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: aiam2359OpenMr. John Turnbull, Celanese Fibers Marketing Company, Charlotte, NC; Mr. John Turnbull Celanese Fibers Marketing Company Charlotte NC; Dear Mr. Turnbull: This responds to your March 19, 1976, recommendation that paragrap S5.1(e) of Standard No. 209, *Seat Belt Assemblies*, be amended to clarify that the temperature specified in the resistance to light' test procedure is intended to be black panel' temperature rather than bare bulb' temperature.; The procedures outlined in Standard No. 209 for the resistance t light' test were adopted from the Bureau Standard's procedures for testing seat belts. The standard was developed by an industry and government group, which included Celanese Fibers, as a simplification and improvement of the A.S.T.M. Designation E42-64 procedure. The resistance to light' test was established to test nylon webbing, which was the standard material used in seat belt webbing at that time.; We recognize, however, that the industry now uses dacron and polyeste materials in seat belt webbing, and that the Standard 209 test procedure developed to test nylon does not give meaningful results for these new materials. Therefore, the National Highway Traffic Safety Administration does not enforce the requirements of paragraph S5.1(e) of Standard No. 209 in the case of seat belt webbing made of dacrons and polyesters, and will not until appropriate testing procedures can be developed and incorporated in the standard for these new materials.; Procedures for testing systems containing materials other than nylo are under development and we plan to initiate rulemaking to incorporate these procedures into standard(sic) 209. You should understand that our commencement of a rulemaking proceeding does not signify that the rule in question will be issued. A decision as to the issuance of the rule is made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.; We would appreciate any data you may be able to provide regardin colorfastness tests for fabrics other than nylon.; Sincerely, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam5166OpenMr. Raymond S. Byers Engineering Manager, Research, Testing, and Certification Utilimaster Motor Corporation 65598 State Road #19 P.O. Box 860 Wakarusa, IN 46573; Mr. Raymond S. Byers Engineering Manager Research Testing and Certification Utilimaster Motor Corporation 65598 State Road #19 P.O. Box 860 Wakarusa IN 46573; "Dear Mr. Byers: This letter responds to your inquiry regarding th alternate placement of a vehicle certification label in your 'Aeromate' van. I apologize for the delay in responding. As you noted in your letter, 49 CFR 567.4 requires that a motor vehicle manufacturer affix a certification label to each vehicle it makes, and permits the manufacturer to place the label in any one of the places listed in that provision. If none of the listed locations is practicable, 567.4 directs the manufacturer to suggest an alternate position for the affixed label, and to request National Highway Traffic Safety Administration (NHTSA) approval for that position. You explain in your letter that in your 'Aeromate' vehicle, the driver's door slides between an inner and outer metal panel, thus making it impossible to affix the label to the hinge pillar, door-latch post, or the door edge that meets the door-latch post. Based on the photographs you included with your letter, affixing the label to the inside of the driver's side door would be unacceptable because, when opened, the door slides between the two metal panels. Thus, when the door is in the open position, the label would be obscured from the view of any observer. You propose installing the label on the inner metal panel in front of the driver's side door opening, to the left of the driver's legs under the instrument panel, and include photographs showing the label affixed to the proposed position. You state, and your photographs appear to confirm, that the location would be visible from the driver's position, and for inspection by officials. In directing a manufacturer to put its certification label in those places set out in 567.4, NHTSA's purpose is to make these labels easy to see and read. Based on the information you supplied, the agency determines that for this particular vehicle design, installing the certification label as you propose will facilitate seeing and reading the label. On the other hand, placing the label as specified in 567.4 may not be practicable and might interfere with unobstructed viewing of the label. Therefore, on the condition that your company's label complies in all other respects with 567.4, NHTSA grants your request to install the certification label on the inner metal panel in front of the driver's door opening as shown in the photographs that you provided to us. I hope this information is helpful. If you have any further questions, feel free to contact David Elias of my office at the above address or by phone, at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1826OpenHonorable Roman L. Hruska, United States Senate, Washington, DC 20510; Honorable Roman L. Hruska United States Senate Washington DC 20510; Dear Senator Hruska: I would like to respond to your February 19, 1975, request fo consideration of Mr. R. L. Herman's views on Standard No. 121, *Air brake systems*. Mr. Herman objects that the National Highway Traffic Safety Administration (NHTSA) may have ignored the majority of comments submitted in response to its recent proposal to delay implementation of the standard, that implementation of the standard should be reconsidered by an activity other than NHTSA, and that the new brake systems may be less safe than existing systems.; Standard No. 121 was issued as a final rule in February 1971. NHTS realized that the economic situation in the automotive industry this past fall might justify a postponement of the scheduled January 1, 1975, effective date. In the short time available for review of the standard before its effective dates, the NHTSA issued a proposal, received comments, and made its decision.; NHTSA concluded that net economic benefit would not be derived fro postponement. The decision was based on evaluation of all the comments, including those concerning the standard's immediate short-term impact on the national economic picture. An important factor in this case was the imminence of the standard and the degree to which financial and employment commitments were made.; As you may know, the President has directed (by Executive Order 11821 that each Federal agency consider the inflation impact of its regulatory actions. At the time of the NHTSA decision on December 31, 1974, final criteria and procedures for implementation of the Order were not yet established. NHTSA did, however, analyze economic effects of its proposal. NHTSA has committed itself publicly to continue monitoring the effectiveness of its standard in accordance with its statutory mandate and the President's direction, with a view to identifying any modifications that would lower costs while achieving comparable levels of safety.; An independent evaluation of the standard and its implementation by th Office of the Secretary (of the Department) was recently conducted, and this study supports the NHTSA decision. A copy of a letter regarding that evaluation is enclosed, and it discusses in detail Mr. Herman's concern about the field testing of the new braking components.; Thank you for your interest in motor vehicle safety. Sincerely, William T. Coleman, Jr. |
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ID: aiam0942OpenMr. R. L. Coleman, Assistant Manager, Crawford and Company Insurance Adjusters, 4915 Augusta Avenue, Post Office Box 6473, Richmond, VA 23230; Mr. R. L. Coleman Assistant Manager Crawford and Company Insurance Adjusters 4915 Augusta Avenue Post Office Box 6473 Richmond VA 23230; Dear Mr. Coleman: This is in reply to your letter of September 19, 1972, concerning a accident involving a 1972 International tractor which you maintain was not certified by its manufacturer as complying with applicable Federal standards. You state that the accident may have been due to 'insufficient gross vehicle weight'.; The Certifications regulations (49 CFR Parts 567,568) do requir final-stage manufacturers to certify the conformity of vehicles they complete, by affixing to them a label containing information specified in the regulations. In the case of vehicles manufactured on or after january 1, 1972, the regulations require that such information include a gross vehicle weight rating, and a gross axle weight rating for each axle. These ratings are set by the manufacturer based on definitional criteria found in the regulations (S 568.3, 49 CFR S 571.3). Your definition of a 'final-stage' manufacturer, 'anyone who installs a component that is not readily attachable', is correct only if the component installation is to an incomplete vehicle.; Your letter has been forwarded to our Office of Standards Enforcement who will conduct whatever investigation is appropriate to determine whether violations of NHTSA regulations have occurred. Such an investigation does not include ascertaining the cause of any accident, or whether a particular vehicle may have been overloaded. It concerns only whether the respective manufacturers have complied with NHTSA regulations applicable to them. If you wish to know the results of this investigation when it is completed, you may write our Office of Standards Enforcement, NHTSA, or call Mr. George Shifflett of that office at (202) 426-1693.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4002OpenMr. T. Chikada, Manager, Automotive Lighting Engineering Control Dept., Stanley Electric Co. Ltd., 2-9-13, Nakamegura, Meguro-Ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakamegura Meguro-Ku Tokyo 153 Japan; Dear Mr. Chikada: This is in response to your letter of June 27, 1985, to the forme Chief Counsel of this agency, Frank Berndt, asking for an interpretation regarding Figure 4-1 of Motor Vehicle Safety Standard No. 108.; With reference to a two- lamp system headlamp with two reflectors, yo have asked which of three specified Points should be regarded as the 'center of aiming pattern' within the meaning of Figure 4-1. The answer is Point B, the center of the bulb for the lower beam. NHTSA provided a clarification of this in the final rule permitting two-bulb replaceable bulb headlighting systems, published on May 22, 1985. I enclose a copy for your information. In it, the agency remarked that 'NHTSA expects the aiming pads to be located on the optical axis of the lower beam portion of the headlamp when only one light source is used for the lower beam.'; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam1200OpenMr. Stan Haransky, Associate Director, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Associate Director Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This is in reply to your letter of July 6, 1973, forwarding to us letter from Mr. Jim Finley of the Hughes Tool Company. Mr. Finley describes two situations, requesting an opinion on the applicability of NHTSA requirements to each of them.; The first question is whether an earth auger body that is mounted o crane carrier will conform to the Certification regulations (49 CFR Part 567) if the vehicle exceeds its stated weight ratings when a derrick is mounted on the vehicle but a permanent metal plate is also affixed to the vehicle which states: 'The GVWR and GAWR require that the derrick be removed before operating this vehicle upon a public highway.'; We do not believe such a label may be used to bring a vehicle int conformity with the Certification regulations. Both 'gross vehicle weight rating' and 'gross axle weight rating' call for a rating set by the manufacturer, but each is intended to reflect a fully-loaded vehicle or axle condition as vehicle is likely to be used. Although your letter is not explicit in this regard, if it is a reasonable expectation that the vehicle will be operated on the public highways with the derrick mounted on it (but for the label), even though the derrick is 'removable', we would not consider the weight ratings to be consistent with the regulations if they do not take into account the weight of the derrick.; Similarly, the components used in the manufacture of the vehicle shoul be of sufficient strength to carry the derrick when the vehicle is in motion. On the other hand, if it is unreasonable to expect the derrick to be attached to the crane carrier when the carrier is operated on the highway, the weight ratings need not take into account the weight of the derrick. In neither case, however, would the label you illustrate affect the conformity of the vehicle to the regulations, in the former case the label does not correct the incorrect weight ratings, and in the latter case, the label is unnecessary,; Your second question is whether Federal regulations regarding lightin may be met if the rear lights of a truck-mounted earth auger utilize hinged covers that are intended to protect the lights during boring operations. You state that when the vehicle is operated, the cover is secured to expose the lights. You ask if we recommend the use of a warning sticker in the cab to remind the driver to open the covers.; The use of these covers is not prohibited by the Federal lightin standard, Federal Motor Vehicle Safety Standard No. 108, 'Lights, Reflective Devices, and Associated Equipment' (49 CFR 571.108). We thInk the idea of a warning sticker in the cab is nonetheless a good one.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3728OpenMr. Buck Burwell, Vice President, Merchant's, Inc., 9073 Euclid Ave., Manassas, VA 22110; Mr. Buck Burwell Vice President Merchant's Inc. 9073 Euclid Ave. Manassas VA 22110; Dear Mr. Burwell: This responds to your recent letter to Mr. Kratzke of my staff, askin questions about a group of trucks tires you wish to sell. Specifically, your company received a large shipment of truck tires from Tong Shinn Chemical Company in Korea. Some of those tires did not have the D.O.T. symbol and other information labelled on the sidewall, as required for all new truck tires by Safety Standard No. 119, *New pneumatic tires for motor vehicles other than passenger cars (49 CFR S571.119). Your company tried to return the tires to the Korean manufacturer, because tires which do not meet the requirements of Standard No. 119 may not be legally sold in this country. However, the Korean manufacturer has gone out of business, leaving your company with $15,000 worth of tires which may not be sold legally in this country unless appropriate information is labelled on the sidewalls.; You indicated in your letter that you would be willing to label th appropriate information onto the sidewalls of the tires. Tong Shinn has indicated that those tires are of the same quality as the tires it shipped to you with the DOT markings. Further, you indicated that your company would be willing to store the names and addresses of the purchasers of these tires, in the event a safety-related recall is necessary. After considering these facts and representations, I believe you may label the tires with the necessary information and sell them, provided that you get some more information from the Korean manufacturer.; This agency has previously allowed the marking of truck tires by party other than the manufacturer in only one instance. That case, which also involved imported truck tires, included four factors which led the agency to make an exception to the policy that only a tire manufacturer can label the necessary information on the sidewall of the tires. Those factors were:; >>>(1) The manufacturer certified that the unmarked tires met th requirements of Standard No. 119, except for the labelling requirement,; (2) The manufacturer provided the appropriate information to b labelled on the tires,; (3) The manufacturer agreed to be responsible for the tires in th event of a safety-related recall, and; (4) The manufacturer agreed that the marking method to be used by th importer would not weaken the tires and destroy their compliance with Standard No. 119.<<<; In this case, Tong Shinn has already provided the first item liste above. It will be necessary for you to contact Tong Shinn to learn what information should be labelled on the tires for purposes of section S6.5 of Standard No. 119 (copy enclosed) and also the appropriate codes and information for the tire identification number, which must be labelled on the sidewalls of the tires per 49 CFR 574, *Tire Identification and Recordkeeping* (copy enclosed). Please furnish Mr. Kratzke with a copy of the information you receive from Tong Shinn on this subject.; As to the third item above, you indicate that your company would b willing to be responsible for the tires in the event of a safety- related recall. To do so, it will be necessary for your company to record the names and addresses of the purchasers of these tires, and store that information for a three year period. For further information on the responsibilities you will have to undertake, see section 574.7 for tire registration requirements for tire manufacturers.; It will also be necessary for you to contact Tong Shinn and explain ho you propose to mark the information of the sidewalls of these tires, and get them to agree that this method of marking the tires will not affect their compliance with Standard No. 119. Again, please furnish a copy of that agreement to Mr. Kratzke of this office.; After you have received this additional information, this agency has n objection to your company marking the tires and selling them. Please understand that this is permitted only because of the unique circumstances of this particular situation, and that if the Korean manufacturer had not gone out of business, you would not be allowed to mark these tires. However, in these circumstances, some flexibility in the requirements is necessary to help you avert a financial loss, while maintaining the necessary safety assurances for purchasers of these tires. If you have any further questions or need additional information, please contact Mr. Steve Kratzke of my staff at (202) 426- 2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1715OpenMr. Randall D. Bartlett, 225 Ginger Drive, Auburn, CA, 95603; Mr. Randall D. Bartlett 225 Ginger Drive Auburn CA 95603; Dear Mr. Bartlett: This is in reply to your letter of November 27, 1974, asking about th legality of rectangular headlamps, particularly with respect to the aftermarket.; Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflectiv Devices and Associated Equipment*, permits the use of a four-headlamp system with rectangular lenses of specified dimensions (approximately 4-1/4 by 6-1/2 inches), on vehicles manufactured between January 1, 1974, and August 31, 1976. The standard also permits manufacture of replacement headlamps for this system for sale in the aftermarket. The standard does not allow rectangular headlamps of other sizes, or a two-headlamp system, either as original equipment or for sale in the aftermarket.; I enclose a copy of that portion of Standard No. 108 covering th rectangular headlamps.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0807OpenMr. Charles R. Matthews, Sr. Safety Engineer, Oshkosh Truck Corporation, P. O. Box 560, Oshkosh, Wisconsin 54091; Mr. Charles R. Matthews Sr. Safety Engineer Oshkosh Truck Corporation P. O. Box 560 Oshkosh Wisconsin 54091; Dear Mr. Matthews: This is in response to your letter of July 5, 1972, requesting a opinion as to how manufacturers may take into account a vehicle's speed capability in establishing GAWR.; The Certification regulations do not specify particular speed criteri for establishing weight ratings. As a minimum, however, we believe the speed chosen should reflect the maximum speed at which it is reasonable to expect the vehicle to be driven. In the case where a vehicle is subject to some low-speed uses, such as seasonal sue as a snow plow, we believe the figure on the certification label should be based on that use of the vehicle in which its expected speed is greatest. The regulations do not provide for variable ratings based on speed.; Finally, you ask whether cautionary labels dealing with GAWR and GVW figures may be installed in the cab. The NHTSA does not object to the use of such labels. They may be used, as appropriate, to indicate permissible use of higher loads in low-speed applications.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4517OpenMr. Peter Cameron-Nott 90 Horace Street Stratford, CT 06497; Mr. Peter Cameron-Nott 90 Horace Street Stratford CT 06497; Dear Mr. Cameron-Nott: This is in reply to your letter of June 1, 1988 with reference to importation of motor vehicle equipment included in an incomplete vehicle. You have stated that the kit will include brake hoses, brake fluid, and glazing, and that these items will conform with Motor Vehicle Safety Standards Nos. 106, 116, and 205 respectively, and that they will all carry the DOT symbol certifying compliance. You ask whether these items may be entered under Box 2 on the HS-7 importation form. The answer is yes. Box 2 (implementing l9 C.F.R. 12.80(b)(l)(ii)) allows importation without bond of motor vehicles and equipment manufactured to conform with, and certified as conforming to, all applicable Federal motor vehicle safety standards. Sincerely, Erika Z. Jones Chief Counsel; |
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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.