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: 19603.drnOpenThe Honorable Bob Kerrey Dear Senator Kerrey: Thank you for your letter forwarding correspondence from Ms. Gina Dunning, former Director of the Nebraska Department of Health and Human Services, Regulation and Licensure. As you are aware, the National Highway Traffic Safety Administration (NHTSA) administers the Federal school bus safety program. Ms. Dunning wrote to you with concerns about a NHTSA regulation affecting child care centers and Head Start programs. In essence, Ms. Dunning was concerned that we have interpreted our statute to disallow dealers' sales of certain new buses to after school care programs that will significantly use the bus to transport school children "to or from school or an event related to school." The buses are those that are not certified as meeting NHTSA's school bus standards. Ms. Dunning has written a separate letter to me, expressing her concern about our interpretation and how it would affect child care transportation providers in Nebraska. Her letter to me is substantially similar to the letter she addressed to you. While we understand that Ms. Dunning is no longer the Director of the state agency, we responded to her successor, Mr. Richard Nelson, on March 25, 1999. I am enclosing a copy of my response for your information, with all referenced enclosures. I hope that the enclosed items are helpful. If you have any further questions, please feel free to contact me. Sincerely, |
1999 |
ID: 19771.drnOpenThe Honorable William E. Barrett Dear Congressman Barrett: Thank you for your letter forwarding correspondence from Ms. Gina Dunning, former Director of the Nebraska Department of Health and Human Services, Regulation and Licensure. Your letter was forwarded to my office for reply, because the National Highway Traffic Safety Administration (NHTSA) administers the Federal school bus safety program. Ms. Dunning wrote to you with concerns about a NHTSA regulation affecting child care centers and Head Start programs. In essence, Ms. Dunning was concerned that we have interpreted our statute to disallow dealers' sales of certain new buses to after school care programs that will significantly use the bus to transport school children "to or from school or an event related to school." The buses are those that are not certified as meeting NHTSA's school bus standards. Ms. Dunning has written a separate letter to me, expressing her concern about our interpretation and how it would affect child care transportation providers in Nebraska. Her letter to me is substantially similar to the letter she addressed to you. While we understand that Ms. Dunning is no longer the Director of the state agency, we responded to her successor, Mr. Richard Nelson, on March 25, 1999. I am enclosing a copy of my response for your information, with all referenced enclosures. I hope that the enclosed items are helpful. If you have any further questions, please feel free to contact me. Sincerely, |
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ID: nht87-1.14OpenTYPE: INTERPRETATION-NHTSA DATE: 01/12/87 FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA TO: Lynn Walker -- Sales Manager, Panamasia West Coast, Inc. TITLE: FMVSS INTERPRETATION TEXT: Mr. Lynn Walker Sales Manager Panamasia West Coast, Inc. 16205 Distribution Way Cerritos, CA 90701
This is in reply to your letter of September 17, 1986, to Mr. Vinson this office asking whether a lamp you wish to import "is legal for highway use in the U.S." The lamp is an aftermarket auxiliary turn signal that is mounted on top of each front fender. The lens is green, but could be any color that is legal for highway use. The lens is visible "from all directions" but could be designed so that it is visible only to the rear, i.e. to the driver. Federal motor vehicle lighting requirements do not currently apply to aftermarket lamps of this nature. Whether the lamp is legal, therefore, is a question to be answered under the laws of each State in which it will be sold and operated. While we are no t familiar with State lighting laws you nay find that there is a greater likelihood that the auxiliary turn signal lamp will be acceptable if it has a yellow lens, or if its green lens is visible only to the driver. I hope that this is helpful to you. Sincerely, Erika Z. Jones Chief Counsel PANAMASIA WEST COAST, INC. 16205 Distribution Way Cerritos, CA 90701 (213) 926-5591 Sept. 17, 1986
Dear Mr. Vinson, We are an Import-Export Company specializing in Automotive Parts and Accessories. We are interested in importing the automotive lamp which is described on the following page. We wish to know if this type of lamp is legal for highway use in the U.S. If any alterations are necessary to make this lamp legal, please advise us of them. If we can give you more information please don't hesitate to contact us at the above address or telephone number. With our best regards, PANAMASIA WEST COAST, INC. Lynn Walker Sales Manager Auto Parts DIRECTIONAL LAMP - 12 VOLT APPLICATION: THIS IS AN ADD-ON ACCESSORY FOR PASSENGER CARS. INSTALLATION: IT IS INSTALLED ON TOP OF THE FRONT FENDERS ABOVE THE HEAD LAMP. APPLICATION IS STICK-ON. THE WIRE CAN BE RUN INTO THE ENGINE COMPARTMENT AS IN THE ILLUSTRATION, OR THE INSTALLER MAY DRILL A HOLE IN THE FENDER DIRECTLY UNDER THE LAMP AND RUN THE WIRE THR OUGH IT. VISABILITY: THE LENSE IS VISIBLE FROM ALL DIRECTIONS. THE LENSE AREA IS THE AREA HIGHLIGHTED IN YELLOW IN DIAGRAM 1. ALSO, PLEASE ADVISE US OF THE LEGALITY OF THE SAME LAMP IF IT WERE VISIBLE ONLY TO THE REAR (VISIBLE TO THE DRIVER).
MATERIAL: THE BASE IS OF FLEXIBLE PLASTIC. THE HOUSING AROUND THE LENSE IS OF METAL. THE LENSE IS PLASTIC. LENSE COLOR IS GREEN, BUT COULD BE ANY COLOR THAT IS LEGAL FOR HIGHWAY USE. INSERT GRAPHICS HERE |
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ID: VINsOpen Mr. Dale Kardos Dear Mr. Kardos: This responds to your letter requesting information on Vehicle Identification Number (VIN) requirements as they pertain to a forthcoming Porsche sport utility vehicle (SUV). You state that the Porsche SUV will be produced in two stages and in two different Porsche plants. The first stage will occur at the Porsche plant in Bratislava, Slovakia, where the body structure will be produced, and the front windshield and VIN will be installed. This basic structure then will be transported to the Porsche plant in Leipzig, Germany, where it will be combined with the rest of the vehicle (i.e., engine, transmission, wheels, tires, brakes, etc.). You ask whether it is acceptable to use the letter "L" as the eleventh character of the VIN, which would indicate the plant of manufacture as the Leipzig plant rather than the Bratislava plant. Under the circumstances described above, this is acceptable. The National Highway Traffic Safety Administration's (NHTSA's) VIN requirements are contained in 49 CFR Part 565. Each VIN must be made up of seventeen characters consisting of Arabic numbers and Roman letters. Under 565.6(d)(2), the eleventh character must represent the "plant of manufacture," which is defined as the plant where the manufacturer affixes the VIN. Since the VINs of the Porsche SUVs will be affixed at the Bratislava plant, it would appear that the eleventh character in the Porsche SUV VINs should indicate the Bratislava plant, not the Leipzig plant. However, the requirements of Part 565 do not apply until the structure at a minimum meets the definition of an "incomplete vehicle." Section 565.4(a) requires a vehicle manufactured in more than one stage to have a VIN assigned by the incomplete vehicle manufacturer. An "incomplete vehicle" is defined as: an assemblage consisting, at a minimum, of frame and chassis structure, power train, steering system, suspension system and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed vehicle. Since the Porsche SUV unit which will be produced at the plant in Bratislava will consist only of the body structure, front windshield, and VIN, it does not meet the definition of an "incomplete vehicle." Thus, the requirements of Part 565 do not apply to the Porsche SUV until the unit produced at the Bratislava plant is married with the power train, steering system, suspension system, and braking system. Since this will take place at the Leipzig plant, NHTSA considers the Leipzig plant to be the plant of manufacture for purposes of 49 CFR Part 565. Consequently, Porsche should use the letter "L" as the eleventh character in Porsche SUV VINs to indicate the Leipzig plant as the plant of manufacture. I hope this answers your question. If you have any further questions regarding this matter, please feel free to contact Mr. Dion Casey in my office at (202) 366-2992. Sincerely, John Womack |
2001 |
ID: nht95-7.40OpenTYPE: INTERPRETATION-NHTSA DATE: November 17, 1995 FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA TO: Jim Young -- Wheeled Coach TITLE: NONE ATTACHMT: ATTACHED TO 10/17/95 LETTER FROM Jim Young to John Womack (OCC 11303) TEXT: Dear Mr. Young: This is in reply to your FAX of October 17, 1995, asking for interpretations of Motor Vehicle Safety Standard No. 108, as in relates to "customer specifications for options incorporated into, or in addition to FMVSS lighting." You have described these options as: "Brake override circuit for rear facing warning lights. The rear warning lights flash as warning lights until the brakes are applied, at which time they become stead burn. This option is in addition to the standard brake lights. If this is acceptable, should the lights be required to meet all requirements of stop lights? (ie.; maximum luminous intensity, color, etc. . .)" As you clarified in a phone conversation with Taylor Vinson of this Office on November 2, the "rear facing warning lights" are part of the ambulance lighting system which is not a system required by Standard No. 108. This option is permissible. Although there is no Federal legal requirement that governs the performance of ambulance warning systems, we recommend that the rear facing warning lights are red, the required color for stop lamps, inasmuch as the intent seems to be provide an additional indication that the brake have been applied. "Brake Enhancer. Standard or additional stop lights are made to flash on/off several times before going steady burn." This is not permissible. Standard No. 108 requires all stop lamps to be steady burning. "Back-up alert strobes. Rear facing high intensity strobe lights that are activated when the gearshift lever is placed into reverse gear." Optional equipment is permissible if it does not impair the effectiveness of lighting equipment required by the standard. You have not indicated the color of the strobe lamps. If they are red or amber, they could cause confusion in the eyes of an observer when operated simultaneously with the steady burning P2 white backup lamp. There is a lesser possibility of confusion if they cast a white light, as long as they do not mask the steady burning backup lamp. In that event, the strobes could be fitted to the ambulances. "Taillight flashers. Taillights or brake lights are flashed alternate to backup lights until brakes are applied, at which time they go steady burn. The option at times may be requested to only work of the rear doors on the ambulance are open." This is not permissible. Standard No. 108 requires taillamps as well as stop lamps to be steady burning, under all circumstances. If you have further questions, you may refer them to Taylor Vinson (202-366-5263). Sincerely, |
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ID: 1985-03.25OpenTYPE: INTERPRETATION-NHTSA DATE: 08/06/85 FROM: AUTHOR UNAVAILABLE; Mr. William Pesce; NHTSA TO: Mr. William Pesce TITLE: FMVSS INTERPRETATION TEXT: Thank you for your May 18, 1985 letter inquiring about the existence of any Federal safety requirements applicable to your projected sale of colored windshield wiper blades. Under the National Traffic and Motor Vehicle Safety Act, this agency has issued Federal Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems, applicable to new motor vehicles. While this standard does not regulate wiper color, it does, among other things, require that a wiping system clear a minimum percentage of a vehicle's windshield. In addition, Standard No. 107, Reflecting Surfaces, also applies to new motor vehicles. This standard specifies reflecting surface requirements for certain components, including windshield wiper blades, in the driver's field of view. Its purpose is to reduce the likelihood that unacceptable glare from reflecting surfaces will hinder safe and normal operation of the vehicle. If a new vehicle equipped with your blade did not comply with Standard No. 104 or Standard No. 107 due to some aspect of that blade, the sale of that car to the public would be a violation of the prohibition in section 108(a)(1) (A) of the Act against the sale of noncomplying vehicles. As to used vehicles, you should be aware that section 108(a)(2)(A) of the Act prohibits manufacturers, distributors, dealers and vehicle repair businesses from knowingly rendering inoperative equipment or elements of design installed on a vehicle under Federal motor vehicle safety standards. Care should be taken that the installation of your product would not have that effect. A rendering inoperative might occur if, for example, your blade were not large enough to enable the wiping system to clear a sufficient area of the windshield. We urge you therefore to ensure that the substitution of your blade for an original equipment blade provided by a vehicle manufacturer would enable the wiping system to continue to perform as required by Standard No. 104, and would not produce unacceptable glare in the driver's field of view, as required by Standard No. 107. I hope this information is helpful. ENCLS. OCC-0747 Department of Transportation May 18, 1985 We propose to offer for sale to the public a colored windshield wiper blade. Our blade attaches to existing windshield wiper arms. It does not alter in any way the speed or rythem of an operating wondshield wiper. It is not made of floresent, or as they are called HOT colors nor is it reflective in any way. We have been unable to find any safty restrictions which would apply to our product. If such restriction do, or do not exist we would appreciate receiving this information by return mail in the envelope provided. William Pesce B P Origionals |
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ID: 16653.ztvOpenMr. Filmore Bouldes Dear Mr. Bouldes: We have received your letter postmarked November 25, 1997, which asks the National Highway Traffic Safety Administration "if it's legal to use any other colors, on the front approach of your vehicle, other than yellow and clear/can you use blue, red etc. inside or outside of your vehicle?" We assume that you mean the color of front lamps, such as headlamps, parking lamps, turn signal lamps, and fog or other supplemental lamps. The question of colors that you are permitted to use for lamps on the front of your vehicle must be answered under the laws of the states in which the vehicle will be licensed and operated. I am sorry that we are not conversant with state laws, but the Michigan Highway patrol will be able to furnish you an answer. However, we believe that most states restrict the use of blue or red front lighting to emergency vehicles. This agency's motor vehicle lighting standard requires vehicles to be manufactured with front lamps that are white (headlamps), or amber (parking and turn signal lamps) in the color of light they emit. Federal law does not prohibit the owner of a vehicle from personally changing these colors, but state laws very likely will. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, |
1998 |
ID: 14119.drnOpen Ms. Jo. Campfield Dear Ms. Campfield: This responds to your request for an interpretation of this agency's laws that apply to your new product, EDGEGUARD, a clear material that is placed on the outer three inches or less of a windshield perimeter to prevent cracks. I apologize for the delay in responding. As you are aware from past correspondence, the National Highway Traffic Safety Administration (NHTSA) has the authority to regulate the manufacture of new motor vehicles and motor vehicle equipment. NHTSA has promulgated Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials, which specifies performance and location requirements for motor vehicle glazing. For windshields, Standard No. 205 specifies minimum levels of light transmittance (70 percent) and light stability; resistance to abrasion, delamination (humidity and boil tests), impact and penetration; and maximum levels of optical deviation and distortion. The various tests and criteria are contained in ANSI/SAE Z26.1, which is incorporated by reference in Standard No. 205. NHTSA has stated in past interpretation letters that films such as the type your letter describes are not glazing materials themselves, and would not have to meet Standard No. 205. However, depending on who installs the glazing, installation of such films on new motor vehicles may be prohibited if, after installation, the vehicle glazing no longer meets the requirements of Standard No. 205, such as those for light transmittance, abrasion resistance and optical distortion. A vehicle manufacturer or dealer placing your film on glazing in a new vehicle prior to sale of the vehicle must certify that the glazing continues to meet Standard No. 205. 49 U.S.C. Section 30112(a) prohibits any person from manufacturing for sale, offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards, including Standard No. 205. After the vehicle has been sold to the first purchaser, the owner may modify the vehicle as he or she pleases, subject to State requirements. Under Federal law, the owner could install your product on the vehicle whether or not such installation adversely affects the light transmittance and other properties of the vehicle's glazing. However, we urge consumers not to degrade the safety of their vehicles. 49 U.S.C. Section 30122(b) provides that a manufacturer, distributor, dealer or motor vehicle repair business "may not knowingly make inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. "Make inoperative" means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the FMVSSs. Thus, none of these persons may knowingly install your film on a vehicle for its owner if the installation would make inoperative the light transmittance or abrasion resistance of the vehicle glazing. Violations of this section may result in Federal civil penalties of up to $1,100 for each violation. Because State law may affect the installation of your product on owners' vehicles, you should check the law in the States where you believe your product may be sold or installed for any applicable requirements. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, |
1997 |
ID: 17556.wkmOpenMr. Enzo Bauk Dear Mr. Bauk: This responds to your letter of March 16, 1998 and refers to the telephone conversation of May 20, 1998 between Mr. O. L. Rand of your staff and Walter Myers of my staff. You stated that your company manufactures, among other things, electric buses and trolleys that use air-over-hydraulic (AOH) braking systems. You stated that there are currently no brake systems available that will permit you to comply with the antilock brake system (ABS) requirements of Federal Motor Vehicle Safety Standard (Standard) No. 121, Air brake systems. You enclosed a list of twenty-five manufacturers and suppliers whom you contacted but who could not or would not provide you the required equipment except at considerable additional cost because of the small number of units involved. You stated that you believe that the ABS requirement should not apply to your vehicles "until the market offers a reliable economically viable system for small equipment manufacturers." Standard No. 121 defines air brake systems as follows:
The standard further defines AOH brake systems as:
Thus, the ABS requirements of Standard No. 121, by their terms, apply to your AOH-equipped vehicles. In reviewing the list of companies that you contacted for AOH brake systems equipped with ABS, we noted that all those companies are U.S. manufacturers and suppliers. As Mr. Rand and Mr. Myers discussed in their telephone conversation, AOH systems are more commonly used in Europe and Japan than they are in the U.S. Thus, you could perhaps have better luck locating suppliers in those areas that could provide the components that you need. In that connection, I refer you to an article entitled Antilock Brakes, Part II which appears in the March 2, 1998 issue of Transport Topics, commencing at page 12. A brief discussion of the effect of antilock requirements on AOH systems appears at page 16 where the author comments on techniques used by Hino Diesel Trucks engineers in Japan (copy enclosed). Mr. Rand and Mr. Myers also discussed the provisions of 49 Code of Federal Regulations, Part 555, TEMPORARY EXEMPTION FROM MOTOR VEHICLE SAFETY STANDARDS (copy enclosed). Mr. Taylor Vinson of this office ((202) 366-5263; fax (202) 366-3820) may be contacted for additional information on this procedure. I hope this information is helpful to you. Should you have other questions or need additional information, feel free to contact Mr. Myers at this address or at (202) 366-2992, fax (202) 366-3820. Sincerely, |
1998 |
ID: nht72-2.25OpenDATE: 03/03/72 FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA TO: Koito Manufacturing Company, Ltd. TITLE: FMVSS INTERPRETATION TEXT: This replies to your letters of January 27, February 8 and February 9, 1972, to the National Highway Traffic Safety Administration, regarding questions on headlamp mounting requirements of Federal Motor Vehicle Safety Standard No. 108. The following comments relate to the specific questions in the letters of each date. Question 1 - January 27, 1972 The Federal Motor Vehicle Safety Standard No. 108 and referenced SAE standards do not preclude the headlamp aiming adjustment by direct sliding contact of the headlamp back (Illegible Word) to the housing. We're concerned however that headlamps of different manufacturers may not always (Illegible Words) properly in such an arrangement because of non-specific dimensional requirements of SAE J571 for the headlamp back envelope. Also in this arrangement pressure is applied to areas of the headlamp not designed for such mechanical pressures. This may result in a high incidence of lamp breakage particularly with some of the "thin walled" lamps. Question 2 - January 27, 1972 The arrangement of the headlamp mounting ring as shown on Figure 3. conforms to the requirements of Federal Motor Vehicle Safety Standard No. 108. Question 3 - January 27, 1972 The arrangement of the headlamp mounting ring as shown on Figure 4 conforms to the requirements of Federal Motor Vehicle Safety Standard No. 108. Question 4 - January 27, 1972 The arrangement of the headlamp mounting ring as shown on Figure 5 conforms to the requirements of Federal Motor Vehicle Safety Standard No. 108. Your letter of February 8, 1972, relates to the request of January 27 1972, and is therefore answered by the above comments. The question in your letter of February 9, 1972, relates to a modification of the headlamp (Illegible Words) as described under question 1 in your letter of January 27, 1972, whereby you propose a single locating lug match in the headlamp retaining ring. The requirements of Federal Motor Vehicle Safety Standard No. 108 are for three-lug indexing. The retaining ring-housing as shown on Appendix - I of your letter of February 9, 1972, does not, therefore, conform to Federal Motor Vehicle Safety Standard No. 108. This Administration has been concerned about problems of accurate headlamp aim and aim retention capabilities, and currently has a research contract titled "Stability of Headlamp Aim" contract DOT-HS-024-1-202 scheduled for completion in July 1972. In general one of the problem areas seems to relate to insufficient strength and life of headlamp aim and retention mechanisms, along with (Illegible Word) that cause field service problems by shifting or actually falling out when replacement of the headlamp is attempted. If you desire, you may contact Mr. Roger Benion of the Southeast Research Institute, (Illegible Words) Road, San Antonio, Texas, 73284, who manages our stability of headlamp Aid contract, for additional technical contracts on your proposed headlamp aiming mechanism. We have enclosed a copy of report DOT-HS-(Illegible Words) on "Vehicle Forward Lighting Performance and Inspection Requirements" which includes preliminary research information on headlamp aim. |
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.