United States Department of TransportationNHTSA 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: aiam1621OpenMr A.J. Burgess,Vice President (Technical),Joseph Lucas North America Inc.,Two Northfield Plaza,Troy, Michigan 48084; Mr A.J. Burgess Vice President (Technical) Joseph Lucas North America Inc. Two Northfield Plaza Troy Michigan 48084; Dear Mr Burgess:#This responds to your letter of September 30,1974 enclosing sample brake hose assemblies and requesting approval of Girling's labeling and banding techniques to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, for labeling brake hoses and brake hose assemblies. #The NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
|
ID: aiam0933OpenMr. Bernard J. Haynes, Manager, Quality Control, The Stearns & Foster Co., Cincinnati, OH, 45215; Mr. Bernard J. Haynes Manager Quality Control The Stearns & Foster Co. Cincinnati OH 45215; Dear Mr. Haynes: This is in reply to your letter of November 15, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to innerspring mattresses you are going to produce for use in motor homes. You raise four questions in your letter which are restated below.; >>>1. 'Under S4.2 of the Standard, do we test the surface materia only, or is tufting considered bonded, sewed, or mechanically attached to underlying material?'<<<; Paragraph S4.1 of the standard lists mattress covers only, and thi would include the tufting since the tufting is incorporated into mattress covers. Consequently, we would treat the underlying material as separate, and only test mattress covers together with the tufting.; >>>2. 'If it is considered mechanically attached, how do we prepare specimen for test?'<<<; Since only mattress covers in this case must meet the requirements o the standard, the question of the tufting's 'mechanical attachment' to underlying material does not arise. Accordingly, you would prepare test specimens of mattress covers together with the tufting in the manner in which it appears in the vehicle as described in Paragraph S5.2 of the standard.; >>>3. 'The sleeping compartment is without a door and at the rear o both a 22 foot and a 25 foot motor home. Is this area considered in the occupant compartment?'<<<; The occupant compartment of a motor home includes any part designed t be occupied by persons. It would include the sleeping compartment irrespective of whether there is a door separating the sleeping compartment from the driver's compartment.; >>>4. 'Must all the material of the mattress, excluding the innersprin unit, pass the test independently, or is Article C of Section S4.2 about protective padding?'<<<; Paragraph S4.1 of the standard lists mattress covers only. Since S4. only refers to items listed in S4.1, it does not include the mattress stuffing.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam2324OpenMr. Jack Roadman, Box 9971, Pittsburgh, PA 15233; Mr. Jack Roadman Box 9971 Pittsburgh PA 15233; Dear Mr. Roadman: This is in response to your letters of February 26 and March 8, 1976 concerning the certification of a truck that you wish to build with a chassis that you have purchased from International Harvester. You have indicated that the chassis did not include an engine, transmission, or radiator. You installed a diesel engine, transmission, and a new driveshaft, and made various modifications to the chassis. You have had difficulties in persuading a body manufacturer to install a truck body.; The source of your difficulties appears to be a misunderstanding of th requirements of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) and the accompanying certification regulations. Pursuant to the Act, the National Highway Traffic Safety Administration has issued Federal motor vehicle safety standards. These standards apply to completed motor vehicles and to certain items of motor vehicle equipment (e.g., brake hoses, tires). The manufacturer of a motor vehicle or an item of equipment to which a standard applies is required by Section 114 of the Act to certify that his product complies with all applicable Federal motor vehicle safety standards.; 'Incomplete vehicle' is defined in 49 CFR Part 568, *Vehicle Manufactured in Two or More Stages*, as:; >>>an assemblage consisting, as a minimum, of frame and chassi structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle.<<<; An incomplete vehicle is, strictly speaking, an item of motor vehicl equipment. There are no Federal motor vehicle safety standards that apply directly to these particular equipment items, and thus there is presently no certification requirement for incomplete vehicles. The manufacturer of an incomplete vehicle is required by Part 568, however, to furnish an 'incomplete vehicle document'. This document, which is described in S 568.4, must indicate the conformity status of the incomplete vehicle with respect to each standard that applies to the vehicles into which it may be completed.; The chassis that you bought from International Harvester (IH) was a item of motor vehicle equipment to which no standards apply. Therefore, IH was not required to furnish you with a certification of compliance. Further, the chassis was not an incomplete vehicle because it lacked an engine and transmission. Therefore, IH was not required to furnish an incomplete vehicle document. Becuase (sic) of your operations on the chassis, you are the manufacturer of an incomplete vehicle. You, therefore, are the person required to furnish an incomplete vehicle document.; Your letter also indicated a concern thay (sic) you were not given 'certificate of origin' by International Harvester when you purchased the chassis. Federal law does not require the issuance of a certificate of origin. Unless you intended to refer to the Section 114 'certification' discussed above, I assume that you have in mind a document that would be the subject of Pennsylvania state law.; Copies of the Act and the certification regulations are enclosed fo your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
|
ID: aiam0319OpenMr. S. Ashimori, Managing Director, Ashimori Industry Company, Ltd., 15, 4 chrome (sic) Yokobori, Higashi-ku, Osaka, Japan; Mr. S. Ashimori Managing Director Ashimori Industry Company Ltd. 15 4 chrome (sic) Yokobori Higashi-ku Osaka Japan; Dear Mr. Ashimori: Thank you for your letter of April 1, 1971, regarding self-fastenin seat belt systems.; Any system which requires no action by vehicle occupants can be used t meet the appropriate options of Federal Motor Vehicle Safety Standard No. 208 - Occupant Crash Protection. 'No action,' in this case, means that no action is permitted by vehicle occupants other than would be required if the protective system were not present in the vehicle.; We have received a number of petitions for reconsideration o clarification of Notice 9, particularly in reference to the role of a passive (no action) safety belt system as it relates to the requirements for Type 1 or Type 2 seat belt installations prior to August 15, 1975. We are now in the process of resolving the petitions received, and our final decisions in response to the petitions will be issued in the *Federal Register* as soon as possible.; Your interest in our motor vehicle safety programs is most appreciated. Sincerely, Clue D. Ferguson, Director, Office of Crashworthiness, Moto Vehicle Programs; |
|
ID: aiam3866OpenMr. Brian Gill, Senior Manager, Certification Department, American Honda Motor Co., Inc., P.O. Box 50, Gardena, CA 90247; Mr. Brian Gill Senior Manager Certification Department American Honda Motor Co. Inc. P.O. Box 50 Gardena CA 90247; Dear Mr. Gill: This is in response to your letter of May 25, 1984, asking for a interpretation of Motor Vehicle Safety Standard No. 108. Table IV specifies that the minimum horizontal separation distance '(centerline to centerline of lamp)' for rear turn signal lamps on motorcycles is 9 inches. You have asked whether the 'centerline' refers to the distance between the lens centers, between the centers of the effective projected luminous areas, or between the bulb centers.; You asked for confirmation of your belief that the prope interpretation is found in the referenced SAE Standard, J588e, which contains the language 'Optical axes (filament centers),' implying that the correct distance is that between the 'bulb centers' as you term it.; We find no direct correlation between the phrases 'centerline t centerline of lamps' and 'optical axis (filament center).' The lamp is a device emitting light whereas 'optical axis (filament center)' does not refer to the lamp but only to a portion of its light-producing component. As that phrase is used in SAE J588e, it defines the method of measuring distances between bulbs in multi-compartment lamps for the purpose of testing for photometric requirements (paragraph 3.1), or in measuring the separation of the turn signal from the headlamp (paragraph 4.2, where, incidentally, it is expressed as the distance between filament and a lamp component, the retaining ring).; Taken literally, 'centerline to centerline of lamps' in our view mean the distance between lens centers. In the response to petitions for reconsideration of the center high-mounted stoplamp amendment (May 17, 1984), the question was asked whether the 'center' of the lamp was its geometric center, its optical center, or the center of the bulb filament. The agency replied that the center of the lamp is the geometric center. Since the purpose of the minimum separation requirement is to insure that the turn signal is perceived as such, we believe that the correct interpretation of 'centerline to centerline' is a measurement from the geometric center of one lamp to the geometric center of the other lamp. The geometric center would be synonymous with the term 'geometric centroid of lens' as used in SAE J1221 *Headlamp-Turn Signal Spacing*.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam5619OpenThe Honorable Bart Stupak U.S. House of Representatives 902 Ludington St. Escanaba, MI 49829; The Honorable Bart Stupak U.S. House of Representatives 902 Ludington St. Escanaba MI 49829; Dear Mr. Stupak: Thank you for your letter enclosing correspondenc from your constituent, Mr. Kurt B. Ries, concerning our requirements for school vehicles. Your letter was referred to the National Highway Traffic Safety Administration (NHTSA) for reply, since NHTSA regulates the manufacture of all vehicles, including vans and school buses. Mr. Ries, Director of the Northeast Michigan Consortium, asks for relief from what he believes is a new Federal regulation. The Northeast Michigan Consortium uses a number of 15-passenger vans to transport students to employment training programs and jobs. Mr. Ries believes the new Federal regulation will require all vehicles transporting students, including vans, to be replaced with 'mini-school buses,' which he believes is economically unfeasible. I appreciate this opportunity to address your constituent's concerns. As explained below, the new regulation that Mr. Ries is concerned about is not a Federal regulation, but one that Michigan is considering adopting as State law. NHTSA has issued safety standards applicable to new motor vehicles, including school buses. Under our regulations, a 'school bus' is a vehicle carrying 11 or more persons, that is sold to transport children to school or school-related events. Congress has directed NHTSA to require school bus manufacturers to meet safety standards on aspects of school bus safety, including floor strength, seating systems, and crashworthiness. Each seller of a new school bus must ensure that the vehicle is certified as meeting these safety standards. While NHTSA regulates the manufacture and sale of new school buses, this agency does not regulate the use of vehicles. Thus, we do not have a present or pending requirement that would require Mr. Ries to cease using his vans for school transportation. The requirements for the use of school buses and other vehicles are matters for each State to decide. We understand from Mr. Roger Lynas, the State Pupil Transportation Director in Michigan, that Michigan is considering changing its school bus definition to make it more similar to NHTSA's. Such an amendment could affect what vehicles can be used for school transportation under State law. For more information about Michigan's proposed amendment, we suggest Mr. Ries contact Mr. Lynas at (517) 373-4013. NHTSA does not require States to permit only the use of 'school buses' when buses are used for school transportation. However, we support State decisions to do so. NHTSA provides recommendations for the States on various operational aspects of school bus and pupil transportation safety programs, in the form of Highway Safety Program Guideline No. 17, 'Pupil Transportation Safety,' copy enclosed. Since school buses have special safety features that conventional buses do not have, such as padded, high-backed seats, protected fuel tanks, and warning lights and stop arms, they are the safest means to transport school children. Guideline 17 recommends that all buses regularly used for student transportation meet our school bus safety standards. I hope this information is helpful. If you have any further questions, please do not hesitate to contact me. Sincerely, Carol Stroebel Director of Intergovernmental Affairs Enclosure; |
|
ID: aiam2426OpenMs. Valerie Hood, Triplex Safety Glass Co., Eckersall Road Kings Norton, Birmingham B38 8SR, England; Ms. Valerie Hood Triplex Safety Glass Co. Eckersall Road Kings Norton Birmingham B38 8SR England; Dear Ms. Hood: This is in response to your September 8, 1976, letter requestin information concerning the Federal regulations that would be applicable to safety glazing for use in 'slow moving' vehicles. Please excuse our delay in answering your questions. Apparently, your earlier letter of February 5, 1976, was misplaced.; Standard No. 205, *Glazing Materials*, specifies requirements fo glazing materials for use in most motor vehicles and motor vehicle equipment. A glazing manufacturer must certify any glazing that is to be used in a motor vehicle (other than a trailer) as being in compliance with Standard No. 205. 'Motor vehicle' is defined in S 102(3) of the National Traffic and Motor Vehicle Safety Act of 1966. I am enclosing a copy of the agency's opinion of what vehicles qualify as 'motor vehicles' under the definition. Glazing material that is to be used in a vehicle that does not qualify as a 'motor vehicle' does not have to meet the performance requirements of Standard No. 205.; Sincerely, Frank Berndt, Acting Chief Counsel |
|
ID: aiam5249OpenMr. Richard Glover Evenflo Juvenile Furniture Co. 1801 Commerce Dr. Piqua, OH 45356; Mr. Richard Glover Evenflo Juvenile Furniture Co. 1801 Commerce Dr. Piqua OH 45356; "Dear Mr. Glover: This responds to your letter and telephone call about the child seat registration form you are considering. The form is required by S5.8 of Standard 213, 'Child Restraint Systems,' and is depicted in figures 9a and 9b of the standard. You ask whether S5.8(c) permits you to place certain additional information in the shaded area on the form. The information is a bar code that you said on the telephone contains information on 'date of manufacture, shift, location and serial number for the product that the card represents.' You explain that the bar code is desired because it can be automatically scanned, which would avoid possible 'mis-keying' of the information into the data record. Further, you state that the bar code has to be surrounded by a slightly larger unshaded 'quiet zone' to enable the scanner to record the bar code information. You are concerned whether NHTSA would conclude that the quiet zone renders a part of the shaded area unshaded. It is our opinion that a bar code that contains the information you described is permitted in the shaded area (the area outside of the space for the consumer to fill in). S5.8(c) of Standard 213 specifies the information that must be provided on the form and states the following: No other information shall appear on the postcard, except identifying information that distinguishes a particular child restraint system from other systems of that model name or number may be preprinted in the shaded area of the postcard, as shown in figure 9a. The bar code, printed in the shaded area, is permitted by S5.8(c). The information provided by the bar code distinguishes a particular child seat from another of the same model name or number. We consider the quiet zone as part of the bar code since it is needed for the bar code to be reliably read. The quiet zone therefore need not be shaded, since the printed bar code (or any other identifying information permitted by S5.8(c)) itself is not. Please note that, while the bar code is permitted, the information on the model name or number and date of manufacture must still be in English under S5.8(c). This information must be in English so that a consumer can see that this information has been provided and that only minimal effort is needed to fill out the registration form. We also wish to note another feature of the form you faxed. Your form has the words 'please print' after the instructions to the consumer 'just fill in your name and address.' 'Please print' is not on the form depicted in figures 9a and 9b of Standard 213. In an earlier letter, NHTSA decided that a minor variation in the wording of a warning expressly specified by Standard 213 was permitted when the change clarified the warning and did not make any substantive change to the warning's meaning. (Letter to Mr. McGuigan, December 18, 1980.) Similarly, 'please print' is a minor variation to the wording of the instructions that clarifies the instructions and does not substantively change them. Thus, it is permitted. I hope this information is helpful. Please call Ms. Fujita at (202) 366-2992 if you have further questions. Sincerely, John Womack Acting Chief Counsel"; |
|
ID: aiam2076OpenMr. Douglas S. McClenahan, President, Charter Arms Corporation, 430 Sniffens Lane, Stratford, CT 06497; Mr. Douglas S. McClenahan President Charter Arms Corporation 430 Sniffens Lane Stratford CT 06497; Dear Mr. McClenahan: This is in response to your letter of September 16, 1975, inquirin whether approval from the Federal Government is necessary before selling motorcycles manufactured by you.; No approval is necessary in order to market your motorcycles. However you should be aware of the regulations governing manufacturer identification and vehicle certification. Each manufacturer who begins to manufacture motor vehicles must submit certain information to the National Highway Traffic Safety Administration describing the type of motor vehicle manufactured (49 CFR Part 566, copy enclosed). In addition, each vehicle must be certified as being in compliance with all applicable Federal Motor Vehicle Safety Standards in effect at the time of manufacture (49 CFR Part 567, copy enclosed).; If you have any further questions, please contact us. Sincerely, Frank A. Berndt, Acting Chief Counsel |
|
ID: aiam4008OpenMr. Sam Verma, President, Erincraft Mfg. Co., Inc., 742 East 8th Street, Michigan City, IN 46360; Mr. Sam Verma President Erincraft Mfg. Co. Inc. 742 East 8th Street Michigan City IN 46360; Dear Mr. Verma: This responds to your letter of August 6, 1985, asking how to obtain 'DOT number,' so that your company can import truck tires into the United States from a plant in India. The procedures to be followed are set forth in 49 CFR Part 574, *Tire Identification and Recordkeeping*, a copy of which is enclosed for your information.; That regulation requires every tire sold in this country to be labele with certain information (see S574.5), including the identification mark assigned to the manufacturer. To obtain an identification mark, the actual manufacturer of the tires should provide the information specified in S574.6 of the regulation. Please note that an identification mark will be assigned only to the actual manufacturer of tires, and not to companies importing those tires. This is because S574.5 requires that this identification mark be *molded* into or onto all new tires. The only party which can mold the mark on the tire is the actual manufacturer. Therefore, the entity which owns the tire plant in India must apply for the identification mark. An identification mark is normally assigned within two weeks after the receipt of such a request.; The owner of the tire plant in India should also be aware of procedural rule which applies to all parties subject to the regulations of this agency, 49 CFR Part 551 (copy enclosed). This rule requires all manufacturers headquartered outside of the United States to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. The agency may be either an individual or a business entity. The identification mark required by Part 574 will *not* be assigned until this agency has received a valid designation of agent from the Indian tire manufacturer. Part 551 specifies that the designation of agent must contain the following six items of information:; 1. A certification that the designation is valid in form and binding o the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made,; 2. The full legal name, principal place of business and mailing addres of the Indian tire manufacturer,; 3. Marks, trade names, or other designation of origin of any of th manufacturer's tires which do not bear its name,; 4. A statement that the designation shall remain in effect unti withdrawn or replaced by the Indian tire manufacturer.; 5. A declaration of acceptance duly signed by the agent appointed b the Indian tire manufacturer, and the agent may be an individual or a U.S. firm or corporation, and; 6. The full legal name and address of the designated agent. If you need any further information or a clarification of some of th information set forth in this letter, please contact Steve Kratzke of my staff at this address or by telephone (202) 426-2992.; Sincerely, Jeffrey R. Miller, 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.