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: aiam3039OpenMr. Maurice H. Allmacher, Project Engineer, Vehicle Regulations, Volkswagen of America, Inc., 7111 East Eleven Mile Road, Warren, MI 48090; Mr. Maurice H. Allmacher Project Engineer Vehicle Regulations Volkswagen of America Inc. 7111 East Eleven Mile Road Warren MI 48090; Dear Mr. Allmacher: This is in response to your letter of June 1, 1979, regarding th provision of Uniform Tire Quality Grading (UTQG) information to vehicle first purchasers (49 CFR 575.104(d)(1)(iii)). You ask whether UTQG information must be provided to first purchasers of vehicles manufactured after the UTQG sidewall molding effective date for the type of tire used on the vehicle, if the vehicle is equipped with tires manufactured prior to the effective date.; Section 575.104(d)(1)(iii) requires that tire grading information b furnished, in the case of bias- ply tires,; >>>'...to the first purchaser of a new motor vehicle, other than motor vehicle equipped with bias-ply tires manufactured prior to October 1, 1979, ...'<<<; Thus, UTQG first purchaser information is not required for vehicle manufactured after the bias-ply sidewall molding effective date of October 1, 1979, but equipped with tires manufactured prior to that date. The regulation applies in the same manner to vehicles equipped with bias-belted and radial tires manufactured prior to April 1, 1980, and October 1, 1980, respectively.; In order to avoid confusion regarding the date of manufacture of tire installed on particular vehicles, manufacturers may choose to supply UTQG information to all first purchasers of vehicles manufactured after the effective date for sidewall molding for the tire type used as standard equipment on the vehicles.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4206OpenHerbert C. Glesmann, President, REMCO, 4138 So. 89th Street, Omaha, NE 68127; Herbert C. Glesmann President REMCO 4138 So. 89th Street Omaha NE 68127; Dear Mr. Glesmann: This is in response to your letter of June 4, 1986, and your subsequen conversation with Judith Kaleta of the Office of Chief Counsel and Richard Morse, Chief of the Odometer Fraud Staff.; Your company, REMCO, has designed a system whereby the odometer on vehicle being towed behind a recreational vehicle (RV) would not accumulate mileage. As you describe it, it is a mechanical disconnect system. Disconnection can only be from the RV by use of a mechanical clutch system while the towed vehicle is connected to the RV. When the towed vehicle is disconnected from the RV, the odometer functions automatically.; The Federal law states that 'No person shall, with intent to defraud operate a motor vehicle on any street or highway knowing that the odometer of such vehicle is disconnected or nonfunctional.' 15 U.S.C. S 1988. Therefore, you asked whether in NHTSA's opinion, the use of the system violates the law.; While the term 'operate' has not been defined in Title IV of the Moto Vehicle Information and Cost Savings Act (the 'Act'), 15 U.S.C. SS 1981-1991, NHTSA has interpreted it to mean drive or tow with a load on the major components. When a vehicle is driven, load is put on the engine, transmission and other components of the drive train. Because REMCO's system puts no load on any components of the drive train, the towed vehicle is not being operated on the streets or highways in violation of the Act. However, persons utilizing the system should be advised that they must notify their buyer of the fact that the vehicle's odometer was disconnected.; Federal regulations, 49 C.F.R. S 580.4, provide for the inclusion o two sets of certifications on the odometer disclosure statements which must be completed at the time a vehicle is transferred. Transferors who tow their vehicles utilizing your system should check the first box of the first set which reads:; >>>I hereby certify that to the best of my knowledge the odomete reading as stated above reflects the actual mileage of the vehicle described below.<<<; However, there is no statement in the second set of certification which applies to this situation. Therefore, transferors who have used your system to tow their vehicle should add a fourth statement which reads:; >>>I hereby certify that the odometer was disconnected when the vehicl was in tow.<<<; The purpose of the Act is to establish certain safeguards for th protection of motor vehicle purchasers. We feel this disclosure is consistent with the purpose of the Act.; I hope this information is helpful to you. If you have any additiona questions, do not hesitate to call me.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam4713OpenMr. Bill Waltz Wagner Division Cooper Industries, Inc. 155 Algonquin Parkway Whippany, NJ 07981; Mr. Bill Waltz Wagner Division Cooper Industries Inc. 155 Algonquin Parkway Whippany NJ 07981; Dear Mr. Waltz: This is in reply to your letter requesting permissio for deviations from marking requirements for round sealed beam headlamps. Wagner has been asked to assemble some headlamps designed to appear as closely as possible to those produced by Guide Lamp in the l950's. The lamps would be marked 'l' and '2' in accordance with the nomenclature of the day, rather than '2Dl', '1C1', and '2C1', as required by Standard No. 108. The DOT symbol would not be provided, 'since this obviously was not on the original lamps.' You have informed us that the lamps 'will be made to today's photometric standards' and 'subjected to all the tests currently required of the round headlights.' Finally, 'they will be distributed on a limited basis through antique parts dealers.' I am sorry, but we have no authority to exempt manufacturers of motor vehicle equipment from any requirements of the Federal motor vehicle safety standards. Our temporary exemption authority under l5 U.S.C. 1410 extends only to motor vehicles. Further, we have no authority to exempt manufacturers of either vehicles or equipment from their statutory obligation to certify through use of the DOT symbol that their products meet all applicable Federal motor vehicle safety standards. Under Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment, the motor vehicle lamps which you have identified, and for which you ask an exemption are designated Type C and Type D sealed beam headlamps. As such, they must be designed to conform to the photometric requirements of SAE Standard J579c, December l978, which are incorporated by reference in Standard No. 108. They are considered replacement equipment, and must conform to all requirements of Standard No. 108, including marking and certification. Standard No. 108 covers both original and replacement vehicle equipment. Depending on the vehicle category, it became effective for original equipment on January 1, l968, and January 1, l969. On January 1, l972, it became effective for equipment intended to replace original equipment on all motor vehicles manufactured on and after January 1, l972. Therefore, it might appear that the standard would not apply in any event to replacement equipment for l950's vehicles. However, the headlamps you describe are designed to conform to all contemporary requirements, except marking and certification. Even though intended for use on l950's vehicles, these circular headlamps are interchangeable with circular headlamps installed on any vehicle manufactured after the effective dates of Standard No. 108. Therefore, they must be designed to conform with Standard No. 108, and marked and certified accordingly. The intended markings 'l' and '2' would signify mistakenly that the headlamps were designed to conform to SAE Standard J579a, October l965 (which also did not require the DOT symbol on the lens). Until June l989, SAE J579a was incorporated in Standard No. 108 as a permissible option to SAE J579c, but the agency deleted it as the lamps appeared to be out of production. However, even had J579a been retained, we could not have allowed the lenses of headlamps manufactured to J579c to be marked according to J579a. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam1511OpenMr. Ronald J. Hansing, Project Engineer, The Adams & Westlake Company, 1025 North Michigan Street, Elkhart, IN 46514; Mr. Ronald J. Hansing Project Engineer The Adams & Westlake Company 1025 North Michigan Street Elkhart IN 46514; Dear Mr. Hansing: This is in reply to your letter of April 16, 1974, concerning a interpretation of the requirements of Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release' (49 CFR 571.217). You appear to ask whether bus windows containing tempered glass must meet the release requirements of paragraph S5.3.2 after (as well as before) the retention test required by S5.1 when the glass breaks during the retention test. You state that tempered glass, once broken, is easily removed from the entire lite by touch, implying that when this is the case there is no longer a need for any release mechanism to be further tested.; Paragraph S5.3.2 requires the release mechanism to meet specifie requirements both before and after the window retention test of S5.1 irrespective of the glazing material used in the lite. Consequently, release mechanisms for windows of tempered glass must conform to the requirements even though the glass may be broken during the retention test.; While your argument that the requirement seems unnecessary whe tempered glass is used is not without some basis, it is also quite likely, in our view, that bus passengers in a crash may be ignorant of the quality of tempered glass to which you refer and thus still attempt to operate the emergency exit using its release mechanism.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3486OpenMs. Shirley C. Jennings, President, DeJen Products Co., 26 Belridge Road, New Britain, CT 06053; Ms. Shirley C. Jennings President DeJen Products Co. 26 Belridge Road New Britain CT 06053; Dear Ms. Jennings: This responds to your recent letter to Administrator Peck regarding warning device you have developed called 'Call Safe.' This product is a reflective letter 'H' which is designed to be placed inside the rear window or windshield of a motor vehicle to call for help. You ask the agency to advertise the avialability of your device in its newsletter.; Federal Motor Vehicle Safety Standard No. 125 (49 CFR 571.125 establishes requirements for emergency warning devices. The standard requires waring devices to be of a uniform construction. Emergency warning devices, for purposes of this standard, are devices which alert drivers to the presence of a disabled vehicle. We assume your device is designed to signal for help concerning *any* emergency in the vehicle, and not just to warn approaching drivers of a disabled car. For example, 'Call Safe' could be used by a driver who has suddenly become ill and needs help. If this is true, the agency would conclude that Standard No. 125 does not apply to the 'Call Safe' device and you, therefore, would not be prohibited by the standard from offering this device for sale as motor vehicle equipment.; Regarding your request, the National Highway Traffic Safet Administration does not endorse specific products. Please contact this office if you need further assistance.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4343OpenMr. John B. White, Engineering Manager, Product Engineering, Michelin Americas Research & Development Corp., P. O. Box 1987, Greenville, SC 29602; Mr. John B. White Engineering Manager Product Engineering Michelin Americas Research & Development Corp. P. O. Box 1987 Greenville SC 29602; Dear Mr. White: This responds to your letter seeking an interpretation of Standard No 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR S571.119). Specifically, you stated that you currently mark a tire with the size designation 385/65 R 22.5 Load Range J. You also stated that this tire has the same dimensions as a 15 R 22.5 Load Range J tire. You asked whether Standard No. 119 would prohibit the following size designation from being marked on the tire:; >>>385/65R22.5 LRJ<<< >>>(15R22.5)<<< The marking requirements for tires subject to Standard No. 119 are se forth in section S6.5 of the standard. Section S6.5(c) requires that each tire be marked on both sidewalls with 'the tire size designation as listed in the documents and publications designated S5.1.' Section S5.1 of Standard No. 119 requires each tire manufacturer to ensure that a listing of the rims that may be used with each tire the manufacturer produces is available to the public. This may be done either by the individual manufacturer furnishing a document to each of its dealers, to this agency, and to any person upon request, or the manufacturer may rely on the tire and rim matching information published by certain standardization organizations.; With respect to the 385/65 R 22.5 Load Range J tire size, Michelin ha not furnished any individual information for this tire size to the agency. The only standardization organization that has published tires and rim matching information for this tire size is the European Tyre and Rim Technical Organization (ETRTO), which did so in its 1987 yearbook. Accordingly, section S5.2 of Standard No. 119 provides that the information for this tire size in the 1987 ETRTO yearbook is considered to be information for Michelin's tires of that size.; The 1987 ETRTO yearbook shows the tire size only as 385/65 R 22.5. A noted above, section S6.5.(c) requires that the tire size designation on the sidewall be 'as listed in the documents and publications designated in S5.1'. Reading this requirement as narrowly as possible, S6.5(c) prohibits Michelin from marking the tires as both 385/65 R 22.5 and 15 R 22.5, since the size is shown only as 385/65 R 22.5 in the publication designated in S5.1 of Standard No. 119.; In a broader sense, the practice of labeling two tire sizes on on tire, as you requested in your letter, was once a fairly common practice and was referred to as 'dual-size markings.' Dual-size markings were a marketing effort by tire manufacturers to try to persuade consumers to change the size and/or type of tire on their vehicles, by representing that this particular tire size was an appropriate replacement for two different sizes of tires. However, the practice of using dual-size markings confused many consumers about the size of the tire on their vehicle. The only purpose of the Federally required markings on tires is to provide consumers, in a straightforward manner, with technical information necessary for the safe use and operation of the tire. The agency concluded that it was inappropriate to permit a marketing technique that was confusing many consumers to defeat the purpose of the required markings on tires. Accordingly, dual-size markings were expressly prohibited for passenger car tires subject to standard No. 109, 36 FR 1195, January 26, 1971.; While Standard No. 119 does not expressly prohibit dual- size markings section S6.5(c) uses the singular when it refers to the 'tire size designation' to be labeled on the tire. Considering the past history associated with dual-size markings, this agency interprets section S6.5(c) of Standard No. 119 as prohibiting a manufacturer from marking a tire with two different size designations, *even if* a document or publication designated in S5.1 were to show two different size designations for the same tire size.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1141OpenMr. Thomas S. Pieratt, Jr., Executive Secretary, Truck Equipment & Body Distributors Association, 602 Main Street, Cincinnati, OH 45222; Mr. Thomas S. Pieratt Jr. Executive Secretary Truck Equipment & Body Distributors Association 602 Main Street Cincinnati OH 45222; Dear Mr. Pieratt: In your letter of May 14, 1973, you present the fact situation of a equipment manufacturer who installs lighting equipment on a component which he supplies to distributors or dealers, for installation by them on motor vehicles. For purposes of this letter, I assume that the installation occurs before the first sale of the vehicles for purposes other than resale. You ask what the equipment manufacturer should do to advise the distributor or dealer 'that the lamps and/or reflectors which he has affixed to his product meets the published S.A.E. specs required by Standard 108.'; There is no Federal requirement that an equipment manufacturer in thi fact situation supply compliance information, although covered equipment that he sells must continue to conform. The requirements for certifying or otherwise providing information concerning conformity with Standard No. 108 apply to the manufacturer of the lighting equipment, and the manufacturer(s) (final-stage and others) of the vehicle in question. It may well be that the customers of the supplier you describe will demand assurances of conformity through commercial channels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5102OpenRobert R. McAusland, P.E. 1311 N. 35th St. Seattle, WA 98103; Robert R. McAusland P.E. 1311 N. 35th St. Seattle WA 98103; "Dear Mr. McAusland: This responds to your letter asking whether you design of an infant seat would comply with S5.2.4 of Federal Motor Vehicle Safety Standard No. 213, Child Restraint Systems. You state that your infant seat would have a frame made from 1/4 inch thick polyethylene sheet, and that all the edges of the frame are rounded to a radius of 1/8 inch. As discussed below, the design would not comply if the edges of the seat frame are contactable by the infant dummy's head or torso during the standard's dynamic test. Some background information on Federal motor vehicle safety laws and regulations may be helpful. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act) authorizes this agency to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the facts set forth in your letter. Standard No. 213 specifies requirements for child restraint systems used in motor vehicles and aircraft, to reduce the number of children killed or injured in motor vehicle crashes and in aircraft. S5.2.4, 'Protrusion limitation,' of Standard No. 213 states: Any portion of a rigid structural component within or underlying a contactable surface, or any portion of a child restraint system surface that is subject to the requirements of S5.2.3 the head impact protection requirements for infant seats , shall, with any padding or other flexible overlay material removed, have a height above any immediately adjacent restraint system surface of not more than 3/8 inch and no exposed edge with a radius of less than 1/4 inch. (Emphasis added.) The term 'contactable surface' is defined in S4 of the standard as 'any child restraint system surface (other than that of a belt, belt buckle, or belt adjustment hardware) that may contact any part of the head or torso of the appropriate test dummy, specified in S7, when a child restraint system is tested in accordance with S6.1.' Under S5.2.4, any edges of a rigid structural component within or underlying a surface that can be contacted by the head or torso of the appropriate test dummy during Standard No. 213's dynamic test must have a radius of at least 1/4 inch. Since the frame edges of your infant seat have a radius of only 1/8 inch, the seat would not comply with S5.2.4 if the surfaces overlying those edges can be contacted by the infant dummy during the dynamic test. You ask whether, since side loading is not specified in Standard No. 213, can you conclude that there is no way that the child's head or torso could contact the sides of the frame, i.e., that the surfaces overlying those edges cannot be contacted by the infant dummy during the dynamic test. We assume that you believe the infant's head and torso are unlikely to contact the frame's edges in the 213 dynamic test since, due to the forward motion of the test, the dummy's components are likely to move forward and rearward, rather than laterally. I note that, for purposes of compliance testing, NHTSA would determine whether the surfaces are contactable surfaces for the purposes of S5.2.4 by observing a dynamic test, conducted according to the procedures in Standard No. 213. With respect to the issue of what information or analysis would be sufficient, for purposes of certification, for you to conclude that the surfaces overlying those edges cannot be contacted by the infant dummy during the dynamic test, manufacturers must have some basis for their certification that a product complies with all applicable safety standards. However, this does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. You should be aware, however, that the direction of dummy movement during the Standard No. 213 dynamic test depends on many variables other than the direction of the test, such as the performance of the restraint's belt system. For example, in the event a child seat's upper torso restraint slipped off the dummy's shoulder in the dynamic test, the dummy could move laterally and strike the sides of the restraint system. You should consider all of the variables that could affect the dummy's performance when determining whether frame contact can occur. I also note that manufacturers of motor vehicles and motor vehicle equipment are subject to the defect provisions of the National Traffic and Motor Vehicle Safety Act. Infant restraints are involved in real-world crashes other than the frontal impacts simulated in Standard No. 213. If data indicated that a child seat exposed occupants to an unreasonable risk of injury, such as sharp edges resulting in injuries in a side crash, the agency might conduct a defect investigation which could lead to a safety recall. Enclosed is an information sheet which provides additional information for new manufacturers of motor vehicles and motor vehicle equipment. If you have further questions, please call Ms. Deirdre Fujita of my staff at (202) 366- 2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0300OpenMr. Y. Nakajima, Manager, Engineering Department, Koito Manufacturing Co., Ltd., 4-8-3 Takanawa, Minato-Ku, Tokyo, Japan; Mr. Y. Nakajima Manager Engineering Department Koito Manufacturing Co. Ltd. 4-8-3 Takanawa Minato-Ku Tokyo Japan; Dear Mr. Nakajima: This is in reply to your letter of February 25, 1971, concerning th photometric requirements for amber turn signal lamps.; You have correctly interpreted the photometric requirements for ambe turn signal lamps as specified in paragraph S4.1.1.7 of Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1972.; Sincerely, Roger H. Compton, Director, Office of Operating Systems Motor Vehicle Programs; |
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ID: aiam5552OpenMr. Stuart Sacks Tradepro, Inc. 7350 N.W. 35th Street Miami, FL 33122; Mr. Stuart Sacks Tradepro Inc. 7350 N.W. 35th Street Miami FL 33122; "Dear Mr. Sacks: This responds to your letter to Mr. Philip Recht, ou former Chief Counsel, in which you stated that you are considering importing tires from the Hangzhou General Rubber Factory, which has been assigned NHTSA manufacturer identification number 7D. You stated that the tires do not display the 'molded D.O.T. code numbers,' and that Federal motor vehicle safety standard (FMVSS) No. 119, New pneumatic tires for motor vehicles other than passenger cars (49 CFR 571.119), 'clearly does not require DOT code numbers for non-passenger tires.' Your reading of FMVSS No. 119 is not correct. I assume from your letter that you are considering importing only non-passenger car tires. This letter, then, will address only the labeling requirements for non-passenger car tires under FMVSS No. 119 and 49 CFR 574. I further assume that by 'DOT code numbers' you mean the tire identification number (TIN) required by 49 CFR 574.5. 49 U.S. Code 30112 provides that no person may sell in or import into the United States any new motor vehicle or new item of motor vehicle equipment that does not comply with all applicable FMVSSs. With respect to non-passenger car tires, which are items of motor vehicle equipment, section S6.5 of FMVSS No. 119 requires specific items of information to be marked on the tire sidewalls. Those markings must be no less than 0.078 inch high and must be 'raised above or sunk below the tire surface' a specified distance. Among other things, the markings must include the TIN (S6.5(b)). Paragraph S6.5(b) of FMVSS No. 119 requires the TIN to comply with part 574. Part 574.5 requires that the TIN be permanently molded into or onto tire sidewalls as specified in Figure 1 of Part 574, and specifies what information the TIN must contain. The TIN can be branded into or onto the sidewalls of retreaded tires after the fact, but not new tires. On new tires, the TIN must be molded into or onto the tire sidewalls by the original manufacturer. I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting 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.