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: aiam1337OpenMr. Mel Aanerud, Manager, Reservation Business Enterprise, Star Route, Box 116, Vineland, MN 56359; Mr. Mel Aanerud Manager Reservation Business Enterprise Star Route Box 116 Vineland MN 56359; Dear Mr. Aanerud: This is in reply to your letter of November 16 concerning a definitio of 'steady burning' lamps.; Our definition of 'steady' is 'regular, uniform, not changed, replace or interrupted, not fluctuating or varying widely.' Stop lamps activated by the Pulsating Safety Brakelite would therefore not be 'steady burning.'; Thank you for your interest in highway safety. Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam4135OpenMr. Takeshi Tanuma, Nissan Research & Development, Inc., P.O. Box 8650, Ann Arbor, MI 48104; Mr. Takeshi Tanuma Nissan Research & Development Inc. P.O. Box 8650 Ann Arbor MI 48104; Dear Mr. Tanuma: Thank you for your letter of February 5, 1986 (ref. W-141-H) concerning the application of Standard No. 201, *Occupant Crash Protection in Interior Impact*, to an inside door 'pull-handle.' You explained that the pull-handle is made of unpadded plastic and does not have a hard inside frame. The drawing provided in your letter shows that the pull-handle is 7.44 inches (186 mm) long, 1.12 inches (28 mm) wide, and projects 1.09 inches (27 mm) from the side of the door. I hope that the following discussion answers your questions.; You first asked if the armrest requirements of S3.5 of the standar would apply to the pull-handle if it is located within the pelvic impact area of either the front or rear passenger door. In determining whether the requirements of S3.5 apply to the structure, the agency has looked at the design and location of the structure, to determine whether it is an armrest (see, for example, the agency's interpretation letter of September 21, 1983, to Mr. Suzuki of your company.). In this case, the pull-handle projects far enough from the side of the door so that it could be used to rest the arm. Further, if the pull-handle were located in the pelvic impact area, it is likely to be used to rest the arm. Thus, we would consider such a pull-handle located in the pelvic impact area to be an armrest which must meet the requirements of S3.5 of the standard.; You also asked if the pull-handle would have to meet the requirement of S3.5 of the standard if it were located outside of the pelvic impact area at the upper portion of the door. In a conversation with Mr. Oesch of my staff, Mr. Hayaski explained that the pull-handle would probably be located near the rearmost edge of the door. In this case, it appears that the pull-handle would be positioned above and to the rear of where occupants would normally be expected to rest their arms. Thus, we would not consider a pull-handle located in the upper portion of the door and near the door's rear edge to be an armrest.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0875OpenShigemitsu Morita, General Manager, Daicel Ltd., New York Liaison Office, 200 Park Avenue, New York, NY, 10017; Shigemitsu Morita General Manager Daicel Ltd. New York Liaison Office 200 Park Avenue New York NY 10017; Dear Mr. Morita: This is in reply to your letter of September 15, 1972, to Mr. Jerome A Palisi, requesting information concerning the application of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to various components of vehicle occupant compartments made of plastic or plastic and metal.; The components that must meet the requirements of the standard ar listed in paragraph S4.1. Some of the components you have asked about are covered by the standard and others are not. Dashboards and instrument panels are considered to be 'front panels' and are therefore covered. Steering wheels normally are 'designed to absorb energy ... in the event of a crash' and, in that case, are covered. The components not covered specifically are handles of handbrakes, meter housings, steering column covers, console boxes, and handle knobs to open and shut windows. These components, such as console boxes, will nevertheless be covered to the extent that they contain materials 'that are designed to absorb energy on contact by occupants in the event of a crash.' We cannot identify what you mean by 'change lever knobs' and, therefore, we cannot comment on this component.; You also ask whether finished or unfinished components should be teste according to the procedures described in S5 of the standard, and what kind of specimens should be prepared for plastic components with metal insertions. The standard does not apply to intermediate or unfinished materials, and compliance testing by the Government is carried out with components removed from motor vehicles that have been marketed. Test specimens should be prepared according to S5.2.1 of the standard regardless of the materials that are present in a given component.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2848OpenMs. Anna Racanelli, Assistant General Manager, Nippondenso Company, Ltd., 16 Henderson Drive, W. Caldwell, NJ 07006; Ms. Anna Racanelli Assistant General Manager Nippondenso Company Ltd. 16 Henderson Drive W. Caldwell NJ 07006; Dear Ms. Racanelli: This is in reply to your letter of August 10, 1978, to Mr. Vinson o this office requesting confirmation of interpretations of Paragraph S4.7 of Motor Vehicle Safety Standard No. 108.; This confirms your interpretations. Paragraph S2, *Application* states the coverage of the standard: t specified vehicle types 'and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies' i.e. those vehicles manufactured on or after January 1, 1972. The equipment items listed in Tables I and III are required motor vehicle lighting equipment, and any item manufactured as a replacement for one of these items that has been original equipment on 1972 or later model vehicles, must meet Standard No. 108's requirements and be so certified.; Paragraph S4.7 allows certification by means of a DOT symbol placed o the item itself. No specific design or size is required. The manufacturer may certify by other means as well, specifically those set forth for all equipment items covered by a standard, in Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403): 'a label or tag on [the] item or on the outside of a container in which such item is delivered'. We would view an indelible stamp on the container as 'a label' within the meaning of Section 114 if Nippondenso wished to certify by this means.; I have no other suggestions regarding use of the DOT symbol, excep that it should be of a size and in a location sufficient to readily identify the item as meeting Federal requirements, thereby avoiding any possible misunderstanding.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1767OpenMr. R.W. Hildebrandt, Group Director of Engineering,Bendix Heavy Vehicle Systems Group,901 Cleveland Street,Elyria, Ohio 44035; Mr. R.W. Hildebrandt Group Director of Engineering Bendix Heavy Vehicle Systems Group 901 Cleveland Street Elyria Ohio 44035; Dear Mr. Hildebrandt:#This responds to your letter of January 17, 1975 requesting confirmation if a telephone discussion between Mr. R.J. Clifford of Bendix and Mark Schwimmer of this office, concerning the effective dates and labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. Your letter posed several questions and suggested their answers. The answers which you have presented represent correct interpretations of Standard No. 106-74.#Please Forgive our delay in responding to your request of October 1, 1974, for an interpretation of the term 'manufacturer of the hose assembly' as used in S5.2.4(b) of the standard. The NHTSA is aware of the problems which you have pointed out, and the issue will be dealt with in a forthcoming notice in the Federal Register.#Your truly,Richard B. Dyson,Acting Chief Counsel; |
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ID: aiam4565OpenMr. Clarence M. Ditlow III Executive Director Center for Auto Safety 2001 S Street, NW Suite 410 Washington, DC 20009; Mr. Clarence M. Ditlow III Executive Director Center for Auto Safety 2001 S Street NW Suite 410 Washington DC 20009; "Dear Mr. Ditlow: This responds to your most recent letter to m concerning retrofitting of cars originally equipped with rear seat lap belts with rear seat lap/shoulder belts. In my November 1, 1988 letter to you, I explained that we have sought the voluntary cooperation of manufacturers to make retrofit kits available for those customers who desire them and that the vehicle manufacturers have responded positively to our efforts. I also explained that the fact that retofit kits are not available for all model lines produced by each manufacturer does not suggest some failure on the part of the vehicle manufacturers or of our policy to encourage the manufacturers to make such retrofit kits available. In a November 7, 1988 letter, you asserted that my November 1 letter 'reflects such callous disregard and ignorance of the facts as to defy belief that you are doing little more than covering up for a GM policy that will kill rear seat passengers.' You stated that you would welcome a 'substantive response' to this letter. I am happy to be able to give you such a response. Let me begin by emphasizing that the lap belts in the rear seat of most vehicles on the road today are effective in reducing the risk of death and injury in a crash. Based on our analysis of a number of crash data files, we estimate that rear seat lap belts saved about 100 lives and prevented over 1500 serious injuries in 1987 alone. These figures would have been substantially higher if more rear seat occupants used their lap belts. In fact, if everyone had worn their rear seat lap belts each time they rode in a vehicle, those belts would have saved about 660 lives and prevented more than 10,000 serious injuries in 1987 alone. These facts illustrate that the fastest and most effective way to save the greatest number of lives and prevent the greatest number of injuries is to convince the public to use the safety belts, including the rear seat lap belts, that are in their vehicles every time they ride in those vehicles. Because of these facts, I do not accept your assertion that GM's policy of not providing rear seat lap/shoulder belt retrofit kits for a few of their past models will 'kill people.' To the extent that reckless assertions like this tell the public that they should not wear their rear seat lap belts, it is unfortunate that you have chosen to divert attention away from the overriding issue of convincing the public to use their safety belts, and instead chosen to mislead the public about the quality of their safety belts. Even though lap belts have been proven to be effective in reducing the risk of death and injury in a crash, we agree that properly designed lap and shoulder belts have the potential to offer even greater crash protection than lap belts alone. For this reason, we have proposed to require that all new passenger cars sold in the United States be equipped with rear seat lap and shoulder belts beginning in the 1990 model year. Additionally, we have actively sought the car manufacturers' cooperation in providing retrofit kits to interested consumers. As you may know, every domestic manufacturer and many foreign manufacturers now offer retrofit kits for many of their vehicle models. You objected to General Motors' (GM) statement in its Information Bulletin that retrofit kits are not offered for its 1978-88 Oldsmobile Cutlass, Buick Regal, Chevrolet Monte Carlo, or Pontiac Grand Prix, 'because GM safety engineers have concluded that in these cars, a rear seat lap/shoulder belt combination would not enhance the safety offered by the lap belt alone.' You asserted that since Leonard Evans, a GM employee, has concluded that lap/shoulder belts are significantly more effective than lap belts and since the National Highway Traffic Safety Administration (NHTSA) is proposing to require rear seat lap/shoulder belts, there is no 'possible scientific basis' for GM's conclusion. NHTSA's proposal reflects our tentative conclusion that rear seat lap/shoulder belts that are designed and installed at the factory have the potential to offer even greater crash protection than lap belts alone for vehicles in general. However, any particular vehicle model's floor pan design, seat stiffness, and seat design (as it relates to occupant posture) can affect the possibility of an occupant submarining under a lap/shoulder belt system in a crash. During the design and production of the vehicle, the vehicle manufacturer can take these factors into account to minimize the likelihood of such submarining and its associated consequences. However, this is emphatically not true for vehicles that were not originally engineered and designed to use rear seat lap/shoulder belts as original equipment. With respect to these vehicles, the effectiveness of a retrofitted rear seat lap and shoulder safety belt system may well depend on the belt system's compatability with the vehicle and the installation of the belt system. The suitability of a particular vehicle for retrofitting is therefore a complex question. It is our view that the judgment as to whether a retrofit lap/shoulder belt system should be installed in a particular vehicle is best made by a vehicle manufacturer, which is most familiar with the detailed seat and structural design and crash performance of the car. I hope this information is helpful. Please let me know if you have any further questions or would like some additional information on this subject. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam2262OpenMr. Michael J. Murphy, President, National Automobile Theft Bureau, 390 North Broadway, Jericho, NY, 11753; Mr. Michael J. Murphy President National Automobile Theft Bureau 390 North Broadway Jericho NY 11753; Dear Mr. Murphy: This is in response to your letter of January 8, 1976, concernin 'track sheets' and 'autotels.'; Section S4 of the Federal Motor Vehicle Safety Standard No. 302 *Flammability of Interior Materials*, lists those components of a motor vehicle that must comply with burn resistance requirements. I have enclosed a copy for your information. An 'autotel' under the back seat, between the frame and the body, or pasted to the top of the gas tank does not fall within the ambit of the standard. Consequently, it is our view that this most important and effective deterrent to vehicle theft is not discouraged by any existing motor vehicle safety standard.; The National Highway Traffic Safety Administration has proposed tha Standard No. 302 be amended to include all materials exposed to the occupant compartment air space. If this amendment is adopted, an 'autotel' under the seat presumably would fall within the purview of the standard. In this case, the 'autotel' could not burn at a rate of more than 4 inches per minute. We believe that this would not prove an impediment to the continuation of the 'autotel' program as a flame-retardant paper is readily available.; If I can be of further assistance in this matter, please do no hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam2798OpenMr. Robert B. Kurre, Wayne Corporation, P.O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Wayne Corporation P.O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your February 28, 1978, letter asking whether portion of your van-type school bus have to comply with the head protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*. You enclosed pictures showing portions of the bus designated in pink and yellow and question the standard's applicability to them.; The head protection zone requirements do not apply to portions of th school bus that are considered part of the bus sidewall. The National Highway Traffic Safety Administration considers the sidewall to include those surfaces that run parallel to the outboard edge of a forward facing seat. Accordingly, the portions of your bus designated in yellow in the pictures need not comply with the requirements since they are part of the bus sidewall structure. The pink portions of your photographs represent part of the bus structure that is perpendicular to the bus sidewall. The NHTSA does not consider them to be part of the bus sidewall structure. Therefore, since they fall within the head protection zone they must comply with all of the requirements applicable to that zone.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2632OpenMr. William F. Cox, President, Cox Trailers, Inc., Grifton, NC 28530; Mr. William F. Cox President Cox Trailers Inc. Grifton NC 28530; Dear Mr. Cox: This is in reply to your letter of July 7, 1977, informing us of you wish to relocate combination stop, tail, turn signal and side marker lamps 'to the upper rear fender' of the boat trailers that you manufacture. You have asked whether this location complies with the requirements of Standard No. 108.; I am sorry that we cannot give you the interpretation you seek Standard No. 108 requires that rear side marker lamps be mounted 'as far to the rear as practicable,' and stop, tail, and turn signal lamps must be mounted 'on the rear.' Even though, in your opinion, at your planned fender location 'the lights will pass all of the required photometric and visibility requirements', when the trailer is carrying a boat the lamps are more likely to be visible 'on the rear.' (sic) as the standard requires.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3920OpenMr. Troy C. Martin, Specifications Chief, State Purchasing and General Services Commission, P.O. Box 13047, Capitol Station, Lyndon Baines Johnson State Office Building, Austin, TX 78711- 3047; Mr. Troy C. Martin Specifications Chief State Purchasing and General Services Commission P.O. Box 13047 Capitol Station Lyndon Baines Johnson State Office Building Austin TX 78711- 3047; Dear Mr. Martin: This responds to your January 24, 1985 letter to the National Highwa Traffic Safety Administration (NHTSA) asking about our school bus safety standards.; Your first question asked whether a bus manufactured to accommodate passengers and 3 wheelchair positions to be used for carrying students would be classified as a school bus. The answer to your question is yes. Whether a vehicle is a school bus depends on the seating capacity of the vehicle. NHTSA determines the seating capacity of a motor vehicle by identifying the number of designated seating positions, as defined in 49 CFR Part 571.3, in the vehicle. 'Designated seating position' is defined as:; >>>any plan view location capable of accommodating a person at least a large as a 5th percentile adult female, if the overall seat configuration and design and vehicle design is such that the position is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jumpseats....<<<; Consistent with this definition, we have also counted position designed to accommodate wheelchairs in determining vehicle seating capacity for the determination of vehicle classification. Since your vehicle carries 10 passengers plus a driver, for a total of 11 persons, it is a school bus under Part 571.3 of our regulations.; The second part of this question asked whether this vehicle would b required to comply with the seating requirements of FMVSS No. 222. The answer is yes. Each new school bus must comply with all applicable requirements of Standard No. 222. Some different requirements apply to school buses having gross vehicle weight ratings (GVWR) of 10,000 pounds or less, than to school buses with GVWR's greater than 10,000 pounds. For example, the seat spacing requirements of Standard No. 222 do not apply to the lighter school buses, since these vehicles are required to have safety belts.; Your second question asked whether a vehicle manufactured to carry student passengers would be classified as a school bus. The answer is no. Such a vehicle does not have the passenger capacity of a bus, and is thus not a school bus. Although the school bus safety standards would not apply to this vehicle, it would have to meet the standards set for a multipurpose passenger vehicle.; Your third and fourth questions concerned side facing seats fo handicapped passengers. You first asked whether seat barriers must be placed forward and rearward of a side facing seat, when the seat is positioned between rows of forward facing seats.; I assume that you are concerned with buses having GVWR's greater tha 10,000 pounds, since the seat spacing requirements of S5.2 of Standard No. 222 apply only to these heavier school buses. In a preamble to a July 12, 1976, Federal Register notice (41 FR 28506), the agency determined that the seat spacing requirements of S5.2 are not appropriate for side facing seats designed to accommodate handicapped or convalescent passengers. Therefore, a restraining barrier is not required forward of a side facing seat. However, a restraining barrier must be provided rearward of any side facing seat that has a forward facing seat next to it, in order to compartmentalize the passengers in the forward facing seat.; Your fourth question assumed that S5.2 applied to side facing seats You asked whether the back of a forward facing seat positioned in front of a side facing seat could be used to meet the barrier requirements of S5.2. As discussed above, S5.2 does not apply to side facing seats.; Your fifth question asked whether safety belts are required for sid facing seats on school buses with GVWR's of 10,000 pounds or less, and on school buses with GVWR's greater than 10,000 pounds. For school buses with GVWR's of 10,000 pounds or less, Standard No. 222 requires that the applicable specifications of Standard Nos. 208, 209, and 210, be met 'at all seating positions other than the driver's seat.' Thus each seating position in a small school bus must have a safety belt and anchorages that comply with the applicable requirements of those standards. Side facing seats on the heavier school buses are not required to have safety belts.; Your sixth question asked if we have information on the use of shoulde straps and harnesses with lap belts for passenger seats on school buses. NHTSA has not conducted any tests on the use of shoulder straps or harnesses with safety belts on school buses. You might want to contact school bus manufacturers to discuss how 3-point belt systems can be used in school buses.; Your last question asked whether NHTSA has any plans at the present t delete the safety belt requirements for school buses with GVWR's of 10,000 pounds or less. Although NHTSA has no present plans to delete the safety belt requirement for the lighter school buses, the agency is presently reviewing the Canadian test data to which you referred in your letter. If we believe there is a need to propose to amend Standard No. 222, the public will have an opportunity to submit comments.; Sincerely, Jeffrey R. Miller, 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.