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: aiam3245OpenMr. John B. Galotti, Service Manager, Sholz Oldsmobile, 35 West Post Road, White Plains, NY 10606; Mr. John B. Galotti Service Manager Sholz Oldsmobile 35 West Post Road White Plains NY 10606; Dear Mr. Galotti: This responds to your recent letter requesting information concernin the legal requirements applicable to the installation of fuel separators and auxiliary fuel tanks in motor vehicles. I am enclosing a copy of a letter the agency issued last year which discusses the Federal requirements and implications that would be involved with such activities. That discussion should answer all of your questions. If, however, you require further information, please contact Hugh Oates of my office at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4887OpenMr. Cliff Chuang Chief Design Engineer Prospects Corporation 114 Crawford Street Lowell, MA 01854; Mr. Cliff Chuang Chief Design Engineer Prospects Corporation 114 Crawford Street Lowell MA 01854; "Dear Mr. Chuang: This responds to your letter seeking clarification o recent amendments to Standard No. 118, Power-operated Window Systems (49 CFR 571.118), as published in the Federal Register on April 16, 1991. Specifically, you were interested in new requirements applicable to remote control operations of power windows. You first asked for confirmation of your interpretation of the new requirement in S5(a) that, while closing, remote control-operated power windows automatically reverse direction 'when they meet a resistive force of 22 pounds or more.' You also asked for an interpretation of the term 'daylight opening' as it appears in S5(b) of Standard No. 118. This agency has received several petitions for reconsideration of the recent amendments to Standard No. 118 with respect to the automatic reversal requirements. In response to the petitions, NHTSA is currently reexamining several aspects of this requirement, including those raised in your letter. The agency will publish its response to the petitions for reconsideration in the Federal Register after it has finished its reexamination of the automatic reversal requirement in the April 16 final rule. Please let us know if you have any questions about this new automatic reversal requirement after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. I hope this information is helpful to you. Please contact us if you have further questions. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam3257OpenMr. Frank J. Douthitt, Douthitt, Mitchell & Paul, P.O. Box 549, 201 N. Bridge Street, Henrietta, TX 76365; Mr. Frank J. Douthitt Douthitt Mitchell & Paul P.O. Box 549 201 N. Bridge Street Henrietta TX 76365; Dear Mr. Douthitt: This responds to your March 19, 1980, letter asking whether it is lega for a manufacturer to build a chassis that would normally have a high gross axle weight rating (GAWR) while continuing to certify the combined axle and chassis to a lower GAWR and gross vehicle weight rating (GVWR). The answer to your question is yes.; The chassis-cab manufacturer and the final-stage manufacturer whe certifying the proper GVWR and GAWR must consider the entire vehicle and its capacity to sustain the load for which it is designed. Therefore, if a manufacturer installs a heavy axle but does not reinforce the frame to correspond with the heavier axle, it must select a GVWR that reflects the capacity of the weaker frame rather than the stronger axle. The GAWR can be any amount appropriate for a given axle without regard to the vehicle's GVWR, provided the sum total of the Gross Axle Weight Ratings (GAWR) is not less than the Gross Vehicle Weight Rating (GVWR).; Your problem arises because the contract for purchase of th chassis-cab specified only the GAWR without insisting that the GVWR be similarly increased. This is entirely a private contractual matter and no Federal regulation of which we are aware has been violated.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3256OpenMr. Frank J. Douthitt, Douthitt, Mitchell & Paul, P.O. Box 549, 201 N. Bridge Street, Henrietta, TX 76365; Mr. Frank J. Douthitt Douthitt Mitchell & Paul P.O. Box 549 201 N. Bridge Street Henrietta TX 76365; Dear Mr. Douthitt: This responds to your March 19, 1980, letter asking whether it is lega for a manufacturer to build a chassis that would normally have a high gross axle weight rating (GAWR) while continuing to certify the combined axle and chassis to a lower GAWR and gross vehicle weight rating (GVWR). The answer to your question is yes.; The chassis-cab manufacturer and the final-stage manufacturer whe certifying the proper GVWR and GAWR must consider the entire vehicle and its capacity to sustain the load for which it is designed. Therefore, if a manufacturer installs a heavy axle but does not reinforce the frame to correspond with the heavier axle, it must select a GVWR that reflects the capacity of the weaker frame rather than the stronger axle. The GAWR can be any amount appropriate for a given axle without regard to the vehicle's GVWR, provided the sum total of the Gross Axle Weight Ratings (GAWR) is not less than the Gross Vehicle Weight Rating (GVWR).; Your problem arises because the contract for purchase of th chassis-cab specified only the GAWR without insisting that the GVWR be similarly increased. This is entirely a private contractual matter and no Federal regulation of which we are aware has been violated.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0282OpenMr. William J. Henrick, Assistant Counsel, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. William J. Henrick Assistant Counsel The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Henrick: This is in response to your letter of May 17, 1971, concerning th applicability of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.; As you mentioned in your letter, under the regulation, a vehicle deale has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.; The Tire Identification and Record Keeping Regulation and th Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5642OpenMr. A.D. Fisher 308 Lolly Lane Jacksonville, FL 32259; Mr. A.D. Fisher 308 Lolly Lane Jacksonville FL 32259; Dear Mr. Fisher: This is in reply to your letter of October 11, 1995 asking for our comments on the relationship of your lighting invention, 'The Enlightener,' to Federal Motor Vehicle Safety Standard (FMVSS) No. 108. The Enlightener is intended to replace the center highmounted stop lamp. The lens has two colors, divided between amber at the top and red at the bottom. The amber portion is lit in a steady burning mode when both the accelerator and brake are not depressed, and in a flashing mode when the transmission lever is in Reverse. The red portion is lit when the brake pedal is depressed and amber is extinguished. This device would not be permissible under FMVSS No. 108. The center highmounted stop lamp must stand alone, the lamp cannot serve another function, and paragraph S5.4(a) prohibits combining it with any other lamp. In addition, the backup function on motor vehicles is furnished by a steady burning white lamp, required by FMVSS No. 108. The presence of a flashing amber lamp operating simultaneously would impair the effectiveness of the backup lamp by sending a conflicting signal. I am sorry that we cannot provide you a more positive response. If you have any questions, you may refer them to Taylor Vinson of this office by calling (202) 366-5263. Sincerely, Samuel J. Dubbin Chief Counsel; |
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ID: aiam0354OpenMr. William J. Henrick, Assistant Counsel, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. William J. Henrick Assistant Counsel The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Henrick: This is in response to your letter of May 17, 1971, concerning th applicability of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.; As you mentioned in your letter, under the regulation, a vehicle deale has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.; The Tire Identification and Record Keeping Regulation and th Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0423OpenMr. Stephen C. Royer, Director of Governmental Relations, National Ready Mixed Concrete Association, 900 Spring Street, Silver Spring, MD 20910; Mr. Stephen C. Royer Director of Governmental Relations National Ready Mixed Concrete Association 900 Spring Street Silver Spring MD 20910; Dear Mr. Royer: This is in reply to your letter of March 30, 1971, concerning th applicability (S 573.3) of the Defect Reports regulations (Docket No. 69-31, Notice 2) published February 17, 1971 (36 F.R. 3064). In your letter you ask,; >>>'If a concrete truck mixer manufacturer is notified of a defect (o brakes, for example) and the concrete truck mixer manufacturer relays this information to the incomplete vehicle manufacturer, and the incomplete vehicle manufacturer indicates that he will file the necessary defect reports with [the] Administration and then does not, would . . . [the] concrete truck mixer manufacturer be deemed in violation of Part 573?'<<<; The answer to this question is yes. Under the circumstances yo describe, both the concrete truck mixer and the incomplete vehicle manufacturer would be in violation of the regulation. Neither manufacturer would be in compliance until one of them filed the report in question, which could be either the defect information report required pursuant to S 573.4 or the quarterly report required pursuant to S 573.5.; The NHTSA cannot become involved in disputes between complete an incomplete vehicle manufacturers as to which one of them will furnish the required reports, and the manufacturers concerned must bear the responsibility for deciding this question between themselves.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3209OpenMr. David Shomberg, Bus Con Corporation, 19 South Main Street, Spring Valley, New York 10977; Mr. David Shomberg Bus Con Corporation 19 South Main Street Spring Valley New York 10977; Dear Mr. Shomberg: This responds to your January 22, 1980, letter asking two questio about the use of your body conversion numbers on the certification labels of your vehicles you produce.; First, you ask whether a final-stage manufacturer may substitute it body conversion number for the vehicle identification number (VIN) that comes with the incomplete vehicle. The answer to this question is no. The VIN must be continued from the incomplete vehicle certification label to the final-stage certification label. However, you may insert your body conversion number on the label in addition to the VIN. Your number should appear at the bottom of the label below the required information.; In your second question, you ask whether you may include your bod conversion number on the alterers' label for previously certified vehicles that you alter. The answer to this question is yes. As indicated above the number should appear at the bottom of the label below the required information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3212OpenMr. David Shomberg, Bus Con Corporation, 19 South Main Street, Spring Valley, NY 10977; Mr. David Shomberg Bus Con Corporation 19 South Main Street Spring Valley NY 10977; Dear Mr. Shomberg: This responds to your January 22, 1980, letter asking two question about the use of your body conversion numbers on the certification labels of vehicles you produce.; First, you ask whether a final-stage manufacturer may substitute it body conversion number for the vehicle identification number (VIN) that comes with the incomplete vehicle. The answer to this question is no. The VIN must be continued from the incomplete vehicle certification label to the final-stage certification label. However, you may insert your body conversion number on the label in addition to the VIN. Your number should appear at the bottom of the label below the required information.; In your second question, you ask whether you may include your bod conversion number on the alterers' labels for previously certified vehicles that you alter. The answer to this question is yes. As indicated above the number should appear at the bottom of the label below the required information.; 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.