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
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ID: aiam3182OpenMr. Steven J. Kalies, Union Springs Central School District, Union Springs, NY 13160; Mr. Steven J. Kalies Union Springs Central School District Union Springs NY 13160; Dear Mr. Kalies: During our telephone conversation, I envisioned the device yo described being covered by our Federal Motor Vehicle Safety Standard (FMVSS) 209, Seat Belt Assemblies. By the description on the price sheet you enclosed in your letter of 1/8/80, I am now not too sure. This device may not be covered under our FMVSS 213, Child Restraint(sic); After a conversation with the NHTSA's Office of Chief Counsel, I a taking the liberty of forwarding your letter to them for their review and response. It would be helpful if a brochure or picture of this device could be sent to our Washington Office. If available, mail it to: NHTSA, Office of Chief Counsel (NOA-30), 400 7th Street, S.W., Washington, D.C. 20590, ATTN: Mr. Stephen L. Oesch.; Thank you for bringing this matter to our attention. Sincerely, Irving Rodness, Motor Vehicle Program Specialist |
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ID: aiam4647OpenI; I; Mr. Dan Trexler Specifications Engineer Thomas Built Buses, Inc. P.O Box 2450 High Point, NC 27261 Dear Mr. Trexler: This is in reply to your letter of May 8, l989, to the former Chief Counsel of this agency, Erika Jones. You have received requests 'to install a master electrical disconnect switch on many buses.' When the switch is turned to the 'off' position 'it renders inoperative the warning signals (to the driver) required by FMVSS l05, 121 and 217. It also inactivates the hazard warning flasher required by FMVSS 108.' You ask whether installation of the switch would constitute a noncompliance, or a 'safety related hazard.' if it is accessible to the seated driver, or if remotely located in the battery or engine compartment, without ready access to the driver. Although you have not explained the purpose of such a device, we understand that a battery disconnect switch of this nature is deemed desirable by many bus owners to prevent drains on the battery when the bus is at rest. When the switch is activated, the bus cannot be started and driven because electric power is not available. Under this circumstance we do not believe that the switch either creates a noncompliance with any of the standards listed, nor constitutes a safety related defect, regardless of its location. When the bus is in operation the warning systems of the standards are not affected. The possibility of inadvertent activation when the bus is in use does not constitute a defect in performance, construction, components, or materials such as to create a safety related defect. To forestall any possibility of inadvertent activation, however, you may find it preferable to locate the switch away from the driver. We understand that a purpose of this switch is to reduce the likelihood of fire after accidents in which there has been fuel spillage. In this circumstance, it is likely that the bus would be positioned either in the roadway or adjacent to it. Safety would be enhanced if the hazard warning signal power source were separate from the batteries inactivated by the disconnect switch, so that these warning lamps could continue to operate. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam4352OpenDr. Ernst, Hella KG Hueck & Co, Postfach 28 40, 4780 Lippstadt, GERMANY; Dr. Ernst Hella KG Hueck & Co Postfach 28 40 4780 Lippstadt GERMANY; Dear Dr Ernst: This is in reply to your letter of February 5, 1987, to Richard Va Iderstine of this agency's Office of Vehicle Safety Standards. You have asked for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to a new headlamp manufactured by Hella that BMW has installed on a new car which it introduced in the United States around April 1, 1987.; The headlamp is of the replaceable bulb type, and as you describe i consist of two additional parts: 'the housing, to which the cover lens is bonded by means of a two-component adhesive', and 'the optical module, consisting of the reflector and the convex lens, joined by the lens carrier....' In your words, 'The two parts are held together by three screws', and you believe that 'the two parts, firmly screwed together, are as effectively joined as would be the case if bonded'.; Paragraph S3 of Standard No. 108 defines a 'replaceable bulb headlamp in pertinent part as 'a headlamp comprising a bonded lens and reflector assembly....' In the Hella design, the lens and reflector assembly are not bonded, and thus the headlamp is not a 'replaceable bulb headlamp' that is permissible for use on motor vehicle sold and used in the United States. The intent of the definition is to ensure that the headlamp lens and reflector are an integral replaceable unit, since that is the only means to assure a mechanically aimable replaceable bulb headlamp which is capable of using any replacement standardized replaceable light source and meets the necessary photometric performance. The foundation of mechanical amiability is that the beam and aiming pad are manufactured to have a specific relationship. If this relationship is altered by replacement of the lens only, or of the reflector only, there is a high likelihood that the lamp may not meet minimum performance requirements when aimed mechanically.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3497OpenMr. Kenneth G. Moyer, 6400 Goldbranch Road, Columbia, SC 29206; Mr. Kenneth G. Moyer 6400 Goldbranch Road Columbia SC 29206; Dear Mr. Moyer: This is in reply to your letter of September 22, 1981, about you 'alert device which automatically turns on the stop lamps of the vehicle when the accelerator is released.' You wish our permission to install the device for experimentation and testing on other vehicles, as well as an interpretation of Federal Motor Vehicle Safety Standard No. 108 whether your device is allowable.; As you know, the agency has devoted considerable effort to improve rea braking signals, culminating in its proposal that passenger cars be equipped with a single high- mounted stop lamp on the centerline of the vehicle. The concept of a pre-brake application signal is a familiar one to us, but the agency has conducted no formal research with respect to it, and in view of its stop-lamp proposal, is unlikely to do so. The technical issues that we consider relevant to your concept are (1) whether most rear-end accidents are preceded by a 'panic' stop by the struck vehicle, (2) whether panic stops involve unique driver behavior that can be reliably discriminated from non-panic stop behavior and used to trigger a pre-braking signal, and (3) whether the resulting signal will automatically result in a decrease in the reaction time of following drivers that is equal to the early warning time it provides. We know of no scientifically acceptable data that support these critical assumptions. We are especially concerned that a high rate of 'false alarms' may lead to a decrease in the overall warning value of the stop lamp signal itself, i.e., the 'cry wolf' phenomenon. This could lead to a significant reduction in the effectiveness of any proposed system.; Paragraph 2.1 of SAE Standard J586d, *Stop Lamps*, September 1977 incorporated by reference in Standard No. 108, defines a stop lamp as one whose operation indicates 'the intention of the operator of a vehicle to stop or diminish speed by braking.'; Your device would activate the stop lamp under a condition indicatin an intent other than the above, which could impair the effectiveness of the stop lamps. We view any use of required lighting equipment for a purpose other than as defined, as an 'impairment' within the prohibition of paragraph S4.1.3 of Standard No. 108 if the device is installed as original equipment. If the device is sold in the aftermarket, our laws preclude modifications that 'render ineffective in whole or in part' required lighting equipment, if the modifications are performed by a person other than the vehicle owner. We would consider your system prohibited by this provision as well.; Noting your comment that the device may be used for testing on schoo buses, this means that there is no prohibition under the laws that we administer which would forbid a school district from installing your device on its fleet. Such a modification would be subject to laws of the jurisdiction in which the school bus is registered and operates.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1150OpenMr. Thomas Pieratt, Truck Equipment & Body Distributors Assoc., 602 Main Street, Cincinnati, OH 45202; Mr. Thomas Pieratt Truck Equipment & Body Distributors Assoc. 602 Main Street Cincinnati OH 45202; Dear Mr. Pieratt: This is in reply to your letter of May 11, 1973, in which you ask abou the certification responsibilities for consecutive manufacturers of certain multi-stage vehicles that are intended for use by utilities. The facts as you present them are that a chassis-cab is purchased by a customer and delivered to a utility distributor, who installs a sub-base and a digger-derrick. The truck is then sent to a body-builder who installs a body consisting essentially of storage compartments, which are used to carry personal tools. The compartments are installed to the floor installed by the utility distributor. The unit is then returned to the utility distributor, who installs clearance and other lamps, reflectors, and other accessories, and hooks up hydraulic lines. Smaller vehicles are described as being manufactured in essentially the same manner.; It appears to us that the manufacturing operations you have describe fit quite readily into the manufacturing categories established by Parts 567 and 568. The utility equipment distributor is an intermediate manufacturer, he performs manufacturing operations, but does not complete the vehicle, as further manufacturing operations, the installation of the body, are clearly contemplated for the vehicle to perform its intended function. The body-builder is the final-stage manufacturer. When he completes his work the vehicle is ready to perform its intended function, except for the addition of the lighting equipment and the other operations performed by the utility equipment distributor. These latter operations appear to involve 'readily- attachable components' and if so the party performing them would not be a final-stage manufacturer.; The certification requirements do not operate differently because, i the case you describe, the utility equipment distributor performs operations on the vehicle at two separate times (installing the derrick, and later the lighting). His responsibilities each time are governed by the operation he then performs. However, inasmuch as the utility distributor appears to perform much of the heavy manufacturing, and because he is also the last person to modify the vehicle, he may wish to assume the responsibility for certification under section 568.7(b), in order that he may affix his name as the manufacturer to the certification label.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4702OpenMr. Satoshi Nishibori Nissan Research & Development, Inc. 750 17th Street N.W., Suite 902 Washington, D.C. 20006; Mr. Satoshi Nishibori Nissan Research & Development Inc. 750 17th Street N.W. Suite 902 Washington D.C. 20006; "Dear Mr. Nishibori: This responds to your January 16, 1990 letter t Mr. Robert Hellmuth, the Director of this agency's Office of Vehicle Safety Compliance, seeking an interpretation of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars (49 CFR 571.120). Specifically, S5.1.2 of Standard No. 120 provides that when a passenger car tire is used on vehicles other than passenger cars, the tire's load rating shall be reduced by dividing it by 1.10 before calculating the sum of the load ratings of all of the original equipment tires on the vehicle. S5.3.2 through S5.3.5 establish requirements for certain information about the tires and rims to be labeled on the vehicle. S5.3.2 sets forth lettering size and format requirements for the labeling. S5.3.3 through S5.3.5 require the labeling to provide the following information: the 'size designation of tires....appropriate (as specified in S5.1.2) for the GAWR' be given on the label, the size and type designation of rims 'appropriate for those tires', and the 'cold inflation pressure for those tires'. Your question was whether the cold inflation pressure set forth on the label in response to S5.3.5 of Standard No. 120 must reflect the 1.1 reduction factor set forth in S5.1.2 for passenger car tires. You suggested in your letter, and in your January 18, 1990 meeting with agency staff, that S5.3.5 does not require the 1.1 reduction factor to be taken into account when determining the cold inflation pressure to be specified. Instead, you suggested that Standard No. 120 requires the vehicle manufacturer to specify an inflation pressure that is adequate to support the tire's share of the gross axle weight rating (GAWR), without regard to the 1.1 reduction factor. I cannot agree with your suggested interpretation. You asserted that S5.3.5 merely requires the label to include the 'cold inflation pressure for those tires,' without referring to S5.1.2 and its 1.1 reduction factor. You contrasted this requirement with that in S5.3.3, which expressly refers to S5.1.2 and the 1.1 reduction factor. You asserted that this difference in wording showed that the 1.1 reduction factor need not be considered when specifying the cold inflation pressure on the label in response to S5.3.5. This argument is not persuasive. The load-carrying capability of a tire generally varies with the inflation pressure of that tire, i.e., a tire can carry a greater load at a higher inflation pressure and a lesser load at a lower inflation pressure. Hence, a reference to inflation pressure alone, without any corresponding load-carrying capability to which that inflation pressure applies would be meaningless. If S5.3.5 of Standard No. 120 were interpreted to require the manufacturer to specify some inflation pressure, without regard to any load that must be borne by the tire at that inflation pressure, the vehicle manufacturer could specify an extremely high or low inflation pressure. Such a specification would be useless or even dangerous for the consumer, and contrary to the purposes of the labeling requirements. You implicitly recognize that such an interpretation is unacceptable when you argue on page 1 of your January 16, 1990 that S5.3.5 of Standard No. 120 must be interpreted to require the manufacturer to recommend an inflation pressure 'that will permit the tires to safely carry Gross Axle Weight Rating loads and will provide good vehicle ride characteristics.' In other words, Nissan agrees that the inflation pressure specified in response to S5.3.5 cannot be an extreme value such as 1 psi, instead, it must be determined with reference to some load that the tires will carry. The question then becomes what loading must be considered to determine if the specified inflation pressure complies with S5.3.5. This question is answered by reading the labeling requirement of S5.3.5 in connection with the other labeling requirements in S5.3, instead of considering S5.3.5 in a vacuum. S5.3.2 sets forth the format and lettering size for the labels to be placed on all vehicles manufactured on or after December 1, 1984. The information that must appear on such labels is set forth in S5.3.3, S5.3.4, and S5.3.5 of Standard No. 120. S5.3.3 specifies that the label shall include information on 'the size designation of tires (not necessarily those on the vehicle) appropriate (as specified in S5.1.2) for the GAWR.' (Emphasis added). On any reading of this emphasized language, it is beyond dispute that the 1.1 reduction factor set forth in S5.1.2 must be considered when specifying the appropriate tire size designation pursuant to S5.3.3. Following this, S5.3.4 requires information on the size and type designation of rims 'appropriate for those tires' to appear on the label. The reference to 'those' tires in S5.3.4 indicates that the tires are the tires previously specified in S5.3.3. Similarly, when S5.3.5 requires the cold inflation pressure for those tires to appear on the information label, the language is referring back to the tires specified in S5.3.3. Since NHTSA agrees with your statements that S5.3.3 incorporates the 1.1 reduction factor of S5.1.2 to determine compliance with S5.3.3, and since S5.3.5 refers to the tires specified in S5.3.3, the 1.1 reduction factor set forth in S5.1.2 must be considered to determine ocmpliance with S5.3.5 of Standard No. 120. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam1500OpenMr. Jim Coughlin, Vice President-Marketing, Bell Helmets Inc., 2850 East 29th Street, Long Beach, CA 90806; Mr. Jim Coughlin Vice President-Marketing Bell Helmets Inc. 2850 East 29th Street Long Beach CA 90806; Dear Mr. Coughlin: This is in reply to your letter of May 1, 1974, concerning th requirements of Standard No. 218, *Motorcycle Helmets*. You mentioned that Bell is producing some helmets to the Snell standard 'irrespective of the DOT standard,' and you enclosed the labels Bell is using to allow the consumer to differentiate the helmets produced to the Snell standard. The labels you enclosed contain the following notice:; >>>*IMPORTANT*: THIS HELMET IS MANUFACTURED FOR RACING AND OTHER HIG PERFORMANCE USES ONLY, AND IS NOT REGULATED BY THE U.S. DEPT. OF TRANSPORTATION. IT IS NOT FOR USE ON PUBLIC STREETS, ROADS AND HIGHWAYS.<<<; We do not consider this notice acceptable. We believe that the phrase '...AND OTHER HIGH PERFORMANCE USES ONLY...,' would mislead the consumer into thinking that a helmet with this notice is safer for use on public roads than a helmet produced to Standard 218. Accordingly, the phrase '...and other high performance uses only...' should not be used to describe the purpose of helmets produced to the Snell standard. Instead, we suggest that the following language be inserted: '...and similar off- road sports only...'.; You also ask how to determine which helmets you manufacture qualify a 'fitting' the size C headform. Any 'fit-all' or other helmets that are designed to fit a range of head sizes that includes the approximate dimensions of the size C headform must meet the requirements of Standard 218. A helmet is considered not to fit a size C headform only if it is clearly intended by its manufacturer to be used only by persons whose heads are either larger or smaller than the size C headform.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2286OpenMr. Gilbert Theissen,6S Hayden Hall,33 Washington Square West,New York, New York 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York New York 10011; Dear Mr. Theissen:#This is in response to your letter of February 5 1976, to Mrs. Winifred Desmond of this agency concerning braking and rollover characteristics of the Jeep vehicle. We are sorry for the delay in our answer.#The Jeep Corporation is correct in saying that 49 CFR 571.105-75, *Hydraulic Brake Systems*, applies only to passenger cars. It will also apply to school buses manufactured after October 25, 1976. Part 575, Consumer Information Regulations, applies as a whole to all motor vehicles (49 CFR 575.4), but the consumer information item requiring reports on brake performance is limited to passenger cars and motorcycles (49 CFR S571.101).#With regard to rollover resistance, the agency has issued an advance notice of proposed rulemaking to collect information on rollover resistance, but no requirement to report on rollover performance exists at this time.#Yours truly,Stephen P. Wood,Assistant Chief Counsel; |
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ID: aiam5543OpenMs. Teresa Thompson 1686 Desoto Trail Dalton, GA 30721; Ms. Teresa Thompson 1686 Desoto Trail Dalton GA 30721; "Dear Ms. Thompson: We have received your letter of April 6, 1995, wit respect to an automotive deceleration signal. You have asked for information 'on how to have this product tested and approved as well as information on the legal ramifications and liabilities for the product.' The Department of Transportation neither tests nor 'approves' products. What it does do is to advise whether motor vehicle equipment is permitted under the statutes and regulations for whose administration it is responsible. In this instance, the appropriate regulation is Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. This standard specifies requirements for only certain items of lighting equipment but it also has an effect on lighting equipment that is not specified in the standard. That is to say, if an item of lighting equipment is not allowable for a manufacturer or dealer to install as original equipment (i.e., equipment on the vehicle at the time of its original sale), in most cases it won't be allowable in the aftermarket for manufacturer or dealer installation on used vehicles as well. As you describe it, the signal is provided by 'a strobe light with an independent power supply, which upon heavy breaking (sic), will activate a strobe for five seconds and on impact for ten minutes.' The prototype 'is approximately 4' by 3' and may be attached to a rear window.' Federal laws cover brake activation of your strobe signal. Standard No. 108 requires turn signal lamps, hazard warning signal lamps, and school bus warning lamps to flash. Headlamps and side marker lamps may be flashed for signaling purposes. But all other lamps provided as original equipment must be steady- burning. We regard a strobe lamp as one that flashes. For this reason, the deceleration signal you describe could not be installed as original equipment. Further, its installation on a used vehicle would take the vehicle out of compliance with Standard No. 108. Notwithstanding the discussion above, there is no Federal prohibition on the sale of the strobe signal device, and Federal law does not prevent the vehicle owner from installing it on a used vehicle (however, manufacturers, dealers, distributors, and motor vehicle repair businesses may not do so), no matter what effect the strobe signal may have upon compliance with Standard No. 108. However, the States have the right to decide whether use of the strobe signal is permissible. We aren't able to provide you with information on State laws, and suggest that you seek an opinion from the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22303. We can't advise you on your potential liabilities either, and suggest that you contact your attorney for an opinion on the applicability of local law. In addition, it is important to note that Standard No. 108 prohibits supplementary original lighting equipment that impairs the effectiveness of the original lighting equipment required by Standard No. 108. The proximity of your strobe device in the rear window to the center highmounted stop lamp required by Standard No. 108 raises the possibility of impairment, especially if the strobe is of a color other than red, or so bright as to mask the center stop lamp signal. I am sorry to be unable to offer you more encouragement at present, as we share your concern with the negative effects of fog and rain on drivers and vehicles. It is obvious that you have given much thought to this problem. Noting that you are testing a prototype, this agency would be interested in receiving any data you have or may develop showing a positive effect of the strobe signal upon the frequency and severity of rear end collisions. You may send this to Michael Perel, Office of Research and Development, NHTSA, Room 6206, 400 Seventh St. SW, Washington, DC 20590. It is conceivable that at some time in the future we would allow the center stop lamp to flash under conditions of rapid deceleration. This could open the way to permissibility of an additional lamp such as yours. I note that, to the extent that your device were only to activate upon impact and not during conditions of rapid deceleration, it would not be prohibited by Standard No. 108. Such a device would be permissible as a supplement to, or substitute for, a vehicle's hazard warning signal system. We do not know whether it would be permissible under State laws (see discussion above). If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0741OpenMr. David Rothschild II, Executive Vice President, David Rothschild Company, Post Office Box 20, Columbus, GA, 31902; Mr. David Rothschild II Executive Vice President David Rothschild Company Post Office Box 20 Columbus GA 31902; Dear Mr. Rothschild: This is in reply to your letter of April 11, 1972, concerning Moto Vehicle Safety Standard No. 302, 'Flammability of Interior Materials.' You ask whether the standard applies to motor homes and recreational vehicles being towed. You also ask what type of certificate or guarantee is required of a fabric manufacturer.; Standard No. 302 applies to passenger cars, multipurpose passenge vehicles, trucks, and buses. It does not apply to trailers, the vehicle category which includes mobile homes and other towed recreational vehicles, and these vehicles are consequently not subject to its requirements. With respect to your questions regarding certification by fabric manufacturers, the standard applies to motor vehicles, and it is the vehicle manufacturer who bears the responsibility to certify, under the National Traffic and Motor Vehicle Safety Act, that the vehicle conforms to the standard. There are no Federal requirements regarding certification to this standard imposed on fabric suppliers. However, manufacturers who purchase materials from such suppliers may require some form of certification or guarantee from them that the materials meet the standard.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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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.