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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



Displaying 1991 - 2000 of 16508
Interpretations Date
 

ID: aiam1964

Open
Mr. Robert P. Crawford, President, Athens Sport Cycles, Inc., 20 W. Stimson Avenue, Athens, OH 45701; Mr. Robert P. Crawford
President
Athens Sport Cycles
Inc.
20 W. Stimson Avenue
Athens
OH 45701;

Dear Mr. Crawford: This is in response to your letter of May 18, 1975, in which you ask number of questions relating to tire registration procedures, and in amplification of your telephone conversation with Mr. Schwartz of my office. We will answer your questions in the order raised.; >>>1 and 2. There is a universal tire registration form (figure 3 i the enclosed Part 574) which manufacturers are required to furnish to you or you may reproduce pursuant to S 574.7 of the regulation.; 3. Since the regulation requires that the manufacturers or their agent maintain the records, the forms should either be sent to the manufacturer or his designated agent. A number of manufacturers utilize services such as the Tire Safety Registry in New Jersey to keep their records, but they merely act as the manufacturer's agent. There is to our knowledge no central place to send the forms for all manufacturers.; 4. We have no idea what is meant by a retailer I.D. number. Ou recommendation is that you contact the manufacturers to determine what they mean.; 5. Our tire recordkeeping regulation only applies to tires for use o motor vehicles. Thus, tires for use on off-road vehicles would not fall within the regulation.; 6. As required by S 574.8 of the enclosed regulation, completed form must be sent to manufacturers every 30 days. The only exception is where you sell less than 40 tires of all makes and manufacturers in the 30- day period, in which case you may wait until you sell 40 tires or for 6 months, whichever comes first.; 7. Retailers are not required to keep any tire owner forms. 8. It is the responsibility of the dealer to mail the forms, althoug he may ask the customer to fill out the form at the time of purchase.<<<; On behalf of the National Highway Traffic Safety Administration, let m commend you for your desire to fully comply with the requirements of our tire recordkeeping regulations. It is through the efforts of dealers such as you that motorcyclists and their passengers are protected against tire defects which might lead to injury or death.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam0676

Open
Mr. Keitaro Nakajima, Director/General Manager, Toyota Motor Sales, U.S.A., Inc., Lyndhurst Office Park, 1099 Wall Street, West, Lyndhurst, NJ, 07071; Mr. Keitaro Nakajima
Director/General Manager
Toyota Motor Sales
U.S.A.
Inc.
Lyndhurst Office Park
1099 Wall Street
West
Lyndhurst
NJ
07071;

Dear Mr. Nakajima: This is in reply to your letter of March 30, 1972, in which you as whether, under the procedures of paragraph S5.2.1 of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' you may interpret the reference to materials having a 'thickness' exceeding 1/2 inch to mean the 'design thickness.' You request this interpretation because it appears that some materials having a design thickness of 1/2 inch or less may increase in thickness due to vibration or moisture absorbtion. In cutting these materials down to the 1/2-inch thickness for testing purposes, you say a fluffy surface is created which burns at a much higher rate than the material's original surface.; For purposes of testing for compliance with the standard, manufacturer are free to deviate from the procedures specified in the standard as long as the results they obtain can be correlated to results obtained using the test procedures of the standard. The test procedures specified in S5.2.1 are not, however, intended to result in a changing of the texture of a material's surface when the material is cut to the specified size. Consequently, while we cannot approve of the interpretation you request, we would consider a slight deviation in the thickness of tested materials from the 1/2-inch specification, in order to preserve the original surface of the material, to be consistent with the standard's test procedure. I point out further that the NHTSA is aware of the problems you have encountered, and is presently considering amendments to the standard which would alter this result.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam5474

Open
Mr. Fredd Scheys President S.E.C. Carat, Inc. 1379 Old Railroad Bed Road Madison, AL 35758-9002; Mr. Fredd Scheys President S.E.C. Carat
Inc. 1379 Old Railroad Bed Road Madison
AL 35758-9002;

Dear Mr. Scheys: This responds to your FAX of January 25, 1995, to Joh Womack of this Office asking whether the interpretation letter sent to you on November 16, 1992, and confirmation letter sent you on March 8, 1993, remain valid. This confirms that these letters remain valid. We note that the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) was recodified in July 1994. The correct citation today is 49 U.S.C. Chapter 301 - Motor Vehicle Safety. The first full paragraph of the second page of the November 16, 1992, letter refers to 'Title 15, United States Code, section 1397(b)(2).' Under the recodification, the citation has become 'Title 49 United States Code, section 30122(b)'. Further, the quoted phrase in that paragraph that reads 'knowingly rendering inoperative in whole or in part any device of element of design installed in accordance with a Federal motor vehicle safety standard' has been restated to read 'knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard.' But the meaning remains the same and there is no substantive change in the prohibition. Sincerely, Philip R. Recht Chief Counsel;

ID: aiam0699

Open
Mr. David J. Humphreys, RVI Washington Counsel, Recreatinal Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC, 20006; Mr. David J. Humphreys
RVI Washington Counsel
Recreatinal Vehicle Institute
Inc.
Suite 406
1140 Connecticut Avenue
Washington
DC
20006;

Dear Mr. Humphreys: This is in reply to your letter of April 25, 1972, concerning th application of Motor Vehicle Safety Standard No. 302 to various components of motor homes. You raise numerous questions in your letter which are restated (rephrased in some cases to facilitate our response) and answered below>; >>>1. (Page 1) 'When speaking of wheel housing and engine compartmen covers we assume this applies only to such coverings on the interior of the vehicle occupancy compartment.'; That is correct. 2. (Page 2, first paragraph) You list several components which yo assume are subject to the standard. We concur that each of these components are subject to the standard with the exception of 'gaucho and daveno' seat cushions, but only because we are not familiar with these terms.; You are also correct in your conclusion that the standard applies t the foam or other material used in seat cushions even though they may also be converted into beds.; 3. (Page 2) 'It would also appear that the standard is applicable t the mattress itself, i.e., the filling material . . . if the mattress cover is 'bonded, sewed, or mechanically attached' to the mattress itself . . .'; S4.2 of the standard lists mattress covers only, and does not apply t the filling of the mattress.; 4. (Page 2) You ask whether seat frames, constructed of plywood o similar materials, are subject to the standard. The standard is not intended to apply to seat frames, and these components need not meet its requirements.; 5. On the bottom of page 2 you refer to the language of the propose amendment to the standard (36 F.R. 9565, May 26, 1971), and ask whether mattress filling and seat frames would have to be tested under the proposal irrespective of whether they are attached to the surface material.; As stated above, neither seat frames nor mattress filling is subject t the standard and would not be required to meet the proposed requirements.; 6. (Page 3) You ask for an interpretation of the phrase 'compartmen shelves.' We consider this term to apply to open shelves, and to not include shelves which are found in cupboards or closets. However, if a shelf is a 'compartment shelf' under the standard, it must meet the requirements as it appears in the vehicle, either with or without coverings, whatever the case may be. Your statement that the standard applies 'only to such shelves if there is a shelf covering' is incorrect.; 7. (Page 3, second paragraph) We agree with your statement that th standard does not apply, with the exceptions noted, to storage cabinets or compartments. We disagree, however, with your statements regarding wall or other compartment panelling, lavatory tops, commodes or toilets, and your discussion of trim panels. We would consider walls to be side trim panels and subject to the standard. Similarly, lavatory tops may be compartment shelves under the standard, and toilets seats are included under the terms seat cushions and seat backs. Moreover, 'trim panels' include trim on walls as well as on instrument panels and doors, and they are subject to the standard.<<<; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam5161

Open
Mr. Larry Bluthardt Director of Pupil Transportation Kansas Department of Transportation Docking State Office Building Topeka, KS 66612-1568; Mr. Larry Bluthardt Director of Pupil Transportation Kansas Department of Transportation Docking State Office Building Topeka
KS 66612-1568;

"Dear Mr. Bluthardt: This responds to your letter of March 19, 1993 concerning the use of built-up foot operated throttle controls. Your questions and the answers to each follows. 1. Is there a violation of the FMCSR's in conjunction with the FMVSS concerning the modification of a school bus foot operated throttle control or other equipment modifications that may relate to the physical accommodation of a commercially licensed driver to perform his or her duties behind the wheel? My answer is limited to a discussion of the Federal Motor Vehicle Safety Standards (FMVSS's), since NHTSA issued these under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act). The Federal motor carrier safety regulations (FMCSR's) are issued by the Federal Highway Administration. For information on the FMCSR's you should contact: Office of Motor Carrier Standards Room 3404 Federal Highway Administration 400 Seventh Street, S.W. Washington, D.C. 20590 (202) 366-1790 The Safety Act authorizes NHTSA to issue FMVSS's that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. NHTSA has exercised its authority to establish Standard No. 124, Accelerator Control Systems (49 CFR 571.124). Standard No. 124 'establishes requirements for the return of a vehicle's throttle to the idle position when the driver removes the actuating force from the accelerator control.' The Safety Act requires each vehicle manufacturer to certify that its vehicle complies with all applicable safety standards, including Standard No. 124. This certification process requires each manufacturer to determine in the exercise of due care that its products meet all applicable requirements. If the throttle control or other equipment on the new school bus were modified by the bus manufacturer, the bus manufacturer must ensure that the vehicle meets all applicable FMVSS's, including Standard No. 124. If the throttle control or other equipment were modified on a new, previously-certified vehicle (e.g., a new, completed school bus) prior to the new vehicle's first sale, the person who modifies the vehicle would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the modification. (See 49 CFR 567.7.) If the modification is made after the vehicle's first sale, the only NHTSA requirement that would affect the modification is the 'render inoperative' prohibition in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section provides that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard. The 'render inoperative' provision would prohibit a commercial business listed in 108(a)(2)(A) from modifying the foot operated throttle in a manner that would negatively affect the vehicle's compliance with Standard No. 124. If the foot operated throttle control was built up in a way that prevented the throttle from returning to idle when the driver removed his or her foot, it would violate the render inoperative prohibition. Please note that the render inoperative prohibition only applies to the named commercial entities. Owners may modify their vehicles without violating any laws or regulations administered by this agency. However, NHTSA encourages vehicle owners not to tamper with vehicle safety equipment if the modification would degrade the safety of the vehicle. 2. If we can modify the foot operated throttle control to the vehicle (school bus), does the modification require specific registration, certification, or inspection prior to the installation? FOR EXAMPLE: Can the modification be made and installed locally, or should the modification be purchased and installed by a certified commercial vendor ie., manufacturer. NHTSA does not limit who may modify vehicles, and does not approve modifications or motor vehicle designs. Thus, the person making the modification does not receive any NHTSA approval prior to making the modification. If the modification is made by a manufacturer, distributor, dealer or repair business, 108(a)(2)(A) would be a factor in how the modification may be performed. As explained above, those persons must not render inoperative any device or design installed pursuant to an FMVSS. State law might affect how a throttle control can be modified on a vehicle. We suggest you consult with your State as to whether its law might affect the registration or inspection of the modified vehicle. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel cc: Office of Motor Carrier Standards";

ID: aiam0363

Open
Mr. Bob Stallius, Hopkinsville Tire Service, Route 1, Fort Campbell Boulevard, Hopkinsville, KY 42240; Mr. Bob Stallius
Hopkinsville Tire Service
Route 1
Fort Campbell Boulevard
Hopkinsville
KY 42240;

Dear Mr. Stallius: This is in reply to your letter of May 14, 1971, concerning the Tir Identification and Record Keeping Regulation. Please accept my apology for not responding earlier.; The National Highway Traffic Safety Administration considers eac enforcement case on an individual basis. If a retreader could demonstrate that good faith attempts had been made to obtain the tin plate by May 22, 1971, and due to circumstances beyond his control he was unable to mark tires manufactured after May 22, 1971, with the required information, we would certainly take this into consideration before beginning any enforcement action.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam5531

Open
Mr. Paul D. Kelly Albertson, Ward & McCaffrey 36 Euclid Street Woodbury, NJ 08096; Mr. Paul D. Kelly Albertson
Ward & McCaffrey 36 Euclid Street Woodbury
NJ 08096;

"Dear Mr. Kelly: This responds to your letter of February 2, 1995 requesting permission or a waiver from the National Highway Traffic Safety Administration (NHTSA) to allow one of your clients, a 'corporation specializing in modification of vehicles for handicapped and disabled citizens,' to modify a vehicle for one of its customers. You explained that the customer 'suffers from a neuromuscular disorder which renders her partially paralyzed.' You further explained that '(s)he cannot turn the factory steering wheel because it is too thick for her to hold and too wide for her to see the gauges.' You described previous modifications done for this customer as follows: the steering box on a stock vehicle (would be) removed and the steering mechanism would be adjusted at a machine shop to a low effort or zero effort steering gear. From this point after-market steering wheels and column adapter kits would be installed to accept this new steering wheel. You explained that your client was concerned that they would no longer be permitted to make such modifications as removal of the original steering wheel also results in removal of the air bag. During an April 4, 1995 phone call with Mary Versailles of my staff you explained that the vehicle is also equipped with a wheelchair lift and that the floor of the vehicle has been lowered. As explained in this letter, replacement of the steering wheel is permitted provided that a lap/shoulder safety belt is installed at the driver's position. By way of background, the National Highway Traffic Safety Administration is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment (49 USC 30111). Manufacturers are required to certify that their products conform to all applicable safety standards before they can be offered for sale (49 USC 30112). If a certified vehicle is modified, other than by the addition, substitution, or removal of readily attachable components, prior to its first retail sale, the person making the modification is an alterer and is required to certify that, as altered the vehicle continues to conform to all applicable safety standards (49 CFR 567.7). After the first retail sale, there is one limit on modifications made to vehicles. Manufacturers, distributors, dealers, and repair businesses are prohibited from 'knowingly making inoperative' any device or element of design installed on or in a motor vehicle in compliance with an applicable safety standard (49 USC 30122). In general, the 'make inoperative' prohibition would require a business which modifies motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in compliance with an applicable safety standard. NHTSA has exercised its authority to issue Standard No. 208, Occupant Crash Protection (49 CFR 571.208). Standard No. 208 requires light trucks and vans manufactured on or after September 1, 1991 to be capable of providing occupant crash protection to front seat occupants when the vehicle is crash tested at 30 miles per hour (mph) into a concrete barrier. A vehicle that provides this crash protection will increase the safety of vehicle occupants. The air bag installed in the customer's vehicle is one means of complying with this requirement. As a result of this new requirement, this agency received a number of phone calls and letters, from both van converters and individuals suggesting that the new light truck and van crash testing requirement will, in effect, prohibit van converters from modifying vehicles to accommodate the special needs of persons in wheelchairs. The agency also received a petition asking for an amendment to the light truck and van crash test requirement in Standard No. 208 to address this problem. As a result on that petition, on March 2, 1993, this agency amended Standard No. 208 to allow manufacturers of light trucks and vans an alternative to complying with the existing requirement (58 FR 11975). Under the amendment, 'vehicles manufactured for operation by persons with disabilities' are excluded from the light truck and van automatic crash protection requirement. Instead, these vehicles must be equipped with a Type 2 manual belt (integrated lap and shoulder belt) or Type 2A manual belt (non-integrated lap and shoulder belt) at the front outboard seating positions. A 'vehicle manufactured for operation by persons with disabilities' is defined as vehicles that incorporate a level change device (e.g., a wheelchair lift or a ramp) for onloading or offloading an occupant in a wheelchair, an interior element of design intended to provide the vertical clearance necessary to permit a person in a wheelchair to move between the lift or ramp and the driver's position or to occupy that position, and either an adaptive control or special driver seating accommodation to enable persons who have limited use of their arms or legs to operate a vehicle. For purposes of this definition, special driver seating accommodations include a driver's seat easily removable with means installed for that purpose or with simple tools, or a driver's seat with extended adjustment capability to allow a person to easily transfer from a wheelchair to the driver's seat. Based on the information you provided, the customer's van would come within this definition. Therefore, if your client would be considered an alterer, it may certify that, with the air bag removed, the vehicle continues to conform to all applicable safety standards, provided that the safety belts are not removed. If the modification is done after the first retail sale, removal of the air bag would not violate the 'make inoperative' prohibition, provided that the safety belts are not removed. I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: aiam1821

Open
Mr. K.L. Hinze, President, Central Electric Company, P.O. Box 1447, 1810 Eleventh Street, Portsmouth, Ohio 45662; Mr. K.L. Hinze
President
Central Electric Company
P.O. Box 1447
1810 Eleventh Street
Portsmouth
Ohio 45662;

Dear Mr. Hinze: #This is in response to your letter of January 21 1975, to Mr. Howard Dugoff of this agency, requesting a manufacturer's designation number for the brake hose assemblies which you manufacture. #S5.2.4(b) of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, was amended on January 29, 1974 (39 F.R. 3680, Docket No. 1-5, Notice 9), and again on February 26, 1974 (39 F.R. 7425, Docket No. 1-5, Notice 10). #In place of an assemble's code number, assigned by the National Highway Traffic Safety Administration, S5.2.4(b) of the standard now requires:#>>>A designation that identifies the manufacturer of the hose assembly, which shall be filed in writing with: Office of Standards Enforcement, 'Brake Hose Identification,' National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590. The marking may consist of a designation other than block capital letters required by S5.2.4.<<<#The designation need not include your company's address, or even its complete name, as long as it identifies the company and is filed with the NHTSA as described above. Furthermore, you do not need a separate designation for each of your two stores. #You have also described a Dymo label marker and requested approval of its use as a means of complying with the banding requirements of S5.2.4. the NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. Furthermore, all of the label information must remain visible after the band has been affixed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of the specific design. #Yours truly, Richard B. Dyson, Assistant Chief Counsel;

ID: aiam0733

Open
Mr. B. H. Walker, Vice President, Dealers Truck Equipment Co., Inc., P.O. Box 2484, Baton Rouge, LA 70821; Mr. B. H. Walker
Vice President
Dealers Truck Equipment Co.
Inc.
P.O. Box 2484
Baton Rouge
LA 70821;

Dear Mr. Walker: This is in reply to your letter of April 17, 1972, inquiring as to you responsibilities for the Certification of two types of vehicles you manufacture. In the first, you mount a winch behind the cab of the truck. The vehicles are then delivered to the Louisiana Highway Department who complete them by adding a fifth wheel and a tail roller. In this set of circumstances, we would consider you to be an 'intermediate manufacturer', subject to the requirements of section 568.5 of the 'Vehicles Manufactured in Two or More Stages' regulations, a copy of which is enclosed.; The second operation you perform is mounting front winches on pick-u trucks. The NHTSA has taken the position that manufacturers such as you who merely add equipment to already completed vehicles may retain that vehicle's certification and need not recertify. However, if you cause the vehicle not to conform to any motor vehicle safety standard, you will be in violation of section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)) and may be subject to civil penalties.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1088

Open
Mr. Lowell Liebenstein, President, Gil-Mar Welding Corp., 2142 Maple Road, Grafton, WI 53024; Mr. Lowell Liebenstein
President
Gil-Mar Welding Corp.
2142 Maple Road
Grafton
WI 53024;

Dear Mr. Liebenstein: This is in reply to your letter of March 14, 1973, asking how to compl with NHTSA Certification regulations in cases where you supply a trailer chassis or frame only, and another manufacturer installs the body. In another example, you supply the vehicle without an axle assembly, which is, we assume, also installed by another party.; Based on your letter, the procedures to be followed in certifyin vehicles such as these are those contained in NHTSA regulations for 'Vehicles Manufactured in Two or More Stages' (49 CFR Part 568, copy enclosed). Briefly, these regulations require the incomplete vehicle manufacturer, who would be you in these cases, to furnish with the incomplete vehicle a document indicating the extent that the incomplete vehicle a document indicating the extent that the incomplete vehicle conforms to Federal standards, and what the final stage manufacturer must do in order that the completed vehicle will conform to all applicable standards.; If upon your review of these regulations you have further questions, w will be pleased to respond to them.; Yours truly, Richard B. Dyson, Assistant 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.