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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 5441 - 5450 of 16490
Interpretations Date

ID: aiam2973

Open
Mr. Charles D. Hylton, III, Director, Editorial Services, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Charles D. Hylton
III
Director
Editorial Services
National Tire Dealers & Retreaders Association
Inc.
1343 L Street
N.W.
Washington
DC 20005;

Dear Mr. Hylton: This is in response to your letter of February 27, 1979, asking whethe tire dealers are responsible for supplying point-of-sale information concerning the Uniform Tire Quality Grading Standards (UTQG) (49 CFR 575.104) to prospective tire purchasers.; Subpart A of Part 575, *Consumer Information Regulations*, provides i section 575.6(c) (49 CFR 575.6(c)) that,; >>>'Each manufacturer of motor vehicles, each brand name owner o tires, and each manufacturer of tires for which there is no brand name owner shall provide for examination by prospective purchasers, at each location where its vehicles or tires are offered for sale by a person with whom the manufacturer or brand name owner has a contractual, proprietary, or other legal relationship, or by a person who has such a relationship with a distributor of the manufacturer or brand name owner concerning the vehicle or tire in question, the information specified in Subpart B of this part that is applicable to each of the vehicles or tires offered for sale at that location ...'<<<; The UTQG Standards, contained in Subpart B of Part 575, specify th information which must be furnished to prospective purchasers by vehicle manufacturers, tire manufacturers, and tire brand name owners (49 CFR 575.104(d)(1)(ii)).; Thus, the Consumer Information Regulations place the responsibility fo providing UTQG point-of-sale information to prospective tire purchasers on manufacturers and brand name owners rather than directly on tire dealers. The means by which tire manufacturers and brand name owners assure that UTQG information is provided for examination will be determined between these suppliers and their dealers and distributors.; You should also note that, in light of the 30-day stay granted by th U.S. Court of Appeals for the Sixth Circuit in the case of *B.F. Goodrich Co. v. Department of Transportation*, the effective dates for all requirements of the UTQG regulation, with the exception of paragraphs (d)(1)(i)(A) and (d)(1)(iii) (49 CFR 575.104(d)(i)(A) and (d)(1)(iii), are now March 31, 1979 for bias-ply tires and October 1, 1979 for bias- belted tires. Paragraph (d)(1)(i)(A), the sidewall molding requirement, and paragraph (d)(1)(iii), the first purchaser requirement, now become effective October 1, 1979 for bias-ply tires and March 31, 1980 for bias-belted tires.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam2974

Open
Mr. Charles D. Hylton, III, Director, Editorial Services, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, DC 20005; Mr. Charles D. Hylton
III
Director
Editorial Services
National Tire Dealers & Retreaders Association
Inc.
1343 L Street
N.W.
Washington
DC 20005;

Dear Mr. Hylton: This is in response to your letter of February 27, 1979, asking whethe tire dealers are responsible for supplying point-of-sale information concerning the Uniform Tire Quality Grading Standards (UTQG) (49 CFR 575.104) to prospective tire purchasers.; Subpart A of Part 575, *Consumer Information Regulations*, provides i section 575.6(c) (49 CFR 575.6(c)) that,; >>>'Each manufacturer of motor vehicles, each brand name owner o tires, and each manufacturer of tires for which there is no brand name owner shall provide for examination by prospective purchasers, at each location where its vehicles or tires are offered for sale by a person with whom the manufacturer or brand name owner has a contractual, proprietary, or other legal relationship, or by a person who has such a relationship with a distributor of the manufacturer or brand name owner concerning the vehicle or tire in question, the information specified in Subpart B of this part that is applicable to each of the vehicles or tires offered for sale at that location ...'<<<; The UTQG Standards, contained in Subpart B of Part 575, specify th information which must be furnished to prospective purchasers by vehicle manufacturers, tire manufacturers, and tire brand name owners (49 CFR 575.104(d)(1)(ii)).; Thus, the Consumer Information Regulations place the responsibility fo providing UTQG point-of-sale information to prospective tire purchasers on manufacturers and brand name owners rather than directly on tire dealers. The means by which tire manufacturers and brand name owners assure that UTQG information is provided for examination will be determined between these suppliers and their dealers and distributors.; You should also note that, in light of the 30-day stay granted by th U.S. Court of Appeals for the Sixth Circuit in the case of *B.F. Goodrich Co. v. Department of Transportation*, the effective dates for all requirements of the UTQG regulation, with the exception of paragraphs (d)(1)(i)(A) and (d)(1)(iii) (49 CFR 575.104(d)(i)(A) and (d)(1)(iii), are now March 31, 1979 for bias-ply tires and October 1, 1979 for bias- belted tires. Paragraph (d)(1)(i)(A), the sidewall molding requirement, and paragraph (d)(1)(iii), the first purchaser requirement, now become effective October 1, 1979 for bias-ply tires and March 31, 1980 for bias-belted tires.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam4245

Open
Mr. Jeffrey S. Jensen, 16722 23rd Ave. S.E., Bothell, WA 98012; Mr. Jeffrey S. Jensen
16722 23rd Ave. S.E.
Bothell
WA 98012;

Dear Mr. Jensen: Your letter of September 10, 1986, has been forwarded to this offic for reply. You have devised a way 'to inscribe lettering on the inside of car & truck taillights so that when the brakes are applied the lettering is seen.' You asked if there are any laws that apply to this concept.; Because you wish to produce this concept we shall consider it as bot original equipment installed by the vehicle manufacturer, and as equipment available in the aftermarket, for purchase by a vehicle owner. The Federal regulation governing vehicle lighting equipment is Federal Motor Vehicle Safety Standard No. 108. It requires a manufacturer to produce vehicles with certain specified lighting devices meeting specific requirements. Further, under it, additional lighting devices and other motor vehicle equipment are permissible provided they do not impair the effectiveness of the lighting equipment required by the standard. The requirements for stop lamps (you called them 'tail lights', but taillamps are the rear lights that are on when the headlamps are on, and are not brake activated) are those of SAE Standard J586c, August 1970. It specifies photometric requirements to be met at specific test points, and a minimum effective projected luminous lens area for lamps.; With respect to compliance with the stop lamp requirements of Standar No. 108, the lettering must not prevent the lamp from meeting photometrics at the applicable test points, or from complying with the minimum area requirements. As to whether the concept would nevertheless impair the effectiveness of the stop lamps, this is a decision to be made by the vehicle manufacturer, though it is subject to review by this agency. Anything that distracts the observer of a stop lamp from instantaneously perceiving its message could be considered an impairment.; As an aftermarket device, it is not subject to Standard No. 108, bu only to the restriction imposed by the National Traffic and Motor Vehicle Safety Act that manufacturers, dealers, and motor vehicle repair businesses must not render inoperative in whole or in part devices such as stop lamps that are installed as original safety equipment. If your device created a noncompliance in the stop lamp, or impaired the effectiveness of it, we would consider this the equivalent of rendering the stop lamp partially inoperative.; Your concept would also be subject to the laws of any State in which device embodying it is sold or used. We are unable to advise you as to these laws, but you must consider them as well.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam2013

Open
Mr. John H. Mueller, The Weatherhead Company, 300 East 131st Street, Cleveland, Ohio 44108; Mr. John H. Mueller
The Weatherhead Company
300 East 131st Street
Cleveland
Ohio 44108;

Dear Mr. Mueller: #Please forgive the delay in responding to you letter of March 25,1975, which suggested an inconsistency in the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*. #S5.1 of the standard requires each hydraulic brake hose assembly to be equipped with end fittings which are attached by means of crimping or swaging. You have correctly pointed out that S5.2.3 specifies labeling requirements for 'hydraulic' end fittings which are neither crimped nor swaged, even though at present there are no hydraulic fittings, that fit that description. This language appears as part of S5.2 because S5.2 is incorporated by reference in S7.2 and S9.1, the labeling requirements for hose, fittings, and assemblies used in air and vacuum brake systems, respectively. Although there is thus no inconsistency, the National Highway Traffic Safety Administration is considering a clarifying amendment along the lines you have suggested, which would eliminate S5.2.3 and specify the labeling requirements directly in S7.2 and S9.1. #Thank you for pointing out this potential source of confusion. #Sincerely, Frank A. Berndt, Acting Chief Counsel;

ID: aiam5300

Open
Ms. Jane L. Dawson Specifications Engineer Thomas Built Buses, Inc. P.O. Box 2450 1408 Courtesy Road High Point, NC 27261; Ms. Jane L. Dawson Specifications Engineer Thomas Built Buses
Inc. P.O. Box 2450 1408 Courtesy Road High Point
NC 27261;

"Dear Ms. Dawson: This responds to your questions about a December 2 1992, rule that amended Standard No. 111, Rear-view mirrors, by establishing field-of-view requirements around school buses (57 FR 57000). The rule amended Standard No. 111 to require a bus driver to be able to see, either directly or through mirrors, certain specified areas in front of and along both sides of school buses. I apologize for the delay in responding. Your first question asks: Are we required to certify that the mirror system has the ability to be adjusted for viewing of the cylinders by a 25th percentile female or to certify that the mirror system has been adjusted? Under the National Traffic and Motor Vehicle Safety Act, each new vehicle manufacturer must certify that its vehicle complies with the Federal motor vehicle safety standards (FMVSS's). NHTSA evaluates a vehicle's compliance with the safety standards using the test procedures and conditions specified in the FMVSS's. Standard 111 requires that specified areas must be visible when viewed from the eye location of a 25th percentile adult female (S9, S13). The test procedures of S13 state that, when testing a school bus, NHTSA will adjust an adjustable mirror to the eye location of a 25th percentile adult female before the test, in accordance with the manufacturer's recommendations (S13.3). Of course, to comply with Standard 111, the mirror will have to be able to be adjusted to the required location at the time NHTSA tests the vehicle. Your second question asks: Are the outside rearview mirrors required to view the area straight down from the mirrors and 200 feet rearward? In an October 21, 1993, telephone conversation with Marvin Shaw of my staff, you explained that you ask whether S9.2 of Standard 111 requires measurement beginning at the ground below the System A mirror (and extending at least 200 feet behind that plane). The answer is yes, the mirror must provide a view of the area straight down from that mirror and extending 200 feet rearward. Section S9.2 states that each school bus must have two outside rearview mirror systems: A System A driving mirror and a System B convex cross view mirror. The System A mirror on the left side of the bus is required by S9.2(b)(2) to provide a view of 'the entire top surface of cylinder M in Figure 2, and of that area of the ground which extends rearward from the mirror surface not less than 60.93 meters (200 feet)' (emphasis added). Please note that the agency is currently reviewing a rulemaking petition in which Blue Bird Body Company has requested that the agency amend Standard No. 111, with respect to System A driving mirrors. 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";

ID: aiam2662

Open
Mr. Malcolm B. Mathieson, Engineering Manager, Thomas Built Buses, Inc. 1408 Courtesy Road, P.O. Box 2450, High Point, NC 27261; Mr. Malcolm B. Mathieson
Engineering Manager
Thomas Built Buses
Inc. 1408 Courtesy Road
P.O. Box 2450
High Point
NC 27261;

Dear Mr. Mathieson: This responds to your August 25, 1977, letter asking several question about the applicability of Standard No. 217, *Bus Window Retention and Release*, to buses other than school buses.; You first state your conclusion that paragraph S5.2 of the standar applies only to buses other than school buses. Your interpretation of S5.2 is correct. Secondly, you state that S5.2.1 applies to all buses with GVWR's of more than 10,000 pounds. This assertion is incorrect. See S5.2.3. Paragraph S5.2.1 applies only to buses other than school buses that have GVWR's greater than 10,000 pounds.; Your final inquiry pertaining to Standard No. 217 concerns th requirement for unobstructed emergency exits in both school and non-school buses. You first correctly state that paragraphs S5.4 through S5.4.2.1 describe the required size of the unobstructed openings for school buses. You then claim that there is no equivalent description for the size of unobstructed openings required in buses other than school buses. This last statement is not entirely accurate. The amount of unobstructed emergency exit openings required for buses other than school buses is detailed in S5.2. This section establishes requirements for the total area of unobstructed emergency exit openings and for the location of those exits. This section also specifies the extent to which the area of each exit is to be counted in determining compliance with the total unobstructed opening requirement. Therefore, although the standard does not specify minimum size requirements for individual exits in buses other than school buses, the standard does contain other requirements for unobstructed openings in buses other than school buses.; You concluded in your letter that buses other than school buses are no required to use the parallelepiped device in determining whether their rear exits comply with the requirements. This conclusion is accurate. For purposes of clarity, however, you should note that Standard No. 217 does not mandate rear doors in buses other than school buses. Those buses can utilize either rear exits or roof exits. Further, regardless of the fact that you use a rear emergency door in buses other than school buses, you must insure that you also provide the other mandatory exits and the correct area of unobstructed openings as described in paragraphs S5.2 through S5.2.2.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam4711

Open
Mr. Michael S. Kmiecik 5601 Western Avenue Omaha, Nebraska 68132; Mr. Michael S. Kmiecik 5601 Western Avenue Omaha
Nebraska 68132;

"Dear Mr. Kmiecik: This is in reply to your letter with respect t vehicle modification kits you wish to purchase, to be used in conversion of Datsun 240-280Z cars from closed to open vehicles. You have asked for the safety standards that apply to l974-78 convertibles, and whether the conversion kit meets these standards. I regret the delay in responding. We appreciate your efforts to meet the requirements of the National Traffic and Motor Vehicle Safety Act. As you appear to realize, the Act requires, in essence, that vehicle alterations by a motor vehicle manufacturer, distributor, dealer or repair business must not render wholly or partially inoperative any device or element of design installed on that vehicle in accordance with a Federal motor vehicle safety standard. This means that a vehicle at the end of its conversion process must continue to meet the standards that applied at the time that it was first manufactured. This does not preclude conversions that render compliance with a standard physically impossible, obviously an open car cannot meet, for example, the standard for roof crush resistance (Standard No. 216), and convertibles, are, in fact, exempt from it. Such a conversion would allow substitution of a two-point (lap belt) restraint system in a convertible for a three-point (lap-shoulder belt) restraint system that may have been installed when it was a closed car (Standard No. 208). After the vehicle alterations are complete, the vehicle must conform to the barrier tests specified in several standards. We note that the items that comprise the kit are intended to add rigidity to the body and frame after removal of the top, but are unable to advise you of the effect these modifications would have upon the safety performance of the vehicle as converted. There are no Federal safety standards that apply to the individual items in your kit. The standards that apply to motor vehicles, including convertibles, manufactured from October 1, l973, through September 30, l978, will be found at Title 49 Code of Federal Regulations Part 571. Specifically, the standards appear in volumes titled 49 CFR Parts 200 to 999, revised as of October 1, l973, l974, l975, l976, and l977. Originally, these volumes were available through the U.S. Government Printing Office (which may have an Omaha outlet). If they are no longer available through the GPO, we recommend that you consult a local law library. Thank you for your interest in motor vehicle safety. Sincerely, Stephen P. Wood Acting Chief Counsel";

ID: aiam1461

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

Dear Mr. Eckhold: This is in reply to your November 21, 1973, petition for amendment o Federal Motor Vehicle Safety Standard No. 215, *Exterior Protection*, requesting that a more specific bumper pendulum impact pattern be adopted.; The revisions you have proposed could result in designs with less tha required protection in areas outside those specified by Ford. Although the impact points suggested by Ford may constitute an adequate testing pattern for Ford vehicles, they may not be adequate for all other manufacturers' vehicle designs.; The necessity of detecting weak points that you cite is one of the mai goals of the safety standards. To the extent that Ford is confident that such 'searching' is unjustified (because there is no reasonable probability of finding a nonconformity), there is no necessity to search. Structural analysis of each bumper design based upon previous test experience should enable the vehicle manufacturer to determine the critical areas for testing. The manufacturer is free to determine, for example, on sufficient data, that all models need not be tested where the basic bumper design, including the energy absorption unit, is utilized in the models. A further reduction in the need for testing can be realized by a retention of the same bumper designs from year to year.; For these reasons, the NHTSA must deny your request for a more specifi demonstration technique.; Sincerely, James B. Gregory, Administrator

ID: aiam5221

Open
Mr. Ron Marion Sales Engineer Thomas Built Buses, Inc. P.O. Box 2450 1408 Courtesy Road High Point, N.C. 27261; Mr. Ron Marion Sales Engineer Thomas Built Buses
Inc. P.O. Box 2450 1408 Courtesy Road High Point
N.C. 27261;

"Dear Mr. Marion: This responds to your inquiry about the applicabilit of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, 'Safety Act') requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm 'on the left side of the bus.' (S5.4) The purpose of this standard is 'to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus.' (S2) When NHTSA specified that the stop arm must be placed on 'the left side of the bus,' the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, 'the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window.' (Emphasis added). This provision indicates that the agency assumed that the 'left' side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle. Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the driver's side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side. I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: aiam5224

Open
Mr. Ron Marion Sales Engineer Thomas Built Buses, Inc. P.O. Box 2450 1408 Courtesy Road High Point, N.C. 27261; Mr. Ron Marion Sales Engineer Thomas Built Buses
Inc. P.O. Box 2450 1408 Courtesy Road High Point
N.C. 27261;

"Dear Mr. Marion: This responds to your inquiry about the applicabilit of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, 'Safety Act') requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm 'on the left side of the bus.' (S5.4) The purpose of this standard is 'to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus.' (S2) When NHTSA specified that the stop arm must be placed on 'the left side of the bus,' the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, 'the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window.' (Emphasis added). This provision indicates that the agency assumed that the 'left' side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle. Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the driver's side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side. I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting 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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