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
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ID: nht90-1.58OpenTYPE: Interpretation-NHTSA DATE: February 27, 1990 FROM: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc. TO: Stephen Wood, Esq. -- Acting Chief Counsel, NHTSA TITLE: FMVSS Number 107, Reflective Surfaces ATTACHMT: Attached to letter dated 7-16-90 to Delbert N. Pier from Paul Jackson Rice; (A35; Greenbook Std. No. 107) TEXT: Hyundai requests assistance with an interpretation regarding Federal Motor Vehicle Safety Standard, Number 107 (reflective surfaces). It is Hyundai's intention to test the surface visible on the windshield wiper blade rail spring. In accordance with ASTM Designation D 523-62T, Hyundai has set up a test specimen for the specular gloss test to accomplish this, see attachment. Because of the limited amount of area (side "B") allowable for the light source to reflect into the specular reflectance meter, Hyundai is using several rail springs gathered together. As shown in the attachment, this allows for the adequate reflective surface to accomplish the test. Hyundai believes this specimen shows sound engineering judgement and is a satisfactory way to conduct this test. Hyundai is requesting an interpretation on this specimen as an acceptable means of conducting the test for establishing compliance with FMVSS, Number 107. Thank you for your assistance in this matter. Should further clarification be needed, do not hesitate to contact me at the telephone number listed above. |
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ID: nht90-1.59OpenTYPE: Interpretation-NHTSA DATE: February 27, 1990 FROM: Don James -- Contracts, Stone Bennett Corporation TO: Docket Section -- NHTSA TITLE: Re Docket No. 88-16; Notice 3 ATTACHMT: Attached to diagram of the toggle installation & envelope (graphics omitted); Also attached to diagram of control panel with auto-neutral (graphics omitted); Also attached to diagram of control panels (text and graphics omitted); Also attached to letter dated 10-12-90 from P.J. Rice (Signature by K.W. Weinstein) to D. James (A36; Std. 102); Also attached to copy of 54 FR 29042, 7-11-89 and 55 FR 1226, 1-12-90, regarding 49 CFR Part 571 and FMVSS 201 (text omitted) TEXT: The above referenced Docket concerns the FMVSS Standard No. 102 and the proposed changes as they relate to Automatic Transmissions without a Park Position. Stone Bennett Corporation has been manufacturing transmission shifting mechanisms since 1973. These mechanisms utilize pneumatics, hydraulics, or, electromotive force or any combination of the three to shift the transmission on the demand of the operato r. In all cases the transmission ranges are indicated by a series of light indicators or a sunshine readable digital display that indicates only the range selected. The method of selecting ranges is not the classic floor mounted or column mounted shift levers. Stone Bennett Corporation uses a toggle mechanism or two pushbutton switches to effect the range to range shift operation. That is, to execute a shift to an adjacent range when in the Neutral position, it will be necessary to depress a shift bu tton (push the toggle lever) to move from neutral to reverse or from neutral to drive. It is necessary to depress the pushbutton or push the toggle lever and release to allow movement through the range sequence. An example is to shift three range posit ions from drive to second in a sequence of RND321. The operator must press/release to shift to 3rd and press/release to shift from 3rd to 2nd and simarily to shift the opposite direction. The overriding purpose of this letter is to ask for a ruling on the acceptability of providing a label indicating the range sequence on the body of the shift control console. Please see the attached documents for a visual understanding of the request. Your immediate attention to this matter will be greatly appreciated. |
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ID: nht90-1.6OpenTYPE: INTERPRETATION-NHTSA DATE: JANUARY 5, 1990 FROM: HANK KMIECIK -- STEERABLE CARRIAGES TO: OFFICE CHIEF COUNSEL -- NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 3-13-90 TO HANK KMIECIK; STEERABLE CARRIAGES, FROM STEPHEN P. WOOD, NHTSA; [A35; VSA 108(A)(2)(A); 108(A)(1)(A)] TEXT: On the advice of Robert Clarke and Michael Trentacoste, I am writing to inform you of our intent to manufacture axle steering systems for tractor trailers, long bodied straight trucks, buses and special application vehicles and ask you to review the syst em and advise us if it is in compliance with the applicable DOT regulations. Description Axle Steering System The axle steering system provides a method and means for steering the rear of a tractor trailer combination by turning the wheels of the trailer to increase the maneuverability of the entire unit during turning maneuvers, parking, provide additional mane uverability in congested traffic and under close clearance conditions. This is accomplished by means of a steering apparatus comprising sections of steel beams, hydraulic cylinder/motor assembly, 2- locking pin assemblies, steering pin assembly, manifol d assembly, air reservoir, battery and control panel. The sections of steel beams used as the framework for the system are welded to one of the existing trailer axles for retrofit to an existing trailer or incorporated simply into the manufacturing process for new trailers. The steering/axle assembly is po sitioned under the trailer chassis and welded to it. The other system components are installed in their designated locations on the trailer chassis (see the enclosed illustrations) and the control panel to operate the steering system is located in the ca b on the dash panel for ease of operation by the driver. No modifications are made or required to the suspension system or the brake system of the axle. The axle steering system requires approximately 16 man hours to install by a skilled truck mechanic and helper. The system is not designed for full-time rear wheel steering at highway speeds. System Operation Assume the trailer has 2 axles on the rear. Both axles have an air suspension. The ideal setup is air suspension and lift kit on each axle. The axle steering system works with either setup, combination of or the non steering axle can be a spring axle.
For example, when the driver needs to make a right hand turn onto a congested road, the driver would bring the tractor trailer momentarily to a full stop, a short distance before the intersection and engage the axle steering system. Using the control pan el (Illegible Word) in the cab, the driver releases air from, or otherwise deactivates, the rear axle suspension system of the steering axle, effectively raising one set of rear wheels off the ground. The driver then selects the right hand turn button o n the control panel which activates a two way double acting hydraulic cylinder which applies force against the raised rear wheel steering assembly in the direction it is desired to change the orientation of the rear axle. After the steering assembly is turned in the desired direction the two locking pins are engaged into the locking hole positions on the curved beam firmly locking the axle/steering system into the desired position, air is readmitted into the rear air/axle suspension system causing the steering wheels to return firmly to the ground. Air is now released from the air/axle suspension system of the adjacent axle which raises the wheels of the adjacent axle and eliminates the ground friction they would create in making the turn. The drive r of the truck then proceeds at slow speed to make the desired turn or other maneuver with the one axle turned. After completing such turn, the vehicle is brought to a stop and the driver repeats the above procedure in reverse order, removing the steering wheels from the road surface turning the rear wheel steering assembly to the normal driving position and engag e locking pins before resuming highway travel. It takes 10-15 seconds from the time the driver stops the truck to complete the initial steering sequence and about the same time to return the axle steering system back to the locked position for normal highway travel after making the turn. Enclosed is a short video tape showing the axle steering system in action. If you require further information or a demonstration, please do not hesitate to ask. AXLE STEERING SYSTEM Steerable Carriages 1/10/90 (Graphics omitted) AXLE STEERING SYSTEM (Graphics omitted) AXLE STEERING SYSTEM (Graphics omitted) |
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ID: nht90-1.60OpenTYPE: INTERPRETATION-NHTSA DATE: MARCH 2, 1990 FROM: HENRY J. NOWAK -- MEMBER OF CONGRESS TO: GENERAL JERRY RALPH CURRY -- ADMINISTRATOR, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 3-16-90 TO BARBARA J. KELLEHER-WALSH, HARTLEY ASSOCS. INC., FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; STD. 213]; ALSO ATTACHED LETTER DATED 2-20-90 TO HENRY J. NOWAK FROM BARBARA J. KELLEHER-WALSH, AND LETTER DATED 8-2 2-89 TO DEIRDRE FUJITA, OFFICE OF GENERAL COUNSEL FROM BARBARA J. KELLEHER-WALSH. TEXT: Enclosed is self-explanatory correspondence from my constituent, Ms. Barbara J. Kelleher-Walsh. I am requesting that very careful attention and consideration be expedited in providing Ms. Kelleher-Walsh the letter of interpretation, and please provide me a written response. With best wishes and kindest regards. ENCS. |
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ID: nht90-1.61OpenTYPE: INTERPRETATION-NHTSA DATE: MARCH 5, 1990 FROM: R. W. SCHREYER -- SR. SALES ENGINEER, TRANSPORTATION MANUFACTURING CORP. TO: HARRY THOMPSON -- U.S. DEPARTMENT OF TRANSPORTATION, NHTSA TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO R. W. SCHREYER FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 12-11-89 TO FRANK BERNDT FROM JOE DABROWSKI, LETTER DATED 3-22-89 TO KEITH A. MCDOWELL FROM ERIKA Z. JONES, AND LETTER DATED 3-25-77 TO ROBERT B. KURRE, WAYNE CORPORATION, FROM FRANK BERNDT. TEXT: Mr. Max Montgomery (State of Nevada, Dept. of Prisons) will, be procuring some prison coaches. He will be specing a Type I lap belt for passengers. Since there is no Federal Safety Standard requiring this, can you provide direction on what course of ac tion we should take. (i.e. Do we design to FMVSS Section 571.210?) Also, please clarify test procedure in Section 571.210. Do all seats in the coach have to be tested simultaneously or can a single seat be tested at one time? If you have any questions, please give me a call at (505) 347-2011 extension 7511. Thank you. |
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ID: nht90-1.62OpenTYPE: Interpretation-NHTSA DATE: March 5, 1990 FROM: Jeffrey Donaldson -- Human Factors Engineer, Arcad TO: Steve Wood --Office of the Chief Counsel, NHTSA TITLE: None ATTACHMT: Attached to letter dated 10-17-90 from P.J. Rice to J. Donaldson (A36; Std. 101) TEXT: In a March 2, 1990 phone conversation with Mr. Roman Brooks, he instructed me that any questions concerning motor Vehicle Safety Standards (MVSS) 101 were to be submitted in writing to you. My inquiry is in reference to MVSS 101 and its application to the Instrument Panel Illumination Intensity Control (Dimmer Switch). Paragraph S5.1 reads as such: "S5.1 location. Under the conditions of S6, each of the following controls that is furnished shall be operable by the driver and each of the following displays that is furnished shall be visible to the driver. Under the conditions of S6, telltales are c onsidered visible when activated." Later in paragraph S5.3.3 (a): "S5.3(a) Means shall be provided for making controls, gauges, and the identification of those items visible to the driver under all driving conditions." Given these statements, the question remains, is the instrument panel illumination intensity control required to be visible to the driver under the requirements of MVSS 101? I appreciate your prompt attention to this and look forward to your response. Please feel free to contact me at (313) 458-6951 with any questions. |
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ID: nht90-1.63OpenTYPE: Interpretation-NHTSA DATE: March 6, 1990 FROM: Bev Wilson -- Head Start Director, Western Community Action, Inc. TO: Dan Giles -- Christianson, Stoneberg, Giles & Myers, P.A. TITLE: Re Head Start Busettes - Are we under Federal Law or State Law? ATTACHMT: Attached to memo dated 2-22-90 from D. Baker to B. Wilson; Also attached to letter dated 3-18-88 from R.C. Rost to Chief Council, NHTSA; Also attached to letter dated 8-26-88 from E.L. Jones to R.C. Rost; Also attached to letter dated 9-7-90 fr om P.J. Rice to D.L. Giles (A36; Std. 108; VSA 103(d)); Also attached to letter from D.L. Giles to S.P. Wood; Also attached to letter dated 3-8-90 from D.L. Giles to D. Baker TEXT: We have two 23-passenger busettes, blue with six-light warning system. Captain Roger Hess received a call from his state office to contact me to have the flashing lights removed. He told me that David Baker, Law Compliance Representative from Mankato, w ould be contacting me. I was to follow his direction on the lights but to tape over them or be cited. They are taped over. (See Mr. Baker's correspondence.) I called Minnesota Body and Equipment out of Shakopee and asked them to pay to have the lights removed, as our purchase agreement said busettes were to meet or exceed all Federal and State requirements. They said they have to put on the lights and would send me the Federal regulations they are under (enclosed). They would not pay to have the lights removed but did say in Minnesota we shouldn't use the lights. In Jackson our driver was told by the police to also have a sign added "this vehicle stops at all railroad crossings" and use the lights. In Marshall the City Attorney contacted us to have the lights removed. If we are to use the Federal warning light system and stop at railroad crossings, are our busettes to be painted yellow? Your help is appreciated. |
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ID: nht90-1.64OpenTYPE: Interpretation-NHTSA DATE: March 6, 1990 FROM: Anthony Riani; David Mitchell TO: To Whom it May Concern TITLE: None ATTACHMT: Attached to letter dated 4-4-91 from Paul Jackson Rice to DS America, Inc., Attn: Messrs. Riani and Mitchell (A37; Part 591) TEXT: We are interested in importing Volkswagon Beetles' into the United States for retail sale. We have already contacted the Environmental Protection Agency as to their requirements for importing vehicles. We have also contacted the Department of Transport ation by telephone. We were told the vehicle has to be crash tested. These tests are to confirm the speeds at which the car can withstand head-on, rear-end, and side collisions. We were also told about some other problems that were experienced by impo rters in the past. We would greatly appreciate any and all information you could send to us regarding all relevant requirements for cars being imported to the United States. We would also appreciate any information about these problems that the Departm ent of Transportation has on record. We are curious to know if documentation by Volkswagon of Mexico certifying these crash requirements can replace a crash tested vehicle or vehicles. Thank you for your help. |
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ID: nht90-1.65OpenTYPE: Interpretation-NHTSA DATE: March 8, 1990 FROM: Lloyd Bentsen -- U.S. Senator TO: Jerry Ralph Curry -- Administrator., NHTSA TITLE: None ATTACHMT: Attached to letter dated 5-25-90 To Lloyd Bentsen and From Stephen P. Wood; (A35; VSA 102(14), 108(a)(1)(a), 108(b)(1) ); Also attached to letter dated 2-12-90 To Lloyd Bentsen and From Johannah Bonewald; Also attached to letter To All Ford Ren t-A-Car System Members and From W.A. Jacques TEXT: I recently received the enclosed constituent inquiry, and I would very much appreciate your providing me with any pertinent information you might have regarding the matter. Your kind assistance is greatly appreciated. |
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ID: nht90-1.66OpenTYPE: Interpretation-NHTSA DATE: March 8, 1990 FROM: Daniel L. Giles -- Christianson, Stoneberg, Giles & Myers, P.A. TO: Dave Baker -- Department of Public Safety TITLE: Re Bev Wilson/Head Start/Marshall, Minnesota ATTACHMT: Attached to memo dated 3-6-90 from B. Wilson to D. Giles; Also attached to memo dated 2-22-90 from D. Baker to B. Wilson; Also attached to letter dated 3-18-88 from R.C. Rost to Chief Council, NHTSA; Also attached to letter dated 8-26-88 from E .L. Jones to R.C. Rost; Also attached to letter dated 9-7-90 from P.J. Rice to D.L. Giles (A36; Std. 108; VSA 103(d)); Also attached to letter dated 3-14-90 from D.L. Giles to S.P. Wood TEXT: Please find copies of the following: 1. March 6, 1990 Letter to Dan Giles from Bev Wilson. 2. Dave Baker Memorandum dated 2-22-90, with attachments. 3. U.S. Department of Transportation Letter (undated). 4. Minnesota Body Equipment Letter to U.S. Department of Transportation dated 3-18-88. After you have reviewed the enclosed documents, you will see that the Head Start director in Marshall, Minnesota appears to have good reason to be confused about the regulations she should be complying with. Could you please call so that we could discus s what actions my client should take, if any, or the manner in which any jurisdictional questions can be resolved without adverse consequences to my client. |
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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.