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: aiam1927OpenMr. H. Miyazawa, Stanley Electric Co., Ltd., 2-9-13 Nakameguro, Meguro-Ku, Tokyo 153, Japan; Mr. H. Miyazawa Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-Ku Tokyo 153 Japan; Dear Mr. Miyazawa: This responds to your letter of May 15, 1975, regarding Federal Moto Vehicle Safety Standard (FMVSS) No. 108 requirements for Type 1A and 2A automotive headlamps.; The following answers are provided for your specific questions: >>>1. FMVSS No. 108 would not prohibit use of metal-back Types 1A an 2A headlamps that conform to all requirements of the standard.; 2. The National Highway Traffic Safety Administration does not issu approvals on automotive equipment. The equipment manufacturer self certifies that the equipment conforms to the applicable FMVSS. The various states may, however, require equipment approval. Information on these approvals may be obtained from the America Association of Motor Vehicle Administrators, 1201 Connecticut Avenue, Washington, D. C. 20036.; 3. The drawings of the Type 1A and 2A headlamp submitted with you letter, indicate that aiming pads have been deleted. Aiming pads are required by FMVSS NO. 108.<<<; For your information enclosed is a copy of FMVSS No. 108, whic includes requirements for Types 1A and 2A headlamps, and a copy of Docket No. 75-8, Notice 1, that proposes to allow use of the four-lamp rectangular systems indefinitely.; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam0635OpenMr. Preston W. Grace, White River Distributors, Inc.; Mr. Preston W. Grace White River Distributors Inc.; Dear Mr. Grace: This is in reply to your letter of March 6, 1972, forwarded to us b Tom Pieratt, wherein you discuss certain situations which have arisen regarding the GVWR of chassis you have purchased for completion by adding bodies.; As far as I can determine from the facts you provided in you letter the chassis manufacturers are doing nothing that is contrary to our regulations. Your complaints seem to be that (a) some chassis that you believe to be identical bear differing weight ratings in their accompanying literature, and (b) you have received some chassis that do not have the weight ratings that you want and believed you were ordering. Both problems appear to be matters of communication between you and the manufacturers or their dealers, which might be resolvable by clearly specifying the desired weight ratings in your purchase order.; Your general statements concerning the effect of the Vehicle Safety Ac and the regulations issued thereunder are essentially correct.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2608OpenMr. Chester J. Barecki, Vice President - Sales Engineering, American Seating Company, 901 Broadway Avenue, N. W., Grand Rapids, MI 49504; Mr. Chester J. Barecki Vice President - Sales Engineering American Seating Company 901 Broadway Avenue N. W. Grand Rapids MI 49504; Dear Mr. Barecki: This responds to your March 24, 1977, letter asking for a interpretation of the requirements for knee contact area in Standard No. 222, *School Bus Passenger Seating and Crash Protection*, which state that, when impacted, 'the resisting force of the impacted material shall not exceed 600 pounds and the contact area on the knee form surface shall not be less than 3 square inches.' You ask whether this requirement can be interpreted as meaning that, when impacted, the resisting force of the impacted material shall not exceed 200 pounds per square inch rather than 600 pounds over 3 square inches.; The 600 pound maximum force and the 3 square inch minimum contact are are two distinct requirements. The first specifies an upper bound on the load that will be applied to the upper leg while the latter specifies a lower bound on the knee area over which an impact load must be distributed. To combine the two requirements, as you suggest, tends to relax the contact area requirement for a load which is less than 600 pounds. Such an interpretation would not ensure the level of safety the agency demands for knee contact area. The suggested combination of the two requirements may not provide an adequate distribution of forces over the knee. Accordingly, the agency declines to accept the suggested interpretation of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5437Open"M. Guy Dorleans Legal Compliance Department Valeo Vision 34, rue St-Andr 93012 Bobigny Cedex France"; "M. Guy Dorleans Legal Compliance Department Valeo Vision 34 rue St-Andr 93012 Bobigny Cedex France"; Dear M. Dorleans: We have received your letter of July 15, 1994, askin whether certain front lamp designs would be permissible under Federal Motor Vehicle Safety Standard No. 108. In the basic front lamp design, the upper beam photometrics of Figure 17A would be provided by Lamps A and B. You have asked whether it is possible to add Lamp D, 'an auxiliary driving beam.' In this variation 'all three A, B and D filaments would be permanently energized together in high beam mode and table 17a (sic) of FMVSS 108 is then fulfilled.' Lamp D meets the photometric requirements of SAE Standard J581 JUN89 Auxiliary Driving Lamps. The photometrics of Figure 17A apply to two-lamp integral beam or two-lamp combination headlighting systems, and the design in your drawing is that of a four-lamp system, subject to the photometrics of Figure 15A. This configuration is not permissible under Standard No. 108. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3449OpenKen Siemens, Metropolitan Property and Liability Insurance Company, Midwest Service Office, 9797 Springboro Pike, P.O. Box 48020, Dayton, OH 45448; Ken Siemens Metropolitan Property and Liability Insurance Company Midwest Service Office 9797 Springboro Pike P.O. Box 48020 Dayton OH 45448; Dear Mr. Siemens: This is in response to your letter of June 25, 1981, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odometer laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal form, the statemust obtain the approval of this agency before its certificate of title can be used as a substitute for the Federal form.; In order to spare states the burden of an apporval (sic) process th agency has indicated that certain variations from the Federal form are acceptable. In the *Federal Register* notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1997, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl title forms that are consistent with the requirements of the Federal law:; >>>Maryland, Pennsylvania Massachusetts, Hawaii Michigan, New York Minnesota, North Dakota Ohio>>> In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each state was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia Delaware, Washington South Dakota, Utah South Carolina, Wisconsin Indiana If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, Assistant Chief Counsel |
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ID: aiam1474OpenMr. Richard H. King, Gracey, Maddin, Cowan & Bird, 500 Court Square Building, 300 James Robertson Parkway, Nashville, TN 37201; Mr. Richard H. King Gracey Maddin Cowan & Bird 500 Court Square Building 300 James Robertson Parkway Nashville TN 37201; Dear Mr. King: Your letter of April 2, 1974, to Mrs. Winifred Desmond has bee referred to this office for reply. In your letter you discuss what you consider to be an omission in the National Traffic and Motor Vehicle Safety Act, viz., requirements for manufacturers to provide sufficient parts for the repair of vehicles in the hands of purchasers when those vehicles are found to contain safety related defects.; You are correct in stating that the National Traffic and Motor Vehicl Safety Act does not require manufacturers to provide sufficient parts for the repair of defective vehicles in the hands of purchasers. The statute limits manufacturers' responsibilities, as you point out, to notification of owners.; The NHTSA has, however, taken some regulatory steps which relate to th availability of repair parts. The 'Defect Notification' regulations (49 CFR Part 577) require manufacturers to estimate and specify in the defect notification letter the day by which repair parts will be available (49 CFR 55 577.4(e)(1)(ii), 577.4(e)(2)(iii), 577.4(e)(3)(iii)). While this does not require repair parts to be available, it at least prohibits manufacturers from keeping purchasers 'in the dark' on the availability of repair parts. Knowingly incorrect statements in response to this requirement can subject a manufacturer to civil penalties and other sanctions.; There are pending in the Congress amendments to the National Traffi and Motor Vehicle Safety Act (S. 355, 93rd Cong., 1st Sess. (1973), H.R. 5529, 93rd Cong., 1st Sess. (1973)) that would in general require manufacturers to repair vehicles found to contain safety related defects without charge to the vehicle purchaser. If such legislation is enacted it would eliminate the problem of the availability of repair parts where safety related defects are found to exist.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4676OpenMs. Linda B. Kent Senior Account Executive Market Development Fasson Specialty Division 250 Chester Street Painesville, OH 44077; Ms. Linda B. Kent Senior Account Executive Market Development Fasson Specialty Division 250 Chester Street Painesville OH 44077; "Dear Ms. Kent: Thank you for your letter requesting an interpretatio of whether the use of a product on motor vehicles would violate Standard No. 205, Glazing Materials (49 CFR /571.205). This product, called 'Contra Vision,' is designed to display messages or advertising materials on windows and other clear surfaces, so that viewers on one side of the clear surface will see the message displayed, while viewers on the other side of the surface will see an essentially transparent surface without any message visible. According to your letter, this product 'will be used for promotional signage in store windows, but also has application in rear taxicab windows, as well as rear and side windows of city buses.' You asked for our opinion of whether this product complies with Standard No. 205. Some background on how Federal motor vehicle safety laws and regulation affect this product may be helpful. Our agency is authorized under the National Traffic and Motor Vehicle Safety Act to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve or certify any vehicles or items of equipment, nor do we endorse any commercial products or processes. Instead, the Safety Act specifies that each manufacturer itself must certify that its products meet all applicable safety standards. The agency periodically tests vehicles and items of equipment for compliance with the standards, and also investigates alleged defects related to motor vehicle safety and alleged violations of other statutory provisions. Your letter indicates that you are already aware that NHTSA has issued a safety standard that applies to the windows installed in motor vehicles. Specifically, Standard No. 205 requires that all new vehicles and all new glazing materials for use in motor vehicles must comply with certain performance requirements. Among the requirements set forth in Standard No. 205 are specifications for minimum levels of light transmittance. A minimum of 70 percent light transmittance is required in glazing areas requisite for driving visibility, which includes all windows in passenger cars. In trucks and buses, the windshield and windows to the immediate right and left of the driver and the rearmost window, if the latter is used for driving visibility, are considered to be requisite for driving visibility, and therefore subject to the 70 percent minimum light transmittance requirement. Your letter did not provide any information on the light transmittance that would be measured through glazing with Contra Vision installed on it. The combination of the glazing material and the Contra Vision must allow at least 70 percent light transmittance to comply with the requirements of Standard No. 205. No manufacturer or dealer is permitted to install Contra Vision on the glazing materials on new vehicles, unless the manufacturer or dealer certifies that the vehicle continues to comply with the 70 percent minimum light transmittance and other requirements of Standard No. 205. After a vehicle is first sold to a consumer, modifications to the vehicle are affected by section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits any manufacturer, dealer, distributor, or repair business from 'rendering inoperative' any device or element of design installed in a vehicle in compliance with any safety standard. This provision of the law means that no manufacturer, dealer, distributor, or repair business could install Contra Vision if the addition of Contra Vision to the glazing would result in a light transmittance of less than 70 percent, or otherwise cause the vehicle to no longer comply with the applicable requirements of Standard 205. Violations of this 'render inoperative' prohibition can result in Federal civil penalties to the manufacturer, dealer, distributor, or repair business of up to $1000 for each noncomplying installation. Section 108(a)(2)(A) of the Safety Act does not affect vehicle owners. Hence, vehicle owners themselves may install Contra Vision or any other product on the glazing of their vehicle, regardless of whether the installation causes the vehicle to no longer comply with Standard No. 205. Individual States have the authority to regulate the operational use of vehicles by their owners, and, therefore, have the authority to regulate or preclude individual owner modifications to the glazing of their vehicles. I have enclosed an information sheet that summarizes the relationship between Federal auto safety laws and motor vehicle window tinting. I hope this information is helpful. If you have any further questions or need any additional information about this topic, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure"; |
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ID: aiam3019OpenMr. Eugene S. Trioli, 24 Wedgemere Road, Malden, MA 02148; Mr. Eugene S. Trioli 24 Wedgemere Road Malden MA 02148; Dear Mr. Trioli: This responds to your recent letter requesting information concernin the Federal requirements that would be applicable to auxiliary propane fuel systems for automobiles, which you would like to market in the United States.; Federal Motor Vehicle Safety Standard No. 301-75, *Fuel Syste Integrity*, (copy enclosed) specifies performance requirements for fuel systems on motor vehicles. Although the standard applies to completed vehicles rather than to fuel tanks or other fuel system components, there are requirements of which you should be aware if you intend to market auxiliary fuel systems. An original vehicle manufacturer that uses your auxiliary system, General Motors for example, has to certify that the entire vehicle complies with all applicable safety standards.; A person who mounts an auxiliary fuel tank or system on a new moto vehicle before the vehicle's first purchase in good faith for purposes other than resale is a vehicle alterer under the National Highway Traffic Safety Administration regulations. That person is required by 49 CFR 567.7 (copy enclosed) to affix a label to the vehicle stating that, *as altered*, the vehicle conforms to all applicable Federal Motor Vehicle Safety Standards--including Standard No. 301-75.; In addition, the mounting of an auxiliary or replacement fuel tank on motor vehicle after the vehicle's first purchase in good faith for purposes other than resale is affected by Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)). That section specifies in relevant part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall *knowingly render inoperative*, in whole or 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.... (Emphasis added.)<<<; Therefore, the mounting of an auxiliary fuel tank or system on a use vehicle must be performed in such a way that the vehicles's compliance with Standard No. 301-75 is not knowingly compromised.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1024OpenMr. R. L. Brown, President, Brown Motor Co., Inc., 1005 S. Main Street, Corbin, KY 40701; Mr. R. L. Brown President Brown Motor Co. Inc. 1005 S. Main Street Corbin KY 40701; Dear Mr. Brown: I am returning herewith copies of two odometer disclosure statement executed by your company on February 15 and 17, 1973. Our regulations require you to submit these statements to each customer, but they do not require you to send us a copy. I suggest that you retain the enclosed copies for your files.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4226OpenMs. Lisa Kreeger, Reichert, Strauss & Reed, 2510 Carew Tower, Cincinnati, OH 45202; Ms. Lisa Kreeger Reichert Strauss & Reed 2510 Carew Tower Cincinnati OH 45202; Dear Ms. Kreeger: This responds to your letters of June 27, 1986, and July 11, 1986, an your subsequent phone conversations with Stephen Oesch of my staff concerning the safety belt installation requirements for multipurpose passenger vehicles and buses. I regret the delay in our response and hope the following information is of assistance to you.; As Mr. Oesch discussed with you, Federal Motor Vehicle Safety Standar No. 208, *Occupant Crash Protection*, sets forth the safety belt installation requirements for passenger cars, trucks, multipurpose passenger vehicles and buses. The standard, a copy of which is enclosed, regulates only the installation of safety belts and does not require their use. However, the Federal Highway Administration's Office of Motor Carriers has issued a regulation (49 CFR Part 392.16) that requires safety belt use by operators of trucks and buses involved in interstate commerce. Belt use is also governed by State mandatory use laws.; S4.2.2 and S4.3 of the standard set forth the safety belt installatio requirements for new multipurpose passenger vehicles (MPV's). Our regulations (49 CFR 571.3) define an MPV as a 'motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' S4.2.2 and S4.3 of Standard No. 208 require the installation of a safety belt for each designated seating position in a MPV.; S4.4 of the standard sets forth the safety belt installatio requirements for buses. Our regulations define a bus as a 'motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons.' S4.4 of Standard No. 208 requires the installation of a safety belt at only the driver's designated seating position in a bus. The agency has set additional safety belt requirements for school buses with a gross vehicle weight rating of 10,000 pounds or less. S5(b) of Standard No. 222, School bus passenger seating and crash protection, requires the installation of a safety belt at the passenger seats in those small school buses. A copy of Standard No. 222 is enclosed.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, 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.