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: aiam4485OpenMr. A. L. Bragg Laboratory Manager Truck-Lite Co., Inc. 310 East Elmwood Avenue Falconer, NY 14733; Mr. A. L. Bragg Laboratory Manager Truck-Lite Co. Inc. 310 East Elmwood Avenue Falconer NY 14733; Dear Mr. Bragg: This is in reply to your letter of June 22, l988, t Mr. Vinson of this Office asking for an interpretation of Motor Vehicle Safety Standard No. 108. It is your understanding that for purposes of measuring the effective projected illuminated area of a lens, the reflex area, if any, must be subtracted from the total lens area. Your company manufactures a combination lamp which 'has four square inches of reflector area and eight square inches of stop, tail and turn area.' You have asked if you may advise your customers that this lamp may be used on vehicles whose overall width is 80 inches or more: 'A) Singularly (that is one on each side of the vehicle in the rear) as a stop, turn, tail and reflex reflector? B) In combination of two's or three's (on each side of the rear of the vehicle), provided that the lamps are separated by at least twenty-two inches?' Your understanding is correct, that the effective projected illuminated lens area must be determined without reference to any reflex reflector that may be combined with it. If the turn signal function in your lamp is met by one compartment, your lamp is acceptable under 'A).' But if the turn signal function is met by more than one compartment, your lamp would not be acceptable as the area of each compartment is less than l2 square inches. With regard to 'B),' the lamps could be used in combinations of twos and threes if they are mounted more than 22 inches apart but could not be used if mounted closer than 22 inches. You also asked about the relationship to paragraph S4.1.1.7. This paragraph covers replacement equipment only, without reference to its location on a vehicle. It applies only to turn signal lamps intended to replace original equipment turn signal lamps on vehicles manufactured in accordance with SAE Standard J588d, June l966. The current original equipment requirement is SAE Standard J588e September l970. You should be aware that the Truck Safety Equipment Institute has petitioned for rulemaking the effect of which would be to extend the l2-inch requirement to lamps used on all wide vehicles without reference to the 22-inch spacing. At present the agency is reviewing this petition. I hope that this answers your questions. Sincerely, Erika Z. Jones Chief Counsel /; |
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ID: aiam3340OpenMr. Kenneth R. Brownstein, PACCAR, Inc., P.O. Box 1518, Bellevue, Washington 98009; Mr. Kenneth R. Brownstein PACCAR Inc. P.O. Box 1518 Bellevue Washington 98009; Dear Mr. Brownstein: This is in response to your letter forwarding your firm's vehicl identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115, *Vehicle Identification Number*.; The National Highway Traffic Safety Administration does not giv 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.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1687OpenMr. Phillip P. Friedlander, Jr., Director of Communications, National Tire Dealers and Retreaders Association, 1343 L Street, N.W., Washington, D.C. 20005; Mr. Phillip P. Friedlander Jr. Director of Communications National Tire Dealers and Retreaders Association 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Friedlander: In the November 25, 1974, issue of the *NTDRA Dealer News*, an articl entitled 'DOT's NHTSA Issues Final Labeling Requirements Under Standard No. 117,' the recently published permanent labeling amendment to standard No. 117 (39 FR 39882, November 12, 1974) is discussed in terms which imply that these requirements are the only labeling requirements imposed by the standard. Such an interpretation in incorrect. Paragraph S6.3.1 of Standard No. 117 still imposes affixed labeling requirements for certain information items which are not permanently labeled on the finished retread.; You may wish to clarify this in a future *Dealer New* issue. Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0995OpenMrs. Arlene I. Lehto, Lehto's National Rubber Stamp and Printing, 901 East 7th Street, Duluth, MN 55805; Mrs. Arlene I. Lehto Lehto's National Rubber Stamp and Printing 901 East 7th Street Duluth MN 55805; Dear Mrs. Lehto:This is in reply to your letter of January 27, 1973 concerning the content of the odometer disclosure statement required by Federal regulations, pursuant to Public Law 92-513.; I am enclosing a copy of the regulation as published January 3, 1973 As you will note, section 580.6 describes the form to be used for disclosure. If disclosure is made on a document that contains the information necessary to identify the transferor and the vehicle, the form can be shortened by omitting the information boxes and the space for the transferor's address. Although we would not object to shortening the text of the statement somewhat, it must contain information specified in 580.4(b) and (c).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1957OpenHonorable G. William Whitehurst, House of Representatives, Washington, DC 20515; Honorable G. William Whitehurst House of Representatives Washington DC 20515; Dear Mr. Whitehurst: A reply to your inquiry of June 5, 1975, concerning grade labellin regulations for new passenger car tires was transmitted to you on June 13 by Mr. James H. Cromwell of the Department of Transportation. Mr. Cromwell also referred your inquiry to me for additional comments.; As you are undoubtedly aware, the original impetus for th establishment of a uniform quality grading system for motor vehicle tires was provided by the National Traffic and Motor Vehicle Safety Act of 1966, which established this agency. The Congress, cognizant of the problems which beset the consumer when he attempts to make an informed choice of motor vehicle tires based on the relative merits of tire brands, included a specific Section 203 in the aforementioned Safety Act of 1966 which states that, 'In order to assist the consumer to make an informed choice in the purchase of motor vehicle tires . . .the Secretary shall . . . prescribe by order, and publish in the 'Federal Register*, a uniform quality grading system for motor vehicle tires.'; The benefits of such a system, while difficult to quantify, represen an enormous potential since some 200,000,000 motor vehicle tires are produced per year and are presently sold to consumers without adequate quantitative measures of their performance. It is expected that, by facilitating increased and more meaningful competition, the quality grading information will enable the tire consumer to obtain more value per dollar than he has in the past. The rule will enable the consumer to judge relative tire performance from a simple grading system, and thereby select a tire which provides him with the optimum solution to his driving needs.; For your review and information, I am enclosing a copy of the Unifor Tire Quality Grading Standards (UTQGS) which was issued in the *Federal Register* dated May 28, 1975. The rule provides quantitative grading measures for three important tire properties -- i.e., treadwear, traction, and temperature resistance.; I trust the above information satisfies your needs. Should you have an further questions, I shall be glad to attempt to provide answers.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2678OpenMr. James E. Reider, President, International Trade Group of Ohio, Inc., 100 East Broad Street, Columbus, OH 43215; Mr. James E. Reider President International Trade Group of Ohio Inc. 100 East Broad Street Columbus OH 43215; Dear Mr. Reider: This is in reply to your letter of October 14, 1977, to Don Williamso of our Ohio regional office.; You enclosed information on an automatic warning flasher lamp that i designed for installation on the parcel shelf inside the rear window of automobiles. You asked whether such a device would be legal on U.S. cars or U.S. highways, and 'what steps might be required to obtain an endorsement for the generic device from the N.H.T.S.A.'; The unit appears to be designed for sale as a motor vehicle accessor in the aftermarket. There are no Federal prohibitions against the sale of the warning device or its installation in motor vehicles. Whether it is legal to use such a device however is a question to be answered under the laws of the jurisdiction where the motor vehicle in which it is installed is registered and/or operated.; The NHTSA does not issue approvals or endorsements of propriety safet devices.; Yours truly, Frank Berndt, Deputy Chief Counsel |
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ID: aiam0645OpenMr. Russell E. MacCleery, Vice President, Automobile Manufacturers Association, Inc., 1619 Massachusetts Avenue, N.W., Washington, DC 20036; Mr. Russell E. MacCleery Vice President Automobile Manufacturers Association Inc. 1619 Massachusetts Avenue N.W. Washington DC 20036; Dear Mr. MacCleery: This is in reply to your letter of March 3, 1972, in which you asked t be referred to the information on which we based our statement in the notice of February 24, 1972, that systems meeting the injury criteria of Standard 208 are available using current seat belt technology.; Research data on the capabilities of seat belts are found in severa places in the public docket, notably in the progress reports from our Safety Systems Laboratory and from Cornell Aeronautical Laboratory (69-7 General Reference Nos. 74, 75, 83, 96, 102, 117, 120 and 135). There are records of vehicle tests in which current lap and shoulder belt systems have met the injury criteria (see, e.g. N13-69-7-20, N13-69-7-37). Also, the record contains information on energy absorbing webbing and anchorages, both of which are improvements within the current state of the art (see, for example, the 6th progress report from Cornell, runs no. 625-630, 69-7 General Reference No. 135, the data from Toyota in N13-69-7- 23, and the Takata Koyjo data in N16-69-7-1).; Although the behavior of the head seems to be a greater problem fo belt systems than the behavior of the chest, due in part to the effects of rebound, we have proposed changes in the head injury criterion that should ease the problem considerably.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam2382OpenMs. Judith E. Ciani, Pillsbury, Madison & Sutro, 225 Bush Street, P. O. Box 7880, San Francisco, CA 94120; Ms. Judith E. Ciani Pillsbury Madison & Sutro 225 Bush Street P. O. Box 7880 San Francisco CA 94120; Dear Ms. Ciani: This responds to your May 11, 1976, question whether S 574.7 of Par 574 (*Tire Identification and Record Keeping*) (49 CFR Part 574), requires that the brand name owner of a single tire brand must supply to its dealers tire registration forms that conform to the dimensions specified for the 'universal form' described in Figure 3 of the regulation. You also request confirmation that a tire registration form 'which fits credit card imprinters and provides for the registration of only two tires' is similar in format to the form described in Figure 3.; Section 574.7 of the regulation specifies in part that '. . . form conforming in size and similar in format to Figure 3 shall be provided to those dealers who request them. . . .' As stated in the preamble accompanying the requirement, the purpose of the specification is to ease the problem of the multi-brand dealer who was 'faced with a multiplicity of different forms and procedures for tire registration' (39 FR 19482, June 3, 1974). The requirement that the 'universal form' conform in size as well as format was added in conjunction with a similar requirement for dealers, in response to petitions for reconsideration of the June amendment (39 FR 28658, November 1, 1974).; Review of the changes indicates clearly that the requirement fo conformity in size of the 'universal form' was directed only to the situation of multi- brand dealers. The NHTSA does not consider the manufacturer or brand name owner of one tire brand to be subject to this requirement in the case of a dealer who sells only one brand of tires. It is clear that any advantage in the storage of different forms from different tire manufacturers would not apply in the case of a one-brand dealer. Accordingly, the NHTSA interprets S 574.7 to not require conformity in the size of forms supplied by a tire manufacturer, brand name owner, or its designee, in the case of requests from dealers that sell only one brand of tire.; In answer to your second request, the NHTSA considers a tir registration form which provides for the registration of only two tires to be similar in format to the form described in Figure 3. Any variation from the size of the form described in Figure 3 would, of course, be subject to the limitation just discussed.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5447OpenOctober 4, 1994; October 4 1994; "Mr. Ashpy Lowrimore Senior Vice President Southern National Bank P.O Box 6676 Florence, SC 29502 Dear Mr. Lowrimore: This responds to your August 11, 1994 letter regarding our requirements for school vehicles. You explain that your church owns a 'commercial bus' and a 15-passenger van and would like to use these vehicles to transport children attending a kindergarten and after school care program that the church operates. You ask to be advised of any requirements applicable to those two vehicles, and have three questions, which I will answer below. I would like to begin with background information about our requirements. Our agency has two sets of regulations, issued under different Acts of Congress, that affect school vehicles. The first of these, the Federal motor vehicle safety standards (FMVSS's) issued under 49 U.S.C. 30101, et seq., apply to the manufacture and sale of new motor vehicles. Our agency was directed by Congress in 1974 to issue standards on specific aspects of school bus safety, including floor strength, seating systems, and crashworthiness. The standards we issued apply to all new vehicles designed to carry 11 or more persons and sold for pupil transportation purposes. Under our requirements, such a vehicle is a 'school bus,' and any person selling such a vehicle must ensure that the new vehicle is certified as meeting the FMVSS's for school buses. The second set of regulations issued by this agency was promulgated under the Highway Safety Act of 1966. These 'regulations' are actually recommendations from NHTSA to the States for use in developing their highway safety programs. Highway Safety Program Guideline No. 17, Pupil Transportation Safety, 23 CFR 1204 (copy enclosed), applies to school vehicles, and contains recommendations for the design, identification and operation of school vehicles. Individual States have chosen to adopt some or all of Guideline No. 17 as their own policies governing their highway safety programs. With that background in mind, I turn now to your specific questions: 1. Can we transport children who are related with our various schools by utilizing the van? ANSWER: The answer depends on State law, because the States regulate the use of motor vehicles, not NHTSA. NHTSA regulates the manufacture and sale of new vehicles. Any person selling a new bus or a new 15-passenger van to your church for purposes that include transporting kindergarten students to and from school or related events must sell buses that meet our FMVSS's for school buses, or face substantial civil fines and injunctive sanctions. NHTSA does not have the authority to regulate vehicle users, and thus does not mandate what vehicle can be used to transport school children. Thus, our regulations impose no requirement on schools that require them to transport students in complying school buses. While NHTSA does not require the use of any particular type of vehicle to transport students, we believe that school buses are the safest motor vehicle transportation currently available. We have included in Guideline No. 17 a recommendation that States require any bus (or van carrying 11 or more persons) used to carry school children to comply with all FMVSS's applicable to school buses at the time of their manufacture (see, recommendation number IV.B.1.h). However, since Guideline No. 17 will affect your church's school vehicles only if South Carolina has adopted it, you should check to see what State requirements are set for the operation of the school vehicles in question. Mr. Perry Brown, Deputy Director of South Carolina's Office of Highway Safety Programs, would be able to provide information about your State's requirements. He can be contacted at the following address: Mr. Perry Brown Edgar A. Brown State Office Building 1205 Pendleton St., Rm. 453 Columbia, SC 29201 2. Are there restrictions associated with the use of the bus in the transportation of children, young adults or senior adults? As explained above, NHTSA has no restriction on the use of motor vehicles. Restrictions on the use of a vehicle are matters of State law. Among other things, the State could require a special driver's license for persons operating buses as you described. A South Carolina official would be able to provide the information you need. 3. If there are special restrictions, can you elaborate on the type of equipment that we must obtain in order to meet any regulations or requirements that are in place? ANSWER: Again, NHTSA has no restrictions on the use of the vehicles by the church. Further, NHTSA does not require schools operating their vehicles to ensure that the vehicles are specially identified or equipped as school vehicles. However, Guideline No. 17 contains recommendations for identifying school buses and equipping them with safety equipment, including school bus lamps and mirrors and emergency equipment. South Carolina may have adopted some of these recommendations in its highway safety program for school vehicles. In summary, NHTSA does not have the authority to regulate the use of school vehicles owned and operated by your church. You should check with South Carolina officials to find out which, if any, State requirements apply to your church's activities. We hope this information is helpful to you. Should you have any further questions regarding this matter, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure "; |
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ID: aiam2228OpenMr. A. G. Colburn, Director of Trailer Design, Lufkin Industries, Inc., P.O. Box 848, Lufkin, TX 75901; Mr. A. G. Colburn Director of Trailer Design Lufkin Industries Inc. P.O. Box 848 Lufkin TX 75901; Dear Mr. Colburn: This responds to your February 6, 1976, questions whether Lufki Industries may, as an incomplete vehicle manufacturer, build 'incomplete chassis trailers' that do not have brakes installed that comply with Standard No. 121, *Air Brake Systems*, and whether Lufkin may tow the 'incomplete chassis trailers' over the highway to the final-stage manufacturer without brakes that conform to Standard No. 121.; Lufkin's activities are regulated by Part 568 of Title 49 of the Cod of Federal Regulations, if the 'incomplete chassis trailers' qualify as 'incomplete vehicles.' A copy is enclosed for your information. Part 568 does not require the incomplete vehicle to meet all applicable safety standards, but S 568.4 does require a statement of the status of an incomplete vehicle's conformity with all applicable standards.; In answer to your second question, the NHTSA permits the use of a incomplete vehicle on the public highways for the purpose of transit between the incomplete vehicle manufacturer and subsequent manufacturers, but for no other purpose, until such time as the vehicle complies with all Federal motor vehicle safety standards applicable to it as completed. This ruling by the NHTSA does not relieve the manufacturer or shipper from any applicable requirement imposed on the incomplete vehicle by other Federal, State, or local authority.; Sincerely, Frank 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.