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: aiam0083OpenMr. Ernest Farmer, Director, Pupil Transportation, Department of Education, 111-C Cordell Hull Building, Nashville, TN 37219; Mr. Ernest Farmer Director Pupil Transportation Department of Education 111-C Cordell Hull Building Nashville TN 37219; Dear Mr. Farmer: Thank you for your letter of June 4, 1968, to Mr. George C. Nield concerning the State Board of Education's requirement for school bus warning signal lamps.; The warning signal system as described in your letter does not meet th requirements of Motor Vehicle Safety Standard 108, effective January 1, 1969. A copy of this Standard is enclosed for your reference. A minimum of four red signal lamps is required and they shall be designed to conform to SAE Standard J887, July, 1964, a copy of which is also enclosed. Four additional amber lamps are permitted. The red and amber system and the red only system shall be installed in accordance with paragraph S3.1.3.2 and S3.1.3.3, respectively, of Standard No. 108.; Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam2581OpenMr. F. Michael Petler, Assistant Manager, Safety and Legislation Department, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, California 90670; Mr. F. Michael Petler Assistant Manager Safety and Legislation Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs California 90670; Dear mr. Petler: This is in reply to your letter of May 6, 1977, asking whether it i permissible to label motorcycle tachometers with the symbol 'r/min' instead of 'RPM.'; Paragraph S5.2.3 of Motor Vehicle Safety Standard No. 123 *Motorcycl Controls and Displays* requires that motorcycle tachometers be identified by the letters 'R.P.M.' at a minimum, and provides that 'appropriate words may be spelled in full.' This means that the required identification must be either 'R.P.M.' or 'revolutions per minute.' S5/2/3 would not allow substitution of 'r/min' as the only identification of a tachometer. However, we have no legal objection to your furnishing that symbol as an additional means of identification of 'R.P.M.' if you so wish.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0835OpenMr. Jack Bronte, President, Paradise Manufacturing Company, 2840 East 26th Street, Los Angeles, CA, 90023; Mr. Jack Bronte President Paradise Manufacturing Company 2840 East 26th Street Los Angeles CA 90023; Dear Mr. Bronte: This is in reply to your letter of August 31, 1972, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether the Standard applies to the shower and matching window curtains you manufacture and sell to manufacturers of mobile homes, trailers, and campers, and whether mobile homes must comply with the requirements of the Standard.; Because Standard No. 302 applies to motor vehicles, the components o vehicle occupant compartments listed in S.4.1 of the Standard are subject to the Standard only when they are installed in a vehicle included under a vehicle class to which the Standard is applicable. Standard No. 302 applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. It does not apply to trailers, the vehicle category which includes mobile homes and other towed recreational vehicles, but it does apply to those campers that are constructed on new chassis. Since the only vehicles you list that must meet the requirements of the Standard and that use your curtains are campers constructed on new chassis, the Standard applies only to the curtains used in such campers.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4768OpenMr. Tony Llama President Davenport Enterprises 4705 Granada Boulevard Coral Gables, FL 33146; Mr. Tony Llama President Davenport Enterprises 4705 Granada Boulevard Coral Gables FL 33146; Dear Mr. Llama: This is in reply to your letter of June ll, l990, wit respect to the allowability of a temporary importation of a vehicle from Panama that does not comply with Federal motor vehicle safety standards. Specifically, the vehicle is a 'van' manufactured in the Soviet Union. Its Panamanian owner has requested that your company design and install a dual air conditioning unit for the vehicle. Once you have built and installed the unit, the van will be returned to Panama for evaluation and testing. You anticipate that the van will be in the United States for at least 90 days. After our review of this matter, we have determined that it would be appropriate for you to enter the van pursuant to the provisions of 49 CFR 591.5(j), under the declaration that the vehicle is being imported solely for the purpose of research, investigations, studies, or demonstrations. This declaration appears as Box 7 on the HS-7 importation form under which the vehicle will enter the United States. If you have any further questions, we shall be happy to answer them. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam1812OpenMr. P. H. Whitman, Government Representative, The Gates Rubber Company, 999 South Broadway, Denver, CO 80217; Mr. P. H. Whitman Government Representative The Gates Rubber Company 999 South Broadway Denver CO 80217; Dear Mr. Whitman: This responds to your letter of January 30, 1975, concerning th relationship between the requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, and Military Specification MIL-H-3992C.; Part 571.7(c) of the Federal Motor Vehicle Safety Standards, 49 CF 571.7(c), provides that:; >>>No standard applies to a vehicle or item of equipment manufacture for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.<<<; Therefore, brake hose sold to the military in conformity wit MIL-H-3992C is not subject to any of the requirements of Standard No. 106-74. While Part 571.7(c) appears to exclude from the requirements of Standard No. 106-74 only that hose which is sold directly to the Armed Forces, the NHTSA interprets this section as also excluding that hose which is sold to military contractors, under contracts requiring it to conform to military specifications such as MIL-H-3992C, for installation in vehicles which are in turn sold directly to the military. We are considering the issuance of an interpretive amendment of Part 571.7(c) to this effect.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam1734OpenMr. Bob Baxter, Chief Engineer, Transportation Products Division, The Binkley Company, Warrenton, MO 63383; Mr. Bob Baxter Chief Engineer Transportation Products Division The Binkley Company Warrenton MO 63383; Dear Mr. Baxter: This responds to your December 9, 1974, question whether the Binkle modular home transporter 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: aiam3527OpenMr. Robert J. Carter, Director, Consumer and Technical Affairs, Woodhill Permatex, 18731 Cranwood Parkway, Cleveland, OH 44128; Mr. Robert J. Carter Director Consumer and Technical Affairs Woodhill Permatex 18731 Cranwood Parkway Cleveland OH 44128; Dear Mr. Carter: This responds to your recent letter concerning a product yo manufacture which is used to repair breaks in automobile windshields. You ask whether such a repair product would conflict with any present motor vehicle safety standards.; The National Highway Traffic Safety Administration has issued Federa Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair product such as you describe, however. There is no Federal regulation which would prohibit the use of such a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new windshield which may require repair as a result of damage sustained, for example, in shipment could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, which would be the responsibility of the person selling the windshield. Therefore, we do not recommend use of windshield repair kits prior to the first purchase of a new windshield by a consumer.; Please contact Hugh Oates of my staff if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2944OpenMr. Sheldon C. Brooks, Marque Motors, 8711 Lyndale Ave., So., Bloomington, MN 55420; Mr. Sheldon C. Brooks Marque Motors 8711 Lyndale Ave. So. Bloomington MN 55420; Dear Mr. Brooks: This is in response to your letter dated December 11, 1978, requestin an exemption from the requirements of Part 581, *Bumper Standard*, for the Lamborghini Countach on the basis that this vehicle is manufactured for a special use under the terms of Section 102(d)(1)(B) of the Motor Vehicle Information and Cost Savings Act (Cost Savings Act) (15 U.S.C. 1912). You state that the subject vehicle is purchased for purposes of show and display rather than daily transportation and therefore is manufactured for a special use.; Section 102(c)(1)(B) of the Cost Savings Act permits the Secretary o Transportation, for good cause shown, to exempt from the coverage of Part 581,; >>>'any make, model or class of passenger motor vehicle manufacture for a special use, if such standard would unreasonably interfere with the special use of such vehicle.'<<<; In adopting this section, Congress discussed 'special use' in terms o functional equipment such as winches and snow removal attachments, which must be connected in proximity to the vehicle bumper. It is doubtful whether COngress contemplated the granting of exemptions for show and display vehicles, since manufacturers undoubtedly consider their models 'works of art' and suitable for display.; |
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ID: aiam5187OpenMs. Laura J. Platter 6662 Mohawk Court Columbia, MD 21046; Ms. Laura J. Platter 6662 Mohawk Court Columbia MD 21046; "Dear Ms. Platter: This responds to your letter to Senator Barbar Mikulski about the Federal government's classification of minivans for safety purposes. You were concerned that classifying minivans as trucks rather than passenger vehicles would permit these vehicles to be equipped with fewer safety features. Congress has authorized this agency, the National Highway Traffic Safety Administration (NHTSA), to issue Federal motor vehicle safety standards that are applicable to new motor vehicles and items of motor vehicle equipment. In the last few years, NHTSA has extended nearly all the passenger car safety standards to cover light trucks and multipurpose passenger vehicles (MPVs). (Minivans are typically considered to be MPVs under our safety standards.) The only significant safety requirement for passenger cars that the agency has not extended to light trucks and MPVs is dynamic side impact protection. This is a new requirement that is being phased in for passenger cars beginning this September. NHTSA is currently in rulemaking to consider whether the dynamic side impact protection requirements should be extended to light trucks and MPV's, and published an advance notice of proposed rulemaking on this subject in June 1992. I hope this information is helpful to you. Sincerely, Howard M. Smolkin Acting Administrator cc: The Honorable Barbara A. Mikulski"; |
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ID: aiam3177OpenMr. Frank Dana, Haynsworth, P.O. Box 2048, Greenville, SC 29602; Mr. Frank Dana Haynsworth P.O. Box 2048 Greenville SC 29602; Dear Mr. Dana: This is in response to your telephone conversation with Kathy DeMete of my staff on Friday, December 21, 1979. You asked for the status of section 580.5(a)(1) of Title 49 of the Code of Federal Regulations. That section exempts from the odometer disclosure requirements anyone transferring a vehicle having a gross vehicle weight rating of more than 16,000 pounds. That exemption is part of the regulation, originally issued in January 1973, which prescribes rules requiring a transferor of a motor vehicle to make a written disclosure to the transferee concerning the odometer reading and its accuracy.; In January 1977, the exemption was declared void by the United State District Court for the District of Nebraska on the grounds that the National Highway Traffic Safety Administration (NHTSA) has exceeded its authority in fashioning the exemption. Notwithstanding the court's decision, the NHTSA believes that it has the authority to create exemptions for vehicles for which the odometer reading is not relevant. The exemption, consequently, remains a part of the odometer disclosure regulations.; For your information, I have enclosed copies of the statement submitted by Freightliner, White, and the National Association of Motor Bus Operators, which support the exemption for larger vehicles.; 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.