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: aiam0039OpenMr. C. F. Talbot, Vice President and Assistant Secretary, McIntosh, Inc., 13881 Himira Avenue, Detroit, MI 48227; Mr. C. F. Talbot Vice President and Assistant Secretary McIntosh Inc. 13881 Himira Avenue Detroit MI 48227; Dear Mr. Talbot: Thank you for your letter of November 3, 1967, to Mr. Lowell K Bridwell, requesting clarification on certain aspects of the Motor Vehicle Safety Act.; In answer to your specific questions, please be advised that th supplier of a component of a motor vehicle is a manufacturer within the meaning of the Motor Vehicle Safety Act. However, he is not obligated to certify that the item of motor vehicle equipment he manufacturers complies with the standard unless he is supplying that item to a distributor or dealer, and then only if there is an applicable Federal Standard.; As regards identification of parts, there is no specific requiremen under the Act.; With reference to the entire matter of keeping of records under Sectio 112(c), this Bureau has under study an appropriate program based on evaluation of certification experience during the next few months that will load to specific regulations. It is contemplated that these regulations will have an effective date of January 1, 1969.; If there is any other information you would like, I hope you will le me know.; Sincerely, William Haddon, Jr., M.D., Director |
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ID: aiam2004OpenMr. John R. Hudson, 1303 Merry Lane, La Marque, TX 77568; Mr. John R. Hudson 1303 Merry Lane La Marque TX 77568; Dear Mr. Hudson: This is in reference to your letter of July 28, 1975, to Corbusie Chevrolet Company of Bryan, Texas concerning that dealer's failure to provide you with an odometer mileage disclosure statement.; As you know, the Motor Vehicle Information and Cost Savings Act (Pub L. 92-513) requires that a written disclosure of a vehicle's correct mileage be provided by the seller to the purchaser at the time ownership of a vehicle is transferred. If the correct mileage is unknown, the Act requires a statement to that effect to be furnished in written form to the buyer. This requirement is not limited to transactions where a dealer is the purchaser. It applies to all type of vehicle transfers, including the one in which you were involved.; In addition, the Act prohibits the alteration of the mileage indicate on an odometer. Violation of this provision and/or the disclosure statement provision may subject the violator to civil liability where his actions were intended to defraud the purchaser. The Act makes available to the buyer a remedy in the amount of $1,500 or treble damages whichever is greater. To obtain this remedy, section 409 of the Act provides that a private civil action be instituted in State or Federal court.; We have mailed a letter to Corbusier Chevrolet informing them of th relevant odometer law requirements (copy enclosed). If they fail to disclose the necessary mileage information, please let us know so that we may take additional steps to enforce their compliance with the law.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4979OpenMr. Neil Friedkin Attorney at Law 325 Exterior Street Bronx, NY 10451; Mr. Neil Friedkin Attorney at Law 325 Exterior Street Bronx NY 10451; "Dear Mr. Friedkin: This responds to your letter asking about th certification of a converted vehicle. You explained that your client leased a 1986 Mercedes and that as part of the lease agreement, Coachbuilders Ltd converted the vehicle from a hardtop to a convertible. In a pending lawsuit, your client is alleging that Coachbuilders did not recertify the vehicle after conversion and that the conversion did not conform with the National Traffic and Motor Vehicle Safety Act ('Safety Act,' 15 U.S.C. 1381). You asked the agency to explain our regulations about conversion and recertification. I am pleased to have this opportunity to do so. The agency's certification regulation requires the manufacturer of a new vehicle to certify that the vehicle conforms to all applicable safety standards in effect on the date of manufacture (567.4 and 567.5). Persons that alter certified vehicles before the first purchase of the vehicle in good faith for purposes other than resale are required to allow the original certification label to remain in place and to add an additional label stating that the vehicle as altered continues to conform to all applicable standards (567.7). Once a vehicle is purchased for purposes other than resale, there is no requirement for an alterer to certify the vehicle's compliance with the standards. The Safety Act, in 114, requires manufacturers and distributors of motor vehicles to certify the vehicles' compliance, but does not extend this requirement to other persons. The Safety Act further provides, in 108(b)(1), that the requirement for a vehicle to comply with all applicable safety standards does not apply after the first purchase for purposes other than resale. In this case, we would consider the purchase by the leasing company to be the first purchase of the vehicle for purposes other than resale. If the modifications were made before that purchase, the modifier would have been required by 567.7 to certify that the altered vehicle continued to conform with the applicable safety standards. If, however, the modifications were made after the leasing company had purchased the vehicle, the modifier would not have been required to make any certification that the modified vehicle continued to conform to all applicable safety standards. If modifications were made after the leasing company purchased the vehicle, the only provision of Federal law that would apply would be section 108(a)(2)(A) of the Safety Act. That section provides in relevant part that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard. In general, this section prohibits any manufacturer, dealer, distributor, or repair shop from removing, disabling, or otherwise 'rendering inoperative' any of the safety systems or devices installed on the vehicle to comply with a safety standard. However, modifications that change a vehicle from one vehicle type to another (e.g., from a hard-top to a convertible) do not violate the 'render inoperative' prohibition, as long as the converted vehicle complies with those safety standards that would have applied if the vehicle had been originally manufactured as the new type. In the case of your client's 1986 Mercedes, there would be no violation of the 'render inoperative' prohibition if the car, as modified, complied with those standards that were applicable to 1986 convertible passenger cars. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0193OpenMr. David A. Phelps, Jr., Engineering Services, Blue Bird Body Company, Fort Valley, GA 31030; Mr. David A. Phelps Jr. Engineering Services Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Phelps: Thank you for your letter of December 9, 1969, providing additiona information on the school bus lighting system as described in your previous letter of November 14, 1969.; Paragraph S3.1.2 of Federal Motor Vehicle Safety Standard No. 10 specifies that, 'No additional lamp, reflective device, and associated equipment shall be installed if it impairs the effectiveness of the required equipment.' The system of front stop lamps as described in your letters, i.e., two non-flashing amber lamps of the same size as and located in line with the two red school bus signal lamps, and actuated by the foot brake only, would not appear to impair the effectiveness of the lighting equipment required by Standard No. 108. It should be noted, however, that, while incorporation of this system in school buses would not be precluded by Standard No. 108, the various States may interpose restrictions as to such system. I would suggest, therefore, that you review the applicable State regulations before initiating installation of the system.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam0469OpenMr. Fredrick A. Stewart, Vice President, Safety and Quality Assurance, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. Fredrick A. Stewart Vice President Safety and Quality Assurance American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Stewart: This is in response to your recent telephone inquiry as to whether th recent amendment of Standard 215, Exterior Protection, requires that vehicles meet the photometric requirements of Standard 108 after being subjected to the Standard 215 impacts.; S5.3.1 of Standard 215 reads: >>>'Each lamp or reflective device, except license plate lamps, shal be free of cracks and shall comply with the applicable requirements of Motor Vehicle Safety Standard No. 108.'<<<; S4.3.1.1 of Standard 108 reads in relevant part: >>>'Each lamp and reflective device shall be located so that it meet the visibility requirements specified in any applicable SAE Standard or Recommended Practice. *In addition, no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified* in any applicable SAE Standard or Recommended Practice.'<<< (Emphasis supplied.); Thus, although the actual photometric tests may be considered 'benc tests', that is, tests whose procedures include removing the devices from the vehicle, the above provision of Standard 108 requires that the configuration of the vehicle external to the devices not prevent them from meeting the photometric requirements. The test procedures themselves require the devices to be placed in their actual orientation on the vehicle. Therefore, the provision in Standard 215 that the lamps and reflective devices shall meet all the requirements of Standard 108 after the impacts includes the photometric requirements.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs; |
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ID: aiam5391OpenMr. John A. Griffiths 510G Bellfield Drive Newport News, VA 23602; Mr. John A. Griffiths 510G Bellfield Drive Newport News VA 23602; Dear Mr. Griffiths: This responds to your request for an interpretatio whether the Federal Motor Vehicle Safety Standards specify for a manual transmission vehicle, a 'neutral safety switch,' or other means to prevent starting of the vehicle unless the clutch is fully depressed. The answer is no. Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect, specifies starter interlocks for automatic transmission vehicles, but not for manual transmission vehicles. (See S3.1.3.) None of the other safety standards specify that motor vehicles include a device of the type you describe, or specify means to prevent starting of a manual transmission vehicle unless the clutch is depressed. I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2454OpenMr. Rex R. Redhair, Shughart, Thomson and Kilroy, 922 Walnut Street, P. O. Box 13007, (sic); Mr. Rex R. Redhair Shughart Thomson and Kilroy 922 Walnut Street P. O. Box 13007 (sic); Dear Mr. Redhair: Your October 20, 1976, letter to the U.S. Department of Transportation Federal Highway Administration, has been referred to this office for reply.; You request data concerning the 10.00-02 'Inland Deep Drive 300,' tha was manufactured by the Mansfield Tire and Rubber Company, Mansfield, OH. Tire Identification Number WLZJAVN 503.; We have enclosed all the Federal Motor Vehicle Safety Standards for: >>>o New Pneumatic Tires, Passenger Cars, Federal Motor Vehicle Safet Standard No. 109; o New Pneumatic Tires for Vehicles Other Than Passenger Cars, Federa Motor Vehicle Safety Standard No. 119; o Part 574 - Tire Identification and Recordkeeping o Tire Code Numbers Assigned New Tire Manufacturers. o Tire Size Codes<<< The tire identification number stated in your letter can be explaine by the use of the above data.; >>>'WL' - is the plant code for the Mansfield, Ohio plant. 'ZJ' - is the tire size code for the 10.00-20 tire size designation. 'AVN' - is an internal code for Mansfield. '503' - means the tire was cured the 50th week of 1973.<<< You also request design and construction information. We do not hav this type of information because it is proprietary. Also enclosed are copies of tire 'Care and Service of Bias and Radial Ply Truck Tires.'; We hope the above has been of some help to you. Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs; |
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ID: aiam4996OpenMs. Eileen Mathews Industry Manager, Hose and Tubing General Electric Company 2 Summit Park Dr. Suite 410 Independence, OH 44131; Ms. Eileen Mathews Industry Manager Hose and Tubing General Electric Company 2 Summit Park Dr. Suite 410 Independence OH 44131; "Dear Ms. Mathews: This concerns your letter to the Federal Highwa Administration (FHWA) asking about FHWA's regulation 393.45 (49 CFR 393.45) and NHTSA's Federal Motor Vehicle Safety Standard No. 106, Brake Hoses. FHWA provided us a copy of its March 6, 1992 response on regulation 393.45. This letter answers your question about Standard 106. You ask about S7.3.6, 7.3.10 and 7.3.11 of the standard. Those sections set forth performance requirements for limiting the amount a hose may change in length under specified conditions (S7.3.6), for the tensile strength of a hose assembly (S7.3.10), and for the tensile strength of an assembly after immersion in water (S7.3.11). Each of these sections excludes certain items from the requirement. Your question relates to those exclusions. S7.3.6 excludes coiled nylon tubes for use in assemblies that meet the FHWA requirements of 393.45. S7.3.10 excludes coiled nylon tube assemblies that meet 393.45. S7.3.11 excludes coiled tube assemblies that meet 393.45. You ask whether those exclusions in S7.3.6, 7.3.10 and 7.3.11 'require compliance with 393.45.' The answer is no. Standard 106 does not require tubing to meet 393.45. Instead, compliance with 393.45 is a condition for excluding the item from S7.3.6, 7.3.10 or 7.3.11. The other condition, relevant for S7.3.6 and 7.3.10, is that the brake hose be coiled nylon tubing. According to your letter, the brake hose (tubing) of your concern would be made from a material other than nylon. Since the second condition would not be satisfied, such hose would not qualify for the S7.3.6 exception, and an assembly made from such hose would not qualify for the 7.3.10 exception, regardless of whether the hose meets regulation 393.45. Thus, S7.3.6 and 7.3.10 would apply to hose and assemblies made from your product, without exception. S7.3.11 does not specify that the coiled tubing must be nylon to qualify for the exception. While NHTSA intended to specify nylon (see, preamble to rule adopting the exclusion, 39 FR 28436, August 7, 1974), as adopted, S7.3.11 excludes a 'coiled tube assembly' that meets regulation 393.45 from its requirements. I hope this information is helpful. If you have any further questions, please contact Deirdre Fujita of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam2141OpenInterps. file, Parts 575.104(d)(1)(ii) and 575.6; Interps. file Parts 575.104(d)(1)(ii) and 575.6; Office visit by Pat Raher, Hogan and Hartson I received an office visit on December 8, 1975, from Mr. Raher of Hoga and Hartson (representing Mercedes-Benz). He showed me a sample information sheet of the type that Mercedes proposes to use to indicate the quality grades of tires with which its vehicles are equipped. We discussed the vehicle manufacturer's information requirement of the Uniform Tire Quality Grading Standards, and I indicated that a formal interpretation would follow our receipt of his letter, which is en route.; Mark I. Schwimmer, Attorney- Advisor |
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ID: aiam0486OpenDavid J. Humphreys, Esq., Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; David J. Humphreys Esq. Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: As we have advised Ed Bernett of your office from time to time durin the fall, a response to your letter on the treatment of removable foam seat cushions under Standard No. 207 has been under review for some time.; Standard No. 207 is essentially a test of the strength of the sea structure. As such it does not prohibit the use of removable seat cushions of the type described in your letter.; We consider it to be the intent of the standard, however, that when th momentum of a cushion is transferred in any way to the seat structure during the course of an acceleration in a given direction, the weight of the cushion must be added to the weight of the seat structure in calculating the force to be applied in that direction under S4.2 and S4.3.2.; Please advise us if you have further questions. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.