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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| search results table | |
ID: aiam3667OpenMr. Houtan Mostaghim, Vice President, Pan United Inc., 154 Hillwood Avenue, Falls Church, VA 22046; Mr. Houtan Mostaghim Vice President Pan United Inc. 154 Hillwood Avenue Falls Church VA 22046; Dear Mr. Mostaghim: This responds to your letter of March 4, 1983, asking whether there ar any Federal regulations applicable to an accessory component used to secure pets to vehicle seat belts. The component latches into the seat belt buckle and is then attached to the pet's collar or leash. Your company intends to import these accessories.; There are no Federal motor vehicle safety standards or regulation applicable to the product you describe. Therefore, as far as this agency is concerned, there are no responsibilities you must meet prior to importing this item (i.e., there are no testing or licensing requirements). You should, however, contact State authorities to determine if they have any licensing requirements or regulations that would be applicable to the sale of such a device.; You will have to contact private counsel to determine the produc liability implications and insurance needs of your enterprise.; Thank you for your inquiry. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0948OpenMr. Edward L. Hawes, President, Hawes Industries, Inc., 1651 E. 9 Mile Road, Hazel Park, Michigan 48030; Mr. Edward L. Hawes President Hawes Industries Inc. 1651 E. 9 Mile Road Hazel Park Michigan 48030; Dear Mr. Hawes: This is in response to your letter of December 7, 1972, regardin Standard 125, Warning Devices. I am sorry that you misunderstood our previous letter of November 27, 1972. We believe that the standard clearly permits the manufacture and sale of your device, for the reasons already discussed, and therefore an amendment is unnecessary. If you still have questions on this matter, do not hesitate to call me.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2975OpenMr. J. B. H. Knight, Chief Car Safety Engineer, Rolls-Royce Motors, Crewe Cheshire, CW1 3PL, England; Mr. J. B. H. Knight Chief Car Safety Engineer Rolls-Royce Motors Crewe Cheshire CW1 3PL England; Dear Mr. Knight:#This responds to your letters of July 11, 1978, an January 18, 1979, concerning Federal Motor Vehicle Safety Standard (FMVSS) 101-80, *Controls and Displays*. I regret the delay in responding to your inquiry. The answers to your questions are as follows:#1. The turn signal control lever used by Rolls-Royce is mounted on the steering column and is positioned horizontally. To operate the turn signals, the lever must rotated either clock-wise or anti-clock-wise. To label the control lever and to indicate the manner of operation, Rolls-Royce is considering placing the arrows of the turn signal symbol so that they point up and down. You ask whether the standard permits that orientation of the arrows.#The answer is no. Section 5.2.1 requires that the turn signal symbol appear perceptually upright to the driver. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle. Complying with the perceptually upright requirement instead of reorienting the symbol to serve other purposes will aid in ensuring quick and accurate identification of the turn signal control. We wish to observe that essentially the same result as that sought by RollsRoyce (sic) in reorienting the turn signal symbol could be achieved by placing curved, thinner arrows next to the symbol to indicate mode of operation.#2. (i) You noted that differing display identification requirements for safety belts appear in FMVSS 101-80 and FMVSS 208. FMVSS 101-80 does not supersede or preempt FMVSS 208 in this area. However, the agency will soon issue a notice that will provide for use of the safety belt symbol in Table 2 of FMVSS 101-80 for the purposes of both standards.#(ii) You are correct in assuming that column 3 of Table 2 should include a reference to FMVSS 105-75 for brake system malfunction displays and a reference to FMVSS 121 for brake air pressure displays. These inadvertent omissions will be corrected in the notice mentioned above. You are also correct in assuming that the options in section 5.3.5 of FMVSS 105-75 are still available.#3. You referred to the statement in the final rule preamble that the visibility requirements of 101-80 would be deemed satisfied even if minimal movements by the driver were necessary and suggested that this interpretation be incorporated in section 6, conditions, and amplified. The agency does not believe that this step is necessary. The agency does, however, believe it appropriate to amplify its earlier interpretation. By minimal movement, the agency meant head movement of not more than a few inches. By a 'few' inches, we mean up to approximately three inches. As to your suggestion for specifying the size of the driver to be used in determining compliance with the visibility requirements, the agency will consider this suggestion and address it at a future date.#4. You should comply with the speedometer scale requirements in FMVSS 101-80 since the labelling requirements in FMVSS 127 were deleted in the response to reconsideration petitions that was published July 27, 1978 (43 FR 32421).#Sincerely, Frank Berndt, Acting Chief Counsel; |
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ID: aiam3372OpenMr. Stephen E. Mulligan, International Harvester, 401 North Michigan Avenue, Chicago, IL 60611; Mr. Stephen E. Mulligan International Harvester 401 North Michigan Avenue Chicago IL 60611; Dear Mr. Mulligan: This is in response to your letter of October 1, 1980, in which you as whether compliance with 49 CFR 567, Certification, will satisfy the requirements of S4.3 of Federal Motor Vehicle Safety Standard No. 115, 49 CFR 571.115.; Section 4.3 of Federal Motor Vehicle Safety Standard No. 115 require that the vehicle identification number (VIN) 'appear clearly and indelibly upon either a part of the vehicle other than the glazing that is not designed to be removed except for repair or upon a separate plate or label which is permanently affixed to such a part.' S4.3.1 requires each character to appear in a capital, sans serif typeface. In the case of passenger cars and trucks of 10,000 pounds or less GVWR, each character must have a minimum height of 4 mm. S4.4 specifies that the VIN for passenger cars and trucks of 10,000 pounds or less GVWR shall be located within the passenger compartment.; Section 567.4 of Part 567, Certification (49 CFR 567), requires tha the certification label be permanently affixed to the vehicle, and display the vehicle identification number. Consequently, for all vehicles except passenger cars and trucks of 10,000 pounds or less GVWR, compliance with S 567.4 of Part 567 would also effect compliance with S4.3 of Standard No. 115 so long as capital, sans serif typeface was used.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3688OpenMr. James E. Forrester, Manager of Engineering Services, Truck Body & Equipment Association, P.O. Box 70409, Washington, D.C. 20088-0409; Mr. James E. Forrester Manager of Engineering Services Truck Body & Equipment Association P.O. Box 70409 Washington D.C. 20088-0409; Dear Mr. Forrester: This responds to your March 15, 1983, letter asking whether emergenc doors in school buses may be marked as 'emergency exits' and still comply with Standard No. 217, *Bus Window Retention and Release*.; Paragraph S5.5.3 states that each school bus exit shall have th designation 'Emergency door' or 'Emergency exit' as appropriate. The agency has previously determined that emergency doors are considered to be emergency exits and thus can be marked as either doors or exits. Emergency windows must be marked only as emergency exits.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3722OpenMs. Mary Ruth Harsha, Office of General Counsel, 3M Center, P.O. Box 33428, St. Paul, MN 55133; Ms. Mary Ruth Harsha Office of General Counsel 3M Center P.O. Box 33428 St. Paul MN 55133; Dear Ms. Harsha: This responds to your company's recent letter regarding th applicability of Federal motor vehicle safety regulations to the sale and application of sun control films on motor vehicles. You ask whether our November 10, 1976, letter to your company on this same subject is still applicable, as well as several other questions.; Our November 1976 letter is still current. Solar films themselves ar not considered glazing materials under Safety Standard No. 205. As stated in that letter, however, the application of such films to motor vehicles by certain persons does give rise to responsibilities under Federal law. I am enclosing a copy of a recent letter of interpretation which discusses the pertinent Federal law on this subject.; I am also enclosing a copy of a telegram that we recently sent to th Hawaii Department of Transportation which discusses the preemptive effect of Safety Standard No. 205 over State laws governing the same aspect of motor vehicle performance, under the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1381, et *seq*. (sic)). The Hawaii legislature has passed a law which attempts to allow dealers and businesses in that State to apply solar films on motor vehicles. Those films are allowed to reduce transmittance down to 35 percent. As pointed out in the enclosed telegram, Safety Standard No. 205 preempts that State statute in certain respects. The letter of interpretation and the telegram should answer all of your questions.; Please note that under Safety Standard No. 205 all windows in passenger car are considered requisite for driving visibility. Thus, all windows in a passenger car must have a light transmittance of at least 70 percent. In vehicles other than passenger cars, typically, only the windshield and front side windows are considered requisite for driving visibility. This means, for example, that a van could have solar films installed on windows behind the driver, since no transmittance requirements are specified for those windows.; I hope this has answered all your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2830OpenMr. Frank B. Caristia, President, Christy Electronics, Inc., 51 East 42nd Street, New York, NY 10017; Mr. Frank B. Caristia President Christy Electronics Inc. 51 East 42nd Street New York NY 10017; Dear Mr. Caristia: Our regional office in White Plains has forwarded your letter of Ma 29, 1978, for reply.; You have requested 'approval' of your vehicle lighting system whic flashes the stop lamps at a rate three times per second when the brake pedal is depressed.; We do not 'approve' lighting devices but we do provide interpretation whether such devices are permissible under Federal lighting requirements. As an item of original vehicle equipment your device would appear to be prohibited by paragraph S4.6 of Federal Motor Vehicle Safety Standard No. 108. This paragraph requires that all lamps be steady - burning in operation except for turn signal lamps, hazard warning, signal lamps, and school bus warning lamps, and it also allows headlamps and side marker lamps to be flashed for signalling purposes.; As an aftermarket device, however, it would be subject to regulation b the individual States. We are forwarding a copy of your letter to the American Association of Motor Vehicle Administrators for an opinion on this point.; We appreciate your interest in safety. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2563OpenMr. L. Wenderoth, Bandag of Nassau, Inc., 40 Brook Avenue, Deer Park, NY 11729; Mr. L. Wenderoth Bandag of Nassau Inc. 40 Brook Avenue Deer Park NY 11729; Dear Mr. Wenderoth: This responds to your March 10, 1977, letter asking whether it i permissible for you to use a DOT number assigned to another tire retreader when you perform special retread work in your plant for the other retreader who lacks facilities to do the work himself.; Standard No. 117, *Retreaded Pneumatic Tires*, requires that th retreader apply a DOT symbol and identification number to the tire. The DOT symbol indicates conformance with Federal regulations. The number enables the National Highway Traffic Safety Administration (NHTSA) to identify the retreader that manufactures the tire. To permit one manufacturer to use the identification number of another would impair the NHTSA enforcement actions. Accordingly, you would not be permitted to use any DOT number other than your own on tires you retread.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2099OpenMr. David Ballon, Glascock, Ballon, Vorder, Bruegge & Friedman, Suite 2424, 100 North Main Building, Memphis, TN 38103; Mr. David Ballon Glascock Ballon Vorder Bruegge & Friedman Suite 2424 100 North Main Building Memphis TN 38103; Dear Mr. Ballon: This is in response to your letter of October 14, 1975, to Ms. Kare Kreshover, of this office, asking if there have been any previous interpretations of Section 580.5(b) of 49 CFR Part 580, *Odometer Disclosure Requirements*, indicating that new car dealers must provide odometer disclosure statements to purchasers of new vehicles. Your question was prompted by a September 17, 1975, letter from this agency to Mr. William C. Koch, advising him that a new vehicle dealer must complete disclosure statements for all vehicles he transfers to persons who are taking possession for purposes other than reselling the vehicles.; Although the National Highway Traffic Safety Administration takes th position that section 580.5(b) clearly expresses the requirement that new vehicle dealers must execute odometer disclosure statements when transferring new vehicles to individuals purchasing them for purposes than resale, it has on two previous occasions explicitly pointed out this responsibility in correspondence. Copies of these two letters are enclosed for your information.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2133OpenHonorable H. S. Knight, Director, United States Secret Service, 1800 G Street, N.W., Washington, DC 20226; Honorable H. S. Knight Director United States Secret Service 1800 G Street N.W. Washington DC 20226; Dear Mr. Knight: This is in response to the November 19, 1975, request from the Secre Service for a description of the application of the Federal bumper standard (Standard No. 215, *Exterior Protection*) to vehicles whose bumper systems are modified.; Standard No. 215, the Federal motor vehicle safety standard tha applies to automobile bumpers, specifies performance requirements with which vehicles must comply. Full- sized passenger cars must be manufactured to withstand a series of longitudinal pendulum and barrier impacts at 5 mph front and rear and corner pendulum impacts at 3 mph front and rear without incurring damage to lighting, cooling, fuel, exhaust, propulsion, suspension, steering, or braking systems, or to doors or other closures.; If, after a vehicle has been purchased for purposes other than resale its owner decides to modify its bumper system, section 108(a) (2) (A) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563), as amended (Pub. L. 93-492), becomes applicable. Under that section manufacturers, distributors, dealers, and motor vehicle repair businesses are prohibited from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a safety standard. Modification of an automobile bumper that caused it no longer to comply with the requirements of Standard 215 in effect on the date of the vehicle's manufacture would be violative of section 108 if the modification was accomplished by one of the above-named persons.; If the bumper were modified by a manufacturer, distributor, dealer, o motor vehicle repair business in such a way that the bumper either continued to meet or exceeded the requirements of Standard No. 215, section 108 would not be violated. All that is necessary is that the bumper continue to be capable of satisfying the performance requirements contained in the Standard on the date of the vehicle's manufacture.; A bumper system that has been modified by a person (individual corporate, or organizational) other than a manufacturer, distributor, dealer, or motor vehicle repair business, need not remain in compliance with the provisions of Standard No. 215.; Yours truly, Richard B. Dyson, Assistant 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.