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: nht73-5.30OpenDATE: 10/26/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Nissan Motor Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 25, 1973, asking whether the fuel spillage measurement specified in Standard No. 301 is an average rate of one onunce per minute (your Item A) or an actual rate. (Your Item B) Your item B is correct. Fuel spillage shall not exceed one ounce per minute in any one of the fifteen minutes of the observed period. YOURS TRULY, NISSAN MOTOR CO., LTD. September 25, 1973 Lawrence Schneider Chief Council National Highway Traffic Safety Administration This is to ask your interpretation regarding the test procedures of MVSS 301 Fuel System Integrity published in Federal Register, Vol. 38, No. 160 (Docket No. 70-20) on August 20, 1973. We feel that the fuel spillage requirement following cessation of vehicle motion of S.5.4 has the following two meanings: A) The calculated fuel spillage rate. Total amount of fuel spillage (oz.) B) The measured fuel spillage rate every minute. All of the collected fifteen one-minute timed samples shall not exceed one ounce per minute. We would like to know which definition is correct understanding. Your prompt reply would be greatly appreciated. Very Truly Yours, Tatsuo Kato |
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ID: nht73-5.31OpenDATE: 10/19/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Jordan Research Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 18, 1973 asking for an interpretation of Standard No. 108. You understand that "the stop lamps must light when applying the automobile brakes and/or when applying the trailer brakes individually." You tell us of a product that gives a driver "manual control of the trailer brakes [but] does not light the stop lamps in this mode." Paragraph S4.5.4 of Standard No. 108 requires that "the stop lamps on each vehicle shall be activated upon application of the service brakes." This section of Standard No. 108 requires that stop lamps on new motor vehicles be wired in this manner. The standard does not apply after the vehicle is purchased, and thus does not prohibit a vehicle owner from modifying the wiring of his vehicle by adding the Electronic Trailer Brake Control. Such an addition, however, might be precluded under State law. |
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ID: nht73-5.32 |
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ID: nht73-5.33OpenDATE: 10/26/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: L.E. Haight, Esq., Attorney at Law TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 21, 1973, concerning your desire to disconnect the interlock system on your new car. The dealer who sold you the car was required to have the interlock working at the time of sale, pursuant to section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)). However, section 108(b)(1) of the Act (15 U.S.C. 1397 (b)(1)), provides that the requirements of 108(a)(1) do not apply after the first purchase of the vehicle for purposes other than resale. As a purchased who intends to use the vehicle, you are therefore not subject to the requirements of the Act and may disconnect the interlock. Despite the absence of legal sanctions for disconnecting the interlock, we would hope that you could find a way to adjust the belt so that it could be worn without aggravating your bursitis. The physical sanctions for an unbelted person in a crash can be serious indeed. SINCERELY, LLOYD E. HAIGHT ATTORNEY AT LAW September 21, 1973 National Highway & Traffic Administration Attention: Bobby A. Boaz I am writing to you regarding the automobile interlocking seat belt device which has been installed pursuant to your instructions under the National Traffic and Motor Vehicle Act of 1966 and regulations issued thereunder. For several years, I have suffered with bursitis in my hip joints and I have found that my physical problem is greatly aggravated by being held into an automobile seat by a belt. It seems that the imperceptible vibration of an automobile seat is transmitted into my hip joints to a much greater extend by reason of being locked into a seat by a seat belt. Because of this, I must have periodic treatments from an orthopedic physician. My purpose in writing to you is to inquire whether or not it is possible, upon presentation of a medical certificate, to obtain an exception to your regulations as to the new seat belt interlocking arrangement. I have just purchased a 1974 automobile and unless I can obtain a release from your agency, I feel I will not do much traveling by automobile. Your early response would be appreciated. L. E. Haight |
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ID: nht73-5.34OpenDATE: 10/30/73 FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA TO: Worcester Polytechnical Institute TITLE: FMVSS INTERPRETATION TEXT: Thank you for your letter of October 10, 1973, and your inquiry concerning Federal Motor Vehicle Safety Standard No. 301, and enforcement actions concerning this standard. Standard No. 301, Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections - Passenger Cars, was effective January 1, 1968, and defined the amount of fuel leakage permissible incidental to a 30 mile-per-hour, fixed barrier collision. A copy of this standard is enclosed for your information. Historically, this standard has not been the basis of any fines, penalties, or recalls as far as the industry is concerned; however, it has been the basis for two relatively minor, voluntary design changes within the industry. Recently, actions have been taken to substantially upgrade Standard No. 301. An amendment to the standard published August 20, 1973 (38 F.R. 22397) expanded the standard to include all motor vehicles under 10,000 pounds, except motorcycles, cover the entire fuel system and provide a rollover provision. A Notice of Proposed Rule Making, also published August 20, 1973 (38 F.R. 22417) provided(Illegible Words) and rear impact requirements, as well as a dynamic rollover provision. Copies of these two actions are also enclosed for your information. (Illegible Word) trust your inquiry has been satisfactorily answered. If we can(Illegible Word) of any further assisunce, pld.^&>> 8!>080>>`#S,{@0xe@ q"(td8Ev? yhRqsU89<.zq1[d`??~?~?~ <>ODY> |
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ID: nht73-5.35OpenDATE: 10/31/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Sheller-Globe Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of October 11, 1973, requesting that Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release," be amended to include buses of the same design as school buses within the exemption from the emergency exit requirements specified for "school buses" in S5.2.3 of the standard. The NHTSA takes the position that buses of the same design as buses specifically designed as school buses, regardless of their intended use, are school buses for purposes of Standard No. 217. They are, therefore, exempt from the emergency exit requirements of the standard as specified in S5.2.3. No amendment of the standard is necessary. SHELLER-GLOBE CORPORATION October 11, 1973 Mr. Richard B. Dyson Assistant Chief Counsel U.S. Department of Transportation Reference: Federal Motor Vehicle Safety Standard - 217 - Bus Window Retention & Release Sheller-Globe Corporation Divisions in Lima, Ohio and Kosciusko, Mississippi, manufacturers of school bus bodies, respectfully petitions the Department of Transportation for a revision in the wording of reference standard, specifically Paragraph S5.2.3 - School Buses. We petition that the wording in this paragraph be modified to read as follows: "The emergency exit requirements do not apply to school buses or buses of like design, such as Activity Buses, adapted for use for other than transportation of children to and from school, but if such buses do contain any push-out windows or other emergency exits, these exits shall conform to Paragraphs S5.3 through S.5.5". This petition is based on the fact that as body manufacturers do offer our base body design for other uses, i.e., Activity Buses for Church Organizations, YMCA Groups, Boy Scout Troops, Community Charity Organizations, etc. The Activity Buses as referred to are constructed of the same base design as what is termed a school bus. The Activity Buses may vary as to color and may be without specific school bus safety warning systems.
Presently the referenced standard, as worded, is a double standard in that it states the standard applies not to school buses but to those same buses if used for reasons other than the transportation of children to and from school. It is of our strong opinion that the standard should apply to neither school buses or buses of like design used by other organizations or that the standard should apply to all buses to include school buses. We respectfully request your expeditious ruling on this petition. If additional information is required in support of this petition, please advise. Respectfully, George R. Semark Safety Engineer - Vehicles Planning & Development Center |
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ID: nht73-5.36OpenDATE: 10/31/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Motor Coach Industries, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letter of September 5, 1973, to Mr. Schneider asking whether you may furnish side turn signal lamp for inter-city buses at the rear wheels, and if so, the required color. It is correct that there are no Federal safety requirements for side turn signal lamps. Therefore, there is no Federal prohibition against your providing such a lamp, and such restrictions as may exist would be those imposed by the States. Rear mounted turn signal lamps under Federal Standard No. 108 may be either red or amber. |
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ID: nht73-5.37OpenDATE: 10/31/73 FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA TO: Moore; Weaver; Moore & Bradberry TITLE: FMVSR INTERPRETATION TEXT: Your letter to Secretary Brinegar of October 8, 1973, has been referred to me for reply. A copy of Part 580, Odometer Disclosure Requirements, is enclosed. This disclosure regulation became effective March 1, 1973, and we assume that the August 1972 date in your letter actually refers to an August 1973 sale which would be subject to the regulation. Title 15 U.S.C. @ 1989 provides a remedy for a violation of the Act made with intent to defraud. A discrepancy between the odometer reading and the disclosure statement could be the result of error, or misunderstanding of the requirement, and by itself, would not establish an intent to defraud. We are unfamiliar with the facts in the case you mentioned, and the above statement should not be construed as an opinion or evaluation of the merits of that case. |
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ID: nht73-5.38OpenDATE: 10/31/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Bankers Trust Company TITLE: FMVSR INTERPRETATION TEXT: This is in reply to your letter of September 17, 1973, which asks whether a bank must make an odometer disclosure statement upon transfer to an auctioneer of a repossessed vehicle in which the bank has only a security interest. To the extent that the bank is acting in the place of the repossessed owner, and in the absence of any other party available to make a statement, it is our opinion that the bank is acting as transferor and should make the disclosure specified in Part 580. Normally the bank does not know that the odometer is inaccurate and should only fill in the blank with the recorded mileage. The bank could authorize its collection agency to actually make the disclosure. |
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ID: nht73-5.39OpenDATE: 11/01/73 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: Adaline R. Crocker TITLE: FMVSR INTERPRETATION TEXT: This is in response to your question about possible violations of the Motor Vehicle Information and Cost Savings Act by an owner who sells his vehicles without knowing for sure if the odometer reading is accurate. The Act and implementing regulation require you to state the recorded mileage on the odometer, and tell your buyer if you know that the recorded mileage is wrong. It appears from your letter that you have some reason to suspect the validity of the present reading. If on the basis of the facts available to you, you conclude that the reading is probably wrong, you should caution your buyer by indicating on the odometer mileage statement that the true mileage is unknown. |
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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.