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: aiam2964OpenMr. John Cordner, Technical Assistant, Product Compliance, Subaru of America, Inc., 7040 Central Highway, Pennsuaken, NJ 08109; Mr. John Cordner Technical Assistant Product Compliance Subaru of America Inc. 7040 Central Highway Pennsuaken NJ 08109; Dear Mr. Cordner:#I regret the delay in responding to your letter o October 17, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls, (sic) and Displays*. You asked whether placing the turn signal symbol on the turn signal switch handle so that the arrows are vertical would comply with the standard.#The answer is no. Section 5.2.1 requires that the turn signal symbol appear preceptually (sic) upright to the driver. The purpose of that requirement is to ensure quick and accurate identification of the vehicle controls. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle.#Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam0959OpenMr. Martin Gal, Vice-President, Pilot, Inc., P. O. Box 40, Battle Creek, MI 49016; Mr. Martin Gal Vice-President Pilot Inc. P. O. Box 40 Battle Creek MI 49016; Dear Mr. Gal: In your letter of December 15, 1972, to the Department, you ask 'Do th regulations require that the brake lite be activated prior to the onset on any brake pressure due to pedal travel . . . can some brake pressure be on before the brake lite lights?'; Paragraph S4.5.4 of Motor Vehicle Safety Standard No. 108 *Lamp Reflective Devices and Associated Equipment* requires that 'the stop lamps shall be activated upon application of the service brake.' The standard does not state a specific time or brake line pressure at which activation shall occur so that some brake pressure is permitted at the activation point.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3676OpenMr. Mike Grant, TRANZ ACC Inc., 21807 Plummer Street, Chatsworth, CA 91311; Mr. Mike Grant TRANZ ACC Inc. 21807 Plummer Street Chatsworth CA 91311; Dear Mr. Grant: This responds to your February 25, 1983, letter asking whether a chil seat that you would like to import would comply with Standard No. 213, *Child Restraint Systems*. Your child seat attaches to a vehicle by use of several of its own anchorage straps which are attached to existing vehicle belt anchorages or by drilling new anchorages. The seat does not use the existing car seat belt system.; Paragraph S5.3.2 of the standard states: 'When installed on a vehicl seat, each child restraint system, other than child harnesses, shall be capable of being restrained against forward movement solely by means of a Type I seat belt assembly (defined in S571.209) that meets Standard No. 208 (S571.208), or by means of a Type I seat belt assembly plus one additional anchorage strap that is supplied with the system and conforms to S5.4.' Since your system has its own harnesses and does not utilize the existing car seat belt system (Type I seat belt), it would not comply with this portion of the standard.; The agency requires child seats to be attachable by use of the existin car seat system for ease of installation and to assist in proper installation and usage. The agency determined in rulemaking that to permit other systems that were more complex and that require the proper attachment of several harness straps would not be in the interest of safety, since it would likely result in improper child seat installation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4019OpenDouglas I. Greenhaus, Esq. National Automobile Dealers Association, 8400 Westpark Drive, McLean, VA 22102; Douglas I. Greenhaus Esq. National Automobile Dealers Association 8400 Westpark Drive McLean VA 22102; Dear Mr. Greenhaus: This is in response to your request of October 7, 1985, concernin Federal odometer disclosure regulations, 49 CFR Part 580.; The form you enclosed, as is, does not meet the requirements of sectio 580.4(a)(3) and/or (4). However, if the purchasing/selling dealer includes his/her name and address at the upper left hand corner of the form, the requisite information will be set forth and the form will conform to agency procedural requirements. There is no prohibition against combining odometer disclosure information with other information concerning the sales transaction.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam3226OpenMr. Brian O'Meara, President & General Manager, O'Meara Ford Center, 400 West 104th Avenue, Denver, CO 80234; Mr. Brian O'Meara President & General Manager O'Meara Ford Center 400 West 104th Avenue Denver CO 80234; Dear Mr. O'Meara: This responds to your February 26, 1980, letter asking about the prope certification for a Ford Mustang that has been converted to a convertible. You ask what certification is required before you would be permitted to sell such a vehicle.; The National Highway Traffic Safety Administration requires al manufacturers of motor vehicles to certify that their vehicles comply with Federal safety standards prior to first sale. In the case of the vehicle that you mention, Ford Motor Company would have certified it when it was sold to the company that converted it to a convertible. Ford's certification label is located on the driver's door or pillar post.; The company that converted the vehicle, Tomaso of America, i responsible for putting its own label on the vehicle indicating that as altered the vehicle continues to comply with the applicable Federal safety standards. The requirements for alterers' labels are located in Title 49 of the Code of Federal Regulations, Section 567.7. Tomaso's label should also be located on the vehicle in the same area as Ford's.; If both of the labels are on the vehicle, it is legal for you to sel it. If either of the labels is missing from the vehicle, then the vehicle is not correctly certified and may be in noncompliance with the safety standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2821OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your April 24, 1978, letter asking two question concerning Standard No. 222, *School Bus Passenger Seating and Crash Protection*.; In your first question, you ask what the National Highway Traffi Safety Administration (NHTSA) means by the phrase 'seat components shall not separate at any attachment point.' This phrase is found in the forward and rearward loading performance tests. You suggest that the NHTSA interpret this to mean a complete separation of a seat component from another component. The NHTSA disagrees with this suggestion.; The standard as written clearly indicates that the agency has intende that seat components remain connected at all attachment points during testing. If the agency had intended a complete separation of seating components to be the test for separation, it would have used that language in the drafting of the regulation. Therefore, the agency declines to adopt the interpretation that you suggest and will require the seat to remain attached at all attachment points during testing.; Your second suggestion concerns a possible problem in the computatio of loads during rearward testing. You state that occasionally the loading bar will become buried in the upholstery material and, therefore, distort the actual seat loads. The NHTSA has not noted the phenomenon to which you refer. However, if it were to occur in compliance testing the agency would be certain to factor out any aberrations in the test results that occurred owing to this loading bar problem.; Sincerely, Joseph J. levin, Jr., Chief Counsel |
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ID: aiam3733OpenMr. 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 response to your letter of July 8, 1983 asking for a interpretation of Motor Vehicle Safety Standard No. 108.; Section S4.2 of SAE Standard J588e *Turn Signal Lamps* establishes minimum distance of 4 inches from the optical axis (filament center) of the front turn signal to the inside diameter of the retaining ring of the headlamp providing the lower beam. You believe that it is not necessary to have a retaining ring on a semi-sealed headlamp and you have asked whether you may substitute the edge of the reflector (as shown on your drawing) to measure the dimension covered by S4.2 of J588e.; The point depicted on your drawing appears to be the inner edge of th reflector, rather than the extreme edge, nevertheless, the 'reflector edge' you have indicated is the approximate location of a retaining ring on a fully sealed headlamp, and is therefore acceptable as a measuring point under Standard No. 108.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3363OpenMr. James A. Guenther, Guenther Auto Works, 3908 West Main - 8B, Belleville, Illinois 62223; Mr. James A. Guenther Guenther Auto Works 3908 West Main - 8B Belleville Illinois 62223; Dear Mr. Guenther: This is in reply to your letter of September 26, 1980 providing furthe information on your proposed manufacturing operation. I am pleased you found our earlier response 'most workable and least bureaucratic' and hope that you will find this letter equally so.; A vehicle consisting of a new body on a used chassis, and retaining th same title, is a 'used' vehicle, which does not have to meet the Federal safety standards that apply to new vehicles. If you were using the chassis of vehicles built on or after January 1, 1968, the resulting vehicle would have to meet the standards that applied when the original vehicle was built. However, there were no vehicle safety standards that applied before January 1, 1968 so your contemplated use of a 1964 chassis(of 1965-67 for that matter) frees you totally of responsibility for vehicle safety standards compliance, no matter whether you are a kit supplier or an end assembler, or are using new or reconditioned components.; A few of our safety standards, however, apply to equipment items specifically brake hoses, brake fluid, lighting equipment, tires, glazing, seat belt assemblies, and wheelcovers/hub caps. If you by any of these items from an outside supplier, and the item is manufactured in the U.S.A., it is virtually certain that it will be certified by its manufacturers as meeting federal equipment standards. From your letter, it would appear that only the glazing standard (Standard No. 205) might be of concern to your operations since you write that you 'will have constructed ... glass panes ...' Glazing bearing the designation 'AS-1' must be installed in the windshield of the new body. I am enclosing a copy of Standard No. 205 for your information.; Under the National Traffic and Motor Vehicle Safety Act you are 'manufacturer' with respect to any vehicle equipment you fabricate or vehicle you assemble. This means that in the event a 'safety related defect' developed in your product, you would be obligated to notify the owners and remedy the defect. I enclose our 'Part 573' which tells you haw to file a defect report with us an 'Part 577' which details how you notify purchasers and the optional remedies you may provide (See 577.5 (g)(i)(g)(v) and (g)(vi)). Finally, if you intend to assemble the vehicles yourself, or if you are fabricating glazing (or other item covered by a Federal standard, you should submit the information required by our 'Part 566' which I also enclose.; If you have any further questions we will, of course, be happy t answer them and we appreciate your wish to be informed of your obligations under Federal law.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3699OpenMr. Stephen E. Parmeter, Route 4, Potsdam, NY 13676; Mr. Stephen E. Parmeter Route 4 Potsdam NY 13676; Dear Mr. Parmeter: This responds to your recent letter concerning the process of repairin breaks in automobile windshields. You ask whether such repairs would conflict with any present Federal motor vehicle safety standards.; The National Highway Traffic Safety Administration has issued Federa Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair process such as you describe, however. There is no Federal regulation which would prohibit the use of a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use.; Please note, however, that using such a material or process in a ne windshield which may require repair (as a result of damage sustained, for example, in shipment) could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, or could fail to bring a noncomplying windshield back into compliance. Either case of noncompliance would be the responsibility of the person selling the windshield (49 CFR 567.7, copy enclosed). Therefore, we do not recommend use of windshield repair processes prior to the first purchase of a new windshield by a consumer.; You will have to contact a private attorney to determine your liabilit under civil law with regards to such a business.; Please contact Hugh Oates of my staff if you have any furthe questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2122OpenHonorable John P. Murtha, House of Representatives, Washington, DC 20515; Honorable John P. Murtha House of Representatives Washington DC 20515; Dear Mr. Murtha: This responds to your November 5, 1975, request for the criteri necessary for construction of testing equipment used to demonstrate compliance with Standard No. 121, *Air Brake Systems*.; The motor vehicle safety standards, including Standard No. 121, ar established as requirements that vehicles must be capable of meeting if tested by the National Highway Traffic Safety Administration (NHTSA). However, the standards are not developed as demonstration procedures that detail methods a manufacturer would use to establish that its products comply. The development of actual test protocols to determine that products conform to the requirements is the responsibility of the regulated industry and the associated industries that service them.; Thus the Thiele Corporation, as a manufacturer of air-braked vehicles may choose whatever test method gives it an adequate basis for certification that its products comply (15 U.S.C. S 1397(a)). Test equipment has been developed by several commercial sources, and Thiele can choose proper systems by consulting with the manufacturers of the brake components it uses. As for specifications for a test track, actual road tests are not necessary to establish compliance with Standard No. 121 where other reasonable means, such as engineering calculations coupled with laboratory tests, can be used to the same effect. Supplier warranties and instructions are one of the primary means by which small assemblers ascertain that their products conform.; Sincerely, Frank A. Berndt, Acting 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.