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: aiam4659OpenFrau Margret Schmock Robert Bosch GMBH Abt. K2/ELE2; Frau Margret Schmock Robert Bosch GMBH Abt. K2/ELE2; "W. Germany FAX Number 07121/35-1792 Dear Frau Schmock: This is i reply to your FAX of September 6, l989, to Mr. Van Iderstine of this agency, asking four questions with respect to requirements for the center highmounted stop lamp. 'l. Is it allowed to use 6 wedge-base-bulbs (3cp) on one high mounted stop lamp?' Federal Motor Vehicle Safety Standard No. l08 does not prescribe the number of bulbs to be used in the center highmounted stop lamp. Although paragraph S5.1.1.27(e) (formerly S4.1.1.41(e)) states that 'the bulb' shall be replaceable without the use of special tools, the intent of this language is not to restrict the number of light sources in the center lamp, but to ensure that any and all light sources are readily replaceable. Therefore, it is acceptable in principle to use 6 bulbs. The sole limitation is that the maximum candlepower limitation of the lamp specified in Figure l0 must not be exceeded. '2. SAE J186 Nov.82 says that the effective projected luminous area shall not be less than 29 square centimeters. How would you measure the projected luminous area of a lamp with 6 bulbs?' It is acceptable to measure the area as if the lamp contained only a single bulb. Incidentally, the November l982 version of SAE Jl86 has not been incorporated by reference into Standard No. l08 as the requirement for center highmounted stoplamps. The correct reference is Jl86a, September l977 (which does not contain the 29 square centimeter specification, that specification is expressed as 4 1/2 square inches in paragraph S5.1.1.27(a)). '3. Must each bulb reach the required photometric values?' No. Photometrics are a measure of the light output at specified test points measured from outside the lamp. Therefore, it is the lamp that meets the photometric requirements, and not the light source or sources. '4. What will happen, if one bulb is defect?' The specification for the lamp applies at the time it is sold to a retail customer. Thus, all bulbs in a lamp must be functional at that time. If a manufacturer chooses to design a lamp to meet the photometric specification when one bulb is not functioning, that would provide an extra measure of safety that is not required by Standard No. 108. Obviously, an inoperative light source should be replaced at the owner's earliest convenience, and the requirement that the light source be replaceable without special tools is intended to add to the convenience of replacement. Sincerely, Stephen P. Wood Acting Chief Counsel"; |
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ID: aiam2349OpenMr. Russell H. Berry, Jr., Marketing Specialist, 'Lucite' Acrylic Sheet Products, 1007 Market Street, Wilmington, DE 19898; Mr. Russell H. Berry Jr. Marketing Specialist 'Lucite' Acrylic Sheet Products 1007 Market Street Wilmington DE 19898; Dear Mr. Berry: This is in response to your letter of April 9, 1976, concerning th certification and marking requirements for glazing specified in Section 6 of Standard No. 205, *Glazing* Materials. You asked whether the standard prohibits use of the 'DOT' symbol and manufacturer's code number by anyone other than a 'prime glazing material manufacturer,' as that term is defined in paragraph S6.1.; Our letter to Dupont explained the separate certification and markin requirements that are applicable to glazing prepared by prime glazing material manufacturers, distributors, and vehicle manufacturers. The standard specifies that the 'DOT' symbol shall be placed on glazing that is designed by the prime glazing material manufacturer as a component of any specific motor vehicle. The agency's interpretations of several years ago pointed out that the standard requires a person other than a prime glazing manufacturer who cuts glazing materials to mark it in accordance with section 6 of ANS Z26 and to certify it in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act of 1966. These interpretations emphasized that a person who cuts and shapes the glazing material received from a prime glazing manufacturer should not include the 'DOT' symbol in his marking and certification.; At the time of the earlier interpretations, the NHTSA considered i necessary from the standpoint of enforcement to distinguish between glazing that had been manufactured by the prime glazing manufacturer for use in specific motor vehicles and glazing that had been cut, shaped, or otherwise altered by another party before installation. The agency was also concerned that the use of the 'DOT' symbol by anyone other than the prime glazing manufacturer would be misleading and could create confusion.; Since that time, the certification procedures have become more widel understood and uniformly practiced throughout the industry, and this has aided the 'traceability' of glazing materials for enforcement purposes. Therefore, the agency no longer prohibits the use of the 'DOT' symbol and the prime glazing manufacturer's code number by the distributor or manufacturer who cuts the glazing, if the prime glazing manufacturer grants permission for such use of his code number to the distributor or manufacturer.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam5327OpenMr. Robert Matulich 8801 Ravenna Avenue, NE Seattle, WA 98115; Mr. Robert Matulich 8801 Ravenna Avenue NE Seattle WA 98115; "Dear Mr. Matulich: This responds to your letter requesting informatio about Federal requirements applicable to your product. According to promotional literature that accompanied your letter, your 'Clear Vu Mirror' is an attachment to exterior mirrors that clears raindrops, dust, and mist, thus making a mirror 'virtually self-cleaning.' I am pleased to explain the applicability of our regulations to your product. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal Motor Vehicle Safety Standards (FMVSSs) that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the National Traffic and Motor Vehicle Safety Act ('Safety Act') establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable FMVSSs. NHTSA currently has no FMVSSs that directly apply to the product you plan to manufacture. NHTSA issued an FMVSS for vehicle rearview mirrors (FMVSS No. 111), but the standard applies to new vehicles, and not to aftermarket mirror products. If your product were manufactured and sold as part of a new vehicle, the vehicle would have to be certified as complying with all applicable standards, including Standard No. 111. The standard sets field of view requirements for new motor vehicles, and your product would have to be mounted on a new vehicle such that it does not block the field of view required by FMVSS No. 111. However, since Standard No. 111 applies only to new vehicles, it does not apply to your product. I note, however, that there are other Federal requirements that indirectly affect you and your product. Under the Safety Act, your product is considered to be 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 safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 108(a)(2)(A) of the Safety Act, which states: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ....' It is conceivable that your product, when placed on a vehicle's exterior mirror, could 'render inoperative' the vehicle's ability to comply with FMVSS No. 111. Persons in the aforementioned categories cannot install your product if it blocks the field-of-view required by FMVSS No. 111, or otherwise caused the vehicle to no longer comply with Standard No. 111. The 'render inoperative' prohibition of 108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your product were placed on an exterior mirror by the vehicle owner, the render inoperative provision would not apply. Nevertheless, NHTSA urges vehicle owners not to degrade the safety of any system or device on their vehicles, including the safety of their rearview mirrors. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam3791OpenMr. A. Chambord, Standards Attache, The French Embassy, Suite 715, 2000 L Street, N.W., Washington, DC 20036; Mr. A. Chambord Standards Attache The French Embassy Suite 715 2000 L Street N.W. Washington DC 20036; Dear Mr. Chambord: This responds to your recent letter to Mr. Steve Kratzke of my staff asking for information on requirements applicable to tire rims for vans. The three points set forth in your letter are correct statements of the requirements, but I will reiterate them to be certain that you provide accurate information.; (1) Vans are considered 'motor vehicles other than passenger cars' fo the purposes of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars* (49 CFR S571.120), and Standard No. 120 sets forth requirements which must be met by all new rims for use on vans. No other standard contains requirements applicable to those rims.; (2) Section S5.2(c) of Standard No. 120 requires the rim manufacture to permanently label each of its van rims with the letters 'DOT' as a certification that the rim satisfies the requirements of Standard No. 120. The manufacturer is expected to exercise due care before making such a certification. No outside inspector, either governmental or privately employed, need be consulted by a manufacturer before certifying the compliance of its rims.; (3) Rims entering into the United States are not individuall inspected, provided that the package containing the rims or the van on which the rims are installed bears an appropriate certification label. The only inspections at the port of entry are checks to see that a certification label is attached to the package of rims or the van.; Should you need any further information on this subject, please do no hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4460OpenRobert J. Kaufman, Esq. Gingold, Kaufman & Chaiken 400 Perimeter Center Terrace, N.E. Suite 720 Atlanta, GA 30346-1234; Robert J. Kaufman Esq. Gingold Kaufman & Chaiken 400 Perimeter Center Terrace N.E. Suite 720 Atlanta GA 30346-1234; Re: GK&C File "1012-271 Dear Mr. Kaufman: This responds to your recent lette concerning the advice I gave to a company called Auto Accessories, Inc., with respect to the installation of that company's armrests in Volvo 240 automobiles. More specifically, on behalf of your client, a Volvo dealership, you seek clarification of that advice and request copies of any information, e.g., tests or studies, regarding the armrests. I appreciate your client's concern for safety. For your information, I have enclosed a copy of my November 18, 1987 letter to that company, in which the advice was provided. I have also enclosed a copy of the armrest installation instructions that were proposed by Auto Accessories and discussed in my response. Based on your reading of a letter from Auto Accessories to Volvo dealers (enclosed with your letter), you concluded that the armrest installation procedure 'ostensibly was either approved, mandated, or suggested by the Department of Transportation.' As you will see from my November 1987 letter, the Department did not take any of those actions. This Department has no authority under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) to approve or endorse any items of motor vehicle equipment or installation procedures therefor. Instead, the Safety Act puts the responsibility on manufacturers to certify that their products comply with the applicable requirements (15 U.S.C. 1403), and obliges manufacturers, distributors, dealers, and motor vehicle repair businesses not to knowingly render inoperative any devices or elements of design in vehicles that were installed in compliance with applicable safety standards (15 U.S.C. 1397(a)(2)(A)). In keeping with this statutory scheme, this agency did not make a determination in the November 1987 letter or on any other occasion that a dealer following the proposed installation instructions would or would not render inoperative a vehicle's compliance with the safety standards. The agency makes such determinations only in the context of an enforcement proceeding. Instead, my November 18 letter pointed out the element of design that might be rendered inoperative by installing the armrests, and advised Auto Accessories as the manufacturer to carefully examine its instructions to determine whether or not following them would result in a 'render inoperative' violation. It appears from the Auto Accessories letter to dealers that that company believes the installation of its armrest would not result in any violations. Our advice to dealers is essentially the same as the advice we gave to Auto Accessories. Dealers should examine the instructions to determine whether following them would render inoperative a vehicle's compliance with Standard No. 208 or any other standard. You may wish to contact Auto Accessories to learn more about the basis for its apparent belief that the installation of its armrest will not violate any requirements of the Safety Act. As for the tests and studies you requested, again, because of our statutory scheme, we have not conducted any regarding the armrest or its installation. We would do so only in the context of an enforcement proceeding. Please let me know if you have any further questions on this subject. Sincerely, Erika Z. Jones Chief Counsel Enclosure"; |
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ID: aiam5246OpenFrau Margret Schmock von Ohr Robert Bosch GmbH FAX 07121/35-1792; Frau Margret Schmock von Ohr Robert Bosch GmbH FAX 07121/35-1792; "Dear Frau Schmock: This responds to your FAX of July 9, 1993, t Taylor Vinson of this Office, asking for a further interpretation of Motor Vehicle Safety Standard No. 108 as it relates to reflex reflectors. In your earlier FAX, you asked whether it is permissible to have an amber painted reflex reflector lens, and the conditions under which it is permissible to have it painted. We informed you that the amber painted reflex reflector lens is permissible provided that the front reflex reflector assembly meets all requirements of Standard No. 108 including the referenced SAE J594f. You ask now whether 'the combination plastic + paint' has to meet SAE J576c, pointing out that the outdoor exposure test requires a period of three years. You also ask whether it is sufficient to have only the plastic material (without paint) tested, and if it is not sufficient, the means by which you may get an exemption from the rule. S5.1.2(c) of Standard No. 108 requires that, after the outdoor exposure test, plastic materials used for reflex reflectors shall meet the appearance requirements of paragraph 4.2.2 of SAE J576c. Paragraph 3.1 of SAE J576c indicates that the plastic materials are to be tested with the colors that will be employed in their end use. We understand that Bosch is not the manufacturer of the plastic materials but is simply the entity that fabricates the reflex reflectors from the plastic materials. Your customer, in turn, will install these reflectors until December 1993 as original equipment on its motor vehicles. We have found, under Standard No. 108, that the manufacturer of the plastic materials advises the lamp manufacturer that, if used in the manner specified by the materials manufacturer, the plastic materials supplied to be incorporated into lamps will perform in accordance with the requirements of SAE J576c for plastic materials. The manufacturer of the materials should provide Bosch with such assurances of compliance with SAE J576c as Bosch deems suitable to support its own assurances in turn to the vehicle manufacturer, enabling the vehicle manufacturer to certify that it meets all applicable Federal motor vehicle safety standards. There is no legal requirement that the plastics manufacturer conduct an actual 3-year test in order to provide Bosch with these assurances. Because our temporary exemption procedures involve a process of three to four months duration, and are not retroactive in applicability, there appears to be no feasible way to consider an exemption. You have asked that this request be treated 'as a confidential business information.' We are unable to do so in this instance because our interpretations are a matter of public record, and the matters discussed herein cannot be separated from our earlier interpretation which has been made available to the public. However, we have removed your name from the copy of this letter that will be publicly available. Furthermore, Taylor Vinson has removed the name of your customer from the publicly available copy of the earlier interpretation, in accordance with the concern you expressed to him in a phone call, and we believe that this meets the intent of your request. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam0460OpenMr. S. Nishibori, Engineering Representative, Liaison Office in U.S.A., Nissan Motor Co., Ltd., 400 County Avenue, Secaucus, NJ, 07094; Mr. S. Nishibori Engineering Representative Liaison Office in U.S.A. Nissan Motor Co. Ltd. 400 County Avenue Secaucus NJ 07094; Dear Mr. Nishibori: In your letter of October 14 you ask whether reflex reflectors on th tail gate of a pick-up truck, as shown in Figure 1 of the drawings you enclosed, meet the requirements of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Standard No. 108 requires, in part, that reflex reflectors be mounte 'on the rear' of a vehicle. Compliance with the requirements of Standard No. 108 is judged with the vehicle in its normal road operating condition. In our view, a pick-up truck is normally operated with the tail gate in a closed position, and the reflex reflectors mounted as shown in Figure 1 appear to meet the rear reflector location requirements of Standard No. 108.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam1701OpenMr. Charles O. Verrill, Jr., Messrs. Patton, Boggs & Blow, 1200 Seventeenth Street, N.W., Washington, DC, 20036; Mr. Charles O. Verrill Jr. Messrs. Patton Boggs & Blow 1200 Seventeenth Street N.W. Washington DC 20036; Dear Mr. Verrill: This is in reply to your two letters of November 8, 1974, on behalf o Trailer Manufacturers Association, requesting interpretations of Standard No. 108 as it applies to boat trailers.; Standard No. 108 requires that clearance lamps be located 'on the rear (Table II) but 'boat trailers need not be equipped with both front and rear clearance lamps, provided an amber (to front) and red (to rear) clearance lamp is located so as to indicate its extreme width' (paragraph S4.1.1.9). You enclose a drawing showing front and rear clearance lamps imbedded in the trailer fender and ask for an interpretation that 'where locating the clearance lamp on the front and rear of the vehicle would not mark the extreme width of the vehicle, the manufacturer shall have the option of locating the clearance lamps as close to the front or rear as practicable in order to mark the overall width of the trailer.'; Paragraph S4.1.1.9 contemplates the use of a double-faced lamp. Thi lamp is generally mounted atop the fender so that the visibility requirements at 45 degrees inboard may be met. Separate lamps also 'located at or near the mid point' would meet the same need for vehicle safety, and would be acceptable, provided that the visibility requirements are also met. This does not seem likely from your proposed configuration, unless the lamps are located above the trailer frame.; You also present the problem of boat trailers on which 'apparatus t hold, load and unload the boat extends from two to four feet beyond the rear frame.' The apparatus overhang may prevent lamps mounted on the rear frame from meeting the visibility requirements of paragraph S4.3.1.1.'You ask for an interpretation 'that would permit the use of detachable light bars where necessary to comply with the visibility requirements of S4.3.1.1.'; There are two solutions to your problem permissible under Standard No 108. The apparatus itself appears to be a permanent and rigid part of the vehicle within the meaning of paragraph S4.3.1, so that the lamps in question could be mounted there and comply with the requirements of the standard. You may not wish to do so, however, because of damage that might be incurred through unloading the immersion in water. In that instance paragraph S4.3.1.1 provides the answer: 'However, if motor vehicle equipment. . . prevents compliance with this paragraph by any required lamp or reflective device, an auxiliary lamp or device meeting the requirements of this paragraph shall be provided'. A detachable light bar would be acceptable as an auxiliary, provided that it complies with the wiring requirements of paragraph S4.5, and the required lighting is retained (in your hypothetical, lamps located at the end of the frame).; We have also received your petition of November 8, 1974, on behalf o Trailer Manufacturers Association to amend Standard No. 108 with respect to boat trailers. You will be informed in due course whether it merits initiation of rulemaking.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam0367OpenMr. Keitaro Nakajima, General Manager, Toyota Motor Co., Ltd., Factory Representative Office, Lyndhurst Office Park, 1099 Wall Street West, Lyndhurst, NJ, 07071; Mr. Keitaro Nakajima General Manager Toyota Motor Co. Ltd. Factory Representative Office Lyndhurst Office Park 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima: This is in reply to your letter of June 1, 1971, to Mr. Douglas W Tome, Acting Administrator, National Highway Traffic Safety Administration, concerning an interpretation relative to the determination of visibility of lamps.; Both of your interpretations are correct. The location of lamps an reflective devices is determined with the vehicle at its curb weight, which is the weight of a motor vehicle with standard equipment, maximum capacity of engine, fuel, oil, and coolant, and, if so equipped, air conditioning and additional weight optional engine.; The overall width is determined with 'doors and windows closed' per th interpretation of 32 F.R. 8088, June 21, 1967.; The visibility requirements for lamps and reflective devices wil therefore be determined with trunk lids, tail gates, hoods, and rear gates in the normal driving, or closed, position.; Sincerely,E. T. Driver, Director, Offices of Operating Systems, Moto Vehicle Programs; |
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ID: aiam5524OpenMr. Robert E. Fouts President Earl's Performance Products 189 W. Victoria St. Long Beach, CA 90805; Mr. Robert E. Fouts President Earl's Performance Products 189 W. Victoria St. Long Beach CA 90805; "Dear Mr. Fouts: This responds to your question whether the whip tes specified in Federal Motor Vehicle Safety Standard No. 106, Brake Hoses, can be interpreted to permit a modification to the test apparatus to facilitate your brake hose's meeting the whip test. As explained below, the answer is no. You describe your brake hose as made of 'extruded teflon armored with stainless steel braid.' You state your brake hose can meet all Standard No. 106 test specifications except for the whip test (See S6.3). The whip test specifies fastening the brake hose on a test apparatus at two ends and cycling for 35 hours. You state because of 'aggravated cyclic stress,' your brake hoses fail before 35 hours. To prevent such failures, you wish to add a 'whip dampener,' a movable 'spherical bearing enclosed in a machined housing', to the brake hose. In addition to the two ends, the whip test apparatus will mount the brake hose at the 'whip dampener.' You wish to know whether the whip test can be interpreted to permit mounting the brake hose at the 'whip dampener.' In our opinion, S6.3 cannot be interpreted to permit mounting the brake hose at the 'whip dampener.' S6.3.1 Apparatus specifies a test apparatus that mounts the brake hose at 'capped end fittings' on one end and 'open end fittings' on the other, and specifies no mounting points in between. Thus, a test apparatus that mounts the brake hose at a 'whip dampener,' which is not an end fitting, would not meet Standard No. 106. However, the issues raised in your letter have led us to consider amending the whip test to permit the 'whip dampener' when testing steel braided brake hoses. Accordingly, we will initiate rulemaking to further consider the issues. I hope this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Philip R. Recht 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.