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: aiam5649OpenMr. Patrick Holmes 22235 Frontier Road Clovis, CA 93611; Mr. Patrick Holmes 22235 Frontier Road Clovis CA 93611; "Dear Mr. Holmes: This responds to your request for an interpretatio whether, if you manufacture a motorcycle helmet for personal use, and ensure that your helmet meets Federal Motor Vehicle Safety Standard (FMVSS) No. 218 Motorcycle helmets, you may certify the helmet. Subject to qualifications explained below, the answer is yes. NHTSA is authorized under 49 U.S.C. Chapter 301 Motor Vehicle Safety to issue FMVSSs for new motor vehicles and new items of motor vehicle equipment. Among the FMVSSs is Standard No. 218. In 49 U.S.C. section 30115, a self- certification system is established whereby the vehicle or equipment manufacturer is responsible for exercising 'reasonable care' in certifying the product will, if tested as specified in the applicable FMVSSs, meet the safety requirements in the standards applicable to the product. Section 30115 states: 'A person may not issue the certificate if, in exercising reasonable care, the person has reason to know the certificate is false or misleading in a material respect.' I have enclosed an information sheet that briefly describes the responsibilities for manufacturers of new vehicles and new items of motor vehicle equipment. Please note the discussion on page two concerning manufacturers' responsibilities to ensure that their products are free of safety-related defects. In addition, as noted on page two, Part 566 of our regulations requires each manufacturer of motor vehicle equipment to which an FMVSS applies (e.g., motorcycle helmets) to submit identifying information to NHTSA, with a description of the items they produce. I have enclosed a copy of Part 566 and of Standard No. 218 for your information. I hope this information is helpful. Please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, Samuel J. Dubbin Chief Counsel Enclosures"; |
|
ID: aiam5024OpenThe Honorable George Allen U. S. House of Representatives 255 West Main Street, Room 102 P.O. Box 136 Charlottesville, VA 22902-0136; The Honorable George Allen U. S. House of Representatives 255 West Main Street Room 102 P.O. Box 136 Charlottesville VA 22902-0136; "Dear Mr. Allen: Thank you for your letter in support of Philatro International's request for an immediate temporary exemption from the oil resistance requirement of Federal Motor Vehicle Safety Standard 106, Brake Hoses. The National Highway Traffic Safety Administration (NHTSA) can appreciate the concern you have for distributors of Philatron's brake hoses such as your constituent, Truck Parts East. NHTSA closely examined Philatron's request and determined that the agency cannot provide the requested exemption. The reasons underlying this conclusion are fully explained in a May 26, 1992, letter from Chief Counsel Paul Jackson Rice to Anthony D. Padgett, counsel for Philatron. In his letter, the Chief Counsel explained that Philatron, as a manufacturer of motor vehicle equipment, is not eligible to be considered for an exemption under the National Traffic and Motor Vehicle Safety Act. The Chief Counsel also concluded that a proceeding resulting from Philatron's rulemaking petition must include a full notice and comment procedure. A copy of the letter is enclosed. I would like to clarify an aspect of our rulemaking procedures mentioned in your letter. While it is correct that the National Highway Traffic Safety Administration granted Philatron's rulemaking petition to amend Standard 106's oil resistance requirement, the agency did not inform Philatron that such an amendment would in fact be adopted. Whenever the agency grants a rulemaking petition, it states that it will subsequently decide whether to issue the requested rule based on all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria. We hope that this information is helpful. Sincerely, Frederick H. Grubbe Acting Administrator Enclosure Letter Dated May 26, 1992 cc: Washington Office"; |
|
ID: aiam0269OpenJames A. Morgan, Esq., Assistant Counsel, B.F. Goodrich Company, 500 South Main Street, Akron, OH 44318; James A. Morgan Esq. Assistant Counsel B.F. Goodrich Company 500 South Main Street Akron OH 44318; Dear Mr. Morgan: This is in reply to your letter of November 20, 1970 concerning you telephone conversation with Mr. Schmeltzer of my office, relating to the Tire Identification and Record Keeping Regulations (Docket No. 70-12, Notice No. 2).; You are not completely correct in your understanding that, as a resul of the tire identification regulations, the DOT symbol will only be required on the sidewall of the tire where the identification number will appear. As indicated in the preamble of the notice of proposed rulemaking on these regulations, it is anticipated that the identification number required by the regulation will replace the manufacturer's identification number required by Standard No. 109. However, no decision has been made as yet whether Standard No. 109 will also be amended to require the 'DOT' symbol on only one sidewall of the tire.; You are correct in your understanding that the regulations were no intended to restrict the third grouping of characters, the optional tire type code, to three symbols (sic) In addition, you are correct in your understanding that a tire manufacturer will receive individual identification numbers for each of its tire manufacturing and retread plants.; Under the regulations, B.F. Goodrich will not be required to apply fo identification marks for Goodrich owned brand name tires if sold and controlled by them.; Concerning your question as to what class of certified mail would b required in the event of a recall, a notification letter sent by certified mail to the addressee, himself, would be preferable but is not, at this time, required by the Act or any regulation issued thereunder.; Thank you for your interest. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
|
ID: aiam1743OpenMr. John Massey, Fontaine Truck Equipment Co., 9051 Sorenson Avenue, Santa Fe Springs, CA 90670; Mr. John Massey Fontaine Truck Equipment Co. 9051 Sorenson Avenue Santa Fe Springs CA 90670; Dear Mr. Massey: Mr. S. G. Holder of the Fontaine Truck Equipment Company asked th National Highway Traffic Safety Administration to explain for your benefit the requirements of Standard No. 121, *Air brake systems*, for alteration of wheelbase and installation of a liftable axle on incomplete or complete vehicles by a dealer like yourself.; I have enclosed a copy of the standard as requested. It lists severa requirements which would be affected by the addition of an additional axle. These changes can be complex, and we believe that some assistance from the manufacturer of the axle may be necessary to assist a final-stage manufacturer or vehicle alterer like yourself in meeting the certification requirements. I enclose a letter to a liftable axle manufacturer which explains the responsibilities of the various parties to each other.; Standard No. 121 was issued in February 1971 in part to reduce th incompatibility in brake performance between the larger air-braked vehicles on the highway and other highway users. Its provisions substantially improve the stopping distance performance and other braking characteristics of air-braked vehicles. To meet these requirements, chassis-cab and other vehicle manufacturers have limited the modifications which may be made to their brake system design so that a vehicle will remain in compliance.; It is for this reason that final-stage manufacturers and vehicl alterers are more limited than previously in the modifications which they can undertake. Wheelbase alteration is an example of the type of modification which seriously affects brake system performance. We expect experience with Standard No. 121 will justify greater freedom in the future for such modifications as wheel base alteration.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
|
ID: aiam1442OpenHonorable Frank Thompson, Jr., House of Representatives, Washington, DC 20515; Honorable Frank Thompson Jr. House of Representatives Washington DC 20515; Dear Mr. Thompson: This responds to your March 19, 1974, request for information in behal of Mr. Robert J. Jones, concerning the commercial offer he received for a device that would defeat the ignition interlock device found on 1974 model passenger cars.; The National Traffic and Motor Vehicle Safety Act of 1966 authorize the issuance of motor vehicle safety standards, one of which requires occupant crash protection, one aspect of which is the ignition interlock system. Section 108(a)(1) of the Act prohibits the sale, offer for sale, introduction into interstate commerce, or the importation of any motor vehicle which does not conform to the standards. Our regulatory authority over new vehicles ends, however, with the first purchase of the vehicle in good faith for purposes other than resale. While we can prohibit arrangements between a dealer and a purchaser to disconnect the interlock, where they are part of the sales transaction, we have no remedy against arrangements to defeat the safety features made after the sales transaction.; Nevertheless, while selling devices intended to defeat safety equipmen may be legal, we consider such practices reprehensible since they increase the chances of death and injury on the highways. We are considering a variety of remedies for the situation reported by Mr. Jones.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam0448OpenMr. Joseph M. Mazzafro, Manager, Production Engineering, Strick Corporation, U. S. Highway No. 1, Fairless Hills, PA, 19030; Mr. Joseph M. Mazzafro Manager Production Engineering Strick Corporation U. S. Highway No. 1 Fairless Hills PA 19030; Dear Mr. Mazzafro: This is in reply to your letter of September 21, 1971, to Mr. Dougla Toms, Administrator, National Highway Traffic Safety Administration, requesting an interpretation on the mounting of identification lamps on your trailers.; We hesitate to agree with you that it is not practicable to mount th identification lamps at the extreme height of the trailer. It would appear to be practicable to mount these lamps at the extreme height, even if a shield were necessary to prevent damage to the lamps during use.; If the identification lamps are mounted at the extreme height of th trailer, the clearance lamp mounting height is optional, therefore, clearance lamps could be mounted on the rear crossmember, as shown on your drawing SK-24139.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
|
ID: aiam2663OpenMr. E.M. Ryan, Design Engineer, The Coachette Company, P.O. Box 1427, Highway 65 South, Conway, AR 72032; Mr. E.M. Ryan Design Engineer The Coachette Company P.O. Box 1427 Highway 65 South Conway AR 72032; Dear Mr. Ryan: This responds to your August 19, 1977, letter asking whether Standar No. 217, *Bus Window Retention and Release*, permits the use of two rear doors for the determination of the size of the required unobstructed rear exit opening.; The standard states in S5.4.2.2 that : [a] school bus with a GVWR o 10,000 pounds or less shall conform to all the provisions of S5.4.2, except that the parallelepiped dimension for the opening of the rear emergency door or doors shall be....' This section specifically allows the determination of the required rear opening through the use of either one or two doors. Therefore, your interpretation that the standard permits the use of two rear doors is correct.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam3518OpenMr. David Traxler, 147 King George Way, Columbia, SC 29210; Mr. David Traxler 147 King George Way Columbia SC 29210; Dear Mr. Traxler: This is to follow-up your telephone call of October 29, 1981, askin whether any Federal motor vehicle safety standards apply to 'hatchback' door latches.; Safety Standard No. 206, *Door Locks and Door Retention Components* includes requirements for side door latches. We have enclosed a copy of that standard for your convenience.; There are no Federal motor vehicle safety standards applicable to th rear latch of a hatchback. However, even in the absence of a safety standard, the defect provisions of the National Traffic and Motor Vehicle Safety Act may be applicable. Sections 151 *et seq*. of the Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam0060OpenMr. Ernest Cipriano, President, Weslock Company, 13344 South Main Street, P.O. Box 54369, Los Angeles, CA 90054; Mr. Ernest Cipriano President Weslock Company 13344 South Main Street P.O. Box 54369 Los Angeles CA 90054; Dear Mr. Cipriano: Your letter of April 22, 1968, to Mr. Bridwell has been referred to m for reply.; You state that it is your understanding that the proposed rule makin in Docket 2-16 will require door locks on trailers and mobile homes to be so constructed 'as to be recessed flush on exterior doors.' Federal motor vehicle safety standard No. 206, Door Latches, Hinges, and Locks - Passenger Cars, was originally issued on January 31, 1967 and became effective on January 1, 1968. An amendment to this standard was issued on April 24, 1968 with an effective date of January 1, 1969.; Neither the standard as presently written or the proposed amendment i Docket 2-16 is applicable to trailers and mobile homes. Moreover, there is no provision either in the standard or in the proposed amendment which requires that door locks must be so constructed 'as to be recessed flush on exterior doors,' even as to those motor vehicles to which the standard applies presently or to which it is proposed to apply in Docket 2-16. For your information, we are enclosing a copy of the recent amendment to Standard No. 206 as attachment No. 1, and a copy of the proposed amendment for Docket 2-16 as attachment No. 2.; In view of the foregoing, you may wish to reconsider your request tha we forward to you the comments contained in Docket 2-16. The cost to you for forwarding those comments would be fifty cents a page and the number of pages contained in Docket 2- 16 is considerable. Since your understanding of the thrust of Docket 2-16 is not correct, your request for an extension of time to May 25, 1968 is denied.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
|
ID: aiam1235OpenMrs. Faye Cannon, Cannon's Cycle Center, Inc., P.O. Drawer 4566, 2159 Hoffmeyer Road, Florence, SC 29501; Mrs. Faye Cannon Cannon's Cycle Center Inc. P.O. Drawer 4566 2159 Hoffmeyer Road Florence SC 29501; Dear Mrs. Cannon: Robert Aubuchon of this agency has asked us to respond to your recen inquiry whether the Solex motor bicycle is a 'motor vehicle' under our regulations, and, if so, how we would categorize it. You are also interested in knowing how our views affect South Carolina's proposed redefinition of bicycle.; Since the Solex is manufactured primarily for use on the public roads it is a 'motor vehicle' as defined by the National Traffic and Motor Vehicle Safety Act of 1966, specifically a 'motorcycle'. As such, it must meet all Federal motor vehicle safety standards applicable to 'motorcycles', and be so certified by its manufacturer. The only such standard currently in effect is No. 108, *Lamps, Reflective Devices and Associated Equipment*, but standards on controls (No. 122) and braking (No. 123) will become effective January 1, 1974 and September 1, 1974 respectively.; While the proposed South Carolina redefinition of 'bicycle' appears t encompass the Solex, the State by so doing could neither relieve the manufacturer from the obligation of complying with Federal motorcycle safety standards, nor impose requirements different from Standards Nos. 108, 122, and 123 as to those aspects of performance covered by the Federal standards.; I hope this answers your questions. Yours truly, Richard B. Dyson, Assistant 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.