NHTSA Interpretation File Search
Overview
NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies.
Understanding NHTSA’s Online Interpretation Files
NHTSA makes its letters of interpretation available to the public on this webpage.
An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.
- Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
- Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
- The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
- Some combination of the above, or other, factors.
Searching NHTSA’s Online Interpretation Files
Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.
Single word search
Example: car
Result: Any document containing that word.
Multiple word search
Example: car seat requirements
Result: Any document containing any of these words.
Connector word search
Example: car AND seat AND requirements
Result: Any document containing all of these words.
Note: Search operators such as AND or OR must be in all capital letters.
Phrase in double quotes
Example: "headlamp function"
Result: Any document with that phrase.
Conjunctive search
Example: functionally AND minima
Result: Any document with both of those words.
Wildcard
Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).
Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).
Not
Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”
Complex searches
You can combine search operators to write more targeted searches.
Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”).
Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”
Search Tool
NHTSA's Interpretation Files Search
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ID: aiam3568OpenMr. J. Mack Shively, Grebe, Gross, Jensen & Peek, P.C., 1530 S.W. Taylor Street, Portland, OR 97205; Mr. J. Mack Shively Grebe Gross Jensen & Peek P.C. 1530 S.W. Taylor Street Portland OR 97205; Dear Mr. Shively: This is in response to your letter of May 11, requesting our views a to the applicability of vehicle identification number requirements and certification label requirements to a semi-trailer to be manufactured by Cranston Diversified Industries. This trailer would have three interchangeable sections.; You are correct in your interpretation of the manner in which ou requirements would be applied to the trailers in question. Only one vehicle identification number and one certification label are required. Affixing the label to the left side of the front section would be consistent with our regulations.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4757OpenMr. Peter Brown President, KC HiLites, Inc. Avenida de Luces Williams, AZ 86046; Mr. Peter Brown President KC HiLites Inc. Avenida de Luces Williams AZ 86046; Dear Mr. Brown: This is in reply to your letter of April 25, l990 asking for our 'comments and approval' regarding an automotive lighting product that your company intends to market. The product is intended for use in a four headlamp systems with lens designations of 'L', 'LF' or 'HB4' on the outboard lamps, and 'U', 'UF' or 'HB3' on the inboard lamps. In normal operation, the lower beam is extinguished when the upper beam is activated, your device would ensure that the lower beam would remain activated when the upper beam is used. You view this as permissible under S5.5.8 of Motor Vehicle Safety Standard No. 108. Initially, let me note that we have no authority to 'approve' any device or invention for use on motor vehicles. We advise whether such products are permissible under the Federal motor vehicle safety standards, but this advice must not be represented in advertising as Federal approval of the device or invention. Section S5.5.8 of Standard No. 108 states in pertinent part that 'On a motor vehicle equipped with a headlighting system designed to conform to the photometric requirements of Figure 15, the lamps marked 'L' or 'LF' may be wired to remain permanently activated when the lamps marked 'U' or 'UF' are activated. Standard No. 108 further specifies that headlamps designed to conform to Figure l5 are the four-lamp sealed beam system Type F (S7.3.7(b)), and a four-headlamp integral beam system (S7.4(a)(1)). In addition, certain types of replaceable bulb headlamp systems may also be designed to conform to Figure l5 photometrics, as shown in recently-adopted Figure 26 (copy enclosed). Replaceable bulb headlamps are also required to have the HB Type number on the lens, as well as the 'U' and 'L' markings. Therefore, installation of your device on the headlighting systems mentioned above would be permitted by Standard No. 108, and you need not be limited to systems that use HB3 and HB4 light sources. With respect to the copy on the material you submitted for review, it would be more accurate to reword the marking references to state ''LF','L', or 'L' and 'HB4' on the upper. . . and the corresponding designation 'UF', 'U', or 'U' and 'HB3' on the lower. . . .' We also note your remark 'Quad-Beam gives you this extra margin of lighting safety that the factory left out.' There is no basis in fact for this statement. Some drivers prefer more foreground light, but there is no indication that the addition of the lower beam when the upper beam is in use has a positive effect upon lighting safety. As you requested, we are returning your samples. Sincerely, Paul Jackson Rice Chief Counsel Enclosures; |
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ID: aiam3092OpenHonorable Jack Brooks, House of Representatives, Washington, DC 20515; Honorable Jack Brooks House of Representatives Washington DC 20515; Dear Mr. Brooks: This responds to your note we received on August 29 enclosin correspondence from one of your constituents, Mr. Don Bush. Mr. Bush requests information concerning passive seat belts on a 1977 Volkswagen Rabbit. Apparently, he was told by the Society of Automotive Engineers that there are currently no standards for this type of restraint system.; The information given Mr. Bush by the Society of Automotive Engineer was incorrect. The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. Safety Standard No. 208, *Occupant Crash Protection*, specifies requirements for restraint systems in passenger cars and other vehicles (49 CFR 571.208). For 1977-model passenger cars manufacturers had three options: (1) total passive protection (protection by means that require no action by vehicle occupants), (2) head-on passive protection, (3) the installation of combination lap and shoulder belts for front, outboard seating positions and lap belts for center and rear seating positions.; Volkswagen apparently certified its 1977-model deluxe Rabbit under th second option of the standard. This option requires the vehicle to meet specified injury criteria in a perpendicular barrier crash test, and to either meet lateral and rollover criteria in dynamic impact tests by automatic means or to install lap belts at front, outboard seating positions. Volkswagen used a single, diagonal passive belt to comply with the automatic frontal crash protection requirement of the second option. Additionally, paragraph S4.5.3 of Safety Standard No. 208 allows a passive belt to be used in lieu of any other belt required by any option of the standard. Therefore, Volkswagen's single, diagonal passive belt also qualifies as a lap belt for purposes of complying with the lateral and rollover requirements of the second option.; I am enclosing a copy of Safety Standard No. 208 for Mr. Bush' information. Please have him contact Hugh Oates of my office if he has any questions after reviewing the standard (202-426-2992). Mr. Bush might also note that General Motors voluntarily installed an active lap belt in its Chevettes that have passive shoulder belts (these vehicles were introduced in the spring of this year). Active lap belts in these vehicles are not required by the standard, however.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1105OpenMr. C. A. Wilson, Examiner, Casualty-Property Division, The Travelers, One Tower Square, Hartford, CT 06115; Mr. C. A. Wilson Examiner Casualty-Property Division The Travelers One Tower Square Hartford CT 06115; Dear Mr. Wilson: This is in reply to your letter of March 30, 1973, concerning th applicability of the Federal odometer disclosure requirements (49 CFR Part 580) to transactions in which an insurance company takes possession of a vehicle after declaring it a total loss and paying the owner's claim, and subsequently transfers the vehicle to a salvage dealer.; You are correct in understanding that transactions of this sort are no exempt under section 580.5 of the regulation. When the owner transfers the vehicle to the insurer, he is required to make disclosure statement, and the insurer, in turn, is required to make disclosure upon sale to the salvage dealer. As a practical matter, however, if the vehicle is so badly damaged that it is unlikely ever to be returned to the road, it will have ceased to be a motor vehicle, for purposes of this regulation. Disclosure would therefore not be required.; In cases where the vehicle is repairable or undamaged, as is often th situation in the recovery of stolen vehicles, a disclosure statement should be given as in any other motor vehicle transaction.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3138OpenMr. K. W. Schang, Director, Vehicle Safety Programs, American Motors Corporation, 14250 Plymouth Road, Detroit, MI 48232; Mr. K. W. Schang Director Vehicle Safety Programs American Motors Corporation 14250 Plymouth Road Detroit MI 48232; Dear Mr. Schang: This responds to your letter of October 11, 1979, requesting ou opinion concerning the proper designated seating capacity of the rear seat in your 1981-model AMC Spirit.; You state that the planned 1981 Spirit rear seat will hav approximately 43 inches of hip room. The amended definition of designated seating position specifies that any position likely to be used as a seating position while the vehicle is in motion will be considered a designated seating position, and includes a caveat that bench or split-bench seats having greater than 50 inches of hip room shall have not less than three designated seating positions. Since the hip room in the rear seat of the 1981 Spirit will be well below the 50-inch caveat in the amended definition, and since you state that the rear seat will be contoured for two persons with distinct recessed areas for each person's buttocks, we conclude that this particular seat would qualify as a two-passenger seat. Under the definition, whether a particular position is 'likely to be used' is determined by the overall seat configuration and design and vehicle design. Given the limited amount of hip room and the configuration of the planned 1981 Spirit rear seat, it is not likely that more than two persons will occupy the seat.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4307OpenRobert A. Rogers, Director, Automotive Safety Engineering, Environmental Activities Staff, General Motors Corporation, General Motors Technical Center, 30400 Mound Road, Warren, MI 48090-9015; Robert A. Rogers Director Automotive Safety Engineering Environmental Activities Staff General Motors Corporation General Motors Technical Center 30400 Mound Road Warren MI 48090-9015; Dear Mr. Rogers: This responds to the letter (USG 2496) from Mr. David Martin concernin how the penetration resistance requirements of Standard No. 205, *Glazing Materials*, would apply to a piece of glazing that has two plys. I regret the delay in our response and hope the following discussion answers the questions raised by General Motors.; The letter explained that the glass manufacturing industry i continuing to develop new types of windshields to reduce facial lacerations. It further explained that a new type of glazing, referred to in the letter as '2-ply' glazing, has been developed which 'differs from the traditional High Penetration Resistant (HPR) windshield and the first generation antilacerative windshields in that it consists of one 'outer' glass ply and an 'inner' plastic laminate.'; The letter stated that there is a question about certifying an item o 2-ply glazing to the requirements of the penetration resistance test (Test No. 26 in ANS Z26.1) that is incorporated in Standard No. 205. In that test, a flat glass sample is supported in a wooden frame and must not allow a 5-pound steel ball to pass through it when the ball is dropped onto the supported sample from a height of 12 feet.; The letter further explains that, >>>When an HPR sample is laid on the wooden frame and the ball i dropped onto it, it cracks and bends somewhat but it is sufficiently rigid so as to remain on the text fixture frame and allow the test to measure its ability to resist penetration of the ball. However, when a 2-ply sample is tested in the traditional manner to Test No. 26, it cracks and bends sufficiently so that the glass test sample falls through the test frame. Thus, the test does not evaluate the ability of the sample to resist penetration of the ball, as is the stated intent of the test. On the other hand, if the traditional test method is appropriately adapted (such as clamping) to retain the 2-ply sample in the test frame, the test does, in fact, serve its intended purpose.'<<<; The letter requests the agency to adopt, by interpretation, modification of the test procedure to permit the retention of a piece of 2-ply glazing in the test frame.; Based on the information you have provided the agency, it appears tha the test procedure used in the penetration resistance test is not appropriate for the newly developed 2-ply windshield. As correctly noted in General Motor's letter, the purpose of the test is to determine whether an item of glazing has satisfactory penetration resistance. Because of (sic) 2-ply glazing material has more flexibility than conventional HPR glazing, the 2-ply material merely flexs (sic) and drops through the wooden test frame when it is struck by the steel ball. Thus, it is not possible to evaluate the penetration resistance of the 2-ply material in the same manner as conventional HPR glazing.; I do not, however, believe that the agency can adopt, b interpretation, a change in the test procedure you have requested. At present, the test procedure provides that the test sample is to be supported in a square wooden frame. The frame, as depicted in Figure 1 of ANS Z26.1, is made so that there is a 7/16 inch lip around the inside edge of the frame. The glass sample is placed inside the frame and supported by the lip during the drop test. The test procedure does not provide for clamping or otherwise holding the sample in place during the drop test.; To address the problem you have raised and to ensure objectivity in th drop test procedure, the agency believes it is necessary to amend the standard to establish uniform requirements for providing additional support to 2-ply glazing materials during the drop test. We will treat the General Motors letter as a petition for rulemaking to amend the standard to set a new test procedure for the impact resistance test. In considering possible amendments, we will carefully examine the work we understand is being done by the International Standards Organization on the clamping of test samples for the drop test.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam2379OpenMr. A. F. Hulverson, Vice President, Engineering, Fruehauf Division, Fruehauf Corporation, 10900 Harper Avenue, P.O. Box 238, Detroit, MI 48232; Mr. A. F. Hulverson Vice President Engineering Fruehauf Division Fruehauf Corporation 10900 Harper Avenue P.O. Box 238 Detroit MI 48232; Dear Mr. Hulverson: This responds to your August 17, 1976, question whether the 'no lockup requirement of S5.3.1 of Standard No. 121, *Air Brake Systems*, requires wheel sensors on both axles of a tandem axle system in those cases where the 'no lockup' performance is provided by means of an antilock system. Sections S5.3.1 (trucks and buses) and S5.3.2 (trailers) specify that the vehicle shall, under various load, road surface, and speed conditions, be capable of stopping; >>>. . .without lockup of any wheel at speeds above 10 mph, except for: (a) Controlled lockup of wheels allowed by an antilock system. . . (b)<<< This basic requirement is stated in performance terms, permitting manufacturer to choose any brake system design that will ensure that the wheels do not lock up under the specified conditions.; The exception to the 'no lockup' requirement set forth above permit 'controlled lockup of wheels allowed by an antilock system.' Manufacturers demonstrated, during the course of rulemaking, that properly functioning antilock systems might be designed to allow wheel lockup for a fraction of a second, and that antilock design should not be inhibited by a prohibition on all lockup. The agency made the 'controlled lockup' exception a part of the standard (36 FR 3817, February 27, 1971) and has subsequently interpreted the term to permit manufacturers latitude in the design of their systems.; In compliance with the basic requirement, most manufacturers hav equipped each axle of a vehicle with a valve to regulate the air pressure that applies the brakes, sensors at each wheel to send a signal when a wheel is locking up, and a logic module that receives the signals and instructs the valve when to release air pressure to prevent lockup ('axle-by-axle control'). Recently, some manufacturers have simplified their systems by utilizing only one valve and logic module to modulate the air supply to both axles of the typical tandem axle system found on many trucks and trailers ('tandem control'). Two approaches to wheel sensor placement have been used for tandem control systems. If it is possible to predict which of the two axles will lock first during braking, sensors may be placed on this axle only, knowing that reduced air pressure in response to a signal from the 'sensed' axle will also release the brakes on the 'unsensed' axle. In other cases, where it is not possible to predict which axle will lock first, tandem control systems may have sensors on all four wheels of the tandem.; In November 12, 1974, and March 7, 1975, letters of interpretation t Dana Corporation, the NHTSA confirmed that a manufacturer may choose the number of wheel speed sensors and logic modules that he includes in his antilock system. Thus, tandem control is not prohibited by the standard, regardless of the number of wheel speed sensors provided. When Dana asked if lockup on the unsensed axle of a single-axle sensor system would qualify for the 'controlled lockup' exception of the requirement, the agency said that it would not, reasoning that the logic module would not exert effective control over the lockup of the unsensed axle without benefit of input signals from wheels on that axle. Therefore, according to the Dana interpretation, the unsensed axle in a single-axle sensor system could not be allowed to lock at all, even momentarily, during the service brake stopping test. No data of actual performance was submitted with the Dana letter.; Your letter argues that the NHTSA's interpretation of 'controlle lockup' (to Dana Corporation) creates an anomalous and unjustified restriction on the use of 'tandem control.' Your submission, and data received by the agency from other interested persons, demonstrate that the Dana interpretation does not adequately reflect the degree of control which a single-axle sensor system actually can exert over the unsensed axle of a tandem system. Based on analysis of the submitted data, it appears that the amount of lockup permitted on unsensed axles is closely controlled by the available antilock systems. While there is a measurable difference in stopping performance between 'axle-by-axle' control and 'tandem control,' the standard already permits either of these means to satisfy the requirements. When the narrower question of the performance difference between sensors on one or both axles is analyzed, it is apparent that virtually no difference exists in the stopping distance of vehicles equipped these two ways. The effective lateral stability available during a stop also appears comparable regardless of placement of sensors on one or both axles. A technical report summarizing these findings will be placed in the public docket as soon as possible.; For this reason, and based on review of test data unavailable at th time of the Dana interpretation, the agency concludes that its interpretation of 'controlled lockup' in response to the question posed by Dana should be, and is hereby, withdrawn. It is the agency's interpretation that the 'controlled lockup' exception is not dependent on the number or location of sensors used in an antilock installation.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0344OpenMr. Donald W. Taylor, Product Techniques Section Manager, SAAB-Scania of America, Inc., 100 Waterfront Street, New Haven, CT 06506; Mr. Donald W. Taylor Product Techniques Section Manager SAAB-Scania of America Inc. 100 Waterfront Street New Haven CT 06506; Dear Mr. Taylor:#This is in reply to your petition of March 12, 1971 for amendment of Motor Vehicle Safety Standard No. 101, *Control Location, Identification, and Illumination*.#You petitioned that the abbreviation for the defroster control identification be changed from 'DEF' to 'DEFR.' In the preamble to the reconsideration and amendment of Standard No. 101, (36 F.R. 8269, May 4, 1971), a copy of which I enclose, this agency noted that additional identifying words or symbols are permissible if they do not conflict with the required or permissible words and symbols set out in Standard No. 101. In our opinion your use of 'DEFR' would create no conflict.#You also petitioned that certain controls located below the drivers H point and available to all passengers be exempted from the control identification illumination requirement. The recent amendment to Standard No. 101 no longer required illumination of all heating and air conditioning controls, but only those that direct air directly upon the windshield. We believe this may be responsive to your petition.#Finally, you asked that we define our position on bilingual control identification. Identification in a language other than English is permissible, in the language of the preamble to the recent amendment, 'as long as the additional words . . . do not conflict with the required words . . .'#We hope this answers your questions.#Sincerely, Robert L. Carter, Acting Associate Administrator, Motor Vehicle Programs; |
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ID: aiam3991OpenMr. John A. Pachuta, Director, Bureau of Motor Vehicles, Commonwealth of Pennsylvania, Department of Transportation, Harrisburg, PA 17122; Mr. John A. Pachuta Director Bureau of Motor Vehicles Commonwealth of Pennsylvania Department of Transportation Harrisburg PA 17122; Dear Mr. Pachuta: Thank you for your letter of July 16, 1985, concerning Federal odomete disclosure requirements. You enclosed sample copies of the revised Pennsylvania Certification of Title (form MV-4 9-84 ) and the Dealer Assignment Covering a Vehicle Acquired and Held for Resale (form MV 9-82 ), to demonstrate that the signature of a purchaser is required in such transactions.; We appreciate Pennsylvania's efforts to assure purchasers' signature on title documents bearing odometer disclosures, as required by the Federal odometer statute (Title IV of the Motor Vehicle Information and Cost Savings Act) and the implementing regulations (49 CFR Part 580). Because the Bureau of Motor Vehicles requires the 'Dealer Assignment' form as an attachment to the Certificate of Title, no additional odometer disclosure statement is necessary if the vehicle is transferred within Pennsylvania.; However, if a vehicle is either retailed or wholesaled to a out-of-state purchaser, a separate odometer statement must still be executed, to assure that the purchaser acknowledges the odometer reading at the time of transfer, as required by 49 CFR S 580.4(e).; For your reference, I have enclosed copies of documents concerning a actual vehicle transfer from Pennsylvania to an out-of-state dealer which did not provide for a purchaser's signature. In that case, the seller (We Try Harder, Inc.) sold the vehicle to a Massachusetts dealer (J&R Whlsle), which in turned assigned the vehicle on a Massachusetts reassignment form. A later odometer reading was disclosed and acknowledged by a subsequent dealer-purchaser in New Jersey, but neither the Pennsylvania title nor the Massachusetts from provided for a signature to demonstrate that the intervening dealer-purchaser was aware of the odometer reading, as required by our regulations.; If it is not practical at this time to revise the Pennsylvania title t include the purchaser's signature prior to assignment or reassignment to an out-of-state party, I urge you to remind such transferors to issue a separate odometer disclosure statement.; Please feel free to contact Ms. Judith Kaleta of this offic (202/426-1834) if you have any questions concerning applicable Federal odometer disclosure requirements.; Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam2683OpenMr. Donald H. Carter, 300 W. 11th Street, Reno, NV 89503; Mr. Donald H. Carter 300 W. 11th Street Reno NV 89503; Dear Mr. Carter: This is in response to your letters of August 24, 1977, and October 8 1977, concerning your Ford F-150 pickup truck.; The November 1976 date on your truck's certification label refers onl to the date of actual manufacture of the vehicle, not its model year. Virtually all manufacturers, including Ford, utilize a model year which does not correspond to the calendar year. Typically, for American manufacturers, this model year begins on September 1 of the previous calendar year, i.e., model year 1977 began on September 1, 1976. Manufacturers usually begin manufacture of their vehicles as early as July in order to have sufficient vehicles in their showrooms by the September start of the model year.; All Federal motor vehicle safety standards specify a date on whic their requirements become effective. Thus, a manufacturer must indicate by the certification label that its vehicles are in compliance with all Federal standards in effect on the date of the vehicles' manufacture. Whether a vehicle is marketed as a particular model year vehicle depends upon the manufacturer's own marketing practice. The certification date does not represent the model year date.; Finally, your first letter stated that your vehicle was ordered o November 4, 1976, with a 3 month delivery interval. Every manufacturer produces a large number of vehicles before there are orders for a specific vehicle, and maintains them in various storage locations around the country. When the manufacturer receives an order from a dealership for a specific vehicle, it will first determine whether it already has such a vehicle in stock, and if it does, it will ship that vehicle rather than specially manufacture a new vehicle.; However, if there is no identical vehicle in stock, it will manufactur one specifically for that order, which can take from a few days to several months to program into the assembly line and produce. As a dealership has no way to know in advance whether the vehicle it ordered is in stock or will have to be specially manufactured, it will often state a delivery date that anticipates the longest possible delay which would result from special manufacture. There is thus no reason for concern over the fact that your vehicle was manufactured in the same month it was ordered. Either Ford had such a vehicle in stock, or was able to manufacture one with very little delay.; I hope that this letter has answered your concerns. Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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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.