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: nht69-1.5OpenDATE: 05/01/69 EST FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA TO: Concorde Rubber Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of April 2, 1969, requesting a Department of Transportation (DOT) code number be assigned the Concorde Rubber Company. According to your letter, Concorde has tires manufactured for it by (Illegible Word) Tire and Rubber Company of Hadera, Israel, and by Lee Tire and Rubber Company of Conehehocken, Pennsylvania, which are labeled with Concorde's brand name and the manufacturer's code number (alliance Tire and Rubber Company uses approved code number DOT 187 and Lee Tire and Rubber Company uses approved code number 152). Pursuant to Motor Vehicle Safety Standard No. 109, DOT numbers to be molded onto new tires, where a brand name is used rather than the manufacturer's own name, are assigned to tire manufacturers so the seller of the tire may identify the manufacturer to a purchaser upon request. The legislative history of section 201 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 4121) e.g., see 112 Cong. Rec. 18792 (daily ed. August 17, 1966), and the plain meaning of section 201 of the Act demonstrates that Congress intended to have tires made for sale under the private brand of a merchandiser bear the name or code mark of the concern that actually produces the tire, not merely an identification of the merchandiser distributing and selling the tires to the public. The Act provides that tire labeling shall include "suitable identification of the manufacturer . . . unless the tire contains a brand name other than the name of the manufacturer in which case it shall also contain a code mark which would permit the seller of such tire to identify the manufacturer thereof to the purchaser upon his request." Accordingly, your request for the Concorde Rubber Company's own code number, so that tires manufactured for Concorde by different tire producers can have the same code number, must be denied. |
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ID: nht69-1.50OpenDATE: 04/29/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: Hueck and Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of March 22, 1969, requesting a clarification of the location requirements for license plate lamps as specified in Federal Motor Vehicle Safety Standard No. 108. As you indicated, Standard No. 108 currently references SAE Standard J587B and also permits the location of license plate lamps at the top, side or bottom of the license plate. The latest revision of SAE Standard J587 (J587c) is no way changes the location provision of Standard No. 108. Therefore, a license plate lamp assembly may be tested according to SAE Standard J587b and Standard No. 108 when the license plate is illuminated from the bottom. Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 states: "Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard." Therefore, any State regulations on the location of license plate lamps should be identical to the requirements of Standard No. 108 on and after the effective date of the standard. |
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ID: nht69-1.6OpenDATE: 07/09/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: The Cleveland Columbus and Cincinnati Highway Inc. TITLE: FMVSS INTERPRETATION |
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ID: nht69-1.7OpenDATE: 01/24/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: Baker Equipment Engineering Company TITLE: FMVSS INTERPRETATION |
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ID: nht69-1.8OpenDATE: 02/03/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: Utility Body Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of January 8, 1969, to Mr. Andrew K. Ness, National Highway Safety Bureau, concerning your request for an interpretation relative to the mounting of clearance lamps. It is required by Federal Motor Vehicle Safety Standard No. 108 that clearance lamps be mounted as near as practicable to the upper right and left extreme edges of the vehicle. Lamps mounted at the right and left extreme edges of the widest part of the body panel shown in your sketch would meet the requirements. The mounting height of these lamps should be as high as practicable without causing objectionable glare in the rearview mirror. Retention of cab mounted clearance lamps is optional. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, comments of this Bureau are for information purposes only and in no way relieve any vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108. |
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ID: nht69-1.9OpenDATE: 02/01/69 EST FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: Hucck and Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of February 11, 1969, to Mr. David A. Fay, concerning your request for an interpretation on Standard No. 108. Subsection (d) of Section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 states "Whenever a Federal Motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the name aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard . . ." Since Federal Motor Vehicle Safety Standard No. 108 is now in effect, and permits red or amber rear turn signal lamps, the States cannot restrict these lamps to be red only. |
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ID: nht69-2.1OpenDATE: 03/28/69 FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA TO: The Hail Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of February 24, 1969, to the Office of Standards Preparation, concerning the proposed lighting equipment on your dump trailers. The lamps and reflectors shown on your drawing 701b1907 dated February 20, 1969, appear to be in conformance with the requirements of Standard No. 108 with the following exceptions: 1. The required license plate lamp is not shown. 2. The minimum mounting height for reflectors is 15 inches. 3. With respect to maximum mounting zones for lamps and reflectors, the limiting dimensions of 16, 30, and 24 inches indicated on your drawing appear to be too liberal for a trailer with essentially square corners. With reference to Notes 2 and 3 on your drawing, certain restrictions as specified in paragraph S3.3 of Standard No. 108 are applicable for combination lamps. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only, and in no way relieve the vehicle manufacturer from (Illegible Word) responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108. |
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ID: nht69-2.10OpenDATE: 06/04/69 FROM: AUTHOR UNAVAILABLE; Howard A. Heffron; NHTSA TO: Concrete Plant Manufacturers Bureau TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of May 27, 1969, in which you submit information and photographs of mobile concrete plants, and ask whether they are "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act, with a view to determining whether comments should be submitted to Docket 1-11, Rear Underride Protection. The matter of whether pieces such as the subject concrete plants are motor vehicles within the meaning of section 102(3) of the Act, and also "trailers" within the meaning of the proposed underride standard, is presently under consideration by this Agency. We encourage your organization and its members to submit to the docket any materials that they consider relevant to the subject. |
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ID: nht69-2.11OpenDATE: 02/07/69 FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA TO: Messrs. Tanaka and Walders TITLE: FMVSR INTERPRETATION TEXT: In response to your letter of September 19, I attach an interpretation of the applicability of the National Traffic and Motor Vehicle Safety Act of 1966 to the Heads Mini-Trail and other similar vehicles ("mini-bikes"), which has been prepared for publication in the Federal Register. This interpretation reiterates the opinion rendered American Honda Motor Co. Inc. on August 8 that mini-bikes are motor vehicles subject to the Act, must comply with applicable Federal Motor Vehicle Safety Standards, and must bear an appropriate certification of compliance. Publication of this interpretations will insure that the Federal requirements will be understood equally by all manufacturers of mini-bikes, domestic and foreign. |
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ID: nht69-2.12OpenDATE: 01/28/69 FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA TO: House of Representatives TITLE: FMVSR INTERPRETATION TEXT: Thank you for your January 8 letter concerning comments by Mr. Jackson Decker of the E. D. Ptnyre Company, which was addressed to the National Highway Safety Bureau on December 20, 1968. I regret that Miss Claybrook of my staff was unable to locate Mr. Decker's letter after the call from your office requesting a copy of my response to Mr. Decker. Mr. Decker's letter consists of comments to the Federal Highway Administration Dockets on the pending proposed regulations under which information would be supplied by manufacturers to consumers about various safety performance characteristics of motor vehicles. My staff was unaware of this letter because it was addressed to the Docket and was sent by the mail room directly to the legal office which maintains all dockets. The dockets contain much of the source material which serves as the basis for final rule making on proposed standards and regulations. In addition, letters such as this are seldom answered not only because it is not appropriate to debate the substance of pending rulemaking actions, but also because the purpose of such correspondence is to provide information to the Government in the development of rulemaking. It is not treated as routine correspondence with the agency. In addition, the volume of such comments frequently reaches such vast proportions that it would be virtually impossible to answer them. For example, in response to a recent Federal Highway Administration proposed regulation some 4,000 comments were submitted. Mr. Decker, incidentally, does not indicate he expected a specific answer to his letter but, rather, in his last paragraph, asks that his views "be given serious consideration before proceeding with the issuance of part 275 of the Federal Motor Vehicle Safety Standards." On December 30, 1968, the Federal Highway Administrator issued a notice extending for 60 days the time for filing comments on a number of the proposed regulations for consumer information. This notice also specified that the proposed regulations would not apply to vehicles produced in two or more stages. I am enclosing a copy of this notice with the appropriate section marked for your information. I regret that we had to ask you to supply a copy of Mr. Decker's letter, but I trust that the above information resolves the issues he raised. |
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.