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: aiam3001OpenH.X. Jackson, F.A.C.H.A., Administrator and Executive Vice-President, Valley Presbyterian Hospital, 15107 Vanowen Street, Van Nuys, California 91405; H.X. Jackson F.A.C.H.A. Administrator and Executive Vice-President Valley Presbyterian Hospital 15107 Vanowen Street Van Nuys California 91405; Dear Mr. Jackson: Thank you for your letter of March 7, 1979, concerning the computerize anti-theft device developed by the BBJ partnership.; As you know, the National Highway Traffic Safety Administration (NHTSA has been developing over the past several years an upgraded Federal Motor Vehicle Safety Standard 114, *Theft Protection*. I have enclosed a copy of the standard now in effect and our recent proposed amendment. You should be aware, however, that in response to comments this proposal may be modified prior to its issuance in final form.; The approach of the NHTSA in issuing motor vehicle safety standards i to establish minimum standards with which all manufacturers must comply. It is our hope that manufacturers will exceed these minimum standards in a way which offers the public greater protection, either throughout an entire vehicle line or by optional equipment which a purchaser may buy. your device appears to fall in this latter category.; The NHTSA does not provide evaluation or approvals of inventions, an we would be unable to advise you whether a vehicle equipped with your device would comply with Standard No. 114 without a more complete description. Based on the information you have provided, however, your device does not appear to conflict with the Standard as currently established. Should you have any specific questions in this regard after reading the enclosed material, please call (202-426-1834) or write Frederic Schwartz, Jr. of my office who will be able to assist you further. You should also be aware that if your device is meant to be installed by the owner if a vehicle after the vehicle is sold by the dealer, the Standard would not apply.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5585OpenMs. Bonnie Ward Eagle County School District RE 50J P.O. Box 740 Eagle, CO 81631; Ms. Bonnie Ward Eagle County School District RE 50J P.O. Box 740 Eagle CO 81631; "Dear Ms. Ward: This responds to your May 2, 1995, letter following u on information provided you by Charles Hott and Leon DeLarm of this agency, concerning the safety of school buses and 'over-the-road type coaches' (e.g., Greyhound-type buses). You ask for confirmation that our safety standards for school buses 'are above and beyond the requirements for over-the-road coaches.' That statement is correct. Our Federal motor vehicle safety standards (FMVSSs) apply to vehicles according to vehicle type. We have FMVSSs that apply to 'buses,' and those that apply to 'school buses.' Since a 'school bus' is a type of 'bus' under our regulations, a new school bus must meet the Federal motor vehicle safety standards that apply to 'school buses' in addition to those that apply to 'buses.' A new over-the-road coach would have to meet our 'bus' standards, but not our 'school bus' standards. We would like to emphasize the importance that our agency attaches to the use of safe buses to transport children. A school bus meeting the school bus safety standards is the safest means of transportation for school children. It may not be the most comfortable for long trips, since it lacks the reclining seats and restroom facilities of some over-the-road coaches, but it has safety features that the coaches lack, such as seat backs designed to cushion impacts, windows that prevent ejections, and exits that facilitate escape after crashes. In the years since buses began to be manufactured with these features, there has been a marked improvement in school bus safety. We urge schools and school districts to consider these features when making school transportation decisions. For your information, I am enclosing a pamphlet that gives a brief description of the FMVSSs, and an information sheet that explains how you can obtain copies of our standards. If you other questions on this or any other issue, please do not hesitate to call Deirdre Fujita of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam2240OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P. O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P. O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to several questions raised by Blue Bird Body Compan concerning the applicability of school bus safety standards to certain bus types under the newly-issued redefinition of school bus (40 FR 60033, December 31, 1975). The new definition (effective October 27, 1976) reads:; >>>'School bus' means a bus that is sold, or introduced in interstat commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.<<<; In your February 24, 1976, letter you ask whether buses utilized t transport athletic teams and school bands to and from athletic events qualify as school buses under the definition that becomes effective October 27, 1976, and, if so, whether they must therefore comply with all applicable Federal motor vehicle safety standards.; From your description of the use of an 'activity bus' to transpor students to and from athletic events related to the students' school, it would be included as a school bus under the new definition if it were sold for this use. It appears clear that the manufacturer and dealer in these cases would both be aware that the purchasing school intended to use the bus to transport students to events related to their school, such as athletic events involving school teams. In close cases, the knowledge of parties to the sales transaction would be determinative of whether the bus was 'sold. . . for purposes that include carrying students to and from school or related events. . . .' Any bus determined to be a school bus under the new definition would be required to meet all applicable standards in effect on the date of its manufacture.; Your December 16, 1975, letter asks whether transit buses that ar based on a basic school bus design must meet the requirements of Standard No. 217, *Emergency Exits*, that apply to buses other than school buses. Since receipt of your letter, the redefinition of school bus has been issued and Standard No. 217 has been amended by the addition of requirements for school buses. In answer to your question, only a bus that is sold for purposes that include carrying students to and from school qualifies as a school bus. A bus designed and sold for operation as a common carrier in urban transportation would be required to meet the requirements of Standard 217 for buses other than school buses.; Your separate question regarding the configuration of emergency exit has been answered in an earlier interpretation of the provision you question. A copy of that interpretation is enclosed.; Your March 4, 1976, letter asked whether the new definition of schoo bus includes buses that are sold for transportation of college-age students. You argued that an intent to include buses other than those for the transportation of preprimary-, primary-, and secondary-school students would go beyond the statutory definition added to the National Traffic and Motor Vehicle Safety Act by the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. S 1391(14)), and apply the standards to a broader variety of vehicles than those for which they were developed. The NHTSA finds this argument to have merit. It therefore withdraws its discussion of the breadth of the regulatory definition of school bus that appeared in the December 31, 1975, preamble. The agency will not consider buses sold for the transportation of college-age students to be school buses.; You also asked if any motor vehicle safety standard requires tha school buses by painted yellow. No motor vehicle safety standard requires yellow paint. At this time, however, Standard No. 108, *Lamps, Reflective devices, and Associated Equipment*, requires installation of warning lights, and this would entail the use of yellow paint by the operator under Pupil Transportation Standard No. 17.; In an area unrelated to school bus definition, you asked in a Februar 20, 1976, letter whether the description of vehicle roof appearing in S5.2(b) of Standard No. 220, *School Bus Rollover Protection*, applies to determination of roof size under both S5.2(a) and S5.2(b). The description is intended to apply to roof measurement under both S5.2(a) and S5.2(b).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1895OpenMr. Donald W. Segraves, Vice President, American Mutual Insurance Alliance, 20 North Wacker Drive, Chicago, IL 60606; Mr. Donald W. Segraves Vice President American Mutual Insurance Alliance 20 North Wacker Drive Chicago IL 60606; Dear Mr. Segraves: This is in response to your letter of March 19, 1975, requestin additional information on two aspects of the March 12, 1975, Federal Register notice (40 FR 11598) proposing to amend the Federal bumper standard.; Your first question relates to the proposed reduction in the number o required longitudinal pendulum impacts from 6 to 2, front and rear. According to a Transportation Systems Center report dated July 1974, an average car is involved in 4.7 low speed (5 mph or below) accidents in its 10-year or 100,000-mile lifetime. Of these, 1.25 are insurance reported, 33% of which are front or rear collisions, 1.25 are repaired but not insurance reported, 62% of which are front or rear collisions, and 2.20 are unrepaired, 38% of which are front or rear collisions. The conclusion reached in the report is that a vehicle is involved in 2.03 front or rear low-speed collisions in its lifetime.; The NHTSA has no specific information regarding reduction in weight an cost of vehicles due to the lowering of the number of pendulum impacts.; Responding to your second question, the NHTSA has not determined wha the cost-benefit trade-off would be in permitting damage to the bumper face bar components and associated fasteners. The decision to allow such damage until 1979 was based on a determination that some manufacturers needed that amount of lead time in order to produce vehicles capable of meeting the more stringent damage criteria. The proposed schedule for implementation of the surface damage criteria would not effect a lowering of the current level of bumper performance and would permit adequate time for the development of more durable bumper systems.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam0787OpenMr. Louis C. Lundstrom, Director, Automotive Safety Engineering, General Motors Corporation, General Motors Technical Center, Warren, MI, 48090; Mr. Louis C. Lundstrom Director Automotive Safety Engineering General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Lundstrom: This is in reply to your letter of July 17, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to radio speaker cones. You request clarification of an interpretation we sent to American Motors dated June 9, 1972, wherein we stated that 'stereo speaker . . . cones incorporated into a door or rear shelf would be considered part of a 'trim panel' and 'compartment shelf,' respectively.' You particularly request clarification of the phrase 'incorporated into.'; The NHTSA's position is that a speaker cone, while not generall subject to Standard No. 302 (we assume that it is not an 'energy-absorbing' component), will be subject to the standard if it is 'incorporated into' a component that is subject to the standard. We would consider a speaker cone to be 'incorporated into' a trim panel or compartment shelf if the cone forms a portion of the surface of the panel or shelf. We would not consider a speaker cone merely attached to an enumerated component, but situated wholly underneath (shelf) or behind (trim panel) its surface to be subject to the standard.; I trust this clarifies our position. Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3902OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of January 18, 1985, to Mr. Vinson o this office asking for three interpretations of Motor Vehicle Safety Standard No. 108 with respect to motorcycle lighting.; Your first question is about the location of rear turn signals. Tabl IV of Standard No. 108 requires that rear turn signal lamps on motorcycles have a minimum horizontal separation distance 'centerline to centerline' of 9 inches. You have asked whether this may be interpreted as filament center to filament center., The answer is no. The phrase means the distance from the geometric center of one lamp to the geometric center of the other.; Your second questions concerns the permissibility of an arrangement o lamps on the rear of a motorcycle. There would be a two-compartment combination stop/tail lamp on the vehicle centerline with separate combination lamps below it on either side of the centerline. The distance between filament centers of the separate lamps would be a maximum 16 inches, and there would be the same distance between the filament centers of each separate lamp and the compartment above it belonging to the two- compartment lamp. You have asked whether this is permissible if the minimum design candlepower complies with requirements for three lighted sections in SAE J585e and SAE J586c, and the effective projected luminous lens area of each compartment or lamp is at least 3 1/2 square inches. This arrangement, though unusual, appears to be acceptable. SAE Standard J586c *Stop Lamps* and SAE J585e *Tail Lamps* state that if multiple compartment or multiple lamps are used, and the distance between filament centers does not exceed 16 inches for three compartment or lamp arrangements, the combination of the compartments or lamps must be used to meet the photometric requirements for the corresponding number of lighted sections. Your design has four lighted sections, where as the SAE Tables provide values for only three. In our opinion, your design would be acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections.; Your final question concerns a combination stop/taillamp of fou sections, two each on either side of the vertical centerline. Though no distance is given for the filament centers, they appear to be closer than 16 inches. You have asked if this design is permissible provided it meets the requirements for three lighted sections, and the effective projected luminous lens area of each compartment is not less than 3 1/2 square inches. The answer is yes, this is acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2610OpenMr. James M. Beach, Director of Engineering, Collins Industries, Inc., P. O. Box 58, Hutchinson, KS 67501; Mr. James M. Beach Director of Engineering Collins Industries Inc. P. O. Box 58 Hutchinson KS 67501; Dear Mr. Beach: This responds to your May 6, 1977, question whether Safety Standard No 301-75, *Fuel System Integrity*, is applicable to all school buses or only to school buses with a GVWR greater than 10,000 pounds.; You are correct in your statement that school buses are included in th broader classification, 'buses', for purposes of the Federal motor vehicle safety standards, unless otherwise specified in a particular standard. Safety Standard No. 301-75 is applicable to passenger cars, and to multipurpose passenger vehicles, trucks and buses that have a GVWR of 10,000 pounds of less, including school buses under 10,000 pounds. The standard is also applicable to larger school buses, and the distinction is made in the standard since the large school buses are the only vehicles having a GVWR greater than 10,000 pounds that are covered by the standard.; Safety Standard No. 301-75 was made applicable to all school buse pursuant to a mandate under the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. 1392(i)(1)(A)).; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2305OpenHonorable William S. Broomfield, House of Representatives, Washington, DC 20515; Honorable William S. Broomfield House of Representatives Washington DC 20515; Dear Mr. Broomfield: This is in response to your letter of May 10, 1976, forwarding petition for reconsideration of the recently issued Part 581 bumper standard from Gulf + Western Manufacturing Company. You indicate your support of the petition and request that you be informed of any action taken by the agency concerning the bumper standard.; It is the National Highway Traffic Safety Administration's policy t issue a notice of action taken on petitions for reconsideration within 120 days after publication of the final rule, unless action within that time is impracticable. I assure you that Gulf + Western's comments and the information contained in all of the petitions for reconsideration will receive thorough consideration. The agency's response to the petitions will be published in the *Federal Register*, a copy of which will be sent as requested.; Sincerely, James B. Gregory, Administrator |
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ID: aiam0338OpenCharles O. Verrill, Jr. Patton, Blow, Verrill, Brand & Boggs, 1200 Seventeenth Street, N.W., Washington, D.C. 20036; Charles O. Verrill Jr. Patton Blow Verrill Brand & Boggs 1200 Seventeenth Street N.W. Washington D.C. 20036; Dear Mr. Verrill: #This is in reply to your letter of May 3, 1971 requesting an additional interpretation of the Tire Identification and Record Keeping Regulation. #If in fact, the vehicle manufactured is not considered a motor vehicle within the meaning of the Act and the mini-bike interpretation (34 F.R. 15416)(copy enclosed), then Part 574, the Tire Identification and Record Keeping Regulation, and section 113 (15 U.S.C. 1402) will be inapplicable. #Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam0292OpenMr. Harold Vischer, Vice President, Bandag, Incorporated, 1056 Hershey Avenue, Muscatine, IA 52761; Mr. Harold Vischer Vice President Bandag Incorporated 1056 Hershey Avenue Muscatine IA 52761; Dear Mr. Vischer: This is in reply to your letter to Mr. Hartman concerning the tir identification and record keeping regulation (49 CFR Part 574) requesting that you be allowed to code by pressure chamber rather than by matrix.; Since the pressure chamber is used by Bandag to serve a purpose simila to the purpose served by the matrix in hot processing of retreaded tires, you may assign code numbers to your pressure chambers and use this code number in place of the matrix code number required by Part 574.; Sincerely, Rodolfo A. Diaz, Acting Associate Administrator, Moto Vehicle Programs; |
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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.