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: aiam2782OpenMr. Stan Haransky, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This responds to your February 21, 1978, letter asking whether sectio 567.5(c)(7) of Part 567, *Certification*, requires a manufacturer to use all of the described statements on its certification label.; The answer to your question is no. That section provides that th listed certification statements are to be used as appropriate. Therefore, it is anticipated that a manufacturer will select for inclusion on its certification labels only those certification statements in subparagraph (c)(7) that are appropriate for the certification of its vehicles.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5047OpenRichard Allison Program Manager The Bott Group, Inc. 32330 Howard Avenue Michigan Heights, MI 48071; Richard Allison Program Manager The Bott Group Inc. 32330 Howard Avenue Michigan Heights MI 48071; "Dear Mr. Allison: This responds to your letter of August 20, 199 requesting an interpretation of Standard No. 216, Roof Crush Resistance. Specifically, you requested 'an interpretation of 1) the proper application and orientation of the test device (S6.2 of this standard) and 2) the distance the test device is allowed to travel (paragraph S4 of this standard), when testing vehicles equipped with roof mounted accessories, such as roof racks (luggage racks).' You believe that there are three possible test conditions. The first condition would conduct the test either without the roof rack installed or with the roof rack removed, and with the test device positioned in accordance with S6.2. The second condition would conduct the test with the roof rack installed, and with the test device positioned using the point of contact established under test condition 1. The third condition would conduct the test with the roof rack installed, and with the test device positioned in accordance with S6.2 to the roof rack. You requested our interpretation as to which is the correct test condition. In addition, you asked if we determined that either test condition 2 or 3 was correct, could the amount of distance traveled before contact with the roof be added to the allowable distance of test device travel under S4. We would conduct our compliance testing for Standard No. 216 with roof mounted accessories such as roof racks removed (your test condition 1). We would do so because the purpose of the test is to measure the strength of the roof, not the strength of roof mounted accessories. Further, as you have noted, conducting the test with roof mounted accessories in place could influence the positioning of the test device. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1907OpenMr. H. (Speedy) Hirai, Technical Representative, Toyo Kogyo Co., Ltd. (Mazda), Representative Office, 23777 Greenfield Rd., Suit 462, Southfield, Michigan 48075; Mr. H. (Speedy) Hirai Technical Representative Toyo Kogyo Co. Ltd. (Mazda) Representative Office 23777 Greenfield Rd. Suit 462 Southfield Michigan 48075; Dear Mr. Hirai: This responds to your April 16, 1975, question whether the tes procedure of S7, 7, 1 of Standard No. 105-75, *Hydraulic brake system*, permits reapplication of the parking brake if the vehicle fails to hold on the required grade after the first application of a force or series of forces. You also ask whether a brake warning indicator which signals a shortlived loss of pressure during a spike stop brake application would conform to S5.3.1(a) (1).; Section S7.7.1 directs (in part) application of the parking brake wit a force or series if forces, release of the service brake which has been holding the vehicle on the required grade, and indicates that in release of the service brake, 'it may be necessary to reapply *it*, if the vehicle moves slightly, to take up the parking brake system slack' (emphasis added).; The word 'it' refers to the service brake system, and not the parkin brake system. This sentence permits application of the service brake only, which has the effect of taking up parking brake system slack due to rotation of the brake shoes and drum prior to bottoming against the anchor pin. This service brake application is intended to provide the best opportunity for a static test of the parking brake.; You state that a differential pressure can occur within the Mazd master cylinder during a spike stop brake application because the piston travels beyond the outlet port to the rear wheel brake lines. This pressure differential causes momentary activation of the brake warning indicator lamp.; The NHTSA would consider in this case that, as a technicality momentary failure of the rear wheel subsystem has occurred because continued braking pressure cannot be applied to the rear wheels. you point out that the system corrects immediately and the signal lamp is extinguished.; From your description of the Mazda system, NHTSA concludes that th activation of the signal lamp conforms to the requirements of S5.3.1(a) (1) as long as it is designed to extinguish as soon as the system corrects and continued brake force could be applied to the read wheels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2628OpenMr. Glenn Taylor, President, Bankhead Enterprises, Inc., 1600 Ellsworth Industrial Drive, N.W., Atlanta, GA 30318; Mr. Glenn Taylor President Bankhead Enterprises Inc. 1600 Ellsworth Industrial Drive N.W. Atlanta GA 30318; Dear Mr. Taylor: This responds to your June 7, 1977, question whether the traile portion of an auto transporter must comply with Standard No. 121, *Air Brake Systems*, if it is manufactured after the current September 1, 1977, termination date for the exclusion of auto transporters from the standard.; As stated in a telephone conversation between you and Mr. Herlihy o this office, the current exclusion for auto transporters terminates September 1, 1977, and either portion of an auto transporter manufactured after that date must comply. Recently, the NHTSA proposed extension of the auto transporter exclusion from September 1, 1977, to January 1, 1979 (copy of proposal enclosed). The comment closing period ended July 11, 1977, and the agency hopes to reach a decision on the proposal in the near future.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0615OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co., Ltd., Liaison Office in U.S.A., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Mizuno: This is in reply to your letter of February 11, 1972, in which yo requested our interpretation as to how seats with varying numbers of adjustment positions are to be adjusted to the position 'midway between the forwardmost and rear most position,' as specified in S8.1.2 of Standard 208.; The intent of the 'midway' provision in S8.1.2 is that the seat must b placed as nearly as possible at the midpoint of its fore and aft travel. Since the standard also provides that the seat is in an adjustment position -- a notch -- there is a possibility that there will not be a notch at the exact center of the range. In such cases, the seat is placed in the notch nearest the midpoint of the seat's travel. In your case A, if the notches are evenly spaced, the middle notch would probably be the nearest to the midpoint and would therefore be used. In your case B, if the two middle notches are not equidistant from the midpoint, the nearest notch would be used. If they are equidistant, the rearmost notch would be used. It is not necessary to make a special notch.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5417OpenWilliam R. Willen, Esq. Managing Counsel American Honda Motor Co., Inc. 1919 Torrance Boulevard Torrance, CA 90501-2746; William R. Willen Esq. Managing Counsel American Honda Motor Co. Inc. 1919 Torrance Boulevard Torrance CA 90501-2746; "Dear Mr. Willen: We have received your 'Petition for Honda Electri Vehicles in accordance with FMVSS 555.6(c)' (correctly, 49 CFR 555.6(c)), dated June 28, 1994. The petition is incomplete in certain respects. It fails to provide the public interest and traffic safety arguments required by 555.5(b)(7). Section 555.6(c)(2)(iii) requires the submission of 'the results of any tests conducted on the vehicle that demonstrate its failure to meet the standard, expressed as comparative performance levels.' You have provided this information with respect to your request for exemption from Standard No. 103 but not with respect to the eight interior components that accompany your request for exemption from Standard No. 302. If you have conducted tests on these components, yuou are required to submit them as part of your petition. In addition, the petition does not state whether the period for which exemption is requested is for one or two years (you may need the latter if the manufacture of the 20 electric vehicles is not completed within a year from the date of grant of the petition). If the vehicles are manufactured outside the United States, Honda may wish to avail itself of the provisions of 49 CFR 591.5(j) which allows a manufacturer to import noncomplying vehicles for purposes of research, investigation, and studies for a period of up to three years (when the temporary importation bond must be paid). After payment of the bond, a manufacturer may request NHTSA for an extension if it requires further time to complete its tests and evaluations. We shall hold your petition in abeyance until we hear further from you. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1454OpenMr. Robert S. Priver, Law Offices of William and Black, 615 South Flower Street, Suite 1111, Los Angeles, CA 90017; Mr. Robert S. Priver Law Offices of William and Black 615 South Flower Street Suite 1111 Los Angeles CA 90017; Dear Mr. Priver: Thank your for your letter of March 29, 1974, requesting informatio and documentation concerning Fuel System Integrity Standards.; The GSA 515/26 Standard which you mentioned was published July 15 1966, and was effective October 13, 1967. This standard was effectively supplanted by Federal Motor Vehicle Safety Standard No. 301 which was effective January 1, 1968. A copy of this original Standard No. 301 is enclosed for your information along with a recent amendment (F.R. 39, 10586, March 21, 1974) that substantially upgrades the requirements of this standard.; We do not consider it appropriate to give advice concerning privat incidents or controversies, beyond what is contained in our regulations and other public issuances. You may find it helpful to contact private-sector groups such as the Society of Automotive Engineers for further information.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3469OpenMr. Daniel M. Jaworski, Johnson, Campbell & Moesta, 912 Buhl Building, Detroit, MI 48226; Mr. Daniel M. Jaworski Johnson Campbell & Moesta 912 Buhl Building Detroit MI 48226; Dear Mr. Jaworski: This responds to your recent letter requesting confirmation that th National Highway Traffic Safety Administration (NHTSA) has not issued any safety standards or regulations concerning the use of brake hose as a fuel line in commercial vehicles. Mr. Vernon Bloom of the NHTSA apparently told you that the agency has no standards regarding vehicle fuel lines.; Mr. Bloom is correct in his statement that no Federal safety standard or regulations preclude the use of brake hose as a vehicle fuel line, and that there are no standards directly relating to fuel lines. However, the agency does have a safety standard which indirectly involves fuel lines. Safety Standard No. 301, *Fuel System Integrity* (49 CFR 571.301), specifies performance requirements governing fuel systems on new motor vehicles. The standard specifies the maximum amount of fuel leakage that may occur following a barrier crash test of a new vehicle. Although the individual components of the fuel system, such as the fuel tank, do not have to meet specific requirements, each component obviously must be durable in order for the entire system to meet the general performance requirement of Standard No. 301. Therefore, you should ascertain whether the brake hose you intend to use as a fuel line would compromise a vehicle's ability to comply with that standard.; I would also point out that, although there are no safety standard directly relating to fuel lines, manufacturers are responsible for any safety-related defects which may occur in their vehicles or equipment. Section 151, *et seq*., of the National Traffic and Motor Vehicle Safety Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge. Under these provisions, you would be responsible if it were determined that your fuel lines constituted safety-related defects.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4656OpenRobert N. Levin, Esq. Hudock & Levin 1101 Connecticut Avenue, NW Suite 910 Washington, DC 20036; Robert N. Levin Esq. Hudock & Levin 1101 Connecticut Avenue NW Suite 910 Washington DC 20036; "Dear Mr. Levin: This responds to your letter on behalf of one of you clients, seeking information on how our law and agency regulations might affect the installation of sun roofs in vehicles. You stated that your client is an automobile repair facility. According to your letter, you recently discovered this agency's regulation (49 CFR /567.7) requiring vehicle alterers to affix to the vehicles they alter a label certifying that the vehicle as altered continues to comply with all applicable safety standards. You asked whether such certification labels must be affixed by your client to those vehicles on which it installs a sun roof. I am pleased to have this opportunity to explain the requirements of our laws and regulations for you. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) authorizes this agency to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Two of those safety standards could be relevant to a repair shop's installation of sun roofs on motor vehicles. Standard No. 205, Glazing Materials, (49 CFR /571.205) sets performance requirements for glazing materials installed in new motor vehicles and for new glazing materials for use in motor vehicles. Any glazing incorporated in a vehicle's sun roof would have to conform to the applicable performance requirements set forth in Standard No. 205. In addition, installation of a sun roof could affect a vehicle's compliance with Standard No. 216, Roof Crush Resistance - Passenger Cars, (49 CFR 571.216), which sets forth strength requirements for roofs of passenger cars. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) specifies that, 'No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ...' Because of this statutory requirement, any person or business that installs sun roofs in new motor vehicles must certify that the vehicle continues to comply with the requirements of all applicable safety standards, including Standards No. 205 and 216. The form and contents for this certification are set forth in 49 CFR Part 567, Certification. Any manufacturer that installs a sun roof on a new motor vehicle is required by /567.4 or /567.5 to certify that the vehicle conforms to the requirements of all applicable safety standards. Any person or business that adds a sun roof to a previously certified new motor vehicle prior to its first sale for purposes other than resale would be required to certify the vehicle's continuing compliance with all applicable safety standards, in accordance with /567.7. Such a person or entity is an 'alterer' for the purposes of Part 567. (Persons or entities that modify vehicles by using a 'readily attachable component' or performing a 'minor finishing operation' are not considered 'alterers.' Modifications involving a readily attachable component or a minor finishing operation are instead subject to the requirements of 49 CFR /567.6. However, NHTSA does not consider a sun roof to be a 'readily attachable component' nor is the installation of a sun roof a 'minor finishing operation.' Hence, this exception is not relevant to your client's activities.). In addition to these certification requirements, an 'alterer' is considered a 'manufacturer' for the purposes of the Safety Act. Among other things, this means an alterer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards arising from the alterations, as specified in sections 151-160 of the Safety Act (15 U.S.C 1411-1420). I have enclosed a general information sheet for new manufacturers that generally describes our statutory and regulatory requirements, and explains how to obtain copies of those statutes and regulations. The certification and labeling requirements set forth in section 114 of the Safety Act (15 U.S.C. 1403) and in Part 567 apply to vehicles only until the first sale of the vehicle for purposes other than resale. Thus, once a vehicle has been purchased by a consumer, persons that modify that vehicle for its owner (e.g., by installing a sun roof) are not required to certify or label the vehicle by this agency's statutes or regulations. A different statutory provision applies to modifications made by a repair shop to vehicles after the first purchase. Section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that, 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard, ...' To comply with the obligations imposed by this 'render inoperative' provision, your client should examine the sun roofs it installs and the means of installation for those sun roofs, and compare those with the requirements of Standards No. 205 and 216. After such an examination and comparison, your client should be able to decide if the sun roof installations it performs result in any apparent violations of the 'render inoperative' provision of the Safety Act. If your client decides there is no apparent 'render inoperative' violation, Federal law does not require any additional actions, such as labeling or certification, on your client's part in connection with the installation of sun roofs in vehicles after the first purchase of those vehicles. You should be aware that NHTSA may reexamine your client's decision and make its own determination of whether your client's sun roof installations may have violated the 'render inoperative' provision in the Safety Act in the context of an enforcement proceeding. I hope this information is helpful. If you have any additional questions, please feel free to contact Mr. Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures"; |
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ID: aiam3193OpenMr. Richard Tearle, Product Planing (sic) and Development, Volvo of America Corporation, Rockleigh, NJ 07647; Mr. Richard Tearle Product Planing (sic) and Development Volvo of America Corporation Rockleigh NJ 07647; Dear Mr. Tearle: This is in response to your recent letter and visit to the NHTS regarding the proper designated seating capacity for the Volvo 262C Coupe. The rear bench seat in this vehicle is 53.15 inches wide and has two depressed areas with contoured upholstery to fashion bucket seats. You ask whether the seat may be designated as having only two seating positions.; It is the agency's opinion that the rear seat in the Volvo 262C Coup must have three designated seating positions. The definition of 'designated seating position' provides, in part, that any bench or split-bench seat having greater than 50 inches of hip room shall have not less than three designated seating positions, 'unless the seat design or vehicle design is such that the center position cannot be used for seating' (49 CFR 571.3). The rear seat in the Volvo Coupe is substantially over this 50-inch caveat in the definition, since it has more than 53 inches of hip room. Further, the seat design is not such that the center position cannot be used for seating. The center position is well padded on both the seat cushion and the seat back and there is no impediment to use of the position. This was demonstrated when several persons sat at the center position when your demonstration vehicle was brought to the agency.; Your letter mentions that the Volvo Coupe has less head room than othe Volvo models, yet there is sufficient head room even at the center position for large persons to occupy the seat. Therefore, we do not believe that the vehicle design is such that the center position cannot be used. The fact that the two outboard positions of the rear seat are aesthetically designed to appear as bucket seats is irrelevant, since the center position is a well-padded integral part of the entire bench seat. Other current models have the same type bucket seat appearance in the rear seat, yet because of hip room have three designated seating positions. You might examine the 1978 Oldsmobile Regency Sedan, for example.; We noted in the demonstration model that the rear seat of the Volv Coupe has an arm rest at the center position that folds into the seat back. If the design of this arm rest were modified to be permanently attached to the seat cushion, the center position could not be used., The bench seat would then qualify as a two-person seat under the definition of 'designated seating position'.; Finally, I would emphasize that this letter only represents th agency's opinion based on the information supplied in your letter and an examination of the demonstration model brought to the agency. The NHTSA does not pass approval on any vehicle design, for any safety standards, prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles comply with all applicable safety standards and regulations, and to certify the vehicles in accordance with that determination.; Sincerely, Frank Berndt, 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.