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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ID: aiam2068OpenMr. Tokio Iinuma, 560 Sylvan Avenue, P. O. Box 1606, Englewood Cliffs, NJ 07632; Mr. Tokio Iinuma 560 Sylvan Avenue P. O. Box 1606 Englewood Cliffs NJ 07632; Dear Mr. Iinuma: This is in response to your letter of August 27, 1975, requesting a interpretation of Standard No. 219 with respect to certain of your test results.; The primary purpose of Standard No. 219 is to protect vehicle occupant from impact with vehicle parts that have penetrated into the passenger compartment through the windshield during a crash. The inner surface of the windshield is the area of interface between the windshield and the passenger compartment. Therefore, the standard is designed to ensure that nothing penetrates into the passenger compartment by precluding penetration of the inner surface of the windshield below the protected zone in a crash test.; In Case 1, although the windshield below the protected zone wa cracked, nothing penetrated the inner surface of the windshield. therefore, it would appear that the windshield is in compliance with S5 of Standard No. 219.; Similarly, in case 2, it appears that the object did not penetrate th inner surface of the windshield, although the windshield was deformed. Therefore, it would appear that the vehicle is also in compliance.; We hope this information is of assistance. Please contact us if yo have any further questions.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5257OpenJohn B. Walsh Legal Affairs Manager Corporate Attorney American Suzuki Motor Corporation 3251 E. Imperial Highway P.O. Box 1100 Brea, CA 92622-1100; John B. Walsh Legal Affairs Manager Corporate Attorney American Suzuki Motor Corporation 3251 E. Imperial Highway P.O. Box 1100 Brea CA 92622-1100; Dear Mr. Walsh: This acknowledges receipt of your letter dated Octobe 29, 1993 requesting an interpretation of the labeling requirements of the recent final rule mandating the installation of air bags in passenger cars and light trucks (58 FR 46551, September 2, 1993). As you suggested in your letter, we believe it would be appropriate to respond to your request in the notice responding to the petitions for reconsideration of the September 2 final rule. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2592OpenMr. James M. Beach, Director of Engineering, Collins Industries, Inc., P. O. Box 58, Hutchinson, KS 67501; Mr. James M. Beach Director of Engineering Collins Industries Inc. P. O. Box 58 Hutchinson KS 67501; Dear Mr. Beach: This responds to your April 28, 1977, letter in which you ask severa questions concerning Standard No. 222, *School Bus Passenger Seating and Crash Protection*, and the definition of school bus.; You first ask whether the seat spacing requirements found in S5.2.1 o the standard are applicable to buses with gross vehicle weight ratings (GVWR) equal to or less than 10,000 pounds. Buses in this weight classification do not have to comply with the mandatory seat spacing requirements. Since these buses are equipped with seat belts, the mandatory seat spacing is not necessary to provide adequate occupant crash protection.; Your second question concerns those areas required to meet the hea protection zone requirements. You ask whether the window frame, window supporting structure, and window glass are included within the head protection zone requirements. The NHTSA issued an amendment of the standard (Notice 6, 41 FR 28506) in an attempt to clarify those portions of the bus subject to the head protection zone requirements. In this notice (copy enclosed), we stated that the sidewall, window and door structures were never intended to be included within the zone and are not subject to the requirements for head protection. However, the roof structure, if it falls within the zone, is subject to the requirements. If you need further information to determine the portions of your bus that would be included within the head protection zone requirements, I suggest that you send the agency sketches of your bus interior depicting those areas of concern.; Concerning seat orientation, you question whether the requirement fo forward facing seats found in S5.1 of the standard applies to buses with GVWR's of 10,000 pounds or less. S5(b) of the standard lists the paragraphs of the standard applicable to buses in the above-mentioned weight classification. S5(b) does not refer to S5.1 which contains the requirement for forward facing seats. This omission was an oversight that occurred during the drafting of the regulation. The agency intended that seats in all school buses be forward facing, unless designed for handicapped or convalescent passengers as permitted in Notice 6. This intent is obvious since, as you note, we require these seats to comply with forward and rearward performance requirements. The NHTSA will soon issue an amendment of the standard to correct this omission.; Your final question concerns the definition of school bus whic excludes common carriers in urban transportation. Your interpretation of this exclusion is correct. These buses are permitted to transport children to and from school but need not comply with the school bus construction standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3229OpenMr. Victor L. Johnson, Jr., Great Dane Trailers, Inc., P.O. Box 67, Lathrop Avenue, Savannah, Georgia 31402; Mr. Victor L. Johnson Jr. Great Dane Trailers Inc. P.O. Box 67 Lathrop Avenue Savannah Georgia 31402; Dear Mr. Johnson: This is to confirm your telephone conversation with Mr. Schwartz of m office, in which he advised you that the manufacturer identifier referred to in Docket 1-22, Notice 10, was the manufacturer identifier required by S4.5.1 of Federal Motor Vehicle Safety Standard No. 115. Inasmuch(sic) as the Society of Automotive Engineers has already assigned a manufacturer identifier to Great Dane Trailer, Inc., this requirements has been met.; I am forwarding your complete VIN plan to the VIN coordinator a required by S6 of the Standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1214OpenMr. Gil W. Bellamy, Administrator, Oregon Traffic Safety Commission, Room 313 Highway Building, Salem OR 97310; Mr. Gil W. Bellamy Administrator Oregon Traffic Safety Commission Room 313 Highway Building Salem OR 97310; Dear Mr. Bellamy: Thank you for your letter of July 23, 1973, enclosing an amende version of Oregon House Bill 2721.; We note that Section 2 of the Bill no longer requires a mandator green- yellow-red rear mounted lighting system but specifies that it may be used on an optional basis, in accordance with the suggestions in Mr. Wilson's letter of July 20, 1973. In order to avoid preemption under the National Traffic and Motor Vehicle Safety Act, ORS 483.412(3)(b) [Section 3] should be similarly amended to substitute 'may' for 'shall' so that all references to a mandatory system are removed from the Bill.; Sincerely, James B. Gregory, Administrator |
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ID: aiam4016OpenThe Honorable Malcolm Wallop, United States Senate, Washington, DC 20510; The Honorable Malcolm Wallop United States Senate Washington DC 20510; Dear Senator Wallop: Thank you for your letter to Secretary Dole requesting clarification o the regulations pertaining to school bus identification. Your letter has been referred to our agency for reply, since we administer the school bus regulations.; You explained that several of your constituents are concerned that ou regulations prohibit identifying nine-passenger vehicles that carry children to and from school as school buses. You suggested that school bus identification should be allowed as an added safety measure to alert other drivers to the nature of the vehicle.; I appreciate this opportunity to respond to your concerns. In brief our regulations do not prohibit States from identifying smaller school vehicles as 'school buses.' States have the discretion to choose to identify nine-passenger school vehicles as school buses if the States wish to include such a requirement in their highway safety programs.; We have two sets of regulations, issued under separate Acts o Congress, that apply to school buses. The first of these, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966, includes the motor vehicle safety standards applying to the manufacture and sale of new school buses. The second set of regulations, issued under the Highway Safety Act of 1966, provides guidelines to the States for their highway safety programs. One of these program standards provides recommended procedures for the identification of school vehicles.; Under the requirements of the Vehicle Safety Act, motor vehicl manufacturers must certify that their vehicles comply with all applicable motor vehicle safety standards. The applicability of our motor vehicle safety standards to a particular vehicle depends, in part, on the classification of that vehicle. Under Federal law, school vehicles carrying 10 or more passengers are 'school buses' which must meet our school bus safety standards. The demarcation between school vehicles carrying 10 or more passengers and those carrying fewer than 10 is thus pertinent for the purpose of determining the classification of a vehicle, and the applicability of our school bus safety standards. Nine- passenger van-type school vehicles are not considered 'school buses' under our regulations, but are classified as 'multipurpose passenger vehicles' (MPV's). While MPV's must be certified as meeting the safety standards for MPV's, they may also be voluntarily manufactured to meet the requirements for school buses as long as the vehicle continues to comply with our standards for MPV's.; I wish to emphasize that our safety standards for school buses ar performance standards which apply only to the manufacture and sale of new school buses. They do not govern the manner in which a school bus is identified or marked. Under the Highway Safety Act, we issued Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed), which contains recommendations for the identification, operation, and maintenance of school vehicles. However, the implementation of Program Standard No. 17 is a matter for the States to decide, and State law would determine the operational requirements, such as those for school bus identification, that school vehicles must meet.; I hope this information is helpful. Please feel free to contact thi agency if you have any further questions.; Sincerely, Diane K. Steed |
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ID: aiam3679OpenMr. K. Inoue, National Technical Service Manager, Toyo Tire Corporation, Compton, CA 90221; Mr. K. Inoue National Technical Service Manager Toyo Tire Corporation Compton CA 90221; Dear Mr. Inoue: This responds to your February 16, 1983, letter to Joseph Innes of thi agency regarding permissible methods for displaying Uniform Tire Quality Grading (UTQG) information on the sidewall of tires. Your first proposed alternative would delete the treadwear grade number, but not the word 'TREADWEAR' itself, from the format established in Option 3 of Figure 1, 49 CFR 575.104. The second proposed alternative would delete both the word 'TREADWEAR' and the numerical grade from the format specified in Option 3, Figure 1. Your proposed alternatives would be used only on tires produced in molds manufactured before August 8, 1983.; In the agency's February 7, 1983, notice suspending the treadwea portion of the UTQGS, tires produced in molds manufactured prior to August 8 were required to display UTQG information on tire sidewalls in one of the formats specified in Figure 1 or in Figure 6 of 49 CFR 575.104. Your first proposed alternative is clearly different from each of the permitted formats. The permitted formats require either that the word 'TREADWEAR' must appear next to the treadwear grade on the tire, or neither the word nor the numerical grade must appear. Your first alternative could confuse tire purchasers, since the display format could be interpreted as attributing the grade which appears after the work (sic) 'TRACTION' to both the treadwear and traction performance of the tire. Therefore, your first proposed alternative would not be permitted under 49 CFR 575.104.; Your second proposed alternative is quite similar to one permitte format, Option 3 in Figure 6. The only difference between your second alternative and Option 3 is that the traction information is centered in the format in Option 3, while it is slightly off-center in your alternative. Your second alternative should in no way be misleading to tire purchasers, however. Further, nothing in our regulations specifies precise centering of the traction information.; Any inconsistency between your proposed format and the permitted one i so small that the agency would, as a matter of prosecutorial discretion, make no attempt to enforce the UTQGS format requirement when your second alternative is used.; If you have further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1644OpenMr. D. D. Evenson, President, Hawaiian Motors Corporation, 22121 South Vermont, Torrance, CA 90502; Mr. D. D. Evenson President Hawaiian Motors Corporation 22121 South Vermont Torrance CA 90502; Dear Mr. Evenson: This is in reply to your letter of September 6, 1974, forwarding draft defect notification letter regarding the noncompliance of certain Cony vehicles with several Federal motor vehicle safety standards.; Your letters (sic) fails in the following respects to conform to 49 CF 577, 'Defect Notification' (copy enclosed):; 1. Section 577.4(a) requires the following statement as the *first sentence of your letter: 'This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.'; 2. Section 577.4(b) requires your second sentence to read:'Hawaiia Motors Corporation has determined that a defect which relates to motor vehicle safety exists in the Cony utility vehicle(s) you purchased from HMC.' If there is any possibility of confusion you should give more precise vehicle identification. Moreover, in cases such as this where the safety defect results from the failure to conform to applicable standards we prefer that that information be conveyed as well. Therefore you should also state, as you have done, that the vehicles do not conform to Federal motor vehicle safety standards for windshield wipers and washers and windshield and side window glazing materials.; 3. Your letter must include a clear, brief description of the defect(s which incorporates the four elements listed in section 577.4(c).; 4. Your letter does not evaluate the risk to traffic safety reasonabl related to the defect as required by section 577.4(d).; 5. Your letter also does not include measures to be taken to repair th defect as required by section 577(e). We had assumed that HMC would bring the vehicles into conformity with each of the standards free of charge. If so, the letter should conform to section 577.4(e)(1). If you plan some other course of action regarding repairs the letter must contain language meeting either section 577.4(e)(2) or (e)(3) as appropriate.; 6. Your letter contains several references to an understanding that th vehicles were purchased for highway use and that the NHTSA's interest is directed at potential future highway use. This is not true. The vehicles are motor vehicles (trucks) under the National Traffic and Motor Vehicle Safety Act and are required to conform to all applicable safety standards regardless of their intended use by the University of California or any other purchaser. Conformity to applicable standards cannot, therefore, be deferred until the sale of these vehicles to other purchasers, but must be accomplished immediately.; We have two other concerns. First, our decision letter of July 2, 1974 states that 52 Cony vehicles were imported in violation of the Act. Since only 32 of these vehicles were purchased by the University of California, defect notification letters must also be sent to the purchasers of the other 20 vehicles. Section 113(f) of the Act (15 U.S.C. 1402(f)) requires you to keep records of first purchasers.; Second, 49 CFR 573 (copy enclosed) requires you to file a Defec Information Report as well as Quarterly Reports on the progress of your notification campaign. Please comply with section 573.4 within 5 working days after receipt of this letter. Prompt submission of both a Defect Report and a complying defect notification letter is necessary to keep our compromise offer in effect.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0956OpenMr. L.A. Volberding, Administrative Manager, Kar-Kraft, Inc., 10611 Haggerty Street, Dearborn, Michigan 48126; Mr. L.A. Volberding Administrative Manager Kar-Kraft Inc. 10611 Haggerty Street Dearborn Michigan 48126; Dear Mr. Volberding: "This is in reply to your letter of December 14, 1972, to Mr. Schneide concerning the relationship j of a certain motorcycle fuel control system to Motor Vehicle Safety Standard No. 123. The system you describe incorporates an automatic fuel shutoff feature with a manual reserve control. You asked whether the fuel control system is permissible under Standard No. 123, and if it must be identified in accordance with the standard."; As Mr. Vinson of our staff advised you, Standard No. 123 does no require a fuel control system of a particular design, but if a manual fuel shutoff control is provided, it must be located and operated in the manner specified in Table 1. Since your system does not incorporate a manual shutoff control, it is not covered by the location and operational requirements of the Table. Table 3 does require identification of the 'fuel tank shutoff valve' which covers all valves regardless of the design of the fuel control system. We have no objection to your proposed method of identification.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3383OpenMr. T. Shimada, Senior Technical Manager, MMC Services Inc., 3000 Town Center, Suite 1960, Southfield, MI 48075; Mr. T. Shimada Senior Technical Manager MMC Services Inc. 3000 Town Center Suite 1960 Southfield MI 48075; Dear Mr. Shimada: This responds to your letter of October 14, 1980, regarding the warnin devices required by Safety Standard No. 114, *Theft Protection*, and Safety Standard No. 208, *Occupant Crash Protection*. You ask whether the sound of a voice repeating the phrase 'please pull out the ignition key' or 'please fasten seat belt' at 2-3 second intervals could be used to satisfy the requirements of Standard No. 114 and Standard No. 208. You also ask whether a buzzer or chime that signals an unfastened seat belt or the presence of the key in the ignition could also be used to give the driver other warnings, such as turning off the headlights.; Standard No. 114 does not specify the nature of the warning that mus be given to the driver in the event that the ignition key is left in the locking system. Thus the system you describe would comply with the rule. Note that the signal must be activated whenever the key has been left in the ignition and the driver's door is opened.; Standard No. 208 requires that the driver's seating position b equipped with a warning system that activates a continuous or intermittent audible signal for a period of not less than four (4) seconds and not more than eight (8) seconds. The signal must begin when the vehicle's ignition switch is in the 'on' or 'start' position and the driver's belt is not in use. If the system you have devised stops the warning only when the belt has been fastened, it would not comply with this rule. The signal must end within eight (8) seconds, irregardless of whether the driver's belt has been fastened. Regarding your specific question, an audible 'voice' signal would be permitted under the standard.; The buzzers or chimes that are installed in accordance with Standar No. 214 (sic) or Standard No. 208 may also be used to warn the driver of other conditions.; We hope you find this information helpful. Please contact this offic if you have any other questions.; 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.