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: aiam0638OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Co., Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Co. Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: In your letter of March 3, 1972, you asked for our interpretation o how a rigid bracket installed on the B-pillar to guide the shoulder belt would be treated under Standard 210.; Although the bracket in question does not perform all the functions o the anchorage, in that it would sustain only a fraction of the total force imposed on the anchorage in an accident, it performs a significant anchorage function by controlling the angle at which the shoulder belt crosses the occupant's chest. It is therefore considered a part of the anchorage and must fall within the acceptable range for upper torso anchorage locations specified in Standard 210.; If you have information to indicate that the acceptable zone could b extended forward of its present position without lessening the effectiveness of the shoulder belt, we would be most interested in obtaining it for review.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2605OpenMr. T. V. Barlow, BSG International, Britax (Wingard ) Limited, Chichester West Sussex PO19 2UG, England; Mr. T. V. Barlow BSG International Britax (Wingard ) Limited Chichester West Sussex PO19 2UG England; Dear Mr.Barlow: This responds to your letter of May 5, 1977, requesting clarificatio of the relationship between paragraph S5.3 of Safety Standard No. 208, *Occupant Crash Protection*, and Safety Standard No. 216, *Roof Crush Resistance*. It is your understanding that Standard No. 216 becomes 'obsolete and ineffective' after August 15, 1977.; Your interpretation is incorrect. Standard No. 216 is a separate independent standard from Standard No. 208 and remains effective in its present form regardless of the amendment of Standard No. 208 according to any of the three alternative proposals issued by Secretary Adams (42 FR 15935, March 24, 1977). Standard No. 216 is applicable to all passenger cars except those that conform to the rollover test requirements of paragraph S5.3 of Standard No. 208 by totally passive means.; Under existing Standard No. 208, a manufacturer must meet the rollove requirements of paragraph S5.3 only if he chooses to use option S4.1.2.1 (total passive protection). If the manufacturer chooses this option he can meet the requirements of Standard No. 216 instead of the rollover requirements of S5.3 until August 15, 1977, but not after that date since the alternative then expires. A manufacturer choosing to use either option S4.1.2.2 or option S4.1.2.3 of Standard No. 208 does not have to meet the rollover requirements of paragraph S5.3, at all. As a manufacturer of seat belts, you are undoubtedly aware that a majority of vehicle manufacturers choose to comply with Standard No. 208 by means of option S4.1.2.3.; If Secretary Adams' Alternative proposal I or Alternative proposal II becomes a final rule, Standard No. 208 will remain in the form just described above. The Secretary's Alternative II (mandatory passive restraints) proposes to make the lateral (S5.2) and rollover (S5.3) requirements of Standard No. 208 optional. A manufacturer would be permitted to use a totally passive system (meeting S54.1, S5.2, and S5.3) or to install lap belts and only meet the requirements of S5.1. If Alternative II were made final, most vehicle manufacturers would probably choose to install lap belts rather than to provide passive protection that would satisfy S5.3. As you noted, Alternative II also proposes to extend the option in paragraph S5.3 (complying with Standard No. 216 instead) from August 15, 1977, to August 31, 1980.; You are correct in your statement that the Secretary does not expect t reach a final decision on his alternative proposals until July.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1880OpenHonorable Glenn English, House of Representatives, Washington, DC 20515; Honorable Glenn English House of Representatives Washington DC 20515; Dear Mr. English: This is in response to your letter of March 25, 1975, requestin information concerning correspondence from Franklin Motor Company commenting on a proposed amendment to the Federal bumper standard by urging that recyclability of bumpers by required.; Although promulgation of rules that have a direct positive impact o the environmental and energy situation is not within the National Highway Traffic Safety Administration's (NHTSA) jurisdiction, the agency gives serious consideration to the effect any of its standards will have on these important areas of concern.; The NHTSA has examined the environmental and energy ramifications o its proposed bumper standard and is continuing to do so. Our most recent proposal (March 12, 1975, 40 F.R. 11598, Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6) ensures that a wide variety of materials, including metals, could continue to be used in bumper systems.; We greatly appreciate your interest and that of your constituents i this matter. You can be sure that their comments will be given every consideration.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam5363OpenMr. David Fabrycky 1633 W. Willeta St. Phoenix, AZ 85007; Mr. David Fabrycky 1633 W. Willeta St. Phoenix AZ 85007; "Dear Mr. Fabrycky: This responds to your letter about an aftermarke product you wish to manufacture. The product is a child safety seat buckle shield, which is intended to prevent a child from opening the buckle on a child restraint system. You state that your device would cover the buckle and prevent the child from gaining access to the pushbutton of a child seat buckle. To depress the pushbutton, the device requires that a latch be actuated and the cover pivoted away from the buckle. You indicated that the device requires 'manual dexterity to exert the forces in many directions simultaneously.' Although we understand your concern that young children not be able to easily unbuckle a child safety seat, we have reservations about devices that interfere with the unbuckling of the seats. I hope the following discussion explains those reservations and answers the questions in your letter about the effect of our regulations on your product. Our agency has the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Safety Standard No. 213, 'Child Restraint Systems,' which applies to all new child restraint systems sold in this country. However, Standard 213 does not apply to aftermarket items for child restraint systems, such as your buckle shield. Hence, you are not required to certify that this product complies with Standard 213 before selling the product. Additionally, you are not required to get 'approval' from this agency before selling the buckle shield. NHTSA has no authority to 'approve' motor vehicles or motor vehicle equipment, nor do we endorse any commercial product. Instead, the National Traffic and Motor Vehicle Safety Act establishes a 'self- certification' process under which each manufacturer is responsible for certifying that its products meet our safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates alleged safety-related defects. Although we do not have any standards that directly apply to your product, there are several statutory provisions that could affect it. Manufacturers of motor vehicle equipment such as your buckle shield are subject to the requirements in sections 151-159 of the Safety Act concerning the recall of products with defects related to motor vehicle safety. The agency does not determine the existence of safety defects except in the context of a defect proceeding, and thus is unable to say whether your product might or might not contain such a defect. However, the agency is concerned that people be able to easily and quickly operate a child safety seat buckle in an emergency. As the agency said in a rule on the force level necessary to operate child restraint buckles: The agency's safety concerns over child restraint buckle force release and size stem from the need for convenient buckling and unbuckling of a child and, in emergencies, to quickly remove the child from the restraint. This latter situation can occur in instances of post-crash fires, immersions, etc. A restraint that is difficult to disengage, due to the need for excessive buckle pressure or difficulty in operating the release mechanism because of a very small release button, can unnecessarily endanger the child in the restraint and the adult attempting to release the child. (50 FR 33722, August 21, 1985) It appears that your product could significantly increase the difficulty of using the buckle release and thus hinder a person attempting to release the belt in an emergency. In addition, use of your product could be affected by section 108(a)(2)(A) of the Safety Act. That section prohibits commercial businesses from knowingly tampering with devices or elements of design installed in an item of motor vehicle equipment, such as a child safety seat, in compliance with the Federal motor vehicle safety standards. In determining the effect of a buckle shield on a child seat's compliance with Standard 213, NHTSA would evaluate the performance of the seat with the buckle shield installed. Standard 213 specifies several elements of design with which a child restraint system is unlikely to comply if your buckle shield were installed. Section S5.4.3.5 of Standard 213 requires the pushbutton release for any buckle on a child restraint to have a minimum area for applying the release force. Since your device will completely cover the buckle when installed, the buckle shield would cause the child restraint to no longer comply with this requirement. That section also requires the buckle to release when a specified maximum force is applied. Your device will not allow the buckle to release when the force is applied because it will cover the buckle and require force to be applied 'in many directions simultaneously.' Your device would thus cause the child restraint to no longer comply with that requirement. Therefore, commercial establishments cannot legally install your device on customers' child safety seats. In addition, section S5.7 of Standard 213 requires each material used in a child restraint system to comply with the flammability resistance requirements of Standard 302, 'Flammability of Interior Materials.' If your buckle shield does not comply with the requirements of Standard 302, commercial establishments cannot legally install your device. The prohibition of section 108(a)(2)(A) does not apply to individual vehicle owners who may install or remove any items on child restraint systems regardless of the effect on compliance with Standard 213. However, our policy is to encourage child restraint owners not to tamper with or otherwise degrade the safety of their child restraints. I hope this information is helpful. If you have any further questions, please contact Ms. Deirdre Fujita of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0161OpenMr. William F. Remmert, Secretary-Treasurer, Parsons Mobile Products, Inc., 2013 Belmont, Parsons, KS 67357; Mr. William F. Remmert Secretary-Treasurer Parsons Mobile Products Inc. 2013 Belmont Parsons KS 67357; Dear Mr. Remmert: Thank you for your letter dated March 18, 1969, in which yo state,'[W]e differ from all other motor-home manufacturers in that we use an existing chassis body combination, which has already been certified by General Motors Corporation. Therefore, to the best of our knowledge, all certification and safety requirements are being met or exceeded at this time.'; Your letter and the materials that you enclosed with it indicate tha you alter a completed vehicle in a way that affects components necessary for compliance with safety standards, and change the vehicle type from a truck to a multipurpose passenger vehicle within the meaning of regulations issued pursuant to the National Traffic and Motor Vehicle Safety Act (49 CFR S. 371.3). In so doing you are evidently acting as a manufacturer within the meaning of section 102(5) of the Act, and must comply with the Certification Regulations that apply to motor vehicle manufacturers (49 CFR Part 367, pp. 38-40 of the enclosed pamphlet). Copies of the Act and pertinent regulations are enclosed.; The information requested in our letter to you dated February 14, 1969 is still relevant. Could we please have your response to that inquiry as soon as possible.; We trust this reply will be of assistance to you in your desire t comply with existing Federal Motor Vehicle Safety Standards and regulations.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service; |
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ID: aiam4821OpenMs. Susan J. Otjen Spill Response Project Oregon State Fire Marshal's Office 3000 Market Street Plaza Suite 534 Salem, Oregon 93710-0198; Ms. Susan J. Otjen Spill Response Project Oregon State Fire Marshal's Office 3000 Market Street Plaza Suite 534 Salem Oregon 93710-0198; "Dear Ms. Otjen: This responds to your request for an opinion whethe Oregon's specifications for Hazardous Material Emergency Response Vehicles are consistent with the Federal Motor Vehicle Safety Standards. Based on the information provided in your letter and telephone conversations with Steve Kratzke of this office, there is no inconsistency betweens Oregon's specifications and the Federal safety standards. The Emergency Response Vehicles in question have a Gross Vehicle Weight Rating (GVWR) of more than 10,000 pounds. Oregon's specifications call for the vehicle to include a manual safety belt at each seating position. One of the parties bidding on the contract for these vehicles suggested that these specifications were inadequate to comply with the requirements of the Federal safety standards, because, according to the bidder, the Federal standards require a crash test to measure the occupant protection afforded in these vehicles. The bidder's assertion is inaccurate. The occupant protection requirements applicable to these Emergency Response Vehicles are set forth in S4.3.2 of Standard No. 208, Occupant Crash Protection (49 CFR 571.208). That section requires that trucks and multipurpose passenger vehicles with a GVWR in excess of 10,000 pounds provide occupant protection at every designated seating position, but gives manufacturers two alternative means of providing the necessary protection. The first option for manufacturers of these vehicles, as set forth in S4.3.2.1, is to provide automatic crash protection (e.g., air bags or automatic safety belts) for occupants. If this option were chosen, the vehicle would be subject to crash testing by NHTSA during its compliance evaluations. To date, no manufacturer of heavy vehicles has ever chosen this option. Instead, they have chosen the second option. The second option, as set forth in S4.3.2.2, is to provide manual safety belts at every designated seating position. No vehicle crash testing is conducted under this option. Instead, compliance evaluations are based on a series of static tests of the safety belt assembly and the anchorage for that assembly. Accordingly, there is nothing in the Oregon specifications for these Emergency Response Vehicles that conflicts with the requirements of the Federal motor vehicle safety standards. I hope this information is helpful. If you have any further questions or need some additional information on this subject, please feel free to contact Mr. Kratzke at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0531OpenMr. Michael Petler, Assistant Manager, Product Development Department, U.S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, CA 90670; Mr. Michael Petler Assistant Manager Product Development Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs CA 90670; Dear Mr. Petler: This is in reply to your letter of November 17, 1971, enclosing copie of consumer information documents you plan to use to comply with the Consumer Information requirements applicable to motorcycles. You state that you plan to place the information for particular models back to back on the same sheet of paper in order that they may correspond to your specification sheets.; The documents you have submitted, when they contain the appropriat values, will comply with the Consumer Information regulations. There is no prohibition against placing the information for two models back to back on the same sheet as you plan to do.; We are pleased to be of assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1834OpenHonorable William D. Hathaway, United States Senate, Washington, DC 20510; Honorable William D. Hathaway United States Senate Washington DC 20510; Dear Senator Hathaway: This is in response to your letter of March 6, 1975, forwardin correspondence from one of your constituents, Mr. Ron Otis, concerning the National Highway Traffic Safety Administration's proposed amendment of the bumper standard. You ask that Mr. Otis' comments be included in the appropriate docket.; Mr. Otis directs his comments to what he believes to be a propose requirement that vehicles manufactured in the future be equipped with plastic bumper systems. His understanding of the proposal is incorrect. The NHTSA published a Federal Register notice on January 2, 1975 (40 FR 10) proposing a reduction in the required performance level of automobile bumpers. The proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face systems.; On March 7, 1975, the NHTSA issued a new Federal Register notice tha expresses the agency's decision that the proposed performance level reduction (January 2, 1975) should not be adopted. The NHTSA did, however, reiterate its position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The proposal also set forth new requirements that would ensure that a wide variety of materials would continue to be used in bumper systems.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam3809OpenTerry D. Day, P.E., Talbott Associates Inc., & S.E. 97th Avenue, Portland, OR 97216-2498; Terry D. Day P.E. Talbott Associates Inc. & S.E. 97th Avenue Portland OR 97216-2498; Dear Mr. Day: This responds to your letter to this office asking for a interpretation of Federal Motor Vehicle Safety Standard No. 208, *Occupant Crash Protection* (49 CFR S571.208). Specifically, you asked if Standard No. 208 requires that all bus passengers be restrained from ejection in the event of a rollover which is severe enough to destroy the integrity of the passenger compartment. Standard No. 208 specifies that the designated seating position for the driver must offer full automatic protection for the occupant in those circumstances *or* that the seating position must be equipped with a seat belt assembly that conforms to the requirements of Standard No. 209, *Seat Belt Assemblies*. No requirements are specified for the other designated seating positions on the bus.; Section S4.4 of Standard No. 208 specifies the protection which buse must afford the occupants, and allows the bus to comply with one of two protection requirements. The first option, set forth in section S4.4.1, is for the vehicle to meet the crash protection requirements set forth in section S5 of the standard (which include restraining the occupant from ejection in the event of a rollover) by means that require no action by the vehicle occupant. This requirement, however, must be met only with respect to an anthropomorphic test device in the driver's designated seating position. The second option, as specified in section S4.4.2, is for the vehicle to be equipped with either a Type 1 or Type 2 seat belt assembly that conforms to Standard No. 209. Again, this option applies only to the driver's designated seating position. Neither of these options sets forth any requirements applicable to any other designated seating position in the bus.; Please feel free to contact me should you have any further questions o need more information on this subject.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0726OpenMr. Cesar E. Cavanna, Chief Engineer, Lox Equipment Company, 355 So. Vasco Road, Livermore, CA 94550; Mr. Cesar E. Cavanna Chief Engineer Lox Equipment Company 355 So. Vasco Road Livermore CA 94550; Dear Mr. Cavanna: This is in reply to your letter of May 17, 1972, concerning problem you are having establishing gross axle weight ratings on vehicles you manufacture. You indicate that the problem occurs because brake drums which you use do not come with manufacturer's ratings, but are merely recommended for use with certain axles. You also ask whether a motor vehicle safety standard will require a 40-foot stopping distance from 20 mph.; Your understanding that brake drum capability does not have to b considered in determining gross axle weight rating is not entirely correct. The gross axle weight rating, which is the load carrying capacity of a single axle system (49 CFR 571.3), is a measure of the safe load-carrying capacity of the entire axle system. Manufacturers should include components in their vehicles that are designed to handle loads up to these ratings. Normally an assembler can rely on the specifications or the advice of a reputable supplier as to the capacity of the supplier's components. We expect manufacturers to exercise due care in ensuring that purchased components are adequate and safe for the vehicles they are used on, in accordance with careful business practices. These do not necessarily have to take the form of formal 'ratings.'; With reference to your question regarding stopping distance, Standar No. 121, Air Brake Systems, effective September 1, 1974 (not July 1, 1972) will, among other things, require a vehicle to stop from 20 mph in 33 and 54 feet on surfaces with skid numbers of 75 and 30 respectively.; 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.