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: aiam3513OpenThomas J. Cody, Esq., Rogers Ferraro & Cody, P.C., P.O. Box 158, Pomona, NY 10970; Thomas J. Cody Esq. Rogers Ferraro & Cody P.C. P.O. Box 158 Pomona NY 10970; Dear Mr. Cody: This is in reply to your letter of December 2, 1981, to Dr. Robert L Henderson of this agency asking for an opinion regarding the legality of a warning system devised by your client, David Stepkin.; Mr. Stepkin's system 'flashes the rear brake lights continuously whe either brake is applied on a motorcycle.' With respect to Federal regulation of motorcycle lighting systems, I refer you to 49 CFR 571.108, Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices and Associated Equipment*, a copy of which is enclosed. Paragraph S4.6(b) in essence requires that brake lamps (or stop lamps as we call them) be steady burning. This requirement would appear to preclude use of your system.; In addition, the substitution of a flashing signal for the steady on to which the public is accustomed might create confusion, thereby impairing the effectiveness of the stop lamp. You will note that paragraph S4.1.3 prohibits the installation of motor vehicle equipment that impairs effectiveness of required lighting equipment.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2450OpenMr. K. W. Schang, Director - Vehicle Safety, Programs, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. K. W. Schang Director - Vehicle Safety Programs American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Schang:#This responds to American Motors Corporation's (AMC's September 9, 1976, request for confirmation that Standard No. 101, *Control Location, Identification, and Illumination*, permits the addition of a 'fan' symbol to a control that is identified by the word 'fan' in accordance with the requirements of S4.2.1.#The AMC interpretation is incorrect. Section S4.2.1 states in part:#>>>S4.2.1 . . . . A control may, in addition, be identified by a symbol, but only a symbol shown in column 3 or 4 shall be used. However, if the word 'None' appears in column 3, no symbol shall be provided. . . .<<<#Table I, whose columns are referred to in S4.2.1, contains an entry for 'Heating and Air Conditioning System,' and column 3 for that entry contains the word 'None'. This means that no symbol can be used in addition to the word 'fan' on the control for the fan control switch.#The language in the preambles to three proposals to amend Standard No. 101 that you list in your letter does not have the effect of amending the requirements of the standard itself. As you are no doubt aware, a recent proposal would amend Table I to include a symbol for the heating and air conditioning system, but this proposal has not yet been made final. A copy of the proposal is enclosed for your information.#Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam2400OpenMr. Edgar E. Lungren, Jr., Pullman Trailmobile, 200 East Randolf Drive, Chicago, IL 60601; Mr. Edgar E. Lungren Jr. Pullman Trailmobile 200 East Randolf Drive Chicago IL 60601; Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identity and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2396OpenMr. Edgar E. Lungren, Jr., Pullman Trailmobile, 200 East Randolf Drive, Chicago, Il 60601; Mr. Edgar E. Lungren Jr. Pullman Trailmobile 200 East Randolf Drive Chicago Il 60601; Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identify and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers will be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking, and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam3443OpenMr. M. S. Keshav, Manager (R&D), Bajaj Auto Limited, Adurdi, Poona - 411 035 India; Mr. M. S. Keshav Manager (R&D) Bajaj Auto Limited Adurdi Poona - 411 035 India; Dear Mr. Keshav: This is in reply to your letter of July 7, 1981 asking for a 'exemption' from the requirement of paragraph S4.5.6 of Motor Vehicle Safety Standard No. 108 that an illuminated pilot indicator be provided in each vehicle equipped with a turn signal operating unit.; In your opinion, the front turn signal lamps mounted on the handlebar of certain motor scooters that you manufacture can serve as pilot indicators, if a front turn signal lamp fails to operate, the failure is readily apparent to the operator, if a left turn signal lamp fails, there is an 'appreciable change in the flashing rate' of the front lamp.; We concur in your interpretation. Although S4.5.6 does require th indicator, SAE Standard J588e *Turn Signal Lamps*, September 1970, incorporated by reference, requires it only if turn signal lamps are not readily visible to the driver. Because the operability of both front and rear turn signal lamps on the vehicles you described may be confirmed by the front turn signal alone, the front lamp is the functional equivalent of a turn signal indicator, and a separate indicator need not be provided.; As this is a matter of long-standing interpretation of Standard No. 10 we have no plans to amend S4.5.6 to incorporate it.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2991OpenMr. Kei Matsui, Manager, Development Administration Division, Toyo Kogyo C., Ltd., P.O. Box 18, Hiroshima, 730-91 JAPAN; Mr. Kei Matsui Manager Development Administration Division Toyo Kogyo C. Ltd. P.O. Box 18 Hiroshima 730-91 JAPAN; Dear Mr. Matsui: This is in response to your letter of February 2, 1979, requestin confirmation that all three of the speedometer faces shown on the attached sheet comply with the requirements of Federal Motor Vehicle Safety Standard No. 127. There is no requirements that a specific lower limit appear on the face of the speedometer, either by number or by markings. Your interpretation is, therefore, correct.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1912OpenMr. Bernard Schwartz, Safe-lite Mfg. Co., 4600 North Olcott Avenue, Harwood Heights, Illinois 60656; Mr. Bernard Schwartz Safe-lite Mfg. Co. 4600 North Olcott Avenue Harwood Heights Illinois 60656; Dear Mr. Schwartz: This is in response to your letter of April 27, 1975, concernin Federal Motor Vehicle Safety Standard No. 125, *Warning devices*. We believe Your reference to Article 7, Title 16 is an erroneous citation.; 5.1.4 of Standard No. 125 requires that warning device be labeled among other things, with the name of the manufacturer. There is no bar to including the distributor's name as well.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam1119OpenMr. Norman E. Salzman, General Manager, The Fairmount Press, 1993 Jerome Avenue, Bronx, NY 10453; Mr. Norman E. Salzman General Manager The Fairmount Press 1993 Jerome Avenue Bronx NY 10453; Dear Mr. Salzman: This is in response to your request for a review of Fairmount Pres forms MFV, ABW, and WH for their conformity with the odometer disclosure requirements of the Motor Vehicle Information and Cost Savings Act.; Form MFV conforms to the requirements, although it appears from th wording of the disclosure that there may be a misunderstanding as to when the disclosure must be given. Your form contains the statement that 'The mileage appearing on the odometer of the motor vehicle described above *at time of transfer* to * was* as follows:' The intent of the regulation is to make disclosure before the transfer, and the MFV form should therefore be executed before transfer, notwithstanding the quoted language.; Form ABW incorporates the disclosure in the bill of sale, as permitte by the regulations. However, the statement is deficient because there is no provision for (1) last plate number, (2) body style, (3) model, and (4) a check-off provision in the situation where the transferor knows the indicated mileage is incorrect.; Form WH is similarly deficient in that there is no provision for (1 body style, (2) last plate number, and (3) a check-off provision in the situation where the transferor knows the indicated mileage is incorrect.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1647OpenMr. R. W. Schneider, Director, Contract Administration, AM General Corporation, 701 West Chippewa Avenue, South Bend, IN 46623; Mr. R. W. Schneider Director Contract Administration AM General Corporation 701 West Chippewa Avenue South Bend IN 46623; Dear Mr. Schneider: This is in reference to your defect notification campaign (NHTSA No 74-0168) concerning some 1/4-ton Model DJ-5C vehicles which may have insufficient windshield glass retention.; The letter which you have sent to the owners of the subject vehicle does not contain the precise language which is required by Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter incorrectly describes the defect as existing in 'the retention of the front windshield on the 1/4-ton Model DJ-5C 'Jeep' Dispatcher. . . .' Part 577.4(b) requires that the defect be described only as existing in the vehicle. The reference to motor vehicle equipment applies only to equipment campaigns where vehicles are not involved. The letter also fails to adequately evaluate the risk to traffic safety as required by Part 577.4(d).; Although mailing of a revised notification letter will not be required it is expected that all future notification letters conform completely with the regulations.; A copy of Part 577 is enclosed. If you desire further information please contact Messrs. W. Reinhart or James Murray of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam0859OpenMr. R. C. Rittersporn, Sales Manager, Sealy of the Carolinas, Inc., P.O. Box 1009, Lexington, NC, 27292; Mr. R. C. Rittersporn Sales Manager Sealy of the Carolinas Inc. P.O. Box 1009 Lexington NC 27292; Dear Mr. Rittersporn: This is in reply to your letter of September 22, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'.; You ask whether the Standard applies to slide-in campers. The answer i that it does not. You also ask about the effective date of the Standard. Standard No. 302 was issued on December 9, 1970, and became effective with respect to vehicles manufactured on or after September 1, 1972.; Yours truly, Richard B. Dyson, 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.