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: aiam2395OpenMr. B. R. Weber, Executive Vice President, Wesbar Corporation, Box 577, West Bend, WI, 53095; Mr. B. R. Weber Executive Vice President Wesbar Corporation Box 577 West Bend WI 53095; Dear Mr. Weber: This is in reply to your letter of September 7, 1976, asking severa questions concerning paragraph S4.4.1 of Federal Motor Vehicle Safety Standard No. 108. I am sorry that we were unable to respond by September 29 as you requested. Your questions and our answers are as follows:; '1. What is the DOT specific definition and interpretation of the word 'combined optically' as they appear in paragraph S4.4.1 of DOT 108?'; In pertinent part, S4.4.1 states that 'no clearance lamp may b combined optically with any taillamp.' The phrase 'combined optically' as used here means that the luminous area of a lens used for a taillamp may not be also used as the luminous area of a lens for a clearance lamp. In other words lamps are 'combined optically' when the same luminous area of a lens is lighted for more than a single function.; '2. Can a clearance lamp and tail lamp be combined in a singl compartment with no opaque barrier wall existing between the clearance lamp bulb and the tail lamp bulb?'; The answer is no because the same luminous area of the lens would b lighted when both lamps are in use, and the lamps would be 'combined optically.'; '3. Does the DOT have no objection to a flashing red signal issuin from the side (at right angles to the fore-aft center line of the trailer) of the clearance lamp?'; Generally S4.6(b) requires most vehicle lamps to be steady burning i normal operation. If the right angle lamp serves as the rear side marker lamp, however, S4.6(b) allows it to be flashed for signaling.; '4. What is the DOT specific definition and interpretation of the ter 'clearance lamp' as it is used in DOT 108?'; The term 'clearance lamps' is defined by SAE Standard J592e incorporated by reference in Standard No. 108, and are 'lamps which show to the front or rear of a vehicle. . . to indicate the overall width and height of the vehicle.'; '5. Does the 'clearance lamp' as the words are used in DOT 108 indicat a lamp intended to serve as its major function, a back up lamp in the event of failure of the tail light filament in the combination tail, turn and stop light bulb.'; There is no intent that a clearance lamp serve as a back-up lamp in th event of a taillamp filament failure though obviously both lamps perform a marking function.; '6. If DOT approves the combination of a clearance lamp and tail lam in the same compartment, would it also approve for a boat trailer, moving the tail light outboard to show the extreme width of an over 80 foot vehicle and eliminate the need for a clearance lamp under those circumstances.'; The question is moot since a combination clearance lamp-taillamp is no permitted.; I understand that you discussed the photometric test procedure fo optically combined lamps with Mr. Owen of this agency, by telephone on September 22, 1976. So that there may be no misunderstanding I would like to set forth the test procedure in this letter. If a single lamp bulb (or filament) is used in the combined lamp, the photometrics for all of the functions must be met simultaneously. If two or more lamp bulbs (or filaments) are used and each is to provide a separate function, only those which provide that function are to be energized during the photometric test. Therefore, in a multiple compartment side marker and clearance lamp (or a multiple compartment tail and clearance lamp that is not optically combined), the clearance lamp bulb is not energized during the photometric test for the other function, and vice versa.; I hope this answers your questions. Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam2956OpenClarence W. Woody, Maryland Department of Transportation, 6601 Ritchie Highway, N.E., Glen Burnie, MD 21062; Clarence W. Woody Maryland Department of Transportation 6601 Ritchie Highway N.E. Glen Burnie MD 21062; Dear Mr. Woody: This is in response to your letter of January 19, 1978, asking whethe the odometer statement is required for transfers between dealers which take place prior to the sale of a vehicle to an individual. The answer is no. Exemption 580.5(b) (49 CFR S 580.5(b)) states; >>>A transferor of a new vehicle prior to its first transfer fo purposes other than resale need not disclose the vehicle's odometer mileage.<<<; This statement is intended to exclude all transfers of new vehicle prior to the first sale to a customer. For example, when the manufacturer transfers the vehicle to a dealer, no statement needs to be issued because the transfer is for resale purposes. If that dealer makes a trade with another dealer, no disclosure statement needs to be issued because this transfer is also for resale purposes. The second dealer is purchasing the vehicle merely to resell it. If that dealer then sells the vehicle to a customer, private or commercial, who is going to use that vehicle for some purpose other than reselling it immediately, then a disclosure statement needs to be issued. This transfer is the first transfer of the vehicle for a purpose other than resale. Beginning with this first transfer to a customer, each transfer of the vehicle from then on must be accompanied by a disclosure statement.; The Federal law does not, however, prohibit the State from requirin such disclosures. The National Highway Traffic Safety Administration supports all affirmative steps which the States take with regard to combating odometer misrepresentation.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam2942OpenMr. D. K. Haenchen, Administrator, Vehicle Regulations, Volkswagen of America, 27621 Parkview, Boulevard, Warren, MI 48092; Mr. D. K. Haenchen Administrator Vehicle Regulations Volkswagen of America 27621 Parkview Boulevard Warren MI 48092; Dear Mr. Haenchen: This is in reply to your letter of January 3, 1979, asking fo confirmation of your interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to a braking system that Volkswagen proposes to use on its 1980 Dasher model.; Specifically, the Dasher will employ a single 'pressure switch on eac vehicle, meaning that the stop lamp will be activated by only one of the [two, split] service brake systems.' You asked whether this is consistent with S4.5.4 of Standard No. 108 which requires that 'the stop lamps on each vehicle shall be activated upon application of the service brakes.' You argued that it meets the standard because:; >>>'Neither FMVSS 571.105-75 nor 575.108 (sic) clearly specify th conditions under which the stop lights have to operate. Specifically, the regulations do not specify that the stop lamps must illuminate upon application of the service brake control if one of the circuits of a dual circuit hydraulic braking system failed.'<<<; We do not concur with your interpretation. S4.5.4 quite clearl specifies the conditions under which the stop lamps must operate--'upon application of the service brakes,' and it is immaterial which circuit of a dual circuit hydraulic braking system is braking the vehicle. Therefore, your proposed system would constitute an apparent noncompliance with Standard No. 108.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam1800OpenMr. Murray Bartlett, B. F. Goodrich Tire Co., 500 South Main Street, Akron, OH 44318; Mr. Murray Bartlett B. F. Goodrich Tire Co. 500 South Main Street Akron OH 44318; Dear Mr. Bartlett: This letter reviews for conformity with statutory requirements a draf defect notification letter received by my office regarding Goodrich's impending notification campaign for tires retreaded by B. F. Goodrich using carcasses branded 'General Belted Jumbo 780.'; As you are aware, defect notifications issued on or after December 26 1974, are required to comply with the requirements in section 153 of the 1974 amendments to the National Traffic and Motor Vehicle Safety Act (Public Law 93-492, 88 Stat. 1470). We have the following changes to recommend in your draft notification.; Section 153(a)(5) requires the notification to specify 'the earlies date . . . on which such defect or failure to comply will be remedied without charge, and in the case of tires, the period during which such defect or failure to comply will be remedied without charge . . .' We believe this requirement should be met by specifying the actual earliest date by which dealers will have necessary replacement parts and instructions, and by informing owners that they have 60 days from that date (or 60 days from the day they receive the notification, whichever is later) to obtain replacement free of charge.; You must also include information that is responsive to sectio 153(a)(6). As the procedures referred to in that section have not been published, it is sufficient if you advise owners that they may write to the Administrator, National Highway Traffic Safety Administration, Washington, D.C. 20590, if they find B. F. Goodrich, its distributors, or dealers, to have failed or to have been unable to perform the replacement satisfactorily.; In other respects we find your letter to conform to the statutor requirements.; Yours truly, James C. Schultz, Acting Chief Counsel |
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ID: aiam4348OpenMarzia Puccioni Jones, Alpex Manufacturing Company, 10926 'J' Street, Omaha, NE 68137; Marzia Puccioni Jones Alpex Manufacturing Company 10926 'J' Street Omaha NE 68137; Dear Mr. Jones: This letter responds to your letter enclosing a prototype horn/ligh and requesting information on its 'legality.' The horn/light is intended to be installed on the roof of a pickup truck or van. The light is located on the rear of the horn and would be visible to following drivers. The light comes on when the driver presses the horn button to sound the horn and goes off when the horn button is released. I regret the delay in this reply.; You asked whether the horn complies with safety and other pertinen regulations, whether the light at the back of the horn must be red or amber, whether it is permissible to mount the horn on the cab of a pick-up truck or van roof, and whether the horn is 'DOT-approved,' or if it would be in violation.; The National Highway Traffic Safety Administration (NHTSA) issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment pursuant to its authority under the National Traffic and Motor Vehicle Safety Act. However, NHTSA does not approve motor vehicles or motor vehicle equipment, nor does it endorse any commercial product. Instead, the Vehicle Safety Act establishes a 'self- certification' process under which each manufacturer must certify that its product meets applicable safety standards. Periodically, NHTSA tests whether vehicles or equipment comply with these standards, and may investigate alleged safety-related product defects.; There is only one standard which may apply to your product if it i installed on new vehicles. Standard 108, *Lamps, Reflective Devices, and Associated Equipment*, applies to vehicle lighting. As we understand your product, its light is not intended to serve as any of the lights required by the standard on a van or pickup. Therefore, the requirements directed to those types of lights would not be applicable. However, there is a general requirement that might affect your horn/light. S4.1.3 prohibits the installation of any light that would impair the effectiveness of any required light. The activation of the light on your product could lead following drivers to believe incorrectly that the vehicle equipped with your product is stopping. Repeated false stopping signals might reduce the following driver's responsiveness to the activation of the vehicle's brake lights.; If your product is installed as aftermarket equipment, it would not b subject to any requirement in Standard No. 108. Standard No. 108 covers aftermarket lighting equipment only to the extent that the aftermarket light replaces required original lighting equipment. Because there is no original equipment requirement for the kind of light you described, the standard does not apply to your aftermarket product.; Regardless of whether your product is affected by any of our standards please be aware that if you or the agency finds your product to contain a safety-related defect after you market the product, you are responsible for conducting a notice and recall campaign under S154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C 1414).; Further, you should be aware that State law may apply to products suc as your horn/light. You may wish to consult the State and local transportation authorities in the areas where you intend to market your horn.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4512OpenMr. Michael Rose Technical Secretary for Executive Director Jamaica Bureau of Standards 6 Winchester Road Kingston l0 JAMAICA; Mr. Michael Rose Technical Secretary for Executive Director Jamaica Bureau of Standards 6 Winchester Road Kingston l0 JAMAICA; Dear Mr. Rose: This responds to your letter, addressed to the Directo of the Office of the Federal Register, concerning Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires. The National Highway Traffic Safety Administration (NHTSA) is the Federal agency which issued and administers that standard. Your questions are addressed below. By way of background information, NHTSA issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act, l5 U.S.C. l38l et seq. The term 'motor vehicle safety standard' is defined by the Act as 'a minimum standard for motor vehicle performance, or motor vehicle equipment performance, which is practicable, which meets the need for motor vehicle safety and which provides objective criteria' (section l02(2)). NHTSA does not grant approvals of motor vehicles or motor vehicle equipment. Instead, section ll4 of the Act requires manufacturers to certify compliance of each motor vehicle and item of equipment with all applicable standards. The Act requires that manufacturers exercise 'due care' to ensure that their products conform to each applicable standard (section 108(b)(l)). I will address your first two questions together. The questions are: l. In the clause dealing with Test Sample, why are the batch size and sample size not mentioned? 2. Why does the standard make no reference to the frequency of testing. As indicated above, Standard No. 109 is a minimum performance standard. All tires must be capable of meeting the standard's requirements. The purpose of the test sample paragraph (S4.2.2.l) in Standard No. 109 is to indicate that a test set for a compliance test consists of three tires. One tire is checked for physical dimensions and is then subjected to resistance to bead unseating and strength, in sequence. The second tire is subjected to the endurance test, and the third tire is subjected to the high speed test. Paragraph S4.2.2.l is not intended to address the question of how many sets of tires a manufacturer should test as a surveillance procedure during production or what batch size the test sets should be drawn from. A manufacturer is not required to conduct any particular frequency of testing or even to run the actual tests specified by Standard No. 109. Instead, a manufacturer must take whatever steps are necessary to ensure that each of its tires, if tested according to the requirements of the standard, would meet those requirements. (For test purposes, however, any one given tire would only be subjected to one of the three test sequences discussed above.) Since Standard No. 109 includes a number of specific test requirements, it is likely that a manufacturer would find it necessary to do some testing in order to ensure that a tire complied with the standard. For enforcement purposes, NHTSA would test a tire according to the specific test requirements of Standard No. 109. Your third question is as follows: 3. Why does the standard make no reference to tolerances for tyre concentricity? NHTSA's standards cover aspects of performance for which the agency has determined there is a safety need. To date, NHTSA has not determined that there is a need for requirements covering tire concentricity tolerances. We note that tire concentricity appears to be primarily an issue of occupant comfort rather than safety. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam4578OpenPeter J. Yanowitch, Esq. Messrs. Davis, Markel, & Edwards 66 West Flagler Street, SUite 608 Miami, FL 33130 Re: Importation of Porsche 959; Peter J. Yanowitch Esq. Messrs. Davis Markel & Edwards 66 West Flagler Street SUite 608 Miami FL 33130 Re: Importation of Porsche 959; "Dear Mr. Yanowitch: This is in reply to your letter of February 27 l989, requesting a response by March l0 as to whether the Department would permit the importation of a Porsche 959 pursuant to l9 CFR 12.80(b)(1)(v). Specifically, you represent a non-resident of the United States who wishes to import such a vehicle, and operate it on the public roads of this country during the l-year period. You have asked for confirmation in writing that if the vehicle is imported on this basis that 'the Department of Transportation would not have jurisdiction to impound, confiscate, destroy, require a bond, or otherwise take any action with respect to the vehicle, so long as the non-resident fully complies with the provisions' of 12.80(b)(l)(v), and, further, that the Department 'would not object to the non-resident driving this vehicle on the road' while it is in the United States. You also state that your client is prepared to submit 'sworn testimony that he will comply with the requirements of the United States Customs Regulations.' Under l9 CFR 12.80(b)(l), each vehicle offered for introduction into the Customs territory of the United States shall be denied entry unless the importer files a declaration which declares that '(v) The importer...is a non-resident of the United States, is importing the vehicle...primarily for personal use for a period not exceeding l year from the date of entry, will not sell it in the United States during that period, and has stated his passport number and country of issue...in the declaration.' This provision was adopted in recognition of international treaties to which the United States is a party, which are intended to assure the free flow of international road traffic. However, this agency does not construe either the regulation or the treaties as conferring an absolute right upon any non-resident to import a non-conforming vehicle if considerations of policy dictate a determination that such entry would not be in the interests of the United States. Chief among these considerations is whether the importer has previously imported a motor vehicle in violation of the importation regulations. Accordingly, we wish to review your client's declaration before the time the vehicle arrives at the port of entry. I enclose a copy of our Form HS-7 for its completion and return to us. We request that a photocopy of the title or other certificate of ownership be enclosed as well. We also ask that a statement be attached to the declaration, so that it becomes a part of it and subject to penalties in the event that it is false or misleading, in which your client discloses whether he has ever imported into the United States any motor vehicle manufactured on or after January l, l968, and, if the answer is affirmative, to provide the make, model, and port and approximate date of entry, and the name of the importer or consignee as it appeared on the declaration. Finally, we also request an affirmation from your client that he will not sell the vehicle, or offer it for sale, either before or during its stay in the United States, and that he will export it at the end of the l-year period. When we have received and reviewed the declaration and statement we shall be pleased to consider this matter further, and we shall answer your questions at that time. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam2564OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P.O. Box 937, Fort Valley, GA 31030; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P.O. Box 937 Fort Valley GA 31030; Dear Mr. Milby: This responds to your March 28, 1977, letter asking whether it is lega to certify a school bus manufactured after April 1, 1977, if the bus is painted a color other than National School Bus Glossy Yellow.; The certification requirements of the National Highway Traffic Safet Administration are found in Part 567, *Certification* (49 CFR 567). This part requires that a manufacturer certify that the vehicle he manufactures complies with all applicable Federal motor vehicle safety standards promulgated under the National Traffic and Motor Vehicle Safety Act of 1966 (as amended) (the Act) (15 U.S.C. 1381). No safety standard promulgated under the Act requires that school buses be painted school bus yellow. Therefore, failure of a manufacturer to produce a school bus of that color would not be a violation of the Act, and his certification of the bus' compliance with motor vehicle safety standards would not be affected.; Pupil Transportation Standard No. 17, promulgated under the authorit of the Highway Safety Act of 1966 (23 U.S.C. 401 et seq.), controls the color of school buses. This standard requires that all vehicles operating as school buses be painted National School Bus Glossy Yellow. Since this standard applies to the operation of school buses and not their construction, compliance with its requirements is not a prerequisite to motor vehicle safety standard certification.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0521OpenMr. Earl S. Everhart, Jr., Vice President - Engineering, Maxim Motor Division, Middleboro, MA 02346; Mr. Earl S. Everhart Jr. Vice President - Engineering Maxim Motor Division Middleboro MA 02346; Dear Mr. Everhart: This is in response to your letter concerning the requirements o Federal Motor Vehicle Safety Standard No. 206. Your letter was forwarded to us November 10, 1971, by Mr. Stan Haransky, Associate Director of the Truck Body and Equipment Association, Inc.; You ask whether the standard would prohibit the manufacture of fir trucks without side doors on the cabs. According to your letter, the trucks are built without side doors in order to allow firemen to enter and exit the cabs quickly during emergencies.; Standard 206 does not require that any type of motor vehicle b equipped with side doors. The standard requires only that if a vehicle subject to it has hinged or sliding side doors, they must conform with the standard's performance requirements for hinges, locks and latches.; Please write if I can be of any further assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5256OpenThe Honorable Phil Gramm United States Senate 2323 Bryan Street, #1500 Dallas, TX 75201; The Honorable Phil Gramm United States Senate 2323 Bryan Street #1500 Dallas TX 75201; "Dear Senator Gramm: Thank you for your inquiry on behalf of you constituent, Mr. Thomas J. Devon of Longview, Texas. The Federal Highway Administration (FHWA) referred your inquiry to this office, since the National Highway Traffic Safety Administration (NHTSA) administers Federal safety standards for tires. In his communication with you, Mr. Devon expressed concern about separated treads from retreaded large truck tires. He referred to the deaths of two young women reportedly caused when they lost control of their vehicle after striking a separated tread in the road. Mr. Devon is concerned that retreaded tires do not meet the same standards as new tires and requested data on accidents caused by separated tire tread sections on the roadway. By way of background information, the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C. 1381, et seq. (Safety Act) authorizes NHTSA to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Pursuant to that authority, NHTSA has issued various Federal Motor Vehicle Safety Standards (FMVSS) applicable to tires: FMVSS Nos. 109 and 110 for new pneumatic passenger car tires, FMVSS Nos. 119 and 120 for new pneumatic tires for other than passenger cars, and FMVSS No. 117 for retreaded passenger car tires. There is currently no standard applicable to retreaded tires for vehicles other than passenger cars. This is because the agency is not aware of any data suggesting a safety need for such a standard. With respect to tire tread separation, examination of actual tire scraps from the nation's highways have indicated that about 60 percent came from retreaded tires and 40 percent from original tires. Because of the many complaints about heavy truck tire tread scraps on and around the highways, the University of Michigan conducted a study in the mid-1980s entitled 'Large Truck Accidents Involving Tire Failure.' That study concluded that most large truck tire failures are caused by vehicle overload and/or tire underinflation. Underinflation causes excessive flexing of the tire. The friction resulting from that flexing causes excessive heat buildup which can, in turn, result in tread separation or other tire failure. Indeed, the heat buildup has been known to be so extreme as to cause the tire to burst into flame. The findings from the Michigan study led the FHWA to prohibit the operation of commercial motor vehicles with overloaded and underinflated tires, unless the vehicle is operated pursuant to a special permit issued by a state. That permit, however, requires a reduced speed to compensate for the increased tire loading. In addition, the vehicle and the tires must be maintained in a safe operating condition at all times. FHWA conducts roadside inspection programs to ensure that such requirements are being met. While scraps of tires on the roadway could pose a safety hazard to motorists, this agency has no real world crash data to indicate what percentage of motor vehicle crashes could be attributed to separated tire treads. Our crash data are limited to the general category of tire failure. Please be assured that NHTSA and FHWA, as well as the tire industry itself, are engaged in ongoing efforts to alleviate this problem by appropriate publicity to large truck owners and operators regarding proper tire care and maintenance and by vigorous vehicle inspection programs. I hope this information is helpful. If your constituent has any further questions, he may contact Walter Myers of this office at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure Constituent's Correspondence"; |
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.