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.”
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NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: nht92-7.29OpenDATE: April 27, 1992 FROM: Frederick H. Grubbe -- Deputy Administrator, NHTSA TO: Wally Herger -- Member, U.S. House of Representatives COPYEE: Washington Office TITLE: None ATTACHMT: Attached to letter dated 3/13/92 from Wally Herger to Nancy Bruce; Also attached to letter dated 2/28/92 from Bill Gaines to Wally Herger TEXT: Thank you for your letter on behalf of Mr. Bill Gaines of Transfer Flow, Inc. Your letter has been referred to me for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for regulating motor vehicle safety. NHTSA issued Federal Motor Vehicle Safety Standard (FMVSS) No. 301, Fuel System Integrity, the subject of Mr. Gaines' concern. Mr. Gaines, a manufacturer of fuel tanks and fuel systems, requested your assistance about his company's "inability to meet" FMVSS 301. Mr. Gaines is concerned about the "inflexibility of testing and high cost of performing (the FMVSS 301) test." Before I address Mr. Gaines' concerns, I would like to provide some background information on our regulations and safety standards. NHTSA has the authority under the National Traffic and Motor Vehicle Safety Act to issue motor vehicle safety standards for new motor vehicles and items of motor vehicle equipment. Manufacturers of new vehicles or equipment must certify that their products conform to all applicable Federal motor vehicle safety standards (FMVSS). Each of the safety standards specifies test conditions and procedures that NHTSA will use to evaluate the performance of the vehicle or equipment being tested for compliance with the particular safety standard. The purpose of FMVSS 301 is to reduce deaths and injuries occurring from fires that result from fuel spillage during and after motor vehicle crashes. It does this by limiting the amount of fuel spillage that can occur when a vehicle is subjected to specified front, rear, and lateral barrier impact tests. FMVSS 301 has applied to passenger cars since 1968, to trucks, vans and buses with a GVWR of 10,000 pounds or less since 1976, and to school buses over 10,000 pounds since 1977. The standard applies to completed new motor vehicles, and not to components of fuel systems. Thus, the manufacturer of a vehicle that is equipped with Transfer Flow's fuel system must certify that the vehicle complies with Standard 301. Similarly, a person altering a new vehicle by replacing the original fuel system with a new one must certify that the vehicle continues to meet Standard 301. With regard to Mr. Gaines' concern about flexibility, I note that the Safety Act does not require a manufacturer to test its products only in the manner specified in the relevant safety standard. A manufacturer may choose any means of evaluating its products to determine whether the vehicle or item of equipment complies with the requirements of the safety standards. Certifications may be based on, among other things, engineering analyses, computer simulations, and/or actual testing. The manufacturer need only ensure that its vehicles or equipment will meet the applicable FMVSS's when tested by NHTSA according to the procedures specified in the Standards. We do not believe that the information provided by Mr. Gaines demonstrates any need to update FMVSS 301's requirements. I hope this information is helpful. |
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ID: nht90-1.29OpenTYPE: INTERPRETATION-NHTSA DATE: 01/29/90 FROM: TIMOTHY A. KELLY -- SALEM VENT INTERNATIONAL, INC. TO: DAVID A. GREENBURG -- NHTSA CHIEF COUNSEL TITLE: SALEM BUS VENTILATOR/ESCAPE HATCH - FMVSS 217 ATTACHMT: ATTACHED TO LETTER DATED 05/30/90; FROM STEPHEN P WOOD -- NHTSA TO TIMOTHY A. KELLY; REDBOOK A35; STANDARD 217; LETTER DATED 01/29/90, FROM TIMOTHY A. KELLY TO DAVID A. GREENBURG -- NHTSA; RE SALEM BUS VENTILATOR/ESCAPE HATCH - FMVSS 217; OCC 4 382 TEXT: Pursuant to our meeting of Thursday, January 25, 1990, I respectfully request a written opinion on the following questions regarding FMVSS 217. 1. Size of Escape Hatch: The only size specification mentioned is that the hatch must accomodate an ellipsoid with a major axis of 20" and a minor axis of 13" pushed horizontally through the escape hatch opening. Is this correct? 2. Application of Specification: A. FMVSS 217 does not address the use of escape hatches/ventilators in the roof of school busses. B. FMVSS 217 does address the use of an escape hatch/ventilator in the roof of busses other than school busses, and further states that if such a device is used (and it conforms to the ellipsoid spec) then a rear exit door may be deleted on vehicles other than school busses. Are A and B above correct? 3. Further Possible Deletions: If the non-school bus manufacturer applies more than one roof escape hatch/ventilator, do any further deletions (other than the rear exit door) accrue to the manufacturer under FMVSS 217. My reading shows that no furth er deletions are available to the manufacturer and that more than one escape hatch/ventilator simply serves the function of additional roof top ventilation. Is the above correct? Thank you for your prompt attention to these questions - I will await your response. Sincerely, [DRAWING OMITTED] |
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ID: 10-000638_Bradley_trailer_tail2OpenMr. David H. Bradley Canadian Trucking Alliance Butterworth House 324 Somerset St. West, Suite 100 Ottawa, ON Canada K2P 0J9 Dear Mr. Bradley: This responds to your letter concerning an aerodynamic device manufactured by Advanced Transit Dynamics, Inc. (ATDynamics) called a boat tail or trailer tail that some of your member motor carriers would like to install on their van trailers to reduce the fuel consumption of their vehicles. (In this letter, we will refer to these aerodynamic devices generally as trailer tails and to the device manufactured by ATDynamics as the ATDynamics TrailerTail.) You state that use of trailer tail technology would help meet a California Air Resources Board regulation that requires all U.S. and Canadian 53-foot van trailers to achieve a 5 percent overall reduction in greenhouse gas emissions by 2016. Background In your letter, you ask for our acceptance of an October 10, 2008 letter from the Director of the Federal Highway Administrations (FHWAs) Office of Freight Management and Operations to ATDynamics, a copy of which you enclosed. (October 10, 2008 letter from Anthony Furst to ATDynamics Andrew Smith.) In the letter, Mr. Furst discusses FHWA regulation 23 CFR 658.16, Exclusions from length and width determinations. Subsection (b) of 658.16 sets forth exclusions from either the measured length or width of commercial motor vehicles, as applicable, and lists aerodynamic devices in subpart (4). Mr. Furst states in the letter that FHWA regulation 23 CFR 658.16(b)(4) excludes an aerodynamic device from the measured length of a commercial motor vehicle provided: (1) the device is not capable of carrying cargo; (2) the device does not extend beyond 5 feet of the rear of the vehicle; (3) the device does not obscure tail lamps, turn signals, marker lamps, identification lamps, or safety devices such as hazardous material placards or conspicuity markings; and, (4) the device has neither the strength, rigidity nor mass to damage a vehicle, or injure a passenger in a vehicle that strikes a vehicle so equipped from the rear. Mr. Furst concludes that FHWA has determined that the ATDynamics TrailerTail meets the conditions of 23 CFR 658.16(b)(4). He states that FHWA-- acknowledges that ATDynamics Trailer Tail was tested by an independent laboratory, KARCO Engineering, and was found to be in compliance with all elements of 23 CFR 658.16(b) (4). Therefore, in accordance with Federal regulations, the ATDynamics Trailer Tail aerodynamic device should be excluded from the length measurements for commercial motor vehicles. KARCO Engineering determined that the ATDynamics Trailer Tail aerodynamic device Passed all of the conditions listed in the regulation, and FHWA accepts those results. Mr. Furst also states that FHWA shared the test results with staff from the National Highway Traffic Safety Administration (NHTSA) for review. Mr. Furst states: NHTSA identified a conspicuity marking issue[and] ATDynamics has taken care of the issue in the manner NHTSA recommended. With that background in mind, in your letter to us you ask for clarification from NHTSA with regard to the process for defining compliance with 23 CFR 658.16(b)(4) on aerodynamic devices. In other words, as we understand your letter, you ask us to confirm that use of the ATDynamics TrailerTail would not violate Federal laws administered by NHTSA. We note that Transport Canada has also contacted us for our views on trailer tails. NHTSAs Framework It would be helpful in answering your question to begin with a discussion of NHTSAs authority under the National Traffic and Motor Vehicle Safety Act (49 U.S.C. Chapter 301, Vehicle Safety Act). NHTSA is authorized under the Vehicle Safety Act to issue Federal motor vehicle safety standards (FMVSSs) applying to the manufacture and sale of new motor vehicles and items of motor vehicle equipment. Manufacturers are required to self-certify that their products conform to all applicable FMVSSs in effect on the date of manufacture. This agency does not provide approvals of new motor vehicles or of modifications of used vehicles. NHTSA has exercised its rulemaking authority to establish a number of standards that apply to new trailers. Those standards include FMVSS No. 108, Lamps, reflective devices, and associated equipment (49 CFR 571.108), which requires trailers to have specified systems to provide adequate illumination of the roadway and to improve the conspicuity of the vehicles. Another standard applying to trailers is FMVSS No. 224, Rear impact protection (49 CFR 571.224). Standard No. 224 requires trailers to have rear impact guards to reduce the harm to occupants of light duty vehicles impacting the rear of the trailer. Each new trailer with a trailer tail sold in the U.S. must be certified by its manufacturer as complying with all applicable standards, including FMVSS No. 108 and No. 224. After the first purchase of a vehicle for purposes other than resale, the Vehicle Safety Act limits modifications that may be made to the vehicle by commercial entities. 49 U.S.C. 30122 states: A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard prescribed under this chapter. In the case of the motor carriers mentioned in your letter, this provision would prohibit a commercial business from installing a trailer tail on a motor carriers new or used vehicle in a manner that would negatively affect the vehicle's compliance with FMVSS No. 108 or No. 224 or any other safety standard.[1], [2] Discussion The question posed by your letter is whether installing the ATDynamics TrailerTail on a new or used vehicle would be permitted under NHTSAs regulations. Unfortunately, we cannot provide a sweeping answer that covers all installations of the ATDynamics TrailerTail. NHTSA assesses the compliance of new vehicles and administers the make inoperative provision of the Vehicle Safety Act concerning new or used vehicles independently from other agencies. We do not approve motor vehicles or processes undertaken by manufacturers. A possible violation of the FMVSSs or the make inoperative provision is evaluated by NHTSA according to the facts of each particular case. Thus, NHTSA would evaluate, among other matters, the design and construction of a particular ATDynamics TrailerTail, the manner in which the trailer tail was attached, and whether the trailer tail impaired the effectiveness of the trailers lamps and other devices installed pursuant to FMVSS No. 108. We cannot prospectively and categorically affirm that all future uses of the ATDynamics device would be acceptable to this agency. However, we recognize and appreciate the effort that has been made seeking the agencies input in exploring possible safety issues related to the ATDynamics TrailerTail. In view of those efforts, we make the following observations based on the KARCO Engineering (KE) test. KE conducted a 35 mile per hour rear offsest crash test for ATDynamics. ATDynamics installed a TrailerTail on a 1991 Pine Trailer. The test vehicle and set-up was prepared by KE. The impacting vehicle was a 1994 Ford Econoline 350 Van. Two Hybrid III 50th percentile adult male test dummies equipped with head triaxial accelerometers to measure head injury accelerations were placed in the driver and right-front passenger seating positions. KEs report on the test states (Laboratory Test Report, Rear-Mounted Aerodynamic Device, TrailerTail mounted to a 1991 Pine Trailer, Prepared for Advanced Transit Dynamics, Inc., July 22, 2008, KARCO Engineering): (a) Inspection of pre- and post-test photographic data showed no appreciable deformation of any structural component of the impacting vehicle attributable to the trailer tail (not including glass, plastic lenses, or trim components); (b) The head injury criterion of neither test dummy exceeded a value of 1,000 as a result of direct contact with the trailer tail; and (c) There was no evidence from either post-test inspection of the transfer of chalk applied to the test dummies or from still or high speed photography that the trailer tail or any resilient component of the impacting vehicle made contact with any portion of the test dummies as a result of contact of the impacting vehicle with the trailer tail. In addition, the report indicates that the open geometry of the ATDynamics TrailerTail does not allow it to carry cargo, and that the vehicles lamps and conspicuity markings would meet FMVSS No. 108. The test data from the KE test indicate that the ATDynamics TrailerTail did not negate the vehicles ability to meet FMVSS No. 224[3] and that the rear impact guard on the vehicle was not made inoperative by the ATDynamic TrailerTail. Thus, there is no basis for NHTSA to conclude at this time that installation of the ATDynamics TrailerTail is prohibited. Please note that NHTSA is interested in Transport Canadas on-going work evaluating the safety and performance of trailer tails. NHTSA will evaluate the outcome of Canadas research to see if we should undertake further work on trailer tails. If you have any other questions, please contact Deirdre Fujita of my staff at this address or by phone at (202) 366-2992. Sincerely, O. Kevin Vincent Chief Counsel 1/24/2011 [1] The make inoperative provision applies to a manufacturer, distributor, dealer, or repair business installing a trailer tail, and not to a vehicle owner that modifies its own vehicle. However, States have the authority to regulate the operation of vehicles in their jurisdictions, and may have restrictions on the type of modifications owners may make. [2] The Vehicle Safety Act also requires manufacturers of motor vehicles and motor vehicle equipment to ensure that their products are free of safety-related defects. A trailer tail would be considered motor vehicle equipment under the Vehicle Safety Act. [3] That is, it appears that the trailer tail would qualify as a nonstructural protrusion under FMVSS No. 224. See S4, definition of rear extremity. |
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ID: 11-000699 Signature Products Group Seat Cushion 214 Interpretation LetterOpen
Mr. Dave Otis Signature Products Group 2550 South Decker Lake Blvd. Ste. #1 Salt Lake City, UT 84119
Dear Mr. Otis:
This letter responds to your letter inquiring about side air bags and their relationship to the seat covers that your company manufactures for sale directly to vehicle owners (in the aftermarket). You ask the following questions: (1) whether there are Federal regulations that regulate the deployment of side air bags in relation to seat covers; (2) whether your company should be concerned with possible liabilities of consumer installation of your products in their vehicles; (3) whether the National Highway Traffic Safety Administration (NHTSA) operates a certification or testing program for seat covers; (4) whether any Federal regulations prevent seat covers from covering the air bag labels that are often found on seats; and (5) whether NHTSA is aware of any industry standards in regards to side impact air bags and seat covers.
This letter responds to your questions. Our answers are based on our understanding of the information provided in your letter.
By way of background information, NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue Federal motor vehicle safety standards (FMVSSs) that apply to both new motor vehicles and new items of motor vehicle equipment.[1] NHTSA does not approve or certify vehicles or items of equipment. Instead, manufacturers are required to self-certify that their vehicles or equipment meet all applicable standards. The agency periodically tests vehicles and items of equipment for compliance with the standards. Manufacturers must also ensure that their products are free of safety-related defects. Currently there are no FMVSSs directly applicable to aftermarket seat covers. Thus, you are not subject to a certification requirement, since no FMVSS applies to your product.[2] However, seat covers are considered motor vehicle equipment under the Safety Act. As a manufacturer of motor vehicle equipment, you must ensure that your seat covers are free of safety-related defects. Among other things, manufacturers are responsible for notifying this agency, notifying purchasers of the product, and remedying the problem free of charge when a safety defect is discovered. (1) Federal Regulations Regarding Side Air Bags and Seat Covers
You ask whether there are Federal regulations that regulate the deployment of side air bags in relation to seat covers. Vehicle manufacturers have been installing side air bags in vehicle seats for a number of years. In 2007, NHTSA issued a final rule upgrading FMVSS No. 214, Side impact protection, to provide increased head and thorax protection for occupants of vehicles that crash sideways into poles or trees or are laterally struck by higher-riding vehicles.[3] Vehicle manufacturers are installing seat-mounted, door- and roof-mounted side air bags in new vehicles to meet this new FMVSS requirement. May you sell an aftermarket seat cover that covers up the seat-mounted side air bag installed to meet FMVSS No. 214? There are several factors to consider. First, under 30122 of the Safety Act, manufacturers, distributors, dealers, and motor vehicle repair businesses are prohibited from knowingly making inoperative any part of a device or element of design that was installed on or in a motor vehicle in compliance with the FMVSSs. In our opinion, if a seat-mounted side air bag were installed in a motor vehicle in compliance with FMVSS No. 214, 30122 would not permit a manufacturer, distributor, dealer, or motor vehicle repair business to install the seat cover if the entity knew that the seat cover would make the air bags inoperative. (We are aware that the persons purchasing your seat covers are typically vehicle owners who install the seat covers themselves and that it is thus unlikely that a manufacturer, distributor, dealer, or repair business will install your seat covers.) Second, vehicle owners are not subject to the make inoperative prohibition of the Safety Act when installing items in their vehicles or otherwise modifying their vehicles. They may install an aftermarket product even if the product negatively affects the safety systems in their vehicles, without violating our regulations. Nonetheless, we encourage vehicle owners to avoid disabling or reducing the effectiveness of safety features on their vehicles. Further, State law may have restrictions on the modifications vehicle owners may make to their vehicles. Third, we believe it is practicable for manufacturers of seat covers to design their product such that the seat covers will not affect the proper deployment of side impact air bags. We understand that seat cover manufacturers have been producing such products for years. NHTSA regulations do not require manufacturers of seat covers to test their seat covers to see if they are compatible with the side air bags. However, generally speaking, we strongly encourage manufacturers to carefully consider how their aftermarket equipment might affect the safety systems on a vehicle.
(2) Liability Arising from Consumer Installation of Seat Covers
You ask whether your company should be concerned with possible liabilities of consumer installation of your products in their vehicles. To answer this question and to further address your questions about testing seat covers, you should consult a private attorney on this matter. As personal injury and tort litigation are generally matters of State law, such an attorney would have the best information with which to advise your company.
(3) Certification and Testing of Products
Your third question asks whether NHTSA operates a certification or testing program for seat covers. As explained above, NHTSA does not provide approvals of or certifications for motor vehicles or items of motor vehicle equipment.
We suggest you contact an independent testing laboratory if you are interested in tests of seat covers. For your information, I have enclosed a list of independent test laboratories that NHTSA has used under contract to conduct compliance testing to various FMVSSs. This list is available on NHTSAs website: www.nhtsa.gov.
(4) Covering the Air Bag Label on Seats
You ask whether any Federal regulations prevent seat covers from covering the air bag labels that are often found on seats. We assume you refer to the label or tag on a vehicle seat that indicates the presence of a side air bag.
Our answer is no. Our safety standards do not require that manufacturers include a label to indicate the presence of a side air bag to the vehicle user. The label does not include safety information or warnings. We have no restrictions on a seat cover covering the tag other than those related to performance, discussed above.
(5) Industry Standards Regarding Seat Covers
You ask whether NHTSA is aware of any industry standards in regards to side impact air bags and seat covers. Our answer is no, but we suggest you try contacting the test laboratories listed in the enclosure. The Society of Automotive Engineers (telephone: 1-877-606-7323) might also have information on industry standards pertaining to your product.
We hope this information has been helpful. For your information, we have enclosed an information sheet that briefly describes manufacturers responsibilities under the Safety Act and other NHTSA requirements.
Should you have any further questions, please contact Jesse Chang of my staff at 202-366-2992.
Sincerely,
O. Kevin Vincent Chief Counsel
Enclosures
Ref: FMVSS No. 214 8/17/2011 |
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ID: 15-005347 BMW Brake Transmission Shift Interlock v5Open
Mr. Samuel Campbell, III BMW of North America, LLC 200 Chestnut Ridge Road Bldg. 150 Woodcliff Lake, NJ 07677-7739
Dear Mr. Campbell:
This responds to your October 5, 2015 letter asking whether BMWs Park Assistant Plus system complies with the brake transmission shift interlock requirement in Federal Motor Vehicle Safety Standard (FMVSS) No. 114.[1]
Your letter describes your Park Assistant Plus system as a remote-controlled parking system that the driver operates from a location outside, but within six feet of, the vehicle. You emphasize that BMWs Park Assistant Plus system is used for only low-speed, short-distance parking maneuvers. Your letter also indicates the procedure the driver must follow to activate and use the system.
The procedure to activate the Park Assistant Plus system requires the driver to place the vehicle in park, turn the vehicle off, exit the vehicle, and press the on/off button on the left side of the key fob[2] while also depressing a safety button on the right side of the key fob, which must remain depressed throughout the remote controlled parking. After activating the feature with the button on the left and continuing to depress the button on the right, the driver will use his or her other hand to touch the key fobs display screen to start the engine and the remote controlled parking movement.[3]
The driver must continue to depress the button on the right side throughout the parking maneuver and has the opportunity to stop the maneuver at any time by releasing the button. Additionally, ultrasonic sensors and cameras automatically stop the vehicle if humans or objects are detected in the vehicles path, which is designed to reduce the risk of injury from a rollaway vehicle.
Your letter goes into detail about how the Park Assistant Plus system works and how BMW has integrated safety features into the system, but the goal of your letter is to learn whether the remote parking feature is prohibited by the brake transmission shift interlock requirement found in Section 5.3 of FMVSS No. 114. Based on your description and the information on your website, we have written this interpretation predicated on the assumption that your vehicles include a service brake foot control and that the Park Assistant Plus system will be installed in a new motor vehicle.
General Authority
By way of background, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue FMVSSs that set performance requirements for new motor vehicles and new items of motor vehicle equipment. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment and does not make determinations as to whether a product conforms to the FMVSSs outside of an agency compliance test. Instead, the Safety Act requires manufacturers to self-certify that their products conform to all applicable FMVSSs that are in effect on the date of manufacture. Manufacturers are also responsible for ensuring that their products are free of safety-related defects.
NHTSA enforces compliance with the FMVSSs by purchasing and testing vehicles and regulated equipment. It also investigates FMVSS noncompliances and safety-related defects.
Your letter states that you believe the Park Assistant Plus system complies with Section 5.3 of FMVSS No. 114, and you ask for NHTSAs concurrence in your interpretation. We note again that NHTSA does not make determinations as to whether a product complies with the FMVSSs outside the context of an agency compliance test. We do, however, agree that the design of the Park Assistant Plus system is not prohibited by FMVSS No. 114. To begin our discussion, keep in mind that when a feature or device, such as BMWs Park Assistant Plus, is installed as original equipment on a new vehicle, the vehicle manufacturer is required to certify that the vehicle satisfies the requirements of all applicable FMVSSs. Discussed below is FMVSS No. 114.
FMVSS No. 114
FMVSS No. 114, Theft protection and rollaway prevention, specifies requirements for theft protection to reduce the incidence of crashes resulting from unauthorized operation of a motor vehicle.[4] It also specifies requirements to reduce the incidence of crashes resulting from the rollaway of parked cars with automatic transmissions. In particular, Section 5.3, Brake transmission shift interlock, requires a brake transmission shift interlock (BTSI) that prevents the shift mechanism from being moved out of the park position unless the service brake is depressed. Section 5.3 applies to motor vehicles with an automatic transmission that includes a park position manufactured on or after September 1, 2010 with a gross vehicle weight rating (GVWR) of 10,000 pounds (4,536 kg) or less (excluding trailers or motorcycles). It is also important to note, as you did in your letter, that Section 5.3 was incorporated into FMVSS No. 114 in 2010 after it was required by the Cameron Gulbransen Kids Transportation Safety Act of 2007 (K.T. Safety Act). Section 2(d)(1) of the K.T. Safety Act specifies, in relevant part:
Each motor vehicle with an automatic transmission that includes a park position manufactured for sale after September 1, 2010, shall be equipped with a system that requires the service brake to be depressed before the transmission can be shifted out of park. This system shall function in any starting system key position in which the transmission can be shifted out of park.
(Emphasis added.) The goal of designing the BTSI system in this way is to prevent an unattended child from shifting the transmission out of the park position when the child is left unattended in a vehicle with the vehicles keys.[5] This is also aimed at preventing a rollaway vehicle from injuring bystanders that are in the vehicles path.
Your product, the Park Assistant Plus system, involves a multi-step activation process in order to use the remote-controlled parking function. As discussed earlier, the procedure to activate the system requires the driver to place the vehicle in park, turn the vehicle off, exit the vehicle, and press the on/off button on the left side of the key fob while also depressing a safety button on the right side of the key fob, which must remain depressed throughout the remote controlled parking. After activating the feature with the button on the left and continuing to depress the button on the right with one hand, the driver will need to use his or her other hand to touch the key fobs display screen to start the remote controlled parking movement. This process activates the system and initiates the pre-check function during which the electronic stability control (ESC) pump applies pressure to the service brakes, and the brake system and energy levels are also checked. Next, the ESC pump applies the service brakes before the vehicle can begin to move out of the park position.
The essence of the issue presented by your letter is the phrase service brake to be depressed in Section 5.3. This is unusual phrasing. Given that the service brake pads themselves are not being depressed when they are moved into place and apply pressure against the disc (in the case of disc brakes) or the drum (in the case of drum brakes), it would have been more clear if the section had read either service brake to be applied or brake pedal to be depressed. The language used in the K.T. Safety Act and in S5.3 falls in between these two phrasings, borrowing a little from each. Thus, the phrase service brake to be depressed is ambiguous and leaves room for interpretation.
Depressed is not defined in FMVSS No. 114, 49 CFR 571.3, Definitions, or the K.T. Safety Act, but Merriam Webster defines the verb depress as to press (something) down.[6] Depressed is the past tense of depress, and means pressed something down in the context of FMVSS No. 114. The something that is pressed down is the service brake, which is defined in 571.3 as the primary mechanism designed to stop a motor vehicle. In the present context, we understand the term depressed, as used in the K.T. Safety Act and in S5.3, to mean simply pressed or applied.
Section 5.3 requires the service brake to be depressed before the transmission can be shifted out of park.[7] It does not, however, specify that the service brake must be pressed or applied by any particular object or function, such as a drivers foot. In your design, the service brake is pressed or applied with an ESC pump actuated by the vehicles operator before the vehicle can be shifted out of the park position. This achieves the goal of Section 5.3 by preventing an occupant, particularly a child, from inadvertently shifting the transmission out of the park position. It also fulfills the BTSI requirement in the K.T. Safety Act.
I hope this information is helpful. If you have further questions, please contact Ms. Sara Bennett of my staff at (202) 366-2992.
Sincerely,
Paul A. Hemmersbaugh Chief Counsel
Dated: 1/4/16 Standard No. 114
[1] 49 CFR 571.114. [2] BMW calls its key fob a Display Key. In this letter, we use the more inclusive term key fob since key is defined in FMVSS No. 114 as a physical device or an electronic code which, when inserted into the starting system (by physical or electronic means), enables the vehicle operator to activate the engine or motor. BMWs key fob contains an electronic code, but is not itself an electronic code. [3] An illustration of this feature can be found on BMWs official YouTube page: https://www.youtube.com/watch?v=6Viyt2aIOG8. [4] Letter to Norman Katz, Esq. of Saretsky, Katz, Dranoff & Glass, L.L.P. (June 6, 2006), available at http://isearch.nhtsa.gov/files/Katz.1.htm,. [5] Letter to Michael X. Cammissa of the Association of International Automobile Manufacturers, Inc. (July 20, 2010), available at http://isearch.nhtsa.gov/files/AIAM%20003788%20114.htm. [6] Depress Definition, Merriam-Webster Online Dictionary, available at http://www.merriam-webster.com/dictionary/depress (last visited Nov. 11, 2015). [7] 49 CFR 571.114. |
2016 |
ID: nht94-7.41OpenDATE: March 16, 1994 FROM: John Womack -- Acting Chief Counsel, NHTSA TO: Harold R. Burke, Esq. -- Duel and Holland (Greenwich, CT) TITLE: Importation of Type M-151 Military Vehicle ATTACHMT: Attached to letter dated 7/8/93 from Harold R. Burke to Office of the Chief Counsel, NHTSA (OCC 8867) TEXT: We have received your letter of July 8, 1993, asking several questions about the motor vehicle importation regulations as they apply to M-151 military vehicles. I apologize for the delay in our response. Your client wishes to import for resale in the U.S. approximately 8,000 such vehicles built in the U.S. between 1973075, and which, according to you, have never been used. Before I answer your questions, you should know that it has been the policy of the Department of Defense (DOD) for at least two decades to section and scrap M-151s at the end of their useful military life rather than to sell them for civilian use or allow further use by other government agencies. This policy, which was developed with the participation and support of this agency, is based on the tendency of the M-151 to turn over during quick turning maneuvers or when driven by unskilled operators. DOD has followed this policy consistently, notwithstanding the economic benefits that would accrue to the government were the vehicles allowed to be sold to the public or to be operated by other Federal agencies, such as the U.S. Park Service, in non-military applications. The unvarying applicability of this policy highlights the safety concern of two Federal Departments for civilian use of the M-151, and we believe that your client should be aware of the potential liability that sale to the public would entail. Your client should also be aware that, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.), (the Act), any person importing motor vehicles for resale is considered the "manufacturer" of these vehicles, and would have the same responsibility as the original manufacturer to notify owners and remedy safety related defects in the event they occurred in the M- 151. (15 U.S.C. 1391(5)). For example, the agency has the authority to determine that a tendency to overturn is a defect in performance, a safety related defect which would require the importer for resale to notify and remedy in accordance with statutory requirements (15 U.S.C. 1411 et seq.). You have asked the following three questions: "1. As U.S. origin vehicles which have been outside this country since 1975 are they now classified as 'foreign' vehicles which are subject to current D.O.T. and E.P.A. safety and emissions criteria?" The National Highway Traffic Safety Administration does not classify motor vehicles as "domestic" and "foreign." Any motor vehicle, whether manufactured in the U.S. or elsewhere, must conform to all applicable Federal motor vehicle safety standards (FMVSS) in order to be sold in the U.S. The FMVSS that apply to a motor vehicle to be imported into the U.S. are those that were in effect at the time the vehicle was manufactured, not those in effect at the time of its importation. We are unable to advise you on the regulations of the Environmental Protection Agency as it is an agency independent of the Department of Transportation. In order to be imported into the U.S., a motor vehicle must conform with (or be brought into conformity with) any applicable FMVSS. Although the M-151 is a "motor vehicle" under the Act, from the beginning the agency on its own volition has excluded motor vehicles manufactured for and sold directly to the Armed Forces of the United States in conformity with contractual specifications from compliance with the FMVSS (49 CFR 571.7(a)), though retaining jurisdiction over them for safety defect notification and remedy campaigns. This means that the M-151 was not designed to comply with FMVSS at the time of its manufacture. For importers of an M-151 other than the Armed Forces of the United States, the importer would be required, as a condition of importation, to bring the M-151 into compliance with the FMVSS that applied at the time of its manufacture. However, because of the restrictions imposed by the Imported Vehicle Safety Compliance Act of 1988 (PL 100-562), it is no longer simple to import nonconforming motor vehicles to which the FMVSS apply. Under this recent legislation, the agency must make a formal determination, either pursuant to a petition or on its own motion, that the vehicles are capable of conversion to meet the FMVSS. Following this, a vehicle may be imported by its owner, only if the owner has a contract with a "registered importer" (one whom the agency has recognized as a converter) to convert the vehicles, or if the importer itself is a registered importer. However, nonconforming vehicles which are imported for resale can only be imported by a registered importer. We would require any prospective civilian importer of an M-151 manufactured in 1973-75 to demonstrate that the vehicle is capable of conversion to comply with the FMVSS that applied to multipurpose passenger vehicles during that period. A bond equal to 150% of the value of the vehicle as determined by the U.S. Customs Service must also be posted during the conversion process. "2. If they are not considered 'foreign' vehicles what, if any, D.O.T. regulations would apply to the registration of such vehicles for use on U.S. roads?" "3. If they are considered 'foreign' vehicles . . . ." There are no Federal registration requirements for vehicles sold to persons other than Federal agencies. State regulations apply. We are not conversant with State registration laws, and refer inquirers for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. |
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ID: 8867Open Harold R. Burke, Esq. Re: Importation of Type M-151 Military Vehicle Dear Mr. Burke: We have received your letter of July 8, 1993, asking several questions about the motor vehicle importation regulations as they apply to M-151 military vehicles. I apologize for the delay in our response. Your client wishes to import for resale in the U.S. approximately 8,000 such vehicles built in the U.S. between 1973-75, and which, according to you, have never been used. Before I answer your questions, you should know that it has been the policy of the Department of Defense (DOD) for at least two decades to section and scrap M-151s at the end of their useful military life rather than to sell them for civilian use or allow further use by other government agencies. This policy, which was developed with the participation and support of this agency, is based on the tendency of the M-151 to turn over during quick turning maneuvers or when driven by unskilled operators. DOD has followed this policy consistently, notwithstanding the economic benefits that would accrue to the government were the vehicles allowed to be sold to the public or to be operated by other Federal agencies, such as the U.S. Park Service, in non- military applications. The unvarying applicability of this policy highlights the safety concern of two Federal Departments for civilian use of the M-151, and we believe that your client should be aware of the potential liability that sale to the public would entail. Your client should also be aware that, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.), (the Act), any person importing motor vehicles for resale is considered the "manufacturer" of these vehicles, and would have the same responsibility as the original manufacturer to notify owners and remedy safety related defects in the event they occurred in the M-151. (15 U.S.C. 1391(5)). For example, the agency has the authority to determine that a tendency to overturn is a defect in performance, a safety related defect which would require the importer for resale to notify and remedy in accordance with statutory requirements (l5 U.S.C. 1411 et seq.) You have asked the following three questions: "1. As U.S. origin vehicles which have been outside this country since 1975 are they now classified as 'foreign' vehicles which are subject to current D.O.T. and E.P.A. safety and emissions criteria?" The National Highway Traffic Safety Administration does not classify motor vehicles as "domestic" and "foreign." Any motor vehicle, whether manufactured in the U.S. or elsewhere, must conform to all applicable Federal motor vehicle safety standards (FMVSS) in order to be sold in the U.S. The FMVSS that apply to a motor vehicle to be imported into the U.S. are those that were in effect at the time the vehicle was manufactured, not those in effect at the time of its importation. We are unable to advise you on the regulations of the Environmental Protection Agency as it is an agency independent of the Department of Transportation. In order to be imported into the U.S., a motor vehicle must conform with (or be brought into conformity with) any applicable FMVSS. Although the M-151 is a "motor vehicle" under the Act, from the beginning the agency on its own volition has excluded motor vehicles manufactured for and sold directly to the Armed Forces of the United States in conformity with contractual specifications from compliance with the FMVSS (49 CFR 571.7(a)), though retaining jurisdiction over them for safety defect notification and remedy campaigns. This means that the M-151 was not designed to comply with FMVSS at the time of its manufacture. For importers of an M-151 other than the Armed Forces of the United States, the importer would be required, as a condition of importation, to bring the M-151 into compliance with the FMVSS that applied at the time of its manufacture. However, because of the restrictions imposed by the Imported Vehicle Safety Compliance Act of 1988 (PL 100-562), it is no longer simple to import nonconforming motor vehicles to which the FMVSS apply. Under this recent legislation, the agency must make a formal determination, either pursuant to a petition or on its own motion, that the vehicles are capable of conversion to meet the FMVSS. Following this, a vehicle may be imported by its owner, only if the owner has a contract with a "registered importer" (one whom the agency has recognized as a converter) to convert the vehicles, or if the importer itself is a registered importer. However, nonconforming vehicles which are imported for resale can only be imported by a registered importer. We would require any prospective civilian importer of an M-151 manufactured in 1973-75 to demonstrate that the vehicle is capable of conversion to comply with the FMVSS that applied to multipurpose passenger vehicles during that period. A bond equal to 150% of the value of the vehicle as determined by the U.S. Customs Service must also be posted during the conversion process. "2. If they are not considered 'foreign' vehicles what, if any, D.O.T. regulations would apply to the registration of such vehicles for use on U.S. roads?" "3. If they are considered 'foreign' vehicles . . . ." There are no Federal registration requirements for vehicles sold to persons other than Federal agencies. State regulations apply. We are not conversant with State registration laws, and refer inquirers for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. Sincerely,
John Womack Acting Chief Counsel ref:591 d:3/17/94 |
1994 |
ID: swivelinglamp.3Open[ ] Dear [ ]: This responds to your letter, in which you ask how a swiveling lamp, incorporated as original equipment in a new vehicles headlight assembly but with its own on-off switch, would be characterized under Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices, and Associated Equipment. Your letter states that the swiveling lamp is designed to automatically enhance illumination around corners and through curves, so as to improve a drivers ability to see pedestrians, bicycles, and other objects that may be in the roadway. Specifically you ask whether the swiveling lamp would be "a supplemental piece of lighting equipment and therefore not directly regulated by [FMVSS No. 108]."For the reasons below, we have concluded that the swiveling lamp you have described would be a component of the required headlighting system under FMVSS No. 108. Consequently, its installation on a motor vehicle would violate those provisions of the standard that limit a replaceable bulb headlamp to having no more than two replaceable light sources. You have requested that the National Highway Traffic Safety Administration (NHTSA) accord your letter confidential treatment because it includes proprietary commercial information. We note your attorneys consent on your behalf that your interpretation request letter and our interpretation may be made public, provided that all information identifying you and your company are deleted. We shall follow this procedure, which will adequately describe the device to allow a reader to understand just what this interpretation covers. Your letter states that the vehicles complete front lighting system will include all of the forward lighting equipment required by FMVSS No. 108, as well as the swiveling lamp, as depicted in the attachments to your letter. However, the swiveling lamp would use a different light source and reflector than any of the other functions, and it is controllable by a manual on-off switch on the dashboard that is independent of the switch for operation of the vehicles standard headlamps. Once engaged, activation of the swiveling lamp is a function of transmission position (i.e., the vehicle must be in neutral or a forward driving position) and of the state of the vehicles headlamp switch (i.e., low or high beams must be engaged). Horizontal aim of the swiveling lamp is determined by both vehicle speed and steering input. Your letter further states that the swiveling lamp has been designed to aim its light output downward and to the side, so as to be distinct from and to not affect the brightness or visibility of any turn signal. According to your letter, the swiveling lamp has also been "designed to minimize glare to other drivers." Paragraph S7 of FMVSS No. 108, Headlighting requirements, requires vehicles to be equipped with one of several permissible headlighting system options, whose specifications are set forth in the standard. Headlighting systems are comprised of headlamps and associated hardware. The standard sets its performance requirements for headlamps, in part, through reference to the Society of Automotive Engineers (SAE) Standard No. J1383 (Performance Requirements for Motor Vehicle Headlamps; April 1985). Under paragraph S7.5, Replaceable bulb headlamp systems, subparagraph (a) provides, "The system shall provide only two lower beams and two upper beams and shall incorporate not more than two replaceable light sources in each headlamp." This limitation on the number of light sources was contained in a final rule published on May 22, 1985, that amended FMVSS No. 108 (50 FR 21052). We note that subsequent to that time, NHTSA has engaged in rulemaking seeking to develop more performance-oriented and less design-restrictive headlighting requirements; [1] however, the proposed system specifying roadway illumination requirements was found to be complex, and there were questions as to whether the uncertain potential benefits justified the perceived regulatory burdens. Consequently, the rulemaking was terminated, [2] and FMVSS No. 108s existing requirements were retained, including the limitation on the number of replaceable light sources. NHTSA stated that it would be willing to revisit the issue of more performance-oriented changes to FMVSS No. 108 through the regulatory process, perhaps through negotiated rulemaking. [3] In determining whether the swiveling lamp is part of a headlamp system or a supplemental piece of lighting equipment, an important consideration is where the swiveling lamp directs its light. According to section 2.1 of SAE J1383, a "headlamp" is defined as "a lighting device providing an upper and/or a lower beam used for providing illumination forward of the vehicle." Your swiveling lamp would provide illumination forward of the vehicle when a turn of a sufficient magnitude is executed, which is consistent with the headlighting function. Based upon its function, we view your lamp as a type of Adaptive Frontal-lighting System (AFS). AFSs are systems that can actively change the intensity and direction of headlamp illumination in response to changes in vehicle speed or roadway geometry, such as providing more light during a turn. We note that the agency published a request for comments on the AFS issue in the Federal Register on February 12, 2003 (68 FR 7101). Other governments and organizations support the position that lamps that bend light in the direction of a turn are adaptive frontal-lighting systems. In order to allow introduction of this new headlighting technology in Europe, regulations are currently being modified under the auspices of the UN Economic Commission for Europe (ECE) (see ECE R112 A2). SAE has also issued a draft standard J2591 (Adaptive Forward Lighting System) that characterizes swiveling lamps as part of the headlighting system. Beyond the fundamental matter of where the light emitted by the swiveling lamp is directed, other factors also lead us to conclude that the swiveling lamp is part of the headlighting system. We note that the swiveling lamp you describe uses a headlamp replaceable light source to emit a beam that provides significantly more light flux than supplemental cornering lamps or fog lamps designed to conform to applicable SAE standards. In addition, when operated as intended, the use of cornering lamps and fog lamps is limited to more narrow driving conditions and situations; in contrast, your swiveling lamps are presumably intended to be used regularly, since turning is a routine part of driving. We do not find the inclusion of a manual on-off switch (which can be left on indefinitely) to be a dispositive indicator that the swiveling lamp is a piece of supplemental lighting equipment. For the above reasons, we have concluded that the swiveling lamp described in your letter is an integral part of the headlighting system, and as such, it would cause the headlighting system to exceed the maximum number of permissible light sources under paragraph S7.5 of FMVSS No. 108. Consequently, the swiveling lamp described in your letter would not meet the requirements of the standard. If you have any further questions, you may call Mr. Eric Stas of my staff at (202) 366-2992. Sincerely, Jacqueline Glassman ref:108 [1] See 54 FR 20084 (May 9, 1989). [2] See 60 FR 58038 (November 24, 1995). [3] Id. at 58039. |
2004 |
ID: GF007036OpenMr. Robert M. Clarke Dear Mr. Clarke: This is in response to your letter of September 15, 2003, seeking clarification of the two effective dates for the new heavy vehicle antilock brake system (ABS) performance requirements in Federal Motor Vehicle Safety Standards (FMVSS) No. 121, and FMVSS No. 105. [1] In your letter, you indicated your understanding that "complete vehicle" manufacturers were subject to the effective date of July 1, 2005.You also indicated your understanding that "incomplete vehicle" manufacturers, including "final stage" manufacturers and "intermediate stage" manufacturers were subject to the effective date of July 1, 2006. You ask whether a "chassis-cab" manufacturer [2] would also qualify as an "incomplete vehicle" manufacturer, and thus be subject to the July 1, 2006, effective date. As discussed below, our answer is yes.
The new regulatory text for FMVSS No. 105 contains similar language with respect to the effective dates. The preamble to the final rule explains that "vehicles built in two or more stages must meet the braking-in-a-curve tests requirements on or after July 1, 2006." The preamble also indicates that the additional lead time was necessary in order to enable early stage manufacturers to provide complying incomplete vehicles to final stage manufactures. [3] With respect to the effective date for vehicles manufactured in two or more stages, the final rule does not differentiate between the different stages of the manufacturing process or different categories of incomplete vehicles. Instead, we provided an effective date of July 1, 2006, for all vehicles built in two or more stages. Accordingly, all vehicles built in two or more stages, including chassis-cabs, are subject to the effective date of July 1, 2006. With respect to your last question, the abbreviation "LLVW" appearing in Table 1 of the August 11 Final Rule, stands for "lightly loaded vehicle weight." The term carries the same meaning in FMVSS No. 121 as it does in FMVSS No. 105 where it is defined as unloaded vehicle weight plus up to 1,500 lb. We intend to add this same definition to FMVSS No. 121 at a future date. I hope this information is helpful. If you have any further questions, please feel free to contact George Feygin of my staff at this address or by telephone at (202) 366-2992. Sincerely, Jacqueline Glassman ref:121 [1] The new requirements were published in the Final Rule on August 11, 2003 (68 FR 47485). [2] A "chassis-cab" is one type of incomplete vehicle. [3] See Id. at 47493. |
2003 |
ID: nht76-1.27OpenDATE: 03/08/76 FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA TO: Michelin Tire Corporation TITLE: FMVSS INTERPRETATION TEXT: This is in response to your letter of January 27, 1976, concerning the rim listing requirements of Federal Motor Vehicle Safety Standards No. 109 and 110. You wish to designate the 15x5.5JJ rim as permissible for use with tire sizes 225-15 and 230-15. You have requested confirmation of your interpretation that you need merely list the rim in a document that is furnished to your dealers, to any person on request, and in duplicate to the Tire Division of the NHTSA. Your interpretation is correct. Please note, however, that this listing must include dimensional specifications and a diagram of the rim, unless each of the association publications referred to in S4.4.1(b) of Standard No. 109 in which the rim is listed already contains such specifications and diagram. We hope that you will also ensure that this tire-rim combination is listed in one of those publications as soon as is possible. MICHELIN TIRE CORPORATION Technical Group JANUARY 27, 1976 Office of the Chief Counsel National Highway Traffic Administration Department of Transportation Re: FMVSS 109 - New Pneumatic Tires for Passenger Cars FMVSS 110 - Tire Selection and Rims We are writing to confirm our interpretation of paragraph S.4.4.1 of FMVSS 110 and paragraph S.3 and S.4.4.1 of FMVSS 109. It is our understanding that in order to add an additional permissible rim width for a tire which is already listed in the tables of FMVSS 109, we need merely include it in a document (such as our Data Book or Technical Bulletin) which is furnished to our dealers and to any person upon request, and in duplicate to the Tire Division of NHTSA. It is our immediate need to add the 15x5.5JJ rim as a permissible fitment for tire sizes 225-15 and 230-15. Your prompt reply would be appreciated. Thank you. John B. White Engineering Manager Technical Information Dept. |
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.