NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
| Interpretations | Date |
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ID: aiam1972OpenMr. Gerhard P. Riechel, Attorney, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. Gerhard P. Riechel Attorney Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Reichel: This is in response to your letter of June 27, 1975, inquiring as t the permissibility under Standard No. 111, *Rearview Mirrors*, of offering for sale new vehicles equipped with louvers affixed to the outside of the rear window without installing a rearview mirror on the passenger side.; Standard 111 requires that an outside rearview mirror of substantiall unit magnification be installed on the passenger side of a vehicle where the field of view provided by the inside rearview mirror is obscured by objects other than seated occupants or head restraints. Based upon the information contained in your letter, it appears that the louver affixed to the rear window obstructs the view to the rear provided by the inside mirror. Since this louver does not fall within the two exceptions named in S3.1.1 of the standard (seated occupants and head restraints), a passenger side rearview mirror would be necessary to comply with the requirements of the standard.; The fact that the obstruction is only slight does not affect thi determination, since the standard is clear on the point that the only obscurity allowable is that caused by occupants or head restraints.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam5032OpenMr. Tim Flagstad 220 West 14th Street National City, CA 9l950; Mr. Tim Flagstad 220 West 14th Street National City CA 9l950; "Dear Mr. Flagstad: This responds to your FAX of June 20, 1992, wit respect to importation of a 1981 Kenworth truck from Canada. This vehicle bears VIN M911042. You state that you imported the truck on February 12, 1990, through 'a licensed broker and all necessary declarations and papers were properly submitted.' You have enclosed a letter from Kenworth of Canada dated March 6, 1991, stating that this truck was 'in compliance with the U.S. federal laws . . . at the time of delivery', which was August 31, 1981. Although you experienced no difficulty in titling the truck in California, the purchaser of your truck, resident in another state, is 'having a problem registering it' because the VIN has only seven characters. Joan Moniz, the daughter of the purchaser talked with Taylor Vinson of this Office on June 23, 24, and 25, 1992, and explained that the problem is that the State of Hawaii is requiring registration as a 1975 vehicle. According to her copy of the HS-7 importation form under which the truck entered the United States, Box 2 was checked, the declaration that the vehicle was manufactured to conform to all applicable Federal motor vehicle safety standards, and bears a certification label to that effect. However, according to her, the truck bears no U.S. certification label, and her records indicate that the date of importation and clearance was January 31, 1990. We are furnishing Ms Moniz a copy of this response. You ask whether paragraph S2 of Safety Standard No. 115 Vehicle Identification Number, exempts this vehicle from the 17-character requirement of paragraph S4.2, 'and make it legal in the United States with a seven digit number.' Paragraph S2 of Standard No. 115 applies to trucks and other motor vehicles, and states in pertinent part that 'Vehicles imported into the United States under Sec. 591.5(f), other than by a corporation which was responsible for the assembly of that vehicle, or a subsidiary of such a corporation are exempt from the requirements of S4.2 . . . .' Section 591.5(f) corresponds to Box 3 on the HS-7 importation form, the declaration that the vehicle to be imported was not manufactured in conformity with the safety standards but will be brought into conformity with them. However, S2 makes it clear that conformity does not require the nonconforming vehicle to meet the requirement of Standard No. 115 that VINs be composed of 17 characters. Indeed, S4.9(a) specifically requires passenger cars imported under part 591 to retain their original VINs. We note that the truck in question was imported under section 591.5(b) (Box 2), as a conforming vehicle, and, in a legal sense, is not eligible for the exclusion provided for vehicles imported under section 591.5(f). However, importation under section 591.5(b) was erroneous, since the truck bore no certification of compliance. Furthermore, in spite of the letter from Kenworth of Canada stating that the truck was 'in compliance with U.S. federal laws' at the time of its delivery on August 31, 1981, it manifestly failed to comply with Standard No. 115 which, as of September 1, 1980, required trucks to have 17-character VINs. Ms Moniz believes that is also lacks an air brake system as required by Federal Motor Vehicle Safety Standard No. 121. Lacking a certification label, the truck should have been imported under section 591.5(f), which would have excused it from compliance with the 17-digit requirement. I shall shortly address a possible resolution of this dilemma. You have also asked whether this truck should have been imported through a 'registered importer'. You state that Taylor Vinson told you in a recent telephone conversation that 'as U.S. Customs had accepted the vehicle's compliance to U.S. Safety Standards and had not required a bond, a registered importer was not required.' This opinion was based on the assumption that the letter from Kenworth of Canada attesting to the truck's conformance with U.S. safety standards had accompanied the vehicle's importation, and was accepted by Customs (for the record, NHTSA currently permits importation of Canadian vehicles without bond or reference to a registered importer provided that a conformance letter from the manufacturer has been submitted for the agency's approval before importation). However, we see that our assumption was incorrect, Kenworth's letter is dated March 1991, and could not have accompanied the truck when it was imported in 1990. If a Canadian-manufactured vehicle is not accompanied by such a letter (or a permanently affixed label certifying compliance to U.S. standards), the vehicle must be entered under section 591.5(f) (Box 3) by a registered importer or by an importer who has a contract with a registered importer who will assure compliance with all the standards. Therefore, the truck in question was subject to the requirement that it be imported by a registered importer, or by a person who had a contract with a registered importer. Furthermore, the truck could not have been admitted into the United States unless the Administrator of this agency had determined that it was capable of conformance to meet the Federal motor vehicle safety standards, and the Administrator had made no such determination. However, the effective date of section 591.5(f), the registered importer requirement, and the vehicle capability requirement was January 31, 1990, the date that the truck appears to have been imported into the United States. Both Customs personnel and brokers should have been aware of the new requirements that became effective on that date. However, as of that date (and for some months thereafter), no registered importers had been appointed, and no vehicle capability determinations had been made. Thus, even if the truck had been imported pursuant to section 591.5(f), this could not have been accomplished until much later in 1990 when the agency made a blanket capability determination concerning Canadian vehicles. Because of the passage of time and the apparent present location of the truck in Hawaii, the agency has no interest in requiring re-entry of this vehicle at this date to conform with regulations that went into effect the date that it was imported. As for the problem of the truck's registration, it is curious that Hawaii would wish to register as a l975 model-year truck a vehicle that was manufactured in 1981. Perhaps the State simply wishes to treat it as a vehicle that conforms to standards in effect in 1975, and does so by assigning it a model year reflecting a time before Standard No. 115 required a 17- character VIN, and before the effective date of Standard No. 121. In any event, Hawaii has recognized that S2 of Standard No. 115 permits the importation of a truck to which the 17-character VIN requirement of S4.2 does not apply. Sincerely, Paul Jackson Rice Chief Counsel cc: Ms Joan Moniz 45623 Halekou Road Kaneohe, Hawaii 96744"; |
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ID: aiam0230OpenDavid Sugarman, Esq., 119 West 57th Street, New York, New York 10019; David Sugarman Esq. 119 West 57th Street New York New York 10019; Dear Mr. Sugarman: In response to your letter of April 16 I enclose copies of Federa Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, 'SAE Technical Reports Referenced in Federal Motor Vehicle Safety Standards'.; The answer to your first question is that Standard No. 108 require passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle 'as far forward as practicable', and one marker and one reflector, red in color, on each side of the vehicle, 'as far to the rear as practicable'. Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverdi displayed at the recent New York show were amber and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standard applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.; In answer to your second question, Table III of Standard No. 10 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.; You have asked in your third question whether headlamps may be place in the grille. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.; Standard No. 107 does not specify a particular color for the horn rin and hub of the steering assembly but it does specify a maximum permissible value for specular glass.; Finally, other than Standard Nos. 205 (Glazing Materials) and 21 (windshield Mounting which all passenger cars must meet, there is no 'specific safety requirement as to the windshield' for convertibles, and there is no 'requirement as to a roll bar'.; Sincerely, Lawrence R. Schneider, Chief, Regulations Division |
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ID: aiam4273OpenMr. George Ziolo, 16182 Arena Drive, Ramona, CA 92065; Mr. George Ziolo 16182 Arena Drive Ramona CA 92065; Dear Mr. Ziolo: Thank you for your letter of September 19, 1986, concerning th labeling requirements of Standard No. 209, *Seat Belt Assemblies*. Those requirements provide that each safety belt is to be labeled with the year of its manufacture. You asked whether the year of manufacturer can be shown in code. As explained below, the answer is no, the standard does not provide for showing the year of manufacture in code.; S4.1(j) of the standard requires each safety belt to be permanently an legibly labeled with the name of the manufacturer, distributor, or importer, the model of the safety belt model, and 'the year of manufacture.' The standard specifically requires the date of manufacture to be provided on the belt and does not provide for the use of a code to represent that date.; The purpose of the labeling requirement is to make it possible for th agency and consumers to identify easily the manufacturer of the safety belt for the purpose of noncompliance and safety-related defect investigations and notification and remedy campaigns. In addition, having the date of manufacture clearly marked on the belt assists consumers in determining whether a particular belt complies with the latest requirements of Standard No. 208 or some earlier version of those requirements. It also assistant the agency in compliance testing of aftermarket and other safety belts because it enables the agency to determine easily which version of the standard should be applied to that safety belt. Having the year shown in a code can complicate the easy identification of which safety belts are covered by an investigation or campaign and make it more difficult to determine which version of the standard applies to the safety belt.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4789OpenMr. Robert Roden Roden & Hayes 2015 First Avenue No., Suite 400 Birmingham, AL 35203; Mr. Robert Roden Roden & Hayes 2015 First Avenue No. Suite 400 Birmingham AL 35203; "Dear Mr. Roden: This responds to your questions about the requirement for key-locking systems in section S4.2(b) of Federal Motor Vehicle Safety Standard No. 114, Theft Protection (49 CFR 571.114). As explained below, the enclosed copy of the agency's recent final rule amending this provision may be relevant to your inquiry (55 FR 21868, May 30, 1990). By way of background, the National Traffic and Motor Vehicle Safety Act, ('Vehicle Safety Act,' 15 USC 1381 et seq.) requires every new motor vehicle sold in the United States to be certified as complying with all applicable Federal motor vehicle safety standards. The Vehicle Safety Act specifies that the manufacturer must certify that each of its vehicles complies with all applicable safety standards in effect on the date of manufacture. Any person violating the Vehicle Safety Act by manufacturing or selling new noncomplying vehicles may be liable for potential penalties of $1,000 per violation up to $800,000 for a related series of violations. One such Federal safety standard is Standard No. 114, Theft Protection, which applies to passenger cars, and to trucks and multipurpose passenger vehicles having a gross vehicle weight rating of 10,000 pounds or less. Your first question asked whether section S4.2(b) requires key locking systems to prevent removal of the ignition key except when the transmission is in the 'park' position. Section S4.2(b) currently requires such vehicles to have a 'key-locking system that, whenever the key is removed, will prevent...(b) either steering or forward self-mobility of the vehicle, or both.' However, the agency has recently amended section S4.2(b) to read as follows: Each vehicle shall have a key-locking system that, whenever the key is removed, prevents: (a) the normal activation of the vehicle's engine or motor, and (b) either steering or forward self-mobility of the vehicle or both. For a vehicle equipped with an automatic transmission with a 'park' position, the key-locking system shall prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. You should be aware that this amendment takes effect on September 1, 1992. For vehicles manufactured before September 1, 1992, S4.2(b) merely requires that when the key is removed, the key-locking system must prevent steering or forward self-mobility, or both. This provision does not address the issue of the transmission's position at the time of key removal. In contrast, under the recent amendment applicable to vehicles manufactured on or after September 1, 1992, S4.2(b) requires automatic transmission vehicles to prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. Your second question asked whether a replacement key-locking system is required to comply with Standard No. 114. Because Standard No. 114 applies to new motor vehicles and not to motor vehicle equipment, the standard does not in itself require aftermarket replacement systems to comply with its requirements. However, you should be aware that section 108(a)(2)(A) of the Vehicle Safety Act prohibits manufacturers, distributors, dealers, or motor vehicle repair businesses from knowingly 'rendering inoperative,' in whole or in part, any device or element of design installed on or in a vehicle to comply with an applicable safety standard. Your third question asked how long the key locking system is required to perform under S4.2(b) of the standard. The Vehicle Safety Act only requires manufacturers to assure that vehicles and equipment comply with applicable safety standards at the time of the first consumer purchase. However, please note that if at any time a manufacturer or the agency determines that a vehicle or item of equipment contains a safety-related defect, which could result from the failure of a system to operate properly, the manufacturer is required to notify all product purchasers of the defect and remedy the defect without charge. See 15 U.S.C. 1411-1414. I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam1071OpenMr. R. K. Ferwerda, President, Great Southern Equipment Company of Tampa, 1023 South 50th Street, Tampa, FL 33619; Mr. R. K. Ferwerda President Great Southern Equipment Company of Tampa 1023 South 50th Street Tampa FL 33619; Dear Mr. Ferwerda: This is in reply to your letter of January 31, 1973, requesting 'a application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks'.; Under NHTSA regulations, the operations you perform appear to make yo a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, 'Manufacturer Identification'.; Copies of NHTSA regulations may be obtained as indicated on th enclosed. 'Where to Obtain Motor Vehicle Safety Standards and Regulations'. We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4623OpenMr. Robert V. Potter, Jr. Spalding & Evenflo Companies, Inc. 5750-A North Hoover Blvd. P.O. Box 30101 Tampa, FL 33630; Mr. Robert V. Potter Jr. Spalding & Evenflo Companies Inc. 5750-A North Hoover Blvd. P.O. Box 30101 Tampa FL 33630; Dear Mr. Potter: This responds to your March 17, 1989, letter askin whether the National Highway Traffic Safety Administration (NHTSA) requires child restraint manufacturers to make spare parts available for their products for a specified amount of time. I regret the delay in responding. NHTSA has addressed the availability issue you raise in a July 31, 1986, letter to Ms. Ziomek of Washington, Michigan, a copy of which is enclosed. As explained in that letter, NHTSA does not specifically require child restraint manufacturers to make replacement parts available for any child restraint. However, manufacturers must be prepared to meet their recall obligations under the National Traffic and Motor Vehicle Safety Act. That law requires that, in the event of a safety-related defect or non-compliance with a safety standard, manufacturers provide a remedy without charge to consumers for eight years after purchase. With regard to your statement about an existing Federal regulation requiring automobile manufacturers to make replacement parts available for 10 years, NHTSA does not have such a requirement. However, automobile manufacturers have the same recall responsibilities described above for safety-related defects and non-compliances. Further, we understand manufacturers commonly follow a voluntary practice of making replacement parts available for vehicle parts likely to become worn or damaged for a 10-year period, which to the best of our knowledge has usually proven adequate to meet general consumer demand. I hope this information is helpful. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure; |
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ID: aiam1421OpenGorou Utsunomiya,Branch Manager,Toyo Kogyo Co., Ltd.,U.S.A. Representative Office,Detroit Branch,23777 Greenfield Rd. S462,Southfield, Michigan 48075; Gorou Utsunomiya Branch Manager Toyo Kogyo Co. Ltd. U.S.A. Representative Office Detroit Branch 23777 Greenfield Rd. S462 Southfield Michigan 48075; Dear Mr Utsunomiya:#This responds to your February 1, 1974, request fo interpretation of Standard No. 106, *Brake hoses*, concerning 'collapse' in S9.2.8, an incorrect value in Table VI, and proper labeling format.#Your confusion about the meaning of 'collapse' in S9.2.8 points out that the requirement was inadvertently changed between notices 7 and 8 and that it should require 'no leakage or separation of the inner tube from the fabric reinforcement of the hose'. The language will be amended in the near future.#In our response to petitions for reconsideration of Standard 106, we corrected the 5/64 value (question 2) and we accommodated labeling of short hose by permitting labeling separated by any amount up to 6 inches (question 4). You must use one line for labeling required by Standard 106, but you may interrupt the stripe on the opposite side of the required labeling with labeling for other countries, in accordance with S5.2.1 (question 5). in answer to question 3, the fractions should read 3/16, as your indicate you wish to do it.#Your associate, Mr Hirai, asked our office for an explanation of the certification requirements of S144 of the National Traffic and Motor Vehicle Safety Act of 1966, as they apply to items of motor vehicle equipment to which a standard applies. I have enclosed a notice of clarification. #Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam1134OpenMr. Doran Rhodes, Assistant to the President, Highway Aircraft Corporation, 909 Fifth Avenue, Box 651, Sidney, NE 69162; Mr. Doran Rhodes Assistant to the President Highway Aircraft Corporation 909 Fifth Avenue Box 651 Sidney NE 69162; Dear Mr. Rhodes: This is in reply to your letter of April 24, 1973, to Mr. Schneide asking for an interpretation that the Fascination vehicle your company proposes to manufacture is 'an automobile.' You state that you 'are currently testing both a single wheel and a dual wheel arrangement in the front, and it is not clear yet which one will prevail.'; If the final configuration of the Fascination were that of four-wheeled vehicle it would be categorized as a 'passenger car' under the Federal Motor Vehicle Safety Standards. Currently all three-wheeled vehicles are classified under our regulations as 'motorcycles.' Under a recent rule making proposal, a copy of which I enclose, the definition of a motorcycle with three wheels would be restricted to those lacking a full or partial enclosure for the driver, clearly excluding the Fascination. If the proposal is adopted, and you choose the three-wheel configuration for the Fascination, then the vehicle would probably be classified as a passenger car. It is possible that some adjustments would be made in the standards applied to three-wheeled or other lightweight vehicles, on petitions received from those interested.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3109OpenMr. C. J. Newman, Vice President, Engineering, The Grote Manufacturing Company, State Rt. 7 - P.O. Box 766, Madison, IN 47250; Mr. C. J. Newman Vice President Engineering The Grote Manufacturing Company State Rt. 7 - P.O. Box 766 Madison IN 47250; Dear Mr. Newman: This is in reply to your letter of August 23, 1979, to the former Chie Counsel Joseph J. Levin, Jr. You have asked whether a double-faced turn signal front side marker lamp 'meets the intent' of Motor Vehicle Safety Standard No. 108, and you enclosed a sample of the lamp for our inspection.; You have quoted paragraph 3.4 of SAE Standard J588e, September 1970 which states 'the flashing signal from a double faced signal lamp shall not be obliterated when subjected to external light rays from either in front or behind at any and all angles.' It is not possible to make a definitive statement about your lamp without actually subjecting it to a representative external light source such as the headlamps of a vehicle in proximity to the vehicle to which the lamp is mounted, but its design appears adequate to meet the intent of paragraph 3.4. Any changes in design of the lenses or baffling from that of the sample lamp submitted, however, might transmit more light from external sources and may not meet paragraph 3.4.; We would also like to observe that since the side marker signal use the front and rear lenses of the turn signal in a single compartment a high intensity ratio of turn signal to side marker signal will be needed if the steady burning light from the side marker lamp is not to obscure the darker portion of the turn signal lamp.; Sincerely, Frank Berndt, Chief Counsel |
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.