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: 3196yyOpen William Engel, Assistant Chief Dear Mr. Engel: This responds to your letter asking whether Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components, requires door locks on fire trucks. Safety Standard No. 206, which applies to all passenger cars, multipurpose passenger vehicles and trucks, does not exclude fire trucks. Thus, new fire trucks are covered by the standard's general requirement that "components on any side door leading directly into a compartment that contains one or more seating accommmodations shall conform to this standard." [ S4] Standard No. 206 does not apply, however, to certain types of doors which are often found on fire trucks. Since your letter did not provide any details about the design of the specific doors to which you refer, I am unable to determine whether any of the doors on those fire trucks would be subject to Standard No. 206's requirements. For your information, I have enclosed two letters from this office which discuss the applicability of Standard No. 206 to specific doors on fire trucks in more detail. The two letters are an August 13, 1980 letter to Mr. Steenbock and a February 11, 1988 letter to Ms. Salvio. The National Highway Traffic Safety Administration has not adopted any amendments to Standard No. 206 that affect the accuracy of the information contained in these letters. I have also enclosed a current copy of Standard No. 206. I hope this information is helpful. Please contact Elizabeth Barbour of my staff at this address or by telephone at (202) 366-2992 if you have further questions. Sincerely,
Paul Jackson Rice Chief Counsel Enclosures /ref:206 d:ll/7/9l |
1970 |
ID: 3197yyOpen Mr. Marc M. Baldwin Dear Mr. Baldwin: This responds to your September 25, 1991, letter in which you asked "the specific date when 2-point seatbelts were outlawed." Lap, or 2-point, belts have never been outlawed by this agency. Rather, 3-point, or lap/shoulder belts have been required at certain seating positions in certain vehicles. Lap belts are still permitted as the only occupant restraint at a seating position in all vehicles at some seating positions. Such seating positions include all seating positions that are not outboard seating positions and all seating positions that are not forward-facing. Your letter mentioned that you are specifically interested in this information for pending litigation regarding a 1984 passenger car convertible. Passenger car convertibles manufactured in 1984 were permitted to have lap belts installed at all seating positions. The following discussion should clarify NHTSA regulations regarding safety belts. S4.1.2 of Standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in passenger cars. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seating positions, lap or lap/shoulder safety belts at all other seating positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protection requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic protection for the front outboard seats, and have a warnin |
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ID: 3198yyOpen c:\temp\interpretations\text\3198yy.txt |
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ID: 3199oOpen Dear: This is in reply to your letters of July 12, and September 2, 1988. In accordance with your request for confidentiality on the basis that your letter of July 12 contains confidential business information, your name, your company's name and address, and the name of the product concerned will be deleted from copies of this interpretation that are made publicly available. Your company wishes to install a leveling device that will lower the height of a motor vehicle to facilitate entry. It can be activated only when the parking brake is applied and the vehicle is at rest. Normal vehicle height is restored by driver activation of a control when the ignition is in the "on" position. Should the operator attempt to drive away without activation of the control, release of the parking brake or registration of motion by a speed sensor ensures that normal vehicle height is restored within approximately l5 seconds. You state that the vehicle will conform to all applicable Federal motor vehicle safety standards "when the vehicle is in its configuration for operation on public roads..., meeting all the requirements relevant to height (i.e., lighting device mounting heights, rear view mirror fields of view, non passenger car CAFE" categorization, and the like). You believe that incorporation of the height adjuster feature should not be considered when determining compliance with either the Federal motor vehicle safety standards, or the vehicle's classification for fuel economy purposes, except for mounting height requirements for lighting equipment designed to be used while the vehicle is stationary (such as parking lamps and hazard warning signal lamps). You ask for our concurrence in this interpretation. Your interpretation is acceptable to us. Provision of the feature described would not invalidate the certification of your company that the vehicle complies with all applicable Federal motor safety standards. We note that the adjustment in height is not automatic, but at the discretion of the vehicle operator. Further, the height adjuster is designed so that if it depresses vehicle height while a vehicle is being operated, it would do so only temporarily, i.e., not more than 15 seconds. Similarly, the height adjuster would not lead to a change in the classification of your vehicle for purposes of the fuel economy standards. Although 49 CFR 523.5 clearly indicates that measurement of angles and clearances for automobiles capable of off-highway operation is to be made when a vehicle is at rest, and your vehicle apparently would not have the requisite angles and clearances when the height adjuster is activated, it would have those angle and clearance when the adjuster is not activated. Further, activation of this feature is discretionary and its effects on the vehicle in motion are, as already noted, very brief. Thus, the vehicle would have the requisite clearance almost all of the time while it is being operated. Sincerely,
Erika Z. Jones Chief Counsel /ref:VSA#523#108 |
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ID: 3199yyOpen Mr. Robert A. Nordmeyer Dear Mr. Nordmeyer: This responds to your September 18, 1991 letter to NHTSA's Rulemaking office concerning your design for an aftermarket sun visor. Your letter has been referred to me for reply. The National Traffic and Motor Vehicle Safety Act authorizes our agency to issue Federal motor vehicle safety standards that apply to new motor vehicles and items of motor vehicle equipment. The Act also authorizes us to require the recall and remedy of any motor vehicle or item of motor vehicle equipment that contains a safety defect. There is currently no Federal motor vehicle safety standard that applies to an aftermarket sun visor. The safety standards relating to sun visors (Standard 201, Occupant Protection in Interior Impact, and 302, Flammability of Interior Materials) apply only to new motor vehicles and not to items of aftermarket equipment. The sun visor in a new vehicle is regulated by Standard 201, which requires that the visor be "constructed of or covered with energy-absorbing material" and that the visor's mounting must "present no material edge radius of less than 0.125 inch that is statically contactable by a spherical 6.5-inch diameter head form." The purpose of that requirement is to reduce the injuries that occur when unrestrained occupants strike the visor or its mounting with their heads. If your sun visor were installed by the manufacturer of a new motor vehicle, the visor would have to comply with the visor requirements of Standard 201. I am enclosing a copy of the standard for your review. Standard 302 requires sun visors in new vehicles to meet the flammability resistance requirements of the standard. The standard specifies that the material used on the visor must not burn at a rate of more than four inches per minute. A copy of the standard is enclosed. Although your sun visor would be sold in the aftermarket, not as an item of original equipment, Standards 201 and 302 can nonetheless affect persons who install the visor. The Safety Act provides that a person who manufactures, distributes, sells or repairs motor vehicles cannot "render inoperative" a regulated device such as a sun visor or its mountings. If a repair shop were to remove a vehicle's sun visor and replace it with your visor, the shop would be in violation of the Act unless your visor complied with the standards. An individual owner may install a visor in his or her own vehicle without regard to the standards. You should also be aware that our safety defect authority has a bearing on the manufacture and sale of your visor. Under the Safety Act, your product is considered to be an item of motor vehicle equipment. A manufacturer of motor vehicle equipment is subject to the requirements in sections 151-159 of the Act concerning the recall and remedy of products with safety defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that NHTSA or a manufacturer determines that the manufacturer's product contain a safety-related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Please contact us if you have further questions. Sincerely,
Paul Jackson Rice Chief Counsel Enclosures /ref:201#302 d:ll/l3/9l |
1970 |
ID: 3200yyOpen Mr. Michael D. Incorvaia 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. l08, 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. l08 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. l08. This means that outage indication is no longer a requirement on new motor vehicles, and that Wagner Electric, under Standard No. l08, 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 /ref:l08 d:ll/l2/9l |
1970 |
ID: 3201yyOpen William Engel, Assistant Chief Dear Mr. Engel: This responds to your letter asking whether Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components, requires door locks on fire trucks. Safety Standard No. 206, which applies to all passenger cars, multipurpose passenger vehicles and trucks, does not exclude fire trucks. Thus, new fire trucks are covered by the standard's general requirement that "components on any side door leading directly into a compartment that contains one or more seating accommmodations shall conform to this standard." [ S4] Standard No. 206 does not apply, however, to certain types of doors which are often found on fire trucks. Since your letter did not provide any details about the design of the specific doors to which you refer, I am unable to determine whether any of the doors on those fire trucks would be subject to Standard No. 206's requirements. For your information, I have enclosed two letters from this office which discuss the applicability of Standard No. 206 to specific doors on fire trucks in more detail. The two letters are an August 13, 1980 letter to Mr. Steenbock and a February 11, 1988 letter to Ms. Salvio. The National Highway Traffic Safety Administration has not adopted any amendments to Standard No. 206 that affect the accuracy of the information contained in these letters. I have also enclosed a current copy of Standard No. 206. I hope this information is helpful. Please contact Elizabeth Barbour of my staff at this address or by telephone at (202) 366-2992 if you have further questions. Sincerely,
Paul Jackson Rice Chief Counsel Enclosures /ref:206 d:ll/7/9l |
1970 |
ID: 3202yyOpen c:\temp\interpretations\text\3202yy.txt |
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ID: 3231yyOpen Mr. Gene Byrd Dear Mr. Byrd: This responds to your September 23, 1991 letter asking about the air pressure requirement specified in S7.3.8 of Standard 106, Brake Hoses. Your letter has been referred to my office for reply. Paragraph S7.3.8 states that an air brake hose assembly shall contain air pressure of 200 psi for 5 minutes without loss of more than 5 psi. You ask whether Standard 106 specifies the length of the hose for an assembly tested to S7.3.8. The answer is no; the standard does not have a generic specification for hose length. Instead, each brake hose assembly is required to meet this requirement as manufactured and sold. For purposes of compliance testing, NHTSA obtains a brake hose assembly specimen by purchasing it on the market or directly from the manufacturer. The length of the hose might vary from assembly to assembly, depending on the particular configuration of an assembly. The assembly is tested as sold to obtain performance results that indicate the assembly's real world performance. While S7.3.8 is a performance requirement for assemblies, we understand that your company (an end fitting manufacturer) seeks to ensure that an assembly made with your fitting will not fail to meet S7.3.8 due to the fitting. Since an assembly is tested to S7.3.8 in the configuration in which it is sold, you could test to the requirement using the length of hose that will be used with your fitting. Legris might be able to avoid duplicative tests by conducting "worst case" testing, such as tests using a fitting with a hose of a length most likely to exhibit an excessive loss of air pressure. Please contact us if you have further questions. Sincerely,
Paul Jackson Rice Chief Counsel /ref:106 d:ll/l5/9l |
1970 |
ID: 3232yyOpen Mr. Robert W. Smith Dear Mr. Smith: This responds to your letter of October 14, 1991, to Taylor Vinson of this Office, asking for a confirmation of your interpretation of Motor Vehicle Safety Standard No. 108, based upon a meeting with Mr. Vinson on August 15, l990. You are developing a license plate frame that incorporates a "flashing/steady burning stop lamp", for use on passenger cars and motorcycles, and "an auxiliary flashing/steady burning stop lamp" for use on vans, minivans, and pickup trucks. You cite a letter of this agency to Bettie Lou Simcox, dated October 24, 1986, as authority for your understanding that Standard No. l08 allows the use of a flashing, steady burning stop lamp. Standard No. 108 covers original motor vehicle lighting equipment, and lighting equipment that is intended to replace the original lighting equipment. It does not cover supplementary or novelty lighting equipment offered in the aftermarket. Mrs. Simcox asked us about the acceptability of an aftermarket stop lamp which, when the brake is applied, pulses before going into a steady burning mode. We informed Mrs. Simcox that her lamp was unacceptable as replacement equipment because Standard No. l08 requires original equipment stop lamps, and lamps designed to replace that equipment, to be steady burning in use, but that it would be permissible under Standard No. l08 as a supplementary stop lamp. For the same reason, your invention would not be prohibited by Standard No. l08 if it is offered in the aftermarket as a supplementary stop lamp, which we understand is your intent. You should be aware that Standard No. 108 specifically requires motor vehicles to be equipped with one or more license plate lamps. We are uncertain of the effect, if any, that the installation of your combination license plate frame/supplementary stop lamp would have upon conformance of a vehicle's license plate lamp(s) with the requirements of Standard No. l08. We therefore remind you of the prohibition in the National Traffic and Motor Vehicle Safety Act that a manufacturer, distributor, dealer or motor vehicle repair business may not render inoperative, in whole or in part, a device such as the license plate lamp that has been installed in accordance with a safety standard such as Standard No. 108. Sincerely,
Paul Jackson Rice Chief Counsel ref:108 d:ll/l5/9l |
1970 |
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.