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: aiam3266OpenMr. Robert A. Eddy, Manager, Quality Assurance, McCreary Tire & Rubber Company, Indiana, PA 15701; Mr. Robert A. Eddy Manager Quality Assurance McCreary Tire & Rubber Company Indiana PA 15701; Dear Mr. Eddy: This is in response to your letter of March 7, 1980, asking whethe ASTM E501 and E524 tires must be graded in accordance with the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104). You state that these tires are manufactured in limited quantities as standards for traction testing and are not manufactured for general highway use. It is the National Highway Traffic Safety Administration's understanding that these tires are used only on a test trailer designed for use in skid testing.; The UTQG regulation applies to new pneumatic tires for use on passenge cars (49 CFR 575.104(c)(1)). Thus, ASTM E501 and E524, which are manufactured solely for use on a traction test trailer, would not fall within the application of the UTQG Standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3773OpenMr. Austin Basham, Director, Motor Vehicle Division, Transportation Department, Manuel Lujan Senior Building, Santa Fe, New Mexico 87503; Mr. Austin Basham Director Motor Vehicle Division Transportation Department Manuel Lujan Senior Building Santa Fe New Mexico 87503; Dear Mr. Basham: On April 9, 1982, the National Highway Traffic Safety Administratio (NHTSA) approved New Mexico's odometer disclosure statement for use in lieu of a separate Federal form.; Pursuant to a recent inquiry, I have found that New Mexico is no longe using this approved form. New Mexico's current Certificate of Title does not satisfy the requirements of 49 CFR Part 580 and, therefore, the Federal odometer disclosure statement must be used.; If New Mexico wants to use its Certificate of Title in lieu of separate Federal form, it must include a statement which refers to State or Federal law, and must include a space for the purchaser's signature. NHTSA considers this signature to be essential because it is an acknowledgment that the purchaser was aware of the mileage. The purchaser, when he signs the document, is prevented from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the title. Additionally, Part 580.4(c) requires that three statements be included on the odometer disclosure statement. New Mexico's title certificate fails to include the first of these three. While it does provide a space for the odometer mileage, it fails to include a statement, as required by this section, stating that the transferor 'certif ies that to the best of his knowledge the odometer reading reflects the actual miles or kilometers the vehicle has been driven.'; It was suggested that New Mexico's Application for Vehicle Title an Registration may be used in lieu of a Federal odometer disclosure statement. This form, however, does not include all required information. The odometer disclosure statement must include the information specified in 49 CFR S 580.4(a)-(e). Alternatively, in accordance with 49 CFR S580.4(f), a 'State certificate of title or such other ownership document' may be used as a substitute and need only include information required by (a), (b), (c) and (e). An application for vehicle title and registration does not constitute an ownership document, and the application fails to include all information specified in Part 580.4(a)-(e).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2861OpenMr. James Tydings, Specifications Engineer, Thomas Built Buses, Inc., 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. James Tydings Specifications Engineer Thomas Built Buses Inc. 1408 Courtesy Road P.O. Box 2450 High Point NC 27261; Dear Mr. Tydings: This responds to your August 21, 1978, letter asking whether you ar permitted under Standard No. 217, to place the emergency exit sign at the bottom of a rear emergency window exit.; The National Highway Traffic Safety Administration has permitted th use of the emergency exit sign to be on the top half of rear emergency doors. This has permitted the sign to be located just below the glass on the rear emergency door. Although your location of the exit sign is not on the top of the rear emergency window exit, its location is similar to the location of the exit sign on a rear emergency door. Since the location of the sign is on the emergency window exit and is within the top half of the bus, the agency has determined that this location complies with the requirement.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3289OpenMr. Robert Slagle, Parts Manager, Brown Motors Volkswagen, 5 West 18th Street at National City Boulevard, National City, CA 92050; Mr. Robert Slagle Parts Manager Brown Motors Volkswagen 5 West 18th Street at National City Boulevard National City CA 92050; Dear Mr. Slagle: This responds to your recent letter requesting information concernin the Federal requirements that would be applicable to the manufacture and installation of auxiliary diesel fuel tanks in passenger cars. I am enclosing a copy of a letter of interpretation the agency issued last August which discusses the general implications of such installations under Federal law.; Your letter asked whether it will be necessary for you to crash tes vehicles that have the auxiliary tanks installed. As indicated in the enclosed interpretation, if the tank is added to a new vehicle prior to its first purchase for purposes other than resale, the person making the alteration will have to certify that the vehicle continues to be in compliance with all Federal motor vehicle safety standards, including Standard No. 301-75. The National Traffic and Motor Vehicle Safety Act requires a manufacturer (including an alterer) to exercise due care to assure that a vehicle it certifies is in fact in compliance with all safety standards (15 U.S.C. 1397). It is up to the manufacturer to determine how he will establish due care and, in this case, whether he will crash test a vehicle or use some other method to ensure compliance of the vehicle. The test procedures in Safety Standard No. 301-75 are not obligatory, only the performance requirements. The test procedures do, however, state how the agency will test a vehicle to determine compliance.; In answer to your question number 4, I can state that it will not b necessary for you to crash test each vehicle which has a tank installed in order to establish due care. If by your question you meant one car of each car 'model,' once again, it is up to the manufacturer how he establishes due care.; In answer to your question number 3, the information contained in th enclosed interpretation includes discussions of all the Federal safety requirements that would be applicable to your company's activities. There may, of course, be other general Federal laws regarding the conducting of a business which would be pertinent. For example, Federal Trade Commission regulations regarding advertising could affect your activities. You are probably aware of these general regulations, however, since you are already an established business enterprise.; Regarding your final question, all vehicle manufacturers, both domesti and foreign, have performed crash tests to determine compliance with Safety Standard No. 301-75. Since your company is a Volkswagen dealership, I suggest you contact Volkswagen regarding its compliance testing program for Safety Standard No. 301-75.; If you have any further questions after reviewing this information please contact Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3323OpenDouglas Middleton, U.S.A.A., P.O. Box 33400, San Antonio, TX 78233; Douglas Middleton U.S.A.A. P.O. Box 33400 San Antonio TX 78233; Dear Mr. Middleton: This is in response to your telephone call of August 6, 1980, to Kath DeMeter of my staff concerning odometer information on state certificates of title.; The following states have odometer statements on their motor vehicl titles that are consistent with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted titles to the agency askin for approval but had inacceptable statements. Each was informed that if they supplied certain additional information their titles would be in conformance. We do not know whether that information was included on the titles:; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah Wisconsin<<<; In order to spare states the burden of an approval process the agenc has indicated that certain variations from the Federal form are acceptable. In the Federal Register notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1 notice, a copy of which is enclosed.; If you have any further questions, please do not hesitate to write. Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2162OpenMr. Melvin R. Stahl, Vice President, Government Regulations, Motorcycle Industry Council, Inc., 1001 Connecticut Ave., N.W., Washington, DC, 20036; Mr. Melvin R. Stahl Vice President Government Regulations Motorcycle Industry Council Inc. 1001 Connecticut Ave. N.W. Washington DC 20036; Dear Mr. Stahl: This is in reply to your letter of December 30, 1975, asking whethe Federal Motor Vehicle Safety Standard No. 108, which permits the manufacture of motor-driven cycles whose top speed is 30 mph, without turn signal lamps, preempts a State requirement that all motor vehicles be equipped with such lamps.; The answer to your question is yes. Even though a State as in you hypothetical may not have defined 'motor vehicle,' or its definition of a vehicle category differs from a definition in 49 CFR 571.3(b) (e.g. where a State defines a motor-driven cycle as a 'bicycle'), it is preempted by Section 103(d) from establishing or maintaining in effect a safety standard that differs from a Federal standard covering the same aspect of performance. Accordingly, since S 4.1.1.26 of 49 CFR 571.108, Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment* excuses low speed motor- driven cycles from the requirement that they be equipped with turn signal lamps, a State cannot require them on identical vehicles.; I hope this answers your question. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2498OpenMr. Allan Cheshire, Market Research Analyst, Robert Bosch Corporation, 2800 South 25th Avenue, Broadview, IL 60153; Mr. Allan Cheshire Market Research Analyst Robert Bosch Corporation 2800 South 25th Avenue Broadview IL 60153; Dear Mr. Cheshire: This is in response to your letter of January 26, 1977, asking fo confirmation of several interpretations of Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*.; You are correct that, as an equipment standard, Standard No. 10 applies only to replacement of equipment that was originally mounted on the vehicle to enable it to comply with the requirements of the standard. It does not apply to items not covered by the standard, but which are frequently provided as new vehicle options, such as fog lamps and cornerning (sic) lamps. Any item of lighting equipment not required is permissable (sic) to be installed, as you also noted, if it does not impair the effectiveness of the required lighting equipment (paragraph S4.1.3). Additional lighting equipment is otherwise subject to State regulation.; You also asked 'what would be the NHTSA's stand on products where SA standards do not exist, for example halogen headlights?' A halogen headlamp that does not comply with Standard No. 108 and is intended as a replacement headlamp may not be imported and sold for this use. On the other hand, halogen fog lamps may be imported and sold, subject to State regulations.; I hope this answers your questions. Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam2532OpenMr. 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 two 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: aiam1037OpenMr. W. A. Scott, Manger (sic), Tech. Service, Chrysler Leasing Corporation, P.O. Box 1057, Detroit, MI 48231; Mr. W. A. Scott Manger (sic) Tech. Service Chrysler Leasing Corporation P.O. Box 1057 Detroit MI 48231; Dear Mr. Scott: This will serve to confirm the advice given you by telephone on Marc 12, 1973, concerning the obligations of a leasing company under the Federal Odometer Requirements, 49 CFR Part 580.; The situation that concerns you is the transfer from the lessor to th lessee of a vehicle that has been wrecked or stolen while in the lessee's possession. In transfers of this type, the lessee often fails to tell the lessor the mileage on the vehicle, so that the mileage cannot be indicated on the disclosure form. It is our opinion that the lessor in this situation should leave the mileage blank and indicate that the true mileage is unknown.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4235OpenMr. Edwin C. Silverstein, 108 Mayfair Lane, Mt. Laurel, NJ 08054; Mr. Edwin C. Silverstein 108 Mayfair Lane Mt. Laurel NJ 08054; Dear Mr. Silverstein: Thank you for your letter of August 16, 1986, concerning how ou standards apply to a product you have invented. According to the literature you provided us, your product, 'Limo Leash' is a harness system used to secure an animal in a vehicle. The system consists of a piece of webbing which can be attached at either end to the 'clothes hooks' installed in a vehicle. A snap hook, which can be attached to the animal's collar, slides along the webbing to allow the animal to move back and forth.; There are no Federal motor vehicle safety standards that apply to harness system used for animals. However, since your product is sold as an accessory for use in a motor vehicle, we would consider it an item of motor vehicle equipment. Thus, the manufacturer of your product would be covered by the agency's regulations on safety-related defects that would pose a hazard to other vehicle occupants. I have enclosed an information sheet which describes those regulations.; Since there may be state regulations governing the manufacture or us of your product, I suggest you check with state transportation officials in the jurisdictions in which you intend to market your product.; If you have any further questions, please let me know. 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.