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 |
|---|---|
ID: aiam1256OpenSekurit-Glas Union GmbH, 5 Koln 1, Postfach 101608; Sekurit-Glas Union GmbH 5 Koln 1 Postfach 101608; Dear Sir: This is in reply to your letter of July 19, 1973, requestin information regarding the marking requirements in FMVSS No. 205 for automobile safety glass.; With respect to your request for a copy of the marking requirements they may be found in paragraph S6. of the enclosed copy of the standard, and in section 6 of American National Standard Z26.1 - 1966. The latter standard can be obtained by writing to the American National Standards Institute, 1430 Broadway, New York, New York 10018.; Information on various State requirements should be obtained from Mr Armond Cardarelli, American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.; You ask whether marking requirements can be met using a specific forma you include in your letter, and refer to 'Approval' and 'Supplemental' markings. It is not clear to us to what you refer, as we prescribe neither 'approval' nor 'supplemental' markings in the standard, and perhaps we will be better able to answer any questions you may have after you have had an opportunity to review the requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam4054OpenMr. Robert R. Gregg, Metzeler Motorcycle Tire, Agent Gregg, Inc., 144 Railroad Avenue, Suite 215, Edmonds, WA 98020; Mr. Robert R. Gregg Metzeler Motorcycle Tire Agent Gregg Inc. 144 Railroad Avenue Suite 215 Edmonds WA 98020; Dear Mr. Gregg: This responds to your letter to Steve Kratzke of my staff, seeking a interpretation of Standard No. 119, *New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR Part 571.119). Specifically, you asked if a motorcycle tire could have its maximum load capacity labeled on the sidewall as follows:; >>>At 60 MPH Max load _____lbs. at _____ psi cold.<<< Such labeling would violate Standard No. 119, as explained below. Section S6.5 of Standard No. 119 requires that certain information b labeled on the sidewall of all tires to which the standard applies. Section S6.5(d) requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires as follows:; >>>Max load _____lbs at _____psi cold.<<< No speed rating or restriction may be given in conjunction with th maximum load rating on the sidewall of the tire. That rating, as its name implies, is intended to alert consumers to the tire's *maximum* capabilities.; A manufacturer may label a speed restriction on its tires to aler consumers to the tire's maximum speed if that maximum is 55 miles per hour (mph) or less. Section S6.5(e) permits speed restrictions of 55 mph or less to be labeled on the sidewall of the tire as follows:; >>>Max Speed _____mph. << |
|
ID: aiam3791OpenMr. A. Chambord, Standards Attache, The French Embassy, Suite 715, 2000 L Street, N.W., Washington, DC 20036; Mr. A. Chambord Standards Attache The French Embassy Suite 715 2000 L Street N.W. Washington DC 20036; Dear Mr. Chambord: This responds to your recent letter to Mr. Steve Kratzke of my staff asking for information on requirements applicable to tire rims for vans. The three points set forth in your letter are correct statements of the requirements, but I will reiterate them to be certain that you provide accurate information.; (1) Vans are considered 'motor vehicles other than passenger cars' fo the purposes of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.120), and Standard No. 120 sets forth requirements which must be met by all new rims for use on vans. No other standard contains requirements applicable to those rims.; (2) Section S5.2(c) of Standard No. 120 requires the rim manufacture to permanently label each of its van rims with the letters 'DOT' as a certification that the rim satisfies the requirements of Standard No. 120. The manufacturer is expected to exercise due care before making such a certification. No outside inspector, either governmental or privately employed, need be consulted by a manufacturer before certifying the compliance of its rims.; (3) Rims entering into the United States are not individuall inspected, provided that the package containing the rims or the van on which the rims are installed bears an appropriate certification label. The only inspections at the port of entry are checks to see that a certification label is attached to the package of rims or the van.; Should you need any further information on this subject, please do no hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam2883OpenHonorable Bob Wilson, House of Representatives, Washington, DC 20515; Honorable Bob Wilson House of Representatives Washington DC 20515; Dear Mr. Wilson: This is in response to your letter of October 17, 1978, concerning telephone call from your constituent, Mr. Stefan Dagrowski, urging standardization of the type of release on seat belts.; Federal Motor Vehicle Safety Standard No. 208, *Occupant Cras Protection*, issued March 10, 1971 (36FR4600), required that effective January 1, 1972, passenger car seat belt assemblies would be released at a single point by push button action. To that extent, the type of release on seat belts is standardized since our standards are primarily performance oriented, and the manufacturers are free to design however they wish to meet those performance requirements.; I hope this information is sufficient to satisfy Mr. Dagrowski' interest in standardized seat belt releases.; Sincerely, Joan Claybrook |
|
ID: aiam1606OpenMr. Norman E. Salzman, General Manager, The Fairmount Press, P.O. Box 3, Bronx, NY 10453; Mr. Norman E. Salzman General Manager The Fairmount Press P.O. Box 3 Bronx NY 10453; Dear Mr. Salzman: This is in response to your letter of August 19, 1974, inquiring as t the compliance of your MVF odometer disclosure form with the Federal odometer requirements.; The MVF form enclosed in your letter fails to comply with ou regulation in several respects. The statement referring to the mileage indicated on the odometer at the time of the vehicle's transfer must be phrased to indicate that the disclosure document was executed at the time of the vehicle's transfer, not at some later time. In addition, the statement must be written in such a manner that it is clear it is to be completed by the transferor alone. To satisfy these criteria the statement should read; >>>'I, * *, state that the odometer mileage indicated on the vehicl described above, at the time of transfer to * * is as follows:'<<<; Instructions are necessary on your form to ensure that the sectio specified for the disclosure of mileage is completed in a consistent manner by all persons. This can be accomplished by inserting the following statement above the lines provided for stating the vehicle's mileage:; >>>'(Complete line 1, and where applicable, complete line 2 and chec line 3.)'<<<; We urge you to reprint your disclosure forms to reflect the change suggested above as they are not currently in compliance with Federal odometer requirements.; Your interest is appreciated. Yours truly, Richard B. Dyson, Acting Chief Counsel |
|
ID: aiam2929OpenHonorable John M. Ashbrook, House of Representatives, Washington, DC 20515; Honorable John M. Ashbrook House of Representatives Washington DC 20515; Dear Mr. Ashbrook: This responds to your December 19, 1978, letter asking whether it i required that school buses be built transport a minimum of 9 passengers.; As you suggest in your letter, there is no requirement that schoo buses be built to transport a minimum of 9 passengers. The school bus safety regulations issued by the National Highway Traffic Safety Administration require the compliance of those vehicles used to transport more than 10 children to or from school and related events. Vehicles with smaller passenger capacities may also transport children to and from school and need not comply with the school bus safety standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
|
ID: aiam0914OpenMr. Robert H. Dougherty, Vice President & General Manager, Pride Products Co., Inc., 101 East Alameda Avenue, Burbank, CA 91502; Mr. Robert H. Dougherty Vice President & General Manager Pride Products Co. Inc. 101 East Alameda Avenue Burbank CA 91502; Dear Mr. Dougherty: This is in reply to your letter of October 23, 1972, requestin information on the use of sample testing for determining conformity to Motor Vehicle Safety Standard No. 213. You ask if there are sampling provisions to which manufacturers should currently be adhering.; There is no specified sampling provision for manufacturers to follow i testing their products for conformity to Standard No. 213. The National Traffic and Motor Vehicle Safety Act requires each item of motor vehicle equipment (for example, each child seat) to conform to the applicable safety standard in effect on its date of manufacture. It is the manufacturer's responsibility to decide what type of testing program is necessary to be reasonably certain that each item complies. The extent of his sampling should depend on such factors as the margin by which typical samples pass the performance requirements, the amount of variation in production that is present, and the degree to which substandard items can be detected by non-destructive techniques.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
|
ID: aiam4404OpenMr. M.B. Mathieson, Director of Engineering, Thomas Built Buses L.P., P.O. Box 2450, High Point, NC 27261; Mr. M.B. Mathieson Director of Engineering Thomas Built Buses L.P. P.O. Box 2450 High Point NC 27261; Dear Mr. Mathieson: This is in reply to your letter of April 27, 1987, asking for clarification of my letter of March 20.; In that letter I answered your question as to whether the results o frontal barrier impact tests that occurred at 30.4 mph with a vehicle that exceeded the test weight limits would constitute either a noncompliance with Standard No. 301 or a safety related defect. Because the test was not conducted in accordance with Standard No. 301's conditions I replied that this would not be a noncompliance, and further, that those results 'do not constitute a safety related defect regardless of the use of the vehicle.' This statement appears unclear to you.; By my earlier statement I intended to explain that we do not use safety standard's compliance test results (particulary if the test was not conducted in accordance with the prescribed procedures) as the sole basis for a determination of a safety-related defect in the same aspect of performance governed by that standard. For example, having determined through rulemaking that a particular level of vehicle performance is expected in a 30 mph crash test, it would be inappropriate to use the results from an otherwise identical crash test conducted at 35 mph to form the sole basis for a determination of a safety-related defect in the tested vehicles. To do so would constitute, in effect, rulemaking to raise the impact speed in the standard to 35 mph. We completely agree, however, with your statement that 'there can be safety- related defects that are not addressed by the standards.' We also agree that the manufacturer has the responsibility to address safety defects that become apparent to him through test data or otherwise.; With this background, we will turn to your question. You have now pose a hypothetical in which your tests indicate that a fully-loaded school bus may encounter a severe leakage exceeding 4.1 ounces of fuel per minute in a head-on impact of 30 m.p.h. This may be evidence that could lead you to believe that there would be a significant number of failures if a school bus, in its normal operation with full complement of students, encounters a head-on collision at what appears to be a reasonable operating speed. This combination of factors might appear to pose an unreasonable risk to safety and afford the basis for the determination that a safety related defect exists.; Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam0447OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Distributors Association, 602 Main Street, Cincinnati, OH, 45202; Mr. Thomas S. Pieratt Jr. Executive Secretary Distributors Association 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: In your letter of September 23, 1971, you asked whether Standard No 302, Flammability of Interior Materials, applied to materials in the passenger compartments of vehicles.; The answer is yes. The standard, as stated in S4.1, applies t 'components of vehicle occupant compartments' only.; Sincerely, Lawrence R. Schneider, Chief Counsel |
|
ID: aiam2180OpenMr. L. David Minsk, Research Physical Scientist, Department of the Army, U.S. Army Cold Regions, Research and Engineering Laboratory, Hanover, NH, 03755; Mr. L. David Minsk Research Physical Scientist Department of the Army U.S. Army Cold Regions Research and Engineering Laboratory Hanover NH 03755; Dear Mr. Minsk: This responds to your December 11, 1975, request for copies of th Federal laws relevant to the use of trucks as carriers for snowplows and spreader bodies.; The National Highway Traffic Safety Administration (NHTSA) primaril regulates the manufacture of motor vehicles and motor vehicle equipment pursuant to authority of the National Traffic and Motor Vehicle Safety Act of 1966. You requested copies of the Federal laws pertinent to the 'use' of a particular motor vehicle, but standards or laws regulating use are promulgated by the jurisdiction in which a motor vehicle is registered or driven.; It might be noted, however, that motor vehicle safety standards ar applicable to the installation of snowplows and spreader bodies on new trucks. For example, paragraph S4.3.1.1 of Motor Vehicle Safety Standard No. 108, *Lamps, reflective devices, and associated equipment* (49 CFR 571.108), specifies that if motor vehicle equipment, including snowplows, would otherwise prevent compliance with the Standard by any required lamp or reflective device, an auxiliary lamp or reflective device meeting the requirements of the Standard must be provided. Similarily (sic), when a spreader body is installed on a chassicab, the completed trucks must comply with all applicable Federal standards.; The truck dealer or other person who installs motor vehicle equipmen on a truck that is certified as being in compliance with motor vehicle safety standards, prior to first sale of the vehicle, is responsible for ensuring that the truck remains in conformity. Failure to do so would constitute a violation of section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act, and subject the responsible party to the civil penalty provisions and other sanctions of the Act.; When a truck has been sold and is in 'use', the Act prohibits manufacturer, distributor, dealer, or repair business from making alterations that render inoperative any devices or elements of design installed in compliance with the Fderal (sic) safety standards.; Please contact us if we can be of any further assistance. Yours truly, 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.