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: aiam1670OpenMr. Charles W. Chandler, Manager of Engineering, Vulcan Trailer Manufacturing Co., P.O. Box 5099, Pratt City Station, Birmingham, AL 35214; Mr. Charles W. Chandler Manager of Engineering Vulcan Trailer Manufacturing Co. P.O. Box 5099 Pratt City Station Birmingham AL 35214; Dear Mr. Chandler: This responds to Vulkan's (sic) November 7, 1974, question whether it Model FTD-6540 'drop deck platform' trailer qualifies as a 'Heavy hauler trailer' which is not subject to the requirements of Standard No. 121, *Air brake systems*, until September 1, 1976. 'Heavy hauler trailer is defined in S4. of the standard as follows:; >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; From the description you enclosed, it appears that the FTD-6540 mode has a primary cargo-carrying surface that is not more than 40 inches above the ground in the unloaded condition, and that it would therefore not be required to meet the standard until September 1, 1976.; It should be emphasized that the 40-inch height is an absolute limi for regulatory purposes, and that reliance on a design height of 40 inches will probably result in the production of some non- complying vehicles due to variations in manufacture. A maximum civil penalty of $1,000 is authorized for each such non- compliance (15 U.S.C. S 1398(a)).; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam2456OpenMr. Keigo Ohgiya, The Japan Automobile Tire Manufacturers' Association, Inc., 9th Floor, Toranomon Building, No. 15, Shiba Toranomon, Minato-Ku, Tokyo, Japan; Mr. Keigo Ohgiya The Japan Automobile Tire Manufacturers' Association Inc. 9th Floor Toranomon Building No. 15 Shiba Toranomon Minato-Ku Tokyo Japan; Dear Mr. Ohgiya: This responds to your April 22, 1976, letter advising the Nationa Highway Traffic Safety Administration that the tire standards of the Japan Automobile Tire Manufacturers' Association (JATMA) are being translated into English. You request that consideration be given to referencing JATMA standards in the Federal motor vehicle safety standards that regulate motor vehicle tire manufacture. I regret that we have not responded to your letter sooner.; Standard No. 109, *New Pneumatic Tires*, and Standard No. 119, *Ne Pneumatic Tires for Vehicles Other Than Passenger Cars*, presently reference the Japanese Industrial Standards (JIS). Because the JATMA standards appear to be updated mote often than the JIS standards, and because the JATMA standards will be issued in English, the agency intends to substitute a reference to JATMA standards in its regulations for the existing reference to JIS standards.; Thank you for providing us with the English translation of th motorcycle tire standards. We request that you provide us copies of all English translations of the standards for all vehicle types as often as the are updated.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0630OpenMr. Robert Waggoner, c/o ABCO Insurance Brokers, P.O. Box 1066, Reseda, CA 91335; Mr. Robert Waggoner c/o ABCO Insurance Brokers P.O. Box 1066 Reseda CA 91335; Dear Mr. Waggoner: This is in reply to your letter of February 16, 1972, requestin information on 'a new law effective January 1, 1972, that makes it mandatory that manufacturers of truck bodies and those repairing such items must now certify their product.'; The National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C 1381 *et seq*.) has required since January 1, 1968, that manufacturers of motor vehicles and motor vehicle equipment certify that the products they manufacture comply with all applicable Federal motor vehicle safety standards (49 CFR 571.101 *et seq.). The 'new law' to which you refer is actually regulations issued pursuant to Section 114 of the Act (15 U.S.C. 1403) which amended existing regulations specifying the method by which manufacturers are to certify compliance. These regulations are the Certification regulations (49 CFR Part 567) and the regulations governing 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). I have enclosed copies of both for your information.; These regulations apply to manufacturers and distributors of moto vehicles as defined in the regulations. They only apply to manufacturers of truck bodies if such manufacturers install the truck bodies on chassis, thus completing the vehicles. The regulations do not apply to one who only repairs truck bodies.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0900OpenMr. Robert I. Yeoman, Plaskolite, Inc., P.O. Box 1497, 1770 Joyce Avenue, Columbus, OH 43216; Mr. Robert I. Yeoman Plaskolite Inc. P.O. Box 1497 1770 Joyce Avenue Columbus OH 43216; Dear Mr. Yeoman: This is in reply to your letter of October 16, 1972, requesting a DO number for safety glazing materials. You indicate that your understanding is that such a number is required in order to obtain approval under ANS Z26.1-1966.; Under Federal Standards applicable to motor vehicle glazing material (Motor Vehicle Safety Standard No. 205, 49 CFR 571.205) the manufacturer of the material is responsible for certifying the conformity of the material to the standard. The NHTSA does not provide prior approvals, but tests materials it purchases on the open market. Motor Vehicle Safety Standard 205 incorporates by reference, with some exceptions, ANS Standard Z26.1-1966. The DOT number to which you refer has been an optional method by which prime glazing material manufacturers certify their materials. Beginning April 1, 1973, prime glazing material manufacturers will be required to use the symbol DOT and a code number in certifying their materials. Plaskolite Incorporated is hereby assigned code number 98. The method for certifying is more fully explained in the Standard.; While the NHTSA does not require prior approvals of glazing materials such approvals are required by certain States. You may obtain information regarding these approvals from the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0500OpenMr. Robert W. Etter, G & D Communications Corporation, 12997 Merriman Road, Livonia, MI 48150; Mr. Robert W. Etter G & D Communications Corporation 12997 Merriman Road Livonia MI 48150; Dear Mr. Etter: This is in reply to your letter of October 22, 1971, and your phon call to Michael Peskoe of November 15, 1971, requesting a copy of the Consumer Information regulations and asking what penalties may be imposed on manufacturers if their vehicles cannot perform as well as the figures they provide pursuant to the regulation. You stated in the above conversation that you have obtained the volume entitled 'Performance Data for New 1971 Passenger Cars and Motorcycles' which contains a copy of the Consumer Information requirements. I have enclosed certain amendments to the Consumer Information regulations which will bring the regulations as they appear in this volume up to date.; With reference to your question regarding penalties for violations o the Consumer Information requirements, Sections 108 and 109 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. SS 1397, 1398) authorize the imposition of civil penalties of up to $1,000 per violation, and up to $400,000 for any related series of violations, against manufacturers whose vehicles cannot perform at least as well as the data they supply indicates. In addition, injunctive proceedings may be utilized pursuant to section 110 of the Act (15 U.S.C. S 1399).; I trust this answers your question. We regret that it was overlooked i our first response to your letter.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam0499OpenMr. Robert W. Etter, G & D Communications Corporation, 12997 Merriman Road, Livonia, MI 48150; Mr. Robert W. Etter G & D Communications Corporation 12997 Merriman Road Livonia MI 48150; Dear Mr. Etter: This is in reply to your letter of October 22, 1971, and your phon call to Michael Peskoe of November 15, 1971, requesting a copy of the Consumer Information regulations and asking what penalties may be imposed on manufacturers if their vehicles cannot perform as well as the figures they provide pursuant to the regulation. You stated in the above conversation that you have obtained the volume entitled 'Performance Data for New 1971 Passenger Cars and Motorcycles' which contains a copy of the Consumer Information requirements. I have enclosed certain amendments to the Consumer Information regulations which will bring the regulations as they appear in this volume up to date.; With reference to your question regarding penalties for violations o the Consumer Information requirements, Sections 108 and 109 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. SS 1397, 1398) authorize the imposition of civil penalties of up to $1,000 per violation, and up to $400,000 for any related series of violations, against manufacturers whose vehicles cannot perform at least as well as the data they supply indicates. In addition, injunctive proceedings may be utilized pursuant to section 110 of the Act (15 U.S.C. S 1399).; I trust this answers your question. We regret that it was overlooked i our first response to your letter.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2332OpenMr. Arlen E. Riggs, Executive Engineer, Peterbilt Motors Company, 38801 Cherry Street, P.O. Box 404, Newark, CA 94560; Mr. Arlen E. Riggs Executive Engineer Peterbilt Motors Company 38801 Cherry Street P.O. Box 404 Newark CA 94560; Dear Mr. Riggs: This reponds (sic) to Peterbilt Motor Company's June 9, 1976, question whether Standard No. 121, *Air Brake Systems*, contains a permanent exclusion for 'auto transporters' and whether 'auto transporter' would include a truck-trailer vehicle combination that includes a dromedary forward of the fifth wheel to hold empty tin cans that are loaded by means of the trailer. I would like to note that I am unaware of 'discussion and interpretive rulings suggested through telephone contact' with this office.; Your interpretation is not correct that the exclusion for 'aut transporters' is permanent. Some confusion may arise from the words in S3 to describe the exclusion until September 1, 1977. The phrase 'or to any vehicle which' that appears at the end of the second sentence in S3 will shortly be modified to 'or that' to improve the structure and clarity of the sentence.; Your question whether a 'can hauler' qualifies as an 'auto transporter appears to be based on the proposed wording of this definition that was modified in final form. As defined in the standard, 'auto transporter' means:; >>>. . .a truck and a trailer designed for use in combination t transport motor vehicles, in that the towing vehicle is designed to carry cargo at a location other than the fifth wheel and to load this cargo only by means of the towed vehicle.<<<; It is clear from this definition that a 'can hauler' would not qualif as an 'auto transporter' subject to the exclusion.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1672OpenMr. Raymond D. Martin, Jr., President, Tag-a-Long Trailers, Inc., P.O. Box F, Centreville, MD 21617; Mr. Raymond D. Martin Jr. President Tag-a-Long Trailers Inc. P.O. Box F Centreville MD 21617; Dear Mr. Martin: This responds to your November 12, 1974, question whether th Tag-a-Long Models 105A-15 & 18, 105A-21, BBFD-25, BBSB-15, and BBSB-25 trailers qualify as 'Heavy hauler trailer(s)' which are not subject to the requirements of Standard No. 121, *Air brake systems*, until September 1, 1976. 'Heavy hauler trailer' is defined in S4. of the standard as follows:; >>>'Heavy hauler trailer' means a trailer with one or more of th following characteristics:; (1) Its brake lines are designed to adapt to separation or extension o the vehicle frame, or; (2) Its body consists only of a platform whose primary cargo-carryin surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent 'front-end structure' as that term is used in S 393.106 of this title.<<<; From the description you enclosed, it appears that the five models yo describe have primary cargo-carrying surfaces that are not more than 40 inches above the ground in the unloaded condition, and that they would therefore not be required to meet the standard until September 1, 1976.; I have enclosed a copy of the August 5, 1974, notice you requested. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1793OpenMr. Tatsuo Kato, Staff, Safety, Nissan Motor Co., Ltd., P.O. Box 1606, Englewood Cliffs, NJ 07632; Mr. Tatsuo Kato Staff Safety Nissan Motor Co. Ltd. P.O. Box 1606 Englewood Cliffs NJ 07632; Dear Mr. Kato: This is in reply to your letter of January 23, 1975, asking whether th name of your distributor may be inserted as the alterer for purposes of the alterer label required pursuant to 49 CFR S 567.7. You indicate that the alteration will be performed on a Datsun Pickup by a dealer, at the request of a customer, but would be the responsibility of the distributor. The labels would be preprinted with the distributor's name, and the dealer would insert only the date on which the vehicle is altered.; We do not believe the alterer label requirements (49 CFR S 567.7 permit the insertion of the name of the distributor as the alterer in the situation you described. The requirements specify that the person making the alteration insert his name on the label, and provide no exceptions from this requirement. Of course, the dealer can rely on the authorization of the distributor to perform the alteration should that issue arise in a subsequent compliance action.; You have also asked why section 567.2 does not specifically apply t dealers. That section was not amended at the time the alterer requirements were issued. However, the NHTSA considers the alterer requirements to apply to any 'person', as stated in that section, and not only to manufacturers and distributors.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0865OpenMr. Gerald D. Stapley, K-146 Northwood Apartments, Capital Hill Drive, RFD-2, Londonderry, NH 03053; Mr. Gerald D. Stapley K-146 Northwood Apartments Capital Hill Drive RFD-2 Londonderry NH 03053; Dear Mr. Stapley: This is in reply to your letter of September 9, 1972, proposing 'tha legal standards for the performance of windshield defrosting systems be established and applied to vehicles manufactured in or imported into USA.'; The National Highway Traffic Safety Administration has opened Docke No. 1-3 to receive comments on extension of coverage of the passenger car defrosting and defogging system standard, Federal Motor Vehicle Safety Standard No. 103, to multipurpose passenger vehicles, trucks, and buses. Ice or slush buildup on the windshield, as well as the overall performance of the defroster system, are among the problems and concerns currently being investigated by the NHTSA.; We plan to combine all the problems associated with vision an precipitation into an Adverse Weather Visibility standard such as you suggest in your letter. This would also include wiping and washing requirements. At the present time research has been initiated to obtain data so that we can propose definite performance requirements for all types of weather conditions. Under our Program Plan such a standard would become effective September 1, 1976.; Your suggestion and the mention of the specific problems ar appreciated and will be considered as we proceed in our rulemaking. Thank you for writing and if we can be of further service, please let us know.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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.