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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| search results table | |
ID: aiam3378OpenD. G. McGuigan, Esq., Office of the General Counsel, Ford Motor Company, The American Road, Dearborn, MI 48121; D. G. McGuigan Esq. Office of the General Counsel Ford Motor Company The American Road Dearborn MI 48121; Dear Mr. McGuigan: This responds to your letter of November 10, 1980, concerning Standar No. 213, *Child Restraint Systems*. You asked whether Ford may make a minor variation in the language specified in S5.5.2(g) for the label that must be permanently affixed to child restraints. As explained below, you may use the language proposed in your letter.; Section 5.5.1 of the standard requires that each child restraint b permanently labeled with specified information. Section 5.5.3 requires that the information specified in S5.5.2(g)-(k) must be displayed on the child restraint so that it is visible when the restraint is installed in the vehicle.; You state that the only information specified for the visible labe that is applicable to the Ford 'TOT GUARD' is the language in S5.5.2(g). That section provides that the child restraint must be labeled with the following words:; >>>WARNING! FAILURE TO FOLLOW EACH OF THE FOLLOWING INSTRUCTIONS CA RESULT IN YOUR CHILD STRIKING THE VEHICLE'S INTERIOR DURING A SUDDEN STOP OR CRASH:; SECURE THIS CHILD RESTRAINT WITH A VEHICLE BELT AS SPECIFIED IN TH MANUFACTURER'S INSTRUCTIONS LOCATED________________.<<<; You are concerned that the above language may create potentia confusion for users of the 'TOT GUARD' since the user might be led to believe that more than one instruction is applicable. In your proposed revision, the word(sic) 'each of' would be deleted from the warning and the word 'instructions' would be changed to the singular.; Your proposed revision does not make any substantive change in th meaning of the warning specified for the label. Since the proposed change is a minor variation intended to clarify the language for restraints that only need to be labeled with one of the specified instructions, it is permitted.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1345OpenMr. Thomas S. Pieratt, Truck Equipment & Body, 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Truck Equipment & Body 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of November 6, 1973, requestin information on whether vehicle certification labels must be affixed by persons who for their own use install fifth wheels on chassis cabs.; The NHTSA takes the position that vehicles completed by persons fo their own use must conform to all applicable motor vehicle safety standards and be certified (by affixing the appropriate label) as conforming. The NHTSA considers the use of these vehicles to be an introduction or delivery for introduction in interstate commerce and subject to the prohibitions of section 108 of the Safety Act. Persons who complete incomplete vehicles are final-stage manufacturers and all other regulations applicable to manufacturers (Parts 566, 573, and 577) apply to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3682OpenMr. Richard H. Attenhofer, Technical Manager, O.E., Dunlop Tire Company, Box 1109, Buffalo, NY 14240; Mr. Richard H. Attenhofer Technical Manager O.E. Dunlop Tire Company Box 1109 Buffalo NY 14240; Dear Attenhofer: This responds to your recent letter to Mr. Kratzke of my staff requesting an interpretation of 49 CFR Part 574, *Tire Identification and Recordkeeping*. Specifically, you asked if Dunlop could use a print type called OCR-A for the DOT symbol and the tire identification number.; Note 1 to Figure 1 of Part 574 specifies only four different prin types which may be used for the DOT symbol and identification number, none of which are OCR-A. However, Note 4 to Figure 1 states that other print type will be permitted if approved by this agency. We have examined the print type shown in the diagram attached to your letter and have no objections to your company printing the required information in OCR-A type.; In the final rule establishing Part 574 (35 FR 17257, November 10 1970), the agency explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The OCR-A print type shown in the diagram attached to your letter is easily readable and thus satisfies our concerns in that regard. Accordingly, that print type is hereby approved.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4147OpenJacques M. Delphin, M.D., 84 Haight Avenue, Poughkeepsie, NY 12603; Jacques M. Delphin M.D. 84 Haight Avenue Poughkeepsie NY 12603; Dear Dr. Delphin: This is in reply to your letter of April 2, 1986, enclosing description of your device to improve car signals, and asking about the regulations applicable to it.; According to the information that you furnished, the device 'cancel turn signal indicators immediately upon the completion of a turn'. The purpose of the device is to eliminate 'the need for drivers to cancel the signal manually when the turn is not sharp enough to activate the standard switch'. The effect of the device is 'to reduce the incidence of traffic accidents due to misinterpreted turn signals'.; As you know, pursuant to Federal Motor Vehicle Safety Standard No. 10 *Lamps, Reflective Devices, and Associated Equipment*, passenger cars manufactured on or after January 1, 1973, have been required to have self- cancelling turn signal indicators. However, there are no performance requirements for the self-cancelling feature. As a general rule, motor vehicle lighting equipment not required by Standard No. 108 is permissible as original equipment provided that it does not impair the effectiveness of lighting equipment required by the standard, and as aftermarket equipment if its installation can be accomplished without creating a noncompliance. The device as you have described it does not appear to impair the effectiveness of the turn signal operating unit, or create a noncompliance with Standard No. 108 (the requirements of SAE Standard J589 *Turn Signal Operating Unit*, April 1964, which is incorporated by reference). Since Standard No. 108 does not preclude its use, the question of its legality is therefore determinable under the laws of each State where it will be used.; Although there is no Federal safety standard that applies to it, th device is an item of motor vehicle equipment subject to the notification and remedy provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, 1411) if its manufacturer or this agency determines that it incorporates a safety related defect.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2990OpenMr. Thomas E. Cole, Vice President, Tire Division, Rubber Manufacturers Association, 1901 Pennsylvania Ave., N.W., Washington, DC 20006; Mr. Thomas E. Cole Vice President Tire Division Rubber Manufacturers Association 1901 Pennsylvania Ave. N.W. Washington DC 20006; Dear Mr. Cole: In your letter of March 19, you pointed out that the tire industry ha printed tire tread labels and consumer information materials based on Figure 2 of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104), as published in the National Highway Traffic Safety Administration's (NHTSA) Docket 25, Notice 24 (43 FR 30542, July 17, 1978). That notice contained a typographical error in the text of Figure 2, which was corrected in Notice 31 (44 FR 15721, March 15, 1979) by substitution of the word 'are' in place of the word 'of' in the first line of the third section of Figure 2.; The labels and other materials printed prior to the issuance of Notic 31 may be technically in noncompliance with the UTQG regulation. To avoid the waste which would result if use of these materials were prohibited, however, NHTSA will permit use of tread labels and information materials containing the Figure 2 text as stated in Notice 24, where orders for printing of these materials were submitted prior to March 15, 1979, the date of publication of Notice 31.; Sincerely, Michael M. Finkelstein, Associate Administrator fo Rulemaking; |
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ID: aiam0104OpenMr. Harry G. Seitz, Driver Education Coordinator, Cleveland Public Schools, 1380 East Sixth Street, Cleveland, Ohio 44114; Mr. Harry G. Seitz Driver Education Coordinator Cleveland Public Schools 1380 East Sixth Street Cleveland Ohio 44114; Dear Mr. Seitz: Your letter of July 3, 1968, addressed to Mr. George C. Nield, of th National Highway Safety Bureau has been forwarded to my office for reply.; The installation of dual controls on driver education cars is not *pe se* in violation of the Federal motor vehicle safety standards. However, the secondary equipment must meet the same safety standards established or the primary controls. The secondary steering column must fulfill the same requirements made for the primary column as set forth in Federal Motor Vehicle Safety Standards Nos. 203 and 204. The installation of an additional foot brake must not affect compliance with Standard No. 105. However, duplicate compliance with the control location and identification requirements of Standard No. 101 is not required since the 'driver' of such a vehicle remains the person seated behind the primary controls. For the same reason the 'driver' mirror requirements of Standard No. 111 apply only with respect to the person seated at the primary controls.; Changes may be made to original equipment when necessary fo installation of secondary controls but none of the standards requirements specified may be eliminated or adversely affected by the alteration.; You may make available copies of this letter to dealers and intereste parties.; Sincerely, Eugene B. Laskin, Acting Director, Office of Standard Preparation; |
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ID: aiam2139OpenMr. Robert L. Webber, Vice President, American Sports Co. Inc., P. O. Box 5603, 2970 East Maria Street, Compton, CA 90221; Mr. Robert L. Webber Vice President American Sports Co. Inc. P. O. Box 5603 2970 East Maria Street Compton CA 90221; Dear Mr. Webber: This is in response to your request of November 21, 1975, for a opinion regarding requirements for certifying universal sized helmets pursuant to Federal Motor Vehicle Safety Standard No. 218.; The requirements of Standard No. 218, *Motorcycle Helmets*, apply t helmets that fit headform size C. This includes the case where, by means of an adjusting mechanism supplied by the manufacturer for the purpose of permitting adjustment to headform size C, the helmet can readily be made to fit headform size C. Thus, any helmet that the manufacturer intends for use by persons with heads in the size C range must meet the requirements of the standard, including the requirement to affix the label required by section 5.6.1 of the standard.; The 'universal' helmet described in your letter seems to fall withi these guidelines in that it is intended to fit, *inter* *alia*, the size C headform. Therefore, notwithstanding the fact that it may also be adjusted to fit other size headforms, it should meet the requirements of FMVSS No. 218, including the labeling requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5306OpenMr. Andrew Tweddle AV Technology Corp. 2340 Alger Troy, MI 48083; Mr. Andrew Tweddle AV Technology Corp. 2340 Alger Troy MI 48083; Dear Mr. Tweddle: This responds to your request for an interpretatio whether AV Technology's armored vehicle is subject to the Federal Motor Vehicle Safety Standards (FMVSSs). As explained below, a vehicle manufactured to U.S. Army contract specifications, and sold to the Army, is not subject to the FMVSSs. In your letter, you explained that AV Technology is in the process of responding to a Department of the Army draft specification for an armored security vehicle. AV Technology proposes to offer its Dragoon ASV, an armored security vehicle, with a weapon carrying capability. Your letter states that the Dragoon ASV would be built to U.S. Army specification MIL-STD-1180. In a telephone conversation with Dorothy Nakama of my staff, you stated that the Dragoon ASV would also be built to other applicable military specifications. The FMVSSs' applicability to vehicles manufactured for and sold to the U.S. military, is addressed at 49 CFR 571.7(c): (c) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications. You stated the Dragoon ASV would be manufactured to all applicable military specifications, specified by the Army. The Army is part of the 'Armed Forces.' Thus, when manufactured to Army contractual specifications, and sold to the Army, the Dragoon ASV is not subject to the FMVSSs. If you have any questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam0554OpenMr. H. Braun, Engineering Supervisor - Production, Motor Coach Industries, Inc., Pembina, ND 58271; Mr. H. Braun Engineering Supervisor - Production Motor Coach Industries Inc. Pembina ND 58271; Dear Mr. Braun: This is in reply to your letter of October 23, 1972, in which you as whether it is permissible under the Certification regulations for you to list alternative tire sizes and gross axle weight ratings on certification labels for vehicles which you sell without tires, but on which you apparently install them before delivery. You indicate that the tires are supplied by the customer, which he either owns, leases, or purchases from you.; Under the Certification regulation, you may if you wish lis alternative tire sizes, and alternative gross vehicle or gross axle weight ratings, as you described in your letter. If you install the tires, regardless of whether they are owned by the vehicle purchaser, leased, or purchased from you, the tire you install should be one of the alternative sizes listed on the certification label.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2569OpenHonorable John W. Wydler, House of Representatives, Washington, DC 20515; Honorable John W. Wydler House of Representatives Washington DC 20515; Dear Mr. Wydler: Thank you for your letter of April 21, 1977, requesting informatio concerning Federal regulations regarding school bus safety on behalf of your constituent, Mrs. Peter Peugeot of Rockville Centre, New York.; I have enclosed a document, 'Summary Description of Motor Vehicl Safety Standards Applicable to Buses,' which should be helpful to Mrs. Peugeot. I have also enclosed an informational summary, 'Where to Obtain Motor Vehicle Safety Standards and Regulations,' along with a set of forms from our Technical Reference Branch indicating how specific information may be retrieved through computer assisted literature searches along with an outline of fees for this service.; In addition to the above material, I have enclosed an order form fo the entire set of Federal motor vehicle safety standards and regulations, in case Mrs. Peugeot desires this specific volume. I would call her attention to the fact that although this document is relatively expensive, it is furnished in loose-leaf form and is updated periodically for an indefinite period with the latest amendments and changes at no additional cost.; I trust this information and material will be of value to Mrs. Peugeot If I can be of further assistance, please do not hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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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.