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: aiam1348OpenMr. Alexander F. Klein, 43 Columbine Lane, Kings Park, NY 11754; Mr. Alexander F. Klein 43 Columbine Lane Kings Park NY 11754; Dear Mr. Klein: Your letter of December 3, 1973, indicates that the National Highwa Traffic Safety Administration Region II office referred you to this office for an explanation of your rights under the Federal odometer disclosure requirements.; After January 18, 1973, the Motor Vehicle Information and Cost Saving Act prohibited alteration, resetting, or disconnection of a vehicle odometer with the intent to defraud a purchaser. After March 1, 1973, regulations under the Act require each seller to make a signed, written disclosure of a vehicle's recorded mileage to his purchaser. If he knows the odometer reading is inaccurate, he must also state that the actual mileage is unknown. This statement must be made before the vehicle is sold.; If these regulations were violated in your particular case, as Troope Moran's investigation may indicate, a civil remedy is available to you under S 409 of the Act for $1,500 or treble damages, whichever is greater. To obtain your remedy, S 409 provides that you may bring a private civil action in State or Federal court.; You may wish to consult an attorney about the possibility of bringin an action in your case. I am enclosing the relevant portion of the Act and the odometer regulation for your information.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam1822OpenMr. C.P. Boling, Division Manager, Stratoflex, Inc., 1428 Cliff Road, Burnsville, Minnesota 55337; Mr. C.P. Boling Division Manager Stratoflex Inc. 1428 Cliff Road Burnsville Minnesota 55337; Dear Mr. Boling: #This is to confirm the interpretation of the labelin requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, which I gave in a telephone conversation on February 27, 1975. #S5.2.4 of the standard requires each brake hose assembly to be labeled with a band. The band must include, among other information, 'a designation that identifies the manufacturer of the hose assembly...' A brake hose distributer who manufactures assemblies at multiple locations is not required to assign a designation to each location. A single designation will suffice. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
|
ID: aiam3974OpenThe Honorable John S. McCain, III, U.S. House of Representatives, Washington, DC 20515; The Honorable John S. McCain III U.S. House of Representatives Washington DC 20515; Dear Mr McCain: Thank you for bringing to our attention the problems experienced b your constituents due to conflicting State laws on motor vehicle window tinting.; The National Highway Traffic Administration (NHTSA) has issued Federal motor vehicle safety standard governing window tinting in new vehicles and replacement equipment, and Federal law also limits the extent to which certain commercial businesses may apply additional tinting. However, Federal law does not preclude individuals from tinting their vehicle windows. That matter is left to the States, and we understand the difficulties that may arise when the tinting laws of adjacent States are inconsistent.; Our agency has been discussing the issue of window tinting with th American Association of Motor Vehicle Administrators, in an effort to better explain the interaction of Federal and State laws in this area. That may also be an appropriate forum in which to consider ways to resolve conflicts between differing State tinting laws. While NHTSA and each state government has a valid interest in preserving its legal authority, we all share a common interest in promoting highway safety and in minimizing inconvenience to traveling motorists. In our view, a well-coordinated and cooperative approach among the various parties can help to address apparent problems in this area.; We will keep you advised of our progress in those discussions. appreciate knowing of your concern in this matter, and I hope you will feel free to contact me if this agency can be of further assistance.; Sincerely, Diane K. Steed |
|
ID: aiam1140OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45222; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45222; Dear Mr. Pieratt: In your letter of May 14, 1973, you present the fact situation of a equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer 'that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108.'; There is no Federal requirement that an equipment manufacturer in thi fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1141OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45222; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45222; Dear Mr. Pieratt: In your letter of May 14, 1973, you present the fact situation of a equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer 'that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108.'; There is no Federal requirement that an equipment manufacturer in thi fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1139OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45222; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45222; Dear Mr. Pieratt: In your letter of May 14, 1973, you present the fact situation of a equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer 'that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108.'; There is no Federal requirement that an equipment manufacturer in thi fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2431OpenMr. R. M. Furman, NVT America, Inc., P.O. Box 6249, Anaheim, CA 92806; Mr. R. M. Furman NVT America Inc. P.O. Box 6249 Anaheim CA 92806; Dear Mr. Furman: This is in response to your letter of October 1, 1976, in which yo pose several questions concerning which of three companies participating in the construction of a motor vehicle would be considered the manufacturer for purposes of 49 CFR Part 566 and which would be responsible, therefore, for meeting the safety standards described in 49 CFR Part 571.; The term 'manufacturer' is defined in section 102(5) of the Nationa Traffic and Motor Vehicle Safety Act (the Act) as 'any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, including any person importing motor vehicles or motor vehicle equipment for resale.' Therefore, the company that assembles a vehicle is considered the manufacturer regardless of the name under which the vehicle is marketed. This interpretation is not affected by which company owns the engineering rights or trademark to the vehicle. A controlling corporation, however, may assume responsibility for conformity with the standards and may substitute its name for the name of its assembling subsidiary.; Part 566, *Manufacturer Identification*, requires the manufacturer, a defined above, to submit identifying information and a description of the items it produces. You should further note that 49 CFR Part 567, *Certification* requires the same manufacturer to affix a label to the vehicle certifying that the vehicle conforms to all applicable safety standards.; I trust this fully responds to your questions. Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam5416OpenMr. Rick Rogers 9624 Davis Road Tampa, FL 33637-5004; Mr. Rick Rogers 9624 Davis Road Tampa FL 33637-5004; Dear Mr. Davis: Robert Hellmuth of this agency has sent us for repl your letter of June 8, 1994, commenting that 'a car's brake lights should go on not only when the brake pedal is pressed, but should also go on when the gas pedal is released.' The enclosed copy of a letter dated January 25, 1990, to Larry Snowhite, Esq., represents the agency's views on this matter, now as then. We appreciate the concern for safety that prompted you to get in touch with us. Sincerely, John Womack Acting Chief Counsel Enclosure; |
|
ID: aiam1513OpenMr. Burt Weller, Engineering Manager, Truck Trailer Manufacturers Ass., 2430 Pennsylvania Avenue, N.W., Washington, DC 20037; Mr. Burt Weller Engineering Manager Truck Trailer Manufacturers Ass. 2430 Pennsylvania Avenue N.W. Washington DC 20037; Dear Mr. Weller: This is in response to your letter of May 29, 1974, concernin paragraph S5.3.2 of Federal Motor Vehicle Safety Standard No. 121, *Air brake systems*.; When a full trailer is tested for compliance with S5.3.2, the wheels o the steerable axle(s) cannot lock up at speeds above 10 mph except for controlled lockup of wheels allowed by an antilock system.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam3641OpenCharles R. Sidner, CPSM, Product Safety Engineer, Grumman Flxible Corporation, 970 Pittsburgh Drive, Delaware, OH 43015; Charles R. Sidner CPSM Product Safety Engineer Grumman Flxible Corporation 970 Pittsburgh Drive Delaware OH 43015; Dear Mr. Sidner: This responds to your March 31, 1983, letter asking about the lo-ai pressure warning device that is required by Standard No. 121, *Air Brake Systems*. In particular you ask whether the requirement must be met with two switches, one on the primary and one on the secondary air tank, or whether one switch on the supply tank would be sufficient.; S5.1.5 of the standard states that a warning signal shall be provide to give a continuous warning of a loss of pressure in the service reservoir system below 60 p.s.i. The intent of the section clearly is to provide a warning to a driver of any instance that results in a loss of pressure in either the primary or secondary service reservoir system.; Depending upon the design of any individual brake system, it might b necessary for more than one switch to ensure that the driver will be alerted to such an air loss. For example, a single switch on the supply tank might be inadequate to signal a loss of pressure in the primary or secondary service reservoir system if the action of the compressor masks such loss of pressure. It is up to the manufacturer to determine whether its system is designed in a way that requires more than one switch.; 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.