No. 108 and certified as meeting all applicable Federal Motor vehicle safety standards.; The standard does not require conformance or certification of item intended as replacement equipment on vehicles manufactured before January 1, 1972 (sic) In this circumstance a manufacturer may continue to manufacture replacement equipment that does not meet Standard No. 108.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1565OpenMr. Ronald J. Hansing, Project Engineer, The Adams & Westlake Company, 1025 North Michigan Street, Elkhart, IN 46514; Mr. Ronald J. Hansing Project Engineer The Adams & Westlake Company 1025 North Michigan Street Elkhart IN 46514; Dear Mr. Hansing: This is in reply to your letter of July 3, 1974, regarding Moto Vehicle Safety Standard No. 217. You requested that we reconsider our opinion of June 11, 1974, that a bus emergency release mechanism which you describe must meet the requirements for emergency exit release in S5.3.2 of the standard after as well as before the retention test required by S5.1, when the glass breaks during the retention test.; Paragraph S5.3.2 requires that the release requirements be met bot before and after the retention test. We do not find sufficient justification to relax this requirement in the situation you described. First, it is not clear that it is as easy as you represent to eliminate by hand all of the glazing material left in the frame. More importantly, however, we still question whether most persons are sufficiently cognizant of the qualities of tempered glass to attempt to remove the remaining fragments in an emergency situation. Finally, glazing with completely different breakage characteristics may be used to replace the original tempered glass at some time during the life of the bus. For these reasons, our conclusion of June 11 remains the same.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0021OpenMr. E. L. Koepenick, Secretary-Treasurer, Fire Apparatus Manufacturers Association, Inc., 7979 Old Georgetown Road, Washington, DC 20014; Mr. E. L. Koepenick Secretary-Treasurer Fire Apparatus Manufacturers Association Inc. 7979 Old Georgetown Road Washington DC 20014; Dear Mr. Koepenick: Your March 7, 1967, letter to Dr. William Haddon, Jr., requested tha you be advised regarding the applicability of lighting requirements, as specified in the Initial Motor Vehicle Safety Standards, to fire apparatus.; With exceptions as noted in Section 255.7, page 2409 of the *Federa Register*, Volume 32, Number 23, dated February 3, 1967 (copy enclosed), the lighting requirements will be applicable to fire apparatus. Initial Standard No. 108 covers lighting requirements for vehicles (as specified therein) that are 80 or more inches wide overall and becomes effective January 1, 1968. A Notice of Proposed Rule Making (see page 2418) of enclosed *Federal Register* includes a Proposed Amendment to Standard No. 108 and a Proposed Initial Standard No. 112, covering vehicles (as specified therein) that are less than 80 inches wide overall. It is anticipated that the proposed Amendment and Initial Standard No. 112 will also become effective on January 1, 1968.; Thank you for your interest in the Motor Vehicle Safety Standards. Sincerely, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
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.