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: aiam3322OpenMr. Terry Coleman, Codes and Safety Manager, Airstream, Jackson Center, OH 45334; Mr. Terry Coleman Codes and Safety Manager Airstream Jackson Center OH 45334; Dear Mr. Coleman: This responds to your June 13, 1980, letter asking whether your compan would be considered a chassis-cab manufacturer subject to the labeling requirements of Part 567, *Certification*. You indicate that you take another manufacturer's incomplete chassis with a motor and add to it a cab and body with bumpers, mirrors, and exterior trim. This vehicle is then sent to a final-stage manufacturer for final completion. We would not consider you to be a chassis-cab manufacturer subject to the certification requirements.; As you know, a chassis-cab is defined in Part 567 as 'an incomplet vehicle, with a completed occupant compartment, that requires only the addition of cargo carrying, work performing, or load bearing components to perform its intended functions.' The incomplete vehicle upon which your manufacturing operation begins is simply a chassis without the cab. As such, that vehicle is subject to the incomplete vehicle document requirements of Part 568, but it is not subject to the chassis-cab certification requirements.; Your modification adds on a bus body which then needs final work befor it can be used. Since you do not complete the occupant compartment as required by the definition of 'chassis-cab', you are not required to attach a certification label. You are simply an intermediate manufacturer. The final- stage manufacturer would attach the only label to the vehicle.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2163OpenMr. LeRoy E. Mueller, President, Wisconsin Trailer Company, Inc., Richfield, WI 53076; Mr. LeRoy E. Mueller President Wisconsin Trailer Company Inc. Richfield WI 53076; Dear Mr. Mueller: This responds to your November 26, 1975, request for confirmation tha the NHTSA permits the establishment of gross axle weight ratings (GAWR) for trailer axles based on use at a speed of less than 60 mph.; Your interpretation is incorrect. In the April 28, 1975, interpretatio letter to Mr. James Srch that was enclosed in the NHTSA's recent letter to you, it was stated that '. . .NHTSA has found it necessary to specify that GAWR's and GVWR's be calculated on the basis of highway speeds and not qualified by reduced speed ratings. . . .'; Since the NHTSA's November 20, 1975, letter to you, the agency ha published a proposal that would amend the definition of GAWR to conform to this interpretation. A copy is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2499OpenHonorable Mark O. Hatfield, United States Senate, Washington, D.C. 20510; Honorable Mark O. Hatfield United States Senate Washington D.C. 20510; Dear Senator Hatfield: With regard to my letter to you of July 1, 1976, concerning th application of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other than Passenger Cars*, to the paver manufactured by Layton Manufacturing Company of Salem, Oregon, I would like to advise you of a clarification of the requirements of the standard that may be relevant to Layton's product.; Essentially, it has been clarified that the requirement of S5.1.1 o the standard accommodates a manufacturer's decision to equip its motor vehicle with tires other than 'tires for highway service.' This means that Layton can choose to use tires that do not conform to the requirements set forth in S5.1.1 of the standard. I have enclosed a copy of the notice that contains a detailed discussion of this clarification.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2533OpenMr. John O. Bohmer, President, Bohmer - Reed, Inc., Motorhome Conversions, Brooten, MN 56316; Mr. John O. Bohmer President Bohmer - Reed Inc. Motorhome Conversions Brooten MN 56316; Dear Mr. Bohmer: This responds to your February 25, 1977, letter asking whether you motor home conversions make you a manufacturer or an alterer for purposes of compliance with the regulations of the National Highway Traffic Safety Administration (NHTSA).; In your conversion of motor homes, you install used bodies on ne chassis. The NHTSA considers the mounting of a used body on a new chassis to be the manufacture of a new motor vehicle that requires certification. This makes you a manufacturer rather than an alterer. The rules for certification are found in Part 567, *Certification*, and Part 568, *Vehicles Manufactured in Two or More Stages*. I have enclosed copies of these regulations for your information.; Your second question asks whether the converted vehicle must compl with Standard No. 302, *Flammability of Interior Materials*, even though the original body was manufactured prior to the effective date of the standard. Vehicles must comply with all standards in effect on the date of their manufacture. For vehicles that you complete by mounting a body on a new chassis, you are permitted to treat as the date of manufacture, the date of manufacture of the incomplete vehicle (as defined in Part 568), the date of final completion of the vehicle, or a date between those dates. Therefore, it appears that the vehicle you manufacture would be required to comply with Standard No. 302.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5022OpenMr. Hal Balzak 28025 N. Sarabande Lane #1216 Canyon Country, CA 91351; Mr. Hal Balzak 28025 N. Sarabande Lane #1216 Canyon Country CA 91351; "Dear Mr. Balzak: This responds to your letter concerning Federal Moto Vehicle Safety Standard No. 201, Occupant Protection in Interior Impact. I apologize for the delay in our response. You stated that you have received a copy of this standard and would like clarification of two issues. Your questions are addressed below. Your first question asked whether Standard No. 201 applied to passenger cars manufactured between January 1, 1968 and September 1, 1981. The answer to this question is yes, the standard applied to all passenger cars manufactured on or after January 1, 1968. Your second question asked whether Standard No. 201 applies to instrument panels manufactured for replacement of damaged units. The answer to this question is that, by its own terms, Standard No. 201 applies only to new motor vehicles. This means that the standard applies to original equipment components, including instrument panels, but not to replacements for those components. However, you should be aware of an important provision in Federal law. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A)) provides that '(n)o manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . .' This provision applies to both new and used vehicles. You specifically asked about the replacement of damaged instrument panels. I note that the Safety Act does not require a manufacturer, distributor, dealer or repair business to return a vehicle to compliance with a standard if a device or element of design has been 'rendered inoperative' by another agent, such as a crash. The prohibition of section 108(a)(2)(A) does not apply to individual owners who alter their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to tamper with the safety equipment installed on their vehicles. I hope this information is helpful. If you have further questions, please feel free to contact Edward Glancy of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam2695OpenHonorable Charles Wilson, House of Representatives, Washington, DC 20515; Honorable Charles Wilson House of Representatives Washington DC 20515; Dear Mr. Wilson: This responds to your October 19, 1977, letter enclosing correspondenc from your constituent, Mr. M. M. Davis, concerning the remanufacture of school buses.; The manufacture that Mr. Davis proposes to undertake would mount an ol school bus body on a new school bus chassis. The regulations of the National Highway Traffic Safety Administration that Mr. Davis enclosed in his letter explicitly state that the use of a new chassis in the remanufacture of a motor vehicle results in the manufacture of a new motor vehicle. Such motor vehicle would be required to comply with all safety standards in effect on the date of manufacture of the chassis or final manufacture of the vehicle or any time between those two dates. In the case of a remanufactured school bus using a chassis manufactured after April 1, 1977, the bus would be required to comply with all of the Congressionally mandated school bus regulations that became effective on April 1.; Sincerely, Joan Claybrook |
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ID: aiam5150OpenW.C. Burke, Captain Department of California Highway Patrol P.O. Box 942898 Sacramento, CA 94298-0001; W.C. Burke Captain Department of California Highway Patrol P.O. Box 942898 Sacramento CA 94298-0001; "Dear Mr. Burke: This responds to your letter requesting a interpretation of FMVSS No. 205, Glazing Materials (49 CFR 571.205). This interpretation is based on my understanding of the statements in your letter as well as statements made by Mr. Greg Bragg of the California Highway Patrol (CHP) in a telephone conversation with Mr. Clarke Harper of this agency's Office of Vehicle Safety Standards and Mr. Marvin Shaw of my staff. You ask about the marking responsibilities of glass installers who put replacement glass in school buses. CHP personnel have found school buses with replacement glass that is not marked. You ask whether an installer who cuts sections of glass from a larger, marked section is required by S6.4 of FMVSS No. 205 to mark each individual smaller section (if not already marked) prior to installing them as replacement windows. As explained below, the answer to your question is yes. The person who cuts a section of glazing to size for installation in a motor vehicle is considered a manufacturer of the glazing. This is because the item of glazing is not considered manufactured until it is in the form that it will actually be sold for installation into a motor vehicle. This position that the person cutting the glazing is a manufacturer was stated early in the history of Standard No. 205, in a letter to Donald Counihan (May 9, 1968). The agency has stated frequently since then that persons cutting sections of glazing are manufacturers, most notably in a preamble for a 1972 rule on Standard No. 205 adopting the requirements of S6.4. (37 FR 24035, November 11, 1972) NHTSA stated that S6.4 requires 'persons who cut glazing' to include the markings required by Standard No. 205 'on each cut piece.' S6.4 requires each person who cuts glazing to mark the piece with the markings required by section 6 of American National Standard (ANS) Z26. Section 6, ANS Z26 requires the following information: (1) the words 'American National Standard' or the characters 'AS,' (2) a number identifying the item of glazing, (3) a model number assigned by the manufacturer that identifies the type of construction of the glazing material, and (4) the manufacturer's distinctive designation or trademark. Section S6.5 of Standard No. 205 also requires that person to certify the material in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act. While your letter refers to persons cutting sections of glazing from larger sections, we note that it is possible that an item of replacement glazing was designed for a specific vehicle by a 'prime glazing material manufacturer' (i.e., 'one who fabricates, laminates, or tempers the glazing material,' see S6.1 of Standard No. 205). If the item was so designed by such a manufacturer, the item must be marked and certified in accordance with S6.1 and 6.2 of Standard No. 205. A person other than a prime glazing material manufacturer installing the glazing without cutting it would have no marking requirement under Standard No. 205. I hope that you find this information helpful. If you have any other questions, please contact Mr. Shaw at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3987OpenMr. Rod Nash, P.E., Corporate Engineering, Collins Industries, Inc., P.O. Box 58, Hutchinson, KS 67504-0058; Mr. Rod Nash P.E. Corporate Engineering Collins Industries Inc. P.O. Box 58 Hutchinson KS 67504-0058; Dear Mr. Nash: This responds to your May 20, 1985 letter to Mr. Francis Armstrong o the Office of Vehicle Safety Compliance, National Highway Traffic Safety Administration (NHTSA). Your letter has been referred to my office for reply.; You asked whether you are correct in certifying a van as a multipurpos passenger vehicle (MPV) if the van carries less than 10 passengers but has the lighting and identifying marks of a school bus. The answer to your question is yes.; I would like you to keep in mind that NHTSA has two sets o regulations, issued under different acts of Congress, which have a bearing on your situation. The first of these is the regulations for the manufacture and sale of new motor vehicles and new motor vehicle equipment, issued by us under the authority of the National Traffic and Motor Vehicle Safety Act of 1966. The second set of regulations is the highway safety program standards issued by us under the Highway Safety Act of 1966. The highway safety program standards cover a wide range of subjects and are consider for Federal funding of state highway safety programs. The yellow paint and black markings of school buses are features of school bus safety covered by the program standard for pupil transportation safety.; We promulgated the following definition of a MPV, as found in 49 CF S571.3, under the authority of the Vehicle Safety Act:; >>>'Multipurpose passenger vehicle' means a motor vehicle with motiv power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.<<<; You are thus correct in certifying a van as a MPV if it carries les than 11 persons, including the driver. This is the case even if the MPV has the yellow paint and black trim of a school bus. You must certify your MPV as meeting all motor vehicle safety standards applicable to MPV's. You may also voluntarily manufacture the MPV in compliance with the requirements of our school bus safety standards, as long as the vehicle continues to comply with our standards for MPV's.; New vans carrying 11 or more persons (i.e., 10 or more passengers) ar 'buses' under NHTSA's definition of a 'bus.' We define 'bus' as 'a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons' (49 CFR S571.3). Regardless of how they are painted or marked, new buses that are sold for purposes that include carrying school children must be certified as meeting our school bus safety standards.; You should also note that the color and other identifying features of school bus are aspects of school bus safety covered by Highway Safety Program Standard (HSPS) No. 17, *Pupil Transportation Safety*. Individual states have chosen to adopt some or all of the highway safety program standards issued by NHTSA for their own highway safety programs. A state's implementation of HSPS No. 17 would affect the operation and identification of school vehicles to the extent of its implementation of the standard's recommendations. A copy of the standard is enclosed for your information.; Please contact me if you have further questions. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0352OpenMr. Harvey P. Leventhal, Manufacturing Manager, Boise Cascade Recreational Vehicles, 61 Perimeter Park Road, Atlanta, GA 30341; Mr. Harvey P. Leventhal Manufacturing Manager Boise Cascade Recreational Vehicles 61 Perimeter Park Road Atlanta GA 30341; Dear Mr. Leventhal: This is in reply to your letter of May 14, 1971, on the subject of th effective date of the requirements for seat belts and seat belt anchorages in multipurpose passenger vehicles.; You have been correctly informed by RVI that the seat belt installatio standard (No. 208), and the seat belt anchorage standard (No. 210) are effective July 1, 1971, with respect to trucks and multipurpose passenger vehicles. The amendment to Standard No. 208 issued September 30, 1970, required seat belts effective July 1, 1971. That standard will be superseded by the new occupant crash protection standard on January 1, 1972, but it is in full effect from July 1, 1971, to January 1, 1972. We regret any confusion that may have arisen as the result of the issuance of the occupant crash protection standard.; The requirements for seat belt anchorages have not been affected in an way by the occupant crash protection rule and it is therefore surprising to find that the effective date of the anchorage standard has also been misunderstood. We would hope that the changes in procurement schedule to which you refer would not result in inability to conform to the standard by July 1, 1971.; On the basis of the information presently available to us there doe not appear to be sufficient cause to postpone the effective dates of Standards No. 208 and 210.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam4311OpenMr. Robert R. Shapro, Vice President, Transportation Specialist, Inc., 512 Cave Road, Nashville, TN 37210; Mr. Robert R. Shapro Vice President Transportation Specialist Inc. 512 Cave Road Nashville TN 37210; Dear Mr. Shapro: This list responds to your request for 'the fact sheet concernin certification as required' by 49 CFR Parts 567 and 568. You describe your company as a 'multistage manufacturer,' and ask how your company can become certified 'to manufacture or alter vehicles in accordance with the code of Federal regulation.' I regret the delay in responding to your request.; First, please be aware that the National Highway Traffic Safet Administration (NHTSA) has authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. The NHTSA does not approve vehicles or equipment, nor do we endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a certification process under which each manufacturer must certify that its product meets agency safety standards, or other applicable standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; As you request, I enclose a copy of 49 CFR Part 567, *Certification* and Part 568, *Vehicles Manufactured in Two or More Stages*. Also, for your information, I enclose an information sheet that may be of interest to you if you are new to motor vehicle and motor vehicle equipment manufacture.; Please note that there is no requirement that a company be 'certified before it can manufacture or alter vehicles. 49 CFR Part 566 does require that if a company begins to manufacture motor vehicles subject to any of the Federal safety standards, it must submit information identifying itself and its products to NHTSA not later than 30 days after it begins manufacture.; I hope you find this information helpful. Sincerely, Erika Z. Jones, 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.