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: aiam5223OpenMr. Howard Schecter P. O. Box 61353 Honolulu, HI 96839; Mr. Howard Schecter P. O. Box 61353 Honolulu HI 96839; "Dear Mr. Schecter: This responds to your request for an interpretatio of Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number - basic requirements (49 CFR 571.115). In a telephone conversation with Dorothy Nakama of my staff, you explained that you own a three-wheel motorcycle built with all used parts. The engine and other parts are from a used Corvair passenger car, and additional parts are from used motorcycles. Your letter asks whether your motorcycle must be assigned a vehicle identification number (VIN). The answer is no. Standard No. 115 applies to new motor vehicles, including motorcycles. NHTSA does not consider your motorcycle as new, since it was built entirely out of used parts. Since Standard No. 115 applies only to new motor vehicles, and NHTSA does not consider your motorcycle to be new, the motorcycle's rebuilder need not, under NHTSA's regulations, assign a VIN to the motorcycle. Your letter stated that the State of Hawaii's Reconstructed Vehicle Department (RVD) would not register your motorcycle since it has no VIN. Registration procedures for motor vehicles are set by each State, not NHTSA. However, we suggest that you show this letter to the RVD officials to explain that your motorcycle need not be assigned a VIN under NHTSA's regulations. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0021OpenMr. E. L. Koepenick, Secretary-Treasurer, Fire Apparatus Manufacturers Association, Inc., 7979 Old Georgetown Road, Washington, DC 20014; Mr. E. L. Koepenick Secretary-Treasurer Fire Apparatus Manufacturers Association Inc. 7979 Old Georgetown Road Washington DC 20014; Dear Mr. Koepenick: Your March 7, 1967, letter to Dr. William Haddon, Jr., requested tha you be advised regarding the applicability of lighting requirements, as specified in the Initial Motor Vehicle Safety Standards, to fire apparatus.; With exceptions as noted in Section 255.7, page 2409 of the *Federa Register*, Volume 32, Number 23, dated February 3, 1967 (copy enclosed), the lighting requirements will be applicable to fire apparatus. Initial Standard No. 108 covers lighting requirements for vehicles (as specified therein) that are 80 or more inches wide overall and becomes effective January 1, 1968. A Notice of Proposed Rule Making (see page 2418) of enclosed *Federal Register* includes a Proposed Amendment to Standard No. 108 and a Proposed Initial Standard No. 112, covering vehicles (as specified therein) that are less than 80 inches wide overall. It is anticipated that the proposed Amendment and Initial Standard No. 112 will also become effective on January 1, 1968.; Thank you for your interest in the Motor Vehicle Safety Standards. Sincerely, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam4961OpenMarc C. Gravino, Esq. Williams & McCarthy P.O. Box 219 Rockford, Ill. 61105-0219; Marc C. Gravino Esq. Williams & McCarthy P.O. Box 219 Rockford Ill. 61105-0219; Dear Mr. Gravino: This responds to your letter of February 7, 1992 asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Specifically, you ask whether the standard contains any requirement that the parking lamps, taillamps, and side marker lamps operate independently of the ignition switch so that when they are activated they will remain activated regardless of whether or not the ignition switch is in the on or off position. You have reviewed Standard No. 108, and reference paragraphs S5.5.3, S5.5.4, S5.5.5, and S5.5.7, copies of which you have enclosed. The answer is no. Under paragraph S5.5.5, the vehicular hazard warning signal operating unit is required to operate independently of the ignition switch, but no other lamp is required by the standard to do so. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam5389Open"Mr. S. Greiff PARS Passive R ckhaltesysteme GmbH Borsigstrabe 2 63/55 Alzenau Germany"; "Mr. S. Greiff PARS Passive R ckhaltesysteme GmbH Borsigstrabe 2 63/55 Alzenau Germany"; Dear Mr. Greiff: This responds to your letter of April 19, 1994 requesting an interpretation of the 500 foot minimum runway length in the Laboratory Test Procedure for Federal motor vehicle safety standards Nos. 208, 212, 219, and 301. Laboratory Test Procedures are provided to contracted laboratories as guidelines for conducting compliance tests. The Laboratory Test Procedures do not limit the requirements of the applicable Federal motor vehicle safety standards. None of the standards referenced in your letter include any requirement for minimum runway length. Instead, the standards specify that the collision into the fixed barrier will occur at any speed up to and including 30 mph. 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, John Womack Acting Chief Counsel; |
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ID: aiam0471OpenMr. Charles O. Verrill, Jr., Patton, Blow, Verrill, Brand & Boggs, 1200 Seventeenth Street, N.W., Washington, DC 20036; Mr. Charles O. Verrill Jr. Patton Blow Verrill Brand & Boggs 1200 Seventeenth Street N.W. Washington DC 20036; Dear Mr. Verrill: This is in reply to your letter of October 12, 1971, in which you mad several requests with respect to the Tire Identification and Record Keeping (49 CFR Part 574) and Certification (49 CFR Part 567) regulations.; >>>1. You suggested that the Tire Identification and Record Keepin regulation be amended to provide that where tires are not shipped on or in a vehicle, the vehicle manufacturer's record keeping obligation be limited to three years from the date of sale. We will take this request into consideration, and let you know when a decision is made. It appears that since the minimum time would apply to all vehicle manufacturers, such a requirement should appear in a regulation other than Part 574.; 2. You requested the deletion of the requirement that information o the certification label be placed 'in the order shown.' We have previously denied petitions relating to the order of information on the label (36 F.R. 19593), and this request is also denied. The requirement that the label information be placed in a definite order has been in effect for over two years, and has been found to enhance the readability and hence the usefulness of the label. Now that further numerical information is to be required on the label, we consider that it will be even more important that this requirement be maintained.; 3. You requested 'an interpretation that a multi-column label or label in two parts each with an information column, will meet the requirements of [Part] 567,' because of the space limitations on some trailers. As long as the information appears in the order specified in the regulation, the NHTSA has no objection to a multi-column label or a label in two parts.; 4. Finally, you requested that a trailer manufacturer be allowed to us up his existing supply of labels, by affixing a supplementary label with the additional required information. As stated above, we have decided to adhere to the requirement that the information on the label be in the order specified, although it may be in more than one column or part. To the extent that the action requested would allow a manufacturer not to conform to that requirement, the request is denied. Although the deviation might appear small, it would seriously detract from the integrity and enforceability of the regulation to allow incidental nonconformity without amending the requirement. The other vehicle manufacturers have undoubtedly already incurred costs similar to those cited by your client, and it would be distinctly unfair not to enforce the regulation evenhandedly as to all parties.<<<; Sincerely, Robert L. Carter, Acting Associate Administrator |
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ID: aiam4432OpenMr. N. Bowyer Senior Engineer Homologation and Legislation Land Rover UK Limited Lode Lane, Solihull West Midlands B92 8NW England UNITED KINGDOM; Mr. N. Bowyer Senior Engineer Homologation and Legislation Land Rover UK Limited Lode Lane Solihull West Midlands B92 8NW England UNITED KINGDOM; "Dear Mr. Bowyer: This responds to your request for an interpretatio of Standard Nos. 208, Occupant Crash Protection (49 CFR /571.208) and 209, Seat Belt Assemblies (49 CFR /571.209). I regret the delay in this response. More specifically, you noted that S4.6.2 of Standard No. 208 requires dynamic testing of manual lap/shoulder belts installed at front outboard seating positions of light trucks and multipurpose passenger vehicles manufactured on or after September 1, 1991. Section S4.6.3 of Standard No. 208 provides: 'A Type 2 seat belt assembly subject to the requirements of S4.6.1 or S4.6.2 of this standard does not have to meet the requirements of S4.2(a)-(c) and S4.4 of Standard No. 209.' Section S4.6(b) of Standard No. 209 provides that: 'A seat belt assembly that meets the dynamic testing requirements of Standard No. 208 shall be permanently and legibly marked or labeled with the following statement: This dynamically-tested seat belt assembly is for use only in insert specific seating position(s), e.g., 'front right' in insert specific vehicle make(s) and model(s) .' You expressed your opinion that dynamically tested belts must be labeled with the information specified in S4.6(b) of Standard No. 209 if the belts do not comply with all of the requirements of Standard No. 209. In these situations, you suggested that the labeling requirements help ensure that the belts will not be installed 'into inappropriate vehicles.' However, you stated your belief that the labeling requirements in S4.6(b) of Standard No. 209 do not apply to dynamically-tested manual belts that also comply with all of the requirements of Standard No. 209. Your understanding of these requirements is incorrect. Section S4.6(b)of Standard No. 209 provides that seat belt assemblies that meet the dynamic testing requirements in Standard No. 208 shall be marked or labeled with certain information. This section contains no exception for seat belt assemblies that meet the dynamic testing requirements and satisfy the performance requirements of Standard No. 209. The reason for not including any such exception was that the agency intended that all dynamically tested manual belts be marked or labeled with the information specified in S4.6(b). You suggested that there is no reason to require labeling of belt assemblies that comply with all requirements of Standard No. 209, just because those belt assemblies also comply with the dynamic testing requirements when installed in a particular vehicle. This assertion would be correct if the protection provided by safety belts depended only on the performance of the safety belts themselves. However, such is not necessarily the case. We emphatically agree with you that a belt assembly that complies with all requirements of Standard No. 209 will provide very substantial protection to an occupant of any vehicle in a crash. However, the protection provided by safety belts to occupants of a particular vehicle depends on more than the performance of the belts themselves, it also depends on the structural characteristics and interior design of the vehicle. The dynamic testing requirements measure the performance of the safety belt/vehicle combination, while Standard No. 209 focuses on measuring the performance of the safety belts alone. See 52 FR 44899-44900, November 23, 1987. With the advent of dynamic testing for light trucks and multipurpose passenger vehicles, NHTSA explained why Standard No. 209 was amended to require labeling of dynamically tested belts, regardless of whether those belts comply with all requirements of Standard No. 209. The final rule establishing dynamic testing requirements for light trucks and multipurpose passenger vehicles explained that NHTSA was adopting the same belt labeling requirements previously adopted for passenger car belts. 52 FR 44898, at 44907, November 23, 1987. In the preamble to the final rule establishing dynamic testing requirements for passenger cars with manual belts at front outboard seating positions, NHTSA explained why it was establishing belt labeling requirements for these dynamically tested safety belts. The agency said: NHTSA believes that care must be taken to distinguish dynamically tested belt systems from other systems, since misapplication of a belt in a vehicle designed for use with a specific dynamically tested belt could pose a risk of injury. If there is a label on the belt itself, a person making the installation will be aware that the belt should be installed only in certain vehicles. 51 FR 9800, at 9804, March 21, 1986. The same concerns apply to dynamically tested belts for light trucks and multipurpose passenger vehicles. Even if Land Rover installs dynamically tested belt systems that comply with all requirements of Standard No. 209 in all of its vehicles, those belt systems might not be appropriate for use in other light multipurpose passenger vehicles. This is particularly true if other light multipurpose passenger vehicles are designed for use only with specific dynamically tested belt systems different from the Land Rover belt system. The chances of the Land Rover belt system being installed in a vehicle for which it would not be appropriate are minimized if there is a label on the belt system indicating that it should be installed only in specific seating positions in Land Rover models and any other vehicles for which the belt system is appropriate. Accordingly, the belt labeling requirements in S4.6(b) of Standard No. 209 apply to all dynamically tested belts for use in light trucks and multipurpose passenger vehicles, regardless of whether those dynamically tested belts comply with all other requirements of Standard No. 209. You asked that we treat your request for an interpretation as a petition for rulemaking if, as we have done, we concluded that your suggested interpretation was incorrect. We will notify you of our response to this petition as soon as we complete our review of it. Sincerely, Erika Z. Jones Chief Counsel cc: Mr. D. Bruce Henderson Legislative Programs Manager Range Rover of North America 4390 Parliament Place P.O. Box 1503 Lanham, MD 20706"; |
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ID: aiam0922OpenPaul F. Middleton, Esq., Attorney-at-Law, 60 E. Main Street, Moorestown, NJ (sic); Paul F. Middleton Esq. Attorney-at-Law 60 E. Main Street Moorestown NJ (sic); Dear Mr. Middleton: This is in reply to your letter of November 22, 1972 to the Nationa Highway Traffic Safety Administration asking 'whether when a school bus is being used to transport pupils, the red lights must go on when the entrance door is opened without exception.'; If the system is one of red lamps only, its activation according to SA Standard J887 is not automatic but manual. The situation differs with respect to the combination amber and red lamps system. Paragraph S4.1.4(b)(ii) of Standard No. 108 effective January 1, 1972, which you reference, states; >>>'The school bus signal lamp system shall be wired so that the ambe signal lamps are activated only by manual or foot operation, and if activated, are automatically deactivated and the red signal lamps automatically activated when the bus entrance door is opened.'<<<; This means that the red lamps are only activated if the amber lamp have been activated before the door is opened. Activation of the red lamp system is thus dependent upon the action of the bus operator in prior activation of the amber lamp system. From the standpoint of safety we hope that his activation of the amber lamp system will be 'without exception' whenever he is transporting pupils.; Because paragraph S3.1.3.2 of Standard No. 108 as it was in effect fro January 1, 1969 to January 1, 1972, which you also reference, could mistakenly be interpreted to require activation of the red lamp system without exception whenever the door was opened, the National Highway Traffic Safety Administration adopted the language of S4.1.4 to clarify the ambiguity.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1630OpenMessrs. Eric B. Chaikin and Stephen J. Cabot, Suite 1300, 1845 Walnut Street, Philadelphia, PA 19103; Messrs. Eric B. Chaikin and Stephen J. Cabot Suite 1300 1845 Walnut Street Philadelphia PA 19103; Dear Messrs. Chaikin and Cabot: This is in reply to your letter of September 20, 1974, inquiring as t the certification responsibility of a person who adds a body to what you suggest is an incomplete vehicle consisting of a new glider kit and a reconditioned engine, drive train, transmission and rear axle. No incomplete vehicle documentation is furnished to the truck body installer. You indicate that some is obtainable, but not enough on which to base certification.; The NHTSA has taken the position that the use of a glider kit in th manufacture of a vehicle constitutes the manufacture of a new vehicle (completed or incomplete, depending on the stage of manufacture) and that such vehicles must therefore be certified as conforming to all applicable Federal motor vehicle safety standards. Copies of our opinions regarding 'glider kits' are enclosed. In your case, the person adding the body to the vehicle is a final-stage manufacturer, and responsible for certifying the vehicle. The person who combined the glider kit with the old power train is very likely, therefore, an incomplete vehicle manufacturer, and should have provided the documentation specified in 49 CFR Part 568, 'Vehicles Manufactured in Two or More Stages.'; While his failure to do so is a violation of these requirements, i does not excuse the final-stage manufacturer from his certification responsibilities. The final-stage manufacturer must, using due care, determine and certify that the vehicle as completed will conform to all applicable standards. His failure to do so would be a violation of sections 108(a)(1) and 108(a)(3) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. SS 1397(a)(1), 1397(a)(3)), subjecting him to the possibility of civil penalties and other sanctions. If the final-stage manufacturer cannot in good faith certify conformity, therefore, he should not complete the vehicle.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0888OpenMr. Elmar Hansen, Hansen and Associates, 1403 Timber Drive, Elgin, illinois 60120; Mr. Elmar Hansen Hansen and Associates 1403 Timber Drive Elgin illinois 60120; Dear Mr. Hansen: This is in response to your telephone inquiry of August 15, 1972 regarding Standard 125, Warning Devices. You asked whether the standard permits the production of a warning device the triangular portion of which would not be collapsible. Standard 125 does allow this configuration.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4062OpenMr. Robert C. Shaver, Mohawk Customs Service, Air Cargo Building, Hancock International Airport, North Syracuse, NY 13212; Mr. Robert C. Shaver Mohawk Customs Service Air Cargo Building Hancock International Airport North Syracuse NY 13212; Dear Mr. Shaver: This responds to your letter to this office, asking whether there wa some procedure whereby you could import new truck tires into this country, if those tires do not have the name of the manufacturer on the sidewall. You enclosed an invoice with a note written by a Customs Service officer stating that such tires do not conform with the requirements of our tire standards, because the 'tires bear no brand name.' Our tire standards do *not* require that new truck tires have the manufacturer's name or a brand name on the sidewall.; For your information, I have enclosed a copy of Standard No. 119, *Ne Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR S571.119). This is the standard applicable to new truck tires. Section S6.5 of this standard lists all of the information that must appear on the sidewalls of all new tires subject to Standard No. 119. As you see, there is no requirement that either the manufacturer's name or a brand name appear on the sidewall of these tires. The tire is required to have a tire identification number which identifies the manufacturer.; It is possible that the Customs Service was confusing the requirement for truck tires with those for passenger car tires. New passenger car tires are subject to the requirements of Standard No. 109, *New Pneumatic Tires - Passenger Cars* (49 CFR S571.109, copy enclosed). Section S4.3.2 does require that new passenger car tires be 'labeled with the name of the manufacturer, or brand name and number assigned to the manufacturer.' However, the tires you are seeking to import are not subject to this requirement, because they are not passenger car tires.; I suggest that you show this letter to the appropriate officers of th Customs Service, and ask them to reconsider their determination that the tires you seek to import do not comply with Standard No. 119. If you have any further questions in this area, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992.; 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.