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 |
|---|---|
ID: nht70-1.7OpenDATE: 03/28/70 FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA TO: Industrija Gouijevih TITLE: FMVSS INTERPRETATION TEXT: In response to your letter of January 8, 1970, the Department of Transportation hereby assign number 212 to Sava, Industrija Gouijevih,(Illegible Words) Jugoslavija as its approved code mark. The approved code mark is for use in identifying the tire manufacturer in accordance with S4.3 of Federal Motor Vehicle Safety Standard No. 107, and the National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1421(1)). You are correct that all passenger car tires manufactured after August 1, 1968 must have permanently molded into or onto them the approved "DOT" recital. However, the application of the recital is not to import purposes only. The application of the(Illegible Words) by a tire manufacturer is the tire manufacturers self certification that his tire conforms to all of the minimum performance requirements of Federal Motor Vehicle Safety Standard No. 109. Standard 109 specifies tire dimensions and laboratory test requirements for bend unseating resistance, strength, endurance and high speed performance; defines tire load ratings; and specifies labeling requirements. A copy of the standard is enclosed. The National Highway Safety Bureau does not certify tires prior to the manufacturer's application of the "DOT" symbol. However, we do maintain a compliance test program by which certification of manufacturers are verified. Violations of this certification are subject to a fine of $ 1,000.00 per tire. Your attention is directed to the requirements for designation of an agent in accordance with the National Traffic and Motor Vehicle Safety Act of 1966, Subsection (110(a)). This requirement is implemented by our General Procedural Rules, Subpart D - Service of Process: Agents. I have enclosed a copy of those requirements for your information. |
|
ID: GAO telematics Sept 13OpenAshley G. Alley, Esq. Office of General Counsel Government Accountability Office (GAO) 441 G St., NW Washington, DC 20548 Dear Ms. Alley: This responds to your e-mail asking about the extent to which the National Highway Traffic Safety Administration (NHTSA) can regulate wireless communication technologies in motor vehicles that might be sources of driver distraction. You asked us to address: 1) Integrated, in-vehicle technologies (e.g., OnStar); 2) Nomadic technologies (e.g., handheld cell phones); and 3) After-market technologies that are integrated after the vehicle is manufactured (e.g., a satellite TV). As you know, NHTSA has authority under 49 U.S.C. Chapter 301 to issue Federal motor vehicle safety standards for motor vehicles and motor vehicle equipment. As discussed below, the answer to the issue of whether that authority permits the agency to regulate the technologies you listed is dependent, first, on whether the items and systems are considered motor vehicle equipment under Chapter 301 and, second, if they are so considered, whether issuing a standard for the items and systems would meet the statutory requirements for a standard, especially the requirement of meeting the need for motor vehicle safety. NHTSAs Authority to Regulate Wireless Communication Technologies that might be Sources of Driver Distraction Background Based on the definitions of motor vehicle safety and motor vehicle safety standard in subsection 30102(a)(8) and (9),[1] the agency has authority to issue standards for motor vehicle equipment as well as motor vehicles. The question of whether something qualifies as motor vehicle equipment is addressed by the definition of that term in subsection 30102(a)(7): "(M)otor vehicle equipment" means-- (A) any system, part, or component of a motor vehicle as originally manufactured; (B) any similar part or component manufactured or sold for replacement or improvement of a system, part, or component, or as any accessory or addition to a motor vehicle; or (C) any device or an article or apparel ... that is not a system, part, or component of a motor vehicle and is manufactured, sold, delivered, offered, or intended to be used only to safeguard motor vehicles and highway users against risk of accident, injury, or death. (Emphasis added.) In order to issue a standard for motor vehicle equipment, the agency must show that the standard meets the requirements in subsection 30111(a). It states that (e)ach standard shall be practicable, meet the need for motor vehicle safety, and be stated in objective terms. Discussion Integrated, in-vehicle technologies (e.g., OnStar) You first asked about integrated, in-vehicle technologies, e.g., OnStar. Given that you separately ask about after-market technologies, we assume that this question is limited to items and systems that are integrated into the vehicle prior to first retail sale. The initial issue for these items and systems is whether they are considered motor vehicle equipment under the definition quoted above. Under 30102(a)(7), all items and systems that are integrated into a vehicle prior to its first retail sale are within the definition of motor vehicle equipment. Accordingly, the agency has authority to issue Federal motor vehicle safety standards for integrated, in-vehicle technologies. However, given the requirement in subsection 30111(a) that each standard meet the need for motor vehicle safety, we can establish standards for these technologies only to the extent that we can show a safety benefit for those standards. A challenge in using our authority is that while research suggests that use of personal communication devices by drivers can adversely affect driving performance, it is difficult to find confirmation that these findings represent actual real-world crash risks. It would also be difficult to develop effective countermeasures for any risks whose existence we could demonstrate. Nomadic technologies (e.g., handheld cell phones) Next, you asked about nomadic technologies, e.g., handheld cell phones. Given your other questions, we assume that this question is limited to items and systems that are not integrated into the vehicle. Since these items and systems would not be integrated into the vehicle, they would be motor vehicle equipment under subsection 30102(a)(7) only if they were considered accessories under (a)(7)(B). NHTSA uses two criteria in determining whether a device is an "accessory." The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine a product's expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. If a product satisfies both criteria, then the product would be an "accessory." Applying these criteria to cell phones, it is our opinion that a substantial portion of the expected uses of a cell phone would not be related to the operation or maintenance of motor vehicles. While a cell phone can be used in a motor vehicle, there is no particular nexus between the function of a cell phone and either the operation or the maintenance of motor vehicles. The cell phone performs the same function wherever it is taken by the user, e.g., on public sidewalks, in buildings, and so forth. Because the first prong of the two-part test for an accessory is not met, a cell phone is not an item of motor vehicle equipment. The same criteria would be applied in determining whether other items or systems incorporating nomadic technologies are accessories. We cannot provide a broad opinion covering all nomadic technologies, since specific information about the item or system and its expected uses is needed to apply these criteria. After-market technologies that are integrated after the vehicle is manufactured (e.g.., a satellite TV) You also asked us to address after-market technologies that are integrated after the vehicle is manufactured (e.g., a satellite TV). Given your other questions, we assume that this question is limited to items and systems that are integrated into the vehicle after first retail sale. Some items and systems incorporating these technologies would come within the subsection 30102(a)(7) definition of motor vehicle equipment. This would likely be the case for satellite TV systems marketed for use in motor vehicles. However, in order to provide a specific opinion, we would need detailed information about the specific product at issue. For those technologies that are items of motor vehicle equipment, the agency would face the same challenges described above in discussing integrated, in-vehicle technologies. Other Considerations We note that our safety standards generally apply to new motor vehicles and new motor vehicle equipment up to the time of first retail sale. Manufacturers, distributors, dealers, or motor vehicle repair businesses modifying a new or used vehicle are prohibited by section 30122 from knowingly making inoperative any 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. For example, installation of after-market technologies reduce the effectiveness of devices or elements of design installed pursuant to our crashworthiness standards would be prohibited. The make inoperative provision does not, however, apply to modifications made by vehicle owners themselves to their own vehicles. Thus, while we recommend that owners maintain the safety of their vehicles, Federal law does not prevent them from making modifications that take their vehicle out of compliance with a safety standard. The States, however, can regulate the changes that vehicle owners make to their vehicles. I hope this information is helpful. If you have any further questions about NHTSAs authority to regulate motor vehicle and motor vehicle equipment manufacturers, please contact Dorothy Nakama at (202) 366-2992. She may be reached at this address. Sincerely yours, Anthony M. Cooke Chief Counsel NCC-20:DNakama:62992:mar:jul/19/07:OCC#07-003616 [S:\NCC20\INTERP\VSA\07-003616 GAO drn.doc] cc:NCC-20, subj/chron, DN, NVS-100, NVS-200, NPO-100 Interps, VSA 102(4), Docket [1] (8) "motor vehicle safety" means the performance of a motor vehicle or motor vehicle equipment in a way that protects the public against unreasonable risk of accidents occurring because of the design, construction, or performance of a motor vehicle, and against unreasonable risk of death or injury in an accident, and includes nonoperational safety of a motor vehicle.
(9) "motor vehicle safety standard" means a minimum standard for motor vehicle or motor vehicle equipment performance. |
|
ID: nht90-1.86OpenTYPE: INTERPRETATION-NHTSA DATE: 03/27/90 FROM: LARRY F. WORT -- CHIEF BUREAU OF SAFETY PROGRAMS DIVISION OF TRAFFIC SAFETY ILLINOIS TO: TAYLOR VINSON LEGAL COUNSEL UNITED STATES DEPARTMENT OF TRANSPORTATION TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 03/27/90 FROM STEPHEN P. WOOD -- NHTSA TO LARRY F. WORT -- ILLINOIS DEPT OF TRANSPORTATION; REDBOOK A35; STANDARD 108; FORD RATIONALE FOR FMVSS 108 COMPLIANCE; BY CLARKS GORTE -- FORD; DATED 03/19/90 TEXT: The State of Illinois is requesting a legal interpretation of the federal requirements for front side marker lights on trucks. The truck model in question is a Ford low profile cab C-8000 cab over engine (see Exhibit A and B). These trucks were manufact ured with a reflex reflector at the location shown on exhibit A and do not have front side marker lights. The truck cab in question has been manufactured this way for more than 20 years. The Division of Traffic Safety, Standard Engineer, has obtained telephone interpretations from Mr. Robert Hagan of the Bureau of Motor Carrier Safety and Mr. Kevin Cavey of the National Highway Transportation Safety Administration. Both of these gentleme n confirmed that the truck should be equipped with a front side marker light. (Exhibits A and B were telefaxed to Washington, D.C. for reference.) Ford Motor Company has submitted a written opinion (Exhibit C) stating that they consider their vehicle to be in compliance. This information was telefaxed by Ford Motor Company to Mr. Richard Hunter in the Central Bureau of Maintenance. A legal opinion is required on the following question of compliance (see Exhibit D); Can the top of the cab clearance light (item six) be used to fulfill the requirements for front side marker lights (item two) on cab over engine vehicles? |
|
ID: babcock.ztvOpenMr. Robert Babcock Dear Mr. Babcock: This is in reply to your letter of January 8, 2003, asking for an opinion whether a multi-component rear reflex reflector configuration would comply with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. The rear reflex reflector configuration in your design consists of three separate reflex reflectors. One reflector is installed on the fender and a second reflector is located adjacent to it, on the deck lid. The third reflector is hidden by the deck lid (it is a reflex reflector located on the flange of the outer lamp housing) and it is not visible until the deck lid is raised. No single reflector fulfills the photometric requirements for a rear reflex reflector, but these requirements are met when the reflector on the fender and either of the other two reflectors are measured. Your design is not a permissible configuration under Standard No. 108. The applicable standard incorporated by reference in Standard No. 108 is SAE J594f, "Reflex Reflectors," January 1977. The text and setup for testing set forth in SAE J594f clearly indicate that the requirements of this standard apply to a single reflex reflector, and may not be met using a combination of separate reflex reflectors. If you wish to proceed with this configuration, we recommend that the reflector located on the fender be redesigned to meet the requirements of SAE J594f. We also note that, for whatever configuration you use, Standard No. 108 requires rear reflex reflectors to be as far apart as practicable. Sincerely, Jacqueline Glassman ref:108 |
2003 |
ID: nht75-5.24OpenDATE: 09/11/75 FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA TO: The University of Connecticut TITLE: FMVSR INTERPRETATION TEXT: Please forgive the delay in responding to your letter of May 22, 1975, which inquired about the status of tire grading standards. On May 20, 1975, the National Highway Traffic Safety Administration issued the Uniform Tire Quality Grading Standards with a series of effective dates beginning January 1, 1976 (40 FR 23073, May 28, 1975). On July 3, 1975, the regulation was republished with minor changes (40 FR 28071). On August 14, 1975, a stay of the effective dates was granted by the United States Court of Appeals for the Sixth Circuit, pending review of the validity of the regulation in a suit brought by eight tire manufacturers. For your convenience, I have enclosed copies of the Federal Register notices referred to above. Yours truly, Enclosures May 22, 1975 Richard B. Dyson -- Acting Chief Counsel; U.S. Dept. of Transportation, National Highway Traffic Safety Administration Re: N40-30(MPP) Dear Mr. Dyson: On August 12, 1974 you were kind enough to bring me up to date on the proposed Federal Tire Grade Labeling Standards. The proposed effective date of May 1, 1975 has now passed and I suspect from recent radio reports that there have been some additional changes in the Standards and in the effective date. I will appreciate being updated on the situation again so that I may pass the information on to our State Extension personnel. Thank you. Sincerely yours, James H. Whitaker -- Associate Professor, THE UNIVERSITY OF CONNECTICUT |
|
ID: nht72-2.14OpenDATE: 10/30/72 FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA TO: Peterson Manufacturing Company TITLE: FMVSS INTERPRETATION TEXT: This is in reply to your letters of September 1, 1972 and September 27, 1972, calling our attention to contradictory provisions of 49 CFR @ 571.108, Motor Vehicle Safety Standard No. 108, and 49 CFR @ 393.22, a regulation of the Bureau of Motor Carrier Safety. We confirm your interpretation that the Motor Carrier Safety Regulations prohibit the inclusion of a clearance lamp in the same shell or housing as a taillamp or identification lamp, while Paragraph S4.4.1 of Standard No. 108 allows use of the same shell or housing as long as the clearance lamp is not optically combined with a taillamp or identification lamp. Although identical regulations are preferable from a manufacturer's standpoint, section 103(g) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1381 et seq.) allows the Bureau of Motor Carrier Safety to promulgate or maintain "a safety regulation which imposes a higher standard of performance [than the safety standards] subsequent to . . . manufacture." The Bureau views its regulation as establishing a higher standard of performance since, in its opinion, separate housings lessen the likelihood that, at a distance, marking and signaling functions will be confused. If you feel that 49 CFR @ 393.22 should be amended to be identical with Paragraph S4.4.1 of Standard No. 108, you should so petition the Bureau. We also confirm that, if the rear identification lamps are located at the extreme height of the vehicle, Paragraph S4.3.1.5 of Standard No. 108 would allow clearance lamps, whether separate or in the same housing as other lamps, to be located at a height less than "as close as practicable to the top of the vehicle." |
|
ID: nht80-1.8OpenDATE: 01/31/80 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Doug Smith TITLE: FMVSS INTERPRETATION TEXT: This responds to your December 6, 1979, letter asking questions about Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps. In particular, you ask whether winged projections are permitted in a rim as long as they do not extend beyond the lip of a rim or the sidewall of a tire. When the standard was issued, the agency concluded that winged projections could catch the clothing of children or pedestrians thereby posing a safety hazard. As a result, the standard prohibits the use of all winged projections regardless of the extent to which they extend from a rim. The standard, however, only prohibits winged projections and does not affect other projections from a rim. SINCERELY, December 6, 1979 Roger Tilton Office of Chief Counsel National Highway Traffic Safety Administration Dear Mr. Tilton: After talking with you this after noon I'm writing for your ruling on wing projections covered in Motor Vehicle Safety Standard no. 211-S3. I am of the opinion that if the knock off (winged projection) does not extends beyond the lip of the rim or the sidewall face of the tire mounted on the rim, it will be all right with the knock off in the center. As I understand the ruling, it is designed to eliminate catching people or objects and dragging them into the wheel. By not extending beyond the lip of the rim or sidewall face the knock off would be safe. Please return you ruling to me as soon as possible. Doug Smith Attachment Omitted. |
|
ID: 17464.ztvOpenMs Sandra L. Sizemore Dear Ms Sizemore: This is in reply to your letter of March 18, 1998, regarding a lamp you are considering manufacturing. We understand from a conversation that Taylor Vinson of this Office had with your husband on April 16, 1998, that the lamp is intended to illuminate in a steady-burning fashion when the brake pedal is applied, and that it will be red in color. The lamp will fit in a spoiler or wing installed on the back of a car. As you note, aftermarket companies have been installing these in spoilers for some time, and we understand from your husband that aftermarket sales are intended both to new car dealers and to parts supplies stores. You believe that "this light may not need to be D.O.T. approved based on the intended application, however our customer requires that the light be D.O.T. approved." The Department has no authority to "approve" or "disapprove" items of equipment, nor are there any "D.O.T. licensing requirements," the subject of three of your questions. We do advise whether supplementary lighting equipment such as your lamp appears permitted or prohibited by the Federal motor vehicle safety standard on lighting, Standard No. 108 Lamps, Reflective Devices and Associated Equipment. I enclose a copy of a letter to Timothy McQuiston, dated January 28, 1994, which discusses the relationship to Federal laws of aftermarket spoilers incorporating stop lamps. If you or your husband have any questions, you may call Taylor Vinson (202-366-5263). As he explained, the direct obligations under Federal law fall upon those persons who install the spoiler-lamp, rather than on those who manufacture or sell it. Nevertheless, your company can help the installer fulfill his obligation by ensuring that the lamp in the spoiler complies with Standard No. 108, principally in ensuring that it has a minimum lens area of 4 1/2 square inches and meets the appropriate photometrics. In addition to the letter to Mr. McQuiston, we are also enclosing a copy of the sections of Standard No. 108 that apply to lamps in spoilers that serve as the required center highmounted stop lamp. These are paragraph S5.1.1.27 and Figure 10. Sincerely, |
1998 |
ID: nht93-6.3OpenDATE: August 5, 1993 FROM: P. J. Harrington -- Assistant Chief, Northern Division, Dept. of California Highway Patrol TO: Superintendent -- Potter Valley Community Unified School Dist. TITLE: None ATTACHMT: Attached to letter dated 2/9/94 from John Womack to Maurice Hannigan (A42; Std. 205) and letter dated 3/31/93 from John Womack to W. C. Burke TEXT: This is to inform you that California Highway patrol has received a written interpretation from the National Highway Traffic Safety Administration (NHTSA) regarding the marking requirements for replacement window glass in school buses. As you are aware, California has adopted the Federal Motor Vehicle Safety Standard for safety glass used in motor vehicles. In their letter (copy enclosed), NHTSA states a person who cuts a section of glass to size for installation in a motor vehicle is considered a manufacturer and is, therefore, required to mark the glass. The only exception to this is if the cut section of glass still contains the original markings, in which case remarking that piece of glass is not necessary. The markings required must contain the following information: (1) the words "American National Standard" or the characters "AS"; (2) a number identifying the item of glazing; (3) a model number assigned by the manufacturer identifying the type of construction of the glass; and (4) the manufacturer's trademark. It is recommended you contact the installer of your glass to notify them of these findings and have the glass in your school buses inspected for the proper markings. To obtain a number as required by this Federal Standard, your installer should contact Mr. John Messcra of the NHTSA at (202) 366-5300. We are allowing an extended period of time by which the glass must be properly marked and in compliance with Federal Motor Vehicle Safety Standard (FMVSS) 205. The new compliance date is January 1, 1994. All school buses inspected by the California Highway Patrol after that date will not be certified if any of the glass is found not to comply with FMVSS 205. Attached is an acknowledgement form. We would appreciate your Superintendent/Director, or designated alternate, completing and returning it to our office by September 1, 1993, in the addressed, postage paid envelope provided. If you have any questions regarding this matter, please contact the Northern Division Motor Carrier Safety Unit at (916) 225-2098. |
|
ID: nht89-3.17OpenTYPE: INTERPRETATION-NHTSA DATE: 10/16/89 FROM: DONALD S. CLARK -- SECRETARY FEDERAL TRADE COMMISSION TO: BUD SHUSTER -- U.S. HOUSE OF REPRESENTATIVES TITLE: NONE ATTACHMT: ATTACHED TO LETTER DATED 11/20/89 FROM STEPHEN P. WOOD -- NHTSA TO CONGRESSMAN BUD SHUSTER; REDBOOK A34; STANDARDS 109, 117, AND 119; LETTER DATED 8/8/89 FROM CONGRESSMAN BUD SHUSTER TO THE DIRECTOR OF CONGRESSIONAL RELATIONS -- DEPARTMENT OF C OMMERCE TEXT: Dear Mr. Shuster: The Department of Commerce has forwarded your letter on behalf of Mr. Lester Hoover to the Federal Trade Commission. Mr. Hoover contacted your office for assistance in obtaining a copy of any regulations pertaining to presale disclosure of grading in formation on automobile tires. I have enclosed a copy of the Commission's 1967 Tire Advertising and Labeling Guides, 16 C.F.R. Part 228, which, inter alia, call for certain disclosures in the sale of blemished, imperfect, or defective tires (Section 228.11) and in the sale of retre ads and used tires (Section 228.9). These are the only regulations promulgated by the Federal Trade Commission that focus specifically on tires, although other regulations and statutes of general application (such as Section 5 of the FTC Act, which the Commission enforces) cover tires along with other products. It may interest Mr. Hoover to know that failure to comply with the Guides is not a per se law violation. Rather, as Section 228.0-1 states, the Guides set forth general principles that the Commission applies in determining whether given representatio ns or other practices concerning tires constitute violations of Section 5 of the Federal Trade Commission Act. The remedy for a violation of Section 5 is generally an administrative cease and desist order, rather than the monetary civil penalties which may be obtained in cases involving violation of a Commission order or Trade Regulation Rule. There may be other tire regulations that would be of interest to Mr. Hoover. I have therefore taken the liberty of forwarding a copy of your inquiry to the Department of Transportation for further review and response. Please let me know whenever I can be of service. Sincerely, Enclosure |
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.