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: aiam4594OpenRobert C. Craig Quality Control Manager Cosco, Inc. 2525 State Street Columbus, IN 47201; Robert C. Craig Quality Control Manager Cosco Inc. 2525 State Street Columbus IN 47201; "Dear Mr. Craig: This responds to your February 3, 1989 letter to Mr George Parker, our Associate Administrator for Enforcement, seeking an interpretation of Standard 213, Child Restraint Systems (49 CFR /571.213). Specifically, paragraph S5.5 of that standard requires each child restraint system to be permanently labeled with certain specified information. One of the items of information required to be permanently labeled on the child restraint is the manufacturer's recommendations for the maximum weight and height of children who can safely occupy the system, and those weight and height recommendations must be expressed in English units (pounds and inches). Your letter stated that your company would like to express its maximum weight and height recommendations in both English units and equivalent metric units (kilograms and meters), and asked whether this would be permitted by Standard 213. As long as the information is presented in a manner that is not likely to cause confusion, Standard 213 does not prohibit manufacturers from expressing required information in equivalent English and metric units. For each of the labeling requirements set forth in NHTSA's regulations, this agency has consistently taken the position that manufacturers may present information in addition to the required information, provided that the additional information is presented in a manner that is not likely to confuse the user. Moreover, the agency has already concluded that passenger car tires may be labeled with required information expressed in equivalent English and metric units. See the enclosed April 5, 1979 letter to Mr. Michael Petler. We would apply the same reasoning in interpreting the labeling requirements of Standard 213. That is, Standard 213 permits manufacturers to present the required information in both English and metric units, provided that the information is presented in a manner that is not likely to confuse persons using the child restraint system. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam3251OpenMr. Don Gerken, Product Engineer, Cosco Home Products, 2525 State Street, Columbus, IN, 47201; Mr. Don Gerken Product Engineer Cosco Home Products 2525 State Street Columbus IN 47201; Dear Mr. Gerken: This responds to your letter of March 27, 1980, to Mr. Stephen Oesch o my staff concerning Standard No. 213, *Child Restraint Systems*. You asked whether the labels and installation diagrams required by the standard must comply with Standard No. 302, *Flammability of Interior Materials*. In addition, you asked whether an upholstery tag, required by State law, attached to the seat must comply with Standard No. 302.; Section 5.7 of Standard No. 213 requires 'each material used in a chil restraint system' to conform to the performance requirements of Standard No. 302. Because the label, installation diagram and tag materials are affixed to the child restraint, they would have to comply with Standard No. 302.; Section 4.2.2 of Standard No. 302 provides that 'any material tha adheres to other materials at every point of contact' shall meet the performance requirements of the standard 'when tested as a composite with the other materials.' Thus, if the label, diagram and tag are affixed to the plastic shell of the restraint so that they adhere to the shell at every point of contact, they would be tested with the shell. If the label, diagram and tag do not adhere at every point of contact, section 4.2.1 requires them to meet the performance requirement of the standard when tested separately.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1693OpenMr. W.A. Hertel,Corporate Staff Engineer,Parker-Hannifin Corporation,17325 Euclid Avenue,Cleveland, Ohio 44112; Mr. W.A. Hertel Corporate Staff Engineer Parker-Hannifin Corporation 17325 Euclid Avenue Cleveland Ohio 44112; Dear Mr. Hertel:#Please forgive the delay in responding to your lette of October 28, 1974, enclosing a sample air brake hose assembly and requesting approval of Parker-Hannifin's banding technique to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, for labeling brake hose assemblies.#The NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that i cannot easily be removed.From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam0981OpenMr. Carl Monk, 428 Southland Boulevard, Louisville, Kentucky 40214; Mr. Carl Monk 428 Southland Boulevard Louisville Kentucky 40214; Dear Mr. Monk: This is in further response to your letter of January 5, 1973, to Mrs Virginia Knauer, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 125, *Warning Devices*.; As you already know from Mr. E.T. Driver's letter of January 24, 1973 and previous correspondence from my office and the Department of Transportation, the National Highway Traffic Safety Administration issued the standard as an equipment item that would be suitable for use in all types of vehicles, from trucks to passenger cars.; In issuing the standard, we were concerned with the great variety o devices presently available, which can create confusion and misunderstanding to the motoring public. We were also concerned with wind stability, and your comments were most useful in our consideration of this aspect of the requirements. FMVSS No. 125 is an attempt to achieve a standardized device having a proper balance of the factors affecting shape, size, cost, visibility, wind stability and weight. These are minimum standards and the manufacture and sale of devices that exceed these requirements is not prohibited.; Again, thank you for your comments. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3354OpenMr. Rodney Ehrlich, Director of Engineering Monon Trailer Division, Evans Transportation Company, 117 North Walnut, P.O. Box 655, Monon, Indiana 47959; Mr. Rodney Ehrlich Director of Engineering Monon Trailer Division Evans Transportation Company 117 North Walnut P.O. Box 655 Monon Indiana 47959; Dear Mr. Ehrlich: This will confirm your telephone conversation with Mr. Frederi Schwartz of my office concerning your proposed compliance scheme for the Federal Motor Vehicle Safety Standard No. 115 - Vehicle identification number.; The National Highway Traffic Safety Administration (NHTSA) does no give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115. This system may be implemented immediately.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4491OpenMr. Richard J. Matysiak President Auto Chek, Inc. P.O. Box 258 Stone Mountain, GA 30086-0258; Mr. Richard J. Matysiak President Auto Chek Inc. P.O. Box 258 Stone Mountain GA 30086-0258; "Dear Mr. Matysiak: This responds to your letter to Mr. Frank Ephrai of our Office of Plans and Policy, asking about the effects of the Federal Motor Vehicle Theft Prevention Standard (49 CFR Part 541, copy enclosed) on certain body repair processes. Specifically, you asked how the theft prevention standard would affect the body repair process of 'clipping' body sections from one vehicle and attaching the clipped section to a different vehicle. This repair process is not prohibited or regulated by the theft prevention standard, as explained below. The purpose of the theft prevention standard is to reduce the incidence of motor vehicle thefts by facilitating the tracing and recovery of parts from stolen vehicles. To achieve this purpose, the theft prevention standard requires manufacturers to affix or inscribe identification markings onto 14 major original equipment and replacement parts of certain high theft cars. Dealers and repair shops are prohibited from removing, obliterating, tampering with, or altering these identification markings, unless the removal, obliteration, tampering, or alteration is reasonably necessary to repair the part or vehicle, see 18 U.S.C. 511. These requirements should not significantly impact the repair process of 'clipping' described in your letter. Nothing in the theft prevention standard or the law prohibits a repair shop from clipping sections from wrecked vehicles. The repair shop would be required by law to leave in place any identification markings on the 'clipped' section that were not damaged in the 'clipping' process. As noted in your letter, the repaired vehicle might have two different vehicle identification numbers (VIN's) marked on its major parts, with some parts marked with the VIN assigned to the repaired vehicle and other parts marked with the VIN assigned to the damaged vehicle from which the section was 'clipped.' The Motor Vehicle Theft Law Enforcement Act of 1984, which ordered this agency to promulgate the theft prevention standard, clearly contemplates that vehicles undergoing repair could wind up with some parts numbered differently than the parts originally on the car. That law is based on the idea that some major parts are likely to survive a crash undamaged and that those parts can legitimately be used to repair other vehicles. Such repairs would naturally result in repaired cars having some parts numbered differently than the rest of the car. Since the law enforcement community vigorously supported this law, they must not have believed that cars with some parts numbered differently than the other parts of the car would pose particular problems for them. You also asked how the 'clipping' process would affect our disclosure and titling requirements. We answered the question of how the disclosure requirements apply in an October 15, 1980 letter to Mr. John Kelly of the Iowa Department of Transportation. In the letter to Mr. Kelly, we said, '... if a vehicle is constructed from the parts of several vehicles, the odometer statement must still be completed at the time of sale. If the seller knows the mileage on the various components used to construct the vehicle, he should inform the purchaser of the highest mileage that he knows, or the mileage on the chassis if he knows it. If he does not know the mileages, he will be required to state that the mileage is not accurate and should not be relied upon. Titling requirements and designations such as 'salvage' and 'rebuilt' vehicles are determined by State law, not Federal law. If you have any further questions on this matter, please contact Steve Kratzke of my staff at this address, or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam1369OpenMr. Danny Lanzdorf,Oshkosh Truck Corporation,2307 Oregon St.,Oshkosh, Wisconsin 54901; Mr. Danny Lanzdorf Oshkosh Truck Corporation 2307 Oregon St. Oshkosh Wisconsin 54901; Dear Mr. Lanzdorf:#This is to confirm your conversation of December 12 1974, with Mark Schwimmer of this office, in which you requested information on the permissibility of spray painting brake hose end fittings in the trucks which you manufacture.#Because the construction of the brake hose assembly is completed before the spray painting would take place, the only requirement of Motor Vehicle Safety Standard No. 106-74 which might prohibit the painting would be a vehicle requirement. Standard No. 106-74 as applied to vehicles is not effective until September 1, 1975, therefore, you may spray paint end fittings until then. The next Federal Register notice concerning the standard will deal with the permissibility of painting end fittings after the September, 1975 effective date.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam3704OpenMr. H. Nakaya, Manager, Mazda (North America) Inc., 23777 Greenfield Road - Suite 462, Southfield, MI 48075; Mr. H. Nakaya Manager Mazda (North America) Inc. 23777 Greenfield Road - Suite 462 Southfield MI 48075; Dear Mr. Nakaya: This is in reply to your letter of May 24, 1983, asking whether th headlamp bezel is considered a 'styling ornament or other feature' for purposes of paragraph 5.2 of SAE J580 *Sealed Beam Headlamp Assembly*, Aug 79 incorporated by reference in Standard No. 108.; The referenced SAE paragraph prohibits styling ornaments or othe features in front of the lens when the headlamp is in use. The intent of this paragraph is to guarantee optimum light output from the headlamp by insuring that no part of the vehicle interferes with the light pattern. If a headlamp bezel is so large that it could interfere with the design light patterns of the lamp, we would consider it a 'styling ornament or other feature' within the meaning of paragraph 5.2.; An oversize bezel interfering with light output would also b prohibited by paragraph S4.1.3 of Standard No. 108 which prohibits installation of motor vehicle equipment that impairs the effectiveness of lighting equipment which the standard requires.; I hope that this answers your question. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1739OpenMr. Harry J. Warmkessel,Mack Trucks, Inc.,Box M,Allentown, Pennsylvania 18105; Mr. Harry J. Warmkessel Mack Trucks Inc. Box M Allentown Pennsylvania 18105; Dear Mr. Warmkessel:#This responds to the August 1, 1974, request o Mack Trucks, inc., that the painting of brake hose end fittings be permitted under the Federal Motor Vehicle Safety Standards No. 106-74.#In the preamble to amendments to the standard which were published June 28, 1974 (39 FR 24012, Docket No. 1-5, Notice 11), the NHTSA interpreted S5.2.3 as prohibiting the painting of end fittings because required labeling would be obscured.#New information indicates that spray painting of end fittings leaves their labeling visible in most cases and that, in the occasional instance where labeling is obscured, excess paint may be easily scraped off. In addition, painting protects the labeled and fittings against corrosion. Therefore, the NHTSA is changing its interpretation of this section, so that the painting of end fittings will not be considered a violation of the standard.#The issue of masking brake hose labeling will be dealt with in the next Federal Register Notice regarding Standard No. 106-74.#Yours truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam2816OpenMr. Robert J. Voshell, Director, Motor Vehicle Division, State of Delaware, P.O. Box 698, Dover, DE 19901; Mr. Robert J. Voshell Director Motor Vehicle Division State of Delaware P.O. Box 698 Dover DE 19901; Dear Mr. Voshell: This is in reply to your letter of May 18, 1978 which asks th following questions:; >>>'Is there a Motor Vehicle Safety Standard which requires al motorcycles to be equipped with turn signals, other than those expressly exempted under FMVSS 108 (whose speed attainable in 1 mile is 30 mph or less) S4.1.1.26?'<<<; Yes. Paragraph S4.1.1 of Standard No. 108 requires, in part, that moto vehicles be equipped with the lamps specified in Table III. Turn signal lamps are required for motorcycles under Table III.; >>>'Does the standard apply to only highway-use vehicles wit trail-bikes exempted?'<<<; Yes. The motorcycles covered by Standard No. 108 must be 'moto vehicles' in the first instance, in order to be subject to the regulatory authority of the National Traffic and Motor Vehicle Safety Act. A 'motor vehicle' is one 'manufactured primarily for use on the public streets, roads and highways'. This would exclude a trail bike unless its manufacturer had certified it to meet all applicable Federal motor vehicle safety standards, indicating his intent that it be used on-road as well as off-road.; We are enclosing a copy of Standard No. 108 as you requested. Sincerely, Joseph J. Levin, Jr., 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.