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: aiam2059OpenMr. Y. Toyoda, Manager, Engineering Dept., Bridgestone Tire Company of America, Inc., 2160 West 190th Street, Torrance, California 90509; Mr. Y. Toyoda Manager Engineering Dept. Bridgestone Tire Company of America Inc. 2160 West 190th Street Torrance California 90509; Dear Mr. Toyoda: Please forgive the delay in responding to your letter of May 22, 1975 concerning truck tires which do not conform to Federal Motor Vehicle Safety Standard No. 119 and which are intended for export to Middle Eastern and African countries.; 49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic an Motor Vehicle Safety Act of 1966, as amended, specify that no Federal Motor Vehicle Safety Standards apply to; >>>a motor vehicle or item of motor vehicle equipment intended solel for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.<<<; Therefore, tires which you manufacture for sale directly to a truc manufacturer who will mount then on trucks which will be driven directly to the port of export need not comply with Standard No. 119. When shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. A label need not remain in the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2853OpenMr. Donald Beyer, National Service Manager, Vespa of America Corporation, 355 Valley Drive, Brisbane, CA 94005; Mr. Donald Beyer National Service Manager Vespa of America Corporation 355 Valley Drive Brisbane CA 94005; Dear Mr. Beyer: This is in reply to your letter of July 3, 1978, requesting a interpretation of Motor Vehicle Safety Standard No. 108, specifically, whether turn signal systems installed on mopeds must meet the standard's requirements. One of NHTSA's engineers has informally advised you, in your words, 'that because turn signal units on mopeds are not required devices...they are not required to meet the specific requirements in FMVSS 108 relative to motorcycles as long as they do not affect the operation of the other required equipment.'; We are pleased that Vespa is considering installing turn signal lamp on motor vehicles that S4.1.1.26 excuses from having them. If you wish to install systems that you intend to comply with Standard No. 108 and which for one reason or another fail to do so, it is doubtful that NHTSA would take any action against Vespa since the equipment is clearly optional and added only at a manufacturer's discretion. We would also view as preempted under Section 103(d) of the National Traffic and Motor Vehicle Safety Act any State action either to require turn signal lamps on mopeds or to establish requirements for such were they added at the option of the manufacturer.; I hope this clarifies the matter for you. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3470OpenDick Sorensen, Brekhus Buick-International, Box 1357, Rapid City, SC 57701; Dick Sorensen Brekhus Buick-International Box 1357 Rapid City SC 57701; Dear Mr. Sorensen: This is in response to your letter of September 10, 1981, in which yo requested information on the Federal odometer disclosure requirements and specifically on their applicability to trucks with a gross vehicle weight rating (GVWR) of over 16,000 pounds. I have enclosed a copy of Title IV of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1981 et seq.) which sets forth the Federal law pertaining to odometers. Section 404 of the Act prohibits any person from altering the odometer of any motor vehicle including trucks of more than 16,000 pounds GVWR.; I have also enclosed a copy of the odometer disclosure requirements (4 CFR Part 580). I have highlighted in red the exemption that applies to large trucks. The agency found that purchasers of these trucks do not rely on the odometer as an indicator of their mileage and, therefore, exempted them from the disclosure requirements. Before you decide whether or not to issue odometer disclosure statements for these trucks, I would like to alert you to the fact that at least one court has held that the agency exceeded its authority in fashioning this exemption and has declared it void. *Lair v. Lewis Service Center*, 428 F.Supp. 778 (D.Neb. 1977). The holding is not binding on any other court and the agency believes the exemption is valid. Nevertheless, you should be aware that should the issue arise again, another court could take a similar view.; I hope that this information is useful to you. If you have any furthe questions, please do not hesitate to write.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam1576OpenMr. William E. Linch, President, Linch-Jones, Incorporated, 131 Honeysuckle Lane, Smyrna, GA 30080; Mr. William E. Linch President Linch-Jones Incorporated 131 Honeysuckle Lane Smyrna GA 30080; Dear Mr. Linch: This is in response to your August 9, 1974, telephone request for clarification of a transferor's duties under the disclosure requirements of the Federal odometer law.; The odometer requirements of the Motor Vehicle Information and Cos Savings Act specify that the transferor of a vehicle provide written disclosure to the transferee of the mileage registered on the odometer at the time of the transaction. If the transferor *knows* that the odometer reading is incorrect for reasons other than calibration error, a statement to that effect must also be executed at the time ownership of the vehicle is transferred.; In the situation where the accuracy of the odometer is in question, th transferor is required to state that the mileage indicated on the odometer is incorrect in accordance with the form specified in S 580 of 49 CFR Part 580, *Odometer Disclosure Requirements*, if there is credible evidence indicating the inaccuracy. If the transferor has no firm basis for a conclusion that the odometer reading is incorrect but feels that it may be wrong, he does not violate the Act by indicating that the true mileage may differ from that shown. In so doing, he provides more information than required, and is not guilty of any violation.; A statement that the mileage *may* differ from that indicated on th odometer would only be a violation where positive evidence exists suggesting that the odometer reading is incorrect. In such a situation the transferor must inform the buyer of the inaccuracy in the manner prescribed in the odometer disclosure requirements.; If you are in need of any further information, please let us know. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1562OpenRobert Markowitz, Esq., Lieberman, Tratras & Markowitz, Shepherd Law Plaza Building, 1300 Shepherd Drive, Houston, TX 77007; Robert Markowitz Esq. Lieberman Tratras & Markowitz Shepherd Law Plaza Building 1300 Shepherd Drive Houston TX 77007; Dear Mr. Markowitz: This is in reply to your letter of July 16, 1974, forwarding to us second sample defect notification letter regarding the failure of certain trailers manufactured by Bill's Trailer Manufacturing Company to conform to Standard No. 108.; Your notification letter still fails to conform to applicabl requirements (49 CFR Part 577, copy enclosed for your further reference). Particularly, Part 577 requires a specific opening statement, which you have omitted, and a specific second statement, which you have altered. We refer you to the regulation regarding the opening statement. With respect to the second, it must state, following the regulatory format, that the manufacturer, Bill's Trailer Manufacturing Company, has determined that a safety related defect exists. We also prefer, in the case of a defect resulting from a noncompliance, that, in addition to describing the equipment that is missing and that will be installed (as you have done), the notification include a statement that the defect results from the failure to conform to Motor Vehicle Safety Standard No. 108. This information could come at the end of the second sentence of your first paragraph, which we assume will be rewritten to conform to this letter. In other respects your letter does conform to Part 577.; For your information, any future defect reports should be sent to th Office of Defects Investigation rather than to this office.; NHTSA has discontinued its mailing list concerning new regulations. enclose a copy of an information sheet on how to obtain our standards and other regulations.; Sincerely, Frank Berndt, Assistant Chief Counsel |
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ID: aiam5460OpenThe Honorable Andrea Seastrand California State Assemblywoman 33d District 523 Higuera Street San Luis Obispo, CA 93401; The Honorable Andrea Seastrand California State Assemblywoman 33d District 523 Higuera Street San Luis Obispo CA 93401; Dear Ms. Seastrand: Thank you for your letter forwarding the concern of Mr. Eric Brandt regarding the use of aircraft tires on the dollies that he uses to move houses and other structures on the highway. I am pleased to have this opportunity to respond. Your office's description of Mr. Brandt's concerns was as follows: He is upset because the California Highway Patrol has stopped him from his house moving business because he is using aircraft tires on the dollies he uses to move the houses. He thinks that the law is being interpreted incorrectly. He is using low profile tires, and he thinks the law means the high floatation tires. The California Highway Patrol officer told Mr. Brandt to contact the Federal Department of Motor Vehicles and find out. In the meantime, he is out of business. Can we help? In accordance with your request, we have prepared a response directly to Mr. Brandt (copy enclosed). If I can be of further assistance, please contact me or Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure; |
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ID: aiam3788OpenMichael J. Schmitt, Counsel, Yamaha Motor Corporation, USA, 6555 Katella Avenue, Cypress, CA 90630; Michael J. Schmitt Counsel Yamaha Motor Corporation USA 6555 Katella Avenue Cypress CA 90630; Dear Mr. Schmitt: This is in response to your letter asking for an interpretation on th permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.; Federal Motor Vehicle Safety Standard (FMVSS) No. 108, 'Lamps Reflective Devices, and Associated Equipment (sic) states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the 'A' type headlamp system described as follows:; >>>Type 1A1 or Type 1A . . . . 1 lamp and either Type 2A1 or Type 2A . . . . 1 lamp<<<< The standard is specified this way because the 2A1 lamp is a lower bea lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an 'upper beam', photometrically it provides only 'fill-in' light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.; Sincerely, Barry Felrice, Acting Associate Administrator for Rulemaking |
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ID: aiam4483OpenMr. Mark Jansen Chevy Duty Pickup Parts 4600 N.W. 52nd St. Kansas City, Mo. 64151; Mr. Mark Jansen Chevy Duty Pickup Parts 4600 N.W. 52nd St. Kansas City Mo. 64151; Dear Mr. Jansen: This is in reply to your letter of September 17, 1988 to Taylor Vinson of this Office. You would like to have parking lamp and tail lamp lenses 'remanufactured' for use on l947-66 Chevrolet and GMC pickup trucks, and have requested our views. We assume that you wish to have lenses manufactured to replace original equipment lenses on the trucks produced in the years indicated. Essentially, your operation appears unaffected by the requirements of this Department. The Federal motor vehicle lighting standard applies only to lenses intended to replace original lenses on vehicles manufactured on and after January l, l972, and would not cover lenses for use on l947-66 trucks. However, if the lenses you intend to manufacture are interchangeable with those on vehicles manufactured on and after January l, l972, you may have an obligation to ensure that they meet Federal requirements. If this is the case, we would be pleased to advise you further. Notwithstanding the foregoing, all replacement lenses are equipment that is subject to Federal notification and remedy provisions if they incorporate a defect that relates to motor vehicle safety. In your case, this likelihood may be remote as the item concerned is a simple one, but attention should be paid to quality control. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam5184OpenMr. Berkley C. Sweet Executive Vice President School Bus Manufacturers Institute 7508 Ben Avon Road Bethesda, MD 20817; Mr. Berkley C. Sweet Executive Vice President School Bus Manufacturers Institute 7508 Ben Avon Road Bethesda MD 20817; "Dear Mr. Sweet: This responds to your letter requesting definitions o primary, preprimary, and secondary school students. You write in response to our July 28, 1992 letter to you in which we state that the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1581, et seq. (Safety Act), defines a school bus as a vehicle that is 'likely to be significantly used for the purposes of transporting primary, preprimary, or secondary school students to or from such schools or events related to such schools' (emphasis added). The terms primary, preprimary, and secondary school are not defined in the Safety Act or in the legislative history of the Act. However, NHTSA has historically interpreted 'preprimary school' to refer to kindergarten, nursery schools and Head Start facilities. 'Primary school' refers to elementary school, and 'secondary school' refers to high school. I have enclosed a copy of our March 20, 1990 letter to Mr. Cadwallader Jones that discusses whether various institutions (e.g., church schools and colleges) are considered 'schools' under the Safety Act. The various states may have their own definitions of a 'school' for determining the use requirements for school vehicles. Therefore, you should check with the state where questions of school vehicle use are at issue. I hope the above information will be of assistance to you. If you have any further questions regarding this matter, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam0254OpenMr. Donald O'Neill, Technical Editor, Automotive Engineering, Two Pennsylvania Plaza, New York, New York 10001; Mr. Donald O'Neill Technical Editor Automotive Engineering Two Pennsylvania Plaza New York New York 10001; Dear Mr. O'Neill: Thank you for your letter of August 17, 1970, concerning Mr. George R Smith's comments on the energy- absorbing steering system in response to my interview in your August issue.; I did not mean to imply that energy-absorbing steering systems were no installed by some manufacturers, such a General Motors, prior to the effective date of our Federal Motor Vehicle Safety Standard No. 203 - Impact Protection for the Driver from the Steering Control System.; Mr. Smith is correct in noting that Standard No. 203 does not requir collapsible steering columns. It was intentionally written in performance terms rather than as a design specification. Most manufacturers chose the collapsible steering column to meet the standard, hence the common use of the term 'collapsible column' to refer to our requirements. However, it should be noted that the standard is also being complied with by steering control systems employing other methods of energy-absorption including energy-absorbing rims and a collapsible bellows located forward of the steering wheel hub.; Regarding your request for a copy of the National Highway Safety Burea 'Program Plan for Motor Vehicle Safety Standards,' This plan is a working document and represents the presently scheduled rulemaking actions to be issued by our Motor Vehicle Programs activity during the period of 1970-1972. I am pleased to enclose a copy as you requested.; I appreciate the opportunity to clarify some of my interview remark and I enjoy reading Mr. Smith's comments.; Sincerely, Douglas W. Toms, Director |
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.