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: aiam3287OpenMr. R. W. Hildebrandt, Group Director, Engineering, Heavy Vehicle Systems Group, The Bendix Corporation, 901 Cleveland Street, Elyria, OH 44035; Mr. R. W. Hildebrandt Group Director Engineering Heavy Vehicle Systems Group The Bendix Corporation 901 Cleveland Street Elyria OH 44035; Dear Mr. Hildebrandt: This responds to your April 8, 1980, letter asking for a interpretation of section 5.2.1.1 of Standard No. 121, *Air Brake Systems*. In particular, you ask whether your system complies with the provisions of that section which require that vehicles have a reservoir capable of releasing the parking brakes in the event of an emergency failure of the service brake system. You indicate that your system is in compliance with the intent of this section but may not be in technical compliance with the actual requirements. Nonetheless, you believe that your system complies based upon a letter of interpretation made by the agency to Berg Manufacturing Company dated August 27, 1979.; The August letter to Berg to which you refer in your letter wa conditioned upon our reading of the facts as stated by Berg in their letter. That letter as it applied to section 5.2.1.1 was not an interpretation of the standard, but rather an assessment by the agency as to whether we believed that the Berg system would comply with the requirements. At that time and based upon the given facts, we stated to Berg that we felt that their system would comply.; The agency has always been reluctant to issue such letters, because i is impossible to determine compliance based upon a manufacturer's description of its vehicles or from vehicle drawings. It is necessary for the agency to conduct tests to be certain whether a vehicle will comply. Accordingly, the agency always indicates in its letters that any assessment of compliance is contingent upon the description made in the manufacturer's letter, and that our opinions only reflect our engineering expertise and in no way bind the agency should we test the vehicle and find a noncompliance. In fact, we have frequently indicated to manufacturers that these letters are of little or no value to them.; Subsequent to the issuance of the Berg letter, the agency has receive a clearer picture of how the Berg system operates. We have notified that company that their system does not comply with the requirements of the standard. Berg has indicated to the agency that they consider their system to be as good as any that is in complete compliance with the standard and has petitioned the agency to amend the standard in a way that would permit their system. The agency is now looking into the Berg request. We suggest that you closely follow that rulemaking action.; With respect to your system, it appears that it too would not compl with the technical requirements of the standard, because your system does not have a reservoir capable of releasing the parking brakes in the event of service brake failure. Although the agency appreciates your argument that your system meets the intent of the standard for the release of parking brakes when the service brake system fails, nonetheless the standard is specific in its requirement that a reservoir be provided that is capable of releasing the parking brakes. We cannot by interpretation remove the reservoir requirement. Our rulemaking effort with respect to the Berg petition will address the question of whether the reservoir requirement remains necessary in the standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4542OpenMr. Steve Zlotkin Overland Parts, Inc. 48368 Milmont Dr. Fremont, CA 94538; Mr. Steve Zlotkin Overland Parts Inc. 48368 Milmont Dr. Fremont CA 94538; "Dear Mr. Zlotkin: This is in response to your letter seeking a interpretation of Standard No. 205, Glazing Materials (49 CFR 571.205). Specifically, your letter stated that your company would like to import some non-laminated windshields into the United States. I apologize for the delay in our response. As explained below, your company is prohibited by Federal law from importing or selling this type of windshield because it does not comply with the requirements of Standard No. 205. Standard No. 205 establishes performance and marking requirements for all glazing installed in motor vehicles. The standard incorporates by reference the requirements of Standard ANS Z-26, 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' of the American National Standard Institute. Standard ANS Z-26 requires that glazing materials for windshields must pass a specified group of test requirements. ANS Z-26 specifies that glazing materials that comply with these test requirements for windshields must be marked AS-1. To date, the only glazing materials that have been marked AS-1 have been laminated safety glass. Unless your non-laminated windshields can meet the requirements for AS-1 glazing and are marked AS-1, they do not comply with the requirements for windshields specified in Standard ANS Z-26 or Standard No. 205. You also should be aware that Standard No. 205 permits glass-plastic glazing. The importation and sale of noncomplying glazing would be a violation of the National Traffic and Motor Vehicle Safety Act ('Safety Act'), the statute under which Standard No. 205 was issued. Section 108(a)(1)(A) of the Safety Act provides: No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle standard takes effect under this title unless it is in conformity with such standard... Your letter set forth two interpretations of the law under which you suggested that your company might be able to import noncomplying windshields. Your first interpretation relied on the fact that these windshields can only be installed in vehicles that were manufactured between 1953 and 1967. Since Standard No. 205's requirements for windshields did not become effective until January 1, 1968, you suggested that the provisions of section 108(a)(1)(A) of the Safety Act might not apply, because no safety standards were applicable to these vehicles. This suggestion is incorrect. All windshields manufactured on or after January 1, 1968 must comply with the requirements of Standard No. 205, regardless of the year of manufacture of the vehicle on which the windshield is designed to be installed. In fact, safety standards relating to components such as brake hoses, lighting equipment, tires, glazing materials, seat belt assemblies, and wheel covers are applicable to components manufactured on or after January 1, 1968, even if those components are manufactured for motor vehicles manufactured before that date. In a January 16, 1987 interpretation letter to Mr. Peter Cameron-Nott (copy enclosed), the agency stated that the above listed component parts including glazing materials that were manufactured on or after January 1, 1968, would have to comply to the relevant safety standards (in the case of glazing, Standard No. 205) even though the underlying motor vehicle was a 1965 Jaguar. Assuming that the non-laminated windshields that were the subject of your letter were in fact manufactured after January 1, 1968, Standard No. 205 applies to those windshields. As already noted, Section 108(a)(1)(A) of the Safety Act prohibits your company from importing any windshields that are subject to Standard No. 205 that do not comply with that standard. Your second suggestion is that your company would be willing to place a sticker on these windshields to warn purchasers that the windshields do not comply with Standard No. 205. The Safety Act contains no exception to section 108(a)(1)(A)'s prohibition for noncomplying equipment, even if it were to be labeled as noncomplying. Hence, section 108(a)(1)(A) prohibits the importation of noncomplying windshields without regard to any warning labels on the windshields. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam0852OpenMr. W.G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley GA 31030; Mr. W.G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of August 24, 1972, requesting a opinion as to appropriate steps to take in certifying vehicles you complete when the chassis, as delivered to you, are equipped with tires which are inadequate for the loads the vehicles are intended to carry. You state you are presently certifying the vehicles on the basis of the load ratings of correct tires, arranging for these tires to be installed by the dealer, and requesting a notarized statement from him to that effect. As a basis for this procedure, you refer to our previous correspondence to you dated March 24, 1972, in which we authorized a somewhat similar procedure involving certain school buses.; As stated to you in our letter of March 24, the procedure outline therein 'is allowed only as to chassis that have already been received by Blue Bird as of the receipt of this letter . . .' Blue Bird is the final-stage manufacturer, and is responsible for the weight ratings applied to the vehicles presently in question. These ratings must be consistent with the definitions of those terms in the regulations, and must reflect the characteristics of the vehicles at the time of their sale to the consumer, assuming further manufacturing does not occur. Although you receive assurances from a dealer that he will change the tires, this will not absolve you from responsibility under the regulations should the dealer fail to do so. We are of the opinion that the best procedure for Blue Bird to follow is to replace the tires before delivery to the dealer.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1740OpenMr. J. L. Brown, President, Brown Truck and Trailer Mfg. Co., P.O. Box 1281, Charlotte, NC 28201; Mr. J. L. Brown President Brown Truck and Trailer Mfg. Co. P.O. Box 1281 Charlotte NC 28201; Dear Mr. Brown: This responds to your December 11, 1974, question whether Standard No 121, *Air brake systems*, or any other Federal brake regulation applies to trailers that are equipped with electric brakes. In a January 2, 1975, telephone conversation with Mr. Herlihy of this office, you indicated that the brake system on your products is entirely electrical.; No Federal braking standards apply to your electrically-brake trailers. Standard No. 121 applies only to trucks, buses, and trailers that the manufacturer chooses to equip with an air brake system.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam4811OpenMr. Richard Cahalan Director of Core Services Commonwealth of Massachusetts Executive Office of Human Services Department of Mental Retardation 160 North Washington Street Boston, MA 02114; Mr. Richard Cahalan Director of Core Services Commonwealth of Massachusetts Executive Office of Human Services Department of Mental Retardation 160 North Washington Street Boston MA 02114; "Dear Mr. Cahalan: This responds to Mr. Oscar Harrell's lette requesting information about Federal regulations concerning the modification of vehicles to accommodate mentally retarded individuals. According to that letter, in response to conversations about this issue with Mr. George Shifflett of this agency's Office of Vehicle Safety Compliance, Mr. Harrell received copies of interpretation letters from my office to Mr. Vincent Foster dated September 4, 1986 and to Mr. W.G. Milby dated November 26, 1979. These letters express NHTSA's policy concerning modifications of vehicles to accommodate the special needs of handicapped individuals and the requirement in 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibiting commercial businesses from knowingly rendering inoperative any elements of design installed on a vehicle in compliance with a Federal motor vehicle safety standard. Given the public interest against restricting the mobility of the handicapped, it is the agency's policy, depending on the particular situation, to consider certain violations of that section as technical ones justified by public need. In a telephone conversation with Marvin Shaw of my staff, you explained that a van conversion company modified new Dodge Maxi-vans for your agency before they were purchased. Among the steps taken by the converter to accommodate handicapped individuals are the removal of the 'top,' the addition of a new 'bottom,' and the installation of a wheelchair lift. According to Mr. Harrell's letter, the converter, when contacted last year, stated that the vehicles, after being converted, comply with State and Federal regulations. You indicated, however, that the converter failed to certify that the vans, as altered, comply with Federal motor vehicle safety standards. I am pleased to have this opportunity to explain our laws and regulations to you. I apologize for the delay in our response. The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards applicable to new motor vehicles and new motor vehicle equipment. Each manufacturer is required to certify that its products meet all applicable safety standards. Based on your letter and the telephone conversation with my staff, it appears that the van converter would be considered an 'alterer' for purposes of of Part 567, Certification (copy enclosed). Section 567.7 defines 'alterer' as A person who alters a vehicle that has previously been certified in accordance with 567.4 or 567.5, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, or who alters the vehicle in such a manner that its stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale... As an alterer, section 567.7 requires the vehicle converter to do the following: (1) Supplement the certification label affixed by the original manufacturer by affixing an additional label stating that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards. This supplemental label must state the name of the alterer and the month and the year in which the alterations were completed (see 567.7(a)), (2) Provide the modified values for the gross vehicle weight ratings or any of the gross axle weight ratings of the vehicle as altered if they are different from those shown on the original certification label (see 567.7(b)), and (3) Provide the type classification, if the vehicle as altered has a different type classification from that shown on the original certification (see 567.7(c). If the converter did not comply with these requirements, then it did not fulfill its certification responsibilities under Part 567. From what you have written to us, we assume that is the case. However, this does not in itself mean that the vehicles, as altered, do not comply with applicable safety standards or are otherwise unsafe. If you believe that the conversion of these vehicles poses a safety problem, you should contact this agency's Office of Enforcement and explain the specific safety problem. If you have any further questions or need additional information on this subject, 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 Enclosure"; |
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ID: aiam0501OpenMr. Warren M. Heath, Commander, Engineering Section, Department of California Highway Patrol, P. O. Box 898, Sacramento, CA 95804; Mr. Warren M. Heath Commander Engineering Section Department of California Highway Patrol P. O. Box 898 Sacramento CA 95804; Dear Mr. Heath: Your inquiry concerning the certification required of seat belt installed in motor vehicles manufactured after January 1, 1972, has been brought to our attention. Motor Vehicle Safety Standard No. 208, which governs the installation of seat belts, requires belts to conform to Standard No. 209. Since Standard No. 209 is amended effective January 1, 1972, your question is whether a vehicle manufactured after that date must have seat belts that are certified as conforming to the new provisions of Standard No. 209.; We construe Standard No. 208 to require only that the belts conform t Standard No. 209 as it was at the time of their manufacture. Thus, a belt manufactured before January 1 that conforms to the contemporaneous (pre-amendment) version of Standard No. 209 may be installed in a vehicle manufactured after that date. A belt manufactured after January 1, must, of course, conform to the amended version of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5353OpenMr. Randolph Schwarz 141 North Madison Drive South Plainfield, NJ 07080; Mr. Randolph Schwarz 141 North Madison Drive South Plainfield NJ 07080; "Dear Mr. Schwarz: This responds to your letter to Mr. John Messera o NHTSA, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 116, Motor vehicle brake fluids. Your letter has been referred to my office for a response. As a consumer retrofitting your vehicle with DOT 5 brake fluid, you had several questions concerning the possible effects that an ingredient in the brake fluid might have on elastomers used in brake systems. Your questions are answered below. You mentioned 'seal swelling additives' added to DOT 5 brake fluid, that contact various elastomers in the brake system. Your first question was, when brake fluid manufacturers combine additives with brake fluid, should consumers be concerned with the combined fluids' compatibility with various elastomers used in braking systems? Standard No. 116 defines, at S4. Definitions, brake fluid as a liquid designed for use in a motor vehicle hydraulic brake system where it will contact elastomeric components made of: styrene and butadiene rubber (SBR), ethylene and propylene rubber (EPR), polychlorophene (CR) brake hose inner tube stock, or natural rubber (NR). In order to minimize failures in hydraulic braking systems, Standard No. 116 specifies minimum performance standards for brake fluids. These performance standards include tests for styrene and butadiene rubber cups, the most common type of elastomer in a hydraulic brake system. The brake fluid manufacturer must certify that the brake fluid complies with Standard No. 116. (See S5.2.2(d).) While DOT 5 brake fluid must meet Standard No. 116, the specific ingredients in the fluid are not regulated by the standard. The brake fluid manufacturer is expected to be aware that in addition to SBR, its brake fluid may contact EPR, CR, and NR elastomers in the brake system. Thus, the brake fluid manufacturers must ensure that contact between the fluid and the above stated elastomers would not result in a safety-related defect under the National Traffic and Motor Vehicle Safety Act. Sections 151-159 of the Safety Act concern the recall and remedy of products with defects related to motor vehicle safety. In the event that the brake fluid manufacturer or NHTSA determines that the brake fluid contains a safety related defect, the brake fluid manufacturer would be responsible for notifying purchasers of the defective brake fluid and remedying the problem free of charge. Your second question was whether DOT 5 brake fluid's compliance with Standard No. 116 ensures compatibility with elastomers. The answer is yes, for SBR elastomers. Further, besides Standard No. 116, the brake fluid manufacturer is subject to sections 151-159 of the Safety Act, that were previously discussed. At this time, NHTSA is not aware of safety related defects resulting from other ingredients used with brake fluid. Your third question was whether Standard No. 116 only addresses SBR compatibility with brake fluid. Standard No. 116, at S4, addresses brake fluid that contacts four elastomer types. However, the tests specified in the standard are only of the most commonly used SBR cups. Your fourth question was, if Standard No. 116 only mentions SBR elastomer, would it be advisable to add other elastomers to the specification, or to discuss elastomer compatibility on the brake fluid container? Information discussing the elastomer compatibility of the brake fluid, or other ingredients, may be voluntarily placed on brake fluid containers. Standard No. 116 specifies information that brake fluid containers must carry. However, Standard No. 116 does not prohibit manufacturers from noting on brake fluid containers, compatibility of the silicone brake fluid, or other ingredients, with various elastomers. Finally, you asked what Standard No. 116 specifies as the maximum viscosity for DOT 5 brake fluid, at -40 degrees Fahrenheit. Standard No. 116 specifies, at S5.1.3(c), that the maximum viscosity is 900 centistokes (cSt). I hope that this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2496OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P. O. Box 937, Fort Valley, GA; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P. O. Box 937 Fort Valley GA; Dear Mr. Milby: This responds to Blue Bird Body Company's November 2, 1976, request fo confirmation that head and knee contact areas specified under S5.3.1.3 and S5.3.2.2 of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, may be measured by the use of the direct transfer of a medium (such as spray paint) from the head or knee form to the seating surface with the addition of the area that falls within nonintersecting lines that are tangent to the outer bounds of the areas of direct contact. You also request confirmation that the impact requirements of S5.3.1.2, S5.3.1.3, and S5.3.2.2 may be conducted on seating that is attached to a test fixture instead of being mounted in a bus body. In both cases you suggest rulemaking action to make your recommended procedures a part of the standard.; When a standard does not specify a particular aspect of a requirement such as the means to measure contact area, a manufacturer is entitled to use any reasonable method it chooses to demonstrate, in the exercise of due care, that the regulated vehicle or item of equipment in fact conforms to the requirement. For your information, the agency intends to use a contact medium test similar to the test you describe and will include in its computation of 'contact area' the maximum area that falls within nonintersecting line segments that are tangent to the outer bounds of the areas of direct contact. The outer bounds of direct contact do not include areas that represent splattering of the transfer medium without contact of the nead or knee form.; In response to your second request, Standard No. 222 is a vehicl standard. Therefore, the impact requirements have meaning only as they apply to seating when installed in a vehicle. For this reason the agency intends to conduct its compliance testing with the seating installed in a bus. The agency's contemplated procedure may involve the removal of seating around the seating being tested, and the test device may be mounted to the floor in place of the seating that is removed.; However, the requirementk that the seating conform as it is installe does not prohibit a manufacturer from using a different test procedure from that specified, in view of the NHTSA's expressed position on the legal effect of its regulations. To certify compliance, a manufacturer is free to choose any means, in the exercise of due care, to show that a vehicle (or item of equipment) would comply if tested by the NHTSA as specified in the standard. Thus, the NHTSA test procedures need not be duplicated by each manufacturer or compliance test facility. Blue Bird, for example, is free to conduct its test on a test fixture outside the bus as long as it can certify that its vehicle would comply if tested by the NHTSA according to the standard.; In view of this disposition of your requests, the agency does no intend to undertake modification of Standard No. 222 at this time. The NHTSA will continue to monitor the results of tests conducted to determine compliance with the head and kneeform contact area requirements of the standard and will modify the standard if warranted.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0151OpenMr. Yoshiyuki Mizuno, Factory Engineer, Nissan Motor Corporation, 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Factory Engineer Nissan Motor Corporation 400 County Avenue Secaucus NJ 07094; Dear Mr. Mizuno:#Thank you for your letter of March 7, 1969, to Dr William Haddon, Jr., concerning the location and the identification of the windshield washer switch on the steering column.#The system as you describe it appears to conform to Federal Motor Vehicle Safety Standard No. 101, however, the Bureau does not issue approvals of any specific system, and the development of equipment to comply with the standard is the responsibility of the individual manufacturer.#In reference to your second question about the identification of the windshield washer switch, Paragraph S3.2 reads, in part, '.... The following controls, when mounted on the instrument panel, shall be identified to permit recognition -- >>>... (c) Windshield Washing System, ....'<<<#This section of the regulation does not apply to the identification of controls in any position other than on the instrument panel.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service; |
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ID: aiam2479OpenMr. Eugene C. Kellogg, USM Corporation, P.O. Box 103, Birmingham, MI 48012; Mr. Eugene C. Kellogg USM Corporation P.O. Box 103 Birmingham MI 48012; Dear Mr. Kellogg: This is in response to your letter of December 21, 1976, concerning th effective date of 49 CFR Part 581, *Bumper Standard*.; Part 581 was published on March 4, 1976, pursuant to Title I of th Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). It is scheduled to become effective on September 1, 1978, at which time it will absorb Federal Motor Vehicle Safety Standard No. 215, *Exterior Protection*, the currently effective bumper standard.; There has been no action taken to delay the scheduled implementatio date of the Part 581 bumper standard. If a decision were made to delay the standard's effective date, it would be published in the Federal Register.; National Highway Traffic Safety Administration rulemaking procedure permit the filing of petitions for reconsideration of final rulemaking actions. Such petitions must be filed within 30 days of the date on which the final rule is published and must be either granted or denied by the agency. Petitions for reconsideration of Part 581 were submitted by several manufacturers. The agency is still considering the issues raised in those petitions and has not yet made a decision as to their disposition. The agency response to the petitions for reconsideration will be published in the Federal Register.; Sincerely, John Womack, Assistant 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.