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: nht94-4.31OpenTYPE: INTERPRETATION-NHTSA DATE: September 16, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Gerald J. Gannon -- General Motors Corporation, Legal Staff TITLE: NONE ATTACHMT: Attached to letter dated 3-22-94 from Gerald Gannon to John Womack TEXT: This responds to your letter asking whether NHTSA intended, in a recent final rule, "to require that vehicles with an automatic transmission with a 'park' provision must prevent steering after removal of the key in order to have an ignition key-operated transmission shift override device?" You stated that the final rule might be interpreted to produce that result, but argued, based on the preamble, that a more limited result was intended. You suggested that a clarifying amendment would be appropriate. We apologize for the delay in our response. After reviewing your letter, we have concluded that the issue you raise should be addressed in rulemaking. We anticipate that a notice addressing this issue will be issued shortly. |
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ID: nht94-4.32OpenTYPE: INTERPRETATION-NHTSA DATE: September 16, 1994 FROM: Dimitrios Kallieris -- Associate Professor and Chief Division, Experimental and Forensic Biomechanics TO: The Director, Office of the Federal Register, National Archives and Records Administration, TITLE: Re: Enquiry regarding 571.212 Standard No. 212, Windshield Mounting. ATTACHMT: Attached to 2/3/95 letter from Philip R. Recht to Dimitrios Kallieris (A43; Std. 212) TEXT: I am writing to enquire about the exact definition of parts of section S5.1 and S5.2 in 571.212 Standard No. 212, Windshield Mounting. We have undertaken 30 m.p.h. crash tests with freshly adhered windscreens to test their adherence. Two Hybrid III dumm ies were placed in the front driver and passenger positions and each was restrained by a three-point belt and air bag. We would like to know whether these test conditions are covered by section S5.1 or S5.2. Furthermore, we are not sure whether the sect ion describes tests in which windshield displacement is measured dynamically, i.e during the crash, or statically, i.e after the crash. If dynamic measurement is required, what is stipulated by the standard regarding measurement technique, e.g. accelero meters or high-speed film/video. Could you please clarify this situation for us. Thank you for your assistance. Yours sincerely, Dimitrios Kallieris. |
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ID: nht94-4.33OpenTYPE: INTERPRETATION-NHTSA DATE: September 20, 1994 FROM: Ed Irvine -- Midwest Conservation Systems, Inc. TO: Phillip Recht -- Chief Counsel, NHTSA TITLE: NONE ATTACHMT: Attached to 1/11/95 letter from Philip R. Recht to Ed Irvine (A43; Std. 121) TEXT: IS IT A REQUIREMENT OF COMMERCIAL UTILITY TRAILERS, THAT FOR EXAMPLE MAY HAVE A BACKHOE TRACTOR, LEAVE THE NEW TRAILER MANUFACTURER WITH A EMERGENCY BREAKAWAY SYSTEM? (SECTION [ILLEGIBLE WORD]) WE HAVE A CORPORATE CUSTOMER WHO IS PURCHASING NEW TRAILERS FROM A MANUFACTURER THAT CLAIMS THEY MUST BE EQUIPPED WITH THEIR BREAKAWAY SYSTEM WHICH IS BASICALLY ONLY A BATTERY IN A BOX. MOST GENERALLY THIS TYPE OF SYSTEM IS NOT CHECKED BY THE OPERATOR AND MOST GENERALLY DEAD WHEN [ILLEGIBLE WORD]. THE CORPORAT E CUSTOMER WOULD LIKE TO BUY THE TRAILERS WITH OUT THEIR BREAKAWAY SYSTEM SO THEY CAN OUTFIT THE TRAILERS WITH OUR SOLAR ENERGIZED BREAKAWAY SYSTEMS. THANKS! ED Enclosure (Brochure omitted.) |
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ID: nht94-4.34 |
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ID: nht94-4.35OpenTYPE: INTERPRETATION-NHTSA DATE: September 23, 1994 FROM: Andrea Seastrand -- California State Assemblywoman TO: John Womack, Acting Chief, NHTSA TITLE: N ATTACHMT: ATTACHED TO LETTER DATED 12/6/94 FROM PHILIP R. RECHT TO ANDREA SEASTRAND (A42; STD. 119) TEXT: Enclosed is a copy of a Casework Intake Form on behalf of my constituent, Mr. Eric Brandt. Please provide me with information on how to best advise Mr. Brandt and address him personally in your response. Please direct your response to my San Luis Obisp o district office. Thank you in advance for your attention in this matter. |
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ID: nht94-4.36OpenTYPE: INTERPRETATION-NHTSA DATE: September 26, 1994 FROM: Frank Lautenberg -- U.S. Senator TO: Susan Slye -- Congressional Affairs, Federal Highway Administration TITLE: None ATTACHMT: ATTACHED TO LETTER DATED 10/28/94 FROM PHILIP R. RECHT TO FRANK LAUTENBERG (A42; REDBOOK 2; STD. 108) TEXT: Enclosed is a copy of a letter I received from Dr. Mark Bauman concerning an automobile courtesy signal. Please review the issues raised by Dr. Bauman and advise me on your findings in the matter. Please direct your response to Andrea Edwards at my Barrington office. Thank you for your assistance in this case. 538 Justice Drive Marlton, NJ 08053-5345 August 31, 1994 The Honorable Senator Frank Lautenberg 208 White Horse Pike Barrington, NJ 08007 Dear Senator Lautenberg, I had the pleasure of speaking with your very able assistant, Ms. Andrea Edwards, last Friday regarding the letter which was forwarded in response to my assistance on our Automobile Courtesy Signal. Enclosed please find a copy of our schematic/installat ion instructions for the signal (we do have a working prototype of the signal). This, in addition to the material which I have sent you earlier this year, should hopefully be sufficient for initial review by the appropriate federal agency. Thank you and your staff very much for your assistance in this matter. I look forward to a favorable response. Sincerely, Dr. Mark L. Bauman AUTOMOBILE COURTESY SIGNAL INSTALLATION (TEXT AND GRAPHICS OMITTED) 538 Justice Drive Marlton, NJ 08053-5345 August 18, 1994 The Honorable Senator Frank Lautenberg 208 White Horse Pike Barrington, NJ 08007 Dear Senator Lautenberg, I am in receipt of your letter of August 5 with the enclosed response from the National Highway Traffic Safety Administration. I am somewhat confused about some of the comments made by Mr. Hart, the acting Administrator. First, he indicates that his agency is not authorized to approve or endorse specific devices and that each manufacturer must certify that its equipment meets applicable safety standards issued by that agency. If there are standards, could we attempt to "test" our signal based upon these standards with information that we already have? If there is such a "self-certification" process, do we have to already be a manufacturer in order to see if our signal will be certified as safe? That would be cost-pro hibitive at this point unless we could be given some way to test our signal based upon our working prototype and other pertinent data. Secondly, Mr. Hart states that there are many suggestions for auxiliary signal devices but states further that there is no objective or scientific evidence that these devices will result in a net safety improvement. I am willing, as a doctor trained in objectivity, to concede that objective data is important in establishing a set of conditions. However, if one observed improvements in medicine, science, etc. throughout history it would be apparent that there are many situations that are simply obvious !! While I would also concede that we don't necessarily have the most perfect solution to this problem, there is no doubt that something should be done to cut down on intersection accidents or potential accidents and we feel that our signal at least has as valid a reason for existence as any other. There are many such instances for this need every day; the conglomeration of statistics should be able to confirm, while at least not denying, such evidence. Mr. Hart eventually indicates that such signal devices could confuse other motorists rather than assisting them and that our device may not be any better than any others. Would it not be beneficial to be able to test such a device objectively or at leas t observe it rather than make such an assumption without observation? I sent a letter to Vice President Gore last fall about such similar matters because he reportedly believes that there is too much bureaucracy in our government. He eventually replied, agreeing with me. How can this nation advance if there are such rest rictive regulations everywhere? If you have any suggestions as to how I can proceed please be so kind as to inform me. You are, after all, the Chairman of the Senate Transportation Committee!! Thank you and your staff very much for your assistance in this matter. Dr. Mark L. Bauman |
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ID: nht94-4.37OpenTYPE: INTERPRETATION-NHTSA DATE: September 28, 1994 FROM: Paul N. Wagner, President, Bornemann Products, Inc. TO: Mary Versailles -- Office of the Chief Counsel, NHTSA TITLE: Re: F.M.V.S.S. #207 Seating Systems ATTACHMT: ATTACHED TO LETTER DATED 12/23/94 FROM PHILIP R. RECHT TO PAUL N. WAGNER (A42; STD. 207); ALSO ATTACHED TO LETTER DATED 8/26/88 FROM ERIKA Z. JONES TO GLENN L. DUNCAN TEXT: Request for Comment From Chief Counsel: Earlier this year, the Agency amended F.M.V.S.S. #208 for seat belt comfort and fit by requiring in the future that designated seating positions have either an adjustable "D" ring or seat belts integrated into the seat (integrated seats). This letter is directed to an issue concerning integrated seats. An integrated seat is defined for now as a seat or seat system that the seat belts are located on the seating structure, in an all-belts-to-seat application; the pelvic portion of the belt may be attache d to the seat bottom, seat slides, or seat riser, while the "D" ring and shoulder belt is actually attached to the back of the seat itself. Our firm is a manufacturer of seating systems for light trucks manufactured in more than one stage, and is considering the manufacture of integrated seating systems. The questions we pose, which may already be before the Agency, are ones that relate to testing requirements for integrated seating. Referring to F.M.V.S.S. #207, S4.2.1, which states: "SEAT ADJUSTMENT. Except for vertical movement of nonlocking suspension type occupant seats in trucks or buses, the seat shall remain in its adjusted position during the application of each force specified in S4.2." Subparagraph S4.2 refers to specific static requirements for seating systems. When a seat belt system, such as those on integrated seats, are attached to the seating system, then the static loads of F.M.V.S.S. #207, S4.2, and F.M.V.S.S. #210, S4.2, are p erformed simultaneously. |
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ID: nht94-4.38OpenTYPE: INTERPRETATION-NHTSA DATE: September 29, 1994 FROM: Samson Helfgott -- Helfgott and Karas TO: John Womak, Esq. -- Acting Chief Counsel, NHTSA TITLE: Re: Our Ref. No.: 12.065 ATTACHMT: ATTACHED TO LETTER DATED 12/8/94 FROM PHILIP R. RECHT TO SAMSON HELFGOTT (A42; REDBOOK 2; STD. 108) TEXT: I received your letter of July 20, 1994 for which I thank you (a copy of which is enclosed for your reference). At the time we had requested information with respect to the utilization of the red and amber lighting arrangement to be placed along the sid e of trucks and other vehicles. At the time, you indicated that we did not state the number and candela of the lamps and how they would be arranged along the side of the vehicle. I now enclose an information sheet with respect to the lighting indicating what we have in mind for placement on the sides of the vehicle. The side front of the vehicle will have only yellow lights and the side rear only red. The red and yellow ligh ts will be placed in conjunction along the center of the side of the vehicle. The running lights are to be in keeping with NHTSA and/or EEC specifications. As we previously explained, during normal vehicle operation the amber (yellow) side lamps of the system would be activated. When the brake pedal is applied, the amber (yellow) lights are extinguished and the required stop lamps and red side lamps of the system would be activated. I would appreciate your comments whether you believe this system would be in violation of any of the Standards. I look forward to receiving your reply. ENCLOSURE TANKER TRAILER SIDE SAFETY SIGNALIGHT SYSTEM IN CONJUNCTION WITH NHTSA THREE LIGHT STANDARD 108 RS (RIGHT SIDE) MAJORITY OF IMPACTS LS (LEFT SIDE) BALANCE Auxiliary Lighting System designed for sides of HAZMAT Tankers to comply or accomplish a no objections from NHTSA Standard 108 [TEXT OMITTED - SEE ORIGINAL SOURCE] |
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ID: nht94-4.39OpenTYPE: INTERPRETATION-NHTSA DATE: September 29, 1994 FROM: Alberto Negro -- Chief Executive Officer, Fiat Auto R&D U.S.A TO: John Womack -- Acting Chief Counsel, NHTSA TITLE: 49 CFR Part 583 - Automobile Parts Content Labeling Request for Interpretation ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM PHILIP R. RECHT TO ALBERTO NEGRO (PART 583; REDBOOK (2)) TEXT: I am writing to ask that you verify whether the 1000 unit threshold of 49 CFR 583.5(g) applies to the Alfa Romeo and Ferrari marques separately or collectively, as those marques are both owned by Fiat S.p.A. Fiat S.p.A. is the stockholder of Fiat Auto S. p.A., which produces Alfa Romeo cars, and of Ferrari S.p.A. which produces Ferrari cars. I thank you for your consideration and I remain at your disposal for all additional information that you require. |
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ID: nht94-4.4OpenTYPE: INTERPRETATION-NHTSA DATE: August 18, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Richard J Quigley TITLE: None ATTACHMT: Attachment dated 8/1/94: Fax from Richard Quigley to John Womack TEXT: This responds to your request for reconsideration of our July 15, 1994 interpretation letter on Standard No. 218, Motorcycle helmets. In that letter, we stated that a drawing you provided would not meet the requirement in S5.6.1(e) of the standard that m otorcycle helmets be labeled with the symbol DOT. You enclosed a new drawing and ask whether it meets S5.6.1(e). The answer is no. The new version of the drawing consists of three figures that you believe constitute the symbol "DOT." Your new drawing continues to incorporate a corporate logo in lieu of the letter "O." As explained in our July 15, 1994 letter, because the symbol DOT constitutes the manufacturer's certification that the helmet conforms to Standard No. 218, there must be no ambiguity in the symbol. Using the corporate logo in lieu of the letter "O" introduces ambiguity as to whether the manufacturer has certified the helmet. Thus, the new version of the drawing you provided does not meet S5.6.1(e) of Standard No. 218. I hope this answers your question. |
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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.