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: aiam1782OpenMr. J.R. Farron,Bendix Corp.,P.O. Box 4001,South Bend, Indiana 46634; Mr. J.R. Farron Bendix Corp. P.O. Box 4001 South Bend Indiana 46634; Dear Mr. Farron:#Please forgive the delay in responding to your lette of November 8, 1974, concerning Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*.#In our letter of July 8, 1974, We explained that a neoprene connector, which you now designate as the Hydrovac Vacuum Connector, is included under the definition of 'brake hose,' set out in the standard, because it is flexible. Your letter of November 8, 1974, suggested that, due to the nature of the connector's installation, it is not subject to the usual hazards associated with the flexibility of brake hose. The connector is nevertheless a 'flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes,' and so cannot be excluded from the definition of 'brake hose' without further rulemaking activity. We are considering the possibility of an amendment of the definition to exclude this type of connector from the coverage of Standard No. 106-74. any such proposal would be published in the Federal Register.#Yours truly,James C. Schultz,Chief Counsel; |
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ID: aiam3245OpenMr. John B. Galotti, Service Manager, Sholz Oldsmobile, 35 West Post Road, White Plains, NY 10606; Mr. John B. Galotti Service Manager Sholz Oldsmobile 35 West Post Road White Plains NY 10606; Dear Mr. Galotti: This responds to your recent letter requesting information concernin the legal requirements applicable to the installation of fuel separators and auxiliary fuel tanks in motor vehicles. I am enclosing a copy of a letter the agency issued last year which discusses the Federal requirements and implications that would be involved with such activities. That discussion should answer all of your questions. If, however, you require further information, please contact Hugh Oates of my office at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1278OpenMr. Donald Gary Hayes, Robertson Tank Lines Inc., P. O. Box 1505, Houston, TX 77001; Mr. Donald Gary Hayes Robertson Tank Lines Inc. P. O. Box 1505 Houston TX 77001; Dear Mr. Hayes: This is in reply to your letter of August 30, 1973, requesting a DO code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.; Any tires retreaded by and solely for use by Robertson Tank Lines ar exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to any Federal motor vehicle safety standard, you are also not required to place a 'DOT' symbol on them. If you retread passenger car tires, however, you are required to place a 'DOT' symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4580OpenMs. Juanita P. Davison 1516 E. Hernandez Street Pensacola, FL 32503; Ms. Juanita P. Davison 1516 E. Hernandez Street Pensacola FL 32503; "Dear Ms. Davison: Thank you for your letter describing you impressions of the automatic safety belts on your 1987 Toyota. I apologize for the delay in this reply. You said that this motorized automatic belt system 'takes away the roominess of the front,' because it is in the way when getting in the car with a handbag or package and that it is cumbersome to get out of the belt system. I am pleased to have this opportunity to explain our law and regulations to you. Before I respond to your specific concerns, I would like to give you some background information on our requirement for automatic occupant protection systems in new cars. Pursuant to the National Traffic and Motor Vehicle Safety Act in 1966 (the Safety Act, 15 U.S.C. 1381 et seq.), a Federal safety standard on occupant crash protection was issued in 1967 requiring the installation of manual safety belts in all new passenger vehicles. Although these manual safety belts showed their effectiveness as safety devices, only a relatively small number of motorists used their manual belts. As recently as 1984, only 12.5 percent of front seat occupants wore their manual belts. Because so few people used their manual safety belts, the Department issued the first requirement for automatic restraints in passenger cars in 1970, and it was scheduled to take effect in 1973. That implementation date was delayed for a variety of reasons. On June 24, 1983, the Supreme Court of the United States found our decision to repeal the requirement for automatic restraints was 'arbitrary and capricious,' and ordered us to reconsider the decision (Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29). Against this background, former Secretary of Transportation Dole issued a final rule amending the Federal safety standard on occupant crash protection on July 17, 1984. That decision, which promotes both automatic restraints and State safety belt use laws, provides a comprehensive approach designed to save as many lives as possible as quickly as possible. We believe that effectively enforced State laws requiring the proper use of the manual safety belts that are in most cars on the road today offer our best opportunity to save lives at virtually no cost to the consumer. The decision also reflects our belief in the value of automatic occupant protection systems, such as air bags and automatic belts, by requiring all new cars to have automatic protection starting with the 1990 model year. The decision required further that automatic protection be phased in during the three years preceding that model year. Each manufacturer was required to equip 10 percent of its model year 1987 cars with automatic restraints. That percentage rose to 25 percent for model year 1988, and 40 percent for model year 1989. However, if the Secretary determines not later than April 1, l989, that State belt use laws have been enacted that meet certain criteria and that are applicable to two-thirds of the U.S. population, then the automatic restraint requirements will be rescinded. You had three specific concerns with your automatic belt system. First, you asked if the motorized automatic belt system in your car was installed to meet some safety regulation. The answer is yes. As explained above, our Standard No. 208, Occupant Crash Protection requires all 1990 model year cars to be equipped with automatic occupant crash protection. Please note that this requirement permits manufacturers to install any automatic occupant protection technology that meets the occupant protection requirements set forth in Standard No. 208. Thus, manufacturers may choose to install motorized, or nonmotorized, automatic safety belts, air bags, other technologies such as 'passive interiors,' or any combination of these technologies. Your second question was whether you can legally disengage the motorized mechanism on the automatic belts in your car. Section 108 of the Safety Act provides that: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard ...' In this case, the automatic belts in your car are a 'device or element of design installed in a motor vehicle in compliance with a Federal motor vehicle safety standard.' Disengaging the motorized mechanism would render the automatic belts inoperative. Therefore, Federal law prohibits Toyota, any other manufacturer, and any distributor, dealer, or repair shop from disengaging the motorized mechanism on your automatic belts. Please note that this Federal prohibition does not prevent you, yourself, from disengaging the motorized mechanism on your automatic belts. However, each of the individual States has the authority to regulate the modifications that may be made to vehicles by their owners and to establish requirements for vehicles to be registered or operated in that State. You may wish to contact the State of Florida to learn if they have exercised their authority to prohibit the disabling of automatic belts. Even if neither Federal nor State law prohibits you from disabling your automatic belt, we encourage vehicle owners not to tamper with the occupant crash protection systems installed in their vehicles. If you were to improperly disengage the motorized mechanism, you would put yourself, other occupants of your car and subsequent owners and users of the car at substantially greater risk of injury in a crash. Third and finally, you said that you have been told it is not safe to wear your automatic belts without also fastening the manual lap belt, because of the possibility of choking. The manual lap belt was voluntarily provided by the manufacturer of your car to provide an even higher level of crash protection for those occupants who choose to use the lap belt. However, the manufacturer of your car has certified that, in a 30 mph frontal crash into a concrete barrier, a test dummy restrained only by the automatic belt in your car would not experience injury-producing forces in excess of the levels specified in Standard No. 208. Hence, the suggestion that the automatic belt by itself is somehow unsafe is simply not true. I would like to thank you for taking the time to express your views on this subject. We welcome the interest of all concerned citizens on this important question and appreciate this opportunity to advise you of our efforts to improve occupant crash protection for all Americans. Sincerely, Erika Z. Jones Chief Counsel "; |
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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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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.