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: aiam1598OpenMr. J. A. Brown, Manager - Engineering Res. & Dev., Dexter Axle Company, Inc., P. O. Box 250, 2030 South Main St., Elkhart, Indiana 46514; Mr. J. A. Brown Manager - Engineering Res. & Dev. Dexter Axle Company Inc. P. O. Box 250 2030 South Main St. Elkhart Indiana 46514; Dear Mr. Brown: This responds to your August 19, 1974, request to be advised of th steps necessary to acquire a manufacturer code number as required by Standards No. 119, *New pneumatic tires for vehicles other than passenger cars*, and No. 120, *Tire selection ad rims for motor vehicles other than passenger cars*.; Standard No. 119 applies to tires only and its is the responsibility o the tire manufacturer to obtain a code number and label it on his products. As a user of tires, you do not have obligations under this standard.; Standard No. 120 is a proposal which applies to rim construction an the selection of the correct rim for the vehicle it equips. As a manufacturer of rims you would have a responsibility to label your products if this proposal becomes an effective regulation. However, we noted in the preamble to that proposal (copy enclosed) that we will not require manufacturer codes until a separate manufacturer code system has been established.; I am also enclosing a copy of the most recent proposal on manufacture codes.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1062OpenMr. John W. Kourik, Chief Engineer, Automotive Products, Wagner Electric Corp., Wagner Division, 11444 Lackland Road, St. Louis, Missouri 63141; Mr. John W. Kourik Chief Engineer Automotive Products Wagner Electric Corp. Wagner Division 11444 Lackland Road St. Louis Missouri 63141; Dear Mr. Kourik: This is in reply to your letter of February 16, 1973, requesting a interpretation of paragraph S5.4.1 of Federal Motor Vehicle Safety Standard No. 105a.; Answers to your questions are as follows:>>>1. The reservoi configuration in your Sketch No. 1 would meet the requirements of S5.4.1 for compartmentalized reservoirs. We have provided a similar interpretation to General Motors Corporation on this point, which is enclosed for your reference.; 2. Since the configuration of your Sketch No. 1 conforms to S5.4.1, single fluid lever sensing device is acceptable; 3. The configuration shown in your Sketch No. 2 would not comply wit volumetric requirements of S5.4.2 since your 'reserve' fluid volume plus 'protected' fluid compartment 'A' and 'B' volumes would not be equal to the total volume required by S5.4.2. S5.4.2 requires a volume for *each* reservoir equal to the fluid displacement resulting when all wheel cylinders or caliper pistons serviced by the reservoir move from a new lining, fully retracted position (etc) to a fully worn, fully applied position. Thus, if this final condition existed on both subsystems, one subsystem would not have the specified fluid available.; 4. The configuration depicted in your Sketch No. 3 would meet th requirements of S3.4.1 and S5.4.2 as well as S5.3.1(b) assuming the indicator lamp would be activated at or above the 25 percent level of fluid volume.; 5. The configuration shown in your Sketch No. 4 would meet th requirements of S5.4.1 and S5.4.2 as well as the requirements of S5.3.1(b) with the same assumption that the lamp would be activated at or above the 25 percent fluid volume level<<<; Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam5021OpenMr. Hal Balzak 28025 N. Sarabande Lane #1216 Canyon Country, CA 91351; Mr. Hal Balzak 28025 N. Sarabande Lane #1216 Canyon Country CA 91351; "Dear Mr. Balzak: This responds to your letter concerning Federal Moto Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact. I apologize for the delay in our response. You stated that you have received a copy of this standard and would like clarification of two issues. Your questions are addressed below. Your first question asked whether Standard No. 201 applied to passenger cars manufactured between January 1, 1968 and September 1, 1981. The answer to this question is yes, the standard applied to all passenger cars manufactured on or after January 1, 1968. Your second question asked whether Standard No. 201 applies to instrument panels manufactured for replacement of damaged units. The answer to this question is that, by its own terms, Standard No. 201 applies only to new motor vehicles. This means that the standard applies to original equipment components, including instrument panels, but not to replacements for those components. However, you should be aware of an important provision in Federal law. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that '(n)o manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or 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. . . .' This provision applies to both new and used vehicles. You specifically asked about the replacement of damaged instrument panels. I note that the Safety Act does not require a manufacturer, distributor, dealer or repair business to return a vehicle to compliance with a standard if a device or element of design has been 'rendered inoperative' by another agent, such as a crash. The prohibition of section 108(a)(2)(A) does not apply to individual owners who alter their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to tamper with the safety equipment installed on their vehicles. I hope this information is helpful. If you have further questions, please feel free to contact Edward Glancy of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0223OpenMr. Folke Kohler, Scandex Sakerhetsglas Aktiebolag, Box 218, S-261 22 Landskrona 1, Sweden; Mr. Folke Kohler Scandex Sakerhetsglas Aktiebolag Box 218 S-261 22 Landskrona 1 Sweden; Dear Mr. Kohler: This is in reply to your letter of March 3, 1970 in which you applie to the National Highway Safety Bureau for registration of glazing materials your company intends exporting to the United States for use in motor vehicles.; It is important that you understand that the National Highway Safet Bureau does not approve or certify that glazing materials meet the requirements of the Federal Motor Vehicle Safety Standard applicable thereto (No. 205, copy enclosed). Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1403 (a copy of the Act is also enclosed) requires the manufacturer to certify that his product complies with all applicable U.S. standards. You may certify that your company's glazing materials meet the standard by following the requirements of Section 114 of the Act or by following the certification alternative provided for in S3.4 of Standard No. 205. If you choose to use the alternative method provided for in the Standard you must apply for an approved manufacturer's code mark.; Although the Bureau does not certify glazing material as complying, i does conduct a compliance program to determine if the manufacturer's product does, in fact, comply with the applicable standards. Persons selling non-complying items of motor vehicle equipment are subject to a civil penalty of up to $1,000 per violation (see Sections 108 and 109 of the Act).; In addition, your attention is directed to Section 110(e) of the Ac which requires persons exporting motor vehicles and motor vehicle equipment into the United States to designate an agent for service of process. See Subpart D-Service of Process: Agents, of the General Procedural Rules (copy enclosed).; Sincerely, Lawrence R. Schneider, Chief, Regulations Division |
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ID: aiam5471OpenMs. Melinda Dresser Manager Contracts/Transportation Carlin Manufacturing, Inc. 3714 N. Valentine Fresno, CA 93722; Ms. Melinda Dresser Manager Contracts/Transportation Carlin Manufacturing Inc. 3714 N. Valentine Fresno CA 93722; "Dear Ms. Dresser: We have received your letter of November 28, 1994 asking whether the exterior lighting of six Oscar Mayer 'Wienermobiles' that your company is manufacturing conforms to applicable Federal motor vehicle safety standards. You have enclosed diagrams showing the location of the exterior lighting devices. Under 49 U.S.C. Chapter 301 - Motor Vehicle Safety, the determination of whether a vehicle conforms with all applicable Federal motor vehicle safety standards is that of the manufacturer who, pursuant to 49 U.S.C. 30115, must certify compliance of the vehicle with those standards upon completion of manufacture. NHTSA has no authority to approve or disapprove specific vehicle designs. We do, however, provide interpretations of our standards to manufacturers upon request. The appropriate standard here is Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Your letter does not state whether Carlin has classified the Wienermobile as a 'passenger car' or as a 'truck'. We believe that the vehicle is a 'truck' within the meaning of 49 CFR 571.3(b) because it appears to be 'designed primarily for the transportation of property or special purpose equipment', rather than for the transportation of passengers, and that its overall width of 94 inches makes it more appropriate for the Wienermobile to meet wide vehicle lighting requirements. Therefore, the Wienermobile must be equipped with the lighting equipment specified in Table I of Standard No. 108, and located as specified in Table II, the requirements for trucks whose overall width is 80 inches or more. This means that they must be equipped with the front and rear clearance and identification lamps that Table I requires for wide trucks, these lamps do not appear on your drawings. In addition, all four-wheeled motor vehicles are required to have hazard warning/turn signal lamps and we don't see these lamps either on the drawings. With respect to front lighting equipment that is depicted, we note that supplementary lighting equipment such as fog lamps and the 'front marker light' are permissible under Standard No. 108 if the manufacturer determines that they do not impair the effectiveness of the lighting equipment required by Standard No. 108, in this instance, the headlamps. In the absence of a clearly erroneous determination, NHTSA will accept the manufacturer's judgment on impairment. Trucks that are subject to Table II need not be equipped with a center high-mounted stop lamp or parking lamps, if that is the purpose of the front marker lamp. We hope that these comments will be helpful. If you have any other questions, please contact Mr. Taylor Vinson of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam0389OpenMr. K. Nakajima, General Manager, Toyota Motor Company, Ltd., Lyndhurst Office Park, 1099 Wall Street, West, Lyndhurst, New Jersey 07071; Mr. K. Nakajima General Manager Toyota Motor Company Ltd. Lyndhurst Office Park 1099 Wall Street West Lyndhurst New Jersey 07071; Dear Mr. Nakajima: This is in reply to your letter of June 9, 1971, regarding th definition of 'curb weight' in Motor Vehicle Safety Standard No. 110.; The air conditioner and the additional weight optional engine are to b included in 'curb weight' if the motor vehicle is equipped with these items. If the motor vehicle is not so equipped, then the items are not to be included in the 'curb weight' or the 'accessory weight'.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0673OpenMr. Philip P. Friedlander, Jr., Director of Communications, National Tire Dealers & Retreaders Association, Inc., 1343 l Street, N.W., Washington, D.C. 20005; Mr. Philip P. Friedlander Jr. Director of Communications National Tire Dealers & Retreaders Association Inc. 1343 l Street N.W. Washington D.C. 20005; Dear Mr. Friedlander: This is in response to your letter of March 28, 1972, asking whethe passenger car tires that have been reclassified, under Standard 109, as 'Unsafe for Highway Use' because they do not conform to the standard may be sold with, or for use on, a vehicle other than a passenger car. For the reasons given below, our answer to your question is no.; Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Ac states that:; >>>'*no person shall* manufacture for sale, *sell*, offer for sale, o introduce or deliver for introduction in interstate commerce, or import into the United States, *any* motor vehicle or *item of motor vehicle equipment* manufactured on or after the date *any applicable Federal motor vehicle safety standard* takes effect under this title *unless it is in conformity* with such standard except as provided in subsection (b) of this section.' (Emphasis supplied.)<<<; We presume that the argument for allowing use of a nonconformin passenger car tire on another type of vehicle (in your case a boat trailer) would be that by so using the tire, it ceases to be a 'tire for use on passenger cars' in the words of the application section of Standard 109, that the standard does not apply to it, and since there is currently no standard for tires on vehicles other than passenger cars, anything may be used on such vehicles.; We would reject this argument. We interpret Standard 109 as applying t tires that are designed and produced for use on passenger cars, and in this view a tire so designed and produced does not become something else because it is ultimately used for a different purpose. the effect of section 108, then, is not merely to prohibit nonconforming passenger car tires from being sold on passenger cars, but to prohibit them from being sold at all, as 'motor vehicle equipment.'; As an entirely separate matter, any reclassified tire sold as moto vehicle equipment would be presumed to contain a safety-related defect within the meaning of sections 111 and 113 of the Act.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1961OpenMr. R. J. Reed, V. P., Steer Safe, Inc., Box 149, Deming, NM 88030; Mr. R. J. Reed V. P. Steer Safe Inc. Box 149 Deming NM 88030; Dear Mr. Reed: This is in response to your letter of May 22, 1975, in which yo request a ruling that a person who installs a 'Steer Safe' steering stabilizer is not required to recertify the vehicle in which it is installed. You refer to a letter to Safety Products, Inc., dated August 24, 1972, in which it was stated that we would accept a determination that the installation of a steering stabilizer manufactured by Safety Products did not constitute remanufacturing, and that a person who installed such a device need not recertify the vehicle on which it is installed.; Since that letter, the National Highway Traffic Safety Administratio has issued regulations covering the alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. These regulations (49 CFR SS 567.7 and 567.8, copy enclosed) supersede opinions such as the one we provided Safety Products, which was based solely on the more general provisions of the National Traffic and Motor Vehicle Safety Act and the certification regulations in effect at that time. Under the new regulations, which were effective February 1, 1974, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than 'readily attachable' components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.; From the description of your device, with the enclosed literature, i appears to require no special expertise or tools to install, and is thus probably readily-attachable. It would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that it is 'readily attachable', and that an altere label is not required when a 'Steer Safe' steering stabilizer is installed.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam4149OpenRobert A. Hutton, Jr., Esq., Curtis, Bamburg & Crossen, Attorneys at Law, 230 South Bemiston, St. Louis, MO 63105; Robert A. Hutton Jr. Esq. Curtis Bamburg & Crossen Attorneys at Law 230 South Bemiston St. Louis MO 63105; Dear Mr. Hutton: This responds to your letter asking about inertial-locking seatbelt and seatbacks. We apologize for the delay in our response. You stated that your firm represents a woman who was injured in a 1982 Ford Escort GT. According to your letter, while braking to exit a highway, the driver's seatback was thrown forward, not locking, causing your client to lose control of the car and crash into a guardrail. You asked for information about inertial-lock mechanisms on automobiles, particularly for seat backs and belts in that car, and references to government safety standards. You specifically asked whether there was a standard for the maximum distance the seatback can travel before locking under load.; The National Highway Traffic Safety Administration (NHTSA) issue Federal motor vehicle safety standards, pursuant to the National Traffic and Motor Vehicle Safety Act. Two of our standards are relevant to inertial-lock mechanisms.; Federal Motor Vehicle Safety Standard No. 209, *Seat Belt Assemblies* specifies requirements for inertial-locking safety belts. Section S4.3(j) specifies the following:; >>>(j) *Emergency-locking retractor*. An emergency-locking retractor o a Type 1 or Type 2 seat belt assembly, when tested in accordance with the procedures specified in paragraph S5.2(j)--; (1) Shall lock before the webbing extends 1 inch when the retractor i subject to an acceleration of 0.7 g. . . .<<<; Thus, for safety belts, there is a specific requirement for the maximu distance the webbing may extend before locking under load.; Federal Motor Vehicle Safety Standard No. 207, *Seating Systems* (4 CFR S571.207), specifies requirements for restraining devices for hinged or folding seats and seat backs. See section S4.3. The standard requires that such seats be equipped with self-locking restraining devices, and specifies both static force and acceleration performance requirements which the restraining devices must meet once engaged. However, the standard does not specify either the load at which an inertial-locking seatback must lock or the maximum distance the seatback can travel before locking under load.; In response to your request for information that relates to th particular car involved in your client's accident, we have enclosed a computer printout listing relevant vehicle owner reports which allege problems similar to that identified by your letter.; I hope this information is helpful. There is no fee for th information.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3376OpenMr. James E. Skeen, President, Cragar Industries, Inc., 19007 South Reyes Avenue, Compton, California 90221; Mr. James E. Skeen President Cragar Industries Inc. 19007 South Reyes Avenue Compton California 90221; Dear Mr. Skeen: The Office of Vehicle Safety compliance has asked me to respond to you October 14, 1980, letter asking for a clarification of the basis upon which it was suggested that your wheel spinners may not be in compliance with Safety Standard No. 211, *Wheel Nuts, Wheel Discs, and Hub Caps*.; Standard No. 211 prohibits the manufacture or assembly of wheel nuts wheel disc and hub caps that incorporate winged projections. This safety standard has been in effect since 1968 and was implemented at that time, because it was determined that these devices presented potential safety hazard to pedestrians and to cyclists. Prior to 1968, manufacturers were constructing devices with winged projections that extended quite far from the wheel. To prevent this from arising again, the agency issued the standard prohibiting the manufacture of *all* such devices.; From reviewing the wheel spinner that you are producing, our technica staff has concluded that it incorporates a winged projection of the type prohibited by the standard. Accordingly, our staff notified you of your possible noncompliance. I trust that this clarifies the basis of our investigation. Any questions that you have with respect to this possible noncompliance would be referred to our office of Vehicle Safety Compliance.; Pursuant to your request, the National Highway Traffic Safet Administration will provide confidential treatment, subject to the limitation of 15 U.S.C. 1418(a)(2)(B), for the total production figure in paragraph 4 of your October 14 letter; 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.