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 |
|---|---|
| search results table | |
ID: nht68-2.12OpenDATE: 06/03/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Gruppe Autoelektrik TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letters of March 7 and May 15, 1968, to Mr. George C. Nield, concerning the requirements for motorcycle headlamps as specified in Motor Vehicle Safety Standard No. 108. On motorcycles, Standard No. 108 permits the use of unscaled headlamps conforming to SAE Standard J584. You will note that this SAE standard does not reference bulb sockets conforming to SAE Standard J567, which is intended to insure functional compatibility between bulb sockets and the bulbs listed in SAE Standard J573. Therefore, the bulbs used in motorcycle headlamps conforming to SAE Standard J584 need not conform to SAE Standard J573. Thank you for writing. |
|
ID: nht68-2.13OpenDATE: 05/27/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Truck Trailer Manufacturers Association TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of May 7, 1968, to Dr. William Haddon, Jr., concerning the location of intermediate side marker lamps and intermediate side reflex reflectors on narrow frame container chassis. The location requirements for these devices, as specified in Motor Vehicle Safety Standard No. 108, may be met by mounting them on the main frame of narrow frame container chassis, provided they are mounted in accordance with the enclosure to your referenced letter and are located at or near the midpoint between the front and rear side marker lamps and side reflex reflectors. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard. Thank you for writing. |
|
ID: nht68-2.14OpenDATE: 07/03/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Ideal Manufacturing Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of June 10, 1968, to Mr. J. O'Gorman of this Bureau, concerning the requirements for side reflex reflectors as specified in Federal Motor Vehicle Safety Standard No. 108. As noted in your letter, paragraph S3.1.1.6 of Standard No. 108, effective January 1, 1969, permits until January 1, 1970, the use of two side reflex reflectors on each side of vehicles that are less than 80 inches in overall width. On and after January 1, 1970, Standard No. 108 requires that these vehicles be equipped on each side with two side reflex reflectors and two side marker lamps. Thank you for writing. |
|
ID: nht68-2.15OpenDATE: 06/07/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Ideal Manufacturing Company TITLE: FMVSS INTERPRETATION TEXT: In response to your trailer lighting questions during your visit with Mr. W. R. Eason and the questions in your letter of March 26, 1968, the following information is provided. 1. Your letter of March 26, 1968, indicates provision of two red tail lamps, two red or amber stop lamps, one white license plate lamp and two red or amber turn signal lamps for compliance with Motor Vehicle Safety Standard 103 after January 1, 1969. In addition to the afore specified lamps the Motor Vehicle Safety Standard 108 requires side reflex reflectors and side marker lamps as specified in the standard. Location of all lamps and reflectors shall be in accordance with Motor Vehicle Safety Standard 10 requirements. Additional requirements are specified for trailers that are 80 inches or more overall width. 2. Your statement (March 26 letter) that, "The above may be combined and may be Class A in photometric value but Class B in size," is essentially correct except that turn signal lamps "shall" be of Class A photometric value rather than "may." 3. The provision of two Class A red reflectors and two Class A amber reflectors does not completely conform to Motor Vehicle Safety Standard 108 requirements, because four Class A red reflectors and two Class A amber reflectors are required. Two of the red reflectors are for rear mounting and two are for aft side mounting, while the two amber reflectors are forward side mounting. Your interpretation that either reflective material conforming to specification L-S-300 or reflectors conforming to SAE Standard J594C may be utilized for the side reflex reflector requirements of Motor Vehicle Safety Standard 108 is correct. 4. With regard to the question of applicability of Motor Vehicle Safety Standard 103 to chassis trailers, enclosed is a copy of Federal Register Volume 33, Number 1, dated January 3, 1968. If the chassis trailer meets the requirements of this document, primarily that it is an incomplete vehicle and is properly labeled in accordance with paragraph 255.13, then the original manufacturer need not install all of the required lighting of Motor Vehicle Safety Standard 108. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard. The nomenclature as used on your proposed label drawing would be considered acceptable for certification requirements and we would appreciate your sending of an actual label sample when they are available. In addition, we would like to have for our records, the actual starting serial number that will identify your vehicles as being built on or after January 1, 1969. Thank you for your interest in the safety program and we trust this information will be of assistance to you in regard to your inquiries. |
|
ID: nht68-2.16OpenDATE: 06/26/68 FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA TO: Volvo, Icorporated TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of May 15, 1968, concerning electrically heated glass which you anticipate using for rear windows in your motor vehicles. The present glazing requirement for motor vehicles are covered in Motor Vehicle Safety Standard No. 205, "Glazing Materials." Section S3, Requirements, stipulates that the glazing materials used must conform to U.S.A. Standard Z 26.1-1966, "American Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways," July 15, 1966. If the electrically heated glass you mentioned meets the requirements of Standard No. 205, we would have no objection to is use. |
|
ID: nht68-2.17OpenDATE: 06/04/68 FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA TO: Wayne Manufacturing Company TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of April 18 stating your uncertainty as to whether certain products of Wayne (945 Four Wheel Street Sweeper, Sanivac, 900 Three Wheel Street Sweeper, and Brush Clipper, 12 and 16 inch size) are regulated by the Federal motor vehicle safety standards. Since a "motor vehicle" subject to regulation by the National Traffic and Motor Vehicle Safety Act of 1966 in "any vehicle driven . . . by mechanical power manufactured primarily for use on the public streets, roads, and highways . . ." (Section 102(3)) both the four wheel street sweeper line and the Sanivac are subject to the Federal standards, specifically those applicable to trucks. They are "designed primarily for the transportation of . . . special purpose equipment" (23 C.F.R. @ 255.3(b)). Accordingly these vehicles must be manufactured in conformity with all Federal standards applicable to trucks, and certification provided to distributors and dealers pursuant to section 114 of the Act. For your guidance I enclose a copy of a Certification Notice with which Wayne should comply. I also enclose a copy of PL 90-283 adding new section 123 of the Act, which I do not believe was included with the Act, standards and amendments, and chassis-cab ruling that Mr. O'Gorman sent Mr. Vermes on May 17 in response to his letter of March 12. On the other hand, the three wheel sweeper, while a "motor vehicle" within the meaning of the Act, does not fall into any of the vehicle types, thus far defined to which standards are applicable, and consequently there are no standards applicable to it at this time. It is unclear from the brochures you enclosed on the 12 and 16 inch Brush Clipper whether these are motor vehicles within the meaning of the Act. We are, of course, pleased to see the emphasis on safety shown by the seven features listed in the descriptive literature on those products, but request that you supply more information covering the use of these machines, such as location of clipping operations, size of towing vehicles etc. |
|
ID: nht68-2.18OpenDATE: 06/20/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Ultra Inc. TITLE: FMVSR INTERPRETATION TEXT: Thank you for your letter of February 27, 1968, concerning certification of the Ultra Van Motorhome as a multipurpose vehicle. An examination of the information submitted indicate that the Ultra Van Motorhome would properly be classified as a multipurpose passenger vehicle within the definition contained in Section 255.3 (b) CFR, Initial Federal Motor Vehicle Safety Standards. Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966 requires every manufacturer of a motor vehicle or motor vehicle equipment to furnish certification of compliance with applicable standards. Details of certification were published as a Federal Register, Vol. 32. No. 215 on November 4, 1967. Your attention is invited to the enclosed copies of these documents and the Federal Motor Vehicle Safety Standards. We trust we have been of assistance to you. |
|
ID: nht68-2.19OpenDATE: 06/07/68 FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA TO: Elgin Sweeper Company TITLE: FMVSR INTERPRETATION TEXT: This is in response to your letter of April 17 requesting either confirmation of your opinion that it was "not the intent of the Federal Motor Vehicle Safety Standards to apply to" the three wheeled motor street sweeper manufactured by Elgin, or, in the alternative, consideration by the Federal Highway Administration of the establishment of a separate classification for these vehicles. Three wheeled motor street sweepers are "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966. However, they do not fall into any of the vehicle types defined thus far, to which standards are applicable, and consequently there are no standards applicable to it at this time. |
|
ID: nht68-2.2OpenDATE: 06/24/68 FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA TO: Toyota Motor Company TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of May 31, 1968, to Mr. George C. Hield, concerning your combination stop, tail, and turn signal lamp. You are correct in your interpretation with respect to the combination lamp (A,B,C) fulfilling the requirement of paragraph S3.3 (a) of Motor Vehicle Safety Standard No. 108. However, the additional tail lamp (C) must also conform to the requirement of paragraph S3.1.2 which specifies that no additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment. If the intensity of tail lamp (C) is extremely high, the lamp could impair the effectiveness of lamp combination (A,B) when the combination is used as a stop or turn signal lamp. As you noted, the intensity of the tail lamps may be reduced by inserting resistance in the tail lamp circuit as provided by SAE Standard J585c. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard. |
|
ID: nht68-2.20OpenDATE: 05/14/68 FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA TO: Center Truck Frame and Body Company TITLE: FMVSR INTERPRETATION TEXT: Thank you for your letter of April 9, 1968, to the Federal Highway Administration, requesting certification information. Enclosed are copies of the National Traffic and Motor Vehicle Safety Act 1966, Federal Motor Vehicle Safety Standards, and a ruling, amendment, and correction relative to chassis-cabs. Please note the certification requirements in the Federal Motor Vehicle Safety Standards. Note also in the chassis-cab amendment that the person combining the chassis-cab with a body or other like structure will be responsible for assuring that the complete assemblage complies with all applicable standards in effect on the date of the chassis-cab, compliance with which has not been previously certified by the manufacturer of the chassis-cab and for assuring that compliance with standards previously met by the chassis-cab have not been adversely affected by reason of the addition of the body or like structure. Your label should reflect the foregoing requirements to be acceptable. Also, the location of the label is required by this office. We trust this answers your questions. |
|
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.