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: aiam2816OpenMr. Robert J. Voshell, Director, Motor Vehicle Division, State of Delaware, P.O. Box 698, Dover, DE 19901; Mr. Robert J. Voshell Director Motor Vehicle Division State of Delaware P.O. Box 698 Dover DE 19901; Dear Mr. Voshell: This is in reply to your letter of May 18, 1978 which asks th following questions:; >>>'Is there a Motor Vehicle Safety Standard which requires al motorcycles to be equipped with turn signals, other than those expressly exempted under FMVSS 108 (whose speed attainable in 1 mile is 30 mph or less) S4.1.1.26?'<<<; Yes. Paragraph S4.1.1 of Standard No. 108 requires, in part, that moto vehicles be equipped with the lamps specified in Table III. Turn signal lamps are required for motorcycles under Table III.; >>>'Does the standard apply to only highway-use vehicles wit trail-bikes exempted?'<<<; Yes. The motorcycles covered by Standard No. 108 must be 'moto vehicles' in the first instance, in order to be subject to the regulatory authority of the National Traffic and Motor Vehicle Safety Act. A 'motor vehicle' is one 'manufactured primarily for use on the public streets, roads and highways'. This would exclude a trail bike unless its manufacturer had certified it to meet all applicable Federal motor vehicle safety standards, indicating his intent that it be used on-road as well as off-road.; We are enclosing a copy of Standard No. 108 as you requested. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3211OpenMr. David Shomberg, Bus Con Corporation, 19 South Main Street, Spring Valley, NY 10977; Mr. David Shomberg Bus Con Corporation 19 South Main Street Spring Valley NY 10977; Dear Mr. Shomberg: This responds to your January 22, 1980, letter asking two question about the use of your body conversion numbers on the certification labels of vehicles you produce.; First, you ask whether a final-stage manufacturer may substitute it body conversion number for the vehicle identification number (VIN) that comes with the incomplete vehicle. The answer to this question is no. The VIN must be continued from the incomplete vehicle certification label to the final-stage certification label. However, you may insert your body conversion number on the label in addition to the VIN. Your number should appear at the bottom of the label below the required information.; In your second question, you ask whether you may include your bod conversion number on the alterers' labels for previously certified vehicles that you alter. The answer to this question is yes. As indicated above the number should appear at the bottom of the label below the required information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4184OpenMr. William H. Spain, National Management, Inc., P.O. Box 3528, Montgomery, AL 36109; Mr. William H. Spain National Management Inc. P.O. Box 3528 Montgomery AL 36109; Dear Mr. Spain: Thank you for your letter of May 20, 1986, asking how our regulation would apply to a wooden steering wheel you manufacture. You explained that you use a standard steering wheel with a steel outer rim. The steel outer rim is then veneered with wood, which is covered with a protective finish. The finished wheel will then be used as an item of original equipment by a vehicle manufacturer. I hope the following discussion answers your question.; The agency has issued two Federal Motor Vehicle Safety Standards tha set occupant crash protection performance requirements for vehicle steering systems, which includes the steering wheel. Those standards are Standard No. 203, *Impact Protection for the Driver from the Steering System*, and Standard No. 204, *Steering Column Rearward Displacement*. Those two standards do not regulate the types of material that may be used in the steering wheel, but instead set performance requirements that the steering systems must meet under certain test conditions. Therefore, a manufacturer may use any material in its steering wheel, as long as the steering system still complies with the performance requirements of Standard Nos. 203 and 204.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3641OpenCharles R. Sidner, CPSM, Product Safety Engineer, Grumman Flxible Corporation, 970 Pittsburgh Drive, Delaware, OH 43015; Charles R. Sidner CPSM Product Safety Engineer Grumman Flxible Corporation 970 Pittsburgh Drive Delaware OH 43015; Dear Mr. Sidner: This responds to your March 31, 1983, letter asking about the lo-ai pressure warning device that is required by Standard No. 121, *Air Brake Systems*. In particular you ask whether the requirement must be met with two switches, one on the primary and one on the secondary air tank, or whether one switch on the supply tank would be sufficient.; S5.1.5 of the standard states that a warning signal shall be provide to give a continuous warning of a loss of pressure in the service reservoir system below 60 p.s.i. The intent of the section clearly is to provide a warning to a driver of any instance that results in a loss of pressure in either the primary or secondary service reservoir system.; Depending upon the design of any individual brake system, it might b necessary for more than one switch to ensure that the driver will be alerted to such an air loss. For example, a single switch on the supply tank might be inadequate to signal a loss of pressure in the primary or secondary service reservoir system if the action of the compressor masks such loss of pressure. It is up to the manufacturer to determine whether its system is designed in a way that requires more than one switch.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2953OpenMr. Hisakazu Murakami, Staff, Safety, Nissan Motor Co., Ltd., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Hisakazu Murakami Staff Safety Nissan Motor Co. Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Murakami: This responds to your January 9, 1979, letter concerning a mistake o the certification labels of approximately 2000 Datsun trucks. You stated that the vehicles, although manufactured in 1979, were incorrectly dated on their certification labels as being manufactured in 1978. You propose to remedy the affected vehicles by crossing out the incorrect date and inserting the correct information.; Your proposed correction is acceptable to the National Highway Traffi Safety Administration. As long as all other information on the certification label is correct, your modification of existing certification labels will comply with the agency's regulations.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1386OpenMiss Charlotte D. Myers, W. E. Myers Estate, Petroleum Equipment, 177 Ferguson Avenue, Burlington, VT 05401; Miss Charlotte D. Myers W. E. Myers Estate Petroleum Equipment 177 Ferguson Avenue Burlington VT 05401; Dear Miss Myers: Your request for information concerning the transfer of cargo tank from one chassis to another has been brought to our attention by the Bureau of Motor Carrier Safety.; The National Traffic and Motor Vehicle Safety Act requires that a labe certifying the compliance of motor vehicles to all applicable safety standards be affixed to a vehicle by its manufacturer. Certification regulations enacted pursuant to the mandate of the Act require the final-stage manufacturer to provide the certification of the vehicle with all applicable standards, based on information concerning the conformity of the chassis furnished by the chassis manufacturer pursuant to our regulations. This means that cargo tank manufacturers who install the tanks on the chassis and so complete the vehicle must certify it as a finished product.; Responding to your specific question, the action of transferring cargo tank from one chassis to another would require a label certifying that the vehicle complies with all applicable safety standards if the chassis was new and had not yet been purchased for purposes other than resale. If the chassis was one which had already been purchased for purposes other than resale, there would be no obligation to recertify the compliance of the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2400OpenMr. Edgar E. Lungren, Jr., Pullman Trailmobile, 200 East Randolf Drive, Chicago, IL 60601; Mr. Edgar E. Lungren Jr. Pullman Trailmobile 200 East Randolf Drive Chicago IL 60601; Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identity and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2050OpenMr. William C. Koch, Assistant Attorney General for Consumer Protection, Room 419, Supreme Court Building, Nashville, TN 37219; Mr. William C. Koch Assistant Attorney General for Consumer Protection Room 419 Supreme Court Building Nashville TN 37219; Dear Mr. Koch: As you requested in your August 29, 1975, telephone conversation wit Karen Kreshover of this office, I am forwarding to you an interpretation of Section 580.5(b) of 49 CFR Part 580, *Odometer Disclosure Requirements*, as it applies to new car dealers.; Section 580.5(b) states that an odometer disclosure form need not b executed by transferors of new vehicles before their first transfer for purposes other than resale. This means that a distributor of new vehicles is not required to provide a dealer with odometer disclosure statements for vehicles he transfers to him. A new vehicle dealer, however, must complete disclosure statements for all vehicles he transfers to person who are taking possession for purposes other than reselling the vehicles. In other words, even a new vehicle which has not been previously sold to a consumer must have its odometer mileage certified in compliance with the odometer disclosure requirements when it is transferred.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4887OpenMr. Cliff Chuang Chief Design Engineer Prospects Corporation 114 Crawford Street Lowell, MA 01854; Mr. Cliff Chuang Chief Design Engineer Prospects Corporation 114 Crawford Street Lowell MA 01854; "Dear Mr. Chuang: This responds to your letter seeking clarification o recent amendments to Standard No. 118, Power-operated Window Systems (49 CFR 571.118), as published in the Federal Register on April 16, 1991. Specifically, you were interested in new requirements applicable to remote control operations of power windows. You first asked for confirmation of your interpretation of the new requirement in S5(a) that, while closing, remote control-operated power windows automatically reverse direction 'when they meet a resistive force of 22 pounds or more.' You also asked for an interpretation of the term 'daylight opening' as it appears in S5(b) of Standard No. 118. This agency has received several petitions for reconsideration of the recent amendments to Standard No. 118 with respect to the automatic reversal requirements. In response to the petitions, NHTSA is currently reexamining several aspects of this requirement, including those raised in your letter. The agency will publish its response to the petitions for reconsideration in the Federal Register after it has finished its reexamination of the automatic reversal requirement in the April 16 final rule. Please let us know if you have any questions about this new automatic reversal requirement after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. I hope this information is helpful to you. Please contact us if you have further questions. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0597OpenMr. V. A. Nolte, Fairmont Railway Motors, Inc., Fairmont, MN 56031; Mr. V. A. Nolte Fairmont Railway Motors Inc. Fairmont MN 56031; Dear Mr. Nolte: This is in reply to your letter of January 4, 1973, concerning th applicability of the Federal motor vehicle safety standards to passenger cars with railway guide wheels manufactured by your company.; You indicate that the guide wheels are installed on a passenger car b removing the bumpers, installing the wheels, and reinstalling the bumper shock absorbers with a new bumper of your own design. This operation is considered to be a manufacturing operation, for purposes of our regulations. If Fairmont installs the wheels on a new vehicle, then sells the vehicle to a customer, the vehicle will have to conform to the applicable safety standards. If, however, Fairmont installs the wheels on a completed vehicle that is owned by the customer, or if it sells the wheel assemblies for installation by a customer, the vehicle will not be required to conform.; The safety standard applicable to passenger car bumpers is Standard No 215. I have enclosed a copy for your reference.; Yours truly, Richard B. Dyson, Assistant 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.