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: aiam5621OpenMr. Thomas K. O'Connor Chief of Maintenance and Operations Metropolitan Water Reclamation District of Greater Chicago 100 East Erie Street Chicago, Illinois 60611; Mr. Thomas K. O'Connor Chief of Maintenance and Operations Metropolitan Water Reclamation District of Greater Chicago 100 East Erie Street Chicago Illinois 60611; Dear Mr. O'Connor: This responds to your letter asking about seat bel requirements for a step van with a GVWR greater than 10,000 pounds. You asked whether lap belts versus lap/shoulder belts are needed for compliance with the Federal motor vehicle safety standards. As discussed below, either lap belts or lap/shoulder belts may be used for this type of vehicle. The National Highway Traffic Safety Administration's safety belt installation requirements are set forth in Standard No. 208, Occupant Crash Protection. I note that this standard specifies requirements based on vehicle type and seating position within the vehicle. Different requirements also apply depending on the GVWR of the vehicle. The requirements for trucks with a GVWR of 10,000 pounds or more are set forth in S4.3.2 of Standard No. 208. That section provides vehicle manufacturers a choice of two options for providing occupant crash protection. Option 1, dealing with automatic crash protection, is not relevant to your inquiry. Option 2, set forth in S4.3.2.2, requires vehicle manufacturers to install Type 1 (lap) or Type 2 (lap/shoulder) belts at every seating position. Thus, either lap or lap/shoulder belts may be used to meet S4.3.2. I hope this information is helpful. If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam4933OpenMr. Joe S. Brito Preferred Custom Concepts, Inc. 4107 Kaufman County Road P.O. Box 0069 Crandall, TX 75114; Mr. Joe S. Brito Preferred Custom Concepts Inc. 4107 Kaufman County Road P.O. Box 0069 Crandall TX 75114; "Dear Mr. Brito: This responds to your letter asking about recen changes in this agency's safety standards as they apply to conversion vans. You stated that, 'The recent changes that have occurred in the truck and van conversion industry regarding seats and seat belt restraints have also sparked rumors that this new law will also regulate the use of wood in the interior of a converted vehicle.' You asked if in fact there is some new NHTSA regulation of 'the use of wood in the interior of a converted vehicle.' I am pleased to have this opportunity to explain our regulations to you. The National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act) to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA has exercised this authority to issue Standard No. 208, Occupant Crash Protection. As of September 1, 1991, Standard No. 208 requires, among other things, 'dynamic testing' of manual lap/shoulder safety belts installed at front outboard seating positions of multipurpose passenger vehicles and trucks with a GVWR of 8,500 pounds or less. 'Dynamic testing' means that, after fastening the safety belts around a test dummy, a test dummy occupying a seating position must comply with specified injury criteria in a 30 miles per hour barrier crash test. The specified injury criteria are the head injury criteria (HIC), chest acceleration and deflection, and femur loading. For your information, I have enclosed a copy of our November 23, 1987, final rule adopting the dynamic testing requirements for light trucks. Nothing in the dynamic testing requirements of Standard No. 208 explicitly prohibits the installation of wood in the interior of conversion vans. Indeed, some 1992 luxury passenger cars, which are also subject to crash testing, have wood installed in the vehicle interior. However, wood is a relatively hard surface in a vehicle interior, especially when compared with the padded dashboard, steering wheel, seats, and other components the head may contact in a crash. It would be very difficult for a vehicle to satisfy the injury criteria during dynamic testing if wood were installed in an area contacted by the dummy head during the crash test. Thus, the dynamic testing requirements for conversion vans may effectively limit the interior areas where wood can safely be installed. In addition, van converters are generally small entities that would not have the resources needed to independently certify that their conversion vans comply with the dynamic testing requirements. The simplest way for these van converters to certify compliance with the dynamic testing requirements is to convert the vans in accordance with the specifications provided by the original manufacturer of the van (e.g., Chrysler, Ford, or General Motors). Because of the difficulties in complying with the dynamic testing requirements if wood were installed in an area contacted by the dummy head during the crash test, the original manufacturers of vans may have advised converters in the van specifications not to add wood in the interior areas of the vans. You may wish to contact van converters or original manufacturers to learn if this is the case. Another safety standard that might limit the interior areas where wood can be installed is Standard No. 201, Occupant Protection in Interior Impact. Standard No. 201 specifies performance requirements for certain areas of the vehicle interior compartment, including portions of the instrument panel. Again, while Standard No. 201 does not explicitly prohibit the use of wood, it may be difficult to comply with the requirements of this standard if wood is added to areas subject to Standard No. 201's performance requirements. I have enclosed a current copy of Standard No. 201 for your information. I hope this information is helpful. If you have any more questions about this issue, feel free to contact Mary Versailles at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam0423OpenMr. Stephen C. Royer, Director of Governmental Relations, National Ready Mixed Concrete Association, 900 Spring Street, Silver Spring, MD 20910; Mr. Stephen C. Royer Director of Governmental Relations National Ready Mixed Concrete Association 900 Spring Street Silver Spring MD 20910; Dear Mr. Royer: This is in reply to your letter of March 30, 1971, concerning th applicability (S 573.3) of the Defect Reports regulations (Docket No. 69-31, Notice 2) published February 17, 1971 (36 F.R. 3064). In your letter you ask,; >>>'If a concrete truck mixer manufacturer is notified of a defect (o brakes, for example) and the concrete truck mixer manufacturer relays this information to the incomplete vehicle manufacturer, and the incomplete vehicle manufacturer indicates that he will file the necessary defect reports with [the] Administration and then does not, would . . . [the] concrete truck mixer manufacturer be deemed in violation of Part 573?'<<<; The answer to this question is yes. Under the circumstances yo describe, both the concrete truck mixer and the incomplete vehicle manufacturer would be in violation of the regulation. Neither manufacturer would be in compliance until one of them filed the report in question, which could be either the defect information report required pursuant to S 573.4 or the quarterly report required pursuant to S 573.5.; The NHTSA cannot become involved in disputes between complete an incomplete vehicle manufacturers as to which one of them will furnish the required reports, and the manufacturers concerned must bear the responsibility for deciding this question between themselves.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5271OpenMr. Jack McIntyre Vice President Tie Tech Inc. Post Office Box 5226 Lynnwood, WA 98046-5226; Mr. Jack McIntyre Vice President Tie Tech Inc. Post Office Box 5226 Lynnwood WA 98046-5226; "Dear Mr. McIntyre: This responds to your letter in which you withdre your petition for rulemaking of August 18, 1993, and requested an agency interpretation instead. You referred to the final rule issued by this agency on January 15, 1993 (58 FR 4585), which amended Federal Motor Vehicle Safety Standard (FMVSS) 222. Specifically, paragraph S5.4.2.(a)(1) of the amendment provides that wheelchair securement devices composed of webbing or straps must meet the requirements for Type I safety belt systems specified in S4.2, among others, of FMVSS 209. You stated that there is no need to specify a minimum width for wheelchair securement belts and that the current industry standard for securement belts is a 1-inch polyester belt. Finally, you stated that the 1-inch polyester belts have less stretch than the 1.8-inch nylon belts and that the 1-inch belts are easier and less cumbersome to connect to a wheelchair. Paragraph S4.2(a), FMVSS 209, provides that seat belt webbing cannot be less than 1.8 inches wide, 'except for portions that do not touch a 95th percentile adult male with the seat in any adjustment position and the seat back in the manufacturer's nominal design riding position . . . .' That means that seat belt webbing must be at least 1.8 inches wide whenever it touches the person of the seat occupant. The width of webbed wheel chair securement belts that do not touch the persons of the chair occupants is not specified in any standard. Therefore, wheel chair securement belts can be 1 inch or some other width, so long as they do not touch the persons of the chair occupants and meet the other requirements of applicable standards. I hope this clarifies this matter for you. If you have any further questions or need any further information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0589OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH, 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of December 24, 1971, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You ask whether the entire interior of a van-type vehicle that has n divider behind the driver would be considered the passenger compartment. The answer to this question is no. The cargo area of such a vehicle would not be considered a 'vehicle occupant compartment' under S4.1 of Standard No. 302, and materials used in the cargo area need not comply with the standard.; You ask further whether a metal compartment bin or rack such as thos used in a telephone truck for storage must be certified. If the bin is within the passenger compartment, and is installed in the truck before its sale to a consumer, it would be required under S4.1, as a 'compartment shelf' to meet the requirements of the standard. Certification would be the responsibility of the truck manufacturer, however, and not the manufacturer of the compartment. If the bin or rack is not within the passenger compartment, it need not meet the requirements of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0073OpenMr. S. J. Fowler, Commercial Officer, Canadian Embassy, 1746 Massachusetts Avenue, NW, Washington, DC 20036; Mr. S. J. Fowler Commercial Officer Canadian Embassy 1746 Massachusetts Avenue NW Washington DC 20036; Dear Mr. Fowler: This is in response to your letters of April 15 and February 15 to Mr B. A. Boaz of the Office of Public Affairs, Federal Highway Administration.; With reference to a Canadian manufacturer of motor buses you have aske 'what safety regulations currently apply to importation of motor buses.' Federal Motor Vehicle Safety Standards Nos. 102, 107, 205, and 209 currently apply to all motor buses, in addition, Standard No. 108 applies to motor buses 80 inches or more in overall width. I enclose a copy of the Standards for your guidance, together with a copy of the regulations governing importation of these vehicles.; You have also asked advice as to placing of lights required, vehicl braking requirements, and propane tank installation for 'tent camper trailers' and 'truck campers' manufactured by Specialites (sic) Capri Limited of Montreal. Standard No. 108 applies to all trailers 80 or more inches in overall width, and specifies the lighting requirements for these vehicles. Thus far it is the only standard applicable to trailers. There are no Federal braking or propane tank installation requirements for these vehicles. The truck camper manufactured by Capri is considered motor vehicle equipment and must conform to the glazing material requirements of Standard No. 205. I enclose a copy of a recent Notice of Ruling Regarding Campers which will be of assistance to Capri.; If there are further questions we shall be glad to answer them, and am sorry for the delay in responding to you.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel |
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ID: aiam4899OpenDavid A. McClaughry, Esq. Harness, Dickey & Pierce 5445 Corporate Drive Troy, MI 48098; David A. McClaughry Esq. Harness Dickey & Pierce 5445 Corporate Drive Troy MI 48098; "Your ref: 0364-50108 Dear Mr. McClaughry: This responds to your lette of July 11, l991, with respect to the applicability of the Federal motor vehicle safety standards (FMVSS) to a sale of motor vehicles to the United States Navy. The Navy has proposed specifications for the design of a zero-emission motor vehicle which may not meet some of the FMVSS. You are aware of the exemptions that 49 CFR 571.7(c) provides for military vehicles, and that l5 U.S.C. 1410(a)(1)(C) provides, upon the Administrator's grant of a petition, for low-emission motor vehicles. These raise certain questions which you have asked us to answer. First, you would like our interpretation of 'military vehicle.' The definition of 'military vehicle' is that contained in section 571.7(c): a vehicle manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications. This means any vehicle that the military purchases. However, if the contractual specifications require compliance with the FMVSS, the military vehicle must be manufactured to conform to the FMVSS. You have asked whether the exclusion extends 'only for FMVSS or all safety standards.' The exclusion of section 571.7(c) is only from the FMVSS. However, vehicles that are owned by the United States Government bear Government registrations. They are not subject to State licensing laws, and, therefore, are exempt from State vehicle safety standards. You have also asked if there are other military safety standards that the vehicles must satisfy. We are unaware of any military safety standards, but, if such standards exist, they would be standards of the Department of Defense, and not those of the Department of Transportation. Finally, you have asked whether your client should attempt to obtain a low-emission vehicle temporary exemption under section 1410(a)(1)(C). Because of the existing exclusion from FMVSS compliance, we see no need for such an exemption if the vehicle is sold exclusively to the Navy or another branch of the military. However, if your client intends to sell the military-specification vehicle to an entity other than the Armed Forces of the United States, it must either comply with all applicable FMVSS at the time of manufacture and sale, or be exempted under one of the four subsections of section 1410(a)(1). Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0566OpenMr. Harry T. Armington, General Manager, universal Tire Apparatus Corporation, 613 Center, Logansport, IN 46947; Mr. Harry T. Armington General Manager universal Tire Apparatus Corporation 613 Center Logansport IN 46947; Dear Mr. Armington: This is in reply to your letter of November 12, 1971, in which yo state that you place a fire pump and body on a chassis which you purchase, and ask whether you are required to place a certification label or 'vehicle alteration label' on the vehicle.; It is unclear to us to what you refer by 'vehicle alteration label. However, based on the very limited information you have provided, it appears that you are a final- stage manufacturer under section 568.3 of the regulations covering 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568). As such you are required, pursuant to Section 568.6 to complete the vehicle so that it conforms to all applicable motor vehicle safety standards, and to certify compliance to those standards by affixing a certification label in the manner set forth in section 567.5 of the Certification regulations (49 CFR Part 567).; Copies of both the Certification regulations and regulations governin 'Vehicles Manufactured in Two or More Stages' are enclosed.; If you have further questions please write. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4876OpenMs. Vicki Haudler 4636 S. Cedar Lake Rd. St. Louis Park, MN 55416; Ms. Vicki Haudler 4636 S. Cedar Lake Rd. St. Louis Park MN 55416; "Dear Ms. Haudler: This responds to your letter seeking furthe information about a possible determination to be made by the Secretary of Transportation under Federal Motor Vehicle Safety Standard No. 208 (49 CFR 571.208). S4.1.4.1 of Standard No. 208 provides that cars manufactured on or after September 1, 1989 must be equipped with automatic crash protection. Vehicles equipped with automatic crash protection protect their occupants by means that require no action by vehicle occupants. Compliance with the minimum performance requirements of Standard No. 208 is determined in a dynamic crash test. That is, a vehicle must comply with specified injury criteria, as measured on a test dummy, when tested by this agency in a 30 mph barrier crash test. The two types of automatic crash protection currently offered on new passenger cars are automatic safety belts (which help to assure belt use) and air bags (which supplement safety belts and offer some protection even when safety belts are not used). As you noted in your letter, S4.1.5 of Standard No. 208 provides that: 'If the Secretary of Transportation determines, by not later than April 1, 1989, that state mandatory safety belt usage laws have been enacted that meet the criteria specified in S4.1.5.2 and that are applicable to not less than two-thirds of the total population . . ., the automatic restraint requirements will not go into effect .' You asked whether the Secretary ever made a determination under S4.1.5 regarding State safety belt use laws. The answer is no. Under S4.1.5, the Secretary was not required to make any determination about any State safety belt laws. In fact, the Secretary never did so. Because no determination was made under S4.1.5, the automatic restraint requirements went into effect as of September 1, 1989 for all passenger cars. I have returned the self-addressed, stamped envelope you enclosed in your letter. Good luck in your legal career. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0136OpenMr. Dick Romney, Vice President, Sales Manager, Utility Body Company, 901 Gilman Street, Berkeley, CA (sic); Mr. Dick Romney Vice President Sales Manager Utility Body Company 901 Gilman Street Berkeley CA (sic); Dear Mr. Romney: Thank you for your letter of January 8, 1969, to Mr. Andrew K. Ness National Highway Safety Bureau, concerning your request for an interpretation relative to the mounting of clearance lamps.; It is required by Federal Motor Vehicle Safety Standard No. 108 tha clearance lamps be mounted as near as practicable to the upper right and left extreme edges of the vehicle. Lamps mounted at the right and left extreme edges of the widest part of the body panel shown in your sketch would meet the requirements. The mounting height of these lamps should be as high as practicable without causing objectionable glare in the rearview mirror. Retention of cab mounted clearance lamps is optional.; With respect to the requirements of Standard No. 108, I must point ou that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, comments of this Bureau are for information purposes only and in no way relieve any vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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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.