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: aiam2045OpenMr. Guy A. Catherine, General Sales Manager, Kleber Corporation, 91-31 Queens Blvd. New York, N.Y. 11373; Mr. Guy A. Catherine General Sales Manager Kleber Corporation 91-31 Queens Blvd. New York N.Y. 11373; Dear Mr. Catherine: #This is in response to your letter of June 3 1975, asking whether it is permissible to import into this country tire designed exclusively for racing purposes. #Tires designed to be used exclusively on racing vehicles, *i.e.*, vehicles other than 'motor vehicles' within the meaning of the national Traffic and Motor Vehicle Safety Act, are not regulated by the Federal motor vehicle safety standards, and may be imported. The labeling that you propose to use appears to be appropriate to warn users of their intended purpose. Manufacturers of such equipment should take all reasonable steps to ensure that their products are not misused. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam0078OpenMr. H. Moeller, Research and Development Department, Robert Bosch Corporation, 40-11 - 24th Street, Long Island City, NY 11101; Mr. H. Moeller Research and Development Department Robert Bosch Corporation 40-11 - 24th Street Long Island City NY 11101; Dear Mr. Moeller: Thank you for your letter of May 24, 1968, to Mr. J. E. Leysath of thi Bureau, concerning the testing of automotive flasher devices.; Motor Vehicle Safety Standard 108 specifies that turn signal flasher and vehicular hazard warning signal flashers conform to SAE Standards J590b and J945, respectively. These SAE standards, in turn, require that the test circuitry and test instrumentation conform to SAE Standard J823a. As you noted, the distribution of the 0.10 0.01 ohm series resistance in the standard test circuit (Figure 1 of J823a) is not specified in SAE Standard J823a. Therefore, your recommended distribution, namely, 0.025 0.005 ohms resistance between the power supply (positive terminal) and flasher input terminal, and 0.075 0.005 ohms resistance between the flasher output terminal and the flasher bulbs, would be permitted by SAE Standard J823a.; Flasher units having a ground terminal that is connected with th negative terminal of the power supply may be tested in the standard test circuit of SAE Standard J823a, provided the ground circuitry does not change the required resistance of 0.10 0.01 ohm looking into terminals A-B with the removable shunts in place (see note for Figure 1, SAE J823a).; The above-stated test provisions in no way except the flasher unit from meeting all performance requirements specified in Standard No. 108, including those specified in basically referenced SAE Standards J590b, 'Automotive Turn Signal Flashers,' and J945, 'Vehicle Hazard Warning Signal Flasher.'; Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam4892OpenMr. Samuel Albury President Three Wolves and Associates, Inc. 7124 Temple Hills Road Suite 169 Camp Springs, Maryland 20748; Mr. Samuel Albury President Three Wolves and Associates Inc. 7124 Temple Hills Road Suite 169 Camp Springs Maryland 20748; "Dear Mr. Albury: This responds to your letter of June 3, 199 concerning whether your company would be considered the manufacturer of certain vehicles. Your company is planning to use jeep conversion kits on Chrysler Corporation jeeps. Under one approach, your company would purchase the basic stripped down model jeep from Chrysler and add the body, stereo, air conditioning, tires, running lights, carpeting, and high visibility seats. You state that the body would be one solid piece and that your company would add wheel wells, doors, a solid or canvas top, and a windshield. Alternatively, your company would purchase the chassis, with engine and transmission, from Chrysler and add the above items. I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. As you are aware, the National Highway Traffic Safety Administration (NHTSA) is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the Safety Act), to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. I will address the responsibilities of your company under the Safety Act in each of the situations you described. First, if your company purchased a stripped down vehicle from Chrysler and made the modifications described, it could be considered an alterer under our regulations. Under 49 CFR Part 567, Certification, an alterer is defined as: A person who alters a vehicle that has previously been certified . . . other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, . . . before the first purchase of the vehicle in good faith for purposes other than resale . . . . As an alterer, your company would be required to certify compliance of its vehicles with the Federal Motor Vehicle Safety Standards in accordance with 49 CFR Part 567. The only exception would be if: 1. The modifications consisted solely of 'readily attachable components,' or 2. The modifications were only 'minor finishing operations.' Whether modifications involve 'readily attachable' components depends on the difficulty in attaching those components. In the past, the agency has looked at such factors as the intricacy of installation and the need for special expertise. Without extraordinary ease of installation, NHTSA would not consider modifications involving the addition or substitution of seats to involve 'readily attachable' components. If considered an alterer, your company would be subject to the certification requirements of 49 CFR 567.7. These requirements include provisions that the alterer supplement the existing manufacturer certification label, which must remain on the vehicle, by affixing an additional label. The label would state that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards. The label would also state the alterer and the month and the year in which the alterations were completed. In addition to these certification requirements, an alterer is considered a 'manufacturer' for the purposes of the Safety Act. Among other things, this means an alterer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards, as specified in sections 151-160 of the Safety Act. Alterers also are subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports. Second, as an alternative, your company is considering buying a chassis from Chrysler. In that case, your company would likely be considered a final-stage manufacturer. Under 49 CFR Part 568, Vehicles Manufactured in Two or More Stages, a final-stage manufacturer is defined as: A person who performs such manufacturing operations on an incomplete vehicle that it becomes a completed vehicle. Under the regulation, incomplete vehicle is defined as An assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle. As a final-stage manufacturer, your company's certification responsibilities would depend on the information provided by the manufacturer of the incomplete vehicle. Under 49 CFR Part 568, the incomplete vehicle manufacturer must furnish your company with a document which states one of the following three things concerning the incomplete vehicle: 1. The vehicle when completed will conform to some or all of the applicable safety standards if no alterations are made to any identified components of the incomplete vehicle, 2. The vehicle when completed will conform to some or all of the applicable safety standards if specific conditions are followed by the final-stage manufacturer, 3. Conformity with some or all of the applicable safety standards is not substantially affected by the design of the incomplete vehicle, so the incomplete vehicle manufacturer makes no representation as to conformity with the standards. After receiving this document from the incomplete vehicle manufacturer, your company would be required to certify compliance with the safety standards. In addition to these certification requirements, a final-stage manufacturer is considered a 'manufacturer' for the purposes of the Safety Act. Among other things, this means a final-stage manufacturer is responsible for notification and remedy of defects related to motor vehicle safety and noncompliances with applicable Federal motor vehicle safety standards, as specified in sections 151-160 of the Safety Act. In addition, final-stage manufacturers are subject to the requirements of 49 CFR Part 573, Defect and Noncompliance Reports. I am also enclosing a general information sheet for manufacturers of new vehicles. This sheet highlights the relevant Federal statutes and regulations and explains how to obtain copies of the regulations. I hope that this information is useful. If you have any further questions, please contact John Rigby at 202-366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam4938OpenMr. Takashi Odaira Chief Representative Emission & Safety Isuzu Technical Center of America, Inc. 46401 Commerce Center Drive Plymouth, MI 48170; Mr. Takashi Odaira Chief Representative Emission & Safety Isuzu Technical Center of America Inc. 46401 Commerce Center Drive Plymouth MI 48170; "Dear Mr. Odaira: This responds to your letter asking about the ne dynamic requirements of Safety Standard No. 214, Side Impact Protection. You noted that the rear seat requirements do not apply to passenger cars which have rear seating areas that are so small that the Part 572, subpart F dummies cannot be accommodated according to the specified positioning procedure. You asked whether a test dummy should nonetheless be placed on the rear seat of such vehicles when conducting the specified dynamic test. As discussed below, the answer to your question is no. Section S3 of Standard No. 214 includes the following language concerning the dynamic side impact requirements: Part 572, subpart F test dummies are placed in the front and rear outboard seating positions on the struck side of the car. However, the rear seat requirements do not apply to passenger cars with a wheelbase greater than 130 inches, or to passenger cars which have rear seating areas that are so small that the part 572, subpart F dummies cannot be accommodated according to the positioning procedure specified in S7. Reading these two sentences together, it is our interpretation that a test dummy should not be placed in the rear outboard seating position of passenger cars which have rear seating areas that are so small that the part 572, subpart F dummies cannot be accommodated according to the positioning procedure specified in S7. While the first sentence states that the test dummies should be placed in both the front and rear outboard seating positions on the struck side of the car, that provision is limited by the sentence which immediately follows. That second sentence makes it clear that the rear seat requirements do not apply to certain vehicles with small rear seating areas. Since the sole purpose for placing a test dummy in the rear outboard seating position is to measure compliance with the dynamic side impact requirements, a test dummy should not be placed in the rear seating position of a passenger car for which the rear seat requirements do not apply. I hope this information is helpful. If you have further questions, please contact Edward Glancy of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam2415OpenMr. Ronald W. Cooke, Engineering Manager, E. Edelmann & Co., Route 38, Airport Industrial Park, Dixon, IL 61021; Mr. Ronald W. Cooke Engineering Manager E. Edelmann & Co. Route 38 Airport Industrial Park Dixon IL 61021; Dear Mr. Cooke: Thank you for your letter of August 19, 1976, to Dr. James B. Gregory requesting information on aftermarket gas caps as they relate to compliance with Federal Motor Vehicle Safety Standard (FMVSS), No. 301. Your inquiry has been forwarded to this office for reply. Apparently your letter of May 26, 1976, was either lost or misdirected, as we can find no record of it in our files, and we sincerely apologize for this delay in responding to your inquiry.; The National Highway Traffic Safety Administration does not regulat vehicle fuel tank caps as such, however, FMVSS No. 301, Fuel System Integrity, specifies performance requirements to assure the integrity of the entire vehicle fuel system (which includes the fuel tank cap) in various crash modes.; Thus, if installation of your replacement cap is accomplished prior t the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the cap or offering the vehicle for sale would be in violation of S108(a)(1) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-503). That would make the installer or seller subject to civil penalties of up to $1,000 for each violation.; Recent amendments to the Traffic Safety Act (Pub. L. 932-492) prohibi any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard (S108(a)(2)(A)). Thus, it is illegal for any of the above named persons to install a fuel tank cap that he knows will cause the vehicle to be in non-compliance with the fuel system integrity standard. Federal Law does not, however, prohibit the owner of a vehicle from purchasing and installing a fuel tank cap of his choice on his own vehicle, even though he may compromise the Fuel System Integrity Standard.; We are interested in any information regarding safety problem associated with replacement gas caps as a basis for further action. If you could provide any such information, we would be most grateful.; Thank you for sharing your thoughts with us. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0428OpenMr. William H. Lawson, Jr., Manager, Market Development, Sierracin Corporation, 12780 San Fernando Road, Sylmar, CA 91342; Mr. William H. Lawson Jr. Manager Market Development Sierracin Corporation 12780 San Fernando Road Sylmar CA 91342; Dear Mr. Lawson: This is in reply to your letter of August 4, 1971, in which yo enclosed a copy of the manufacturer's symbol that would be used to identify windshields manufactured by the Sierracin Corporation, and ask whether the symbol is acceptable as illustrated. You also request our comments on requirements for the label location on the product.; The symbol you have enclosed complies with Motor Vehicle Safet Standard No. 205, 'Glazing Materials' and, except for the omission of a hyphen between the 'DOT' symbol and the manufacturer's code mark, also with the marking requirements proposed in the notice of January 9, 1971 (36 F.R. 326), which would amend certain provisions of the standard. We would consider this deviation to be inconsequential.; With reference to location requirements, the present standard does no specify a location for the windshield marking. The proposed amendment, which is still under consideration, would require the mark to be placed in the lower left hand corner of the windshield.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2100OpenMr. Chester Mercer, Jr., Mercer Machine & Hydraulics, Inc., 13060 Butler Street, Redding, Pennsylvania 19601; Mr. Chester Mercer Jr. Mercer Machine & Hydraulics Inc. 13060 Butler Street Redding Pennsylvania 19601; Dear Mr. Mercer: #I am writing to confirm your October 17, 1975 telephone conversation with Mark Schwimmer of this office concerning the requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. I understand that your company manufactures, from hose and end fittings supplied by other manufacturers, hydraulic brake hose assemblies for use in motor vehicles. #For your convenience, I am enclosing a copy of the standard (including two recent Federal Register notices) and an information sheet entitled 'Where to Obtain Motor Vehicle Safety Standards and regulations.' #The standard specifies performance and labeling requirements for brake hose, end fittings, and brake hose assemblies. As an assembly manufacturer, you must certify that your assemblies comply with the standard by affixing a band as set out in S5.2.4. A designation of your choice should identify you as the assembler. You need register this designation with the NHTSA only once, even if you also manufacture air brake hose assemblies. #While the standard generally requires assemblies to be manufactured from conforming hose and end fittings, an exception (set out in S12.) permits the use of hose and fittings which meet the performance requirements but not the labeling requirements, until August 31, 1976. (The labeling requirements for hose and fittings became effective September 1, 1974, this exception is designed to facilitate the depletion of inventories of such components manufactured before that date.) #The standard does not specify the testing which you must do, it does specify the performance levels which assemblies must meet when tested by the NHTSA for compliance. The National Traffic and Motor Vehicle Safety Act of 1966, as amended, requires you to conduct a notification and remedy campaign with respect to noncomplying assemblies. You are also subject to a civil penalty of up to $1,000 for each noncomplying assembly ( not to exceed $800,000 for each related series of noncompliances). The amount of testing which you perform has no effect on your notification and remedy obligations. If, however, you did exercise due care, you are not liable for the civil penalty. 'Due care' is a flexible concept. It is evaluated on a case-by-case basis, taking into consideration the size of your company, the amount of testing you perform, and other factors. #Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam5295OpenCheryl Graham, District Manager Northeast Region ARI P.O. Box 5039 Mt. Laurel, NJ 08054; Cheryl Graham District Manager Northeast Region ARI P.O. Box 5039 Mt. Laurel NJ 08054; "Dear Ms. Graham: We have received your letter of November 10, 1993 asking about the permissibility of aftermarket installation of an auxiliary pair of stop lamps 'at each side of the rear window.' By way of background information the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards under the authority of the National Traffic and Motor Vehicle Safety Act (Safety Act). Under that Act, the sole restraint upon modifications to vehicles in use is that, if performed by a manufacturer, distributor, dealer, or motor vehicle repair business, the modifications must not 'knowingly render inoperative, in whole or in part, any device or element of design installed on . . . a motor vehicle in compliance with an applicable Federal motor vehicle safety standard . . . .' (15 U.S.C. 1397(a)(2)(A)). In NHTSA's view, if the modifications tend to impair the safety effectiveness of the 'device or element of design', then, at the minimum, a partial inoperability may have occurred within the meaning of the statutory prohibition. The question raised by your letter, therefore, is whether the installation of the auxiliary stop lamps in that location would impair the effectiveness of the three original equipment stop lamps. NHTSA decided to require the center highmounted stop lamp in addition to the then-existing original equipment two-lamp stop lamp system following research which indicated that a three-lamp system of this configuration was demonstrably more effective in preventing rear end crashes than other rear end lighting systems that were tested, and considerably lower in cost. Included in the testing was a four-lamp system which incorporated two lamps at each side of the rear window, but no tests were conducted on the five-lamp system you describe. The reasons for the better performance of the three-lamp system are unclear, but the triangular lighting array proved to be more effective than the trapezoidal four-lamp system (and more effective than a system tested which separated the usual stop lamp from the taillamp). Your customer appears to believe that the ability of following drivers to avoid rear end crashes is enhanced by a five-lamp stop lamp system. On the other hand, your proposed system, by incorporating the two lamps at each side of the rear window, would appear to change the lighting array. We cannot say that the five-lamp system would either enhance or detract from safety. Thus, we cannot find that the additional lamps would 'render inoperative' the original equipment three-lamp system, and it would be permissible under the regulations of this agency. However, the permissibility of such a modification would be determinable under State law. We are unable to advise you on the laws of the various States and suggest that you write the American Association of Motor Vehicle Administrators for an interpretation. Its address is 4600 Wilson Boulevard, Arlington, VA 22203. You have also asked 'if the work is done improperly and results in an accident, where does the liability lie?' This question is a matter of state law, and we suggest that you consult a local attorney concerning it. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2550OpenMr. Robert B. Kurre, Director of Engineering, Wayne Corporation, P. O. Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre Director of Engineering Wayne Corporation P. O. Box 1447 Industries Road Richmond IN 47374; Dear Mr. Kurre: This responds to your December 10, 1976, petition to amend Standard No 222, *School Bus Passenger Seating and Crash Protection*. In your petition you request that the NHTSA withdraw the requirements for seat belts in buses with gross vehicle weight ratings (GVWR) of 10,000 pounds or less. Secondly, you suggest that the NHTSA reconsider the validity of establishing 10,000 pounds GVWR as the dividing line between buses that must be equipped with seat belts and those which need not be so equipped. The NHTSA denies your requested rulemaking.; The NHTSA mandated the installation of seat belts in school buses wit GVWR's of 10,000 pounds or less, because these vehicles are subject to different crash pulses than larger school buses under the same accident circumstances. To ensure adequate protection for children transported in these vehicles, the NHTSA applied to small school buses some of the seating requirements mandated for larger buses plus the installation of seat belts. Since we are aware of no data indicating that small buses do not need the additional protection provided by seat belts, the NHTSA considers the provision of seat belts in these school buses to be a necessary safety requirement.; The second recommendation in your petition suggests that the NHTS classification of vehicles into two groups, one with GVWR's of 10,000 pounds or less and another with GVWR's greater than 10,000 pounds, is arbitrary. You indicate that a vehicle weighing slightly more than 10,000 pounds will not react in a crash situation significantly different than a vehicle slightly under 10,000 pounds. Accordingly, you suggest that there is no valid reason to have different requirements for buses within a relatively narrow weight range.; The NHTSA has historically classified vehicles into the two weigh groupings you mention. This has been done in part because there are significant differences between large and small vehicles with respect to their reactions in crashes. The agency realizes that any line differentiating the two classes may seem arbitrary to manufacturers of vehicles that fall barely on either side of the line. Arguably, these vehicles, similar in many respects, would exhibit only minor differences in crash pulse in any given accident situation. Nonetheless, the classification is valid for the majority of vehicles in each class. Since we are aware of no data that would indicate that a line could better be drawn elsewhere, the NHTSA has decided to retain the present classification.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0097OpenMr. Toyotaro Yamada, Manager, Toyota Motor Company, Limited, 231 Johnson Avenue, Newark, NJ 07108; Mr. Toyotaro Yamada Manager Toyota Motor Company Limited 231 Johnson Avenue Newark NJ 07108; Dear Mr. Yamada: Thank you for your letter of July 23, 1968, to Mr. George C. Nield Acting Director, Motor Vehicle Safety Performance Service, concerning the requirements for turn signal and hazard warning signal flashers as specified by Motor Vehicle Safety Standard No. 108.; With certain exceptions, paragraph S3.3 of Standard No. 108 permits th use of combination lamps, reflective devices and items of associated equipment, provided the requirements for each lamp, reflective device and item of associated equipment are met. Therefore, a combination turn signal and hazard warning signal flasher may be used, provided the requirements for each signal (turn and hazard warning) are met.; You are correct in your understanding that Standard No. 108 an basically referenced SAE Standards J590 and J945 do not require operation of the flasher unit with only one signal bulb in the test circuit. The standard test circuit shown in Figure I of SAE Standard J823 indicates a minimum of two signal lamps and one pilot indicator lamp as the lamp load.; Thank you for writing. Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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.