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 |
|---|---|
| search results table | |
ID: aiam3793OpenMr. J. N. White, 1300 California Drive, Rolla, MO 65401; Mr. J. N. White 1300 California Drive Rolla MO 65401; Dear Mr. White: This is in response to your January 3, 1984, letter to Roger Fairchil of this office regarding Federal Motor Vehicle Safety Standard No. 111 (Rearview Mirror Systems). You have requested information on the applicability of that standard, particularly in regard to aftermarket mirrors.; FMVSS 111 is a rule or regulation (the terms are generally use interchangeably) establishing requirements for rearview mirrors on new passenger cars, multipurpose passenger vehicles, trucks, buses, school buses, and motorcycles. Aftermarket mirror manufacturers do not have to certify compliance with our standards. However, the addition of an aftermarket mirror to a motor vehicle may be subject to certain legal requirements. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibits any manufacturer, distributor, or dealer of motor vehicles or motor vehicle equipment, or any motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on a vehicle in compliance with a safety standard. Thus, manufacturers, distributors, dealers, and repair businesses cannot remove a rearview mirror installed as original equipment in compliance with our standard and replace that mirror with a noncomplying aftermarket mirror. Replacement by other individuals or organizations or replacement with a complying aftermarket mirror would be permitted.; With regard to your final question as to requirements applicable to th use of non-glare glass in mirrors, this agency issued on November 6, 1978, a notice of proposed rulemaking on possible upgrading of rearview mirror requirements (copy enclosed). One part of this proposal would establish image luminance criteria for rearview mirrors. The agency has not yet determined whether this requirement should be implemented, and no action is imminent on that proposal.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam4056OpenG. F. Kirchoff, Special Project Manager, Morton Thiokol, Inc., 3350 Airport Road, Ogden, UT 84405; G. F. Kirchoff Special Project Manager Morton Thiokol Inc. 3350 Airport Road Ogden UT 84405; Dear Mr. Kirchoff: Thank you for your letter of November 13, 1985, to Stephen Oesch of m staff asking how our standards would affect a diagnostic and sensor warning light for a self-contained airbag system you are developing. You explained that the system would be mounted in the steering wheel and would have the diagnostic and sensor light located on the steering wheel horn pad.; Your warning light would be affected by Safety Standard No. 208 *Occupant Crash Protection*. S4.5.2 of the standard requires crash-deployed restraint systems, such as airbag systems, to have an indicator that monitors the readiness of the system. In addition, the indicator must be clearly visible from the driver's seat. Placing your diagnostic and sensor warning light in the center of the horn pad should ensure that it is visible to the driver.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam0916OpenMr. D. R. Pomeroy, Chief Chemist, Textile Rubber & Chemical Company, 14241 East Alondra Boulevard, La Mirada, CA, 90638; Mr. D. R. Pomeroy Chief Chemist Textile Rubber & Chemical Company 14241 East Alondra Boulevard La Mirada CA 90638; Dear Mr. Pomeroy: This is in response to your letter of November 3, 1972, to our Regiona Administrator, Region IX, San Francisco, California office concerning the test procedures of Federal Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.'; You state that in the test procedure described in paragraph S5.3, yo see 'no room for the bunsen burner to stand' when a carpet specimen 14 inches long is in the center 'of all inside dimensions of the box.' The source of your interpretive difficulty with respect to the test procedure appears to be your assumption that the carpet specimen should be placed in the center 'of all inside dimensions' of the test cabinet. The test procedure only specifies that the specimen be mounted 'in a horizontal position, in the center of the cabinet.'; The standard does not specify a particular means for positioning th bunsen burner tube or for positioning the test specimen above the top of the burner tube, because there are a variety of satisfactory means used for this purpose. The specimen holder should be in the center of the cabinet with the closed end contacting the end of the cabinet.; Since the bunsen burner is used with the air inlet shutoff, it is i effect a 3/8 inch inside diameter tube with a metering valve. There is no reason why such a device, without the bunsen burner base, may not be permanently mounted inside the cabinet for convenience.; You also ask whether bottled propane gas can be substituted for natura gas. The answer to this question is that your choice of what gas to use is a matter within your own discretion. The standard simply specifies that for our compliance testing, the gas supplied to the burner will have 'a flame temperature equivalent to that of natural gas.'; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
|
ID: aiam3639OpenMr. Bruce Henderson, Automobile Importers of America, Inc., 1735 Jefferson Davis Highway, Suite 1002, Arlington, VA 22202; Mr. Bruce Henderson Automobile Importers of America Inc. 1735 Jefferson Davis Highway Suite 1002 Arlington VA 22202; Dear Mr. Henderson: This responds to your letter asking about the identificatio requirements of FMVSS 101, *Controls and Displays*. You asked whether it is permissible for a manufacturer to identify a certain manual control with the symbol specified by the European Economic Community (EEC) for the cold start control. According to your letter, the control resets injection timing *and* actuates cylinder warming.; By way of background information, the agency does not provide approval of motor vehicles or motor vehicle equipment. The Vehicle Safety Act requires that each manufacturer assure that its products are in compliance with all applicable standards. The following only represents the agency's opinion based on the specific facts provided in your letter.; The answer to your question is yes, since Standard No. 101 does no include any identification requirements applicable to that specific type of control.; Section S5 of Standard No. 101 requires each passenger car manufacture with any control listed in S5.1 or in column 1 of Table I to meet the requirements of the standard for the location, identification and illumination of such control.; Neither section S5.1 nor column 1 of Table I list or include a singl control which operates the *two* functions noted above.; Since Standard No. 101 does not include any identification requirement applicable to that type of control, identification is at the discretion of the manufacturer. It is therefore permissible, under that standard, to identify that type of control with the symbol specified by the EEC.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam1604OpenMr. Harry L. Cuthbert, Chief Engineer, Eagle International Inc., P.O. Box 4119, 2045 Billy Mitchell Blvd., Brownsville, TX 78520; Mr. Harry L. Cuthbert Chief Engineer Eagle International Inc. P.O. Box 4119 2045 Billy Mitchell Blvd. Brownsville TX 78520; Dear Mr. Cuthbert: This responds to your July 16, 1974, request for approval of the Bendi 'dual circuit air brake system' for use on your buses in satisfaction of Standard No. 121, *Air brake systems.* In a subsequent phone call with Mr. Herlihy of this office, you stated that your only concern was whether the standard requires a parking brake system that meets the axle-by axle retardation force requirements of S5.6.1 and the grade holding requirements of S5.6.2.; The National Highway Traffic Safety Administration is unable t 'approve' plans or prototype systems for compliance with a standard in advance, because there is no way to establish that a vehicle so equipped actually meets the requirements until it has been manufactured.; With regard to your specific question, S5.6 states that each vehicl shall have a parking brake system that meets the requirements of S5.6.1 or S5.6.2 at the manufacturer's option. This means that you are free to choose a system which meets either of these requirements but does not meet both.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
|
ID: aiam4406OpenMr. Barry Patterson, President, Patterson Incorporated, 1920 Springfield Road, Kelowna, B.C. V1Y 7R8; Mr. Barry Patterson President Patterson Incorporated 1920 Springfield Road Kelowna B.C. V1Y 7R8; Dear Mr. Patterson: This is in reply to your letter of September 21, 1987, asking for ou 'acceptance and recommendation' of a safety device endorsed' by the government of the Province of Saskatchewan. This device automatically activates parking lamps, and the lower beams of headlamps 'with the touch of the Brake Pedal'.; The National Highway Traffic Safety Administration has no authority t accept, recommend, or endorse any item of motor vehicle equipment. We can, however, discuss the relationship of your device to U.S. Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, and the National Traffic and Motor Vehicle Safety Act ('the Act') under which the standard was issued. This standard applies to the manufacture and sale of new motor vehicles. A device such as yours is permissible as original vehicle equipment as long as it does not impair the effectiveness of lighting equipment required by Standard No. 108. There is no indication in your descriptive literature that the effectiveness of parking lamps, headlamps, or the stop lamps would be impaired by the installation and operation of your device.; With respect to sale in the aftermarket for vehicles in use, you device is not prohibited under the Act if its installation by a person other than the vehicle owner does not render inoperative in whole or in part any lamps installed to comply with Standard No. 108. We see no indication that this would occur. However, such an installer should be aware of the wiring requirement in Standard No. 108 that taillamps, parking lamps, side marker lamps, and the license plate lamp shall be activated when the headlamps are on.; The rules for operation of vehicles in use are established by th individual States, and several of these may have restrictions on the use of headlamps during daylight hours. For further information on this subject you should write the American Association of Motor Vehicle Administrators, 1201 Connecticut Ave., N.W., Washington, D.C. 20036.; This agency has proposed that motor vehicles be equipped with daytim running lights, in a manner similar, though not identical, to the new requirement of the Canadian Ministry of Transport. If this proposal is adopted, the Act would prohibit any State from having a different standard than the Federal one. As of the effective date of such an amendment to Standard No. 108 daytime operation of frontal lighting should be permissible in all States.; If you have any further questions we will be pleased to answer them. Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam4369OpenKarl-Heinz Faber, Vice President, Product Compliance and Service, Mercedes-Benz of North America, Inc., P.O. Box 350, Montvale, NJ 07645; Karl-Heinz Faber Vice President Product Compliance and Service Mercedes-Benz of North America Inc. P.O. Box 350 Montvale NJ 07645; Dear Mr. Faber: Thank you for your letter of April 16, 1987, concerning th requirements of Standard No. 208, *Occupant Crash Protection*. In particular, you asked for an interpretation of the requirements of S4.5.1 of the standard. I hope that the following discussion answers your question.; S4.5.1 of Standard No. 208 provides that each vehicle with a cras deployed occupant protection system must have a label setting out a manufacturer's recommended schedule for the maintenance or replacement needed to keep the performance of the occupant protection system at the level required by the standard. S4.5.1 further provides that 'the label shall be permanently affixed to the vehicle within the passenger compartment.' You explained that at the present time, you place the label for your air bag system on the glove box door. You further explained that you place all other important safety-related information, such as the certification label and tire information placard, on the latch post for the driver's door.; You stated that you want to relocate the air bag label from the glov box door to the latch post on the driver's side. You explained that one of the benefits of the new location is that it will establish a common location for the operator to quickly find important information. You said that the new location should remind vehicle operators of the replacement schedule since the tire pressure placard, which is routinely reviewed by the vehicle operator, is in the same location. Finally, you noted that dealership service personnel will be alerted to the replacement schedule since 'it is common practice for Service Writers to copy down the VIN from the certification label on the driver door latch post.'; NHTSA agrees that a label placed on the driver's latch post would mee the requirements of S4.5.1. The purpose of the location requirement is to place the replacement and maintenance schedule in a location that can be easily observed by the vehicle owner. Thus, the standard requires the label to be within the occupant compartment of the vehicle. The agency considers a label placed on the latch post, which is inside the exterior surface of the vehicle and is a part of the physical structure that constitutes occupant compartment, as meeting the location requirement. As you pointed out in your letter, the latch post is already used as a location for other important safety-related information about the vehicle.; If you have any further questions on this standard or need additiona information, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel |
|
ID: aiam1491OpenMr. Keigo Ohgiya, Executive Director, The Japan Automobile Tire Manufacturers' Association, Inc., 9th Floor, Toranomon Building, No. 15, Shiba Toranomon, Minato-Ku, Tokyo, Japan; Mr. Keigo Ohgiya Executive Director The Japan Automobile Tire Manufacturers' Association Inc. 9th Floor Toranomon Building No. 15 Shiba Toranomon Minato-Ku Tokyo Japan; Dear Mr. Ohgiya: This responds to your April 22, 1974, petition to permit the use of th DOT symbol on tires to which no standard applies.; The provisions appearing in the April 3, 1974, *Federal Register* (3 FR 12104) are amendments to the standard, and your submission is in effect a petition for reconsideration of these changes.; Our reasons for prohibiting the use of the DOT symbol on ties to whic no motor vehicle safety standard is applicable are listed in notice 7. We have found the expense of covering the label to be justified, to avoid confusio in the symbols's meaning and the concept of compliance. We have determined that means are available to securely cover the DOT symbol, or in the alternative, to remove it after the molding process.; For these reasons, your petition is denied. Sincerely, James B. Gregory, Administrator |
|
ID: aiam3156OpenHonorable S. I. Hayakawa, United States Senate, Washington, DC 20510; Honorable S. I. Hayakawa United States Senate Washington DC 20510; Dear Senator Hayakawa: This responds to your October 25, 1979, letter enclosing correspondenc from your constituent Mr. Morrill N. Farr asking about the agency's air brake standard. Mr. Farr also asked about the highway use tax. We understand that the Federal Highway Administration will respond to you directly with an answer to that question.; With respect to the air brake standard, Mr. Farr asked whether th Government would reimburse him for a portion of the costs of installing the no lockup portion of his air brake system. Mr. Farr stated that a court has held the no lockup requirement of the air brake standard invalid, and accordingly, the Government should reimburse vehicle owners for the installation of no lockup systems that have been proven to be faulty.; The court in *PACCAR v. The National Highway Traffic Safet Administration*, 573 F.2d 632 (9th Cir. 1978) *cert. den'd* 439 U.S. 862 (October 2, 1978), stated that the no lockup portions of the standard were invalid because some of the systems constructed in accordance with the requirements were unreliable. The court also indicated that a proper no lockup device could substantially improve the safety of vehicles. Our air brake standard does not specify a particular design or construction of brake system. It is a performance standard, and manufacturers are free to choose any design or construction that complies with the performance requirements. The fact that some manufacturers chose faulty systems is unfortunate. If the system on Mr. Farr's truck is faulty, his remedy lies with the manufacturers of the truck and the system, not with the Government.; This agency has attempted over the past several years to address th problem of faulty systems by initiating several investigations under the statutory provisions requiring manufacturers to recall and remedy defective vehicles and equipment. Those investigations contributed to the decisions of a number of manufacturers to conduct recalls.; Sincerely, Frank Berndt, Chief Counsel |
|
ID: aiam4693OpenRoger C. Fairchild, Esq. Shutler and Low 14500 Avion Parkway Suite 300 Chantilly, VA 22021-1101; Roger C. Fairchild Esq. Shutler and Low 14500 Avion Parkway Suite 300 Chantilly VA 22021-1101; "Dear Mr. Fairchild: This responds to your request for my opinion o whether a particular vehicle (the Pinzgauer) would be considered a 'motor vehicle' for the purposes of the National Traffic and Motor Vehicle Safety Act. When NHTSA previously considered this question, we stated in a March 25, 1982 letter to Mr. Leonard Fink that the Pinzgauer would be considered to be a motor vehicle, based on the information that was available to the agency at that time. However, that letter also stated that the agency would be willing to reconsider this conclusion if additional information were provided regarding the vehicle's marketing, advertising, and actual use. Your recent letter set forth three additional factors that you suggested might lead the agency to change its previous conclusion that the Pinzgauer was a motor vehicle. As explained in detail below, this agency reaffirms the previous conclusion that the Pinzgauer appears to be a motor vehicle. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. NHTSA has interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., airport runway vehicles and underground mining devices) are not considered motor vehicles, even though they may be operationally capable of highway travel. Vehicles that have an abnormal body configuration that readily distinguishes them from other highway vehicles and a maximum speed of 20 miles per hour (mph) are not considered motor vehicles, because their use of the public roads is intermittent and incidental to their primary intended off-road use. On the other hand, vehicles that use the public highways on a necessary and recurring basis are motor vehicles. For instance, a utility vehicle like the Jeep is plainly a motor vehicle, even though it is equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, then NHTSA has interpreted the vehicle to be a 'motor vehicle'. Further, the agency has determined that a vehicle such as a dune buggy is a motor vehicle if it is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, regardless of the manufacturer's stated intent regarding the terrain on which the vehicle is to be operated. Vehicles such as the Pinzgauer are not easily classified under either of these groupings. On the one hand, the Pinzgauer is obviously designed to have substantial off-road capabilities, as evidenced by high ground clearance, deep water fording capabilities, and all-wheel drive. According to its manufacturer, 95 percent of the annual production of Pinzgauers is purchased by armed forces worldwide. These factors suggest that the Pinzgauer should not be classified as a motor vehicle. On the other hand, the available information shows the Pinzgauer is suitable for use on-road. The vehicle has a top speed of nearly 70 miles per hour. Page 4 of Enclosure 1 of your letter shows that the Pinzgauer is equipped with turn signals and states that the power steering minimizes steering effort 'both in difficult terrain and when parking.' Page 4 of Enclosure 3 with your letter describes the serviceability of the Pinzgauer 'with ordinary on- and off-road usage.' These factors suggest that the vehicle is designed and intended to be routinely used on the public roads, which suggests that it should be classified as a motor vehicle. In instances where the agency is asked whether something is a motor vehicle, when the vehicle has both on-road and off-road operating capabilities, and about which there is little or no evidence about the extent of the vehicle's on-road use, NHTSA has applied five factors to reach its conclusion. These factors are: 1. Whether States or foreign countries have permitted or are likely to permit the vehicle to be registered for on-road use. 2. Whether the vehicle is or will be advertised for use on-road as well as off-road, or whether it is or will be advertised exclusively for off-road use. 3. Whether the vehicle's manufacturer or dealers will assist vehicle purchasers in obtaining certificates of origin or title documents to register the vehicle for on-road use. 4. Whether the vehicle is or will be sold by dealers also selling vehicles that are classified as motor vehicles. 5. Whether the vehicle has or will have affixed to it a warning label stating that the vehicle is not intended for use on the public roads. When NHTSA previously considered whether the Pinzgauer should be considered a motor vehicle, the available information regarding these factors showed that the manufacturer had equipped the vehicle with side marker lights, the manufacturer expected the vehicle to be used on-road, and that it would be sold by dealers that also sell vehicles that are clearly motor vehicles. In your letter, you enclosed some additional information and brochures from the manufacturer that show the manufacturer continues to expect Pinzgauers to be used both on- and off-road. Since the manufacturer does not now expect to sponsor the vehicle's sale in the U.S., no information is available on the anticipated dealers. The additional information enclosed with your letter did not specifically address any factors on which no information was previously available to NHTSA. Hence, the agency has no basis for changing its previous conclusion that the Pinzgauer appears to be a motor vehicle. You suggested three reasons that might lead the agency to reverse its previous conclusion. First, you suggested that the 6-wheeled version of the Pinzgauer has a unique body configuration which distinguishes it from typical, on-road vehicles and makes it particularly well suited to off-road use. You correctly noted that the agency's 1982 letter addressed both the 4-wheeled and 6-wheeled version of the Pinzgauer. However, for the purposes of this analysis, there is no attribute of the 6-wheeled version that would lead the agency to conclude that it should be classified differently than the 4-wheeled version of the Pinzgauer. Many vehicles that are clearly motor vehicles have 6 wheels. In all other respects, the 4- and 6-wheeled Pinzgauers have similar on-road capabilities, including a top speed of more than 65 miles per hour. Second, you suggested that NHTSA concluded that the Unimog is not a 'motor vehicle' in a February 7, 1984 letter, and that the Unimog and Pinzgauer are comparable vehicles. In the February 7, 1984 letter to Mr. Karl-Heinz Faber to which you refer, NHTSA stated that it had no basis for changing its previous conclusion that the Unimog was not a 'motor vehicle.' NHTSA also noted that this conclusion was based upon the assumptions that Unimog vehicles would continue to be marketed through dealers of farm machinery and heavy equipment and that Unimog vehicles would have a label affixed stating that the Unimog is not manufactured for highway use. In other words, the information available for Unimog (especially regarding factors number 4 and 5 above) was sufficient to lead the agency to conclude that it was not a motor vehicle, even though Unimogs are operationally capable of on-road use. By way of contrast, either no information is available for Pinzgauer vehicles regarding the five factors identified above or, if information is available for a factor, it suggests that the Pinzgauer should be treated as a motor vehicle. Since the Pinzgauer is operationally capable of on-road use, and there is no indication that the manufacturer does not intend for it to spend a substantial amount of time on-road, NHTSA reaffirms its previous statement that these vehicles appear to be 'motor vehicles,' within the meaning of the Safety Act. Third, you suggested that NHTSA's 1982 conclusion did not include a consideration of the primary design intent of the Pinzgauer for military purposes and the high percentage of its total sales to the military. NHTSA's 1982 conclusion and this reconsideration both are addressed only to the non-military versions of the Pinzgauer. The military versions of the Pinzgauer would not be subject to the safety standards if their sales satisfied 49 CFR 571.7(c). In both the 1982 and this examination of whether the non-military versions of the Pinzgauer are motor vehicles, the agency fully considered the substantial off-road capabilities of these vehicles. However, absent indications that the manufacturer does not intend the Pinzgauer to spend substantial periods of time on-road, NHTSA concluded in 1982, and reaffirms at this time, that the non-military versions of the Pinzgauer appear to be 'motor vehicles' within the meaning of the Safety Act. I hope this information is useful. If you have any further questions or need some additional information on this topic, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
|
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.