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: aiam2022OpenMr. Dennis Replansky, Four Penn Center Plaza, Philadelphia, PA 19103; Mr. Dennis Replansky Four Penn Center Plaza Philadelphia PA 19103; Dear Mr. Replansky: This responds to your recent request for a discussion of wha constitutes the manufacture of a new trailer when used components from an existing trailer are utilized. As you are aware, a newly-manufactured air-braked trailer must, in all but a few cases, be equipped with an air brake system that conforms to Standard No. 121, *Air Brake Systems*.; The use of new components in combination with used components t assemble a complete vehicle is a common practice in both truck and trailer operations. The National Highway Traffic Safety Administration (NHTSA) has recognized this commercial practice by establishing that the use of a new body on a used 'chassis' that has already been certified does not constitute the manufacture of a new vehicle. In contrast, placing a used body on a new chassis that has never been certified as a vehicle has been determined to create a newly-manufactured vehicle that must be certified. This distinction did not present difficulty to trailer manufacturers in the past, when they were only required to meet the lighting requirements of Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Since implementation of Standard No. 121, however, manufacturers hav had to determine whether the particular assembly they undertake contains a used 'chassis' which would not be required to meet the air brake standard. As a general matter, the NHTSA has stated that, as a minimum, the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and main frame of the existing vehicle must be used to qualify as a used 'chassis'. However, the many different types of trailer construction make it difficult to determine what constitutes the main frame of some configurations. The NHTSA has concluded that the load-bearing structural member(s) which run the length of the vehicle and support the trailer will be considered to be the 'main frame'.; In the case of monocoque van construction, the trailer side walls whic constitute the main load-bearing members through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of container chassis, the box frame that consitutes (sic the main load- bearing member through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of a platform trailer, the main frame members which run th length of the trailer must be reused in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of a tank trailer in which the tank serves the purpose o and replaces frame rails, the tank must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle. If a separate frame serves as the load-bearing member through the length of the vehicle, the tank could be replaced without the operation constituting the manufacture of a new vehicle. An inner tank may be replaced without certification as a new vehicle if the inner tank does not serve as a main load-bearing member.; Modifications of existing trailers to increase or decrease volumetri capacity or vehicle length are generally permitted without recertification. For example, the barrel of a tank trailer may be lengthened in response to the new weight limits without recertification of the vehicle.; In closing, it should be noted that Bureau of Motor Carrier regulation may differ on modification or rebuilding of vehicles in interstate commerce.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2067OpenMr. Eugene D. Sambucetti, Wesco Truck & Trailer Sales, P.O. Box 626, Woodland, CA 95695; Mr. Eugene D. Sambucetti Wesco Truck & Trailer Sales P.O. Box 626 Woodland CA 95695; Dear Mr. Sambucetti: This responds to your recent request for a discussion of wha constitutes the manufacture of a new trailer when used components from an existing trailer are utilized. As you are aware, a newly-manufactured air-braked trailer must, in all but a few cases, be equipped with an air brake system that conforms to Standard No. 121, *Air Brake Systems*.; The use of components in combination with used components to assemble complete vehicle is a common practice in both truck and trailer operations. The National Highway Traffic Safety Administration (NHTSA) has recognized this commercial practice by establishing that the use of a new body on a used 'chassis' that has already been certified does not constitute the manufacture of a new vehicle. In contrast, placing a used body on a new chassis that has never been certified as a vehicle has been determined to create a newly-manufactured vehicle that must be certified. This distinction did not present difficulty to trailer manufacturers in the past, when they were only required to meet the lighting requirements of Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; Since implementation of Standard No. 121, however, manufacturers hav had to determine whether the particular assembly they undertake contains a used 'chassis' which would not be required to meet the air brake standard. As a general matter, the NHTSA has stated that, as a minimum, the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and main frame of the existing vehicle must be used to qualify as a used 'chassis'. However, the many different types of trailer construction make it difficult to determine what constitutes the main frame of some configurations. The NHTSA has concluded that the load-bearing structural member(s) which run the length of the vehicle and support the trailer will be considered to be the 'main frame'.; In the case of monocoque van construction, the trailer side walls whic constitute the main load-bearing members through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of container chassis, the box frame that consitutes (sic the main load- bearing member through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of a platform trailer, the main frame members which run th length of the trailer must be reused in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.; In the case of a tank trailer in which the tank serves the purpose o and replaces frame rails, the tank must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle. If a separate frame serves as the load-bearing member through the length of the vehicle, the tank could be replaced without the operation constituting the manufacture of a new vehicle. An inner tank may be replaced without certification as a new vehicle if the inner tank does not serve as a main load-bearing member.; Modifications of existing trailers to increase or decrease volumetri capacity or vehicle length are generally permitted without recertification. For example, the barrel of a tank trailer may be lengthened in response to the new weight limits without recertification of the vehicle.; In closing, it should be noted that Bureau of Motor Carrier regulation may differ on modification or rebuilding of vehicles in interstate commerce.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam2048OpenMr. Martin Rothfield, General Manager, Flasher Division, Ideal Corporation, 1000 Pennsylvania Avenue, Brooklyn, NY 11207; Mr. Martin Rothfield General Manager Flasher Division Ideal Corporation 1000 Pennsylvania Avenue Brooklyn NY 11207; Dear Mr. Rothfield: This is in reply to your letter of August 11, 1975. You ask fo confirmation that 'variable load flashers are permitted as replacement equipment by Federal Motor Vehicle Safety Standard No. 108 for any vehicle contemplated by Paragraph S2 of the Standard, where such devices shall operate in accordance with the appropriate Tables of the Standard.' You noted that some suppliers were under the impression that variable load flashers, which do not provide a failure indication, were not permitted as after-market replacements for fixed-load flashers.; The confusion apparently arose when the agency amended S4.5.6 o Standard No. 108 (June 6, 1974, 39 FR 20063) to permit variable-load flashers to be used (*i.e.*, to except from the failure indicator requirement) on trucks capable of accommodating slide-in campers (as well as vehicles of 80 inches or more overall width and those equipped to tow trailers, as provided by S4.5.6 before the amendment). To specify its intent more definitely, the amendment added the words, 'where a variable-load turn signal flasher is used,' to the exception to the requirement for a failure indicator. Some persons evidently thought that the new, explicit reference to variable-load flashers meant that such flashers could not be used as replacement equipment where the vehicles originally had fixed-load flashers.; That was not the agency's intent. The language was only added to mak it clear that where a fixed-load flasher is installed as original equipment, a failure indicator must be included. But a variable- load flasher may be used as replacement equipment for a fixed- load flasher on any of the vehicle classes specified in S2 as covered by the standard.; Incidentally, the statement in your letter that the June 1974 amendmen 'concerned itself only with original equipment applications' is incorrect. S2 of the standard states in pertinent part that it applies to 'lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies.' This means that equipment must comply with applicable requirements regardless of whether it is used as original or replacement equipment. For example, original and replacement variable load flashers must both meet the appropriate requirements of SAE Standard J590b, 'Automotive Turn Signal Flashers,' October 1965.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam4886OpenMr. Charles Stansell 5414 Robin Road Garland, TX 75043; Mr. Charles Stansell 5414 Robin Road Garland TX 75043; "Dear Mr. Stansell: This responds to your letter requesting informatio about the labeling requirements in Federal Motor Vehicle Safety Standard No. 218, Motorcycle Helmets (49 CFR 571.218). You posed two questions. First, you asked if it was true that 'the law does not prohibit anyone from removing a DOT sticker?' The DOT sticker to which you refer is the helmet manufacturer's certification that the helmet complies with Standard No. 218. Federal law prohibits any manufacturer, distributor, dealer, or repair business from removing the certification from the helmet. Federal law does not prohibit individual owners from removing the DOT certification from their own motorcycle helmets, but State law may do so. You will need to contact officials in the State of Texas to learn if there is such a prohibition in your State. Second, you asked if it was true that a 'large number' of motorcycle helmets manufactured before October 3, 1988 are not considered in violation of Standard No. 218 even though they do not have the DOT certification sticker. It is true that not all helmets manufactured before October 3, 1988 were subject to Standard No. 218. Those helmets that could not fit on the test headform (typically the small and extra small helmets) were not subject to the standard, and were not labeled with a DOT certification. However, the total population of helmets that were too small to fit on the headform was only approximately 10 percent of all helmets. The remaining 90 percent of helmets manufactured before October 3, 1988 were subject to Standard No. 218 and were required to be certified by means of a DOT sticker. All motorcycles helmets manufactured on or after October 3, 1988 are required to be certified as complying with Standard No. 218. For your information, I have enclosed two of our interpretation letters that provide detailed responses to the issues raised in your letter. These two letters are a December 8, 1988 letter to Mr. Wayne Ivie of the Oregon State Department of Transportation and a December 4, 1987 letter to Mr. Larry Hoppe. I have also enclosed a NHTSA information sheet on motorcycle helmets. I hope this information is helpful. If you have any further questions or need additional information, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam5326OpenMr. Steve J. Brooks Program Manager IAD West Coast, Inc. 5761 McFadden Avenue Huntington, Beach CA 92649; Mr. Steve J. Brooks Program Manager IAD West Coast Inc. 5761 McFadden Avenue Huntington Beach CA 92649; "Dear Mr. Brooks: This responds to your letter asking about th operation and classification of a commercial vehicle you wish to manufacture. The vehicle will carry fewer than 10 passengers and its GVWR will be 11,500 pounds. You were particularly interested in the type of operator's license that would be required of the driver. Driver licensing requirements for vehicle operators are determined by state law. Since the vehicle's GVWR will be less than 26,000 lbs, and the vehicle will presumably be designed to carry fewer than 15 passengers, the driver will not be required, under the Federal Highway Administration's (FHWA's) Commercial Driver Licensing (CDL) regulations, 49 CFR part 383, to qualify for a commercial driver license. However, some states require that drivers obtain a commercial driver license to drive vehicles that have lower GVWRs. The driver licensing requirements of the state in which the vehicle is registered, will apply. For more information about the CDL requirements, you can contact the FHWA Chief Counsel's office at (202) 366-0834. Vehicle classification is relevant for the regulations and standards of our agency. The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and motor vehicle equipment. Each FMVSS for motor vehicles applies to one or more particular types of vehicles, e.g., a standard might apply to passenger cars, buses, trucks, and/or trailers. To determine which FMVSSs apply to their vehicles, manufacturers classify their vehicles using the definitions in 49 CFR part 571.3 of NHTSA's regulations. Under part 571.3 (copy enclosed), your vehicle, which you said is built in a bus/truck chassis, appears to be a 'truck' or a 'multipurpose passenger vehicle.' Under part 567, a manufacturer must state the vehicle classification on the vehicle's certification label and certify that its motor vehicle complies with all applicable FMVSSs. NHTSA may take issue with a manufacturer's vehicle classification in an enforcement proceeding if the agency does not agree with the manufacturer's classification. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam5398OpenHerr P. Binder ITT Automotive Europe GmbH Bietigheim-Bissingen Germany; Herr P. Binder ITT Automotive Europe GmbH Bietigheim-Bissingen Germany; FAX 07142/73-2895 Dear Herr Binder: This responds to your FAX of Apri 28, 1994, to Taylor Vinson of this Office, requesting an interpretation of Motor Vehicle Safety Standard No. 108. Your letter shows a rear motor vehicle lighting array of four lamps, two on the body ('Rearlamp 1') and the other on the tailgate ('Rearlamp 2'). The four lamps appear to be equal in size. You cite the requirement of Standard No. 108 and 'SAE J588e Sept. 77' that the lamp must 'provide an unobstructed projected illuminated area of 12.5 cm2 measured at 45 deg.' and state that this 'will not be performed by Rearlamp 1 because of the tailgate, however, the requirement is met by Rearlamp 2 and will be met by Rearlamp 1 if the tailgate is open. You have asked whether such a system is allowed. First, a correction. There has never been a standard known as 'SAE J588e Sep. 77.' We believe that your are referring to SAE Standard J588e September 1970, which is incorporated by reference in Standard No. 108, but now applies only to certain replacement turn signal lamps (See S5.8.4(b)). The standard that applies to new passenger car designs such as you have depicted is SAE J588 NOV84 Turn Signal Lamps for Use on Motor Vehicles Less than 2032 mm in Overall Width. The visibility requirements, however, remain as you have stated. They are set forth in paragraph 5.4.1 of SAE J588 NOV84. As you have noted, the turn signal lamps must be visible through horizontal angles of 45 degrees to the right or left, depending on whether they are mounted on the right or left. To be considered visible, 'the lamp must provide an unobstructed view of the outer lens surface . . . of at least 12.5 cm2 measured at 45 deg. to the longitudinal axis of the vehicle.' We believe that the design depicted is in accordance with Standard No. 108. It is, in operation, a turn signal lamp system of two lamps on each side of the vehicle. Contrary to your assertion, we believe that the outer lamp on each side, Rearlamp 1, will meet the visibility requirements when the tailgate is in place because visibility must be met only at 45 degrees outboard (the agency judges compliance with the vehicle in its normal operating condition, that is to say, with the tailgate closed). Thus, under Standard No. 108, Rearlamp 2 is regarded as a permissible supplementary turn signal lamp. I hope that this is helpful to you. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam3539OpenH. A. Kendall, Ph.D., United Sidecar Association, Inc., 1621 Palomino Lane, Kingwood, TX 77339; H. A. Kendall Ph.D. United Sidecar Association Inc. 1621 Palomino Lane Kingwood TX 77339; Dear Dr. Kendall: This is in reply to your letter of February 20, 1982, with respect t pulsating headlamps.; You have interpreted my letter of February 9, 1982, as stating tha 'for daytime operation of a motorcycle headlight, the light may be permitted to pulsate or modulate from one level of brightness to another.' On the contrary, I stated that 'a lamp whose intensity varies from a higher output to a lower output...would be prohibited.' However, I also stated that, if complete deactivation occurs (i.e., from a higher output to no output), then that mode of operation is permissible.; With respect to your latest letter and the problems of headlighting i older motorcycles, there would be no need to have the smaller bulb illuminated, and the 'definite on/off/on/off sequence' you mention is sufficient for compliance with Standard No. 108.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam0526OpenMr. Wayne Myers, Angle Product Company, 11830 Brookpark Road, Cleveland, OH 44130; Mr. Wayne Myers Angle Product Company 11830 Brookpark Road Cleveland OH 44130; Dear Mr. Myers: This is in further response to the telephone inquiries you made o December 14, 1971, concerning the effective date of Federal Motor Vehicle Safety Standards (sic) No. 206 with respect to trucks.; You stated that you understood that the original January 1, 1972 effective date had been or would be postponed to September 1, 1972. No such postponement has been made or proposed. The standard will go into effect with respect to trucks on the first of this coming year, as originally scheduled.; Your source of information may have confused the effective date of th standard with that of a minor proposed amendment to the standard. That amendment, which was to become effective on January 1, 1972, is now scheduled to become effective September 1, 1972. A copy of that proposed amendment is enclosed for your information.; You also asked about the existence of a mailing list which would enabl you to receive our new standards and amendments to our existing standards. The Government Printing Office periodically publishes supplements to a loose-leaf publication entitled 'Federal Motor Vehicle Safety Standard (sic) and Regulations.' The most recent supplement, number 5, was published in November of this year. Detailed information concerning this service, including its cost, can be obtained from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402.; If you wish to receive our proposed, as well as our final, new standar (sic) and amendments, you should consider subscribing to the *Federal Register*. A year's subscription to this publication, which costs $25.00, can be ordered from the Superintendent of documents.; Please write if we can be of further assistance. Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3517OpenThe Honorable Phil Sharp, House of Representatives, Washington, DC 20515; The Honorable Phil Sharp House of Representatives Washington DC 20515; Dear Mr. Sharp: This responds to your recent letter requesting information on behalf o your constituent, Mr. Mark Lecher. Mr. Lecher is under the impression that there is some new law 'banning cars with dark-tinted windows.' He is particularly concerned that he will have to replace the windows on his Datson (sic) pickup.; The National Highway Traffic Safety Administration issues safet standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. There is a safety standard which specifies performance and location requirements for glazing materials used on motor vehicles (Standard No. 205). However, the requirements of this standard as they relate to tinting have not changed in years. The standard currently requires the windshield and front side windows in cars and trucks (i.e., windows necessary for driving visibility) to have a luminous transmittance of at least 70 percent. Other windows may be tinted as darkly as the manufacturer wishes. If the windows in Mr. Lecher's pickup were factory-installed, they are presumably in compliance with Standard No. 205. Therefore, Mr. Lecher should not worry about having to alter his windows. There is no new Federal law or regulation, nor any proposed rule, to change the requirements of Standard No. 205 in this regard.; Mr. Lecher might be referring to a State law or regulation. W understand that some states are considering prohibitions against the use of dark tinting films which can be applied to existing vehicle windows. Such State laws would not require Mr. Lecher to alter the windows on his pickup, however, if the windows are the original glazing installed by the manufacturer in compliance with the Federal standard. This is because Section 103(d) of the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1392, *et seq*.) pre-empts any state law which is applicable to the same aspect of performance as a Federal safety standard.; Standard No. 205 would pre-empt any State law which attempted t specify the amount of tinting that a piece of new motor vehicle glazing could have. Standard No. 205 would not pre-empt a State law which prohibits the applications of films or decals on existing glazing, however, since Standard 205 does not apply to the use of glazing after it has been purchased by a consumer. I suggest that Mr. Lecher contact his State Department of Motor Vehicles to find out about any activity in this area.; I am enclosing a copy of the Vehicle Safety Act for Mr. Lecher' information.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4183OpenMr. Joel Silidker, 323 Jefferson Drive, Guilford, CT 06437; Mr. Joel Silidker 323 Jefferson Drive Guilford CT 06437; Dear Mr. Silidker: This is in reply to your letter of July 15, 1986, to Mr. Vinson of m staff, bringing to our attention the lack of a center high-mounted stop lamp on your 1986 Nissan Stanza wagon, and asking us to look into this matter. You have enclosed a letter from Nissan informing you that your wagon has 4-wheel drive and thus is not certified as a 'passenger vehicle' required to have the light. However, you believe that manufacturers of other 4-wheel drive vehicles are providing the new lamp.; Federal Motor Vehicle Safety Standard No. 108 requires the new lamp a original equipment on all 'passenger cars' manufactured on and after September 1, 1985. It is not required on other types of motor vehicles such as 'multipurpose passenger vehicles'. This latter category is defined for purposes of the Federal motor vehicle safety standards as a vehicle constructed on a truck chassis, or with special features for occasional off- road operation. The principal feature for such operation is 4- wheel drive. If a 4-wheel drive vehicle is built on a passenger car chassis, its manufacturer may treat it as either a 'passenger car' or 'multipurpose passenger vehicle' for purposes of compliance with the safety standards, and for purposes of certification to those requirements. We believe that the certification plate permanently attached to the door post of your Stanza identifies it as a 'multipurpose passenger vehicle' and that Nissan is therefore not required to provide the center mounted stop lamp.; As for the reason that the lamp is installed on other 4-wheel driv vehicles, it may be that they are certified as passenger cars, or that their manufacturers have voluntarily chosen to equip them with the new lamp.; Thank you for your interest in safety. Sincerely, Erika Z. Jones, 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.