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
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ID: aiam0248OpenMr. P. F. Feran, Vice President, Bruce Duncan Company, Inc., 417 South Hill Street, Los Angeles, CA 90013; Mr. P. F. Feran Vice President Bruce Duncan Company Inc. 417 South Hill Street Los Angeles CA 90013; Dear Mr. Feran: This is in reply to your letter of July 20, 1970, in which you reques a ruling as to whether the Honda ATV is subject to the Federal Motor Vehicle Safety Standards and Regulations promulgated as a result of the National Traffic and Motor Vehicle Safety Act of 1966 (the Act).; The descriptive literature furnished with your letter states that, 'th machine looks to be street legal,' and shows that the vehicle has lighting equipment. Therefore, the Honda ATV, as described appears to be a 'motor vehicle' within the meaning of Section 102(3) of the Act, and specifically a 'motorcycle' as defined in 49 CFR 571.3(b). Motorcycle means a motor vehicle with motive power having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.; We trust this will clarify the situation for you. We will be pleased t answer any additional questions that you might have.; Sincerely, Francis Armstrong, Director, Office of Compliance, Moto Vehicle Programs; |
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ID: aiam3872OpenMr. William Shaw, Sales Manager, Shinn Fu Co., of America, Inc., 1004 Ancover Park, East Seattle, WA 98188; Mr. William Shaw Sales Manager Shinn Fu Co. of America Inc. 1004 Ancover Park East Seattle WA 98188; Dear Mr. Shaw: This is in reply to your letter of December 5, 1984, with respect t the permissibility under Federal regulations of a 'Supplemental Eye-Level Rear Stop Light' which provides functions additional to a stop signal.; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices and Associated Equipment* specifies requirements only for center high-mounted stop lamps as original equipment on passenger cars, and for equipment that replaces original equipment center high mounted stop lamps.; If you offer this device to new car dealers for installation on ne cars before their sale, the dealer bears the responsibility for insuring that the car he sells complies with the center high mounted stop lamp requirements for new motor vehicles. On vehicles manufactured before September 1, 1986, equipped with the center lamp, that lamp may flash with the hazard warning lamp, but it cannot be combined with other lighting functions such as turn signal.; However, the device you wish to offer appears intended as a aftermarket device and not intended as original equipment for passenger cars. If this assumption is correct, there is no Federal standard that applies to it, and its legality must be determined according to the law of each State where it will be in use.; We hope that this information has been helpful. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2760OpenMr. Edmund C. Burnett, Recreation Vehicle Industry Association, 5272 River Road, Suite 400, Washington, DC, 20016; Mr. Edmund C. Burnett Recreation Vehicle Industry Association 5272 River Road Suite 400 Washington DC 20016; Dear Mr. Burnett: This responds to your January 18, 1978, letter asking several question about the applicability of Standard No. 302, *Flammability of Interior Materials*, to several vehicle components that you submitted.; First you ask whether padded material used for the top portion of dashboard would be considered to fall within the ambit of the standard. As you stated in your letter, the National Highway Traffic Safety Administration has determined that a dashboard is considered a front panel and is included within the components subject to the standard. Therefore, since the padding you propose to use on the top of the dashboard constitutes part of the dashboard it is required to comply with all of the requirements of the standard.; In your second question you ask whether the same material mentioned i question 1 would be required to comply with the standard when used as a seat cushion. Paragraph S4.1, which lists the components covered by the standard, specifically includes seat cushions. Therefore, any material used for this purpose is required to comply with the standard.; In regard to both of the above questions, you ask whether a dashboar or seat cushion consisting of vinyl stitched at varying intervals to padding would be subject to two tests - one for the vinyl and one for the padding. Paragraph S4.2.1 states that: 'any material that does not adhere to other material(s) at every point of contact shall meet the requirements of S5.3 when tested separately.' When the vinyl is stitched to the padding in the manner outlined in your letter, the vinyl does not adhere to the material at every point of contact. Accordingly, the materials must be tested separately.; Your questions 3 and 4 require no response since the materials to whic you refer must be tested separately, not as composite materials.; In your question 5, you correctly state that the two top material would be required to be tested separately. If as installed in the vehicle the third layer of material would fall within 1/2 inch of the occupant compartment, then it too would be tested in accordance with the requirements. It does not matter that this material would not be within 1/2 inch of the surface when the stitching is removed for testing of each component separately. In a related question you ask whether the stitching itself would be tested. Since the stitching is part of the seat cushion, it is subject to the requirements and since it does not adhere at every point of contact, it should be tested separately. From the standpoint of practicality, however, the stitching cannot be tested separately in the prescribed manner, and is usually simply tested as part of the material itself.; Finally you submitted a section of headlining material and questio whether it would be required to comply with the requirements. This material falls within the list of components covered by the standard and, therefore, must comply with all of the requirements. The material that you submitted is composed of two layers joined at every point of contact and would be tested as a composite material.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2330OpenMr. Daryl Nims, Nims Sportsman, 225 Main Street, Ames, IA, 50010; Mr. Daryl Nims Nims Sportsman 225 Main Street Ames IA 50010; Dear Mr. Nims: This will confirm your telephone conversation of June 23, 1976, wit Mr. Vinson of this office concerning the preemptive effect of the Federal motor vehicle safety standards with respect to moped turn signals.; The Federal standards are issued pursuant to Title 15, United State Code, Section 1392(a). Judging that a multiplicity of State and Federal vehicle safety standards would constitute a burden on interstate commerce, Congress also enacted Section 1392(d), which prohibits a State from establishing or continuing in effect a vehicle safety standard that differs from a Federal safety standard covering the same aspect of vehicle performance. For example, Federal Motor Vehicle Safety Standard No. 108 contains requirements for motorcycle headlamp performance. Therefore, if a State has a standard on motorcycle headlamp performance it must be identical to the Federal one, and may not impose either greater or lesser requirements. On the other hand, there is no Federal standard for fog lamps, and a State may set whatever requirements it deems appropriate for fog lamps.; How does preemption apply to moped turn signals? Under the Federa standards, a moped is categorized as a 'motorcycle' since it is 'a motor vehicle. . .having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.' (Title 49, Code of Federal Regulations, Section 571.3(b)). For some purposes a moped is considered a 'motor-driven cycle' which is 'a motorcycle with a motor that produces 5-brake horsepower or less.' Standard No. 108 requires motorcycles manufactured on or after January 1, 1973, to be equipped with turn signal lamps. However, in recognition of the limited ability of low-powered motorcycles, Standard No. 108 was amended effective October 14, 1974, to add paragraph S4.1.1.26 which states that 'A motor- driven cycle whose speed attainable in 1 mile is 30 mph or less need not be equipped with turn signal lamps.' Pursuant to Section 1392(d) this means that a State can validly require a moped to be equipped with turn signal lamps in only two instances: If the moped were manufactured between January 1, 1973 and October 14, 1974, or if it were manufactured on or after October 14, 1974, and has a top speed exceeding 30 mph.; I hope this clarifies the matter for you. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam3171OpenMr. R. M. Premo, Director, Vehicle Safety Activities, Sheller-Globe Corporation, 3555 St. Johns Road, Lima, OH 45804; Mr. R. M. Premo Director Vehicle Safety Activities Sheller-Globe Corporation 3555 St. Johns Road Lima OH 45804; Dear Mr. Premo: This responds to your November 12, 1979, letter asking whether severa joints in your school bus must comply with Standard No. 221, *School Bus Body Joint Strength*. All of the joints concern what you have called maintenance access panels.; As you are aware, the agency has discovered through its complianc testing that most school bus manufacturers have taken advantage of the maintenance access panel exemption from the standard. The result is that many joints in school buses are not as secure as they should be and, during an accident, might result in injury to children being transported in those buses. The agency is very concerned about this practice and is considering methods of limiting the maintenance access panel exemption.; Your letter asks the agency to consider the fact that the panels whos joints you are questioning are plastic and not metal. Therefore, you conclude that the edges are not sharp, and even if the panels come unfastened in an accident, their edges will not be likely to injure the occupants of your buses.; The standard establishes joint strength tests that apply uniformly t all joints regardless of the material used in the panel. While it may be true that plastic panels are less likely to injure occupants of buses when a panel becomes disconnected during an accident, Standard No. 221 addresses other safety areas beyond preventing the sharp edges of panels from cutting occupants. Joint strength is necessary for the vehicle integrity during accidents. This is as important as preventing cutting edges from panels. Accordingly, the agency will continue to subject all joints falling within the parameters of the standard to the requirements of the standard without regard to the material used in a panel.; With respect to the questions posed in your letter, you first as whether the right and left hand windshield pillar covers must comply with the standard. You indicate that a hose runs behind one pillar cover and a cable control runs behind the other. The agency has indicated that the installation of a wire, hose or cable behind a wall does not make that wall a maintenance access panel. Accordingly, the agency concludes that the joints connecting the pillar cover panel are subject to the standard.; Your questions 2, 4, and 5 refer to panels that cover motors which yo indicate must be serviced. The motors include the windshield wiper and heater motors. The agency is unable to determine from your pictures and sketches whether all of the joints surrounding these motors are subject to the standard. The joints connecting panels that *must* be removed for *routine* servicing of a vehicle's motors would not be considered as joints subject to the standard. However, these joints must be the minimum necessary for routine servicing of the motors. In compliance testing your vehicles, the agency will only exempt those joints that are necessary for routine servicing. We will not exempt adjacent panel joints simply because wires run beneath them.; In your third question you describe a dash trim panel that covers wiring harness, some chassis cowl mounting bolts, and an entrance door cable. The agency needs more information to make a formal determination with respect to this panel and its joints. Our inclination based upon the information that you have presented is that these would be joints subject to the standard, because the removal of this panel is not required for routine maintenance.; Your final question asks whether the entrance door control cover mus comply with the standard. You state only that it must be removed to remove the dash trim panel. As we stated in the last paragraph, we believe that the dash trim panel joints may be required to comply with the standard. If this is the case, it may also be necessary for the door control cover joints to comply with the standard. The key factor in determining whether this panel's joints must comply with the requirement is whether the panel must be removed for routine maintenance. You have not proven such a need in your letter, and therefore, the agency cannot give you a determination concerning the need for these joints to comply with the standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3521OpenMr. L. J. A. Mills, G. & C. Mills Plastics Inc., 9 Carrier Drive, Ontario, Canada M9V4B2; Mr. L. J. A. Mills G. & C. Mills Plastics Inc. 9 Carrier Drive Ontario Canada M9V4B2; Dear Mr. Mills: This responds to your recent letter asking whether an auxiliary win deflector which you sell must have a 'safety label.' Also, you ask whether you should send one of your products to the agency in order to obtain official approval.; The answer to your first question is yes. Section 108(a)(1) of th National Traffic and Motor Vehicle Safety Act provides that no person shall; >>>'(A) manufacture for sale, sell, offer for sale, or introduce o deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard . . .; '(C) fail to issue a certificate required by section 114, or issue certification to the effect that a motor vehicle or item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards, if such person in the exercise of due care has reason to know that such certification is false or misleading in a material respect.'<<<; Since your auxiliary wind deflector is a piece of motor vehicl equipment and is subject to Safety Standard No. 205, *Glazing Materials*, you are required by section 108 to certify that it complies with that standard. As noted on page 2 of our October 8, 1980 letter to Mr. Hingtgen (which you received), section 114 of the Vehicle Safety Act requires the manufacturer or distributor to place a label or tag on the item of equipment or on the outside container in which the equipment is delivered. This label or tag must state (i.e., certify) that the item of equipment complies with all applicable safety standards, in this case Standard No. 205. You are correct in your assumption that you print this label or tag yourself. The agency does not provide the labels.; In answer to your second question, you should not send a sample of you product to the agency for approval. The agency does not grant prior approval of any motor vehicle or piece of motor vehicle equipment. As you can see from section 108 quoted above, the Vehicle Safety Act requires self- certification by the manufacturer that its product is in compliance with all applicable Federal motor vehicle safety standards. The agency's enforcement program begins only after the manufacturer has certified its product (i.e., the agency may obtain an item of equipment or vehicle from the open market and determine whether it is in fact in compliance with all standards).; I hope this has answered all remaining questions you might have. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0024OpenMr. John Hollyfield, Inspector, Motor Vehicle Inspection, Texas Department of Public Safety, 5205 N. Lamar Boulevard, Box 4067, North Austin Station, Austin, TX, 78751; Mr. John Hollyfield Inspector Motor Vehicle Inspection Texas Department of Public Safety 5205 N. Lamar Boulevard Box 4067 North Austin Station Austin TX 78751; Dear Mr. Hollyfield: Mr. Arnold Wise has asked that I answer your letter of April 14, 1967 concerning a clarification of several requirements of Motor Vehicle Safety Standards 207, 208, and 209.; I am enclosing copies of the *Federal Register* of August 31, 1966, an February 3, 1967, which provide all of the information which you require. You will note that Standard No. 207 is concerned with the anchorage of the seats - not seat belts. Standard No. 208 requires seat belts in all passenger cars manufactured after January 1, 1968. In a regular size, four door, sedan-type vehicle with regular undivided seats, six lap belts would be required and, in addition, upper torso restraints would be required in the front outboard seats if the windshield header is in the head impact area.; The installation of seat belts in other than passenger cars is no required by the initial standards. However, any seat belts that are manufactured after March 1, 1967, must conform to the requirements of Motor Vehicle Safety Standard No. 209.; Your interest in the traffic safety program of this Bureau i appreciated.; Sincerely, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service; |
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ID: aiam2019OpenMr. Wade H. Barrineau, III, Compact Van Equipment Co., Inc., 5159 E. Shore Drive, Conyers, GA, 30207; Mr. Wade H. Barrineau III Compact Van Equipment Co. Inc. 5159 E. Shore Drive Conyers GA 30207; Dear Mr. Barrineau: This is in response to your letter of July 17, 1975, inquiring as t the regulations to which you may be subject by manufacturing and selling interior shelving, interior safety bulkheads, and roof mounted ladder carriers for Ford Econoline vans.; The National Highway Traffic Safety Administration has issue regulations covering the alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. (49 CFR SS567.7 and 567.8, copy enclosed). Under these regulations, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than 'readily attachable' components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.; From the description of your products, it appears that no specia expertise or tools are required for their installation. They would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that they are 'readily attachable', and that an alterer label is therefore not required when these products are installed.; The only Safety Standard that might apply to your products is Standar No. 302, *Flammability of Interior Materials* (copy enclosed).; In addition, as items of motor vehicle equipment, your products ar subject to the requirements of the National Motor Vehicle and Traffic Safety Act of 1966, as amended, and must therefore be free from safety-related defects.; If you have any further questions, feel free to write again. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam5226OpenKenneth G. Koop, Risk Control Representative Intergovernmental Risk Management Agency One Oakbrook Terrace 22nd Street at Butterfield Road Suite 412 Oakbrook Terrace, IL 60181; Kenneth G. Koop Risk Control Representative Intergovernmental Risk Management Agency One Oakbrook Terrace 22nd Street at Butterfield Road Suite 412 Oakbrook Terrace IL 60181; "Dear Mr. Koop: This responds to your letter of June 3, 1993 requesting information on a modification for police vehicles. You seek permission to remove the passenger seat and passenger air bag from police vehicles, and to permanently mount equipment where the passenger seat had been. As explained below, this type of modification would be permitted under Federal law. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act) to issue Federal motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. Among the standards that NHTSA has issued are two which could be affected by the modification you propose: Standard No. 207, Seating Systems, (49 CFR 571.207), which requires each vehicle to have an occupant seat for the driver and sets strength and other performance requirements for all occupant seats in a vehicle, and Standard No. 208, Occupant Crash Protection (49 CFR 571.208), which specifies occupant protection requirements based on vehicle type and seating position within the vehicle. If your contemplated modification is made before a vehicle's first purchase for purposes other than resale, the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration (See 49 CFR Part 567.7). Once the front passenger seat is removed, Standard No. 208 would not require an air bag for that location since an occupant restraint is only required if a seating position is there. After a vehicle's first purchase for purposes other than resale, i.e., the first retail sale of the vehicle, the presence and condition of devices or elements of design installed in the vehicle under applicable safety standards is affected by section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section provides: 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. NHTSA does not consider there to be a violation of the 'render inoperative' prohibition with respect to occupant restraints if, after one of the named types of commercial entities modifies a used vehicle, the vehicle is equipped with occupant restraints at every seating position and those occupant restraints are the type that Standard No. 208 permitted when the vehicle was new. Again, if a seating position were removed from a used vehicle, the removal of the air bag as well would not violate the render inoperative provision because the presence of the air bag was originally premised on the presence of the seating position. However, the render inoperative prohibition would be violated if removal of the passenger side air bag caused the driver side air bag to malfunction or deploy. I would like to caution you to contact the vehicle manufacturer concerning the proper procedure for any air bag removal. Removing an air bag could cause it to deploy and injure the mechanic. In addition, removal of the passenger side air bag could cause the driver side air bag to malfunction or deploy. You should also note that the 'render inoperative' prohibition applies only to the named entities. Therefore, vehicle owners are permitted to make any modifications to their vehicles, even if the vehicle would no longer comply with applicable safety standards. However, we encourage vehicle owners not to tamper with the occupant protection systems installed in their vehicles. You should be aware that S4.5.2 of Standard No. 208 requires a readiness indicator for an air bag system which is clearly visible from the driver's seating position. NHTSA believes that most manufacturers install one indicator for both air bags. After the passenger side air bag is removed, this indicator would show that the air bag system is not operative. NHTSA is concerned that the driver would then be unable to tell if the driver side air bag were functional. Therefore, I urge you to contact the manufacturer to determine how the indicator could be altered to monitor the readiness of the driver side air bag only. As a final caution, I note that the purpose of the 'render inoperative' provision is to ensure, to the degree possible, current and subsequent owners and users of the vehicle are not deprived of the maximum protection afforded by the vehicle as newly manufactured. Your letter states that you will 'place permanently mounted policing equipment in the seat's place.' It is our understanding that it is common for police cars to be sold after a few years of service. Presumably any police equipment would be removed before such a sale. I urge you to either reinstall the passenger seat and occupant restraint or to make these modifications in a way that will discourage reinstallation of the passenger seat, so that future users of the vehicle are unlikely to use a seating position that does not have any occupant restraint. 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"; |
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ID: aiam0474OpenMr. H. A. Sage, Director of Research and Engineering, Truck- Lite Company, P. O. Box 387, Jamestown, NY, 14701; Mr. H. A. Sage Director of Research and Engineering Truck- Lite Company P. O. Box 387 Jamestown NY 14701; Dear Mr. Sage: This is in reply to your letter of October 15, 1971, to Mr. Lewis Owe of this Office concerning the coating of Lexan lenses.; Plastic lenses used in the required lamps are required by Federal Moto Vehicle Safety Standard No. 108 to meet SAE J576, which specifies no loss of surface luster and no surface deterioration. This Agency does not have the authority to 'waive' any requirements of a Federal motor vehicle safety standard.; If you believe that motor vehicle safety does not demand requirement of this severity, you may submit a petition asking for an appropriate amendment of Standard No. 108.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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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.