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
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ID: aiam2545OpenMr. Robert B. Kurre, Director of Engineering, Wayne Corporation, Post Office Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director of Engineering Wayne Corporation Post Office Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: this responds to your February 22, 1977, letter asking whether restraining barrier in front of a seat with a back higher than that required in S5.1.2 of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, must coincide with or lie outside of the perimeter of the extended seat back.; The requirements for restraining barrier surface area are found i paragraph S5.2.2 of the standard. That section states that: 'in a front projected view of the bus, each point of the barrier's perimeter coincides with or lies outside of the perimeter of the seat back of the seat for which it is required.' The seat back of the seat for which a restraining barrier is required has dimensions specified in S5.1.2 of the standard. Therefore, a restraining barrier must only coincide with or lie outside of the seat back surface required by S5.1.2. If a seat back surface exceeds the size required in Standard No. 222, the size of the restraining barrier need not coincide.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0128OpenMr. H.F. Barr, Vice President, General Motors Engineering Staff, General Motors Technical Center, Warren, Michigan 48090; Mr. H.F. Barr Vice President General Motors Engineering Staff General Motors Technical Center Warren Michigan 48090; Dear Mr. Barr: This will acknowledge your letter of October 23, 1968, requesting th addition of the 5-inch alternative rim size for use with the 155-13/6.15-13 tire size designation.; In your request you cited a letter from the German Rubber Industr stating that 'for passenger car tires in addition to the rim specified in the German Industrial Standards (DIN) also the use of the next large size rims is permissible.' The subject of the foot note in the German standard was discussed by my staff in conversations with Mr. Von Polhemus. When the Federal Motor Vehicle Safety Standards were written, it was the intent to accept the German Industrial Standards (DIN) of 1967 for all tire and rim combinations listed based on established usage. We did not intend to apply foot notes from any 1967 reference materials to the present or future tire and rim combinations.; However, on the basis of the data submitted indicating compliance wit the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the *Federal Register,* Volume 33, No. 195, page 14969, dated october 5, 1963, the 5J alternative rim size for the 155-13/6.15-13 tire size designation will be listed within Table I of Appendix A to Standard No. 110. This change will be published in the *Federal Register* in the near future.; The addition on this new alternative rim size to the table i accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim size. If no comments are received, the amendment becomes effective after 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of Procedural Rules for Motor Vehicle Safety Standards will be considered.; Sincerely, H.M. Jacklin, Jr., Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam2115OpenMr. William F. Morie, Executive Vice President, Georgia Automobile Dealers Association, 508 Hartford Building, 100 Edgewood Avenue, N.E., Atlanta, GA 30303; Mr. William F. Morie Executive Vice President Georgia Automobile Dealers Association 508 Hartford Building 100 Edgewood Avenue N.E. Atlanta GA 30303; Dear Mr. Morie: This is in response to your letter of September 19, 1975, inquiring a to the disclosure responsibilities of an individual who sells a vehicle with nonoperational odometer.; You describe a situation in which a dealer executed an odomete disclosure statement indicating that the actual odometer mileage was unknown where the odometer was nonfunctional. Apparently, the purchaser now claims sale of the vehicle with such an odometer inaccuracy constitutes misrepresentation by the dealer.; Based upon the facts of the case as you have presented them, th National Highway Traffic Safety Administration (NHTSA) does not consider that a violation of the odometer requirements of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513) has occurred. If the dealer in question executed an odometer disclosure statement, at the time of sale, that complies with the Federal disclosure requirements (49 CFR Part 580, *Odometer Disclosure Requirements), and states that the mileage indicated on the odometer differs from the true mileage for reasons other than calibration error he satisfied his responsibilities under the law. The buyer was informed that the odometer mileage was incorrect and therefore should not be relied upon as an indication of the vehicle's condition.; As long as a seller informs his buyer as to the validity of th odometer mileage, he has no additional responsibility to repair an apparently nonfunctional odometer.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1693OpenMr. W.A. Hertel,Corporate Staff Engineer,Parker-Hannifin Corporation,17325 Euclid Avenue,Cleveland, Ohio 44112; Mr. W.A. Hertel Corporate Staff Engineer Parker-Hannifin Corporation 17325 Euclid Avenue Cleveland Ohio 44112; Dear Mr. Hertel:#Please forgive the delay in responding to your lette of October 28, 1974, enclosing a sample air brake hose assembly and requesting approval of Parker-Hannifin's banding technique to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, for labeling 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 i 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; |
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ID: aiam0981OpenMr. Carl Monk, 428 Southland Boulevard, Louisville, Kentucky 40214; Mr. Carl Monk 428 Southland Boulevard Louisville Kentucky 40214; Dear Mr. Monk: This is in further response to your letter of January 5, 1973, to Mrs Virginia Knauer, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 125, *Warning Devices*.; As you already know from Mr. E.T. Driver's letter of January 24, 1973 and previous correspondence from my office and the Department of Transportation, the National Highway Traffic Safety Administration issued the standard as an equipment item that would be suitable for use in all types of vehicles, from trucks to passenger cars.; In issuing the standard, we were concerned with the great variety o devices presently available, which can create confusion and misunderstanding to the motoring public. We were also concerned with wind stability, and your comments were most useful in our consideration of this aspect of the requirements. FMVSS No. 125 is an attempt to achieve a standardized device having a proper balance of the factors affecting shape, size, cost, visibility, wind stability and weight. These are minimum standards and the manufacture and sale of devices that exceed these requirements is not prohibited.; Again, thank you for your comments. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3354OpenMr. Rodney Ehrlich, Director of Engineering Monon Trailer Division, Evans Transportation Company, 117 North Walnut, P.O. Box 655, Monon, Indiana 47959; Mr. Rodney Ehrlich Director of Engineering Monon Trailer Division Evans Transportation Company 117 North Walnut P.O. Box 655 Monon Indiana 47959; Dear Mr. Ehrlich: This will confirm your telephone conversation with Mr. Frederi Schwartz of my office concerning your proposed compliance scheme for the Federal Motor Vehicle Safety Standard No. 115 - Vehicle identification number.; The National Highway Traffic Safety Administration (NHTSA) does no give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115. This system may be implemented immediately.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4491OpenMr. Richard J. Matysiak President Auto Chek, Inc. P.O. Box 258 Stone Mountain, GA 30086-0258; Mr. Richard J. Matysiak President Auto Chek Inc. P.O. Box 258 Stone Mountain GA 30086-0258; "Dear Mr. Matysiak: This responds to your letter to Mr. Frank Ephrai of our Office of Plans and Policy, asking about the effects of the Federal Motor Vehicle Theft Prevention Standard (49 CFR Part 541, copy enclosed) on certain body repair processes. Specifically, you asked how the theft prevention standard would affect the body repair process of 'clipping' body sections from one vehicle and attaching the clipped section to a different vehicle. This repair process is not prohibited or regulated by the theft prevention standard, as explained below. The purpose of the theft prevention standard is to reduce the incidence of motor vehicle thefts by facilitating the tracing and recovery of parts from stolen vehicles. To achieve this purpose, the theft prevention standard requires manufacturers to affix or inscribe identification markings onto 14 major original equipment and replacement parts of certain high theft cars. Dealers and repair shops are prohibited from removing, obliterating, tampering with, or altering these identification markings, unless the removal, obliteration, tampering, or alteration is reasonably necessary to repair the part or vehicle, see 18 U.S.C. 511. These requirements should not significantly impact the repair process of 'clipping' described in your letter. Nothing in the theft prevention standard or the law prohibits a repair shop from clipping sections from wrecked vehicles. The repair shop would be required by law to leave in place any identification markings on the 'clipped' section that were not damaged in the 'clipping' process. As noted in your letter, the repaired vehicle might have two different vehicle identification numbers (VIN's) marked on its major parts, with some parts marked with the VIN assigned to the repaired vehicle and other parts marked with the VIN assigned to the damaged vehicle from which the section was 'clipped.' The Motor Vehicle Theft Law Enforcement Act of 1984, which ordered this agency to promulgate the theft prevention standard, clearly contemplates that vehicles undergoing repair could wind up with some parts numbered differently than the parts originally on the car. That law is based on the idea that some major parts are likely to survive a crash undamaged and that those parts can legitimately be used to repair other vehicles. Such repairs would naturally result in repaired cars having some parts numbered differently than the rest of the car. Since the law enforcement community vigorously supported this law, they must not have believed that cars with some parts numbered differently than the other parts of the car would pose particular problems for them. You also asked how the 'clipping' process would affect our disclosure and titling requirements. We answered the question of how the disclosure requirements apply in an October 15, 1980 letter to Mr. John Kelly of the Iowa Department of Transportation. In the letter to Mr. Kelly, we said, '... if a vehicle is constructed from the parts of several vehicles, the odometer statement must still be completed at the time of sale. If the seller knows the mileage on the various components used to construct the vehicle, he should inform the purchaser of the highest mileage that he knows, or the mileage on the chassis if he knows it. If he does not know the mileages, he will be required to state that the mileage is not accurate and should not be relied upon. Titling requirements and designations such as 'salvage' and 'rebuilt' vehicles are determined by State law, not Federal law. If you have any further questions on this matter, please contact Steve Kratzke of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam1369OpenMr. Danny Lanzdorf,Oshkosh Truck Corporation,2307 Oregon St.,Oshkosh, Wisconsin 54901; Mr. Danny Lanzdorf Oshkosh Truck Corporation 2307 Oregon St. Oshkosh Wisconsin 54901; Dear Mr. Lanzdorf:#This is to confirm your conversation of December 12 1974, with Mark Schwimmer of this office, in which you requested information on the permissibility of spray painting brake hose end fittings in the trucks which you manufacture.#Because the construction of the brake hose assembly is completed before the spray painting would take place, the only requirement of Motor Vehicle Safety Standard No. 106-74 which might prohibit the painting would be a vehicle requirement. Standard No. 106-74 as applied to vehicles is not effective until September 1, 1975, therefore, you may spray paint end fittings until then. The next Federal Register notice concerning the standard will deal with the permissibility of painting end fittings after the September, 1975 effective date.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam3704OpenMr. H. Nakaya, Manager, Mazda (North America) Inc., 23777 Greenfield Road - Suite 462, Southfield, MI 48075; Mr. H. Nakaya Manager Mazda (North America) Inc. 23777 Greenfield Road - Suite 462 Southfield MI 48075; Dear Mr. Nakaya: This is in reply to your letter of May 24, 1983, asking whether th headlamp bezel is considered a 'styling ornament or other feature' for purposes of paragraph 5.2 of SAE J580 *Sealed Beam Headlamp Assembly*, Aug 79 incorporated by reference in Standard No. 108.; The referenced SAE paragraph prohibits styling ornaments or othe features in front of the lens when the headlamp is in use. The intent of this paragraph is to guarantee optimum light output from the headlamp by insuring that no part of the vehicle interferes with the light pattern. If a headlamp bezel is so large that it could interfere with the design light patterns of the lamp, we would consider it a 'styling ornament or other feature' within the meaning of paragraph 5.2.; An oversize bezel interfering with light output would also b prohibited by paragraph S4.1.3 of Standard No. 108 which prohibits installation of motor vehicle equipment that impairs the effectiveness of lighting equipment which the standard requires.; I hope that this answers your question. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1739OpenMr. Harry J. Warmkessel,Mack Trucks, Inc.,Box M,Allentown, Pennsylvania 18105; Mr. Harry J. Warmkessel Mack Trucks Inc. Box M Allentown Pennsylvania 18105; Dear Mr. Warmkessel:#This responds to the August 1, 1974, request o Mack Trucks, inc., that the painting of brake hose end fittings be permitted under the Federal Motor Vehicle Safety Standards No. 106-74.#In the preamble to amendments to the standard which were published June 28, 1974 (39 FR 24012, Docket No. 1-5, Notice 11), the NHTSA interpreted S5.2.3 as prohibiting the painting of end fittings because required labeling would be obscured.#New information indicates that spray painting of end fittings leaves their labeling visible in most cases and that, in the occasional instance where labeling is obscured, excess paint may be easily scraped off. In addition, painting protects the labeled and fittings against corrosion. Therefore, the NHTSA is changing its interpretation of this section, so that the painting of end fittings will not be considered a violation of the standard.#The issue of masking brake hose labeling will be dealt with in the next Federal Register Notice regarding Standard No. 106-74.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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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.