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: aiam4342OpenMs. Dianne Black, Engineering Manager, Legislation, Compliance, and Product Development, Jaguar Cars, Inc., 600 Willow Tree Road, Leonia, NJ 07650; Ms. Dianne Black Engineering Manager Legislation Compliance and Product Development Jaguar Cars Inc. 600 Willow Tree Road Leonia NJ 07650; Dear Ms. Black: Your letter to Barry Felrice concerning Federal Motor Vehicle Safet Standard No. 114 has been referred to me for response. This response is based on your letter, and a telephone conversation of March 17, 1987, between Mr. Edward Stumpkey of Jaguar and Mr. Kenneth Rutland of this agency clarifying certain matters raised in your letter. I regret the delay in this response.; Standard 114, *Theft Protection, requires that each vehicle subject t it must have a key-locking system which must prevent not only normal engine activation, but also either steering or forward self-mobility or both when the key is removed.; You mention a system intended to meet the standard, but indicate tha 'for security reasons,' you are reluctant to supply specific details on that system. Without reference to specific data, you state that your system meets paragraph S4.2(a) of Standard 114, that is, removing the key from the ignition prevents normal engine activation.; You go on to say that the microprocessing systems that control vehicl operations will not function when the driver removes the ignition key. Therefore, you state, you meet one of the conditions in S4.2(b) of the Standard, that is , removing the key must prevent forward self-mobility of the vehicle.; Based on the information you supplied, NHTSA can not agree that you key- locking system meets either requirement of S4.2(b). As I understand your description of Jaguar's system, deactivating the engine is the means by which you assert you prevent vehicle forward self-mobility. If a manufacturer could comply with the S4.2(b) with respect of preventing forward self-mobility by preventing normal engine activation under S4.2(a), S4.2(b) would be redundant. Paragraph S4.2(b) requires an added safeguard with respect to forward self-mobility, such as a transmission lock or other means, to prevent a vehicle from moving under its own power should the engine somehow be activated without inserting the key.; Therefore, preventing normal engine activation under S4.2(a) will no meet the condition in S4.2(b) of preventing vehicle forward self-mobility. If Jaguar has some means other than deactivating the engine to prevent forward self-mobility, its system may be acceptable. Otherwise, Jaguar must add some means to meet at least one of the conditions in S4.2(b).; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3487OpenMr. Roy Knoedler, Cosco, 2525 State Street, Columbus, IN 47201; Mr. Roy Knoedler Cosco 2525 State Street Columbus IN 47201; Dear Mr. Knoedler: This responds to your letter concerning the application of Standard No 213, *Child Restraint Systems*, to a booster seat that uses a vehicle lap belt or lap/shoulder belt to restrain a child weighing 20 or more pounds. The following discussion answers your questions concerning the application of specific sections of the standard to a booster seat.; Section 4 of the standard defines a 'child restraint system' as 'an device, except Type I or Type II seat belts, designed for use in a motor vehicle to restrain, seat, or position children who weigh not more than 50 pounds.' Since the booster seat you described would be used to seat a child weighing less than 50 pounds in a vehicle, it is a child restraint system and thus must meet the requirements of the standard. The vehicle lap belt (Type I belt) or lap/shoulder belt (Type II belt) used with the system are specifically excluded by the definition of child restraint system and thus are not covered by the requirements of the standard.; You said that the booster seat would have no sides, back or fixed o movable surface directly in front of the child and asked how the standard would apply to such a design. The standard does not require a child restraint to have a back, sides or fixed or movable surface in front of the child. If such surfaces are provided, however, they must comply with the applicable requirements of sections 5.2.2, 5.2.3, and 5.2.4.; Each child restraint is required to meet the minimum head suppor surface requirements of S5.2.1. Section 5.2.1.2, however, exempts forward-facing child restraint (sic) from the minimum head support surface requirement if, 'the target point on either side of the dummy's head is below a horizontal plane tangent to the top of the standard seat assembly when the dummy is positioned in the system and the system is installed on the assembly in accordance with S6.1.2.' Thus, unless your design is within the exception of S5.2.1.2, it would have to comply with the minimum head support requirements of S5.2.1.1. Any head support surface would also have to comply with the applicable requirements of S5.2.3. and S5.2.4.; You asked about the application of S5.4.3.2 to a booster seat. Sectio 5.4.3.2 provides that:; >>>Each belt *that is a part of a child restraint system* and that i designed to restrain a child using the system and to attach the system to the vehicle shall, when tested in accordance with S6.1, impose no loads on the child that result from the mass of the system or the mass of the seat back of the standard seat assembly specified in S7.3. (Emphasis added.); <<>>(c) In the case of each seating system recommended for children ove 20 pounds, crotch restraint in the form of:; (i) a crotch strap connectable to the lap belt or other device used t restrain the lower torso, or; (ii) a fixed or movable surface that complies with S5.2.2.1(c).<<< The purpose of subsection (c) is to require a belt or surface desig that will prevent the child from submarining under the lap belt (i.e., sliding down and forward under the belt). Thus, if a crotch belt is not provided, the surface of the restraint must be designed to prevent submarining and comply with S5.2.2.1(c). For example, the seating surface of the restrain could be designed to prevent submarining.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1140OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45222; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45222; Dear Mr. Pieratt: In your letter of May 14, 1973, you present the fact situation of a equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer 'that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108.'; There is no Federal requirement that an equipment manufacturer in thi fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5103OpenMr. Kenneth W. Webster II Project Engineer Transportation Research Center Inc. East Liberty, OH 43319-0367; Mr. Kenneth W. Webster II Project Engineer Transportation Research Center Inc. East Liberty OH 43319-0367; "Dear Mr. Webster: This responds to your letter of October 26, 1992 seeking an interpretation of Standard No. 124, Accelerator Control Systems (49 CFR 571.124). More specifically, your letter requested clarification of the correct test procedure for S5 of Standard No. 124 under a specific condition. By way of background information, under the National Traffic and Motor Vehicle Safety Act, each manufacturer is responsible for certifying that its vehicles or products meet all applicable safety standards. Manufacturers must have some basis for their certification that a vehicle or product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. Section S5 of Standard No. 124 requires vehicles to comply with certain requirements 'when the engine is running under any load condition, and at any ambient temperature between -40 F. and +125 F. after 12 hours of conditioning at any temperature within that range.' (Emphasis added.) For purposes of the safety standards, the term any 'means generally the totality of the items or values, any one of which may be selected by the Administration for testing.' (49 CFR 571.4) Therefore, vehicles must meet Standard No. 124's requirements at all temperatures within the specified range. Your letter states that some vehicles are impossible to start after conditioning for 12 hours at -40 F. You asked which of the following procedures would be correct when testing a vehicle which will not start: Alternative (1): Test with engine not running at the -40 F. test condition. Alternative (2): Raise temperature until engine will start. Record test temperature and perform test. In conducting a compliance test, NHTSA would follow the procedures set forth in Standard No. 124. The agency would not follow the Alternative (1) test procedure since the standard specifies requirements that must be met 'when the engine is running.' The agency could conduct a compliance test at any temperature or temperatures within the specified -40 F. to +125 F. range. I note that S5.3 specifies that the performance requirement for maximum time to return to idle position varies depending on whether the vehicle is 'exposed to ambient air at 0 F to - 40 F. during the test or for any portion of the 12-hour conditioning period.' This language makes it clear that the ambient air does not need to be held at a single temperature during the conditioning period or during the test. If NHTSA chose to conduct a compliance test at -40 F. and the vehicle would not start because of the extreme cold, the agency would most likely either use a standard engine heater to assist in starting the vehicle or warm the entire vehicle to a temperature where it would start. I note, however, that if the agency did warm the vehicle to assist in starting, it might lower the temperature back down to -40 for purposes of conducting the test. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam0301OpenMr. Quentin H. McDonald, President, The Bobby-Mac Company, Inc., Post Office Box 209, Scarsdale, NY 10538; Mr. Quentin H. McDonald President The Bobby-Mac Company Inc. Post Office Box 209 Scarsdale NY 10538; Dear Mr. McDonald: This is in reply to your letter of February 4, 1971, in which yo submitted for our review a draft of a label that you intend to use on your Bobby-Mac baby chair in accordance with paragraph S4.1 of Motor Vehicle Safety Standard No. 213. We have restated the parts of your label whose compliance with the requirements of S4.1 is questionable, followed by our comments.; >>>1. 'In each position, reclining to upright, Bobby-Mac exceed Federal Motor Vehicle Safety Standard No. 213 requirements for child seating systems.'<<<; We assume that you intend this statement to be your certification pursuant to Section 114 of the National Traffic and Motor Vehicle Safety Act, that the Bobby-Mac seat complies with Standard No. 213. While certification is not required to be placed on the label by S4.1, placing it there is not inconsistent with either Section 114 of the Act of Standard No. 213. However, we do not consider the statement you have used to be an adequate certification statement. This is because when read literally, the statement deals only with the static force requirements of the standard, as the other requirements, such as those for labeling (S4.1), providing instructions (S4.2), adjustments (S4.3), and others, are neither concerned with the 'position' of the child seat nor can they be 'exceeded.' You must certify compliance with all the requirements of the standard, and your statement should be changed accordingly. Should you wish to use it, the following statement, for child seats manufactured on or after April 1, 1971, would be satisfactory: 'This child seating system conforms to all Federal motor vehicle safety standards applicable to it on the date of manufacture shown below.'; >>>2. 'Bobby-Mac can only be used in cars with standard auto seat bel which must be used to secure Bobby-Mac safely on front or rear auto seat. In vehicles with seats more elevated from floor than usual passenger auto, thereby not permitting sufficient length in auto seat belt to loop around Bobby-Mac, or if for any reason auto seat belt is short, auto dealer or auto belt manufacturer can supply belt lengthener.'<<<; You have apparently placed this statement on the label to comply wit paragraph S4.1(e) of the standard which requires a statement describing in general terms the types of vehicles and designated seating positions in those vehicles in which the system is recommended or not recommended for use. It is your responsibility under the requirement to make certain that the types of vehicles you recommend have seat belts that are long enough to use the Bobby-Mac as recommended. You have stated that the Bobby-Mac can be used with a standard auto seat belt, but you have also indicated that there are types of vehicles or belt conditions with which the Bobby-Mac should not be used without some modification. We believe that your exceptions should be stated more objectively, such as prescribing the minimum belt loop length above the seat cushion that is required, so that a consumer can more accurately determine whether you are recommending the Bobby-Mac for use in his vehicle.; With reference to your recommendation concerning seat belt lengthener if these lengtheners are not available by April 1, 1971, your label would not comply with the requirement. If they are available your label should describe them in sufficient detail, such as by part number, so that consumers will know precisely what they must obtain in order to properly install the Bobby-Mac seat. Your seat would be required to meet the force requirements of the standard when tested in the vehicles in which you recommend it for use and using any of the seat belt modifiers that you recommend for use with it.; >>>3. 'When Bobby-Mac is used for older, taller youngster, it must b used on auto seat whose seat back or head restraint extends at least 6 inches above top of Bobby-Mac seat bucket.'<<<; In this case, you indicate that a child of a certain height must b placed at only certain seating positions. In order to provide consumers with some objective criteria by which they can determine whether Bobby-Mac is appropriate for their vehicles, the minimum height of the child that needs the additional head restraint protection should be provided, rather than describing him as merely 'older' or 'taller.' In addition, it would be preferable if you specified the total seat back height above the seat cushion that is necessary for the children you have in mind, rather than indicating this measurement as the distance from the top of the child seat bucket. The information would be more useful to consumers, as it would allow them to determine the appropriateness of the Bobby-Mac without first obtaining one.; >>>4. Finally, based upon the photographs submitted with your letter the Bobby-Mac seat does not appear to be a rearward-facing child seat. If this is the case, the statement, 'For use only on forward-facing vehicle seats,' as required by S4.1(g), must be included on the label.<<<; Please write if you have further questions. Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2296OpenMr. James E. Harris, President, Willamette Wheel Inc., 1235 S.E. Grand, Portland, OR 97214; Mr. James E. Harris President Willamette Wheel Inc. 1235 S.E. Grand Portland OR 97214; Dear Mr. Harris: I am writing in response to your April 21, 1976, telephone conversatio with Mark Schwimmer of this office, concerning the modification work that you perform on previously certified Datsun pickup trucks, which consists of converting them from two-wheel- to four-wheel-drive vehicles.; As indicated in the October 30, 1975, letter from Richard B. Dyson t you, you are a vehicle alterer who is subject to the requirements of 49 CFR 567.7. That section requires that you affix a label to the vehicle stating that, *as altered*, the vehicle conforms to applicable Federal motor vehicle safety standards.; The Federal government does not certify or otherwise issue advanc approval of motor vehicles. As Mr. Schwimmer explained, the statement on the label constitutes your certification of conformity. If you fail to provide this certification, or if in the exercise of due care you have reason to know that it is false or misleading, you are subject to civil penalties under the National Traffic and Motor Vehicle Safety Act of 1966, as amended.; All altered vehicles must comply fully with all applicable safet standards. Therefore, as Mr. Schwimmer further explained, you would not be relieved of the requirements of S567.7 simply by virtue of the fact that, as altered, the vehicle complied fully with the standards. You would be relieved of the requirements only if both of the following conditions were met:; >>>(i) the alteration is performed solely by the addition substitution, or removal of readily attachable components such as tire and rim assemblies, or by minor finishing operations such as painting, and; (ii) the stated weight ratings of the vehicle are still valid.<<< Because the conversion of the vehicles in question does not meet th first condition, you are subject to the requirements of S 567.7. Please note further that, if your modifications affect the validity of the weight ratings assigned to the vehicles by Datsun, your label must show valid, modified ratings.; An information sheet entitled 'Where to Obtain Federal Motor Vehicl Safety Standards and Regulations' is enclosed for your convenience.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam5553OpenMr. Stuart Sacks Tradepro, Inc. 7350 N.W. 35th Street Miami, FL 33122; Mr. Stuart Sacks Tradepro Inc. 7350 N.W. 35th Street Miami FL 33122; "Dear Mr. Sacks: This responds to your letter to Mr. Philip Recht, ou former Chief Counsel, in which you stated that you are considering importing tires from the Hangzhou General Rubber Factory, which has been assigned NHTSA manufacturer identification number 7D. You stated that the tires do not display the 'molded D.O.T. code numbers,' and that Federal motor vehicle safety standard (FMVSS) No. 119, New pneumatic tires for motor vehicles other than passenger cars (49 CFR 571.119), 'clearly does not require DOT code numbers for non-passenger tires.' Your reading of FMVSS No. 119 is not correct. I assume from your letter that you are considering importing only non-passenger car tires. This letter, then, will address only the labeling requirements for non-passenger car tires under FMVSS No. 119 and 49 CFR 574. I further assume that by 'DOT code numbers' you mean the tire identification number (TIN) required by 49 CFR 574.5. 49 U.S. Code 30112 provides that no person may sell in or import into the United States any new motor vehicle or new item of motor vehicle equipment that does not comply with all applicable FMVSSs. With respect to non-passenger car tires, which are items of motor vehicle equipment, section S6.5 of FMVSS No. 119 requires specific items of information to be marked on the tire sidewalls. Those markings must be no less than 0.078 inch high and must be 'raised above or sunk below the tire surface' a specified distance. Among other things, the markings must include the TIN (S6.5(b)). Paragraph S6.5(b) of FMVSS No. 119 requires the TIN to comply with part 574. Part 574.5 requires that the TIN be permanently molded into or onto tire sidewalls as specified in Figure 1 of Part 574, and specifies what information the TIN must contain. The TIN can be branded into or onto the sidewalls of retreaded tires after the fact, but not new tires. On new tires, the TIN must be molded into or onto the tire sidewalls by the original manufacturer. I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1843OpenHonorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5-mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety- related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0751OpenMr. Barry Kulik, 114 West 30th Street, New York, NY 10001; Mr. Barry Kulik 114 West 30th Street New York NY 10001; Dear Mr. Kulik: This is in reply to your letter of May 14, 1972, to Mr. Armstron asking whether combination turn signal and hazard warning signal flashers conforming to Federal requirements effective January 1, 1973, may be installed in vehicles manufactured before that date.; The answer is yes. Motor Vehicle Safety Standard No. 108 was amended o December 28, 1971 to allow use of flashers manufactured to conform with Standard No. 108a. I enclose a copy of the amendment for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0546OpenMr. H. H. Damman, Marketing Administration Manager, Manitowoc Engineering Company, 500 South 16th Street, P. O. Box 70, Manitowoc, WI 54220; Mr. H. H. Damman Marketing Administration Manager Manitowoc Engineering Company 500 South 16th Street P. O. Box 70 Manitowoc WI 54220; Dear Mr. Damman: I apologize for the delay in answering your letter regarding Part 566 Manufacturer Identification and Part 567, Certification. You describe the machines you manufacture and ask whether you are a final-stage manufacturer within the meaning of the regulation and therefore required to submit information regarding your products.; Part 566 and 567 apply to manufacturers of motor vehicles and moto vehicle equipment to which a motor vehicle safety standard applies. 'Motor vehicle' is defined in the National Traffic and Motor Vehicle Safety Act as 'any vehicle driven or drawn by mechanical power for use on the public streets, roads, and highways. ; Since the truck cranes you describe appear from the information yo provide us to have a primary purpose of transporting the cranes on public highways, you are considered a manufacturer of motor vehicles and thus you are covered by Parts 566 and 567. Because you 'mount the crane upperworks and outrigger assemblies to the carrier' you are a final-stage manufacturer as defined in Part 568, Vehicles Manufactured in Two or More Stages, and are required to submit information to us under these regulations. As a manufacturer of motor vehicles you are also required to submit information under Part 573, Defect Reports.; I enclose copies of Parts 566, 567, 568, and 573 for your reference. have also attached a description of Government Printing Office documents services which cover NHTSA rulemaking developments.; Sincerely, Richard B. Dyson, Assistant 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.