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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



Displaying 13741 - 13750 of 16510
Interpretations Date
 search results table

ID: nht70-1.1

Open

DATE: 04/30/70

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: David Sugarman, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of April 16 I enclose copies of Federal Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, "SAF Technical Reports Referenced in Federal Motor Vehicle Safety Standards".

The answer to your first question is that Standard No. 108 requires passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle "as far forward as practicable", and one marker and one reflector, red in color, on each side of the vehicle, "as far to the rear as practicable" Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two, was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverd; displayed at the recent New York show were number and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standards applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.

In answer to your second question, Table III of Standard No. 108 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.

You have asked in your third question whether headlamps may be placed in the grill. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.

Standard No. 107 does not specify a particular color for the horn ring and hub of the steering assembly but it does specify a maximum permissible value for specular glass.

Finally, other than Standard Nos. 205 (Glazing Materials) and 212 (Windshield Mounting) which all passenger cars must meet, there is no "specific safety requirement as to the windshield" for convertibles, and there is no "requirement as to a roll bar".

Sincerely,

Enclosures April 16, 1970

U.S. Department of Transportation Federal Highway Administration

Re: F.H.W.A. Temporary Exemption

No. 69-9 issued to Automobile

Monteverdi Ltd.

September 9, 1969 expiring

August 1, 1971

Gentlemen:

I represent Automobile Monteverdi Ltd. of Switzerland. In furtherance of my letter of April 9, 1970 requesting certain information as to the above, will you inform me as to the following:

1-a)Is there a safety standard requirement with regard to lights on the side of the automobile (front and/or back); if so, is it a requirement for a light or may it be a reflector?

b) Whether it is a requirement for a light or a reflector, is there a requirement as to its size or shape?

2. With regard to rear lights, brake, safety stop and blinker; is there a specific requirement as to the color of such lights, may they be red or orange etc?

3. With regard to headlights, may the manufacturer place headlights in the grill on a two seater model and a convertible model?

4. With regard to the steering wheel is there a specific requirement that the cross bar of a steering wheel be a particular color e.g. black or grey? I know that it may not be chromed.

5. With regard to a convertible model, is there a specific safety requirement as to the windshield, and is there any requirement as to a roll bar?

I would appreciate hearing from you.

Very truly yours,

David Sugarman

ID: nht70-1.10

Open

DATE: 05/22/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Micro Machinery Products

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your comments and suggestions contained in your April 23, 1970, letter to Mr. Douglas Toms concerning motor vehicle Safety.

In your letter, you ask that the Bureau clarify whether a dealer who sells "Micro-siped" tires that do not comply with Standard No. 109 would be subject to a civil penalty. Section 108(a) of the National Trafic and Motor Vehicle Safety Act of 1966 (15 U.S.C.et seq.) prohibits any person from manufacturing for sale, selling or offering for sale any item of motor vehicle equipment unless it is in conformity with Federal Motor Vehicle Safety Standards. The prohibitions specified in the Act, do not apply after the first purchase in good faith for purposes other than resale (108(b)(1)). Therefore, if a dealer offers for sale or sells new tires that have been micro-siped and those tires do not comply with Standard No. 109 he would be subject to a civil penalty of up to $ 1,000 for each tire that did not comply. This penalty provision would not be applicable, however, if the tires to be micro-siped are owned by the user of the tires.

It is noted for your information that section 569.7(c) of the Regrooved Tire Regulation (formerly 369.7(c), copy enclosed) prohibits the sale, offer for sale, or introduction in interstate commerce "siped tires produced by cutting the tread surface of a regrooved or regroovable tire without removing rubber, if the tire cord material is damaged as a result of the siping process, or if the tire is siped deeper than the original, retread, or regrooved groove depth."

Your interest in the motor vehicle safety program is greatly appreciated.

ID: nht70-1.11

Open

DATE: 12/17/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Northeast Kentucky Area Development Council, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1970, to Mr. Lowell K. Bridwall, Administrator, Federal Highway Administration, asking for a definition of "blemished," "second," and "form use only," which has been referred to this office for reply.

Tire manufacturers are required to certify that their product complies with the Federal Motor Vehicle Safety Standard No. 109, and do so by labeling each tire they certify with the symbol "DOT." Tires that are certified by the manufacturer and marked "seconds" are not necessarily unsafe, as the "second" may be due to a cosmetic defect not affecting the tire's performance.

Sometime a tire manufacturer will make a tire that he believes is defective in a way that affects the safety of the tire. Often, that manufacturer will mark the tire "farm use only" or "non-highway use" and then sell it. In such instances, he is required to remove the DOT symbol.

We do not have a definition for "blemished."

We have enclosed a copy of an amendment to the passenger car tire standard (No. 109) that contains the definition for "non-highway use tires" which is applicable to "farm use only," and "tire identification and recordkeeping" which is applicable to "manufacturer's marks on tires."

Thank you for your interest in the Motor Vehicle Safety Program.

ID: nht70-1.12

Open

DATE: 10/29/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Atlas Supply Company

TITLE: FMVSS INTERPRETATION

TEXT: Reference is made to your letter of October 8, 1970, requesting an increase in the maximum permissable overall width of the "78" series belted bias passenger car tires covered by Table I-J, Appendix A, of MVSS 109.

The dimensional requirements specified in MVSS 109 for passenger car tires are the result of a rule making action in which the tire industry and other interested persons participated. Tire section width and overall width were permitted to exceed the specified section width dimensions by 7% to accommodate differences in manufacturing tolerances, design practice, tire growth patterns when inflated, and to provide for sidewall decorations and protective ribs.

The allowance of 7% is considered the maximum desirable for dimensional uniformity and interchangeability among tires of the same size produced by different manufacturers. For this reason, we cannot give favourable consideration to your request at this time.

ID: nht70-1.13

Open

DATE: 04/30/70

FROM: AUTHOR UNAVAILABLE; Frances Armstrong; NHTSA

TO: Clements, McClellan and Hawley

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1970, to the Director, National Highway Safety Bureau, that has been referred to this office.

The type of information requested under items 1 and 2 of your letter can be extracted, within the limitations of the tests conducted, from the enclosed test result summaries. However, it should be recognized that the scope of the Bureau's testing program is such that valid statistical inferences relating to industry-wide rates or tire defects or failures are not possible with the limited data available.

Prior to the adoption of the labeling requirement in Federal Motor Vehicle Safety Standard No. 109, tires could be identified by manufacturer. This was an industry practice, involving the use of serial number systems and was not required by Government regulation nor was the coding used readily available to the general public.

We trust this and the enclosed publications will answer your questions. We will be pleased to answer any additional questions.

Thank you for your interest in the programs of the National Highway Safety Bureau.

ID: nht70-1.14

Open

DATE: 05/18/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Calhoun & Phelan

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of April 29, 1970, to the National Commission on Products Safety, that has been referred to this office.

In your letter you ask for our advice as to whether or not there are any accepted standards for passenger car automobile tires such as weight and size limits. We do have standards for passenger car tires such as weight limit versus ply rating and there are accepted tests to determine the reliability of tires. Federal Motor Vehicle Safety Standard No. 109 has been established for that purpose. The Standard's requirements are for labeling, which includes maximum inflation pressure and maximum load rating, strength, continuous load-carrying endurance and high speed performance under load.

Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims - Passenger Cars, requires, among other things, a placard, permanently affixed to the glove compartment door or an equally accessible location. The placard must contain all of the information spelled out in Part S.4.3 of that Standard, a copy of which is contained in the enclosed booklet on page 19. Tire labeling requirements along with test procedures are listed under Federal Motor Vehicle Safety Standard No. 109, on pages 12 through 19.

The tire to which you refer is a 2-ply 4-ply rated tire. The load ratings for a 855-14 tire can be found on page 15 of the enclosed booklet. The maximum load rating is 1,770 lbs. at the maximum inflation pressure of 32 p.s.i.

It is important for you to note that the test procedures have to do with new tires. We have no procedures for testing tires that have failed.

Although we do not become involved in private litigations, there is a publication for sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402, under the title, "Automobile Accident Litigation - A Report to the Federal Judicial Center to the Department of Transportation," that might be of interest to you. The price for the publication is $ 2.75.

We are also enclosing the following publications:

The National Traffic and Motor Vehicle Safety Act of 1966

Summary of 1968 Compliance Tests Arranged by Standard, that includes a General 855-14 tire and, a form letter explaining the Bureau's position relative to test results and where they might be obtained.

We trust this information will be useful to you.

ID: nht70-1.15

Open

DATE: 10/01/70

FROM: C. A. Baker for R. H. Compton; NHTSA

TO: Barrington Homes of Florida, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 14, 1970, to Mr. Rodolfo A. Diaz, Acting Associate Director for Motor Vehicle Programs, National Highway Safety Bureau concerning clearance lights on mobile homes.

A mobile home moved on its own wheels is a "motor vehicle" under the National Traffic and Motor Vehicle Safety Act, and is categorized as a "trailer".

Federal Motor Vehicle Safety Standard No. 108 requires clearance lamps to be installed on trailers 80 or more inches in overall width. In transit a mobile home towed on its own wheels must therefore be equipped with clearance lamps; however, these lamps may be temporarily installed and removed when the mobile home has reached its destination.

We would appreciate your providing us, if possible, with the names of manufacturers of mobile homes whom you believe to be towing these vehicles without equipping them with lighting devices meeting Standard No. 108. This will assist us in our efforts to insure that all manufacturers meet their obligations under the Act.

ID: nht70-1.16

Open

DATE: 08/01/70 EST

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Transelex Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 5 discussing your "new type of warning beacon' for use on emergency vehicles.

The photometric test action of SAE Recommended Practice J845,(Illegible Words) Emergency Warning Lamp refers to both "lamps flashed by rotation or oscillation" and lamps flashed by current interruption". The letter phrase appears to cover the Transelex lamp as you have described it, and we interpret J845 as applicable. Our interpretation would seem to answer your question on AAMVA approval.

Current Federal lighting requirements do not cover warning lamps, and even if they did, no Department of Transportation approval would be required. Under the National Traffic and Motor Vehicle Safety Act of 1966 it is the manufacturer of motor vehicles or equipment to which a standard applies who certifies compliance with that standard.

Sincerely,

ID: nht70-1.17

Open

DATE: 03/17/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: The Auto Sun Products Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 13 indicates that your understanding of the regulatory situation is correct. There is no prohibition in the motor vehicle safety standards against the sale of a non-conforming attachment bolt as a separate item. All that Standard No. 209 requires is that the seat belt assemblies which your firm supplies must be accompanied by conforming attachment bolts.

Before you act on your understanding, however, you should give special consideration to the consequences of any widespread use of attachment bolts which do not conform to the strength and other requirements of the standard. If, for example, we found that vehicle owners were being induced to secure their aftermarket seat belts to anchorages by the use of attachment bolts that do not provide adequate strength in crash situations, we would be compelled to consider whether the public interest would require rulemaking action aimed at preventing the marketing of such understrength bolts. We appreciate your desire not to evade the regulations or take advantage of what may be considered a loophole in them.

Sincerely,

ID: nht70-1.18

Open

DATE: 04/01/70 EST.

FROM: Lawrence R. Schneider; NHTSA

TO: Motion Development

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 23 requesting confirmation that vehicles with a curb weight of 1,000 pounds or less are not required to meet Federal motor vehicle safety standards.

As Mr. Vinson of my staff informed you, 49 CFR @@571.7(a) requires conformance to Federal standards of "motorcycles and trailers regardless of weight and...all other motor vehicles over 1,000 pounds curb weight." Thus your dune buggy with a "weight" of 385 pounds appears to be exempt from the Federal standards.

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.