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: aiam2794OpenCary C. Boyden, Hayward Air Plaza, Suite 220, 22693 Hesperian Boulevard, Hayward, CA 94541; Cary C. Boyden Hayward Air Plaza Suite 220 22693 Hesperian Boulevard Hayward CA 94541; Dear Mr. Boyden: This is in response to your letter of February 22, 1978, concerning th Federal odometer requirements.; The question you raised was whether the lessor can leave th transferee's name and address on the odometer disclosure statement blank in cases where the transferee is a bank who has not yet determined whether the vehicle will be leased or the subject of a secured lending arrangement.; As defined in 49 CFR S 580.3, 'Transferee' means 'any person to who the ownership in a motor vehicle is transferred by purchase, gift, or any means other than by creation of a security interest.' Therefore, if the bank is taking possession of the vehicle in order to lease it, the lessor should indicate that the bank is the transferee. If the bank is taking possession of the vehicle in order to make it the subject of a secured lending arrangement, the bank's customer, and not the bank, should appear on the disclosure statement as transferee.; You indicated that additional paper work would result if the bank wer required to be listed as the transferee in both of the above situations until it decided how to dispose of the vehicle. As a result, you suggested that it be acceptable to list as transferee the bank or its customer as their respective interest may appear. You stated that 'this alternative would allow the bank either to retain the statement on its own behalf or to forward the disclosures to the ultimate debtor at the time it is determined to consummate the transaction as a secured loan rather than a lease.'; It is our opinion that your proposed alternative is acceptable under 4 CFR Part 580, so long as the bank transmits the disclosure to the transferee. The lessor, as transferor, would be responsible for furnishing the transferee with the statement. Should the bank fail to transmit the statement, the lessor could be held responsible for the bank's negligence.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2936OpenClarence W. Woody, Maryland Department of Transportation, 6601 Ritchie Highway, N.E., Glen Burnie, MD 21062; Clarence W. Woody Maryland Department of Transportation 6601 Ritchie Highway N.E. Glen Burnie MD 21062; Dear Mr. Woody: This is in response to your letter of December 5, 1978, asking whethe the abbreviated odometer disclosure statement currently used on Maryland certificates of title may also be used on a Uniform Manufacturer's Statement of Origin. Motor vehicle manufacturers are not required to provide dealers with odometer disclosure statements for new vehicles. Section 580.5 of Title 49 specifically exempts these transactions. Therefore, since there is no Federal requirements that any odometer disclosure statement be issued, you may include the abbreviated statement on the Uniform Manufacturer's Statement of Origin. Manufacturers, however, would not be required by Federal law to complete it.; You should be interested to know that the National Highway Traffi Safety Administration will shortly issue a proposed notice of rulemaking that will allow use of the abbreviated form on all transfer of ownership documents, not merely the certificate of title.; If you have any further questions, please do not hesitate to write. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3726OpenMr. Roderic A. Esmonde, P.E., Athey Products Corporation, Capital Equipment Division, P.O. Box 669, Raleigh, NC 27602; Mr. Roderic A. Esmonde P.E. Athey Products Corporation Capital Equipment Division P.O. Box 669 Raleigh NC 27602; Dear Mr. Esmonde: This responds to your recent letter concerning the requirements o Safety Standard No. 205, *Glazing Materials*. You enclosed a sample of a rigid plastic you would like to use on the side windows of street sweepers, and asked whether the standard would be applicable to that type of material.; Safety Standard No. 205 specifies performance and location requirement for glazing materials to be used on motor vehicles. Only those materials that are specified in the standard may be used on a vehicle, and only in the vehicle location specified for each glazing type. Thus, the sample you enclosed may be used only if it qualifies as one of the glazing types (Items) specified in the standard. A specific piece of glazing material qualifies as a particular glazing Item under the standard if it meets all of the performance tests specified in the standard for that Item. For example, your sample would be considered an Item 12 rigid plastic, which could be used in the vehicle locations specified for that glazing type, only if it passes all of the tests specified in the standard for Item 12 plastics.; Whether or not your sample does qualify as a permitted glazing Ite under the standard will have to be determined by your company. The agency does not provide advance approval for any motor vehicle or piece of motor vehicle equipment. It is the manufacturer's responsibility to determine compliance with the motor vehicle safety standards and to certify that compliance.; I would also note that the glazing manufacturer is required to certify by markings etched on the material, any piece of glazing which is to be used in a motor vehicle (see S6. of Standard No. 205). These required markings would include a specification of the glazing type, e.g., 'Item 12.' The glazing sample you enclosed should be from a piece of certified material if that material is to be used on your motor vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2257OpenHoward A. Heffron, Esq., 1700 Pennsylvania Ave., N.W., Washington, DC, 20006; Howard A. Heffron Esq. 1700 Pennsylvania Ave. N.W. Washington DC 20006; >>> Re: Yankee Metal Products Corporation<<< Dear Mr. Heffron: This is in reply to the petition of March 16, 1976, by your clien Yankee Metal Products Corporation ('Yankee' herein) for an interpretation of 49 CFR 571.108, Motor Vehicle Safety Standard No. 108. Yankee seeks an interpretation 'that the use of strobe type signal warning lamps on school buses is permissible provided that such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887.'; Yankee has submitted a test report by Electrical Testing Laboratories Inc. indicating conformance to SAE Standard J887 including its photometric requirements. Yankee has also submitted an opinion by a professional engineer that 'the Yankee strobe lights tested by ETL meet the photometric requirements of SAE J887.'; As you know, this agency does not 'approve' specific lighting device prior to their introduction into interstate commerce, and all that is legally required is that the manufacturer certify that its product meets all applicable Federal motor vehicle safety standards. The ETL report and professional opinion indicate that the design of the Yankee system complies with SAE J887, and thus they provide a basis upon which Yankee could certify that its system meets Standard No. 108. Therefore the use of its strobe type signal warning lamps appears to be permissible under Standard No. 108.; This means that the interpretation provided Mr. John J. Giesguth o December 9, 1975, does not apply to any strobe light system where an equivalency of conforming performance can be demonstrated, as Yankee appears to have done.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2430OpenMr. Kerry G. Lund, United Recreational Products, Inc., Country Road & Highway 35, Webster, WI 54893; Mr. Kerry G. Lund United Recreational Products Inc. Country Road & Highway 35 Webster WI 54893; Dear Mr. Lund: This responds to your July 16, 1976, request for information on th requirements for a manufacturer of a light utility trailer which is designed to carry snowmobiles. I regret that we have not responded sooner.; The information you request appears in Title 49 of the Code of Federa Regulations, and I enclose an information sheet which explains how this material may be acquired.; Part 566, *Manufacturer Identification (49 CFR Part 566), specifie identification information which must be submitted to the NHTSA by manufacturers of vehicles and equipment regulated by our standards.; Part 567, *Certification* (49 CFR Part 567), specifies the content an location of the certification label or tag which must be attached to motor vehicles regulated by our standards.; At this time the only Federal safety standards applicable to al trailers are Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, and Standard No. 120, *Tire and Rim Selection for Vehicles Other Than Passenger Cars*. The enclosed information sheet also explains how to acquire those regulations.; Standard No. 121, *Air brake systems*, became effective on January 1 1975, in the case of trailers which the manufacturer has decided to equip with air brakes. Thus trailers which you manufacture on or after January 1, 1975, which utilize air brakes must meet the air brake standard.; After you have reviewed the regulations I have referred to, pleas contact me if you have any further questions.; Yours truly, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4762OpenMr. Pat Crahan Director, Government Relations U-Haul International 2727 North Central Avenue P. O. Box 21502 Phoenix, Arizona 85036-1502; Mr. Pat Crahan Director Government Relations U-Haul International 2727 North Central Avenue P. O. Box 21502 Phoenix Arizona 85036-1502; "Dear Mr. Crahan: Thank you for your letter to Dr. August Burgett o this agency, seeking an interpretation of Standard No. 115, Vehicle Identification Number -- Basic Requirements (49 CFR 571.115). I apologize for the delay in this response. Specifically, you stated that U-Haul manufactures its trailers itself and never sells those trailers to any other party. You asked if Standard No. 115 requires trailers that are used exclusively by the party that manufactures them to be identified with a vehicle identification number (VIN). The answer to your question is yes. S2 of Standard No. 115 specifies that the standard applies to trailers, and makes no exception for trailers that are used exclusively by the manufacturer. S4.1 of Standard No. 115 provides that: 'Each vehicle manufactured in one stage shall have a VIN that is assigned by the manufacturer.' Again, no exceptions are set forth for vehicles that will be used exclusively by the manufacturer. Because those regulatory provisions do not include any special exceptions, every new trailer must have a VIN, irrespective of whether the trailer will only be used by the same party that manufactured it. I hope this information is useful. If you have any further questions or need any additional information about this topic, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam4106OpenMr. I. Levy, B.P.T. Leisure International Ltd., 3/4 Portland Street, London, W1N 5AG, ENGLAND; Mr. I. Levy B.P.T. Leisure International Ltd. 3/4 Portland Street London W1N 5AG ENGLAND; Dear Mr. Levy: Thank you for your letter of January 14, 1986, concerning the effect o our regulations on a product you may export to the United States. I hope the following discussion answers your questions.; The product, which you call a 'Klunk- Klip' safety belt comfort device consists of a plastic device which attaches to the upper torso belt anchorage. A belt user can then pull the webbing through the open wedge and close the wedge to introduce slack into the shoulder portion of the belt.; As background information, let me explain that the agency does not hav the authority to approve or endorse items of motor vehicle equipment, such as your device. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards.; Your particular aftermarket product is not covered by any of our safet belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your product. Those responsibilities are set out in sections 151-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2425OpenMr. Richard B. Ansell, Anschelewitz, Barr, Ansell & Bonello, 513 Bangs Avenue, Asbury Park, NJ 07712; Mr. Richard B. Ansell Anschelewitz Barr Ansell & Bonello 513 Bangs Avenue Asbury Park NJ 07712; Dear Mr. Ansell: This responds to your September 8, 1976, question whether the window of recreational vehicles' qualify as secondary means of egress' and what Federal requirements would apply to them if they do so qualify.; The only Federal requirement for the provision of emergency exits appl to buses (Standard No. 217, *Bus Window Retention and Release*, 49 CFR 571.217 (copy enclosed)). Bus' is defined by our regulations to mean a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons (49 CFR 571.3). Thus, Standard No. 217 would apply to the vehicle you describe if it is designed to carry more than 10 persons (including the driver) while the vehicle is in motion.; The standard does not use the term secondary means of egress' bu specifies a minimum area of unobstructed opening that may be provided by several means (*e.g.*, emergency door, push-out window').; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4352OpenDr. Ernst, Hella KG Hueck & Co, Postfach 28 40, 4780 Lippstadt, GERMANY; Dr. Ernst Hella KG Hueck & Co Postfach 28 40 4780 Lippstadt GERMANY; Dear Dr Ernst: This is in reply to your letter of February 5, 1987, to Richard Va Iderstine of this agency's Office of Vehicle Safety Standards. You have asked for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to a new headlamp manufactured by Hella that BMW has installed on a new car which it introduced in the United States around April 1, 1987.; The headlamp is of the replaceable bulb type, and as you describe i consist of two additional parts: 'the housing, to which the cover lens is bonded by means of a two-component adhesive', and 'the optical module, consisting of the reflector and the convex lens, joined by the lens carrier....' In your words, 'The two parts are held together by three screws', and you believe that 'the two parts, firmly screwed together, are as effectively joined as would be the case if bonded'.; Paragraph S3 of Standard No. 108 defines a 'replaceable bulb headlamp in pertinent part as 'a headlamp comprising a bonded lens and reflector assembly....' In the Hella design, the lens and reflector assembly are not bonded, and thus the headlamp is not a 'replaceable bulb headlamp' that is permissible for use on motor vehicle sold and used in the United States. The intent of the definition is to ensure that the headlamp lens and reflector are an integral replaceable unit, since that is the only means to assure a mechanically aimable replaceable bulb headlamp which is capable of using any replacement standardized replaceable light source and meets the necessary photometric performance. The foundation of mechanical amiability is that the beam and aiming pad are manufactured to have a specific relationship. If this relationship is altered by replacement of the lens only, or of the reflector only, there is a high likelihood that the lamp may not meet minimum performance requirements when aimed mechanically.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0429OpenMr. Jay Samoff, Greenbaum, Wolff & Ernst, 437 Madison Avenue, New York, NY 10022; Mr. Jay Samoff Greenbaum Wolff & Ernst 437 Madison Avenue New York NY 10022; Dear Mr. Samoff: This is in reply to your letter of July 28, 1971, requesting a official interpretation of certain provisions of the Defect Reports regulations (49 CFR Part 573). You ask whether S 573.5 requires quarterly reports to contain information of defect notification campaigns initiated prior to the regulation's effective date, which is now October 1, 1971 (36 F.R. 14742, August 11, 1971). If not, you ask whether an automobile manufacturer must provide any information concerning campaigns begun prior to the regulation's effective date.; The answer to your first question is no. Quarterly reports require pursuant to S 573.5 are not required to contain information regarding notification campaigns initiated before October 1, 1971.; With reference to your second question, manufacturers are required t provide certain information regarding notification campaigns initiated before the regulation's effective date. Section 113(d) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1402(d)) requires manufacturers to furnish NHTSA a copy of all notices, bulletins, and other communications to dealers or purchasers regarding any defect in a vehicle of (sic) item of equipment sold or serviced by the dealer. In addition, S 573.7 of the Defect Reports regulations requires a copy of certain notices, bulletins, or other communications to be furnished to NHTSA monthly. Both of these requirements apply to notices, bulletins, and other communications regarding defects discovered or determined to be related to motor vehicle safety before as well as after the regulation's effective date. Furthermore, the agency may, should the need arise, request information from manufacturers regarding past campaigns under the authority of section 112(d) of the Act (15 U.S.C. 1401(d)).; If you have further questions please write. Sincerely, Lawrence R. Schneider, Acting 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.