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: aiam3724OpenMr. Chuck Howard, President, Safety Alert Co., Inc., 1667 9th Street, Santa Monica, CA 90404; Mr. Chuck Howard President Safety Alert Co. Inc. 1667 9th Street Santa Monica CA 90404; Dear Mr. Howard: This is in reply to your letter of June 28, 1983, occasioned by wha you believe is our misconception of the way your 'Safety Alert' system operates. In my letter of June 17 I stated that 'Safety Alert', which was intended to flash a yellow bulb installed in the backup lamp system, would create a noncompliance with Standard No. 108 which requires backup lamps to be white in color and steady burning when in use. You now bring it to our attention that your system does not alter the normal operation of the backup lamps which are steady burning when a vehicle is in reverse, even when 'Safety Alert' is installed.; We understood this when we advised you that you could use 'Safet Alert' through any rear lighting system which Standard No. 108 allows to flash for signalling purposes such as the hazard warning or turn signal systems. The converse of this is that 'Safety Alert' cannot be used through any rear lighting system that Standard No. 108 requires to be steady-burning when in use, such as the backup lamp system, even though when used as a backup lamp it is steady burning. I am sorry this was not clear to you.; We are unaware that any foreign manufacturer is failing to comply wit Standard No. 108 by installing a backup lamp system that 'reflects amber' as you have told us.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0618OpenMr. Kent Chen, Import Manager, Mid-North American Import Export Company, Division of Charles, Incorporated, P. O. Box 529, Council Bluffs, IA 51501; Mr. Kent Chen Import Manager Mid-North American Import Export Company Division of Charles Incorporated P. O. Box 529 Council Bluffs IA 51501; Dear Mr. Chen: This is in reply to your letter of February 26, 1972, regardin importation of truck tires that were manufactured in Spain.; At the present time, the *proposed* Federal Motor Vehicle Safet Standard No. 119 that will apply to truck tires is in preparation. We expect that it will be issued in the very near future and that it will become effective on or about September 1, 1972.; Until then, truck tires are subject only to Regulation Part 574 - Tir Identification and Recordkeeping, which became effective May 22, 1971. Importation of truck tires for use on the public roads and highways requires compliance with Regulation Part 574. We are enclosing a copy of the regulation so that you may be informed of your obligations as an importer. You may use the listed tires or sell them to distributors and dealers if regulation requirements are satisfied.; We are also enclosing a pamphlet that contains additional guideline concerning importation of motor vehicles and equipment.; Apparently the tires described in your letter are manufactured in th Torrclavego, Santander, Spain plant of General Fabrica Espanola del Caucho, S.A. (General Tire International) and if manufactured since May 22, 1971, would be identified by the code marking *AB*.; Please let us know if we can be of further assistance in this matter. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1505OpenMr. Earl E. Eckert, 510 S. Avenue, Nevada, IA 50201; Mr. Earl E. Eckert 510 S. Avenue Nevada IA 50201; Dear Mr. Eckert: This is in reply to your letter of May 3, 1974, inquiring as to th applicability of the Federal odometer law to trucks over 16,000 pounds.; The Federal odometer regulation does not require transferors o vehicles with a Gross Vehicle Weight Rating of more than 16,000 pounds to provide an odometer disclosure statement upon transfer of the vehicle. By Gross Vehicle Weight Rating, the regulation is referring to the value specified by the manufacturer as the loaded weight of a single vehicle, which appears on its permanent certification label.; I have enclosed copies of pertinent portions of the Act and th regulation for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1038OpenMr. Jim Peters, Florida Department of Agriculture and Consumer Services, Tallahassee, FL 32304; Mr. Jim Peters Florida Department of Agriculture and Consumer Services Tallahassee FL 32304; Dear Mr. Peters: This is in response to your letter of February 27, 1973, concerning a instance of odometer tampering reported to your office by Mr. J. L. Scott.; The National Highway Traffic Safety Administration has been delegate authority to administer Title IV, Odometer Requirements, of the Motor Vehicle Information and Cost Savings Act, P.L. 92-513. Although the Act establishes private civil actions as the principal means of enforcement (section 409), we find it useful to learn of cases such as the one you report.; In Mr. Scott's case, however, the sale of the ranch wagon with th suspect odometer occurred before January 18, 1973, the effective date of the Federal act. The resetting of the odometer was therefore not a violation of Federal law, and Mr. Scott has no Federal recourse.; We would be interested to know if you have other reports concerning th dealer from whom Mr. Scott purchased his vehicle. If it appears that the dealer has made a business of resetting odometers, we would consider injunctive action against him.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0578OpenMiss Donna M. Bernard, Scott's Trailer Market, 2020 Fremont Street, Las Vegas, NV 89101; Miss Donna M. Bernard Scott's Trailer Market 2020 Fremont Street Las Vegas NV 89101; Dear Miss Bernard: In reply to your letter of January 28, 1972, we are enclosing a copy o Regulation Part 574 - Tire Identification and Recordkeeping.; To answer your specific question whether the manufacturer i responsible for furnishing the tire serial numbers, as a matter of record, on the invoice of the vehicle, the regulation does not specify this requirement.; The manufacturer is not required to retain a record of tir identification numbers for each vehicle prior to shipment of the vehicle. Normally, the dealer records these numbers at the time of sale along with the purchaser's name and address. The manufacturer provides the means to record this information and the dealer remits the information to him.; If the manufacturer chooses to retain a record of tire identificatio numbers for each vehicle prior to shipment, although he is not required to do so, he may request the dealer to send him only replacement numbers involved in a change, plus name and address of purchaser.; Please let us know if you need further clarification of the subject. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1571OpenMr. John H. Mueller,The Weatherhead Company,300 East 131st Street,Cleveland, Ohio 44108; Mr. John H. Mueller The Weatherhead Company 300 East 131st Street Cleveland Ohio 44108; Dear Mr. Mueller:#This responds to your July 10, 1974, request t modify the hose labeling provisions of Standard No. 106-74, *Brake hoses*, to permit DOT labeling of 1/8-inch O.D. nylon tubing.#To the best of our knowledge 1/8-inch O.D. tubing is not used as brake hose as it is defined by the standard:#>>>'Brake hose' means a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes'<<<#The tubing is used for pressure gauge lines and in two-speed differentials, but is apparently not used to transmit or contain the pressure used to apply force to a vehicle's brakes. As it is not considered to be brake hose under the standard, it should not be labeled with the DOT symbol.#Aside from this prohibition on the use of the DOT symbol, you are free to label 1/8-inch O.D. nylon tubing as you choose.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4233OpenThomas F. McRedmond, State of Tennessee, Department of Revenue, Andrew Jackson State Office Building, Nashville, TN 37242; Thomas F. McRedmond State of Tennessee Department of Revenue Andrew Jackson State Office Building Nashville TN 37242; Dear Mr. McRedmond: I have reviewed your letter of November 14, 1986, and the Tennesse Certificate of Title and Application for Certificate of Title which you forwarded to me. As I advised you previously, the Tennessee Certificate of Title may not be used in lieu of a separate odometer disclosure statement.; Federal regulation, 49 C.F.R. S580.4(e), requires that the transfere shall acknowledge receipt of the disclosure statement by signing it. Therefore, the signature must be on the same document with the disclosure information and not on a separate piece of paper. The National Highway Traffic Safety Administration considers the signature to be essential. In addition to being an acknowledgement of receipt, it prevents the purchaser from later alleging that he was not informed of the mileage. Furthermore, the buyer's signature is important to investigative and prosecutional efforts.; I urge you to notify Tennessee dealers and distributors that thei failure to issue and/or return a separate odometer disclosure statement may subject them to civil and criminal penalties.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3588OpenMr. William J. Benzie, Corporate Fleet Coordinator, The Continental Insurance Companies, Eighty Maiden Lane, New York, NY 10038; Mr. William J. Benzie Corporate Fleet Coordinator The Continental Insurance Companies Eighty Maiden Lane New York NY 10038; Dear Mr. Benzie: This responds to your recent letter asking about Federal regulation pertaining to automotive glass and to windshield repair kits. You are particularly interested in the Novus windshield repair method and ask if it has been approved by the agency.; The agency has issued Safety Standard No. 205, *Glazing Materials* (4 CFR 571.205), which specifies performance and location requirements for glazing used in motor vehicles. I am enclosing a copy of that standard for your information. There are no standards or regulations specifically governing windshield repair methods. However, I am enclosing a letter of interpretation which the agency issued in 1975 regarding the Novus method of windshield repair. I am also enclosing a letter of interpretation which discusses the general responsibilities of persons who modify or repair vehicles, including windshields, under the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381 et seq.). Please look closely at the third and fourth paragraphs of that letter.; Please note that the agency does not grant prior approval of any moto vehicle, motor vehicle equipment or method of vehicle repair. It is the responsibility of the vehicle or equipment manufacturer to certify that its products are in compliance with all applicable safety standards and regulations.; I hope the enclosed information will answer all of your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1316OpenMarcia Mellinger, Lane County District Attorney, 450 Lane County Courthouse, Eugene, OR 97401; Marcia Mellinger Lane County District Attorney 450 Lane County Courthouse Eugene OR 97401; Dear Ms. Mellinger: You have asked what information an automobile dealer must provide in Federal odometer statement concerning prior vehicle ownership and mileage over 100,000 miles.; The Federal regulation only requires information which the transfero knows or has good reason to know about the vehicle's mileage. It does not require that he disclose the name of the former owner. It does require that he state the recorded mileage, and if he knows or has good reason to know that the recorded mileage is not correct he must make a further statement that the actual mileage is unknown. In your example, therefore, he would only state the five-digit figure appearing on the odometer, and make the further statement if he knew or had been told that the vehicle had traveled more than 100,000 miles. He is not required to check with former owners as to vehicle history, but he would be accountable under local consumer protection laws for any misleading statements he made about the vehicle's history.; Please contact me if I can be of further assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4213OpenMr. Gerald B. Eastland, Chief, Title Division, Mississippi State Tax Commission, P.O. Box 960, Jackson, MS 39205-0960; Mr. Gerald B. Eastland Chief Title Division Mississippi State Tax Commission P.O. Box 960 Jackson MS 39205-0960; Dear Mr. Eastland: This is in response to your letter of August 14, 1986, concernin Mississippi House Bill 64 and Federal odometer disclosure requirements.; I have reviewed House Bill 64 and the reverse side of the ne Mississippi certificate of title. The disclosure statements as set forth in lines 155-164 of the bill and on the reverse side of the title conform to the Federal odometer disclosure requirements, 49 C.F.R. S 580.4. However, even assuming the front of the title includes the vehicle's year, make, model and body type and the vehicle identification number, the title fails to include a space for the buyer's signature. The National Highway Traffic Safety Administration considers the signature to be essential because it is an acknowledgement that the purchaser is aware of the mileage. Furthermore, the signature prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title.; Because the title does not contain all the information required b Federal regulation, transferors of motor vehicles in Mississippi must continue to issue a separate odometer disclosure statement. In addition, dealers and distributors must retain, for four years, each odometer statement they receive and a copy of each odometer statement they issue.; I hope this information will help you in your efforts to assist dealer in complying with the Federal regulations. If I could be of further assistance, do not hesitate to contact me.; Sincerely, Erika Z. Jones, 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.