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 |
|---|---|
ID: 20132.ztvOpenMr. Shigeyoshi Aihara Dear Mr. Aihara: This is in reply to your letter of June 10, 1999, presented at a meeting with NHTSA representatives that day, asking for an interpretation of S5.1.2 of Federal Motor Vehicle Safety Standard No. 108. I am sorry that we were unable to provide you a response by July 6 as you requested in your letter of June 28 to Taylor Vinson of this Office. Your company has developed a new rear turn signal lamp, consisting of an outer plastic lens, an inner cap, and an uncolored filament bulb. The color of the lens is "pale (light) pink color, and, this plastic material complies with the requirements of SAE J576c . . . excluding the color requirement." You tell us that the trichromaticity coordinates of the plastic material used in the outer lens do not fall within either the red or the white areas of the chromaticity chart of SAE J578c. However, when illuminated, the lamp provides an amber color that fall within the coordinates specified in SAE J578c. You have asked whether this design is acceptable under S5.1.2 relating to plastic materials used in optical parts of motor vehicle lighting devices. Although this does not affect our answer to your question, please note, in Standard No. 108, that SAE Recommended Practice J576c of 1970 has been replaced by SAE J576 JUL91 as the applicable standard for plastic materials used in lighting devices. However, J578c remains the Federal standard for color. We regret to inform you that this design is not acceptable. Although S1, Scope, of SAE J578c states that "The specification applies to the overall effective color of light emitted by the device," regardless of the color of its lens, both SAE J576 JUL91 and Standard No. 108 apply the color requirement to plastic components of lamps as well. S5.1.2(e) of Standard No. 108 requires the trichromatic coordinates of the plastic samples, tested according to that paragraph, to conform to the requirements of SAE J578c. Paragraphs 4.1 and 4.2.2 of SAE J576 JUL91 also require conformance of plastic samples to the chromaticity coordinate requirements of SAE J578c. This standard specifies color coordinates only for red, white, yellow (amber), green, and blue. Because the lens of your lamp does not meet any of the coordinates of SAE J578c, Standard No. 108 does not permit its use. At the meeting, we noted that the iner lens was a greenish color. It, too, must comply with the color coordinate requirements of paragraphs 4.1 and 4.2.2 of SAE J576 JUL91. At that time, you also asked if it were acceptable to use a plastic fabricated from the mix of two resins, each of which complied with the requirements of SAE J576. You cannot assume, when two complying resins are blended, that the resulting plastic will also comply with SAE J576 JUL91, and we recommend that you test the blended plastic to ensure that it meets all the specifications of S5.1.2 and SAE J576 JUL91. This would be the case whether it was the intent to create a new color, or whether the rejected molded parts are reground and plastics of differing compositions are mixed and recycled into newly-molded lamp lenses. As we said in the preamble to the 1995 final rule amending S5.1.2, "it is incumbent upon the vehicle or equipment manufacturer . . . not to change the composition of the plastics materials [obtained from the plastics manufacturer] in a manner that would cause it to be noncomplying." 60 FR 46066, copy enclosed. Sincerely, |
1999 |
ID: 20146.drnOpenDr. Barbara Goodman Dear Dr. Goodman: This responds to your request for an interpretation on the continuing validity of the National Highway Traffic Safety Administration's interpretation letter of August 11,1987, to Mr. Ernest Farmer, Director of Pupil Transportation of the Tennessee Department of Education on refurbishing school buses. This letter confirms that the August 11, 1987, interpretation letter to Mr. Farmer is still valid. For your information, I am enclosing a copy of a May 2, 1988, interpretation letter to Robert R. Keatinge, Esq. The Keatinge letter clarifies the Farmer letter by explaining that in interpreting 49 CFR 571.7(e), the Farmer letter understood the bus bodies involved to be new. Therefore, the Farmer letter did not purport to address the question of combining an old bus body with new and/or used chassis components. I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, |
1999 |
ID: 20159.ztvOpenMs. Tammy Ruff Dear Ms Ruff: The Federal Highway Administration has forwarded to us for reply your letter of May 5, 1999. Your letter has been supplemented with information obtained from a telephone call to your office on June 23, 1999, by the agency's Office of Vehicle Safety Compliance, as well as from your website on June 22, 1999. You ask for a list of "the necessary equipment to enable the street legal construction of dune buggies to be driven in Hawaii" as rental vehicles. Under the laws that we administer, a vehicle that is "street legal," i.e., which is manufactured primarily for use on the public roads, is required to comply with all applicable Federal motor vehicle safety standards. Your website information describes the Sandrail as "designed to be driven on soft sand, the beach and tall hills." Thus, the Sandrail has not been designed primarily for on road use and, in its present configuration, is not a "motor vehicle" subject to our jurisdiction. However, your present intent is to construct "street legal" Sandrails. We shall consider those vehicles as manufactured primarily for use on the public roads and therefore "motor vehicles" which must comply with our laws regulating motor vehicles and their manufacturers. Our Office of Vehicle Safety Compliance learned from your company on June 23, 1999, that the vehicles that Sandrail intends to manufacture will be capable of speeds of more than 25 miles per hour. The on-road Sandrail will be required to meet the same Federal motor vehicle safety standards as "multipurpose passenger vehicles" (assuming that the dune buggies retain their capability for occasional off-road operation). These standards include the requirements to provide air bags for the driver and outboard front seat passenger. Sandrail is also required to submit to this agency certain information relating to its VIN in accordance with 49 CFR Part 565 Vehicle Information Number. Sandrail is also required, within 30 days after it commences manufacture of motor vehicles, to file with us an information statement in compliance with 49 CFR Part 566 Manufacturer Identification. I enclose a copy of a "New Manufacturers" information package which will outline our requirements for manufacturers. If you would like more information on the Federal motor vehicle safety standards, or have any other questions, please contact the agency's Office of Vehicle Safety Compliance. Sincerely, |
1999 |
ID: 20161.ztvOpenMr. Ron Woodward, P.E. Dear Mr. Woodward: This is in reply to your letter of June 7, 1999, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. S7.8.2.1(c) of Standard No. 108 states that:
Paragraph S7.8.5.2 requires each headlamp system that is capable of being aimed by equipment installed on the vehicle to include a Vehicle Headlamp Aiming Device (VHAD) that conforms to the remainder of the paragraph. Paragraph S7.8.5.2(a)(2)(iv)requires that the horizontal indicator of a horizontal adjustment mechanism of a VHAD
You ask for
You give as an example a lamp that has a +/- 1 degree of horizontal travel. You are asking for an interpretation that a system that adjusts a headlamp horizontally but which differs from the specifications of S7.8.5.2 is not a "horizontal adjustment system" within the meaning of S7.8.2.1(c). We cannot provide the interpretation you seek. You admit that the headlamp is not fixed but is adjustable horizontally up to +/- 1 degree. As you note, "[t]he standard . . . states that the only acceptable type of horizontal adjuster is a horizontal adjuster which conforms to the horizontal VHAD requirements contained in the standard." Standard No. 108 is quite clear on this point: a manufacturer need not provide a horizontal adjustment mechanism on a headlamp that is visually/optically aimable and has a lower beam. But if the manufacturer chooses to provide a mechanism that adjusts the headlamp, it must meet all requirements of S7.8.5.2 including the +/-2.5 degree specification, even if the headlamp itself is designed for only +/- 1 degree of horizontal travel. Because we cannot concur with your desired interpretation, we are treating this matter as a petition for rulemaking in accordance with your request. We have forwarded your letter to the Associate Administrator for Safety Performance Standards who will respond to your petition. If you have any questions, you may call Taylor Vinson of this Office (202-366-5263). Sincerely, |
1999 |
ID: 20174.ztvOpenMr. Bart W. Hill Dear Mr. Hill: This is in reply to your letter of June 9, 1999, with respect to the operation of side turn signal lamps on dump bodies that your company manufactures. Thank you for including photos to help us advise you. You install side turn signal lamps on your products. The wiring on trucks with dump bodies is such that "the side turn also lights when the brakes are applied" (we understand that the side turn signal is steady burning when activated by the brakes). A Pennsylvania state police officer has told your customer that this is illegal. However, the Pennsylvania Department of Transportation ("PennDot")has informed you that it is legal "if it does not violate the Federal standard." Therefore, you have asked whether this configuration does violate the Federal standard. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, does not require a vehicle to have side turn signal lamps. S5.1.3 of Standard No. 108 prohibits the installation of supplemental lighting equipment if the lamps would impair the effectiveness of lighting equipment that the standard requires. As we see it, the question here is whether the operation of both amber-colored side turn signal lamps in a steady burning mode when the red stop lamps are activated in a steady burning mode can be said to impair the effectiveness of the stop lamps. The activation of both side turn signal lamps in a steady burning mode is the functional equivalent of an amber supplementary stop lamp that is mounted on the vehicle's side. In our opinion, auxiliary lighting equipment must perform in the same manner, and perform the same function, as the original equipment it is intended to supplement. Standardization of signals is important so that following drivers will not hesitate to respond when the brakes of a vehicle are applied and its stop lamps are activated. The combination of amber side lamps and red rear ones have the potential to create confusion in adjacent and following drivers. I am sorry, therefore, to tell you that we have concluded that your system of amber stop lamps would impair the effectiveness of the stop lamps required by Standard No. 108, and, hence is impermissible under S5.1.3. If you have any questions you may phone Taylor Vinson of this Office (202-366-5263). Sincerely, |
1999 |
ID: 20176.ztvOpenMs. Debra Taylor Re: Classification of Airfield Bus as "Off Road" Vehicle Dear Ms. Taylor: We are replying to your letter of June 19, 1999. You have asked for confirmation that the Cobus 3000 is an "off road" vehicle, and "as such with which Federal and State specifications and regulations, if any we must comply with to legally sell our bus to Covington Airport in northern Kentucky." The National Highway Traffic Safety Administration is authorized to regulate "motor vehicles." A "motor vehicle" is defined in pertinent part as a vehicle "manufactured primarily for use on the public streets, roads, and highways" (49 U.S.C. 30103(a)(6)). You have enclosed a brochure on the Cobus 3000 and tell us that it is "built specifically for airfield use, to transport passengers between a remotely parked aircraft and the terminal or from terminal to terminal." The brochure identifies the Cobus 3000 as "the airport star" and depicts it in various applications around airfields. We do not consider airfields to be "public roads," nor such service roads as may lead from terminal to terminal or from parking lots to terminals. Therefore, we do not consider the Cobus 3000 to be "manufactured primarily for use on the public roads," and a "motor vehicle" subject to our jurisdiction (we have no definition of an "off road" vehicle as such). This means that there are no regulations or specifications of this agency that apply to the Cobus 3000. The Consumer Product Safety Commission (CPSC) has jurisdiction over vehicles that are not motor vehicles. We are unable to advise you whether the CPSChas issued regulations covering airport buses. I am sorry that we are also unable to advise you whether either Kentucky or the Covington airport authority has issued rules or regulations on airport buses. Sincerely, |
1999 |
ID: 20178.ztvOpenECIE Dear Ms. Migliazza: We are replying to your emails of June 18, 1999, to Kenneth Weinstein of this agency, and of July 8, 1999, to Taylor Vinson of this Office. We apologize for the delay in responding to you. In your first email, you have told us that your company manufactures lighting equipment for motorcycles and that you "have the certificate of compliance and test report of our device with tests according to your FMVSS 108." You have asked whether the certificate of compliance is "always acceptable for you or have we to remake all the test to obtain another certificate after some year?" You reference a headlamp that meets the 1992 version of Standard No. 108 and is molded with a "92DOT" symbol, which is supported by "the test report and the certificate of compliance of 1992." First, a clarification. We believe that you are using the term "certificate of compliance" to mean the statement by a test laboratory that the lighting device that it has tested meets the specifications of Standard No. 108, as indicated by the accompanying test report. However, under our laws, a "certificate of compliance" is the indication by a manufacturer that its lighting product meets Standard No. 108, such as the DOT symbol on a headlamp lens. Each item of motorcycle lighting equipment covered by Standard No. 108 must comply with the standard, and be certified by its manufacturer as conforming to the standard. A test report based on proper testing can verify that the particular lamp tested conforms to Standard No. 108, and can afford a reasonable basis for the manufacturer to certify compliance, by concluding that identical lamps, if tested, would also conform to Standard No. 108. However, human and mechanical errors in production (such as failure to account for variations in tolerances) can result in the production of non-complying products. Therefore, we believe that a manufacturer of lighting equipment should test its product pursuant to a quality control program after the lighting item is produced to assure itself that the product as manufactured conforms to Standard No. 108. In your email of July 8, 1999, you ask if we can write "what is the US right procedure for lighting device certification." We are pleased to provide you with this information. The lens of each headlamp (other than a motorcycle headlamp) must be certified by marking it with the DOT symbol (S7.2(a) of Standard No. 108), whether the headlamp is original or replacement equipment. Other items of replacement lighting equipment, including motorcycle headlamps, may be certified either by marking with the DOT symbol (S5.8.10), or "by a label or tag on the equipment or on the outside of the container in which the equipment is delivered" (49 U.S.C. 30115). Other than headlamps, no certification is required for lighting items installed on a motor vehicle as original equipment; the manufacturer of the vehicle attaches a label to the vehicle certifying that it complies with all applicable Federal motor vehicle safety standards, and this includes certification to the requirements of Standard No. 108. Of course, the vehicle manufacturer should obtain test reports and other quality-related assurances from the lighting equipment manufacturer that the equipment complies before it affixes its vehicle certification label. There is no need to "register" a certificate of compliance with NHTSA or any other entity. However, a manufacturer located outside the United States is required to designate an agent in the United States who can receive official correspondence (49 CFR 551.45). Further, all manufacturers of equipment covered by Standard No. 108 are required to file an identification statement with us (49 CFR 566). I hope that this answers your questions. Sincerely, |
1999 |
ID: 20180.ztvOpenThe Honorable Orrin G. Hatch Dear Senator Hatch: Thank you for your letter of June 4, 1999, requesting our advice on "existing law regarding motor vehicle lighting and how that law affects a recent invention," which is described as an "enhanced motor vehicle warning system" ("the System"). Our agency, the National Highway Traffic Safety Administration (NHTSA), has been authorized by Congress to issue Federal motor vehicle safety standards. One of these standards prescribes performance requirements for both original and replacement motor vehicle lighting equipment, 49 CFR 571.108, Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Standard No. 108 requires motor vehicles to be manufactured in accordance with its requirements and prohibitions. The System works as follows. When a vehicle's horn is sounded, the System also flashes the vehicle's headlamp upper beams and its backup lamp or lamps. As you point out, paragraph S5.5.10(b) of Standard No. 108 allows the headlamps to be wired to flash for signaling purposes. However, as you also point out, S5.5.10(d) states that all other lamps shall be steady burning, and you conclude that the System would appear to violate this clause. You have asked for "an official interpretation of the rule to determine if the rear lamps, when connected to this device, would violate (d)." Your interpretation is correct; S5.5.10(d) does not allow the backup lamp or lamps to flash when in use, and the System is not permissible because it flashes the backup lamps. S5.5.10(a) specifies that hazard warning system lamps be wired to flash. One of your staff members discussed with us whether the System would be allowable were it modified to operate through the hazard warning system, which flashes in normal operation when activated by the driver, rather than through the backup lamps, which do not flash in use. The acceptability of such a Standard No. 108. This paragraph prohibits the installation of additional equipment on a vehicle if it would "impair the effectiveness" of lighting equipment required by the standard. In recent years, we have come to the conclusion that use of required lighting equipment for other than its original purpose may compromise and reduce its safety effectiveness. As we said in 1996,
We believe that a hazard warning system should not be used for the auxiliary purpose of providing an optical warning when the horn is sounded, since such a warning bears no relationship to the original purpose of a hazard warning signal and thus could create confusion about the meaning of the hazard warning signal. For this reason, we conclude that S5.1.3 would prohibit the optical warning system you describe even if it were modified to operate through the hazard warning system lamps. In the event that the System is precluded by Standard No. 108, you have asked about our procedure for petitioning for rulemaking to amend Standard No. 108. These procedures are set forth in 49 CFR 552.4. The petition must contain the name and address of the petitioner and be addressed to the NHTSA Administrator. It must be in the English language, prefaced by the word "Petition," set forth facts in support of an amendment, and contain a brief description of the substance of the requested amendment. We are required to inform the petitioner within 120 days whether the petition is granted or denied. If the petition is granted, action on it may not be immediate as the petition must take its place among other rulemaking priorities. Petitioners for changes in signaling lamp requirements should become familiar with the policy statement we issued in 1998 discussing how we evaluate rulemaking petitions to require or permit new or different signal lighting or signal lighting actuation (63 FR 59842). I enclose a copy for your information. You also express your understanding that "NHTSA can issue a letter stating that Standard 108 does not preclude the use of this device in new vehicles, thereby allowing this invention to be installed on new cars." We do provide interpretive letters of this nature when a product does not conflict with the requirements and prohibitions of Standard No. 108. For the reasons indicated above, we cannot provide such a letter for this System. Although a copy of the patent of the device and related application data did not accompany your letter, we did not need this information for purposes of this interpretation. If your staff has further questions, they may call Taylor Vinson of this Office (202-366-5263), the attorney who has previously spoken with your office on this subject. Sincerely, |
1999 |
ID: 20240.ztvOpenMr. Peter Shaw Dear Mr. Shaw: This is in reply to your letter concerning the classification of certain portable asphalt storage tanks that you are manufacturing for a United States corporation. I apologize for the delay in our response. The U.S. corporation will import these tanks and you have been advised by George Entwistle of our agency that they may be imported under Box 8 of Form HS-7 "Declaration" as off-road vehicles. You have asked that we confirm that the tanks may be so imported. A "motor vehicle" may not be imported into the United States unless it conforms to all Federal motor vehicle safety standards that applied on the date of its manufacture and is so certified by its manufacturer (49 U.S.C. 30112(a)). A "motor vehicle" is defined, in part, as a vehicle driven or drawn by mechanical power that is "manufactured primarily for use on the public streets, roads, and highways" (49 U.S.C. 30103(a)(6)). You have informed us that:
From this description, it appears that the portable asphalt tank has not been manufactured "primarily for use on the public roads," within the meaning of the definition, and that its use of the public roads is infrequent and incidental to the primary purpose for which the tanks have been built. This purpose is the storage of asphalt for use on construction sites (which may or may not be on the public roads). Accordingly, we confirm that you need not manufacture them to comply with the U.S. Federal motor vehicle safety standards, and that the U.S. corporation may import them pursuant to the declaration of Box 8 that they have not been manufactured primarily for use on the public roads. We note that, as a matter of law, there is no such thing as "D.O.T. approved parts." We have no authority to approve or disapprove motor vehicles or equipment items. If you use this term to mean that an equipment item such as a tire or lamp bears a DOT symbol, the symbol means only that the manufacturer is thereby certifying compliance of that product with the appropriate Federal motor vehicle safety standard. In no sense can you use the term in connection with parts of an air brake system since the manufacturer of the vehicle certifies to the overall performance of the vehicle's air brake system without reference to any individual part. If you have any questions, you may call Taylor Vinson of this Office (202-366-5263). Sincerely, |
2000 |
ID: 20264.drnOpenRussell Roden, P.E. Dear Mr. Roden: This responds to your request for an interpretation whether your products are "motor vehicles" within the National Highway Traffic Safety Administration's (NHTSA's) definition. As explained below, the answer is no. Your letter states that your company designs and manufactures "modular process systems" for the construction, industrial maintenance, and the quarry and mining industry. Your products include grit recycling and dust collection systems, and sand "dedusting units." In order to facilitate movement, your company's equipment is permanently attached to flat trailers which are manufactured by another company. You emphasize that the equipment your company designs and manufactures is a "process system where the trailer is used as a base skid with wheels for mobility and erection." As an example of your company's products, you included a photograph of an "air classification system" used in the bridge and industrial painting industry and in the quarry and mining industry. In a telephone conversation with Dorothy Nakama of my staff, you explained that the length of time your company's equipment is at a job site depends on the task. The equipment could be at a maintenance or construction site or at a quarry for years at a time. You stated that the equipment rarely stays at a job site for less than six to eight weeks. NHTSA's statute defines "motor vehicle" at 49 U.S.C. 30102(a)(6) as:
Whether the agency considers your products to be motor vehicles depends on their use. The statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. In contrast are instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time. Such vehicles are considered motor vehicles for purposes of our statute, since the on-highway use is more than "incidental." Based on your description, it appears that your company's vehicles are not motor vehicles within the meaning of our statute. This is because the vehicles stay on job sites for extended periods of time (usually for months or years) and only use the highway to move from site to site. We may reassess this interpretation if we were to receive additional information indicating that your vehicles use the roads more than on an incidental basis. Please note that since States may require products such as those which your company manufactures to be registered, you may wish to contact State motor vehicle administrators to determine whether there are State requirements you must meet. You also pose several questions about the application of excise taxes to your product. We are unable to answer questions relating to taxes. For further information about Federal taxes, please contact the U.S. Internal Revenue Service (IRS). The IRS's web site is at www.irs.gov. You should contact the State of Maryland for information about Maryland tax law. I hope this information is helpful. If you have any questions, please contact Dorothy Nakama at (202) 366-2992. Sincerely, |
1999 |
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.