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 |
|---|---|
ID: aiam1386OpenMiss Charlotte D. Myers, W. E. Myers Estate, Petroleum Equipment, 177 Ferguson Avenue, Burlington, VT 05401; Miss Charlotte D. Myers W. E. Myers Estate Petroleum Equipment 177 Ferguson Avenue Burlington VT 05401; Dear Miss Myers: Your request for information concerning the transfer of cargo tank from one chassis to another has been brought to our attention by the Bureau of Motor Carrier Safety.; The National Traffic and Motor Vehicle Safety Act requires that a labe certifying the compliance of motor vehicles to all applicable safety standards be affixed to a vehicle by its manufacturer. Certification regulations enacted pursuant to the mandate of the Act require the final-stage manufacturer to provide the certification of the vehicle with all applicable standards, based on information concerning the conformity of the chassis furnished by the chassis manufacturer pursuant to our regulations. This means that cargo tank manufacturers who install the tanks on the chassis and so complete the vehicle must certify it as a finished product.; Responding to your specific question, the action of transferring cargo tank from one chassis to another would require a label certifying that the vehicle complies with all applicable safety standards if the chassis was new and had not yet been purchased for purposes other than resale. If the chassis was one which had already been purchased for purposes other than resale, there would be no obligation to recertify the compliance of the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2400OpenMr. Edgar E. Lungren, Jr., Pullman Trailmobile, 200 East Randolf Drive, Chicago, IL 60601; Mr. Edgar E. Lungren Jr. Pullman Trailmobile 200 East Randolf Drive Chicago IL 60601; Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identity and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2050OpenMr. William C. Koch, Assistant Attorney General for Consumer Protection, Room 419, Supreme Court Building, Nashville, TN 37219; Mr. William C. Koch Assistant Attorney General for Consumer Protection Room 419 Supreme Court Building Nashville TN 37219; Dear Mr. Koch: As you requested in your August 29, 1975, telephone conversation wit Karen Kreshover of this office, I am forwarding to you an interpretation of Section 580.5(b) of 49 CFR Part 580, *Odometer Disclosure Requirements*, as it applies to new car dealers.; Section 580.5(b) states that an odometer disclosure form need not b executed by transferors of new vehicles before their first transfer for purposes other than resale. This means that a distributor of new vehicles is not required to provide a dealer with odometer disclosure statements for vehicles he transfers to him. A new vehicle dealer, however, must complete disclosure statements for all vehicles he transfers to person who are taking possession for purposes other than reselling the vehicles. In other words, even a new vehicle which has not been previously sold to a consumer must have its odometer mileage certified in compliance with the odometer disclosure requirements when it is transferred.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam4887OpenMr. Cliff Chuang Chief Design Engineer Prospects Corporation 114 Crawford Street Lowell, MA 01854; Mr. Cliff Chuang Chief Design Engineer Prospects Corporation 114 Crawford Street Lowell MA 01854; "Dear Mr. Chuang: This responds to your letter seeking clarification o recent amendments to Standard No. 118, Power-operated Window Systems (49 CFR 571.118), as published in the Federal Register on April 16, 1991. Specifically, you were interested in new requirements applicable to remote control operations of power windows. You first asked for confirmation of your interpretation of the new requirement in S5(a) that, while closing, remote control-operated power windows automatically reverse direction 'when they meet a resistive force of 22 pounds or more.' You also asked for an interpretation of the term 'daylight opening' as it appears in S5(b) of Standard No. 118. This agency has received several petitions for reconsideration of the recent amendments to Standard No. 118 with respect to the automatic reversal requirements. In response to the petitions, NHTSA is currently reexamining several aspects of this requirement, including those raised in your letter. The agency will publish its response to the petitions for reconsideration in the Federal Register after it has finished its reexamination of the automatic reversal requirement in the April 16 final rule. Please let us know if you have any questions about this new automatic reversal requirement after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. I hope this information is helpful to you. Please contact us if you have further questions. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0597OpenMr. V. A. Nolte, Fairmont Railway Motors, Inc., Fairmont, MN 56031; Mr. V. A. Nolte Fairmont Railway Motors Inc. Fairmont MN 56031; Dear Mr. Nolte: This is in reply to your letter of January 4, 1973, concerning th applicability of the Federal motor vehicle safety standards to passenger cars with railway guide wheels manufactured by your company.; You indicate that the guide wheels are installed on a passenger car b removing the bumpers, installing the wheels, and reinstalling the bumper shock absorbers with a new bumper of your own design. This operation is considered to be a manufacturing operation, for purposes of our regulations. If Fairmont installs the wheels on a new vehicle, then sells the vehicle to a customer, the vehicle will have to conform to the applicable safety standards. If, however, Fairmont installs the wheels on a completed vehicle that is owned by the customer, or if it sells the wheel assemblies for installation by a customer, the vehicle will not be required to conform.; The safety standard applicable to passenger car bumpers is Standard No 215. I have enclosed a copy for your reference.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5541OpenMr. Lance Tunick Vehicle Science Corporation P.O. Box 1015 Golden, CO 80402-1015; Mr. Lance Tunick Vehicle Science Corporation P.O. Box 1015 Golden CO 80402-1015; Dear Mr. Tunick: This responds to your FAX of April 19, 1995 requesting clarification of an April 3, 1995, letter from this office. You asked for verification that the 'seat belt anchorages in the following scenario are exempt from the location requirement of Standard No. 210: A vehicle with 2 front seating positions that is fitted with an air bag and manual three-point seat belt at each position, and such restraint meets the frontal crash protection requirements of S5.1 of Standard No. 208 with the air bags alone and with the belts and air bags together, but the belts alone are not crash tested under FMVSS 208.' Your understanding is correct. I hope this information has been helpful. If you have other questions or need some additional information, 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: aiam2284OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This is in response to your April 14, 1976, letter concerning th meaning of the effective dates of Federal motor vehicle safety standards.; You are correct in your understanding that a vehicle's date of sale i irrelevant to a determination of which standards are applicable to it. 49 CFR S 571.7(a), *Applicability*, specifies in relevant part:; >>>...each standard ... applies according to its terms to all moto vehicles or items of motor vehicle equipment the manufacture of which is completed on or after the effective date of the standard.<<<; For vehicles that you complete by mounting a body on a chassis, you ar permitted by 49 CFR S 567.5(a)(7) to treat as the time that manufacture is 'completed' for the purposes of S 571.7(a) any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture, regardless of when the body or chassis was sold. Please note that you must be consistent in your choice of completion date, e.g., you may not choose one date to determine applicability of certain standards while choosing another date for other standards.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam1851OpenMr. Danny Lanzdorf, Oshkosh Truck Corporation, 2307 Oregon Street, Oshkosh, WI 54901; Mr. Danny Lanzdorf Oshkosh Truck Corporation 2307 Oregon Street Oshkosh WI 54901; Dear Mr. Lanzdorf: This responds to the questions you raised in a March 18, 1975 telephone conversation with Mark Schwimmer of this office, concerning the effective date of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses,* as applied to the brake hose assemblies in fire trucks which you manufacture.; Standard No. 106-74 became effective for brake hose assemblies on Marc 1, 1975. An assembly which is not completed until it is installed in a vehice (sic) is considered to have been manufactured on the date of installation. If that installation occurred on or after March 1, then the assembly must comply with the standard. While 49 CFR Part 571.8 provides in certain cases for delay of the effective date of a standard with respect to firefighting vehicles, such a delay is available only for a vehicle requirement. There is no change in the March 1, 1975, effective date for brake hose assemblies.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam0743OpenMr. Lewis B. Hastings, Director of Government Relations, Rubber Manufacturers Association, 1346 Connecticut Avenue, N.W., Washington, D.C. 20036; Mr. Lewis B. Hastings Director of Government Relations Rubber Manufacturers Association 1346 Connecticut Avenue N.W. Washington D.C. 20036; Dear Mr. Hastings: #This is in reply to your letter of June 9, 1972 asking whether the National Traffic and Motor Vehicle Safety Act preempts the various States from enforcing the Vehicle Equipment Safety Commission's Regulation V-1 with respect to passenger car tires. #Section 103(d) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1392(d)) requires any State law applicable to the same aspect of motor vehicle performance as a Federal motor vehicle safety standard to be identical to the Federal standard. We believe this section, considered in light of Federal Motor Vehicle Safety Standard No. 109, invalidates any State law that requires passenger car tires (except tires procured by a State for its own use) to meet the VESC Regulation V-1, or to be labeled with the V-1 symbol. #Sincerely, Lawrence R. Schneider, Chief Counsel; |
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ID: aiam5111OpenMr. Eugene Berk Food and Drug Administration Center for Devices and Radiological Health Office of Compliance and Surveillance 1390 Piccard Dr. Rockville, MD 20850; Mr. Eugene Berk Food and Drug Administration Center for Devices and Radiological Health Office of Compliance and Surveillance 1390 Piccard Dr. Rockville MD 20850; "Dear Mr. Berk: This follows up on telephone conversations between yo and Deirdre Fujita of my staff about a letter you received from the Medical Device Inspection Company (MDI) concerning the 'Tumble Forms LifeSeat.' While much of the information in the letter is subject to a claim of confidentiality, Ms. Carolann Kotula-Cook of MDI told us that we can provide, for purposes of a letter that will be placed in the public docket, the following description of the LifeSeat. The LifeSeat is described by MDI as 'a safety seat designed to protect children who are riding in emergency medical vehicles. The seat is designed to be secured to the ambulance stretcher or cot... and may also be secured to the vehicle's captain's chair.' You ask whether the LifeSeat is a 'child restraint system' regulated by Federal Motor Vehicle Safety Standard No. 213, 'Child Restraint Systems.' As discussed below, the answer is yes. Standard No. 213 specifies requirements for child restraint systems used in motor vehicles and aircraft, to reduce the number of children killed or injured in motor vehicle crashes and in aircraft. The term 'child restraint system' is defined in S4 of the standard as 'any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less.' As described in MDI's letter, the LifeSeat meets the child restraint system definition, since it is designed to restrain or seat a child in a motor vehicle. Under the National Traffic and Motor Vehicle Safety Act, each child restraint system that is sold in or imported into the United States must be certified as complying with Standard No. 213. Since the LifeSeat is a child restraint system, it must be certified as complying with Standard No. 213. We informed Ms. Kotula-Cook that it appears the LifeSeat would not comply with some of Standard No. 213's requirements. We have sent her a copy of the standard, and an information sheet for manufacturers of motor vehicles and motor vehicle equipment. The information sheet describes manufacturers' responsibilities under Federal law for manufacturing vehicles and items of equipment, such as the responsibility to ensure these products do not have any safety-related defects. Ms. Kotula-Cook said that MDI will be contacting us directly for more information about Standard No. 213 and these responsibilities. We are returning the copy of MDI's letter you provided us. If you have any questions, please call Ms. Fujita at (202) 366-2992. Sincerely, Paul Jackson Rice 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.