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: aiam3560OpenMr. M. W. Urban, Sure-View, Inc., 1337 N. Meridian Street, Wichita, KS 67203; Mr. M. W. Urban Sure-View Inc. 1337 N. Meridian Street Wichita KS 67203; Dear Mr. Urban: This responds to your letter of April 5, 1982. I believe that the cop which I recently sent you of my May 14, 1980, letter to Mr. Seashores clearly and carefully explains the agency's statutory authority to regulate design elements such as size and dimension. As my letter of March 25, 1982, to you noted, S9.1 of Standard No. 111 is consistent with that statutory authority.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0490OpenMr. Thomas G. Maylone, General Manager, Trike Motor Company, P.O. Box 1044, Pontiac, MI 48056; Mr. Thomas G. Maylone General Manager Trike Motor Company P.O. Box 1044 Pontiac MI 48056; Dear Mr. Maylone: You wrote some time ago to request information concerning th application of various motor vehicle safety standards to passenger cars with curb weights of less than 1,000 pounds. Contrary to the information you obtained from *Motor Trend*, this category of passenger cars is still exempt from the standards. There is a possibility that at some future date the exemption granted by 571.7(a) will be changed or revoked, but any such action can be taken only after opportunity for public comment.; Please advise us if you feel it necessary to have your remainin questions answered.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2011OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50 - 100, W. Alondra Blvd., Gardena, CA 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 - 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill:#I am writing to confirm your telephone conversation o August 4, 1975, with Mark Schwimmer concerning the applicability of Federal Motor Vehicle Safety Standard No. 101, *Control Location, Identification and Illumination*, to an intermittent-operation windshield wiper switch.#Your letter of June 4, 1975, described such an intermittent operation switch which is distinct from the normal windshield wiper switch. As Mr. Schwimmer explained, Standard No. 101 required neither illumination nor any particular location for this intermittent switch, because the normal switch is already subject to all of the standard's requirements.#Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam0042OpenMr. R.L. Donnelly, Corporate Secretary, The Armstrong Rubber Company, 4755 Elm Street, West Haven, Connecticut 06516; Mr. R.L. Donnelly Corporate Secretary The Armstrong Rubber Company 4755 Elm Street West Haven Connecticut 06516; Dear Mr. Donnelly: #Mr. Bridwell has asked that I reply to your lette of December 5, 1967, which asks if the labeling requirements of S4.3 of Standard No. 109, can be complied with by placing some of the information on one sidewall of a tire and other information on the other sidewall. #The Standard requires that all of the labeling information be on both sidewalls and placing some of the necessary information on one sidewall of the tire and some on the other would not satisfy this requirement. #The standard provides that until August 1, 1968, the labeling requirements of S4.3 may be met by affixing to each tire a label or tag that incorporates all specified information not molded into or onto the tire.'(sic) #Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel; |
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ID: aiam1947OpenMr. Stan Haransky, Truck Body and Equipment Association, 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Truck Body and Equipment Association 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This responds to your request for a determination whether a mobil water tower trailer equipped with air brakes would be subject to the requirements of Standard No. 121, *Air brake systems*.; The answer to your question is yes. From the description supplied t you by Klein Products, the trailer does not appear to qualify for exclusion from the standard.; I would like to advise you that the National Highway Traffic Safet Administration recently proposed exclusion of this vehicle type from Standard No. 121, and we invite the submission of comments from the Truck Body and Equipment Association or Klein Products on our proposal.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0317OpenMr. Keitaro Nakajima, General Manager, Toyota Motor Company, Ltd., Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, New Jersey 07071; Mr. Keitaro Nakajima General Manager Toyota Motor Company Ltd. Lyndhurst Office Park 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: #This is to confirm your understanding that the DO symbol, which represents the tire manufacturer's certification that the tire complies with the passenger car tire standard, is required on tires installed on multipurpose passenger vehicles, if such tires are originally designed and have passenger car tire size designations. However, since Standard No. 110 does not, at the present time, apply to multipurpose passenger vehicles,the responsibility for assuring that these tires contain the DOT symbol is limited to the tire manufacturer. #Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam1290OpenMr. Franklin J. Kivel, 1100 City National Bank Tower, Oklahoma City, OK 73102; Mr. Franklin J. Kivel 1100 City National Bank Tower Oklahoma City OK 73102; Dear Mr. Kivel: Your request for information on odometer laws was forwarded to us b the Office of Consumer Affairs.; There is at this time no Federal law that requires odometers to b sealed. The Motor Vehicle Information and Cost Savings Act, which we administer, prohibits altering, resetting, or disconnecting odometers except for lawful repair. It does not, however, require sealed odometers and automobile manufacturers do not normally seal odometer units. Some manufacturers incoporate (sic) anti-tampering features which stain the odometer drum with ink or that destroy its gears if an attempt is made to reverse its direction.; The Act does require disclosure of a vehicle's actual and recorde mileage by a seller before its transfer to a buyer. We are presently conducting a study of the Act's effectiveness.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam2727OpenMr. Ethan Evans, State Farm Insurance Companies, 1 State Farm Plaza, Bloomington, IL 61701; Mr. Ethan Evans State Farm Insurance Companies 1 State Farm Plaza Bloomington IL 61701; Dear Mr. Evans: This is to confirm your telephone conversation of December 1, 1977 with Kathy DeMeter of my staff. The question you raised was whether odometer disclosure statements have to be executed under section 580.4 and retained under section 580.7 of title 49, Code of Federal Regulations when the vehicle involved is a salvage vehicle.; If the vehicle is repairable and will subsequently be used as a moto vehicle, disclosure would have to be made. Likewise, the disclosure statements would have to be maintained if section 580.7 is adopted as a final rule. However, if the vehicle is so badly damaged that it cannot be returned to the road, it will have ceased to be a motor vehicle for purposes of the regulations. Disclosure would therefore not be required.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2582OpenMr. Noah Stone, 2620 Equitable Building, Atlanta, GA 30303; Mr. Noah Stone 2620 Equitable Building Atlanta GA 30303; Dear Mr. Stone: This letter is to confirm a telephone conversation you had with Kath DeMeter of this office on May 17, 1977. You asked whether the Federal odometer mileage disclosure statement, required to be executed by 49 CFR Part 580, needed to be a separate piece of paper. The answer is 'no.' The regulation does not require the disclosure to be separate from other documents. If the full information required by section 580.4 can be included, a disclosure on the bill of sale or other document would satisfy the requirements. The only limitation is that it would have to be executed prior to the completion of the sale as required by section 580.4(a) of the regulation.; If you have any further questions, please do not hesitate to write. Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2093OpenMr. C. Brad Woodford, Swan and Woodford, 325 West Southern Avenue, Suite 9, Tempe, Arizona 85282; Mr. C. Brad Woodford Swan and Woodford 325 West Southern Avenue Suite 9 Tempe Arizona 85282; Dear Mr. Woodford: #This responds to your August 27, 1975, request fo standard applicable to glass-belted tires with the size designation H78-15 which were standard equipment on a 1973 Ford automobile. Such tires are subject to Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires--Passenger Cars*, a copy of which is enclosed. #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.