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: aiam0328OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co. Ltd., Liaison Office in U.S.A., 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 400 County Avenue Secaucus NJ 07094; Re: Interpretation of Motor Vehicle *Safety Standard No. 101*#Dear Mr Mizuno:#In your letter of April 27 you ask whether it is permissible to use the words 'emergency throttle' to identify the hand throttle which Standard No. 101 requires to be identified by the word 'throttle' alone.#In our opinion the use of identifying words or symbols in addition to those required or permitted by Standard No. 101 is permissible as long as the additional words or symbols do not conflict with those required or permitted. We see no such conflict in this instance and confirm your belief 'that this wording can be used.'#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam1493OpenMr. G. Meier, Technical Service Manager, Porsche/Audi, 818 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. G. Meier Technical Service Manager Porsche/Audi 818 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Meier: This is in reference to your defect notification campaign (NHTSA No 73-0229) concerning possible fires resulting from a short in the radiator cooling fan in some Audi 100's.; The letter which you have sent to the owners of the involved vehicle does not entirely meet the requirements of 49 CFR Part 577. Specifically, the phrase, 'possible hazard that may exist in your vehicle,' may be construed as a disclaimer since it tends to discourage vehicle owners from having their vehicles corrected and is therefore not permitted. It is, however, permissible to state that the defect may not be present in every vehicle being campaigned if such a statement is applicable.; It will not be necessary to send an additional letter in this instance but all future defect notifications must comply with the applicable regulation. If you desire further information, please contact Messrs. W. J. Reinhart or James Murray at this office (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam4691OpenMr. Victor Crisci 70 Lenox Road Wayne, NJ 07470; Mr. Victor Crisci 70 Lenox Road Wayne NJ 07470; Dear Mr. Crisci: This is in response to the telephone call you made t me after receiving the interpretation of Motor Vehicle Safety Standard No. 108 furnished you on August 7, l989. To summarize, you wished to know whether a 'safety light flasher' to be installed on your motorcycle would conflict with DOT regulations. This device flashes a motorcycle headlamp between upper and lower beam for 2 to 4 seconds, then returns the light to the beam it was in when the flasher was activated. If the headlamp is off, the flasher will turn it on and initiate an identical flash cycle. We advised you that Standard No. 108 allowed flashing headlamps only on vehicles equipped with turn signals (S5.5.10(c)), and that the provision applicable to motorcycle headlamps (S5.5.l0(d)) permitted only headlamp modulators, which must provide varying intensities within a single beam, and not between beams. You have questioned this interpretation because motorcycles are required to be equipped with turn signals. We have reviewed Standard No. 108, and have concluded that your device is prohibited, albeit for reasons other than section S5.5.10(c). Section S5.5.1 requires that the means for switching between upper and lower beams conform to one of two SAE Recommended Practices, either J564a, or J565b. The first requires that the switch be operated by a simple movement of the driver's hand or foot. We do not interpret this as allowing automatic switching between upper and lower beams. Although the second provides for automatic switching, it is in the context of changing the upper beam to the lower one when oncoming traffic is approaching. Your device does not contain this feature. We must also bring your attention to section S5.1.3. This section prohibits the installation of supplementary lighting devices if they impair the effectiveness of lighting equipment that is required by Standard No. 108. In our opinion, a device that switches between upper and lower beam at times when the headlamp is illuminated would impair the roadway illumination that the headlamp is intended to supply. In addition, if the flasher caused lamps other than the headlamp to flash (such as the taillamp, which must be activated when the headlamp is steady-burning), that are required to be steady-burning in use, a noncompliance with section S5.5.11(e) would result. Sincerely, Stephen P. Wood Acting Chief Counsel; |
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ID: aiam1169OpenMr. John R. Hand, The J.L. Hudson Company, Detroit, MI 48226; Mr. John R. Hand The J.L. Hudson Company Detroit MI 48226; Dear Mr. Hand: This is in response to your request for a statement of your odomete disclosure obligations under the Motor Vehicle Information and Cost Savings Act, Public Law 92- 513.; Under the Act, all transferors must make a 'mileage statement' to th transferee. 'Transferor' means any person who transfers his ownership in a motor vehicle by sale, gift, or any means other than by creation of a security interest. This includes a dealer transfering (sic) a new or used vehicle. The only exceptions to the requirement are for vehicles over 16,000 pounds gross weight rating, non-self-propelled vehicles, vehicles 25 years old or older, and new vehicles sold by a dealer to another dealer for resale.; The statement must contain (1) the odometer reading, (2) date o transfer, (3) transferor's name and current address, (4) vehicle identification or serial number, make, model, year, body-type, last plate number, (5) a statement that actual mileage differs from recorded mileage if such is the case and the transferor knows it, and (6) reference to the Motor Vehicle Information and Cost Savings Act with the statement that incorrect information may result in civil liability under it. An example of an adequate statement and format is enclosed for your information.; The federal government does not print these forms but severa commercial printers have prepared Federal disclosure forms for the convenience of dealers. Alternatively, the statement may be included in the bill of sale, or other transfer document. In any case, it must be completed and signed prior to the transfer. Either the original or carbon copy may go to the transferee. It may be advisable to include a second disclosure statement in your form to provide for the odometer disclosure by the buyer on his trade-in vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3154OpenMr. Francois Louis, Safety and Environmental Regulations Department, Renault USA, 100 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Francois Louis Safety and Environmental Regulations Department Renault USA 100 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Louis:#I regret the delay in responding to your lette requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. The answers to your specific questions appear below.#*Section 5.2.2*#*Question 1*:Is the expression 'word form' met when using the following abbreviations?#>>>HI for High#LO for Low<<<#*Answer*: The requirement in section 5.2.2 that identification of the heating and air conditioning control shall be in 'word form unless color coding is used' does not preclude the use of readily understandable abbreviations. Therefore, the abbreviations shown above may be used.#*Question 2*: Can we use the arrow symbols corresponding to air directed either on the windshield or the feet for heater and ventilation controls?#*Answer*: Section S5.2.2 of Safety Standard 101-80 states that:#>>>Identification shall be provided for each function of any .... heating and air condition system control, and for the extreme positions of any such control that regulates a function over a quantitative range. If this identification is not specified in Tables 1 or 2, it shall be in word form unless color coding is used.<<<#If, when you speak of directing air on the windshield you are referring to the function performed by a windshield defrosting and defogging system, the control for that system must be identified by use of the symbol shown in Table 1, Column 3 of Safety Standard 101-80. If this is not what you are referring to, any symbol which you use for identification of the control must be accompanied by an identifying word or words or by a readily understood abbreviation or abbreviations unless color coding is used. The same would be true with respect to the identification of a control which directs air from the heater to the feet since Safety Standard 101-80 does not currently specify a symbol for this type of control. Please note, that although section 5.2.2 permits the use of color coding, generally color coding has been used only to identify the extreme positions of a control that regulates temperature over a quantitative range.#*Section 5.3.2*#*Question 1*: What meaning should we give to the expression, 'each discrete and distinct telltale'?#*Answer*: Section 4 of Safety Standard 101-80 defines the word 'telltale' as 'a display that indicates, by means of a light-emitting signal, the actuation of a device, a correct or defective functioning or condition, or a failure to function.' A discrete and distinct telltale is a display that indicates the actuation, correct or defective functioning condition, or a failure to function of *a single* automotive device, system or function.#*Question 2*: Does 'in conjunction' imply that the indicator light and the indicator be joint or directly beside one another?#*Answer*: Safety Standard 101-80 states that: 'any telltale used in conjunction with a gauge need not be identified.' This means that any telltale (what you have referred to as an indicator light) that is an integral part of a gauge (what you have referred to as an indicator) need not be identified. For example, a telltale placed on the fuel gauge to indicate low fuel would not have to be identified by use of the symbol indicated in Table 2 Column 4 of Safety Standard 101-80. However, the gauge itself must be identified by that symbol. If the telltale were placed elsewhere, it would have to be identified by the symbol indicated in Table 2, Column 4.#*Section 5.3.3*#*Question 1*: In this paragraph there is no indication of the number of rheostats required to regulate the luminous intensity of the different instruments.#*Answer*: The number of rheostats to be used is left to the discretion of the manufacturer.#*Question 2*: What is to be understood by 'any illumination that is provided in the passenger compartment'?#*Answer*: This phrase refers to any passenger compartment lighting regardless of its source or purpose, which is activated when and only when the headlights are activated. This interpretation is based upon the language of section 5.3.3 of Safety Standard 101-80 and upon the discussion in the preamble of the notice of proposed rulemaking that proceeded the final promulgation of Safety Standard 101-80. (41 FR 46460, October 21, 1976). The preamble of this notice states that the variable lighting requirements are meant to satisfy the need to enable drivers to reduce glare in the passenger compartment and that their application was expanded in order to include all illumination activated by the headlights 'regardless of whether it shines upon a control [or] display.'#Consequently, such items as a green ring encircling the cigarette lighter, the power window switches and the electric clock encased in the dashboard would be subject to the variable illumination requirements if those items are activated when and only when the headlights are activated.#*Question 3*: Does the phrase 'when and only when the headlights are activated,' include the 'on' parking lamps position of the switch?#*Answer*: This phrase refers only to the situation where the headlight switch is in that position which activates the headlights regardless of what other lights may be activated when the switch is placed in this position. The phrase does not refer to the situation where the headlight switch is in the position which activates only the parking lamps.#*Table 1*#*Question 1*: How must we define 'key locking system' as used in this standard?#Does this expression imply a notion of anti-theft, or does it apply only to a control by key of starting up the engine and/or shutting off the engine without any interaction with an anti-theft locking control on the steering column or the transmission, for example.#*Answer*: The key locking system is the one referred to in section S4.1 of Safety Standard 114. It states that:#>>>Each passenger car shall have a key-locking system that, whenever the key is removed will prevent (a) Normal activation of the car's engine or other main source of motive power, and (b) Either steering or forward self- mobility of the car, or both.<<<#Table 1 of Safety Standard 101- 80 indicates that the identifying words 'engine start' and 'engine stop' must be used when the engine control is separate from the key locking system. These identifying words would have to be used, for example, in a vehicle in which starting or stopping the engine required both insertion or removal of the key and use of a separate control designed to start or stop the engine.#I hope that you will find these responses helpful. If you have any further questions please feel free to address them to Ms. Debra Weiner of my office.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam1539OpenMr. J.R. Farron,Bendix Corporation,401 Bendix Drive,South Bend, Indiana 46620; Mr. J.R. Farron Bendix Corporation 401 Bendix Drive South Bend Indiana 46620; Dear Mr. Farron:#This responds to your May 28, 1974, question whether short neoprene connector of two steel vacuum brake lines in the Bendix Hydrovac unit is subject to Standard No. 106, *Brake hoses*.#The neoprene connector functions as a brake hose under the definition set out in the standard:#>>>'Brake hose' means a flexible conduit that transmits or contains the fluid pressure or vacuum used to apply force to a vehicles brakes.<<<#The determination of the 'flexibility' of a particular brake line material is a difficult but important decision. Flexibility is required in brake lines for at least two reasons. First and most important is the flexibility required to accommodate large amounts of relative motion in service, in frame-to-axle applications for example. Less obvious but important is the flexibility required in event a brake line is displaced during repair or alteration of the brake system or other nearby vehicle components. A mechanic's decision to bend a brake line during repairs may depend on whether it 'looks' flexible, and therefore appearance becomes an important element of the determination. On this basis the NHTSA has concluded that copper and steel chassis plumbing, for example, do not invite bending during repairs because their appearance makes their relative inflexibility obvious.#In contrast, plastic air brake chassis plumbing and small sections of hose used to connect steel or copper tubing, are examples of 'flexible conduits' that invite bending in order to make repairs. To ensure that these 'flexible conduits' are not damaged when they are displaced, they are considered brake hose subject to the bend and deformation requirements of the standard. In the case of the Hydrovac, the presence of the neoprene connector would appear to permit flexibility to compensate for component misalignment and to permit removal and repair of the steel tubing. It therefore is considered a brake hose under this standard.#Sincerely yours,Robert L. Carter,Associate Administrator,Motor Vehicle Programs; |
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ID: aiam3504OpenDr. John R. Holsten, Director of Regulatory Affairs, M. Lowenstein Corporation, Technical Center, P.O. Box 2000, Lyman, SC 29365; Dr. John R. Holsten Director of Regulatory Affairs M. Lowenstein Corporation Technical Center P.O. Box 2000 Lyman SC 29365; Dear Mr. Holsten: This responds to your November 25, 1981, letter asking whethe children's car seats must comply with the flammability requirements of Standard No. 302, *Flammability of Interior Materials*. The answer to your question is yes. Section S5.7 of Standard No. 213, *Child Restraint Systems*, specifically states that each material used in a child restraint system shall comply with the flammability requirements of Standard No. 302.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1256OpenSekurit-Glas Union GmbH, 5 Koln 1, Postfach 101608; Sekurit-Glas Union GmbH 5 Koln 1 Postfach 101608; Dear Sir: This is in reply to your letter of July 19, 1973, requestin information regarding the marking requirements in FMVSS No. 205 for automobile safety glass.; With respect to your request for a copy of the marking requirements they may be found in paragraph S6. of the enclosed copy of the standard, and in section 6 of American National Standard Z26.1 - 1966. The latter standard can be obtained by writing to the American National Standards Institute, 1430 Broadway, New York, New York 10018.; Information on various State requirements should be obtained from Mr Armond Cardarelli, American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.; You ask whether marking requirements can be met using a specific forma you include in your letter, and refer to 'Approval' and 'Supplemental' markings. It is not clear to us to what you refer, as we prescribe neither 'approval' nor 'supplemental' markings in the standard, and perhaps we will be better able to answer any questions you may have after you have had an opportunity to review the requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4054OpenMr. Robert R. Gregg, Metzeler Motorcycle Tire, Agent Gregg, Inc., 144 Railroad Avenue, Suite 215, Edmonds, WA 98020; Mr. Robert R. Gregg Metzeler Motorcycle Tire Agent Gregg Inc. 144 Railroad Avenue Suite 215 Edmonds WA 98020; Dear Mr. Gregg: This responds to your letter to Steve Kratzke of my staff, seeking a interpretation of Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR Part 571.119). Specifically, you asked if a motorcycle tire could have its maximum load capacity labeled on the sidewall as follows:; >>>At 60 MPH Max load _____lbs. at _____ psi cold.<<< Such labeling would violate Standard No. 119, as explained below. Section S6.5 of Standard No. 119 requires that certain information b labeled on the sidewall of all tires to which the standard applies. Section S6.5(d) requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires as follows:; >>>Max load _____lbs at _____psi cold.<<< No speed rating or restriction may be given in conjunction with th maximum load rating on the sidewall of the tire. That rating, as its name implies, is intended to alert consumers to the tire's *maximum* capabilities.; A manufacturer may label a speed restriction on its tires to aler consumers to the tire's maximum speed if that maximum is 55 miles per hour (mph) or less. Section S6.5(e) permits speed restrictions of 55 mph or less to be labeled on the sidewall of the tire as follows:; >>>Max Speed _____mph. << |
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ID: aiam3791OpenMr. A. Chambord, Standards Attache, The French Embassy, Suite 715, 2000 L Street, N.W., Washington, DC 20036; Mr. A. Chambord Standards Attache The French Embassy Suite 715 2000 L Street N.W. Washington DC 20036; Dear Mr. Chambord: This responds to your recent letter to Mr. Steve Kratzke of my staff asking for information on requirements applicable to tire rims for vans. The three points set forth in your letter are correct statements of the requirements, but I will reiterate them to be certain that you provide accurate information.; (1) Vans are considered 'motor vehicles other than passenger cars' fo the purposes of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.120), and Standard No. 120 sets forth requirements which must be met by all new rims for use on vans. No other standard contains requirements applicable to those rims.; (2) Section S5.2(c) of Standard No. 120 requires the rim manufacture to permanently label each of its van rims with the letters 'DOT' as a certification that the rim satisfies the requirements of Standard No. 120. The manufacturer is expected to exercise due care before making such a certification. No outside inspector, either governmental or privately employed, need be consulted by a manufacturer before certifying the compliance of its rims.; (3) Rims entering into the United States are not individuall inspected, provided that the package containing the rims or the van on which the rims are installed bears an appropriate certification label. The only inspections at the port of entry are checks to see that a certification label is attached to the package of rims or the van.; Should you need any further information on this subject, please do no hesitate to contact me.; 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.