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: aiam2441OpenMr. James A. Rupp, Vice President and General Manager, Kustom Fit of Ohio, Inc., P.O. Box 216, Pioneer, OH 43554; Mr. James A. Rupp Vice President and General Manager Kustom Fit of Ohio Inc. P.O. Box 216 Pioneer OH 43554; Dear Mr. Rupp: This responds to your April 30, 1976 request for confirmation tha 'liability' for the correct location of a vehicle's seating reference point (SRP) lies with a vehicle manufacturer or alterer that installs seating and not with the manufacturer of the seat. I regret that we have not responded to your request sooner.; >>>'Seating reference point' is defined by NHTSA regulations (49 CFR 571.3) to mean --; . . . .the manufacturer's design reference point which -- (a) Establishes the rearmost normal design driving or riding positio of each designated seating position in a vehicle,; (b) Has coordinates established relative to the designed vehicl structure,; (c) Simulates the position of the pivot center of the human torso an thigh, and; (d) Is the reference point employed to position the two dimensiona templates described in SAE recommended Practice J826, 'Manikins for Use in Defining Vehicle Seating Accommodation', November 1962.<<<; While the term 'manufacturer' found in the beginning of this definitio could refer to either a vehicle or equipment manufacturer under the relevant statutory definition (15 U.S.C. & (sic) 102(5)), the references in subparagraphs (a) and (b) make clear that the SRP is a location established with reference to the vehicle structure. It is a commonly understood reference point for specifying the available space for a seated occupant within a vehicle. The only exception to this relationship to the vehicle has been in the case of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, where the NHTSA has indicated it would accept an SRP designation that is established with reference to the seat frame. This policy is limited to school buses where seat placement within the vehicle is subject to more variation than in other vehicle types.; This means that the NHTSA, in verifying the compliance of a vehicl with a standard such as Standard No. 210, *Seat Belt Anchorages*, will ask the vehicle manufacturer for the location of the SRP.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0186OpenMr. Heinz C. Hoppe, Executive Vice President, Mercedes-Benz of North America, Inc., 158 Linwood Plaza, Fort Lee, NJ 07024; Mr. Heinz C. Hoppe Executive Vice President Mercedes-Benz of North America Inc. 158 Linwood Plaza Fort Lee NJ 07024; >>>Re: Consumer Information<<< Dear Mr. Hoppe: We have received your submittal of consumer information in response t the requirements of 49 CFR Part 375. That regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to purchasers, the following comments are only advisory in nature. There is one respect, however, in which the information, if supplied in this form to prospective purchasers, would not satisfy the requirements of the regulations.; The Consumer Information section on Vehicle Stopping Distance, 49 CFR 375.101, specifies that the information presented shall contain 'the most adverse combination of maximum or lightly loaded vehicle weight and complete logs of braking in any one of the vehicle brake subsystems.' In your submittal, you have presented information for failures in each of the front and rear subsystems, instead of selecting the most adverse combination of weights and system failures. This is likely to confuse consumers attempting to compare vehicles of different manufacturers, and fails to satisfy the requirement that the information shall be submitted 'in essentially the form illustrated in Figure 1' of S 375.101.; We will be glad to answer any questions that you may have with respec to the requirements of these or other motor vehicle safety regulations and standards.; Sincerely, Robert Brenner, Acting Director |
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ID: aiam2011OpenMr. Brian Gill, Assistant Manager, Safety & Environmental Activities, American Honda Motor Co., Inc., P.O. Box 50 - 100, W. Alondra Blvd., Gardena, CA 90247; Mr. Brian Gill Assistant Manager Safety & Environmental Activities American Honda Motor Co. Inc. P.O. Box 50 - 100 W. Alondra Blvd. Gardena CA 90247; Dear Mr. Gill:#I am writing to confirm your telephone conversation o August 4, 1975, with Mark Schwimmer concerning the applicability of Federal Motor Vehicle Safety Standard No. 101, *Control Location, Identification and Illumination*, to an intermittent-operation windshield wiper switch.#Your letter of June 4, 1975, described such an intermittent operation switch which is distinct from the normal windshield wiper switch. As Mr. Schwimmer explained, Standard No. 101 required neither illumination nor any particular location for this intermittent switch, because the normal switch is already subject to all of the standard's requirements.#Sincerely, Frank A. Berndt, Acting Chief Counsel; |
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ID: aiam5500OpenMr. Richard J. Kinsey Manager, Fuel Economy Planning & Compliance Ford Motor Company The American Road Dearborn, Michigan 48121; Mr. Richard J. Kinsey Manager Fuel Economy Planning & Compliance Ford Motor Company The American Road Dearborn Michigan 48121; "Dear Mr. Kinsey: This responds to your letter requesting ou concurrence on a procedure for determining the domestic content and country of origin for foreign-sourced allied and outside supplier components. I apologize for the delay in our response. You stated that you would like to obtain the relevant information from your present purchasing systems rather than by soliciting the information from your foreign suppliers. You stated that both processes will result in the same information, and that you believe requiring your foreign suppliers to respond to requests for information would impose costly and unnecessary burdens on those suppliers. We are now in the process of completing our response to several petitions for reconsideration of the final rule on domestic content labeling. Your question is sufficiently related to some of the issues raised by the petitions that we believe it should be addressed in the context of that response, rather than in a separate letter. We realize, however, that manufacturers and suppliers have an immediate need for guidance regarding the procedures for making content determinations for the 1996 model year. In a recent letter (copy enclosed) to the American Automobile Manufacturers Association, we advised that NHTSA had decided to give manufacturers and suppliers for model year 1996 the same alternative they had last year, i.e., in lieu of following the required procedures, they may use other procedures that are expected to yield similar results. Therefore, your planned approach will not raise any concerns for model year 1996. I hope this information has been helpful. If you have any other questions or need some additional information in this area, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosure"; |
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ID: aiam0702OpenThe Reverend Norman E. Douglas, Pastor and Student Chaplain, The United Methodist Church, Moland Road, Post Office Box 488, Alfred, NY 14302; The Reverend Norman E. Douglas Pastor and Student Chaplain The United Methodist Church Moland Road Post Office Box 488 Alfred NY 14302; Dear Mr. Douglas: This is in reply to your letter of May 2, 1972, in which you reques information relating to your responsibilities under the National Traffic and Motor Vehicle Safety Act of 1966 (the Act) and the Federal Motor Vehicle Safety Standards (FMVSS) and regulations issued thereunder.; Motor homes are not defined as such under the regulations. They fall i the category of multipurpose passenger vehicle and would be subject to all of the standards that apply to that type vehicle.; I am enclosing the following publications. The answers to you questions can be found therein:; >>>1. The Act 2. December 2, 1971, edition of the Federal Register - Recodification 3. Part 566 of Title 49 of the Code of Federal Regulations Manufacturer Identification; 4. Part 567 - Certification 5. Part 568 - Vehicles Manufactured in Two or More Stages 6. Part 573 - Defect Reports 7. Part 574 - Tire Identification 8. Notice of Publications Change<<< In the event you purchase an incomplete vehicle (chassis) fro Cadillac, they will furnish the documentation as required by part 568. In modifying the chassis you assume the role as an intermediate manufacturer and the recreational vehicle manufacturer becomes the final stage manufacturer. All terms are defined in Part 568.; Federal regulations concerning anti-pollution emission control device are not the responsibility of the Department of Transportation, but of the Environmental Protection Agency. A copy of your inquiry is being furnished to the Director, Division of Certification and Surveillance, Mobile Source Pollution Control Program, 2565 Plymouth Road, Ann Arbor, MI 48105. He will, I am sure, forward such information as he deems appropriate.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam1810OpenMr. E. J. O'Reilly, Vice President, Sales, YKK ZIPPER (U.S.A.), Inc., Illinois Division, 2165 Shermer Road, Northbrook, IL, 60062; Mr. E. J. O'Reilly Vice President Sales YKK ZIPPER (U.S.A.) Inc. Illinois Division 2165 Shermer Road Northbrook IL 60062; Dear Mr. O'Reilly: This is in response to your letter of February 13, 1975, in which yo ask whether zippers fall under the purview of Federal Motor Vehicle Safety Standard No. 302.; S4.1 of the standard states that the following components of passenge cars, multipurpose passenger vehicles, trucks, and buses must meet its requirements:; >>>Seat cushions, seat backs, seat belts, headlining, convertible tops arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, mattress covers, and any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.<<<; To the extent that a zipper is a part of any of these components, i would fall within the ambit of the standard. While recreational vehicles are not currently covered by Standard No. 302, the National Highway Traffic Safety Administration issued on November 15, 1974, a Notice of Proposed Rulemaking to extend the coverage of the standard to include recreational vehicles (copy enclosed).; You should also be aware that other rulemaking relevant to the coverag of the standard is underway and will soon be published in the *Federal Register*. For this reason, we recommend you subscribe to either the Government Printing Office Safety Standard subscription service or an equivalent commercial service as detailed in the enclosure.; Sincerely, James C. Schultz, 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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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.