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: aiam1217OpenMr. Brian Gill, American Honda Motor Co., Inc., P. O. Box 50, 100 W. Alondra Blvd., Gardena, CA, 90247; Mr. Brian Gill American Honda Motor Co. Inc. P. O. Box 50 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill: This is in reply to your letter of July 6, 1973, regarding th applicability of Standard No. 302 to a label that Honda wants to place on the driver's side sun visor to inform occupants about the seat belt interlock system.; The applicability of the standard depends on whether the label i attached in such a way as to form a permanent part of the sun visor. You state that Honda's label is 'easily removable and obviously not part of the sun visor.' If the label meets these criteria, we would not consider it to be a part of the visor. It would therefore not be subject to Standard No. 302.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4015OpenMr. Roger C. Fairchild, TechLaw, Inc., 12030 Sunrise Valley Drive, Suite 200, Reston, VA 22093; Mr. Roger C. Fairchild TechLaw Inc. 12030 Sunrise Valley Drive Suite 200 Reston VA 22093; Dear Mr. Fairchild: This responds to your letter of June 13, 1985, to Stephen P. Wood o this office, concerning the importation and assembly of chassis-cab units by your client. You asked about the division of certification responsibilities between your client and the manufacturer of the chassis-cab units. In addition, you asked about the accuracy of a summary you have prepared of our safety standards. I hope the following discussion answers your questions.; According to the information provided in your letter and in subsequen telephone conversations, the chassis-cab units would be shipped from a British manufacturer to your client with the occupant compartment or cab, and other major parts, such as the engine and transmission, individually assembled. In addition, the British manufacturer would also affix the vehicle identification number (VIN). Your client would then assemble the vehicles by bolting the parts together with ordinary tools, and add a fifth wheel or hydraulic/dump assembly to the back of the completed vehicles. You said that the British manufacturer of these chassis-cab units has agreed to assume legal responsibility for all duties and liabilities imposed by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 *et seq*.).; Under the Vehicle Safety Act, certification of compliance of a moto vehicle must be by the manufacturer or importer of an incomplete or a completed vehicle. Based upon the facts given above, your client would be importing items of motor vehicle equipment and not motor vehicles, since the various parts have not been assembled to form an incomplete or complete motor vehicle. The British manufacturer should certify that each item of motor vehicle equipment which is covered by a Federal motor vehicle safety standard complies with such standard. Your client would be assembling the various parts and completing the vehicles by adding work-performing components. Therefore, your client would be responsible for certifying the completed vehicles and for assuming the duties and liabilities imposed by the Act. An information sheet briefly describing those duties is enclosed.; If the British manufacturer assembled the chassis-cab unit parts int an incomplete vehicle before exporting them, then the vehicle would be covered by the certification requirements of Part 568, *Vehicles Manufactured in Two or More Stages* (49 CFR Part 568). Section 568.7(a) provides that an incomplete vehicle manufacturer, in this case the British company, can assume responsibility for certifying the vehicle, as long as it accepts all of the legal responsibilities for manufacturers set forth in the Vehicle Safety Act. The incomplete vehicle manufacturer would then be responsible for affixing the certification plate required by Part 567.5(e).; You also ask for our approval of a summary of National Highway Traffi Safety Administration safety standards and regulations applicable to heavy duty trucks. As you correctly stated in your letter, the agency cannot pre- approve motor vehicles or items of motor vehicle equipment. Under section 114 of the Vehicle Safety Act (15 U.S.C. 1403), a manufacturer has the responsibility to certify that its vehicles comply with all applicable Federal motor vehicle safety standards. We have, however, reviewed your summary and find it to be a reasonable description of the major requirements of the various safety standards applicable to heavy trucks. As you recognize, a manufacturer cannot rely on a summary, but must base its certification on a vehicle's compliance with all of the requirements of the applicable safety standards.; I hope this information is helpful to you. If you have any furthe questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0955OpenMr. Gorou Utsunomiya,Branch Manager,Toyo Kogyo USA Rep. Ofc. Det.,23777 Greenfield Road, Suite 462,Southfield,Michigan 48075; Mr. Gorou Utsunomiya Branch Manager Toyo Kogyo USA Rep. Ofc. Det. 23777 Greenfield Road Suite 462 Southfield Michigan 48075; Dear Mr. Utsunomiya:#This is in reply to your letter of November 28 1972, asking for an interpretation of S5.2 of Safety Standard No. 105a.#The transmission you describe has a separate park position, and this position must be engaged before the ignition key can be removed. We confirm that a vehicle equipped in this manner may meet the parking brake system requirements if S5.2.2 rather than those of S5.2.1.#As for your second question, a vehicle with a manual transmission that must be placed in reverse gear before the ignition key can be removed would also meet the requirements of paragraph S5.2.2#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam2968OpenMr. James Tydings, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your February 28, 1979, letter asking about th remanufacturing of vehicles using old chassis and new bodies. In particular, you ask whether these vehicles must comply with the new safety standards.; The remanufacturing operation that you mention need not comply with th new safety standards. Such a remanufactured vehicle may need to comply with the safety standards in effect on the date of manufacture of the used chassis. Otherwise, there might be a rendering inoperative of the compliance of the vehicle with the safety standards. I am enclosing a copy of an interpretation that discusses the remanufacturing issue.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1647OpenMr. R. W. Schneider, Director, Contract Administration, AM General Corporation, 701 West Chippewa Avenue, South Bend, IN 46623; Mr. R. W. Schneider Director Contract Administration AM General Corporation 701 West Chippewa Avenue South Bend IN 46623; Dear Mr. Schneider: This is in reference to your defect notification campaign (NHTSA No 74-0168) concerning some 1/4-ton Model DJ-5C vehicles which may have insufficient windshield glass retention.; The letter which you have sent to the owners of the subject vehicle does not contain the precise language which is required by Part 577 (49 CFR), the Defect Notification regulation. Specifically, the second sentence of your letter incorrectly describes the defect as existing in 'the retention of the front windshield on the 1/4-ton Model DJ-5C 'Jeep' Dispatcher. . . .' Part 577.4(b) requires that the defect be described only as existing in the vehicle. The reference to motor vehicle equipment applies only to equipment campaigns where vehicles are not involved. The letter also fails to adequately evaluate the risk to traffic safety as required by Part 577.4(d).; Although mailing of a revised notification letter will not be required it is expected that all future notification letters conform completely with the regulations.; A copy of Part 577 is enclosed. If you desire further information please contact Messrs. W. Reinhart or James Murray of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam3380OpenMr. Eric C. Oppenheim, Esq., Corporate Attorney, Kux Manufacturing Company, 12675 Burt Road, Detroit, MI =48223; Mr. Eric C. Oppenheim Esq. Corporate Attorney Kux Manufacturing Company 12675 Burt Road Detroit MI =48223; Dear Mr. Oppenheim: This is in reply to your letter of November 23, 1980 asking whether an Federal regulation 'prohibits the use of reflective red markings on the front of vehicles.'; The Federal Motor Carrier Safety Regulation administered by the Federa Highway Administration of the Department of Transportation impliedly prohibit the use of red reflectors on the front of vehicles subject to its jurisdiction by requiring that all reflectors, other than those at the rear, be amber in color (49 CFR 393.26(d)). The common contract, private or exempt carriers covered by this requirement are found in 49 U.S.C. 303.; The Federal motor vehicle safety standard on vehicle lighting (49 CF 571.108) applicable to the manufacture of all motor vehicles contains a general prohibition (paragraph S4.1.3) against installation of reflective devices that impair the effectiveness of required lighting equipment. Because of the generally accepted lighting coding of amber to the front and red to the rear, we would view installation of red reflective material on the front of a vehicle as prohibited by S4.1.3.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4445OpenMr. Billy S. Peterson President Automotive Safety Testing, Inc. Product Liability-Testing-Certification at TRC of Ohio East Liberty, OH 43319; Mr. Billy S. Peterson President Automotive Safety Testing Inc. Product Liability-Testing-Certification at TRC of Ohio East Liberty OH 43319; Dear Mr. Peterson: This is in reply to your letter of September 23 1987, with respect to positioning of rear mounted lamps and reflectors in accordance with Federal Motor Vehicle Safety Standard No. 108. Your client has designed a vehicle in which the backup lamps and rear reflex reflectors would be mounted on the deck lid, and you have asked whether there are any current or contemplated prohibitions that would preclude this design. The lamps in question will be mounted on a rigid part of the vehicle as required by paragraph S4.3.1 of Standard No. 108, and the deck lid will be closed and the lamps and reflectors in full view under normal operating conditions. The visibility requirements of lamps and reflectors in Standard No. 108 are predicated on the normal driving or closed deck lid position. Since the use of motor vehicles, including driving with deck lids open or otherwise having the lamps and reflectors obscured by a particular load on the vehicle is under the jurisdiction of the individual States, we do not anticipate rulemaking on this subject. Thus this design is not prohibited by Standard No. 108. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam0406OpenMr. David J. Humphreys, Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut AVenue, Washington, DC 20006; Mr. David J. Humphreys Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut AVenue Washington DC 20006; Dear Mr. Humphreys: This is in reply to your letter of June 22, 1971, enclosing a copy o Mr. Shrake's memorandum 'Seat Belts Required by July 1, 1971', copy attached.; We concur in your conclusion that the seat belt requirement does no apply to chassis-cabs, cabs, and vans, manufactured before July 1, 1971, and that, on or subsequent to that date, are completed as, or modified to become, motor homes. We concur also with the other points set out in the memorandum.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam4916OpenMr. Michael D. Incorvaia Manufacturing Engineering Manager Wagner Lighting P.O. Box 4650 Sevierville, TN 37864; Mr. Michael D. Incorvaia Manufacturing Engineering Manager Wagner Lighting P.O. Box 4650 Sevierville TN 37864; Dear Mr. Incorvaia: This responds further to your letter of July 3 1991, which we informed you on August 20, will be accorded confidential treatment. Paragraph 4.5 of SAE Standard J588e, Turn Signal Lamps, September 1970, states that 'failure of one or more turn signal lamps to operate should be indicated by a 'steady on', 'steady off', or by a significant change in the flashing rate of the illuminated indicator.' Electronic flashers available today provide a 'significant change' in flash rate by doubling it as an outage indication. Wagner Lighting has developed a lamp outage indication that will remain within the performance parameters of Standard No. 108, but provide an outage flash rate that appears to be slightly less than 50% greater than that of normal operation. However, there will be 'a recognized change in flashing rate.' You have asked whether these changes may be regarded as 'significant' within the meaning of SAE J588e. Your letter indicates that the design contemplated by Wagner Electric is for application in new motor vehicles. Although SAE J588e remains in effect as a replacement equipment standard, Standard No. 108 has been amended to incorporate by reference new SAE standards for turn signal lamps, and it is these standards that now apply to turn signals on new motor vehicles. Specifically, on and after December 1, l990, a motor vehicle must be manufactured to meet either SAE Standard J588 NOV84, Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width, or SAE Standard J1395 APR85, Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width. The outage indication requirement of SAE J588e was not adopted in either of the SAE standards, and has not been incorporated directly in Standard No. 108. This means that outage indication is no longer a requirement on new motor vehicles, and that Wagner Electric, under Standard No. 108, may adopt such change in flash rate as its design may call for. We are returning the tape that you enclosed. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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ID: aiam5604OpenMs. Yvonne Anderson Todd Vans East Highway 28 Morris, MN 56267; Ms. Yvonne Anderson Todd Vans East Highway 28 Morris MN 56267; "Dear Ms. Anderson: This responds to your letter of July 13, 1995 concerning a van which your company is modifying. The van is owned by a local school system. The school system has asked your company to raise the roof, extend the side door, install wheelchair tiedowns, and install a wheelchair lift. The vehicle was certified as a 'bus,' but your modification would reduce the seating capacity so that the vehicle would become a 'multipurpose passenger vehicle' (MPV). You asked whether this vehicle must be certified following the modifications. The answer to your question is no. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles. A vehicle must be certified as complying with all applicable safety standards before it can be sold or imported. After the first retail sale, there is a limit on modifications made to vehicles. Manufacturers, distributors, dealers, and repair businesses are prohibited from 'knowingly making inoperative' any device or element of design installed on or in a motor vehicle in compliance with an applicable safety standard (49 USC 30122). In general, the 'make inoperative' prohibition would require a business which modifies motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in compliance with an applicable safety standard. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting 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.