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: aiam2651OpenMs. Jill M. Zick, BURLEY, SMIERTKA, SWANK AND MISKO, Attorneys and Counselors at Law, 2525 West Jefferson, Trenton, MI 48183; Ms. Jill M. Zick BURLEY SMIERTKA SWANK AND MISKO Attorneys and Counselors at Law 2525 West Jefferson Trenton MI 48183; Dear Ms. Zick: This is in reference to your September 6 letter, regarding modificatio of motor vehicles for the handicapped, which was forwarded to this office by the Lansing, Michigan, office of the Federal Highway Administration.; Your letter has been forwarded to the Office of Chief Counsel, Nationa Highway Traffic Safety Administration, Washington, DC. I'm sure you may expect to hear from that office shortly.; Sincerely, Ardella J. Pitts, Highway Safety, Management Specialist |
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ID: aiam5194OpenDr. Thomas L Luckemeyer Dept. VER/LB SWF Auto Electric GmH; Dr. Thomas L Luckemeyer Dept. VER/LB SWF Auto Electric GmH; "FAX 07142/73 28 95 Dear Dr. L ckemeyer: As you have requested, we ar responding by FAX to your FAX letter of June 25, 1993, to Taylor Vinson of this Office. Our FAX letter to you of May 28, 1993, provided an interpretation of SAE J588 NOV84, incorporated by reference in Federal Motor Vehicle Safety Standard No. 108. You mention the l990 SAE Ground Vehicle Lighting Manual which refers to SAE J588 September l970, and ask which is the correct SAE reference. Standard No. 108 was amended with an effective date of December 1, 1990, to substitute 'SAE J588 NOV84' for 'SAE J588 September 1970' as the U.S. Federal requirement for turn signal lamps used as original equipment on passenger cars and other motor vehicles with an overall width of less than 80 inches overall width. Turn signal lamps may still be manufactured to the requirements of 'SAE J588 September 1970' if they are intended to replace original equipment turn signal lamps that were manufactured in accordance with 'SAE J588 September 1970.' We understand that your earlier letter asked for an interpretation of Standard No. 108 as it related to the design of lamps for future production, and trust that this answers your question. As you have requested, we are also FAXing a copy of Table III. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam3943OpenMr. Ralph Walker, 5517 Cleon Avenue, North Hollywood, CA 91605; Mr. Ralph Walker 5517 Cleon Avenue North Hollywood CA 91605; Dear Mr. Walker: This responds to your letter of April 8, 1985, and follows up on you telephone conversation with Stephen Oesch of my staff concerning safety regulations applying to sun roof windows for recreational vehicles. The National Highway Traffic Safety Administration has issued Standard No. 205, *Glazing Materials*, which sets requirements for the glazing used in motor vehicles, including the glazing for a sun roof in a recreational vehicle. A copy of the standard is enclosed.; You were particularly interested in the certification requirements fo sun roofs. Paragraphs S6.1 and S6.3 of Safety Standard No. 205 specify that prime glazing material manufacturers shall certify each piece of glazing for use in motor vehicles. The certification must be in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act and with section 6 of the ANS Z-26 standard. These requirements would be applicable to the company from which you buy your glazing, since that company would qualify as a prime glazing material manufacturer.; As a manufacturer or distributor who cuts a section of glazing for us in a motor vehicle, your company would be required to certify its product in accordance with paragraphs S6.4 and S6.5 of Standard No. 205. S.6.4 requires your company to mark any section of glazing that it cuts with the same AS number, manufacturer model number and manufacturer trademark or designation as the piece of glazing from which it was cut.; S6.5 requires your company to certify your product in accordance wit section 114 of the National Traffic and Motor Vehicle Safety Act. Section 114 provides that an item of motor vehicle equipment (including glazing) may be certified by means of a label or tag on the item of equipment or on the outside of a container in which the equipment is delivered. The label or tag must certify that the item of motor vehicle equipment complies with all applicable motor vehicle safety standards, Standard No. 205 in this case.; Please let me know if you have any further questions. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0396OpenKendall M. Barnes, Esq., General Counsel, Department of the Army, Headquarters United States Army Material Command, Washington, D.C. 20315; Kendall M. Barnes Esq. General Counsel Department of the Army Headquarters United States Army Material Command Washington D.C. 20315; Dear Mr. Barnes: This is in reply to your letter of June 29 with its enclosures from th Staff Judge Advocate, Aberdeen Proving Ground. The Judge Advocate requests an 'interpretation of the applicability of the [military] exception to recent motor vehicle brake fluid legislation,' stating his specific interest in 'the use of MIL-P-46046' brake fluid.; We are unaware of any 'legislation' that affects the manufacture an use of MIL-P-46046 brake fluid. The NHTSA issued an amended brake fluid standard on June 24 but this does not affect the exception provided in 49 CFR S 571.7(c) that 'No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specification.' Thus continued use of MIL-P-46046 brake fluid by military personnel appears permissible as far as this agency is concerned.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam0683OpenMr. J. W. Kennebeck, Manager, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This is in reply to your letter of April 10, 1972, on the subject o the label required by Standard 207 to be affixed to a seat that is not intended for use while the vehicle is in motion.; Although S4.4 of Standard 207 does not require the warning to b verbal, it is our impression that the concept is difficult to convey by nonverbal symbols. A quick review of personnel in the NHTSA revealed that most of them were familiar enough with the international sign system to know that something was being forbidden, but were unsure as to what the forbidden act was. Of the two symbols, the one showing the vehicle in motion appeared to be more understandable, but not by much.; It is our conclusion that neither of the symbols is adequate to giv the warning intended by S4.4. This is not to say that the symbols would not be adequate in other countries whose citizens are more familiar with symbolic labeling. I might add that the label need not contain the exact words of the standard. It would be acceptable, for example, to say 'Do not ride in this seat,' if you find that shortening the phrase would make the label less cumbersome.; Sincerely, Richard B. Dyson |
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ID: aiam1991OpenMr. E. Cooper Lipshield, Manager Research and Development, Orscheln Lever Sales Company, 1177 N. Morley Street, Moberly, MO 65270; Mr. E. Cooper Lipshield Manager Research and Development Orscheln Lever Sales Company 1177 N. Morley Street Moberly MO 65270; Dear Mr. Lipshield: This is in response to your letter of July 10, 1975, in which yo request a copy of the proposed rule dealing with tilt cab vehicle latch systems (Docket No. 69-27), which was referred to this office by the Docket Section.; Notice 1 of Docket 69-27 was published as an advance notice of propose rulemaking on October 22, 1969 (34 FR 17115). On January 25, 1972, a notice was published suspending rulemaking on 69-27 and proving that no regulation would be issued without additional notice and opportunity for comment (37 FR 1120). There has been no further action taken on tilt cab vehicle latch systems since that date.; If we can be of any further assistance, please let us know. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5481OpenMr. Arthur W. Perkins Perkins, Phillips & Puckhaber 85 North State Street P.O. Box 1138 Concord, NH 03302-1138; Mr. Arthur W. Perkins Perkins Phillips & Puckhaber 85 North State Street P.O. Box 1138 Concord NH 03302-1138; "Dear Mr. Perkins: This responds to your letter of September 30, 1994 concerning the applicability of 'various federal regulations to a motor vehicle that was converted from its original intended purpose as a cargo van to a passenger vehicle.' The modifications to the vehicle were made prior to its first retail purchase. The modifications included adding bench seats with Type 2 seat belts, adding windows, and covering the interior of the vehicle. The vehicle was involved in an accident in which four persons were ejected from the vehicle, two of whom were fatally injured. Your firm represents the two injured passengers and the estates of the two fatally injured passengers in a products liability and negligence action. Your letter asks a number of questions relative to the liability of three defendants in this action. Before answering your specific questions, I would like to explain that the purpose of our interpretation letters is to explain or clarify the meaning of our standards and regulations. Our letters are not intended to be adjudicative in nature. Given that the issues you raise about the defendants' actions concern past conduct and involve complicated factual issues, I would like to make it clear that this agency cannot comment on the liability of these parties. Your letter asked a number of questions. One series of questions asks which parties are responsible for ensuring that a vehicle complies with all Federal motor vehicle safety standards prior to its sale. A second series of questions addresses the issue of what types of modifications are considered either 'the addition, substitution, or removal of readily attachable components ... or minor finishing operations.' The third series of questions concerns the applicability of requirements in Standard No. 210, Seat Belt Assembly Anchorages, and Standard No. 301, Fuel System Integrity, to seats and seat attachment hardware. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not approve or certify any vehicles or items of equipment. Instead, each manufacturer is responsible for 'self- certifying' that its products meet all applicable safety standards. NHTSA's certification regulations are set forth in 49 CFR Part 567. Under this regulation, each manufacturer is required to certify that its motor vehicles comply with all applicable Federal safety standards. In addition to certification responsibilities, pursuant to 49 U.S.C. 30112(a), 'a person may not ... sell, offer for sale, or introduce or deliver for introduction in interstate commerce...any motor vehicle ... unless the vehicle ... complies with all applicable standards and is covered by a certification issued under section 30115 of this title.' Section 30112(b) provides certain exceptions to section 30112(a), which may or may not apply under the circumstances you have described. A person who alters a previously certified new vehicle also must certify that the altered vehicle complies with all applicable standards (49 CFR 567.7). However, as your questions recognize, this provision does not apply to the 'addition, substitution, or removal of readily attachable components ... or minor finishing operations.' In asking whether certain changes would be considered either 'the addition, substitution, or removal of readily attachable components ... or minor finishing operations,' you listed the following changes: installation of windows, installation of sub-flooring, installation of padding, installation of carpeting, installation of seats, changing the seating arrangements, attaching seat belts to the frames of bench seats, exterior painting, striping and new wheels. Tire and rim assemblies (wheels) are specifically mentioned in the regulation as examples of 'readily attachable components.' Painting is specifically mentioned in the regulation as an example of a minor finishing operation. In previous interpretations of 567.7, NHTSA has stated that adding seats or changing seating arrangements (absent 'extraordinary ease of installation') would not be considered the addition of 'readily attachable components.' With regard to the remaining changes you listed, NHTSA has stated that whether modifications involve 'readily attachable components' depends on the difficulty in attaching those components. The agency has looked at such factors as the intricacy of installation and the need for special expertise. Because changes must be made to the vehicle structure, windows would not be considered 'readily attachable components.' Unless anchorages are already available, the addition of seat belts to a vehicle also would not be classified as the addition of 'readily attachable components.' The addition of sub-flooring, padding, and carpeting to the floor of the vehicle may or may not involve the addition of 'readily attachable components,' depending on the amount of changes that were made to the vehicle itself. Finally, because striping is similar to painting, that modification would be considered a 'minor finishing operation.' With regard to your questions concerning the requirements in Standard No. 301, that standard sets forth requirements for the integrity of the fuel system and does not set forth requirements applicable to vehicle seats. The requirements for seats and their attachment assemblies are set forth in Standard No. 207, Seating Systems. Standard No. 207 requires all seats except side-facing seats and passenger seats in buses to withstand a force of 20 times the weight of the seat applied both in a forward and rearward direction. For a forward-facing seat, if a seat belt assembly is attached to the seat, S4.2(c) of Standard No. 207 requires the forces imposed in a forward direction to be applied simultaneously with the forces imposed on the seat by the seat belt loads required by S4.2 of Standard No. 210. There is no requirement for simultaneous loading with respect to forces applied on such seats in the rearward direction. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles 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: aiam0379OpenGerhard P. Riechel, Esq., Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Gerhard P. Riechel Esq. Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Riechel:#This is in replay to your letter of June 2 requestin confirmation of certain matters concerning compliance of the 1973 model Volkswagen Type I (Beetle) and Type II (Station Wagon) vehicles with Motor Vehicle Safety Standard No. 101.#We confirm that the arrangement, identification, and illumination of the heater and defroster controls as described at the meeting of May 25 between representatives of this agency and Volkswagen, and as presented in your letter of June 2, appear to meet the intent of Standard No. 101. Specifically, the requirement of paragraph S4.3 that control identification 'shall be illuminated whenever the headlamps are activated' does not necessarily require the installation of a separate light source to illuminate the identification of each control. Thus, if the ambient illumination emanating from the dash panel provides sufficient illumination to identify heater and defroster controls mounted on the drive shaft tunnel, then the illumination requirement would appear to be met. We agree that the use of contrasting lettering on the control knobs increases the likelihood that this method of compliance would meet the intent of Standard No. 101.#Sincerely, Robert L. Carter, Acting Associate Administrator, Motor Vehicle Programs; |
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ID: aiam2344OpenMr. Glenn W. Dobrick, Chief Engineer, Kentucky Manufacturing Company, P.O. Box 8186, 2601 South Third Street, Louisville, KY 40208; Mr. Glenn W. Dobrick Chief Engineer Kentucky Manufacturing Company P.O. Box 8186 2601 South Third Street Louisville KY 40208; Dear Mr. Dobrick: This responds to Kentucky Manufacturing Company's June 17, 1976 question whether the replacement of the frame of a converter dolly constitutes the manufacture of a new vehicle subject to applicable motor vehicle safety standards when the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and the fifth wheel of the damaged converter dolly are reused. This office received clarification from you by telephone that the fifth wheel would be reused, although this was not stated in your letter.; The replacement of the frame is considered a repair by the Nationa Highway Traffic Safety Administration and not the manufacture of a new vehicle. Thus the operation you describe would not constitute the manufacture of a new trailer that would require certification of compliance with safety standards such as Standard No. 121, *Air Brake Systems*.; I have enclosed a copy of a recent amendment of NHTSA regulations tha permits the rebuilding of trailers without certification in some cases when it was previously prohibited. The details of the conditions under which such rebuilding is allowed are discussed in the preamble of the document.; Yours truly, Frank Berndt, Acting Chief Counsel |
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ID: aiam0729OpenMemorandum to File: Definitions, 571.3(b), Interpretation; Memorandum to File: Definitions 571.3(b) Interpretation; Memorandum from Attorney-Advisor Subject: Fiat Ambulance Guiseppe Carretto, the Fiat lawyer, telephoned me on June 14 to as whether a Fiat 238 truck chassis to which an ambulance body had been mounted would be considered a 'multipurpose passenger vehicle.'; I replied that it would. Z. Taylor Vinson |
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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.