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: aiam0579OpenMr. George Diederich, West Coxsackie, NY 12192; Mr. George Diederich West Coxsackie NY 12192; Dear Mr. Diederich: This is in reply to your letter to Secretary Volpe concerning the Tir Identification and Record Keeping regulation (49 CFR 574).; It is unfortunate that you feel the way you do concerning th regulation. However, it does not appear to be an unreasonable burden on the seller of the mobile home to record the name of the purchaser of the mobile home and forward it to the manufacturer.; With regard to the need for the regulation the National Traffic an Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.) was amended by adding section 113(f) (15 U.S.C. 1402) which requires manufacturers of tires to maintain the names of first purchasers. The amendment also provides that the Secretary may establish procedures for the maintainance (sic) of these records.; The legislative history of section 113(f) clearly indicates that th Congress recognized that in spite of defective tires reaching the marketplace, tire manufacturers had no way of notifying the purchaser of the defective tire and that he could be jeopardizing his life and property, as well as the life and property of the general public, by continuing to use the defective tire.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam0378OpenMr. H.H. Vischer, Vice President, Bandag Incorporated, 1056 Hershey Avenue, Muscatine, IA 52761; Mr. H.H. Vischer Vice President Bandag Incorporated 1056 Hershey Avenue Muscatine IA 52761; Dear Mr. Vischer: This is in reply to your letter of May 10, 1971, and to confir opinions given by members of this office in subsequent phone conversations with you.; Under the National Traffic and Motor Vehicle Safety Act and regulation issued pursuant to it the treadless casing you import is not considered to be a completed tire until the tread is applied. Therefore, the Bandag dealer applying the tread is considered to be the tire manufacturer and the Korean manufacturer of the casing does not have to put his own 'DOT' number on the casing.; Since you expect many of your dealers will be using this process, i order not to unduly expend the new manufacturer's list, all your dealers are to use your assigned code number 'XX' for the grouping representing the manufacturer's assigned code and their own three symbol retreader's code in the third grouping which is normally considered the optional code:(sic); Your dealers, as manufacturers of the tires are responsible fo maintaining the records of the first purchaser of the tires they manufacturer (sic).; I believe Docket No. 70-12, Notice No. 9 (36 F.R. 9869) answers you question concerning the location of tire identification numbers.; Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
|
ID: aiam1683OpenMr. Jeffrey B. Lugash, Suite 2200, 1801 Century Park East, Los Angeles, California 90067; Mr. Jeffrey B. Lugash Suite 2200 1801 Century Park East Los Angeles California 90067; Dear Mr. Lugash: This responds to your October 30, 1974, questions whether th Department of Transportation or any 'private establishment' requires manufacturers to file specifications for automobile, motorcycle, and airplane tires, whether Standard No. 119, *New pneumatic tires for vehicles other than passenger cars*, lists these specifications, and what the number '222474 7MRR' means on the bead of a motorcycle tire.; The Department of Transportation's National Highway Traffic Safet Administration has issued Standard No. 119 (effective March 1, 1975), which establishes minimum performance and labeling requirements with which the manufacturer must comply. A copy of the standard is enclosed. Certain tire specifications must appear on the sidewall, and certain rim-matching specifications must be published by the manufacturer or appear in a publication of at least one private tire organization.; It is the general practice of the tire industry to list specification of tires in a private publication, such as the 'Year Book' of the Tire and Rim Association in the United States. Their address is: The tire and Rim Association, Inc., 3200 West Market Street, Akron, Ohio 44313.; The NHTSA Tire and Wheel Division has determined that the number whic you cite is of significance only to the manufacturer of the tire.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
|
ID: aiam0364OpenMr. George Talin, President, Lynd-Talin Tire Company, 3000 Cherry Avenue, Long Beach, CA 90807; Mr. George Talin President Lynd-Talin Tire Company 3000 Cherry Avenue Long Beach CA 90807; Dear Mr. Talin: This is in reply to your letter of May 10, 1971, concerning the Tir Identification and Record Keeping Regulation. Please accept my apology for not responding earlier.; The National Highway Traffic Safety Administration considers eac enforcement case on an individual basis. If a retreader could demonstrate that good faith attempts had been made to obtain the tin plate by May 22, 1971, and due to circumstances beyond his control he was unable to mark tires manufactured after May 22, 1971, with the required information, we would certainly take this into consideration before beginning any enforcement action.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam3506OpenMr. Robert Munoz, Wonder Enterprise, 2955 S.W. 15 Street, Miami, FL 33145; Mr. Robert Munoz Wonder Enterprise 2955 S.W. 15 Street Miami FL 33145; Dear Mr. Munoz: This is in reply to your letter of November 22, 1982, asking whethe Federal regulations would prohibit use of your patented device, the 'Illuminated Wonder Panel.' This device would be used in the space provided for the front license plate and consists of a panel on which numbers or letters would be illuminated from behind, if an owner wished to 'personalize' his vehicle. You have indicated that the candela for each character averages .0365, and that with a seven character maximum, a total output of less than .25 candela would result. You submitted photographs showing this device in operation from a distance of 50 feet on a vehicle using parking lamps only, and using parking lamps/low beam headlamps.; Your device is not directly regulated by the Federal motor vehicl safety standard on vehicle lighting, Standard No. 108 (sic) As an item of original equipment, your device is permissible unless it impairs the effectiveness of lighting equipment required by the standard, such as parking lamps and headlamps. Judging by the photographs you submitted, it does not appear that your device would impair the effectiveness of other lighting equipment. As an aftermarket item, your device is subject to regulation by any State in which the vehicle bearing it is registered. You will have to consult these States for further advice.; We hope that this is responsive to your request. Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam1092OpenMs. Lois M. Woocher, Attorney, Boston Regional Office, Federal Trade Commission, Rm. 2200-C, Kennedy Federal Building, Government Center, Boston, MA 02203; Ms. Lois M. Woocher Attorney Boston Regional Office Federal Trade Commission Rm. 2200-C Kennedy Federal Building Government Center Boston MA 02203; Dear Ms. Woocher: This is in response to your letter of March 21, 1973, forwarding complaint from Kenneth D. Peaslee. Mr. Peaslee ordered a 1973 Honda motorcycle, and was delivered one manufactured in December 1971. He asks if the dealer should make him a partial refund. The question is one should be answered under Massachusetts laws and we are unable to advise him of his rights. There is no violation of any regulation administered by this agency.; I note that the Massachusetts investigator made the statement in hi letter of March 15, 1973, which you enclosed that the Federal Government 'stopped' a practice of model year misdating 'among foreign auto importers.' That statement is not really accurate. We require (49 CFR Part 567) that each motor vehicle be equipped with a label disclosing among other things, the month and year of manufacture. The main purpose of this is to allow a determination of what Federal motor vehicle safety standards were applicable when the vehicle was manufactured. This dating may make it commercially more difficult for a manufacturer or dealer to represent the vehicle as being of a later model year, but such representations are not prohibited or otherwise regulated under our rules.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam1089OpenMs. Lois M. Woocher, Attorney, Boston Regional Office, Federal Trade Commission, Rm. 2200-C, Kennedy Federal Building, Government Center, Boston, MA 02203; Ms. Lois M. Woocher Attorney Boston Regional Office Federal Trade Commission Rm. 2200-C Kennedy Federal Building Government Center Boston MA 02203; Dear Ms. Woocher: This is in response to your letter of March 21, 1973, forwarding complaint from Kenneth D. Peaslee. Mr. Peaslee ordered a 1973 Honda motorcycle, and was delivered one manufactured in December 1971. He asks if the dealer should make him a partial refund. The question is one should be answered under Massachusetts laws and we are unable to advise him of his rights. There is no violation of any regulation administered by this agency.; I note that the Massachusetts investigator made the statement in hi letter of March 15, 1973, which you enclosed that the Federal Government 'stopped' a practice of model year misdating 'among foreign auto importers.' That statement is not really accurate. We require (49 CFR Part 567) that each motor vehicle be equipped with a label disclosing among other things, the month and year of manufacture. The main purpose of this is to allow a determination of what Federal motor vehicle safety standards were applicable when the vehicle was manufactured. This dating may make it commercially more difficult for a manufacturer or dealer to represent the vehicle as being of a later model year, but such representations are not prohibited or otherwise regulated under our rules.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam0943OpenMr. David J. Humphreys, RVI Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, D.C. 20006; Mr. David J. Humphreys RVI Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington D.C. 20006; Dear Mr. Humphreys: This is in reply to your letter of December 12, 1972, concernin Standard No. 126. In essence you object to the requirements effective January 1, 1973, that the camper manufacturers furnish the camper purchaser a statement advising him to select a truck 'whose manufacturer recommends a cargo center of gravity that will contain the camper's center of gravity when it is installed.' You base your objection upon the feeling that use of such language may mislead dealers and purchasers since camper manufactures are not required to provide center of gravity information until September 1, 1973. You ask if it is permissible to add the qualifying phrase '(if the camper has a center of gravity indicated)' to the language quoted and required by Standard No. 126.; We anticipate that many camper manufacturers will be able to provid center of gravity information before September 1, 1973. Inclusion of the language you request would, in our judgement, discourage prospective purchasers of a truck-camper combination from searching for a proper match if the camper at hand which he is examining does not have a center of gravity indicated. The language in question is an advisory caution only, and in our judgement does not impose an unreasonable burden on any of the parties concerned. For these reasons, Your request is denied.; If the required language is included, however, a camper manufacturer i not prohibited from also including a notation that center of gravity information is required to be furnished only with campers manufactured on or after September 1, 1973.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam1004OpenMr. Raymond Fink, The Gates Rubber Company, 999 South Broadway, Denver, Colorado 80217; Mr. Raymond Fink The Gates Rubber Company 999 South Broadway Denver Colorado 80217; Dear Mr. Fink: This is in reply to your letter of January 24, 1973 inquiring what NHTSA would consider to be an appropriate generic name for Dupont's Fiber B. #The approval of generic names of cord materials is under the jurisdiction of the Federal Trade Commission. We understand that agency has issued a temporary approval with regard to this material, and that a further petition is currently under review. For purposes of conformity to Standard No. 109 we will, of course, accept any generic name approved by the Federal Trade Commission. #If you desire further information regarding this matter, you may write to Mr. Edward B. Finch, Assistant Director for Textiles and Furs, Federal Trade Commission, Washington, D.C. 20580. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
|
ID: aiam2767OpenMr. Donald Reed, Trailer Manufacturers Association, 401 North Michigan Avenue, Chicago, Illinois 60611; Mr. Donald Reed Trailer Manufacturers Association 401 North Michigan Avenue Chicago Illinois 60611; Dear mr. Reed: This responds to your December 22, 1977, letter asking whether the tir information label required by Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, must contain the rim size of the rim that is mounted in the vehicle.; Paragraph S5.3.2. of the standard states that the label must contai 'the size designation and, if applicable, the type designation of rims (not necessarily those on the vehicle) appropriate for those tires.' This paragraph specifically permits a manufacturer to equip a vehicle with rim sizes that differ from those listed on its tire information label.; Sincerely, Joseph J. Levin, Jr., 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.