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: aiam3088OpenMr. T. Ohinouye, MMC Services, Inc., Suite 1960, 3000 Town Center, Southfield, MI 48075; Mr. T. Ohinouye MMC Services Inc. Suite 1960 3000 Town Center Southfield MI 48075; Dear Mr. Ohinouye: This responds to your recent letter requesting an interpretatio concerning the proper 'designated seating capacity' for the 'Dodge D-50' and 'Plymouth Arrow' pick- up trucks. The trucks with which you are concerned have bench seats with 53.5 inches of hip room, with a contoured indentation at the center position for the gear shift lever. You believe that only two positions should be designated for this type of bench seat.; As stated in the preamble to the recent notice amending the definitio of 'designated seating position', and noted in your letter, the presence of a floor gear-shift lever would not normally be sufficient to discourage or make use of the center position on a large bench seat impossible, even if the bench seat has a slightly indented contour for the shift lever (44 FR 23232, April 19, 1979). The notice did state that there could conceivably be a vehicle design in which the gear-shift lever would constitute an impediment to sitting. For example, if the lever extended to within a few inches of the seat back, the center position could not easily be used. This does not appear to be the case with the 'Dodge D-50' or 'Plymouth Arrow', however.; Since the bench seats in the subject vehicles have 53.5 inches of hi room, well over the 50-inch caveat in the amended definition, it is the agency's opinion that there should be three designated seating positions. The photographs enclosed in your letter show that three test dummies can be placed on the bench seat, even though somewhat crowded. Moreover, these photographs show two 95th-percentile male dummies and one 5th-percentile female dummy. If two (or three) 5th-percentile female dummies had been used in your demonstration, instead, you would have illustrated that there is more than ample room for three passengers to sit comfortably on a 53.5-inch bench seat. Also, human beings obviously have more flexibility than the stiff test dummies used in your demonstration. We believe that if you use human subjects in this same experiment (a 95th-percentile male driver and two 5th-percentile female passengers, for example), you will see that three persons can easily and comfortably occupy these bench seats.; Finally, I would emphasize that this letter only represents th agency's opinion based on the information supplied in your letter. The NHTSA does not pass approval on any vehicle design, for any safety standards, prior to the actual events that underlie certification. It is up to the manufacturer to determine whether its vehicles comply with all applicable safety standards and regulations, and to certify its vehicles in accordance with that determination.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3122OpenMr. Charles F. Finn, Volkswagen of America, 27621 Parkview Boulevard, Warren, MI 48092; Mr. Charles F. Finn Volkswagen of America 27621 Parkview Boulevard Warren MI 48092; Dear Mr. Finn:#This responds to your letter requesting a interpretation of Federal Motor Vehicle Safety Standard 101-80, Controls and Displays. Specifically, you asked whether a 'barely discernible' light on the headlamp control, which is activated when the ignition is turned to the 'on' position, complies with the requirements of the standard. Under S5.3.3, 'any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable ....' Since the light in question is not activated when the headlamps are activated, it need not meet the intensity requirements of S5.3.3.#Sincerely, Frank Berndt, Chief Counsel; |
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ID: aiam2363OpenMr. Malcolm B. Mathieson, Engineering Manager, Thomas Built Buses, Inc., 1408 Courtesy Road, P. O. Box 2450, High Point, NC 27261; Mr. Malcolm B. Mathieson Engineering Manager Thomas Built Buses Inc. 1408 Courtesy Road P. O. Box 2450 High Point NC 27261; Dear Mr. Mathieson: this responds to Thomas Built Buses' June 4, 1976, question whether th requirements in S5.1.3 and S5.1.4 of Standard No. 222, *School Bus Seating and Crash Protection*, to 'Apply additional force...through the...loading bar until (a specified number) of inch-pounds of energy has been absorbed in deflecting the seat back...' can be satisfied in part by the energy that is returned to the load bar as it is withdrawn from the seat back. You also ask if there are minimum or maximum time limits on withdrawal of the loading bar from the seat surface.; The requirement for the absorption of a minimum amount of energy i deflecting the seat back in the forward and rearward directions is calculated to provide adequate measurement of the energy involved in the impact between the bus occupants and the seating in a percentage of school bus crashes. The agency calculated the amount of energy to be consumed by the seat back that would result in adequate protection. The specification requires the seat to 'absorb' (i.e., receive without recoil) a specific amount of energy. This value is represented by the amount of energy that is not returned to the loading bar as it is withdrawn. Described graphically, the area that represents returned energy under the seat back force/deflection curve must be subtracted from the entire area that lies under the curve in order to calculate the energy 'absorbed' by the seat back.; With regard to your second question, no time limits have bee established for withdrawal of the loading bar. The agency intends to utilize a withdrawal time that is not more than five minutes so that creep will not be a significant factor in determining energy absorption. Because the time is not specified, the manufacturer is free to use any reasonable time that does not significantly affect the elastic and plastic components of the seat back loading.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2699OpenMr. Tokio Iinuma, Nissan Motor Co., Ltd., P.O. Box 1606, 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Tokio Iinuma Nissan Motor Co. Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Iinuma: This is in response to your letter of October 11, 1977, askin questions regarding application of the set and dent limitations contained in Part 581, *Bumper Standard*.; Your letter contained a series of diagrams about which questions on th applicability of the bumper damage criteria were asked. The questions are answered in the order in which they were posed.; 1. A total deformation of 9/8-inch is allowed only at the points on th bumper which actually come into contact with the impact ridge of the pendulum test device or the barrier face. All other bumper surfaces are limited to deformation no greater than 3/4-inch set.; 2. The crack illustrated in Question 2 would not be a dent as describe in S 581.5(c)(11)(ii). A crack that did not entail a measurable separation of the exterior surface of the bumper face bar, would not constitute a deviation in the contour of that component.; 3. Dimension A measures the change in contour and should be used t determine the size of the dent at the point of contact with the impact ridge of the pendulum test device or the barrier face.; 4. The straight line to measure the dent would be that labeled 'D since it connects the bumper contours adjoining the area of contact with the impact ridge of the pendulum test device. The size of the dent would be the distance from the original contour surface to the final deformation surface at the point of contact with the impact ridge.; 5. Dimension B identifies the amount of bumper set since it marks th distance of maximum change in the position of the bumper face bar relative to the vehicle frame.; 6. Since dents only occur at the point of contact with the impact ridg of the pendulum test device or the barrier face, the deformations described in the illustrations would be set.; 7. Since the deformation is not at the point of contact with either th impact ridge of the pendulum test device or the barrier face, it is set.; 8. If the operating force initially required to open the hood followin impact is within a range that permits operation by the normal universe of drivers, unaided by any tools, it would probably not be considered a noncompliance under the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam2733OpenMr. Takashi Shimoda, Nichirin Rubber Industrial Co., Ltd., 1118, Sazuchi, Bessho, Himeji, Japan; Mr. Takashi Shimoda Nichirin Rubber Industrial Co. Ltd. 1118 Sazuchi Bessho Himeji Japan; Dear Mr. Shimoda: This responds to your letter dated November 29, 1977, asking about th procedures for obtaining approval of hydraulic brake hoses. Your company is altering the labeling on some of its hose and asks whether the hose must be retested and whether notice of the changes must be given.; The National Highway Traffic Safety Administration (NHTSA) does no approve in advance motor vehicles or motor vehicle equipment. It is up to manufacturers to certify that their products comply with all applicable safety standards and regulations. The NHTSA conducts compliance testing for purposes of enforcement.; It is, therefore, up to your company to decide whether to test its hos according to the procedures specified in Safety Standard No. 106, *Brake Hoses*. The NHTSA only requires that you determine in the exercise of due care that the hose meets all requirements specified in the standard. Further, you do not have to give the NHTSA notice when you change the labeling information on your hose, unless you change the designation identifying your company. In that case, the new designation would have to be filed with the NHTSA according to the specifications of paragraph S5.2.2(b) of Standard 106.; You will have to contact the American Association of Motor Vehicl Administrators directly to determine their requirements for approval and notification following your labeling changes.; Please contact me if our office can be of any further assistance. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3821OpenMr. Leslie R. Ablondi, Pleasant Valley Corporate Center, Suite 800, 2024 Arkansas Valley Drive, Little Rock, AR 72212- 4237; Mr. Leslie R. Ablondi Pleasant Valley Corporate Center Suite 800 2024 Arkansas Valley Drive Little Rock AR 72212- 4237; Dear Mr. Ablondi: This responds to your March 16, 1984 letter regarding the applicabilit of Federal Motor Vehicle Safety Standard (FMVSS) 111 to an aftermarket rearview mirror which one of your clients proposes to market. This mirror would be attached to the original equipment inside mirror stalk in such a way that the view through the OEM mirror is unimpaired. Your client's mirror would permit the driver to view children in the rear seat of the vehicle.; FMVSS 111 (see 49 C.F.R. 571.111, copy enclosed) is directly applicabl to new motor vehicles only. However, that standard may apply indirectly to aftermarket mirrors through the operation of 15 U.S.C. 1397(a)(2)(A). The latter provision prohibits any motor vehicle manufacturer, distributor, dealer, or repair business from rendering inoperative any 'device or element of design installed on or in a motor vehicle...in compliance with an applicable Federal motor vehicle safety standard...' Thus, the installation of a replacement or even a supplemental rearview mirror in a motor vehicle could be unlawful if that installation resulted in a mirror system which did not comply with the requirements of FMVSS 111.; Based on your description of your client's mirror, it does not appea that the aftermarket installation of that mirror would be prohibited under 15 U.S.C. 1397(a)(2)(A), since the operation of the OEM mirror system is unaffected by the addition of the aftermarket mirror.; If you have any further questions on this matter, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam5019OpenMr. Frank J. Sonzala Senior Vice President International Transquip Industries, Inc. 6131 Brookhill Drive Houston, Texas 77087-1131; Mr. Frank J. Sonzala Senior Vice President International Transquip Industries Inc. 6131 Brookhill Drive Houston Texas 77087-1131; Dear Mr. Sonzala: Thank you for your letter regarding Federal Moto Vehicle Safety Standard No. 121, Air Brake Systems. Your company is a manufacturer of air brake systems and is apparently having difficulty selling your product to vehicle manufacturers because of a compliance issue related to Standard No. 121. I am pleased to provide you the following information. By way of background information, the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, the Safety Act requires manufacturers to certify that their vehicles or equipment comply with applicable safety standards. Standard No. 121 specifies braking requirements for vehicles equipped with air brake systems. The purpose of the standard is to ensure safe braking performance under normal and emergency conditions. The standard applies only to motor vehicles and not to motor vehicle equipment. Therefore, vehicle manufacturers are responsible for ensuring compliance with the standard, and not brake equipment manufacturers such as ITI. The dispute between ITI and the vehicle manufacturers (you use the term 'original equipment manufacturers') relates to the standard's parking brake requirements. The specific requirement at issue, set forth at S5.6 of Standard No. 121, requires a vehicle's parking brake to meet certain grade holding requirements (or other equivalent requirements) with 'any single leakage-type failure' of certain parts, including service brake chamber diaphragms. The purpose of this requirement is to ensure that a driver can safely park his or her vehicle in the event of a leakage-type failure in the service brake system. Leakage-type failures include such things as ruptured or severed brake hoses and torn diaphragms. Since these types of failures are relatively common in air brake systems, NHTSA believes that it is important that drivers be able to safely secure heavy trucks and other vehicles with such failures, until the vehicles can be repaired. For the purpose of determining whether a vehicle can meet Standard No. 121's grade holding requirements with one particular leakage-type failure, a failed diaphragm, IT would like the standard to be interpreted to cover only a very limited and specific type of failure, i.e., a hole 1/8 inch in size located in a particular place. Your letter states that the vehicle manufacturers generally have a broader view of what constitutes a failed diaphragm, i.e., they believe that failures include holes larger than 1/8 inch. You argue that Standard No. 121 is ambiguous in this area and requests NHTSA to issue an interpretation supporting your position. After reviewing this matter, we can state that the vehicle manufacturers are correct in their understanding that a failed diaphragm is not limited to a diaphragm wit a 1/8 inch hole. Therefore, if a vehicle cannot pass Standard No. 121's grade holding test with a larger hole in a failed diaphragm, the vehicle manufacturer cannot certify that the vehicle complies with the standard. Further, we disagree with ITI's contention that Standard No. 121 is ambiguous as to what constitutes a failed diaphragm. As indicated above, Standard No. 121 specifies that the grade holding requirements must be met with any single leakage-type failure of certain parts, including a failed diaghragm. The usage of the term 'any,' when used in connection with a set of items, is specifically designed at 49 CFR 571.4 as meaning the totality of that set of items, any one of which may be selected by the Administration for testing. Thus, a vehicle must meet the grade holding requirements regardless of the extent of the failure selected by NHTSA for testing. We note that leakage-type failures of many types and sizes can occur in vehicle brake systems. NHTSA intentionally did not limit the size or location of such failures in developing this requirement to ensure that a vehicle has adequate grade holding performance regardless of the specific nature of such a failure. You also asked whether other broken components, such as heavy parking springs, brake shoes, linings, and drums should be part of Standard No. 121's test requirements, since diaphragms are tested when torn. Although NHTSA's brake standards do not have any express test requirements for broken parking springs, brake shoes, linings or drums, those standards include a number of requirements to ensure adequate braking performance in the event of various failure in a vehicle's brake system. We hope that this information is helpful. Sincerely, Paul Jackson Rice Chief Counsel Enclosure; |
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ID: aiam2226OpenMr. James C. Murphy, Assistant Vice President, National Association of Independent Insurers, 2600 River Road, Des Plaines, Illinois 60018; Mr. James C. Murphy Assistant Vice President National Association of Independent Insurers 2600 River Road Des Plaines Illinois 60018; Dear Mr. Murphy: This is in response to your letter of February 17, 1976, in which yo asked that we reconsider our opinion of January 13 that any State laws regulating the content of vehicle identifications numbers (VIN's) would be preempted by Standard No. 115. Your reason was that the lack of standardization of VIN's caused many problems for insurance companies, State licensing agencies, and traffic enforcement agencies.; I think you might have misunderstood our intention concerning VIN's W agree that non-standardization of them is costly to all concerned, and we are working actively to promulgate a standardizing amendment to Standard 115. We are concerned, moreover, that if the States do not act in a uniform manner in laying down requirements for manufacturers, they might impose severe and unnecessary costs on them (and the public). This, of course, was the reason why Congress inserted the preemption provisions in the Vehicle Safety Act in the first place.; We want very much to have a system that applies not only to all State and all manufacturers, but to all the countries of the world, so that vehicles may move freely without danger of running afoul of identification standards. We have been working closely for several years with the International Standards Organization and the Society of Automotive Engineers to arrive at an acceptable world-wide uniform system. Our development work is finished now, and we expect to be issuing a proposal shortly for such a uniform system. We will appreciate your interest and your help in finalizing our standard in this area.; Sincerely. James B. Gregory, Administrator |
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ID: aiam5449OpenAlbert W. Unrath, Sr., President Albert W. Unrath, Inc. P.O. Box 631 Colmar, PA 18915 Dear Mr. Unrath:; Albert W. Unrath Sr. President Albert W. Unrath Inc. P.O. Box 631 Colmar PA 18915 Dear Mr. Unrath:; "This responds to your request for an interpretation of how NHTSA' regulations apply to your company's plans to refurbish used vehicles. In a telephone conversation with Dorothy Nakama of my staff, you explained that after refurbishing, the vehicles will have lower gross vehicle weight ratings (GVWRs). You wish to know whether you could add a label showing the lower GVWR to the vehicles' original certification label (which you refer to as the 'original Vin Plate'). As explained below, NHTSA does not require the supplementary label on a refurbished--and not newly manufactured--used vehicle. We would, however, encourage you to add the label on the refurbished vehicles, since the label would provide important safety information to the vehicle operator. On the other hand, the modifications you make to the vehicle could be so extensive that the resulting vehicle is considered 'new' under our regulations. If the vehicle is a new vehicle, you must certify the vehicle as complying with all applicable Federal motor vehicle safety standards (FMVSS's), and include on your certification label the new GVWR of the vehicle. Based on the information you provided, the vehicles you are refurbishing are 'trucks' under section 571.3 of our regulations. Section 571.3 defines a 'truck' as a motor vehicle with motive power 'designed primarily for the transportation of property or special purpose equipment.' You provided two photographs of the vehicles after they have been refurbished. Your photographs show the refurbished vehicles as carrying 4' x 8' 'Advanced Warning Flashing Arrow' signs on flat beds. Since your vehicles are designed for transporting property or special purpose equipment, the vehicles are 'trucks' under 571.3. You describe your refurbishing process in your letter. You state that you will take a used truck with a GVWR of 45,000 or 80,000 pounds (lbs.), 'scrap' the body, and check remaining truck parts such as the subframe, brakes, steering system, axles, and suspension. You will repair and replace those parts, as needed. Next, you will clean and paint the frame and running gear, and add a new support frame and 'attenuator mounting hardware with braces.' After the vehicle is refurbished, its GVWR will be approximately 25,500 lbs. As a general rule, NHTSA has no requirements for 'used' vehicles. Whether a vehicle is considered new or used depends on the origin of its parts. For example, we regard an assemblage of a new body on a chassis of a vehicle that was previously registered for use on the public roads to be a 'used' vehicle and therefore not subject to the FMVSS's. When a modified chassis is being used in the refurbishment, NHTSA has a regulation (49 CFR section 571.7(e)) for determining when the modifications to the used chassis are so extensive that the resulting vehicle will be considered new for the purposes of the FMVSS's. Section 571.7(e) states: When a new cab is used in the assembly of a truck, the truck will be considered newly manufactured . . ., unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components were taken from the same vehicle. It does not appear that you plan to add a new engine, transmission, or drive axle to each refurbished truck. If you leave the requisite components specified in section 571.7(e) in place from the previous vehicle, we would consider the vehicle you produce to be a used vehicle. However, please keep in mind that you would be subject to the provisions of 49 U.S.C. section 30122(b), which provides that: 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 ... in compliance with an applicable Federal motor vehicle safety standard . . . This means that the refurbished truck must continue to meet the FMVSS's that it met before the modification, such as those for braking, lighting and safety belt systems. Any violation of this 'make inoperative' prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation. You ask whether, after refurbishing the used truck, your company may affix additional labels with a new GVWR to reflect the lower GVWR. Since NHTSA generally does not regulate used vehicles, we do not require or prohibit the addition of a supplementary GVWR label. However, we would encourage you to add the supplementary GVWR label to the vehicle. As you note, in an interpretation letter of May 24, 1993 to the American Association of Blood Banks (AABB), NHTSA recognized that certain modifications that might be made to a used vehicle (e.g., adding or deleting an axle) could make the originally assigned GVWR inappropriate for the vehicle as modified. In the letter to the AABA, NHTSA stated that although it is not required by our regulations, we believe it would be appropriate in these situations to add a label to the vehicle which indicates the appropriate loaded weight of the modified vehicle. Similarly, in your case, since the GVWR of the refurbished trucks would be much lower than that indicated on the certification label, we believe it would be appropriate for your company to add a label to the trucks which indicates the appropriate loaded weight of the refurbished truck. As noted at the beginning of this letter, it is possible that your modifications could result in a 'new' vehicle. You indicate that, if needed, you could replace the vehicle's subframe, brakes, steering system, axles, suspension, and/or support frame. If you were to remove all the drive components from the frame of the original vehicle and add new drive components or rebuilt drive components from different vehicles, the vehicle would be a new vehicle and would have to be certified by you as complying with all applicable FMVSS's in effect on the date of the remanufacture of the new vehicle. You also asked that NHTSA 'approve' your proposed operations. NHTSA has no authority to 'approve' refurbishing operations. Under our regulations, manufacturers of new vehicles 'self-certify' that their vehicles comply with all applicable FMVSS's. Likewise, businesses refurbishing used vehicles must assure themselves that the resulting vehicle continues to meet the FMVSS's that it met before the modification. NHTSA can examine the refurbisher's determination in the context of an enforcement proceeding. I hope this information is helpful. If you have any other questions, please contact Dorothy Nakama at this address or by telephone at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel"; |
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ID: aiam2676OpenMs. Gail Burnette, Koons Leasing Inc., 30 Hillwood Avenue, Falls Church, VA 22046; Ms. Gail Burnette Koons Leasing Inc. 30 Hillwood Avenue Falls Church VA 22046; Dear Ms. Burnette: This responds to your September 12, 1977, telephone request to Roge Tilton of my staff concerning the applicability of the new Federal school bus safety standards to buses used to transport children to and from day care centers.; The National Highway Traffic Safety Administration (NHTSA) ha previously determined that day care center operators may not have been aware that their buses would fall within the ambit of the new standards. Therefore, the NHTSA has temporarily exempted these buses from the requirements. The agency is considering, however, extension of the standards to buses operated by these facilities. I am enclosing a letter in which the agency has detailed its reasons for the temporary exclusion of day care center buses from the new school bus safety standards.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.