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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



Displaying 5021 - 5030 of 16517
Interpretations Date

ID: aiam0484

Open
Mr. Harold T. Halfpenny, Halfpenny, Hahn & Roche, 111 West Washington Street, Chicago, IL, 60602; Mr. Harold T. Halfpenny
Halfpenny
Hahn & Roche
111 West Washington Street
Chicago
IL
60602;

Dear Mr. Halfpenny: This is in reply to your letters of October 18, 1971, and November 1 1971, to Mr. Douglas Toms, Administrator, National Highway Traffic Safety Administration, concerning the 'Panic-Stop' signal system from Donel Corporation.; You are correct in your interpretation that Federal Motor Vehicl Safety Standard No. 108 is not applicable to the 'Panic-Stop' system when this system is not installed on motor vehicles as original equipment. The motor vehicle laws and regulations of the individual States, are, however, applicable to the 'Panic-Stop' system when sold and used as aftermarket equipment.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: aiam2513

Open
Mr. Dennis G. Moore, Dry Launch, 1113 Greenville, Livermore, CA 94550; Mr. Dennis G. Moore
Dry Launch
1113 Greenville
Livermore
CA 94550;

Dear Mr. Moore: This is in reply to your letter of December 27, 1976, asking severa questions about Federal Motor Vehicle Safety Standard No. 108. You referenced my letter of October 7, 1976 to Wesbar Corporation, and my views about the prohibition against the optical combination of lamps (S4.4.1).; It is evident from your letter and others that our previou interpretations of the term 'optical combination' have been found to be ambiguous and lacking in the objective criteria that a Federal motor vehicle safety standard must provide. We have reviewed the matter, and now wish to modify our previous interpretation. In our view a lamp is 'optically combined' when the same light source (i.e. bulb) and the same lens area fulfill two or more functions (*e.g.* taillamp and stop lamp, clearance lamp and turn signal lamp). A dual filament bulb would be regarded as the 'same light source'. In determining conformance, the photometric requirements for clearance and taillamp functions, where two bulbs are located in a single compartment, must be met with only the bulb energized that is designed to perform the specific function. But the 15 candlepower maximum under Standard No. 108, however, would be determined with both the taillamp and clearance lamp bulb energized. Further, the lamp must be located to meet requirements for both clearance and taillamps. our re- interpretation means that the issue of light spill-over from one area of the lamp to another is irrelevant to conformance.; You have also asked whether the November 1975 amendments (S4.3.1.1.1 'permit clearance lights that are designed *for OEM application only* be allowed to have lower or no photometrics in this area but still be considered a combination clearance and sidemarker lamp' as the lamp otherwise complies with Standard No. 108.; The amendment in question was intended to cover clearance lamps only If a lamp is intended as a combination clearance and side marker lamp and does not meet the requirements for a clearance lamp because of the exemption provided by S4.3.1.1.1, it must nevertheless meet the requirements for side marker lamps. If it doesn't, a separate conforming side marker lamp must be provided.; Yours truly, Frank Berndt, Acting Chief Counsel

ID: aiam5239

Open
Mr. Sam C. Nigro Bus Product Manager Webasto Thermosystems 1598 E. Lincoln Madison Heights, MI 48071; Mr. Sam C. Nigro Bus Product Manager Webasto Thermosystems 1598 E. Lincoln Madison Heights
MI 48071;

"Dear Mr. Nigro: This responds to your letter about auxiliary heater fueled by compressed natural gas (CNG) and liquid natural gas (LNG) for installation on buses using those alternative fuels. You stated that your company currently manufactures auxiliary heaters for diesel fueled buses, and is interested in developing heaters that would 'burn CNG and LNG same as the engine.' In a telephone conversation with Marvin Shaw of my staff, you explained that you would like information about NHTSA's current requirements for auxiliary heaters on alternative fueled buses and the agency's future plans in this area. I am pleased to have this opportunity to explain our regulations to you. By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Safety Act, 15 U.S.C. 1381, et seq.), it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable Federal motor vehicle safety standards (FMVSS's). The following represents our opinion based on the facts provided in your letter. NHTSA does not have any safety standards specifically covering auxiliary heaters of any kind, and I am not aware of any plans to issue standards in this area. Nevertheless, an auxiliary heater is an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with defects relating to motor vehicle safety. If you or NHTSA determines that a safety-related defect exists, you must notify purchasers of your product and remedy the problem free of charge. (This responsibility is borne by the vehicle manufacturer in cases in which the heater is installed on a new vehicle by or with the express authorization of that vehicle manufacturer.) Any manufacturer that fails to provide notification of or remedy for a defect may be subject to a civil penalty of up to $1,000 per violation. As Mr. Shaw informed you on the telephone, earlier this year NHTSA proposed to issue a safety standard that would apply to CNG tanks (i.e., containers designed to store CNG as motor vehicle fuel on-board a motor vehicle) and vehicles using CNG as a fuel (58 FR 5323, January 21, 1993). If this proposed standard is adopted, it would affect your product in the following manner. If your heater were installed as original equipment on a new vehicle, the vehicle manufacturer is required by our certification regulations to certify that the entire vehicle (with your product installed) satisfies the requirements of all applicable FMVSS's, including the CNG fuel system standard. If the heater were added to a new, previously-certified vehicle (e.g., a new completed bus), the person who adds the system would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. These certification requirements apply to the vehicle manufacturer and alterer regardless of whether the heater is connected to the vehicle's fuel system. Of course, if the heater is connected to the vehicle's fuel system, the vehicle's compliance with the CNG standard should be carefully scrutinized. If the heater were installed on a used vehicle by a vehicle manufacturer, distributor, dealer or repair business, the installer would not be subject to the certification requirements outlined above. Instead, the installer would have to ensure that it did not knowingly render inoperative the compliance of the vehicle with any applicable safety standard, including the CNG standard. This is required by 108(a)(2)(A) of the Safety Act. If the modification of the vehicle entailed connecting the heater to the vehicle's fuel system, compliance with the CNG standard would be especially germane to whether 108(a)(2)(A) were violated. The prohibition of 108(a(2)(A) does not apply to individual vehicle owners who alter their own vehicles. Thus, under our requirements, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with the FMVSS's. However, NHTSA encourages vehicle owners not to tamper with vehicle safety equipment if the modification would degrade the safety of the vehicle. The certification responsibilities discussed above would affect vehicle manufacturers even if the proposed CNG standard is not adopted or is not yet effective when you market your product. Except for FMVSS 301, which sets fuel system integrity requirements for gasoline and diesel-powered buses under 10,000 pounds GVWR, all of the FMVSS's that apply to a diesel- or gasoline- powered vehicle now apply to a CNG-powered vehicle. A manufacturer of a CNG- powered vehicle who installs your heater as original equipment must certify the vehicle to those standards, regardless if the CNG FMVSS is among them. Similarly, a vehicle alterer would have to certify that the vehicle, as altered, complies with all applicable FMVSS's. The 'render inoperative' prohibition would also apply even in the absence of a CNG FMVSS. The commercial entity listed in 108(a)(2)(A) who installs the heater on a CNG-powered vehicle would have to ensure that it did not knowingly render inoperative the compliance of the vehicle with any FMVSS that applies to the vehicle, even if a CNG standard is not among them. I am enclosing for your information a copy of NHTSA's proposed FMVSS for CNG tanks and vehicles. Also enclosed is a fact sheet titled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and a booklet entitled Federal Motor Vehicle Safety Standards and Regulations. As you are aware, the Federal Highway Administration has issued a regulation applicable to heaters on commercial vehicles. (49 CFR 393.77). You can contact the FHWA for an interpretation of its regulations at the following address: Theodore McConnell Chief Counsel Federal Highway Administration 400 7th Street, SW Washington, D.C. 20590 I hope this information is helpful. Please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, John Womack Acting Chief Counsel Enclosure";

ID: aiam2006

Open
Mr. Fred Long, South Texas Tire Test Fleet, Drawer J, Devine, TX 78016; Mr. Fred Long
South Texas Tire Test Fleet
Drawer J
Devine
TX 78016;

Dear Mr. Long: This is to confirm your telephone conversation of July 31, 1975, wit Mark Schwimmer concerning the treadwear test procedures specified in 49 CFR Part 575.104, *Uniform Tire Quality Grading Standards* (UTQGS).; You had previously pointed out that the A78-13 and other tires ar available neither as original equipment nor as recommended replacement options on any 1975 model passenger cars, although they are available as replacement options for the 1974 Ford Pinto. You had asked whether it is permissible for a tire manufacturer to conduct treadwear testing for such tires on a 1975 Pinto, in light of the National Highway Traffic Safety Administration's (NHTSA) statement that; >>>tires will be tested for compliance only on vehicles for which the are available as original equipment or recommended replacement options. (40 FR 23076, May 28, 1975)<<<; As Mr. Schwimmer explained to you, the UTQGS rules does not dictate th method by which a tire manufacturer must conduct his testing to assign grades. It merely specifies the procedures which the NHTSA will follow when testing tires for compliance with the rule. While the surest way for the tire manufacturer to be confident of compliance would be to follow these procedures in every detail, he is not legally obligated to do so. His obligation is simply to ensure that, when tested by the NHTSA according to the specified procedures, his tires are capable of achieving the grades which he has assigned to them. He may fulfill this obligation by whatever means he believes reliable and necessary. Thus, for example, he might choose a 1975 Pinto to test an A78-13 tire, if he is confident that the model year change in the Pinto will have no effect on the tire's treadwear performance. This decision is his, however. The NHTSA, in its compliance testing, would test such a tire on a 1974 Pinto or on some other passenger car for which it is original equipment or a recommended replacement option.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: aiam0191

Open
Mr. J. C. Eckhold, Automotive Safety Director, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold
Automotive Safety Director
Ford Motor Company
The American Road
Dearborn
MI 48121;

>>>Re: Consumer Information<<< Dear Mr. Eckhold: This is in response to your telegram of December 15 concerning th submission of consumer information on passenger cars produced by your associated company in England. You stated, 'This data will be submitted to the Bureau thirty (30) or more days in advance of any of these cars being offered for sale in the United States as required by section 375.6 as published on October 22, 1969.'; The regulation (49 CFR S 375.6(b))requires information to be mad available to prospective purchasers, on or after January 1, 1970, on 'each of the vehicles offered for sale' at the dealer showroom. The general applicability of the information is to vehicles manufactured on or after January 1, 1970. The intent of the regulation is to provide prospective vehicle buyers with information on all the various types of vehicles currently being manufactured and available for purchase after that date.; You apparently are assuming that, within the meaning of the regulation no vehicles are 'offered for sale' to prospective purchasers except those that are physically present in the dealer showroom. This certainly does not reflect the practice of most manufacturers, whose dealers, while keeping a representative stock of vehicles on hand, offer for sale (and enter into contracts for sale of) the manufacturer's complete line of vehicles. This interpretation would, furthermore, tend to defeat the main reason for providing information to prospective purchasers, since a dealer would never be obligated to provide information on vehicles other than those that happened to be in his possession at a given moment.; We advise you, therefore, that the term 'vehicles offered for sale' i the prospective purchaser requirement, 49 CFR S 375.6(b), refers to all the types of vehicles that a manufacturer represents, or the dealer represents with the permission of the manufacturer, as being available for purchase by the general public at a particular dealer location. The regulation requires that consumer information be provided to prospective purchasers on each of there (sic) vehicles on or after January 1, 1970, and to the Administrator 30 days in advance of its availability to prospective purchasers.; Sincerely, Lawrence R. Schneider, Acting Assistant Chief Counsel fo Regulations;

ID: aiam2456

Open
Mr. Keigo Ohgiya, The Japan Automobile Tire Manufacturers' Association, Inc., 9th Floor, Toranomon Building, No. 15, Shiba Toranomon, Minato-Ku, Tokyo, Japan; Mr. Keigo Ohgiya
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, 1976, letter advising the Nationa Highway Traffic Safety Administration that the tire standards of the Japan Automobile Tire Manufacturers' Association (JATMA) are being translated into English. You request that consideration be given to referencing JATMA standards in the Federal motor vehicle safety standards that regulate motor vehicle tire manufacture. I regret that we have not responded to your letter sooner.; Standard No. 109, *New Pneumatic Tires*, and Standard No. 119, *Ne Pneumatic Tires for Vehicles Other Than Passenger Cars*, presently reference the Japanese Industrial Standards (JIS). Because the JATMA standards appear to be updated mote often than the JIS standards, and because the JATMA standards will be issued in English, the agency intends to substitute a reference to JATMA standards in its regulations for the existing reference to JIS standards.; Thank you for providing us with the English translation of th motorcycle tire standards. We request that you provide us copies of all English translations of the standards for all vehicle types as often as the are updated.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam5393

Open
Erika Z. Jones, Esq. Mayer, Brown & Platt 2000 Pennsylvania Avenue, N.W. Washington, D.C. 20006-1882; Erika Z. Jones
Esq. Mayer
Brown & Platt 2000 Pennsylvania Avenue
N.W. Washington
D.C. 20006-1882;

"Dear Ms. Jones: This responds to your letter asking for ou concurrence that 103(d) of the National Traffic and Motor Vehicle Safety Act preempts a 'California flammability standard' as that standard applies to child restraint systems. The standard you enclosed is California Business and Professions Code, Division 8, Chapter 3, 19006 and 19161. I apologize for the delay in this response. Because it was not readily apparent from your letter that the California flammability standard applies to child restraint systems, Ms. Fujita of my staff contacted California state officials for more information about the standard. We were informed by Mr. Art Anderson, Chief of the California Highway Safety Office, that California does not have a flammability standard for child restraint systems. Mr. Anderson was aware that Federal Motor Vehicle Safety Standard (FMVSS) No. 302 applies to child restraints by way of S5.7 of FMVSS No. 213, 'Child Restraint Systems.' As you point out, Federal preemption issues would arise if California had a flammability standard for child restraint systems that covered the same aspect of performance as FMVSSs 213 and 302. However, in view of Mr. Anderson's statement that California has no flammability standard for child restraint systems, we need not address those issues today. We hope this information is helpful. Mr. Anderson of the California Highway Safety Office (telephone (916) 445-0527) said he will be happy to answer any questions you might have about California's requirements. If you any further questions about 103(d), please do not hesitate to contact us. Sincerely, John Womack Acting Chief Counsel cc: Art Anderson";

ID: aiam4428

Open
Mr. Dave Anderson Sales Manager Gist Ornamental Iron Works, Inc. l2l27 Woodside Avenue Lakeside, CA 92040; Mr. Dave Anderson Sales Manager Gist Ornamental Iron Works
Inc. l2l27 Woodside Avenue Lakeside
CA 92040;

Dear Mr. Anderson: This responds to your letter about Federa requirements for trailers. According to your letter, you are in the planning stages of becoming a manufacturer of, and dealer for, automobile trailers. The trailers would hitch to the back of automobiles and be designed to carry cargo. You noted that in response to an earlier inquiry, you received a copy of the handout entitled 'Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' You stated that you are unclear just how this applies to automobile trailers. You asked what you need to do to comply with any applicable Federal regulations, and what regulations apply to trailers of the kind you plan to build. Trailers are considered motor vehicles under Federal law. As a manufacturer of motor vehicles, you would be required to submit identification information to the National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566, Manufacturer Identification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. The procedure is specified in 49 CFR Part 567. The following safety standards apply to trailers: Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, Safety Standard No. 115, Vehicle Identification Number--Basic Requirements, Safety Standard No. ll9, New Pneumatic Tires for Vehicles Other Than Passenger Cars, Safety Standard No. l20, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, trailers with certain braking systems must meet Safety Standard No. l06, Brake Hoses, Safety Standard No. 116, Motor Vehicle Brake Fluids, and Safety Standard No. l2l, Air Brake Systems. All of these safety standards are found in 49 CFR Part 57l. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel;

ID: aiam3617

Open
Mr. J. L. Campbell, Jr., 12813 95th Avenue, N.E., Kirkland, WA 98033; Mr. J. L. Campbell
Jr.
12813 95th Avenue
N.E.
Kirkland
WA 98033;

Dear Mr. Campbell: I have recently received a copy of your letter to Senator Gorto concerning the difficulties small manufacturers of motor vehicles have in complying with Federal standards. To alleviate these difficulties, you suggested that blanket exemptions from the bumper regulations and the Federal motor vehicle safety standard on side door strength be granted to all 4-wheel vehicles under 800 pounds dry weight.; As explained more fully below, this agency does not have authority fro Congress to grant an exemption from the bumper standard for the ultra-lightweight vehicles you describe. Such authority would require new legislation. However, we do have authority either to exclude all of those vehicles from the side door strength standard or to exempt particular manufacturers of those vehicles from that standard.; Congress set forth the guidelines under which this agency could issu exemptions from the bumper standards in section 102(c)(1) of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1912(c)(1). Exemptions may be granted only to passenger motor vehicles manufactured for a special use. While neither the Cost Savings Act nor this agency has defined 'special use', the Cost Savings Act is explicit that a vehicle can be exempted only if two conditions are met: (1) the vehicle is manufactured for a special use, (2) compliance with the bumper standard would unreasonably interfere with that use. The example Congress cited for such a vehicle was a Jeep with snow removal equipment on the front. The agency believes that the purpose of an ultra-lightweight passenger vehicle is essentially the same as that of a lightweight vwehicle such as the Toyota Starlet, Honda Civic or Ford Escort, i.e., to carry passengers. The agency does not view that purpose to be a special use within the meaning of section 102. Further, even if the first condition could be met, it is not clear that the second one could be. Hence, an amendment to the Cost Savings Act would have to be made by the Congress before we could grant an exemption from the bumper standard to your ultra-lightweight passenger motor vehicles.; Concerning your request regarding Standard No. 214, side door strength NHTSA formerly excepted motor vehicles (other than trailers and motorcycles) of 1,000 pounds or less curb weight from all safety standards. However, that exception was eliminated in 1973 (38 F.R. 12808, May 16, 1973). At that time, the agency stated that manufacturers seeking relief from compliance problems peculiar to these vehicles could either petition for amendments to individual standards or petition for an exemption under section 123 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410).; These options remain the ones available to manufacturers o ultra-lightweight vehicles. Thus, one option is to submit a petition for rulemaking under 49 CFR Part 552 requesting the agency to amend Standard No. 214 to exclude those vehicles from that standard's applicability provision. I should point out that few, if any, petitions of this type have been submitted since the agency's May 1973 notice and none have been granted. Also, you should be aware that the rulemaking process is often a lengthy one.; The other option is for a manufacturer to submit a petition for th exemption of his vehicles from a particular standard. I have enclosed a copy of 49 CFR Part 555 which sets forth the information that a manufacturer must include in its petition. Exemption petitions are not uncommon and are often granted at least in part. Also, because fewer procedural steps are necessary, the exemption process is typically much faster than the amendment process. Should you wish to submit an exemption petition, you may find useful the enclosed copies of section 123 of the Safety Act and Standard No. 214, *Side Door Strength* (49 CFR S 571.214).; If you need any further assistance or information on either of thes subjects, please do not hesitate to contact me. We try to minimize the regulatory difficulties experienced by small manufacturers to the extent we can do so consistent with our legislative authority.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam2905

Open
Mr. F. Michael Petler, Assistant Manager, Safety & Legislation Department, U.S. Suzuki Motor Corporation, P.O. Box 2107, Santa Fe Springs, California 90670; Mr. F. Michael Petler
Assistant Manager
Safety & Legislation Department
U.S. Suzuki Motor Corporation
P.O. Box 2107
Santa Fe Springs
California 90670;

Dear Mr. Petler: This is in response to your letter of August 11, 1978, requesting a interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 127, Speedometers and Odometers.; Standard 127 does not specify that the number '0' appear on the face o the speedometer. It is permissible for you to reletter the '0' mph position to read '5' mph, as the lowest measured speed indicated. This would solve the problem you indicate regarding the relationship of the graduation distance between the 0 and 10 mph to that between 10 and 20, 20 and 30, etc.; The NHTSA has received petitions for reconsideration requesting tha the 10 percent deviation requirement be eliminated. A determination will be made at a later date whether to grant the petitions.; Sincerely, Joseph J. Levin, Jr., 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.

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