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: 77-1.23OpenTYPE: INTERPRETATION-NHTSA DATE: 02/15/77 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Oconomowoc Public Schools; Wisconsin TITLE: FMVSR INTERPRETATION TEXT: This responds to your February 3, 1977, letter asking whether the new school bus definition (effective April 1, 1977) precludes the use of vans which seat less than 10 passengers from transporting children to and from school. The Motor Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L. 93-492) authorized the NHTSA to redefine the term "school bus" to include all motor vehicles which seat 10 or more passengers and which transport children to and from school. The NHTSA redefined the term in accordance with the wishes of Congress for the purpose of prescribing safety requirements for buses that fall within the definition. The definition does not preclude the use of vans or any other type of motor vehicle which seat fewer than 10 passengers from transporting children to and from school. Such vehicles may transport children without complying with the school bus safety requirements. SINCERELY, Oconomowoc Public Schools February 3, 1977 Charles E. Duke Deputy Administrator NHTSA Members of the Wisconsin Legislature are attempting to define a school bus to allow some flexibility for vehicle use in the under 10 passenger capacity. Senate Bill 110 was introduced on Wednesday, February 2, 1977 with the leaders attempting to push it through without opposition. The bill has many fine features with only one specific area of concern on the part o school administrators. In place of using the term "vehicles under 10 passengers," the author stated specifically "an automobile or station wagon that is not designed or constructed as a van" may be used. This is for transportation other than transportation of children to or from school. The proponents for this measure claim the new federal regulation to be enacted on April 1, 1977 will require all states to conform to this measure. Since many schools have small vans for use in lunch delivery, mail service, and the like, they find these vehicles very useful in transporting small groups like the golf team, forensic students, and band groups and at a minimum cost. I am enclosing the portion of Bill 110 that pertains to vehicle on use of the description. Please review the measure and provide a ruling term "vehicles under 10 passengers" in place of "an automobile or station wagon that is not designed or constructed as a van" with reference to the new federal regulation. The chairman of the review board on legislative measures stated yesterday that he felt a hearing on Bill 110 would be held by February 15, 1977. I realize the request is on short notice but also realize that without some interpretation from your agency, we will be forced to live with a measure that will be very costly and inefficient. Thank you for your help and assistance. Carlyle Holtan Director of Transportation [ENC. OMITTED] |
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ID: 77-1.24OpenTYPE: INTERPRETATION-NHTSA DATE: 02/17/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Topeka Metropolitan Transit TITLE: FMVSS INTERPRETATION TEXT: This responds to your January 4, 1977, letter posing several questions concerning the National Highway Traffic Safety Administration's (NHTSA) definition of school bus and its effect upon the use of transit buses to transport children to and from school. You asked several questions in your letter: (1) Are buses designed and sold for operation as common carriers in urban transportation prohibited from use in school transportation services under Federal regulations? Buses sold for operation as common carriers in urban transportation (transit buses) are not prohibited from use in school transportation. The definition of "school bus" is not intended to include transit buses on regular common-carrier routes, although they may be used in some circumstances to transport school students to and from school and related events. This type of bus has never been considered a school bus under the motor vehicle safety standards for school bus construction or under the Pupil Transportation Standard No. 17 (43 CFR 1204) for school bus operation. (2) If the answer to (1) is no, must such buses when used incidentally in school transportation services comply with any safety standards required of "school buses" under the Federal regulations and if so, from which are they exempt and to which must they comply? (of special concern is forward facing seats requirement of 49 CFR @ 571.222 - s5.1). The answer to your question is no. As noted above, common carriers in urban transportation are excluded from the Federal definition of "school bus" and need not comply with any Federal school bus construction regulation. While Kansas has chosen to define "school bus" differently (and in a manner to include these transit buses), this state definition represents a voluntary decision to extend Federal construction requirements (such as forward facing seats) to a broader catagory of vehicles than dictated by Federal law and regulations. (3) Do federal regulations encourage or discourage the incidental use of common carrier buses to help solve urban school transportation problems? Federal safety regulations promulgated under the authority of the National Traffic and Motor Vehicle Safety Act neither encourage nor discourage the incidental use of transit buses to transport children to and from school. (4) Is the Kansas law with regard to school buses, by its definition in K.S.A. 8-1461 (Supp., 1976), and its requirements of under K.S.A. 8-2009 (Supp., 1976) (which include all safety requirements of the Kansas Transportation Manual, effective May 1, 1976) preempted, as applied to common carriers sold and designed for use in urban transportation, by federal law under 15 U.S.C. @ 1392 (d)? The NHTSA responded to your question on preemption in our letter dated June 15, 1976. That response is still valid. With regard to your question concerning the preemption of the Kansas definition of "school bus," only state motor vehicle safety standards in conflict with Federal standards are preempted. State definitions of terms are not preempted by Federal definitions. SINCERELY, TOPEKA METROPOLITAN TRANSIT AUTHORITY January 14, 1977 Frank Berndt Acting Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration On May 17, 1976 the Topeka Metropolitan Transit Authority requested an opinion from your office concerning a proposed amendment to an existing Kansas statute and its possible conflict with Federal law. Your responsive opinion of June 15, 1976 was helpful but our efforts failed in the Kansas legislature. Currently, under my understanding of Kansas law, the TMTA is prohibited from transporting any school child to or from school in its buses which were designed and sold for use as common carriers in urban transportation because of the Kansas definition of school bus (K.S.A. 8-1461 Supp, 1976), the requirement of forward facing seats (K.S.A. 8-2009 (a) Supp. 1976) and many other regulations issued by the secretary of transportation under authority of K.S.A. 8-2009 (Supp. 1976) to which TMTA's common carrier buses do not comply. Consequently the TMTA is proposing amendments to the Kansas statutes which prohibit the use of our buses in school related transportation. There is concern by the Director of Highway Safety that to allow utilization of TMTA's buses would violate Federal law and regulations, and in the 1976 legislature session he convinced the legislators of his belief. To clear up this controversy we request an update of your last opinion by responding to the following specific questions: (1) Are buses designed and sold for operation as common carriers in urban transportation prohibited from use in school transportation services under Federal regulations? (2) If the answer to (1) is no, must such buses when used incidentally in school transportation services comply with any safety standards required of "school buses" under the Federal regulations and if so, from which are they exempt and to which must they comply? (of special concern is forward facing seats requirement of 49 CFR @ 571.222 - s5.1). (3) Do federal regulations encourage or discourage the incidental use of common carrier buses to help solve urban school transportation problems?
(4) Is the Kansas law with regard to school buses, by its definition in K.S.A.8-1461 (Supp., 1976), and its requirements of under K.S.A. 8-2009 (Supp., 1976) (which include all safety requirements of the Kansas Transportation Manual, effective May 1, 1976) preempted, as applied to common carriers sold and designed for use in urban transportation, by federal law under 15 U.S.C. @ 1392 (d)? Answers to these questions or as many of them as you feel is appropriate, will greatly clarify our position. James N. Clymer Legal Staff |
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ID: 77-1.25OpenTYPE: INTERPRETATION-NHTSA DATE: 02/17/77 FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA TO: Nissan Motor Co., Ltd. TITLE: FMVSS INTERPRETATION TEXT: This responds to your January 6, 1977, question regarding the effective date of the recent amendment to Standard No. 116, Motor Vehicle Brake Fluids, that specifies color coding requirements for brake fluids (41 FR 54942, December 16, 1976). You asked whether motor vehicles manufactured after the effective date for the color coding requirements (September 1, 1978) may be equipped with brake fluids manufactured prior to that date that do not conform to the color coding requirements. The answer to your question is yes. Paragraph S5.3 of Standard No. 116 specifies that motor vehicles having hydraulic brake systems shall be equipped with brake fluid that has been manufactured and packaged in conformity with the requirements of the standard. The agency interprets this to mean that vehicles shall be equipped with any brake fluid that conformed to the requirements of Standard No. 116 at the time the brake fluid was manufactured. Sincerely, ATTACH. NISSAN MOTOR CO., LTD. January 6, 1977 Frank A. Berndt -- Acting Chief Counsel, National Highway Traffic Safety Administration Dear Mr. Berndt: I would like to take this time to ask you for your interpretation regarding the effective date of brake fluid color coding requirements (MVSS 116, Docket 71-13; Notice 12) for the motor vehicles. My understanding is that even on and after September 1, 1978 the motor vehicles can be equipped with brake fluid manufactured before that date which do not meet the color coding requirement of S.5.1.14 because FMVSS 116 except S5.3 does not apply to the motor vehicle manufacturer but to the brake fluid manufacturer. Is my understanding correct? Thank you for your attention to this matter. We look forward to hearing your interpretation of the above. Very truly yours, Tokio Iinuma -- Staff, Safety |
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ID: 77-1.26OpenTYPE: INTERPRETATION-NHTSA DATE: 02/17/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Lucas Industries North America, Inc. TITLE: FMVSS INTERPRETATION |
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ID: 77-1.27OpenTYPE: INTERPRETATION-NHTSA DATE: 02/22/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: BMW of North America, Inc. TITLE: FMVSS INTERPRETATION TEXT: This is in response to your January 17, 1977, letter concerning the requirements of Safety Standard No. 111, Rearview Mirrors, for passenger cars. You requested confirmation of your interpretation that the standard specifies no requirements for outside rearview mirrors on the passenger's side of the vehicle when the inside rearview mirror meets the field of view performance requirements of paragraph S5.1.1 of the standard. Your interpretation is correct. If the inside rearview mirror of a passenger car meets the specified performance requirements, the vehicle is not required to be equipped with an outside rearview mirror on the passenger's side. However, a manufacturer is free to equip its vehicles with outside right-hand mirrors, either plane or convex, if he choses. You should note that each passenger car whose inside rearview mirror does not meet the field of view performance requirements of paragraph S5.1.1 must have an outside rearview mirror of unit magnification installed on the passenger's side of the vehicle. SINCERELY, BMW OF NORTH AMERICA, INC. January 17, 1977 Frank A. Berndt, Esq. Acting Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration Federal Motor Vehicle Safety Standard, FMVSS 111, Paragraph 5.3, states that "each passenger car whose inside rear view mirror does not meet the field of view requirements of S 5.1.1, shall have an outside rear view mirror of unit magnification installed on the passenger side . . . " (emphasis added). In Paragraph S 5.3, the emphasis is placed on the inside rear view mirror, which does not meet the field of view requirements of S 5.1.1. It is BMW's understanding that the outside rear view mirror on the passenger side, whether of unit or non-unit magnification, does not fall within the jurisdiction of FMVSS 111, when the vehicle's inside rear view mirror meets the field of view requirements of S 5.1.1. Your confirmation in writing of this understanding would be appreciated.
Karl-Heinz Ziwica Manager, Safety Engineering |
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ID: 77-1.28OpenTYPE: INTERPRETATION-NHTSA DATE: 02/22/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Blue Bird Body Company TITLE: FMVSS INTERPRETATION TEXT: This responds to your January 19, 1977, question whether the requirement of S5.2 of Standard No. 222, School Bus Passenger Seating and Crash Protection, for a restraining barrier of specified size in front of certain designated seating positions necessitates the provision of an additional barrier surface in front of those portions of a bench seat that do not form part of the designated seating positions. You describe a front-row two-passenger bench seat in a bus (with a seat back that extends beyond the bench to provide adequate restraint for a three-passenger seat aft of it) and ask about the restraining barrier that is required in front of the two-passenger front-row seat. Paragraph S5.2.2 requires that the perimeter of the restraining barrier coincide with or lie outside of the perimeter of the seat back of the seat for which it is required. This means that the restraining barrier must coincide with or lie outside of the perimeter of the seat back of the designated seating position or positions for which it is required. Therefore, a seat with only two designated seating positions must only be equipped with a restraining barrier in front of those two seating positions. SINCERELY, BLUE BIRD BODY COMPANY January 19, 1977 Frank Berndt Chief Counsel National Highway Traffic Safety Administration The purpose of this leter is to get an interpretation regarding paragraph S5.2.2, Barrier Position and Rear Surface Area, of FMVSS 222, School Bus Passenger Seating and Crash Protection. The subject paragraph reads "The position and rear surface area of the restraining barrier shall be such that, in a front projected view of the bus, each point of the barrier's perimeter coincides with or lies outside of the perimeter of the seat back of the seat for which it is required." In the development of this standard it has been our understanding that NHTSA was contemplating a possible passenger loss on the right front seat of the school bus. This would necessitate a special seat at the right front position which would have seating provision for two passengers and a seat back wide enough to provide barrier protection for the three passengers in the second front seat on the right side. With this configuration the barrier in front of the right front seat would be a two passenger barrier. We have designed such a seating and barrier configuration as described above. * We would like confirmation of our interpretation that paragraph S5.2.2 allows this configuration. * See enclosed photos showing mockup of this seat and barrier arrangement. Thank you for your early attention and reply to this matter. W. G. Milby Manager, Engineering Services (Graphics omitted) (Graphics omitted) |
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ID: 77-1.29OpenTYPE: INTERPRETATION-NHTSA DATE: 02/22/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: General Motors Corporation TITLE: FMVSS INTERPRETATION TEXT: This responds to General Motors Corporation's February 2, 1977; request for confirmation that the impact protection requirements contained in S3.1 of Standard No. 201, Occupant Protection in Interior Impact, apply only to the area of the instrument panel that falls within a defined zone and does not apply to other objects installed near the instrument panel, such as the control handle of a spotlight mounted in the right-side windshield pillar, that also fall within the specified zone. The impact protection requirements of the standard apply only to the instrument panel itself in S3.1. This section references a Society of Automotive Engineers recommended Practice J921 which specifies that the instrument panel assembly be removed from the vehicle for testing. Thus, the presence of objects in the specified impact zone within the vehicle must be disregarded for purposes of judging compliance of the vehicle with the requirement itself. SINCER |
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ID: 77-1.3OpenTYPE: INTERPRETATION-NHTSA DATE: 01/18/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Meyer Products, Inc. TITLE: FMVSS INTERPRETATION TEXT:
JAN 18 1977 N40-30
Mr. D. J. Henry Executive Vice President Meyer Products, Inc. 18513 Euclid Avenue Cleveland, Ohio 44112
Dear Mr. Henry:
This is in response to your November 16, 1976, letter concerning the removal of snow below assemblies prior to testing motor vehicles for conformity to Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity.
You have pointed out that a snow plow assembly includes components other than the part that actually contacts and moves the snow. You have requested confirmation of your interpretation that "no part of the snow plow assembly, including mounting components, was to be attached to a vehicle for purposes of (compliance testing ..." That interpretation is incorrect. The presence or absence of snow plow components on a vehicle during compliance testing depends on whether the components are included in the vehicle's "unloaded vehicle weight". As the July 16, 1976, letter from Mr. Robert Carter of this agency to the jeep Corporation indicates, unloaded vehicle weight includes the weight of accessories that are not ordinarily removed from the vehicle when they are not in use. The statement in that letter that "snow plows" would be removed by the NHTSA prior to compliance testing can be amplified as follows: 1) A snow plow, i.e., the component of a snow plow assembly that actually contacts and moves the snow, will be removed. 2) Those other components of a snow plow assembly that, like the snow plow itself, are ordinarily removed when not in use will also be removed. 3) Those components which are not ordinarily removed from the vehicle when not in use will not be removed by the NHTSA prior to compliance testing. The agency will abide by a manufacturer's good faith categorization of accessories and components of accessories.
Sincerely,
Frank Berndt
Acting Chief Counsel
November 16, 1976
Mr. Frank A. Berndt Acting Chief Counsel National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, D.C. 20590
Dear Mr. Berndt:
Recently, our Sales Manager, Mr. Michael Groff, had the pleasure of meeting with Mr. Robrt N. Williams of your organization in regard to Federal Motor Vehicle Safety Standard 301-75, and Mr. Williams suggested that we address this letter to you.
Meyer Products, Inc. is a manufacturer of snow plows and salt spreaders for installation on or use in conjunction with motor vehicles, and we have been concerned about the effect of FMVSS 301-75 upon our business and that of our distributors.
In attempting to determine what, if any, action we should be taking with respect to FMVSS 301-75, we have examined a letter dated July 16, 1976, from Robert L. Carter, Associate Administrator for Motor Vehicle Programs of the National Highway Traffic Safety Administration, to Jeep Corporation, which states that snow plows "would be removed by the NHTSA prior to testing for conformity to Standard No. 301-75." As you will appreciate, a snow plow assembly consists of many components other than the moldboard that actually contacts and moves the snow. It has been our interpretation that no part of the snow plow assembly, including mounting components, was to be attached to a vehicle for purposes of teting the vehicle for compliance with FMVSS 301-75, and Mr. Groff has reported to us that our interpretation was orally confirmed by Mr. Williams. In order to better asdsure our distributors that the installation of Meyer Products snow plows by them will not require them to retest the vehicles and will not result in their violating the National Traffic and Motor Vehicle Safety Act of 1966, as amended, or the regulations promulgated pursuant thereto, we would appreciate your sending us a leter confirming our understanding as recited above. Since winter and the snow season have already arrived, it is imperative that we advise our distributors with respect to FMVSS 301-75 immediately, and we, therefore, request and thank you for your prompt response to this letter.
Sincerely yours,
MEYER PRODUCTS, INC.
D. J. Henry Executive Vice President
DJH/lt
cc: Marc W. Freimuth, Esq. Squire, Sanders & Dempsey
cc: Mark Schwimmer, Esq. National Highway Traffice Safety Administration
cc: Robin N. Williams National Highway Traffic Safety Administration |
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ID: 77-1.30OpenTYPE: INTERPRETATION-NHTSA DATE: 02/23/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Union Carbide Corporation TITLE: FMVSS INTERPRETATION TEXT: This responds to your January 31, 1977, question whether Safety Standard No. 116, Motor Vehicle Brake Fluids, currently requires a border around the safety warnings that are required to be placed on brake fluid containers. Standard No. 116 was recently amended (41 FR 54942, December 16, 1976) to specify color coding requirements for hydraulic brake system fluids and to make a minor change in the required warning label. The proposal preceding this amendment did specify that the safety warnings on brake fluid containers be surrounded by a color coded border (40 FR 56928, December 5, 1975). However, after reviewing the comments submitted regarding the cost of the proposed borders and after reevaluating the expected safety benefits, the agency decided to withdraw the proposed requirement. The final rule, therefore, did not include a requirement for color coded borders. Although Standard No. 116 does not require a border around the safety warnings on brake fluid containers, manufacturers are permitted to use a border if they choose. Sincerely, ATTACH. UNION CARBIDE CORPORATION January 31, 1977 Office of Chief Counsel -- National Highway Traffic Safety Administration, Department of Transportation Dear Sir: It is my understanding from reading Docket No. 71-13; Notice 12 published in the Federal Register 41, No. 243 - Thursday, December 16, 1976, that the border around the warning statement on brake fluid containers specified in Standard No. 116 (49CFR 571.116) is no longer mandated. It is my further understanding that a border around the statement is permitted for the purpose of setting off the statement from the balance of the information on the label. If my understandings are correct, I wish to receive written confirmation of them from your office.
Very truly yours, W. G. Whitehead -- Manager, Product Safety and Regulatory Affairs cc: D. Raymond; F. M. Redler; R. W. Shiffler; G. W. Warnock |
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ID: 77-1.31OpenTYPE: INTERPRETATION-NHTSA DATE: 02/23/77 FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA TO: Silver Thread Studios TITLE: FMVSS INTERPRETATION TEXT: This responds to your February 1, 1977, letter requesting information concerning the Federal regulations that would be applicable to glazing for use in van-type vehicles. Your assumption that the glazing regulation is not applicable to plastic material used for porthole windows and sun-roofs in vans is incorrect. Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, 49 CFR 571.205, specifies requirements for all glazing materials for use in motor vehicles and motor vehicle equipment. The standard specifies the types of glazing that may be used in various locations in vehicles and, in addition, specifies performance requirements for each type of glazing. Although the standard does permit the use of plastic glazing in side windows and sun-roofs of van-type vehicles, the plastic glazing must meet specified performance requirements. I am enclosing a copy of Standard No. 205 (and the ANS Z26 standard that is incorporated by reference in Standard No. 205) for your information. From the standard you will be able to determine the various types of glazing that may be used for side windows and sun-roofs in vans. SINCERELY SILVER THREAD STUDIOS February 1, 1977 Office of Chief Council National Highway Transportation Safety Mr. Rodness of your White Plains office referred me to you. We are planning to manufacture windows for vans and would like to know which windows are required by law to be made of safety glass. More specifically, we are interested in the laws pertaining to portholes, sun-roofs and rear windows. Portholes are those windows of varied design (such as heart shaped, etc.) currently made of plastic material and positioned on the side of the van to allow light in the rear of the van. Sun-roofs are those windows installed on the roof which can be opened to allow air in the rear of the van. Both of these windows are currently made of plastic material, and I believe that safety glass regulations do not apply to them. Could you please comment on this. Thank you for your cooperation. I remain Steven Katz |
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.