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: aiam2259OpenMr. L. Frank Hay, President, Beachcomber Industries Ltd., P.O. Box 1660, North Railway Avenue, Morden, Manitoba R0G 1J0; Mr. L. Frank Hay President Beachcomber Industries Ltd. P.O. Box 1660 North Railway Avenue Morden Manitoba R0G 1J0; Dear Mr. Hay: This is in response to your December 31, 1975, letter concernin certification of the travel trailer that you manufacture.; This Department does not certify or otherwise issue advance approval of motor vehicles or motor vehicle equipment. Certification, under applicable law and regulations, must be done by the manufacturer. The Canadian and U.S. motor vehicle safety standards are not identical, so you must ensure that your travel trailers do in fact comply with all of the latter that are applicable. A pamphlet summarizing the U.S. Federal motor vehicle safety standards is enclosed, along with a copy of the regulations governing vehicle certification. The safety standards themselves are set forth in their entirety in Part 571 of Title 49 of the Code of Federal Regulations.; Please note that Section 110(e) of the National Traffic and Moto Vehicle Safety Act (15 U.S.C. S 1399(e)) requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United States to designate a permanent resident of the United States as his agent, upon whom service of all processes, orders, notices, decisions, and requirements may be made. Our records indicate that Beachcomber Industries Ltd. has not complied with this requirement.; The procedural regulations (49 CFR 551.45) for designation of agen pursuant to the Act require:; >>>(1) A certification by its maker that the designation is binding o Beachcomber Industries Ltd. under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made,; (2) The full legal name, principal place of business and mailin address of Beachcomber Industries Ltd.,; (3) Trade names or other designations of origin of the products o Beachcomber Industries Ltd. that do not bear its legal name,; (4) A provision that the designation remain in effect until withdraw or replaced by Beachcomber Industries Ltd.,; (5) A declaration of acceptance duly signed by the agent appointed which may be an individual, a firm, or a U.S. corporation, and; (6) The full legal name and address of the designated agent.<<< In addition, the designation must be signed by one with authority t appoint the agent, the signer's name and title should be clearly indicated beneath his signature.; Please note further that you are required by 49 CFR Part 566 *Manufacturer Identification*, to submit certain information to the NHTSA not more than 30 days after your vehicles begin to be imported into the United States. Copies of this regulation and the procedural regulations for designation of agent are also enclosed for your convenience.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0677OpenMr. W.W. Marsh, Executive Vice President, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, D.C. 20005; Mr. W.W. Marsh Executive Vice President National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Marsh: This is in reply to your letter of April 5, 1972, concerning th amendment to Motor Vehicle Safety Standard No. 117, published March 23, 1972 (Docket 1-8, Notice 7,37 F.R. 5950). In your letter you protest against the labeling requirements of the standard. It is not clear from your letter, however, whether you are referring to both the requirements for affixed labels (S6.3.1), or for permanent labeling (S6.3.2), or both, and as a consequence we have treated your comments as referring to the labeling requirements in general.; You state in your letter that retreaders, particularly smal retreaders, cannot meet the labeling requirements 'on any reasonable and practical basis.' You state further that you have demonstrated haw the labeling requirements will force retreaders to hire additional personnel, increase production time, and consequently increase the retreaders' cost per tire. You also claim that the labeling issue is a 'fairly simple problem' whose solution can be easily found within the statutes.; Congress, in enacting section 201 of the National Traffic and Moto Vehicle Safety Act, made it clear that motor vehicle tires should be permanently labeled with specific items of information dealing with their safe use. The labeling requirements of Standard No. 117 are based on this statutory mandate and do recognize and allow for difficulties retreaders might have in meeting all of the requirements for labeling set forth in section 201. For example, Standard No. 117, in not requiring that the generic name of the cord material or the actual number of plies be included in the labeling information for retreaded tires, recognizes that this information will not be available for some casings which are allowed to be used.; The NHTSA considers the labeling requirements of Standard No. 117 to b both reasonable and practical, and believes they can be met by the overwhelming majority of retreaders, if not all, in an economical manner. Each item of information is now available to the retreader should the need to relabel arise. By using the procedures and technology developed for compliance with the Tire Identification and Recordkeeping regulations (49 CFR Part 574), by combining labeling information on the same label where appropriate, and by careful sorting of casings before retreading, the NHTSA believes that even the smallest retreader can meet these requirements. While the requirements will no doubt cause some changes in existing production techniques, with a possible slowing initially of the production process, there is no reason to believe that these changes, once instituted, will result in significant permanent increases in the costs and time needed for the production of retreaded tires.; Finally, you cite figures showing what you claim is an abnormally hig number of retreaded tire manufacturers who have gone out of business in the past year, and ask, 'How many more will be lost before we get reasonable and practical and understandable regulations?' We understand your concern for retreading companies that have gone out of business. But since Standard No. 117 has not yet become effective, these closings are obviously not the result of NHTSA regulations.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam2155OpenMr. Benjamin C. Throop, Senior Vice President, Administration, Transcon Lines, P.O. Box 92220, Los Angeles, CA 90009; Mr. Benjamin C. Throop Senior Vice President Administration Transcon Lines P.O. Box 92220 Los Angeles CA 90009; Dear Mr. Throop: Thank you for your December 6, 1976, letter in which you detail th difficulties experienced by Transcon Lines with certain antilock devices installed in satisfaction of Standard No. 121, *Air Brake Systems*. You explain that Transcon disconnected both defective and potentially defective antilock devices, and you ask for an explanation of your legal responsibilities for the disconnections under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1391, *et seq*.).; After the first purchase of the vehicles for purposes other tha resale, the only statutory prohibition against disconnection of safety equipment such as the antilock system is found in S 108(a)(2)(A) which provides:; >>>S108(a)(2) (2)(A) No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, 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 [except for repair]. . . .<<<; A person that does not fall within the enumerated categories is no prohibited from disconnection of the antilock system after purchase. Also, I have spoken to Federal Highway Administration officials who assure me that, because a defective system is involved, the Bureau of Motor Carrier Safety would not require that the system be connected.; Two National Highway Traffic Safety Administration (NHTSA) staf engineers visited the manufacturer of the antilock systems installed on the tractors and trailers in question to investigate the problems you describe. In replacing the sensors on the trailers, it was discovered that improperly manufactured exciter rings (all produced on August 9, 1976) appear to be the source of the problem. In addition to agreeing to replace all the sensors on the trailers in question, the antilock manufacturer has identified all of the sensors manufactured on the day in question and has initiated a defect recall campaign with the NHTSA. In the case of tractor malfunction, a shuttle valve that has been used for years on trailers appears to be sticking because of excessive corrosion on the particular vehicles in question. It is our understanding that the rate of air loss caused by the sticking can be compensated for by the air compressor and does not pose a safety hazard.; With regard to your concern that the systems 'fail safe,' Standard No 121 specifies that 'electrical failure of any part of the antilock system shall not increase the actuation and release times of the service brakes' (S5.5.1). This provision does not require that the system be completely incapable of malfunction, but the manufacturers have made concerted efforts to make the systems 'fail safe.' Quite apart from the requirements of the standard, each of the antilock manufacturers faces the same prospects for product liability suits on its antilock products as in the case of any other of its products.; We will continue to monitor the defect campaign efforts of the antiloc manufacturer to ensure that an unsafe condition does not arise.; Sincerely, John W. Snow, Administrator |
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ID: aiam1833OpenMr. M. W. Kletzli, Director, Parts and Service Operations, Brockway Motor Trucks, 106 Central Avenue, Cortland NY 13045; Mr. M. W. Kletzli Director Parts and Service Operations Brockway Motor Trucks 106 Central Avenue Cortland NY 13045; Dear Mr. Kletzli: This is in acknowledgment of your quarterly report submitted on Januar 31, 1975, in accordance with the defect reporting regulations, Part 573. Enclosed with your report were copies of the owner notification letters, service bulletins, and other information concerning your safety campaign (your No. 218) involving some 700 Series L and LL model trucks which may experience automatic application of the spring brakes caused by use of an air line which is too large.; This office has no record of this campaign and did not receiv knowledge of it prior to your January 31 report. Since your owner letters and service bulletins were mailed in October of 1974, it appears that you did not comply with the 5 working day time limit for submitting defect reports specified in Part 573 (49 CFR). You are therefore cautioned that all future reports must be submitted on a timely basis. A failure to do so may result in the imposition of civil penalties and injunctive sanctions against your company.; The National Highway Traffic Safety Administration identificatio number *75-0024* has been assigned to this campaign. Please refer to this number in all future correspondence concerning this campaign. The second quarterly status report for this campaign is required to be submitted by May 6, 1975. A full and complete Defect Report in accordance with Part 573 must also still be submitted for this campaign.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam3586OpenMr. William R. Harris, Jr., Harris Enterprises, Box 999-94, Westport, CT 06880; Mr. William R. Harris Jr. Harris Enterprises Box 999-94 Westport CT 06880; Dear Mr. Harris: This is in reply to your letter of July 1, 1982, to Mr. Vinson of thi office with regard to your 'new motorcycle lighting system' and asking about possible conflicts with the Federal motor vehicle safety standards.; Your device is an 'aftermarket accessory' light which may be mounted t a motorcycle helmet, and which is integrated by a cord into the motorcycle's headlighting system, providing an auxiliary beam of light in conjunction with the beam of light projected by the main headlamp.; Federal Motor Vehicle Safety standard No. 108, *Lamps, Reflectiv Devices, and Associated Equipment*, is the standard on vehicle lighting and lighting equipment while Standard No. 218, *Motorcycle Helmets*, is the other standard of relevance. Neither standard directly addresses an aftermarket device such as your and as your lamp is intended to be installed by the helmet owner, it does not appear to conflict with any other regulatory prohibition of this agency. It would, therefore, be subject to regulation by the individual States in which the device is worn.; We see nothing in your correspondence that legally qualifies a 'sensitive proprietary information', and our interpretation will be given its usual circulation.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4328OpenMr. T. Chikada, Manager, Automotive Lighting, Engineering Control Department, Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. T. Chikada Manager Automotive Lighting Engineering Control Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Chikada: This is in reply to your letter of March 4, 1987, with reference t aiming adjustment of fog lamps. We understand that Stanley is developing a fog lamp and replaceable bulb headlamp with a common lens and housing. Since the portion of the housing also functions as a reflector, the fog lamp moves simultaneously with the headlamp in aiming adjustment. In your view, it will not impair the effectiveness of the headlamp, and you ask for confirmation that the lamp 'is acceptable in the U.S.A.; Federal Motor Vehicle Safety Standard No. 108 contains no requirement for a fog lamp, and would prohibit it only if it impaired the effectiveness of any other lamp mounted on the front of a vehicle that is required by the standard. Assuming that the fog lamp does not impair the effectiveness of the headlamp, its installation would not crate a noncompliance with Standard No. 108. However, in the absence of a Federal standard on fog lamps, the individual States may establish their own requirement for fog lamps. We are unable to advise you whether this design would be acceptable in each of the 50 States, and other jurisdictions in which the Federal standards must be met, we can only advise you that it does not appear prohibited by Federal law.; The American Association of Motor Vehicle Administrators (AAMVA). 120 Connecticut Avenue, N.W., Washington, D.C., 20036 may be able to advise you as to state laws relevant to your design.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam3418OpenMr. John Y Yonezawa, Tokai Rubber Industries, Ltd., 3600, Kita Toyama, Komaki City, Aichi Pref. 485, Japan; Mr. John Y Yonezawa Tokai Rubber Industries Ltd. 3600 Kita Toyama Komaki City Aichi Pref. 485 Japan; Dear Mr. Yonezawa: This responds to your recent letter regarding several new kinds o plastic vacuum brake hoses that you plan to manufacture. The plastic brake hoses are flexible nylon tubes for use in a vacuum braking system. You indicate that these hoses cannot comply with several provision of Safety Standard No. 106, and ask whether the plastic hoses could qualify as 'vacuum tubing connectors.'; Safety Standard No. 106 (49 CFR 571.106) specifies performance an labeling requirements for brake hose, which is defined in the standard as:; >>>a flexible conduit, other than a vacuum tubing connector manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.'<<<; Since the nylon tubes which you plan to manufacture will transmit th vacuum used to apply force to a vehicle's brakes, the tubes would qualify as 'brake hose' under this definition and would be subject to all requirements of Safety Standard No. 106. Moreover, it appears that the nylon tubes would not qualify as 'vacuum tubing connectors,' which are excepted from compliance with the standard in the definition of brake hose. Section 4 of Safety Standard No. 106 defines 'vacuum tubing connector' as:; >>>a flexible conduit of vacuum that (i) connects metal tubing to meta tubing in a brake system, (ii) is attached without end fittings, and (iii) when installed, has an unsupported length less than the total length of those portions that cover the metal tubing.'<<<; According to the illustrated drawings included in your letter, th nylon flexible tubes with which you are concerned would have an unsupported length which is greater than the total length of those portions that cover metal tubing. Therefore, the nylon tubes would not qualify as 'vacuum tubing connectors' under subsection (iii) of the above definition. The purpose of the definition is to except from compliance with the standard only those vacuum connectors that have unsupported lengths short enough that they will not sag or deflect because of their own weight. While your nylon tubes may be sturdy enough to meet this intended purpose, as the definition is currently written, the tubes cannot be considered vacuum tubing connectors.; If, as your letter indicates, the nylon brake hose does not comply wit all requirements of Safety Standard No. 106, you would not be permitted to sell it in the United States. You may wish to petition the agency to amend Standard No. 106 to establish separate performance requirements specifically designed for nylon vacuum tubing such as that produced by Tokai. I am enclosing a copy of the procedures which explain how you can file a petition, in case you are interested.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4657OpenMr. Karl-Heinz Faber, Vice President Product Compliance Service and Parts Mercedes-Benz of North America, Inc. P.O. Box 350 Montvale, NJ 07645-0350; Mr. Karl-Heinz Faber Vice President Product Compliance Service and Parts Mercedes-Benz of North America Inc. P.O. Box 350 Montvale NJ 07645-0350; Dear Mr. Faber: This is in reply to your letter of August 9, l989, wit respect to the interpretation of the word 'headlamp' as it appears in paragraph S7.2 of Motor Vehicle Safety Standard No. 108. In pertinent part, this paragraph specifies that certain markings shall be placed on the lens of each headlamp, with 'each headlamp' to be marked with the voltage and part or trade number. Noting that 'headlamp' is not a defined term but 'replaceable bulb headlamp' is, you have asked for confirmation that marking the lens, the reflector, or the light source with the voltage would be in compliance with paragraph S7.2. The agency intends that the voltage be indicated on the exterior of the headlamp. If the manufacturer does not wish to put it on the lens, Standard No. 108 will permit, as of December 1, l989, voltage marking to be on an exterior part of the headlamp body, but not on the light source. I hope that this answers your question. Sincerely Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam4671OpenMr. Dennis T. Johnston Senior Executive Engineer Product Engineering and Regulatory Affairs Sterling Motor Cars 8953 N.W. 23rd Street Miami, Florida 33172; Mr. Dennis T. Johnston Senior Executive Engineer Product Engineering and Regulatory Affairs Sterling Motor Cars 8953 N.W. 23rd Street Miami Florida 33172; "Dear Mr. Johnston: This responds to your letter reporting a change i the locking system to be installed on the MY 1991 British Sterling car line. Although your letter does not explicitly request the agency determine that the change is of a de minimis nature and that therefore the Sterling vehicles containing the change would be fully covered by the previously granted exemption for Sterling vehicles, we are treating the letter as making such a request. The alternative to making such a request is to submit a modification petition under 49 CFR 543.9(b) and (c)(2). As you are aware, the Sterling car line was granted an exemption, pursuant to 49 CFR Part 543, from antitheft marking because Austin Rover showed that the antitheft device to be used in lieu of marking on the car line was likely to be as effective as parts marking. This exemption was issued on July 16, 1986, and appeared in the Federal Register on July 22, 1986 (51 FR 26332). In your letter, you stated that beginning with the start of MY 1991, Sterling Motor Cars (Sterling) plans an improvement in the antitheft device that is standard equipment on the Sterling vehicle. The change involves the consequence of opening of the trunk when the system is armed. Currently, the system, once armed, activates when the trunk is opened, even if it is opened with the key. In order to avoid this, the antitheft device must first be disarmed before the trunk is opened. It is our understanding that Sterling plans to change the system by allowing the system to be disarmed by opening the trunk with a key and rearmed by closing the trunk lid. However, if the trunk were to be forced open without a key, the alarm would still be activated. After reviewing the planned change to the antitheft device on which the exemption was based, the agency concludes that the change is de minimis. While the change means that opening the trunk with a key will no longer activate the alarm, the agency does not believe that activating the alarm under those circumstances contributes to theft prevention. The agency concludes that the antitheft device, as modified, will continue to provide the same aspects of performance provided by the original device and relies on essentially the same componentry to provide that performance. Therefore, it is not necessary for Sterling to submit a petition to modify the exemption pursuant to 543.9(b) and (c)(2). If Sterling does not implement the new antitheft device as described in your letter, or delays implementation until after MY 1991, we request that Sterling notify the agency of such decisions. Sincerely, Barry Felrice Associate Administrator for Rulemaking"; |
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ID: aiam4851OpenMs. Jessie M. Flautt 4405 Lafayette Street Bellaire, TX 77401; Ms. Jessie M. Flautt 4405 Lafayette Street Bellaire TX 77401; "Dear Ms. Flautt This responds to your letter to Mr. Steve Kratzke o my staff, requesting that the National Highway Traffic Safety Administration (NHTSA) grant permission to a repair business to modify your motor vehicle. You explained that you are under five feet, two inches and legally blind in one eye. You further explained that, due to the increased size of headrests in recent years, you are unable to locate a 1991 automobile which does not have headrests which impede your field of vision. You wish to arrange to have the size of the headrests in a 1991 automobile reduced. You asked if you could obtain permission from this agency to permit this modification. I hope the following discussion explaining our regulation will be of assistance to you. I would like to begin by clarifying that there is no procedure by which persons petition for and are granted permission from NHTSA to arrange to have a motor vehicle repair business modify their motor vehicle. Repair businesses are permitted to modify vehicles without obtaining permission from NHTSA to do so, but are subject to certain regulatory limits on the type of modifications they may make. In certain limited situations, we have exercised our discretion in enforcing our regulations to provide some allowances to a repair business which cannot conform to our regulations when making modifications to accommodate the special needs of persons with disabilities. Since your situation is among those given special consideration by NHTSA, this letter should provide you with the relief you seek. Our agency is authorized to issue Federal Motor Vehicle Safety Standards (FMVSS) that set performance requirements for new motor vehicles and items of motor vehicle equipment. Manufacturers are required by the National Traffic and Motor Vehicle Safety Act (Safety Act) to certify that their products conform to our safety standards before they can be offered for sale. Manufacturers, distributors, dealers and repair businesses modifying certified vehicles are affected by 108(a)(2)(A) of the Safety Act. It prohibits those businesses from knowingly rendering inoperative any elements of design installed on a vehicle in compliance with a FMVSS. In general, 108(a)(2)(A) would require repair businesses which modify motor vehicles to ensure that they do not remove, disconnect or degrade the performance of safety equipment installed in compliance with an applicable safety standard. Violations of 108(a)(2)(A) are punishable by civil fines up to $1,000 per violation. In situations such as yours where a vehicle must be modified to accommodate the needs of a particular disability, we have been willing to consider any violation of 108(a)(2)(A) a purely technical one justified by public need. I can assure you that NHTSA would not institute enforcement proceedings against a repair business that modifies the headrest on your vehicle to accommodate your condition. We caution, however, that only necessary modifications should be made to the headrest to accommodate your condition and we urge your dealer to modify your vehicle in such a manner that would not degrade from the safety currently provided by your vehicle. Many manufacturers are currently installing headrests in vehicles which exceed the minimum dimensions required by FMVSS No. 202, Head Restraints. I urge you not to have your headrest reduced below these dimensions if it is not necessary for your field of view. If you have further questions or need some additional information in this area, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice 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.