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: aiam1586OpenMr. R.W. Cheetham, Director of Quality Assurance, Armstrong Rubber Company, 500 Sargent Drive, New Haven, CT 06507; Mr. R.W. Cheetham Director of Quality Assurance Armstrong Rubber Company 500 Sargent Drive New Haven CT 06507; Dear Mr. Cheetham: This will confirm that the suggested defect notification letter enclosed in your letter of August 14, 1974, meets the requirements of 49 CFR Part 577.; We appreciate your taking this action with respect to the Steel Belte Surveyor 78 tire.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam1357OpenMr. James M. Robertson, University Club Tower, Suite 2410, Tulsa, OK 74119; Mr. James M. Robertson University Club Tower Suite 2410 Tulsa OK 74119; Dear Mr. Robertson: This responds to your December 10, 1973, question whether a deale violates the odometer Disclosure Requirements of the Motor Vehicle Information and Cost Savings Act and 49 CFR Part 580 if he simply duplicates the disclosure made to him when he bought the car.; If the dealer acts in good faith in making his disclosure, he i entitled to rely on the disclosure made to him as the basis of his statement. On the other hand, collusion between the dealer and the former owner to knowingly make a false disclosure would violate the Act. Either might be subject to suit and damages if intent to defraud can be shown.; We realize that such a burden of proof is difficult to meet and w suggest that, with regard to the dealer, an alternative remedy might be a report of possible misrepresentation to the state agency that licenses dealers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0843OpenMr. Roy G. Mason, AMCON, 770 Privet Court, Sunnyvale, CA 94086; Mr. Roy G. Mason AMCON 770 Privet Court Sunnyvale CA 94086; Dear Mr. Mason: This is in reply to your letter of August 30, 1972, on the possibl effects of bumper legislation on the type of bicycle and tire carrier manufactured by your company.; The National Highway Traffic Safety Administration has adopted Moto Vehicle Safety Standard No. 215 to establish a minimum level for the performance of passenger car bumpers in low speed impacts. The standard applies to new vehicles. It does not apply to equipment that may be placed on or near the bumper after the vehicle has been sold to a customer. If your products are installed after the sale of the vehicle, they are not affected by Standard No. 215.; The State statutes with which we are familiar also apply to ne vehicles and would presumably not affect the installation of your products. However, you might find it advisable to ask the opinion of responsible State officials on this question.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4134OpenMr. Bob Quick, 1830 North Ridge Street, Coralville, IA 52241; Mr. Bob Quick 1830 North Ridge Street Coralville IA 52241; Dear Mr. Quick: Thank you for your recent telephone call in which you asked whether i would be legally permissible for an odometer which is being installed in your automobile to replace one that was registering high mileage to be set at the mileage that the automobile was actually driven. There is regrettably no means for this to be done under the Federal odometer law. Section 407 of the Motor Vehicle Information and Cost Savings Act, as found in 15 U.S.C. 1987, permits the 'replacement of an odometer, provided the mileage indicated thereon remains the same as before the . . . replacement.' No adjustments are permitted to compensate for any excess mileage that may have registered on the odometer being replaced. Although some may regard this as being unduly stringent, the creation of such a loophole could invite fraudulent abuse and seriously undermine the effectiveness of our odometer enforcement program.; Enclosed for your information is a copy of the statute and regulation that establish odometer requirements, together with a fact sheet that we have prepared on the subject.; If we can be of any further assistance, please feel free to contact u again.; Sincerely, David W. Allen, Assistant Chief Counsel |
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ID: aiam1684OpenMr. Ray L. Underwood, F.T.E. Industries, Inc., P.O. Box 7209 Cody Station, 4225 Quinlan, Flint, MI 48507; Mr. Ray L. Underwood F.T.E. Industries Inc. P.O. Box 7209 Cody Station 4225 Quinlan Flint MI 48507; Dear Mr. Underwood: This responds to your November 11, 1974, question whether th Model-FTE468T42 trailer qualifies as a 'heavy hauler trailer' which is not subject to the requirements of Standard No. 121, *Air brake systems*, until September 1, 1976. 'Heavy hauler trailer' is defined in S4. of the standard as follows:; >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; From the description you enclosed, it appears that the trailer has primary cargo-carrying surface that is not more than 40 inches above the ground in the unloaded condition, and that it would therefore not be required to meet the standard until September 1, 1976.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2005OpenGerhard P. Reichel, Volkswagen of America, Inc., Englewood Cliffs, N.J. 07632; Gerhard P. Reichel Volkswagen of America Inc. Englewood Cliffs N.J. 07632; Dear Mr. Reichel: Please forgive the delay in responding to your letter of April 10 1975, requesting an interpretation of S4.3, the placarding requirements, of Federal Motor Vehicle Safety Standard No. 110, *Tire Selection and Rims--Passenger Cars.; You have proposed a format for presenting vehicle capacity weight which is designed to accommodate, with a single placard, several different model configurations. The NHTSA has not objection to this format, provided that the weights listed are correct.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0937OpenMr. Harry W. Protzeller, Dyna-Plastics, Incorporated, P.O. Box 9284, 3205 Forge Road, Shreveport, LA 71109; Mr. Harry W. Protzeller Dyna-Plastics Incorporated P.O. Box 9284 3205 Forge Road Shreveport LA 71109; Dear Mr. Protzeller: This is in reply to your letter of November 30, 1972, to the Federa Register concerning an interpretation of Federal Motor Vehicle Safety Standard No. 108.; You have asked whether a side marker lamp may be combined opticall with a taillamp as long as requirements of Standard No. 108 applicable to each lamp are met. The answer is yes, S4.4.1 permits this combination.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3848OpenPaul Escobosa, Esq., Dinkelspiel, Donovan & Reder, One Embarcadero Center - 27th Floor, San Francisco, CA 94111; Paul Escobosa Esq. Dinkelspiel Donovan & Reder One Embarcadero Center - 27th Floor San Francisco CA 94111; Dear Mr. Escobosa: In reply to your letter of May 22, 1984, to Mr. Vinson of my office this is to advise you that you will find the truck air brake standard at 49 CFR 571.121, Motor Vehicle Safety Standard No. 121, *Air Brake Systems*.; As Mr. Vinson informed you, the 'Autostop' braking device about whic you inquired is not directly regulated by a Federal motor vehicle equipment or vehicle standard. However, its installation on a truck conforming to Standard No. 121 must not render the air brake system inoperative in whole or in part, pursuant to 15 U.S.C. 1397(a)(2)(A). If installation occurs before the truck is delivered to its first purchaser for purposes other than resale, the installer is required to attach a label to the truck in accordance with 49 CFR 567.7 that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards.; In any event, as an item of motor vehicle equipment, the 'Autostop' i subject to the notification and remedy provisions of 15 U.S.C. 1411 *et seq*. in the event that either its manufacturer or this agency determines that it contains or creates a safety-related defect.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3843OpenPaul Escobosa, Esq., Dinkelspiel, Donovan & Reder, One Embarcadero Center - 27th Floor, San Francisco, California 94111; Paul Escobosa Esq. Dinkelspiel Donovan & Reder One Embarcadero Center - 27th Floor San Francisco California 94111; Dear Mr. Escobosa: In reply to your letter of May 22, 1984, to Mr. Vinson of my office this is to advise you that you will find the truck air brake standard at 49 CFR 571.121, Motor Vehicle Safety Standard No. 121, *Air Brake System*.; As Mr. Vinson informed you, the 'Autostop' braking device about whic you inquired is not directly regulated by a Federal motor vehicle equipment of vehicle standard. However, its installation on a truck conforming to Standard No. 121 must not render the air brake system inoperative in whole or in part, pursuant to 15 U.S.C. 1397(a)(2)(A). If installation occurs before the truck is delivered to its first purchaser for purposes other than resale, the installer is required to attach a label to the truck in accordance with 49 CFR 567.7 that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards.; In any event, as an item of motor vehicle equipment, the 'Autostop' i subject to the notification and remedy provision of 15 U.S.C. 1411 *et seq.* in the event that either its manufacturer or this agency determines that it contains or creates a safety-related defect.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2419OpenMr. Etsuo Yamazoe, Factory Manager, Nichirin Rubber Industrial Co., Ltd., 1118, Sazuchi, Bessho, Himeji, Japan; Mr. Etsuo Yamazoe Factory Manager Nichirin Rubber Industrial Co. Ltd. 1118 Sazuchi Bessho Himeji Japan; Dear Mr. Yamazoe: #This is in belated response to your May 14, 1976 letter concerning Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #The National Highway Traffic Safety Administration (NHTSA) recognizes the designation 'NCRN' as identifying Nichirin Rubber Industrial Co. on all brake hoses and brake hose assemblies manufactured by Nichirin, regardless of whether these components are intended for use in hydraulics, air, or vacuum brake systems. #The NHTSA does not issue approvals of motor vehicle equipment prior to sale. Under the National Traffic and Motor Vehicle Safety Act of 1966, as amended, certification of compliance with applicable safety standards is performed by the manufacturer. Standard No. 106-74 does not specify the testing which a manufacturer must do before certifying that his brake hose and assemblies comply, it does specify the performance levels which these products must meet when tested by the NHTSA for compliance. The manufacturer is required to exercise due care in assuring himself that his certification is neither false nor misleading. #Sincerely, Frank A. Berndt, 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.