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: aiam1755OpenMr. Al Zajic, Engineering Department, American Trailers, Incorporated, 1500 Exchange Avenue, Box 26568, Oklahoma City, OK 73126; Mr. Al Zajic Engineering Department American Trailers Incorporated 1500 Exchange Avenue Box 26568 Oklahoma City OK 73126; Dear Mr. Zajic: This is in acknowledgment of your Defect Information Report i accordance with the defect reporting regulations, Part 573.; The Defect Information Report involves: 25 Aluminum Grain Hoppe Doubles trailers. Possibility that the lower side rail in the area of the upper coupler assembly may develop fatigue cracks. This information was furnished in your letter of January 10, 1975.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *75-0009*. The first quarterly status report for this campaign is required to be submitted by May 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; On December 26, 1974, an amendment to the National Traffic and Moto Vehicle Safety Act of 1966 (the Act) became effective. This amendment, among other provisions, modifies the content of the required owner notification and also changes some of the associated procedures. Since your owner notification letter was mailed after this date, section 153 of the amended Act should have been followed. Your letter should have referred to a specific date as the earliest date on which the defect will be remedied without charge (section 153(a)(5). Because remedy without charge is contingent upon actual dates, we believe the inclusion of a specific date is preferable to the statement in your letter. The date stated should be the earliest date on which parts and facilities can reasonably be expected to be available, and may be the same, an earlier, or a later date than the date of your letter. You must also include information that is responsive to section 153(a)(6) of the Act. As the procedures referred to in that section have not been published, it is sufficient if you advise owners that they may write to the Administrator, National Highway Traffic Safety Administration, Washington, D. C. 20590, if they find American Trailers to have failed or to have been unable to perform the repair satisfactorily.; It is therefore necessary that you send a revised notification lette by first class mail to the registered owners of those trailers which have not yet been corrected. A copy of your revised notification letter should be sent to this office (unless a 100 percent completion rate makes this unnecessary).; A copy of the Act including the 1974 amendment is enclosed. If yo desire further information, please contact Messrs. W. Reinhart or James Murray of this office at (202) 426- 2840.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam1195OpenMr. Robert G. Beaumont, President, Sebring Vanguard, Inc., P.O. Box 1479, Sebring Air Terminal, Sebring, FL 33870; Mr. Robert G. Beaumont President Sebring Vanguard Inc. P.O. Box 1479 Sebring Air Terminal Sebring FL 33870; Dear Mr. Beaumont: This is in reply to your letter of July 30, 1973, requesting furthe information about the relationship of the Federal motor vehicle safety regulations to the Vanguard electric vehicle.; You ask the following questions: >>>'1. Would prior commitments made before May 16, 1973, be sufficien for a temporary exemption?'<<<; Previously-existing commitments for parts that do not conform t systems covered by Federal motor vehicle safety standards may be presented to support the argument that compliance as of January 1, 1974, would cause substantial economic hardship. No temporary exemption has ever been requested on this basis alone, however, and whether an exemption would be granted solely on this basis would depend upon other facts in the case.; >>>'2. Can VANGUARD be classified as a multipurpose passenger vehicl and what relief would that give us from adhering to federal safety standards?'<<<; As you know, a 'multipurpose passenger vehicle' (MPV) is defined i part as a vehicle 'with special features for occasional off-road operation.' Intent for incidental off-road use is insufficient to qualify a passenger car as an MPV. The manufacturer makes the initial determination whether a vehicle is a passenger car or whether it is a MPV, incorporating 'special features' for occasional off-road operation not normally found on a passenger car. If he asks our views, we will provide them. If he does not, we are not precluded from questioning his vehicle categorization at a later date if it appears erroneous to us. The Vanguard appears to be a passenger car, but we would be willing to consider the matter further if you think it possesses unique off-road features.; >>>'3. How can we incorporate safety improvements in our vehicles prio to January 1, 1974, that may put us over the weight limit without violating law?'<<<; When you have completed a definitive review of your compliance proble areas you may apply for such exemptions as appear necessary. If safety improvements result in a vehicle weight that exceeds 1,000 pounds, you may legally market a vehicle if it has been exempted before January 1, 1974.; We appreciate your keeping us informed of your program with th Vanguard.; Sincerely, Lawrence. R. Schneider, Chief Counsel |
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ID: aiam4195OpenMr. Andrew A. Kroll, 1401 East Girard, 207, Englewood, Colorado 80110; Mr. Andrew A. Kroll 1401 East Girard 207 Englewood Colorado 80110; Dear Mr. Kroll: This responds to your letter requesting an interpretation of Standar No. 109, *New Pneumatic Tires - Passenger Cars* (49 CFR S571.109). Specifically you asked whether that standard is applicable to foam-filled passenger car tires that do not have any air in the inner tire cavity. Standard No. 109 does not apply to foam-filled passenger car tires.; Section S2 of Standard No. 109 specifies that '[t]his standard applie to new pneumatic tire for use on passenger cars manufactured after 1948.' In section S3 of the standard, the term 'pneumatic tire' is defined as 'a mechnaical(sic) device made of rubber, chemicals, fabric and steel or other materials, which, when mounted on an automotive wheel, provides the traction and *contains the gas or fluid that sustains the load*' (emphasis added). Thus the relevant question is whether the foam filling the tires in question is considered a 'gas or fluid'. In a February 14, 1975 letter to Mr. J. F. Hutchinson, NHTSA stated that foam-filled tires 'should not be considered pneumatic tires.' This conclusion means that foam-filled tires for use on passenger cars are *not* subject to the requirements of Standard No. 109.; One result of this determination is that foam- filled tires can *not be installed as original equipment on any new passenger car. Standard No. 110, *Tire Selection and Rims* (49 CFR S571.110) sets forth requirements for new passenger cars. Section S4.1 of Standard No. 110 reads as follows: 'Passenger cars shall be equipped with tires that meet the requirements of S571.109.' Since foam-filled tires are not subject to Standard No. 109, they are still 'item of motor vehicle equipment' within the meaning of section 102(4) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391(4)). Among other things, this means that, if there is a determination that the tires contain a defect related to motor vehicle safety, the manufacturer of the foam-filled tires is required to notify purchasers and dealers of the defect and remedy the defect without charge to the purchasers, if the tire was purchased less than 3 calender years before the determination of defect was made.; If you have any further questions on this subject or need mor information, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4008OpenMr. Sam Verma, President, Erincraft Mfg. Co., Inc., 742 East 8th Street, Michigan City, IN 46360; Mr. Sam Verma President Erincraft Mfg. Co. Inc. 742 East 8th Street Michigan City IN 46360; Dear Mr. Verma: This responds to your letter of August 6, 1985, asking how to obtain 'DOT number,' so that your company can import truck tires into the United States from a plant in India. The procedures to be followed are set forth in 49 CFR Part 574, *Tire Identification and Recordkeeping*, a copy of which is enclosed for your information.; That regulation requires every tire sold in this country to be labele with certain information (see S574.5), including the identification mark assigned to the manufacturer. To obtain an identification mark, the actual manufacturer of the tires should provide the information specified in S574.6 of the regulation. Please note that an identification mark will be assigned only to the actual manufacturer of tires, and not to companies importing those tires. This is because S574.5 requires that this identification mark be *molded* into or onto all new tires. The only party which can mold the mark on the tire is the actual manufacturer. Therefore, the entity which owns the tire plant in India must apply for the identification mark. An identification mark is normally assigned within two weeks after the receipt of such a request.; The owner of the tire plant in India should also be aware of procedural rule which applies to all parties subject to the regulations of this agency, 49 CFR Part 551 (copy enclosed). This rule requires all manufacturers headquartered outside of the United States to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. The agency may be either an individual or a business entity. The identification mark required by Part 574 will *not* be assigned until this agency has received a valid designation of agent from the Indian tire manufacturer. Part 551 specifies that the designation of agent must contain the following six items of information:; 1. A certification that the designation is valid in form and binding o the manufacturer 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 mailing addres of the Indian tire manufacturer,; 3. Marks, trade names, or other designation of origin of any of th manufacturer's tires which do not bear its name,; 4. A statement that the designation shall remain in effect unti withdrawn or replaced by the Indian tire manufacturer.; 5. A declaration of acceptance duly signed by the agent appointed b the Indian tire manufacturer, and the agent may be an individual or a U.S. firm or corporation, and; 6. The full legal name and address of the designated agent. If you need any further information or a clarification of some of th information set forth in this letter, please contact Steve Kratzke of my staff at this address or by telephone (202) 426-2992.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam4431OpenMr. Hiroshi Kato MMC Services Inc. 3000 Town Center Suite 1960 Southfield, MI 48075; Mr. Hiroshi Kato MMC Services Inc. 3000 Town Center Suite 1960 Southfield MI 48075; "Dear Mr. Kato: This is in response to your letter of April 19, 1988 concerning whether a Mitsubishi Motors Corporation SH27 lightweight industrial truck that you intend to offer for sale in the United States should be classified as a motor vehicle under Section 102(3) of the National Traffic and Motor Vehicle Safety Act ('Safety Act'). You stated that this vehicle is intended for 'general or carrier work for off-road applications,' and that it is capable of a maximum speed of approximately 25 mph. You further explained that your company planned to advertise, promote, and market this vehicle as an off-road vehicle. Based on the information provided in your letter, it appears that the SH27 would not be a motor vehicle under the Safety Act. Section 102(3) of the Safety Act (15 U.S.C. 1391(3)) defines a 'motor vehicle' as any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. NHTSA has interpreted this language as follows. Vehicles that are equipped with tracks or are otherwise incapable of highway travel are plainly not motor vehicles. Further, vehicles designed and sold solely for off-road use (e.g., airport runway vehicles and underground mining devices) are not considered motor vehicles, even though they may be operationally capable of highway travel. Vehicles that have an abnormal body configuration that readily distinguishes them from other highway vehicles and a maximum speed of 20 miles per hour (mph) are not considered motor vehicles, because their use of the public roads is intermittent and incidental to their primary intended off-road use. On the other hand, vehicles that use the public highways on a necessary and recurring basis are motor vehicles. For instance, a utility vehicle like the Jeep is plainly a motor vehicle, even though it is equipped with special features to permit off-road operation. If a vehicle's greatest use will be off-road, but it will spend a substantial amount of time on-road, then NHTSA has interpreted the vehicle to be a 'motor vehicle'. Further, the agency has determined that a vehicle such as a dune buggy is a motor vehicle if it is readily usable on the public roads and is in fact used on the public roads by a substantial number of owners, regardless of the manufacturer's stated intent regarding the terrain on which the vehicle is to be operated. Your vehicle is not easily classified under either of these groupings. On the one hand, your vehicle has a body configuration nearly identical to standard trucks, can be registered for use on the highways of several foreign countries, and can obtain a a maximum speed of approximately 25 mph. These factors suggest that the vehicle should be classified as a motor vehicle. On the other hand, you stated that this vehicle is intended to be used only for off-road applications and that this vehicle will be advertised and promoted for off-road purposes only and will contain four warning labels stating 'Warning: Off Road Use Only.' These factors suggest that the vehicle should not be classified as a motor vehicle. In instances where the agency is asked whether a vehicle is a motor vehicle when it has both off-road and on-road operating capabilities, and about which there is little or no evidence about the extent of the vehicle's on-road use, the agency has applied five factors in offering its advice. These factors are: 1. Whether States or foreign countries have permitted or are likely to permit the vehicle to be registered for on-road use. You noted that several foreign countries including Japan and Taiwan register for on-road use the general export configuration of this vehicle. This suggests that your vehicle should be considered a motor vehicle. You attempted to distinguish this fact by stating that the vehicle to be sold in the United States has different specifications than the general export vehicles. The differences are that the United States version has a maximum speed of 25 mph while the general export version can achieve speeds of greater than 55 mph, the engine displacement in the United States version has an engine of 548 cc rather than the 796 and 783 cc for the general export version, and the United States version has an hourmeter (similar to agricultural vehicles) rather than a speedometer. You stated that these differences mean that there is little basis for assuming that the experience in other countries would correlate to the likelihood of States permitting the vehicle to be registered for highway use in the United States. Since the vehicle closely resembles a small truck for highway use, we believe it is likely that States would permit it to be registered for highway use, just as other countries have. Therefore, this factor suggests that your vehicle should be considered a motor vehicle. 2. Whether the vehicle is or will be advertised for use on-road as well as off-road, or whether it is or will be advertised exclusively for off-road use. You stated that your advertising and promotional materials will state that your vehicle should be used only for off-road purposes and will not depict or suggest that the vehicle can be used on-road. This factor suggests that the vehicle should not be considered a motor vehicle. 3. Whether the vehicle's manufacturer or dealers will assist vehicle purchasers in obtaining certificates of origin or title documents to register the vehicle for on-road use. You stated that your dealers will be instructed that this vehicle is to be used solely for off-road purposes and that no assistance should be given to obtain a title for the vehicle or to register the vehicle in this country. Your company also will state on any ownership document that this vehicle is not intended for on-road use. Therefore, this factor would indicate that the vehicle should not be considered a motor vehicle. 4. Whether the vehicle is or will be sold by dealers also selling vehicles that are classified as motor vehicles. You stated that this vehicle will only be sold by dealerships that sell vehicles other than motor vehicles, such as material handling equipment like lifts and agricultural equipment. This factor suggests that the vehicle should not be considered a motor vehicle. 5. Whether the vehicle has or will have affixed to it a warning label stating that the vehicle is not intended for use on the public roads. You stated that four warning labels will be affixed to the interior and exterior of the vehicle body. Labels stating 'Off Road Use Only' will be applied to the exterior front panel of the cab, the rear gate, and the instrument panel. Additionally, a label stating 'Warning: Off Road Use Only' will be affixed to the exterior rear panel of the cab. This factor would indicate that the vehicle is not a motor vehicle. Based on the representations in your letter, the agency believes that the Mitsubishi SH27 lightweight truck does not appear to be a motor vehicle under the Safety Act. However, we will reexamine this conclusion if we learn that, for example, the vehicle is in fact used on the public roads by a substantial number of its owners. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel /"; |
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ID: aiam2052OpenMr. John B. White, Engineering Manager, Technical Information Department, Michelin Tire Corporation, P.O. Box 3467, New Hyde Park P.O., New York 11040; Mr. John B. White Engineering Manager Technical Information Department Michelin Tire Corporation P.O. Box 3467 New Hyde Park P.O. New York 11040; Dear Mr. White: This is in reply to your letter of July 9, 1975, inquiring as to th proper designation of plies on a truck tire constructed with two polyamide plies in the casing and two steel plies in the belt.; The designation that you suggested ('Tread: 2 Steel Plies, Sidewall: Polyamide Plies') is incorrect. The designation on such a tire should indicate the presence of four plies in the tread area and two in the sidewall area (with compositions in each case).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0144OpenMr. E. Woodbridge, Chief Engineer, The Society of Motor Manufacturers and Traders Limited, Forbes House, Halkin Street, London SWI; Mr. E. Woodbridge Chief Engineer The Society of Motor Manufacturers and Traders Limited Forbes House Halkin Street London SWI; Dear Mr. Woodbridge: Thank you for your letter of January 9, 1969, to the Federal Highwa Administrator concerning your 1968 Edition of the S.M.M.T. Tyre and Wheel Engineering Manual.; Federal Motor Vehicle Safety Standard No. 109, within Section S3, list the 'Tyre and Wheel Engineering Data Book dated 1965/1966 of the Society of Motor Manufacturers and Traders Limited (S.M.M.T.)' as one of the references containing acceptable test rims.When Standards No. 109 and No. 110 were developed, the National Highway Safety Bureau accepted the S.M.M.T. 1965/1966 Data Book tire and rims combinations based on established usage. We did not, nor do we at present intend to accept general updating of these referenced publications, either foreign or domestic, as valid reasons for amending Standard No. 109 and No. 110. Consequently, any new tire size designations or alternative rim sizes that you wish to list within Standards No. 109 or No. 110 will have to comply, on an individual basis, with the abbreviated guidelines as outlined in the October 5, 1968 *Federal Register*.; Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service; |
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ID: aiam3534OpenThe Honorable James Abdnor, United States Senate, Washington, DC 20510; The Honorable James Abdnor United States Senate Washington DC 20510; Dear Senator Abdnor: Your February 23, 1982, letter to Secretary Lewis on behalf of Mr. Ric Johnson has been referred to this office for reply. Mr. Johnson inquired about Federal regulations applicable to a motorcycle helmet which was worn by a person involved in a fatal accident and which Mr. Johnson believes to have been manufactured in 1979.; Federal Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets* (4 Code of Federal Regulations Part 571.218), establishes minimum performance requirements for most helmets. The standard's applicability to a particular helmet depends on the date of manufacture and size of that helmet. The date of manufacture should be readily ascertainable. Paragraph S5.6.1 of the standard requires that the date and month of manufacture of each helmet subject to the standard appear on a permanent label affixed to the helmet.; The question of size is more complicated. As proposed, the standard wa to have applied to all helmet sizes. Compliance was to have been determined by placing the helmet on the appropriate headform (A, B, C or D, representing head sizes from small to large) and subjecting the helmet to certain tests. As initially implemented on March 1, 1974, the standard applied only to helmets which fit size C headforms since the other headform sizes were not available. Generally speaking, these were medium size helmets. As the enclosed notice explains, >>>'...helmets that fit headform size C' should be all helmets other than those that must be tested on the other headform sizes. To determine which helmets must be tested on a particular headform size, one follows the procedures of paragraph S6.1.3 of the standard.<<<; The other headform sizes did not become available as anticipated Consequently, the standard was extended to all helmets that can be placed on size C headforms. The substitution of 'placed on' for 'fit' brought all large helmets and many small helmets within the ambit of the standard. That extension became effective May 1, 1980. Again as explained in the enclosed notice, >>>'(p)laced' is a broader term than 'fit' primarily in that the former term does not imply any upper limit on helmet size.; Only small, child-size helmets (A) would be excluded since they coul not physically be placed on the size (C) headform. As noted in the procedures discussed above, normal fitting procedures would be used to determine if a particular helmet could be placed on the size 'C' headform, without the use of undue force.<<<; Thus, if the helmet mentioned in Mr. Johnson's letter was manufacture on or after March 1, 1974, and 'fits' the size C headform, it was required to comply with the standard. Likewise, if the helmet was manufactured on or after May 1, 1980, and can be 'placed on' the size C headform, compliance was required.; We have enclosed a copy of Standard No. 218 as it originally becam effective, as well as a copy of the amendment to the standard that became effective on May 1, 1980.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1009OpenTom Caine, Esq., Legal Counsel, Goodyear Tire & Rubber Company, Akron, OH, 44316; Tom Caine Esq. Legal Counsel Goodyear Tire & Rubber Company Akron OH 44316; Dear Mr. Caine: This is to confirm your conversation with Dave Schmeltzer of thi office in which he informed you that a spare tire that is installed in a new vehicle within the occupant compartment would not have to meet the requirements of Standard No. 302 if it is not designed to absorb energy on contact by occupants in the event of a crash. However, this ruling is limited to the actual tire and would not apply to the wheel housing cover of a spare tire since that would be a component specified in S4.1 of the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3405OpenMr. James J. Schultz, Severy, Incorporated, 2233 El Segundo Boulevard, El Segundo, CA 90245; Mr. James J. Schultz Severy Incorporated 2233 El Segundo Boulevard El Segundo CA 90245; Dear Mr. Schultz: This responds to your recent letter asking whether a 4-wheel driv pickup truck must comply with Safety Standard No. 216, *Roof Crush Resistance*. You also ask whether the definitions of vehicle classification under Federal regulations are mutually exclusive.; The application section of Safety Standard No. 216, section 3 specifies that the standard applies to passenger cars. This means that the standard applies *only* to passenger cars. Therefore, the standard does not apply to a pickup truck.; The definitions of the basic vehicle classifications found in 49 CF Part 571.3 are mutually exclusive. If a vehicle falls within the definition of a 'truck,' the vehicle is not also within the definition of a 'passenger car.' The definition of a passenger car does not specifically exclude trucks because the definition is based on the function of the vehicle. Thus, a passenger car is defined as a motor vehicle designed for carrying persons. A truck, on the other hand, is defined as a vehicle designed primarily for the transportation of property or special purpose equipment. Since a pickup is designed primarily for carrying property and not persons, it is a truck and not a passenger car. Each motor vehicle has a certification label attached to its door which specifies the vehicle's classification.; I hope this has clarified any questions you had concerning vehicl classification under the Federal Motor Vehicle Safety Standards.; Sincerely, Frank Berndt, 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.