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: aiam1887OpenMr. R. Wieman, Ohio Hydraulics, 2510 E Sharon Road,Cincinnati, Ohio 45241; Mr. R. Wieman Ohio Hydraulics 2510 E Sharon Road Cincinnati Ohio 45241; Dear Mr. Wieman: #This responds to your letter of March 7, 1975, to Mr Francis Armstrong of this agency, concerning possible changes if Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #On March 4, 1975, the NHTSA proposed a change in the definition of 'brake hose assembly' which would exclude from the standard's requirements certain assemblies made for repair of used vehicles (40 F.R. 8962, copy enclosed.) As proposed, the change would not exclude assemblies made by hose distributors. Several of the comments responding to the proposal have suggested that such distributor-made assemblies also be excluded, #When a final decision is made on this issue, it will be published in the Federal Register. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam0795OpenMr. F. Michael Petler, Assistant Manager, Product Development Department, U. S. Suzuki Motor Corporation, 13767 Freeway Drive, Santa Fe Springs, CA 90670; Mr. F. Michael Petler Assistant Manager Product Development Department U. S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs CA 90670; Dear Mr. Petler:#In a telephone call subsequent to receiving our answe of July 20 to your letter of July 11, you indicated that you were concerned with a different question from the one we answered regarding the Suzuki handlebar switches you enclosed. The question you had in mind was whether the direction of movement of the switches was sufficiently vertical to satisfy the requirement for 'up' and 'down' positions.#The switches you submitted move in an arc at approximately 45 degrees from the vertical. Since they have in that position a substantial vertical component, we consider that they would conform in that respect with the requirements of the standard.#Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam3013OpenMr. Jack W. Sperr, Coordinator, Pupil Transportation, Department of Education, 942 Lancaster Drive, N.E., Salem, OR 97310; Mr. Jack W. Sperr Coordinator Pupil Transportation Department of Education 942 Lancaster Drive N.E. Salem OR 97310; Dear Mr. Sperr: This responds to your April 6, 1979, letter asking several question about the applicability of the school bus safety standards to van-type vehicles.; First, you ask whether a vehicle that transports more than 10 person and is constructed in accordance with the school bus safety standards must be painted, lighted and marked as a school bus. As you know, Highway Safety Program Standard No. 17 formerly permitted Type II school vehicles, under 16 passengers, to be marked, painted, and lighted at the option of the school district. As a result of the Motor Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L. 93-492), all school buses must be equipped with school bus lights. Since they must have lights, they must also be painted and marked as school buses. Therefore, all school vehicles carrying more than 10 persons must be properly painted, marked and lighted.; In your second question you ask whether a school can purchase and use noncomplying used van manufactured after April 1, 1977. The National Highway Traffic Safety Administration (NHTSA) regulates, for the most part, vehicles up to the point of first purchase. Therefore, the sale of a noncomplying used vehicle would be beyond the control of this agency. However, we caution schools purchasing such vehicles that they may be unable to insure them, and they may be responsible for significantly increased liability in the event of an accident. Further, we encourage States not to license such vehicles for the transportation of school children.; Third, you ask whether the standard applies to leased or rente vehicles. The answer to your question is yes. Part 571.3 of our regulations (49 CFR 571) defines school bus as 'a bus that is sold, or introduced in interstate commerce,...' The phrase introduced in interstate commerce includes the lease or rental of vehicles for school use. Since these leased or rented vehicles are considered school buses, they must comply with the safety standards.; In your fourth question, you ask whether a contractor or school ca remove seats from a van that it inadvertently purchased so that as modified it will transport 10 or fewer persons. A school or contractor can modify its own vehicles any way that it chooses. A dealer, manufacturer, or repair business, on the other hand, cannot alter a vehicle in any manner that would render inoperative its compliance with Federal safety standards. The agency notes that if a school removes seats from the van in the manner suggested in your letter, the van would no longer be required to comply with the school bus safety standards. However, a new van-type vehicle that transports 10 or fewer persons must comply with safety standards applicable to multipurpose passenger vehicles (MPV). Your modified vehicle probably would not comply with these MPV requirements. You should remember that the operation of a noncomplying school bus or a noncomplying MPV does not subject a school to liability to the NHTSA. However, a school's private liability in the event of an accident might be increased.; In your final question, you ask whether the NHTSA is enforcing th school bus regulations. The agency has taken extensive steps to enforce its school bus regulations. These include a major testing program of buses manufactured in compliance with the standards. As a result of these tests, some noncompliances have been determined and some remedies have occurred. With respect to the sale of vans as school vehicles, the agency has warned many dealers of the illegality of this practice, and in most instances, these dealers have repurchased the vehicles that were sold in violation of the law.; We encourage States to adopt licensing practices that ensure tha vehicles used to transport school children and manufactured after April 1, 1977, comply with the safety standards. Many States now have such licensing programs, and the problem of van misuse is rapidly diminishing in those areas. We further encourage States to report instances of violations to our Office of Vehicle Safety Compliance. That Office will take the necessary steps to enforce the law.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4386OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Assoc., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Assoc. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: With reference to your phone conversation with Make Peskoe on Septembe 8, I have enclosed a copy of an NHTSA opinion which concludes that a person adding a snow plow to a completed vehicle is not required to certify the vehicle. In such a case, the existing certification label should be left in place. You should note that the opinion also states that if the mounting of the snow plow causes the vehicle not to conform to any applicable motor vehicle safety standard, and the vehicle is not brought back into conformity before sale, the person mounting the plow will be violating section 108(a)(1) of the National Traffic and Motor Vehicle Safety act, and will be subject to civil penalties and other sanctions as prescribed in sections 109 and 110 of the Act.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3443OpenMr. M. S. Keshav, Manager (R&D), Bajaj Auto Limited, Adurdi, Poona - 411 035 India; Mr. M. S. Keshav Manager (R&D) Bajaj Auto Limited Adurdi Poona - 411 035 India; Dear Mr. Keshav: This is in reply to your letter of July 7, 1981 asking for a 'exemption' from the requirement of paragraph S4.5.6 of Motor Vehicle Safety Standard No. 108 that an illuminated pilot indicator be provided in each vehicle equipped with a turn signal operating unit.; In your opinion, the front turn signal lamps mounted on the handlebar of certain motor scooters that you manufacture can serve as pilot indicators, if a front turn signal lamp fails to operate, the failure is readily apparent to the operator, if a left turn signal lamp fails, there is an 'appreciable change in the flashing rate' of the front lamp.; We concur in your interpretation. Although S4.5.6 does require th indicator, SAE Standard J588e *Turn Signal Lamps*, September 1970, incorporated by reference, requires it only if turn signal lamps are not readily visible to the driver. Because the operability of both front and rear turn signal lamps on the vehicles you described may be confirmed by the front turn signal alone, the front lamp is the functional equivalent of a turn signal indicator, and a separate indicator need not be provided.; As this is a matter of long-standing interpretation of Standard No. 10 we have no plans to amend S4.5.6 to incorporate it.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1184OpenMr. Charles Leeds, 1775 Broadway, New York, NY 10019; Mr. Charles Leeds 1775 Broadway New York NY 10019; Dear Mr. Leeds: This is in reply to your letter of July 12, 1973, concerning th obligations of a bank under the odometer disclosure requirements of Title 49 CFR Part 580, upon its sale of a repossessed vehicle.; If upon its repossession the bank becomes the owner of the vehicle, i is required to make a disclosure statement pursuant to 49 CFR Part 580. The auctioneer does not, as a rule, obtain ownership of a vehicle and would not be required to make the disclosure statement.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0146OpenMr. Sam W. Folsom, Jr., Gold Cross Ambulance Service, Inc., 304 Northwest Tenth, Oklahoma City, OK 73103; Mr. Sam W. Folsom Jr. Gold Cross Ambulance Service Inc. 304 Northwest Tenth Oklahoma City OK 73103; Dear Mr. Folsom: This is in reply to your letter of January 18, 1969, to Dr. Willia Haddon, Jr., requesting information on Federal Motor Vehicle Safety Standards (FMVSS) applicable to ambulances.; If the ambulance is built on a passenger car chassis, all of the FMVS applicable to passenger cars would apply. However, if the ambulance is built on a truck chassis, the FMVSS applicable to multi-purpose passenger vehicles would apply. There have been no special exceptions granted for ambulances.; Enclosed for your information and guidance are copies of the Nationa Traffic and Motor Vehicle Safety Act of 1966 and the FMVSS established thereunder.; Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service; |
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ID: aiam2481OpenMr. J. W. Lawrence, Manager, Safety & Environmental Engineering, White Motor Corporation, 35129 Curtis Boulevard, Eastlake, OH 44094; Mr. J. W. Lawrence Manager Safety & Environmental Engineering White Motor Corporation 35129 Curtis Boulevard Eastlake OH 44094; Dear Mr. Lawrence: This is in reply to your letter of February 18, 1977, asking whether 4 CFR Part 577 conflicts with Section 153(c)(4) of the National Traffic and Motor Vehicle Safety Act.; Pursuant to Section 153(c)(4) notification by a manufacturer to dealer must be 'by certified mail or other more expeditious means.' On the other hand, Part 577 requires notification to be given by first class mail to the first or most recent purchaser known to the manufacturer, in your view, which could mean a dealer. You stated that the 'apparently conflicting' requirements affect the mailing of notices to dealers when they are the last known purchasers.; There is no conflict. Part 577 is a regulation for the notification o owners of vehicles, not dealers. The regulation sets forth-- 'requirements for notification to owners of motor vehicles' (577.1) and its purpose 'is to insure that notifications of defects or noncompliances adequately inform and effectively motivate owners...to have such vehicles...inspected and, when necessary, remedied as quickly as possible' (577.2). A dealer is not an 'owner' within the intent of Part 577 and a manufacturer's notification obligation to its dealers is that set out in Section 153(c)(4).; Therefore, we cannot confirm that first class mailings from manufacturer to a dealer conform to Part 577, and your letter offers no facts upon which to base a finding that first class mail is a 'more expeditious means' of dealer notification than certified mail.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5344OpenMr. Frank Williams President Safety Brake Set 3508 Cascade Highway Silverton, OR 97381; Mr. Frank Williams President Safety Brake Set 3508 Cascade Highway Silverton OR 97381; "Dear Mr. Williams: This responds to your letter requesting informatio about Federal requirements related to a product that 'sets the brakes on an air brake vehicle when the driver exits the cab.' I apologize for the delay in our response. You stated that your 'device does not hook into the brake system but pops the parking button out if the driver is off the seat and the door is open. The brake then must be manually disengaged.' You requested confirmation that the agency will neither support nor oppose the aftermarket installation of such a device. I am pleased to have this opportunity to explain our regulations to you. I am also enclosing a copy of a fact sheet entitled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' By way of background information, the National Highway Traffic Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter. NHTSA does not have any specific regulations about a product such as your device. However, since this device is related to a vehicle's air brake system, it could affect a vehicle's compliance with Standard No. 121, Air Brake Systems. That standard applies to almost all new trucks, buses, and trailers equipped with air brake systems. If your system is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that, with the device installed, the vehicle satisfies the requirements of all applicable safety standards, including Standard No. 121. (See 15 U.S.C. 1397(a)(1) and 49 CFR Part 567). If the device is added to a previously certified new motor vehicle prior to its first consumer purchase, then the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. 49 CFR 567.7. If the device is installed on a used vehicle by a manufacturer, distributor, dealer, or motor vehicle repair business, then the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. 15 U.S.C. 1397(a)(2)(A). In particular, these entities should ensure that the installation of your device does not render inoperative the vehicle's compliance with the parking brake requirements set forth in S5.6. I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam0516OpenMr. Armand F. Macmanus, Esq., Phillips Petroleum Company, Bartlesville, OK 74004; Mr. Armand F. Macmanus Esq. Phillips Petroleum Company Bartlesville OK 74004; Dear Mr. Macmanus: This is in reply to a request made on behalf of Phillips Petroleu Company by Veigh J. Nielson for an assigned identification mark for two of Phillips' plants which manufacture tires for research purposes.; As I informed you in my letter of September 20, 1971, if Phillip purchases a new tire, removes the tread material and then applies its own experimental tread containing various rubber compounds, Phillips is considered to be a new tire manufacturer. If Phillips applies its experimental tread to a used tire, it is considered a retreader of tires.; As a new tire manufacturer you are required to certify the tire a conforming to the new passenger car tire standard (No. 109) and comply with Part 574 - Tire Identification and Record Keeping (49 CFR 574). Accordingly, you are assigned the identification mark of 'J1' for tires made in your Bartlesville, Oklahoma plant and 'K1' for tires manufactured in your Stow, Ohio plant.; If you act as a retreader then Part 574 would not be applicable for th tires you retread because they are retreaded for your own use. (Enclosed is a copy of Docket No. 70-12, Notice No. 8 which makes the regulation inapplicable to retreaders who retread for their own use). As explained in my letter of September 20, you are, of course, required to certify that your new tires and your retreaded tires comply with the respective standards for new and retreaded tires if they are to be used on the public highways, by placing the symbol DOT on the tires in the prescribed location.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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.