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: aiam1187OpenMr. Dennis C. Sullivan, Pacific Gas and Electric Company, 77 Beale Street, San Francisco, CA 94106; Mr. Dennis C. Sullivan Pacific Gas and Electric Company 77 Beale Street San Francisco CA 94106; Dear Mr. Sullivan: This is in reply to your letter of June 21, 1973, inquiring as to you responsibilities regarding the conformity and certification of motor vehicles on which Pacific Gas and Electric Company (PG & E) performs certain manufacturing operations. You indicate that the operations involve 'body transfers,' in which used bodies are first removed from used trucks chassis, repaired and repainted, and then transferred to new cabs and chassis. The two questions you raise are:; >>>1) Must the vehicle comply with Federal motor vehicle safet standards at the time of the body transfer, and; 2) If not, need it comply at the time of sale to the public.<<< You indicate that your position is that you believe the answer to bot questions to be negative, that with respect to the first question, the vehicle need not conform nor be certified as conforming because no 'sale' of the vehicle has occurred, and with respect to the second question, you argue that the provisions of the National Traffic and Motor Vehicle Safety Act regarding used vehicles (Sec. 108(b)(1), 15 U.S.C. S 1397 (b)(1) appear to exempt these vehicles from conforming to the standards when they are sold.; We must disagree with both of your conclusions. We agree that th operations performed by PG & E, adding used bodies to new chassis, make PG & E a 'final-stage manufacturer' as defined in the Certification and Vehicles Manufactured in Two or More Stages regulations (49 CFR Parts 567, 568). The Certification regulations require that final-stage manufacturers who complete vehicles for their own use ascertain and certify conformity to all applicable standards as of the time the final-stage manufacturing operations are performed. We do not agree that section 108(b)(1) of the Safety Act (15 U.S.C. S 1397(a)(1)) applies only in connection with the sale of vehicles. That section also requires conformity with respect to the introduction and delivery for introduction of vehicles in interstate commerce. We have construed this language to include the use of any vehicle by its manufacturer on the public highways, even if the vehicle has not been sold. The responsibility for certification under the regulations is concomitant with the responsibility for conformity, and, similarly, is not dependent upon a vehicle sale.; The National Traffic and Motor Vehicle Safety Act, in our view, als requires a vehicle used by its manufacturer to conform to all applicable standards at the time of its eventual sale by that manufacturer. Our conclusion is based upon section 108(b)(1), which requires conformity until the first purchase of the vehicle for a purpose other than resale. where a manufacturer uses his own vehicles, that purchase would not take place until the manufacturer ultimately sells the vehicle. However, the NHTSA is aware that conformity of vehicle systems which deteriorate under normal use may be impossible to maintain, and as a matter of administrative practice does not consider it necessary for such a manufacturer to renew conformity when his use of the vehicle has been bona fide.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2601OpenMrs. J. A. Selsemeyer, 5911 Cape Cod Court, Indianapolis, IN 46250; Mrs. J. A. Selsemeyer 5911 Cape Cod Court Indianapolis IN 46250; Dear Mrs. Selsemeyer: This responds to your April 1, 1977, letter asking several question concerning a manufacturer's responsibility for tires installed as original equipment on a passenger car.; You asked the following questions in your letter: >>>1. Are there any laws now in effect which pinpoint responsibilit for the quality of tires received as original equipment on a new car?<<<; Section 159 of the National Traffic and Motor Vehicle Safety Act o 1966 (the Act) (15 U.S.C. 1381 *et seq*.) places responsibility upon the vehicle manufacturer for compliance of original equipment with motor vehicle safety standards. However, Section 159 gives the National Highway Traffic Safety Administration the authority to shift to the tire manufacturer the responsibility for compliance of tires with Federal safety standards. You should note that the Act establishes responsibility for compliance with Federal regulations and does not establish remedies for litigants in private law suits.; >>>2. Is it true that there is a federal law which makes it mandator for United States auto manufacturers to buy original equipment tires in equal amounts from each domestic manufacturer of tires? If so, may I have a copy of this law?<<<; There are no Federal laws of which we are aware that require vehicl manufacturers to purchase equal numbers of tires from each tire manufacturer.; >>>3. What is the current status of safety testing as provided by la in 1966, but never implemented? This law was to be effective January 1, 1976 for radial tires, July 1, 1976 for bias-belted tires, and January, 1977 for bias- ply tires. Was it? If not, what are the prospects?<<<; The regulation to which you refer is known as Uniform Tire Qualit Grading and is found in the Code of Federal Regulations, Title 49, Part 575. The effective dates for implementation of tire quality grading standards for the three tire types you mention have been delayed by litigation. The agency intends to establish new effective dates shortly.; >>>4. Can a customer of General Motors ask for and receive a servic agreement for the tires at the time of sale of a car?<<<; This is a contractual matter between the purchaser of a motor vehicl and General Motors. Federal regulations neither encourage nor discourage such arrangements.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam3913OpenMr. Carl R. Ball, Chief of Police, The Atchison, Topeka and Santa Fe Railway Company, 4100 South Kedzie Avenue, Chicago, IL 60632; Mr. Carl R. Ball Chief of Police The Atchison Topeka and Santa Fe Railway Company 4100 South Kedzie Avenue Chicago IL 60632; Dear Mr. Ball: This responds to your letter of February 20, 1985, asking whethe Safety Standards Nos. 212 and 219 prohibit the mounting of police spotlights on the door post of a vehicle. None of our standards prohibit such a mounting, however, the mounting must be done in a manner that the vehicle still complies with our safety standards. The following discussion more fully explains the effect of the agency's standards on spotlight mounting.; If the spotlight is mounted on a new vehicle before its first purchase for purposes other than resale, the person installing the spotlight would have to certify that the vehicle, as altered, continues to comply with all of the applicable Federal motor vehicle safety standards. Since the A pillar of the vehicle would have to be altered to install the spotlight, the installation could affect the vehicle's compliance with Standard No. 212, *Windshield Retention*, as well as Standard No. 216, *Roof Crush Resistance*. If the spotlight is mounted away from the windshield, it does not appear that the installation would affect the vehicle's compliance with Standard 219, *Windshield Zone Intrusion*.; If the alteration is made after a vehicle's first purchase, the section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act may apply. That section provides that no manufacturer, dealer, distributor, or motor vehicle repair shop may knowingly render inoperative an element of design installed in compliance with our safety standards. Thus, if any of those persons install a spotlight they must ensure that they have not rendered inoperative the vehicle's compliance with our standards.; Section 108(a)(2)(A) does not apply to individual vehicle owners However, the agency urges owners that alter their vehicles not to defeat safety equipment installed in the vehicle.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2251OpenMr. W. G. Milby, Staff Engineer, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Staff Engineer Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to Blue Bird Body Company's March 15, 1976, request fo confirmation that calculation of the material tensile strength of body panels under S6.2(a) of Standard No. 221, *School Bus Body Joint Strength*, is based on the minimum thickness permitted by American Society for Testing and Materials (ASTM) Standard 525 for the thickness specified in ordering the material. This response also reflects the April 1, 1976, meeting held between Blue Bird representatives and National Highway Traffic Safety Administration (NHTSA) personnel at Department of Transportation headquarters.; Under ASTM standards, the thickness of listed materials is permitted t vary from the specified or 'nominal' thickness by a small amount. If the thickness tolerance of a material is specified by the ASTM, the NHTSA bases its determination of thickness on the 'minimum thickness' specified for that material in the 1973 edition of the Annual Book of ASTM Standards. If the thickness tolerance of a material is not specified by the ASTM, the NHTSA uses the minimum thickness permitted by the school bus manufacturer's material specification.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam5594OpenMr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo, CA 93012; Mr. Robert J. Ponticelli President American International 1040 Avenida Acaso Camarillo CA 93012; "Dear Mr. Ponticelli: This replies to your letter of July 25, 1995 asking for an opinion 'on the use of Electro-Luminescent Strip Lighting on motor vehicles.' The device in question 'is an ornamental light which produces less than .05 candela/sq. inch.' You have enclosed a brochure which shows the strip in use as a license plate frame and to mark the sides or perimeter of a vehicle. We assume that you are not asking about the license plate frame but only the 'Lighted Pin Striping'. The 'Lighted Pin Striping' comes in 'basic white' but once applied, seven colors of overlay tape are available to change the color. The brochure shows it in shades of blue and pink. You would like our views 'on the installation of this product by regulated parties such as new car dealers and non-regulated entities such as aftermarket specialty shops and vehicle owners.' We are pleased to provide you with the interpretation you seek. The basic obligation of a new-car dealer is to deliver a new car that remains in compliance with all the applicable Federal motor vehicle safety standards for which its manufacturer has certified compliance. In other words, the dealer must ensure that none of its actions before the sale of a new vehicle create a noncompliance with a safety standard. Further, if a dealer alters a vehicle before sale other than by the addition, substitution, or removal of readily attachable components, or minor finishing operations such as painting, is required to certify that the altered vehicle continues to meet the standards. The Federal new vehicle standard that relates to your product is Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. This standard permits a new car dealer to add supplementary lighting equipment such as the luminescent strip if the supplementary equipment does not impair the effectiveness of the lighting equipment required by Standard No. 108. The most common cause of impairment is lighting equipment that creates confusion with, or distraction from, the purpose of any item of required lighting equipment. Under Standard No. 108's lighting scheme, the color of lamps on the front of a vehicle are restricted to white and amber. On the side of the vehicle, side marker lamps and reflectors must be only amber to the front and red to the rear. Rear lighting is red or amber, with the color white permitted for the backup lamp only. The Lighted Pin Striping comes in a variety of colors. Your brochure shows one that is pink or red in color mounted on the front of a vehicle. We believe it possible that a motorist seeing a color of light on the front of the vehicle generally used on the rear or on the side at the rear could be distracted from the driving task. There is also the possibility that the strip would be bright enough to mask and thereby reduce the effectiveness of an adjacent front or rear turn signal, or stop lamp. In general, the agency tries to discourage the use of novelty lighting devices because of the uncertain reaction an unfamiliar light or reflection may cause in other drivers on the roadway. However, the determination as to whether installation of the lighting strip would impair the efficiency of required lighting equipment is initially that of the new car dealer who must determine whether his modifications to a new vehicle might take it out of compliance. Unless that determination is clearly erroneous, NHTSA will not contest it. With respect to sales in the aftermarket, installation by a manufacturer, distributor, dealer, or motor vehicle repair business of the lighting strip would be prohibited if the use of the strip would, in the words of the statute, 'make inoperative' any of the required lighting equipment. We tend to equate 'make inoperative' and 'impair effectiveness' so that the same considerations would have to be taken into account in installing the lighting equipment on a used as well as a new car. However, this prohibition does not extend to the vehicle owner who, under Federal law, may install the lighting strip regardless of its effect upon compliance. Nevertheless, even if novelty lighting equipment does not violate Federal law, the ultimate decision of its acceptability is that of the State in which the lighting strip is to be used. It is our understanding that, for example, that California requires any emitted or reflected light from the front of vehicles to be white or yellow in color, which would appear to preclude installation of the lighting strip in colors other than these. For an opinion on the treatment of the lighting strip under State laws, we suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0796OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letters of July 25 and 28, 1972, on th subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.; The 'nominal design riding position' specified in Standard 208 an formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.; The term 'most upright position' used in Standard 210 was adopted i part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.; There have, however, been difficulties with the use of the 'mos upright position', in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the mannikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the *Federal Register*.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1884OpenMr. Jim Kielty, 1700 N. North Part - 3P, Chicago, IL 60614; Mr. Jim Kielty 1700 N. North Part - 3P Chicago IL 60614; Dear Mr. Kielty: This is in response to your letter of February 25, 1975, requestin information concerning the odometer disclosure requirements contained in Title IV of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513).; I have enclosed copies of the package that was sent to the Stat Attorneys General requesting their assistance in attacking the problem of odometer tampering and the report made by the agency pursuant to Section 413 of the Act.; You ask whether odometers are now tamper-proof and whether a Federa standard exists which requires their use. As far as we know, there is no item which could be called a 'tamper-proof' odometer currently in use on motor vehicles. Some vehicle manufacturers have tamper-resistant odometers, but, I do not know if these are installed as standard equipment on vehicles. The National Highway Traffic Safety Administration (NHTSA) has not promulgated a standard requiring the inclusion of tamper-resistant odometers in motor vehicles. The concept has been examined, but the problems inherent in specifying objective criteria for tamper-resistance appeared great. It became apparent that development of a 'tamper-proof' odometer specification was not possible, since we are uncertain if there is any way of making an odometer truly tamper-proof. We are open to suggestions as to how we might develop criteria that would ensure some level of tamper resistance.; Since the Federal odometer disclosure statement is mandatory throughou the United States, there is no pressure on States to make the Federal statement mandatory via State law. Some States have retained the odometer laws of disclosure that were in effect in their State prior to the enactment of the Cost Savings Act. In these States, the State law is not affected by the Federal requirements, as long as the Federal requirements are fulfilled. We do not know how many States have adopted disclosure requirements identical to the Federal ones. However, we support such a move, since it would then enable the State to enforce its provision and utilize any State remedies that might be available for noncompliance.; To date, the NHTSA has not prepared any model State odometer tamperin legislation. We do, however, intend to develop a model State law sometime in the near future. Any State that requests assistance in preparing odometer tampering legislation for presentation to the State legislature would be provided with the model law.; Based on a survey conducted by the NHTSA concerning the level o compliance with the disclosure requirements of the odometer law, it became apparent that a large number of used car dealers are not complying with the disclosure provisions. We have been attempting to solve this problem by enlisting the aid not only of the National Automobile Dealers Association but the Dealers Safety Mobility Council and the American Association of Motor Vehicle Administrators. In addition, a public information campaign has been initiated by the NHTSA that hopefully will ameliorate the current odometer disclosure problem.; Private civil actions have been brought under the Cost Savings Act Since they are private actions, it would be very difficult for us to monitor them. Thus, we must rely on individuals to report cases to us. For this reason, we do not know how many actions have been initiated, nor how they have been resolved.; We have received numerous reports alleging repeated violations of th Act by single dealers. However, since we have no investigative authority under the Act, we are unable to investigate the reports to obtain evidence necessary to bring an injunctive suit (the only Federal enforcement remedy under the Act). We were able to obtain sufficient evidence to bring such a suit in Florida. That case is currently in progress and had the advantage of two informants who were prior employees of the defendant and willing to testify against him.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0283OpenMr. A. Hammerstein, Robert Bosch GMBH, 7000 Stuttgart- Feuerbach, Postfach 400, Germany; Mr. A. Hammerstein Robert Bosch GMBH 7000 Stuttgart- Feuerbach Postfach 400 Germany; Dear Mr. Hammerstein: This is in reply to your letter of December 23, 1970, to the U. S Department of Transportation concerning the time when stop lamps will be required to meet Class A photometrics.; The conflict between the requirements of paragraphs S4.1.1.6 an S4.1.1.7 has already been called to our attention, and will be clarified in an amendment to Standard No. 108 scheduled to be published in the *Federal Register* in the near future.; It was not intended for the stop lamps to meet the Class A photometri values, nor are they required to, until January 1, 1973.; Sincerely, Roger H. Compton, Director, Office of Operating Systems Motor Vehicle Programs; |
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ID: aiam5081OpenMs. Shirley A. Stewart President SAS Electrical Service, Inc. 1601 Society Court Herndon, VA 22070; Ms. Shirley A. Stewart President SAS Electrical Service Inc. 1601 Society Court Herndon VA 22070; "Dear Ms. Stewart: This responds to your letter of October 16, 1992, t this office regarding the installation of a 'silent monitor' on school buses. You stated in your letter that you made a presentation to Mr. Maurice Hicks and Mr. Rich Van Iderstine of this agency at a meeting on October 2, 1992, and you asked how our standards apply to installation of this device on school buses. You described the silent monitor as a six-inch cube of welded steel designed to house a video camera to monitor the interior of school buses. You explained that the device is installed in the interior access panel above the bus windshield facing the passenger compartment. The box protrudes into the interior of the bus by three to four inches. The front of the box, which swings open for installation of a video camera, contains a reflective solar glass window to prevent glare on the inside of the box. By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable Federal safety standards. The following represents our opinion based on the facts provided in your letter. NHTSA does not have any safety standards specifically covering silent monitors. However, it is possible that the installation of a silent monitor could affect the compliance of a vehicle with some safety standards. All new motor vehicles manufactured for sale in the United States must be certified by their manufacturers as complying with the applicable Federal motor vehicle safety standards. If your silent monitor is installed in a new school bus prior to its first sale to a customer, the person making the installation would be considered a vehicle alterer. Under our certification regulation (49 CFR Part 567), a vehicle alterer must certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards. Manufacturers, distributors, dealers, or motor vehicle repair businesses modifying a used vehicle are prohibited by Section 108(a)(2)(A) of the Safety Act from knowingly rendering inoperative any safety device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Thus, if your silent monitor is installed in a used school bus, any businesses, including your own, making such installations cannot render inoperative the vehicle's compliance with any of our standards. We also note that manufacturers of motor vehicle equipment have responsibilities under the Safety Act regarding safety defects. Under Sections 151, et seq., of the Safety Act, such manufacturers must notify purchasers about safety-related defects and remedy the product free of charge. In order to determine how installation of your silent monitors could affect the compliance of school buses with applicable Federal safety standards, you should carefully review each standard, including but not limited to those addressing school bus body joint strength, crash protection, and windshield intrusion. In that regard, I am enclosing for your information a fact sheet entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and a booklet entitled Federal Motor Vehicle Safety Standards and Regulations. As indicated above, you stated that your silent monitor would be installed in the interior access panel above the bus windshield facing the passenger compartment. Given the added weight that would be on the panel, we suggest that you carefully evaluate whether additional securement of the panel is needed to ensure that the panel and silent monitor do not come loose during a crash. We also note that the silent monitor appears to have sharp edges. You may wish to consider adding padding to prevent injury to an occupant who comes in contact with the monitor. I hope this information is helpful. If you have any further questions, please feel free to contact Walter Myers of my staff at this address or at (202) 366- 2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0779OpenMr. Satoshi Nishibori, Engineering Representative, Liaison Office in U.S.A., 560 Sylvan Avenue, Englewood Cliffs, NJ, 07632; Mr. Satoshi Nishibori Engineering Representative Liaison Office in U.S.A. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letter of June 29, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials', to replacement parts for vehicles manufactured on or after September 1, 1972.; Standard No. 302 does not apply to replacement parts or aftermarke materials irrespective of the date of their manufacture. It applies only to new vehicles manufactured on or after September 1, 1972, and not to the replacement materials used in those vehicles.; Yours truly, Richard B. Dyson, Assistant 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.