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: aiam3211OpenMr. 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 |
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ID: aiam3323OpenDouglas Middleton, U.S.A.A., P.O. Box 33400, San Antonio, TX 78233; Douglas Middleton U.S.A.A. P.O. Box 33400 San Antonio TX 78233; Dear Mr. Middleton: This is in response to your telephone call of August 6, 1980, to Kath DeMeter of my staff concerning odometer information on state certificates of title.; The following states have odometer statements on their motor vehicl titles that are consistent with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted titles to the agency askin for approval but had inacceptable statements. Each was informed that if they supplied certain additional information their titles would be in conformance. We do not know whether that information was included on the titles:; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah Wisconsin<<<; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1 notice, a copy of which is enclosed.; If you have any further questions, please do not hesitate to write. Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam3598OpenMr. Fukuo Takata, Manager, Certifications Regulations Section, Ichikon Industries, Ltd, 80 Itado, Isehara City, Kanagawa 259-11, JAPAN; Mr. Fukuo Takata Manager Certifications Regulations Section Ichikon Industries Ltd 80 Itado Isehara City Kanagawa 259-11 JAPAN; Dear Mr. Takata: This is in reference to your letter of June 30, 1982, to Mr. Elliott o this agency concerning the effective luminous lens area of a front turn signal lamp under Federal Motor Vehicle Safety Standard (FMVSS) No. 108 with respect to three proposed designs.; We assume that you wish to know what is the effective projecte luminous lens area for a front turn signal on vehicles less than 80 inches in overall width. The SAE Standard No. J588e, 'Turn Signal Lamps,' which you quote, imposes no additional requirements for a two compartment front turn signal lamp. Thus, it appears that so long as you meet the minimum of 3.5 square inches for a single compartment lamp, your proposed designs (Case 1 and 2) meet the necessary requirements of FMVSS No. 108. Case 3 would not conform as neither of the two section compartments meets the 3.5 square inch minimum.; Sincerely, Courtney M. Price, Associate Administrator for Rulemaking |
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ID: aiam1920OpenMr. Andrew H. Swartz, Johnson, Hogan & Ometer, Post Office Drawer 668, Moneterey, CA 93940; Mr. Andrew H. Swartz Johnson Hogan & Ometer Post Office Drawer 668 Moneterey CA 93940; Dear Mr. Swartz: This is in response to your letter of April 11, 1975, requesting a interpretation of the meaning of 'gross vehicle weight rating.'; The gross vehicle weight rating (GVWR) of a trailer consists of th weight of the empty trailer plus its rated cargo load. The weight of the tractor is not included. The tractor and the trailer are considered as two separate vehicles, each with its own individual GVWR.; The Distributors Association interpretation you cited is correct, bu you appear to have misinterpreted it. In the case of a semi-trailer, a significant portion of the loaded trailer's GVWR may be supported by the tractor's rear axle. Therefore, the trailer's GVWR may be significantly higher than its gross axle weight rating, which is the weight an entire axle system, including tires, wheels, axle, and suspension systems, is capable of supporting.; Please let me know if you need further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4232OpenMr. Alvin A. Leach, Manager, Corporate Transportation Services, Carolina Power & Light Co., PO Box 1551, Raleigh, NC 27602; Mr. Alvin A. Leach Manager Corporate Transportation Services Carolina Power & Light Co. PO Box 1551 Raleigh NC 27602; Dear Mr. Leach: Thank you for your letter of September 5, 1986, to Administrator Stee concerning the safety belt installation requirements for heavy trucks. The Administrator has asked my office to respond since you asked for an interpretation of the requirements of Standard No. 208, *Occupant Crash Protection*. I hope the following discussion answers your questions.; You first asked whether lap/shoulder safety belts are required in truck with a gross vehicle weight rating greater than 10,000 pounds. S4.3 of the standard, a copy of which is enclosed, sets out the requirements for such trucks. S4.3 permits a manufacturer to install either a lap safety belt, referred to as a Type 1 belt in the standard, or a lap/shoulder belt, referred to as a Type 2 belt, in a heavy truck. At the present time, we do not have any plans to require lap/shoulder belts in heavy trucks. We are taking steps to improve the comfort and convenience of safety belt systems in heavy vehicles. As explained in the attached notice, the agency is currently considering several changes to the standard which would make it easier to use safety belts in heavy vehicles. We expect to issue a final rule on this subject later this year.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1078OpenMr. Arthur H. Davis, RFD 2, Box 174A, Bangor, ME 04401; Mr. Arthur H. Davis RFD 2 Box 174A Bangor ME 04401; Dear Mr. Davis: This is in reply to your letter which we received April 5, 1973, whic asks if you, as a dealer of tires, may register all new and retreaded tires sold to first purchasers on a single form and send that form to a tire registry service.; Under the Tire Identification and Record Keeping regulation (49 CF Part 574) dealers selling cars to first purchasers must record the sale and forward the required information to the manufacturer or his designee. Therefore, you can only record all the tire sales from various manufacturers and retreaders on a registry service form if that registry service is the designee of all of the manufacturers and retreaders whose tires you sell.; For your information we have enclosed a copy of the Tire Identificatio and Record Keeping regulation (Notice No. 5) and a copy of an interpretation of the regulation dealing with the question of manufacturers' designees (Notice No. 10).; Thank you for your interest in auto safety. Sincerely, David Schmeltzer, Assistant Chief Counsel |
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ID: aiam0058OpenMr. C. A. Pierquet, Truck Equipment, Incorporated, 680 Potts Avenue, P. O. Box 2345, Green Bay, WI 54306; Mr. C. A. Pierquet Truck Equipment Incorporated 680 Potts Avenue P. O. Box 2345 Green Bay WI 54306; Dear Mr. Pierquet: Thank you for your letter of March 6, 1968, to Mr. Lowell K. Bridwell Federal Highway Administrator, in which you inquired about certification responsibility for lighting on your truck bodies.; Federal Motor Vehicle Safety Standard No. 108 on lighting applies t motor vehicles, not to motor vehicle equipment such as truck bodies.; When the body is mounted on the chassis cab, the lighting requirement of Federal Standard No. 108, not certified by the manufacturer, must be fulfilled.; Certification must be provided to the dealer when the chassis cab i completed for the dealer. A dealer selling to the final purchaser need not certify, but is responsible for lighting to be in compliance with Federal standard No. 108, for that part of the lighting (or other standards) which have not been previously certified.; Trusting this information answers your questions. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service; |
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ID: aiam0150OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P.O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P.O. Box 898 Sacramento CA 95804; Dear Mr. Heath: Thank you for your letter of January 24, 1969, to Dr. William Haddon Jr., former Director, National Highway Safety Bureau, concerning the installation of front identification lamps on various vehicles manufactured in more than one stage.; Motor Vehicle Safety Standard No. 108 specifies that multipurpos passenger vehicles, trucks, truck tractors, and buses of 80 inches or more in overall width shall be equipped with three identification lamps on the front of the completed vehicle. This standard is applicable to the completed vehicle and it is the responsibility of the final assembler to certify that such vehicle conforms to the standard. A manufacturer of a chassis-cab is not required to mount identification lamps on the chassis-cab. However, if he does so, the manufacturer who adds a body to the chassis-cab is not required to add identification lamps to the front of the body.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam3163OpenMr. W. G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your October 9, 1979, letter relating to the prope classification of school buses on certification labels.; Your letter is accurate in that school buses may be designated a 'school buses' on their certification labels. The agency thinks that for the purpose of clarity the term 'school bus' should be included on the label to further clarify the particular design of the bus. All other buses that comply only with standards applicable to non-school buses must be certified as 'buses'.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3162OpenMr. W. G. Milby, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your October 9, 1979, letter relating to the prope classification of school buses on certification labels.; Your letter is accurate in that school buses may be designated a 'school buses' on their certification labels. The agency thinks that for the purpose of clarity the term 'school bus' should be included on the label to further clarify the particular design of the bus. All other buses that comply only with standards applicable to non-school buses must be certified as 'buses'.; 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.