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: 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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ID: aiam2297OpenMr. R. A. Plummer, Vice President & General Manager, Rome Engineering & Manufacturing Co., P.O. Box 707, Claxton, GA 30417; Mr. R. A. Plummer Vice President & General Manager Rome Engineering & Manufacturing Co. P.O. Box 707 Claxton GA 30417; Dear Mr. Plummer: This responds to Remco's April 26, 1976, question whether an exclusio from a safety standard based on the gross axle weight rating (GAWR) of an axle is met by using the rating of the axle beam by its manufacturer, or whether the truck or trailer manufacturer must also consider the load-bearing abilities of the wheels, rims, and hubs used with the axle beam.; Gross axle weight rating is defined in 49 CFR 571.3 to mean: >>>. . .the value specified by the vehicle manufacturer as th load-carrying capacity of a single axle system, as measured at the tire-ground interfaces.<<<; This definition means that the determination of GAWR is made by th vehicle manufacturer and that the axle beam rating of the component suppler cannot be the only basis for GAWR calculation. The GAWR is the value established at the tire-ground interfaces at each wheel position, and this means that the wheels, rims, hubs, and tires must be included in the determination. Thus, with regard to the exclusion from Standard No. 121, *Air Brake Systems*, until September 1, 1977, for any vehicle with an axle that has a GAWR of 24,000 pounds or more, the vehicle manufacturer must take into consideration each component on the axle as well as its attachment to the vehicle frame.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam1842OpenHonorable Les AuCoin, House of Representatives, Washington, DC 20515; Honorable Les AuCoin House of Representatives Washington DC 20515; Dear Mr. AuCoin: This is in response to your letter of March 11, 1975, forwarding comment from one of your constituents, Mr. Keith A. Burbidge, on the proposed weakening of the bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would then have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975 which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Burbidge appears to be directing his comments to what he believe to be a proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; We have placed Mr. Burbidge's letter in the appropriate docket. Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam0750OpenMr. Keitaro Nakajima, Director/General Manager, Factory Representative Office, Toyota Motor Sales, U.S.A., Inc., 1099 Wall Street West, Lyndhurst, NJ 07071; Mr. Keitaro Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales U.S.A. Inc. 1099 Wall Street West Lyndhurst NJ 07071; Dear Mr. Nakajima:#In your letter of June 19 you ask whether a propose headlamp symbol would meet the requirements of Standard No. 101.#The NHTSA answered this question in a notice published in the *Federal Register* on May 4, 1971 (36 F.R. 8296). In responding to a question by General Motors whether the published headlamp identification symbol was only representative of the required symbol, or definitive in the sense that it must be copied exactly, the NHTSA stated that it intended the symbol to be representative only.#I enclose a copy of the notice for your information.#Yours truly, Richard B. Dyson, Assistant Chief Counsel; |
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ID: aiam1792OpenMr. Lamar Washington, Jr., General Manager, M.I.T. Innovation Co-op, Room 33-111 Innovation Center, Cambridge, MA 02139; Mr. Lamar Washington Jr. General Manager M.I.T. Innovation Co-op Room 33-111 Innovation Center Cambridge MA 02139; Dear Mr. Washington: This is in reply to your letter of January 24, 1975, to the Office o Chief Counsel asking whether your proposed 'Autocycle' is a 'motorcycle' for purposes of the Federal motor vehicle safety standards.; The Autocycle has a steerable front wheel and a rear traction whee arranged in tandem like a conventional two-wheeled motorcycle. However, it also has a pair of smaller side wheels that are lowered to the ground to assist in the stabilization of the vehicle at low speeds and while standing still. These auxiliary wheels, as we understand it, retract at moderate and high speeds.; A 'motorcycle' is a 'motor vehicle with motive power having a seat o saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground' (49 CFR 571.3(b)). Although you have not specified the low speeds at which the auxiliary wheels are deployed, we have concluded on the basis of the information you have provided that the Autocycle is essentially designed to travel on two wheels in contact with the ground, and that the auxiliary wheels serve only the limited function of providing stabilization at low speeds. Therefore, the Autocycle is a 'motorcycle' for purposes of compliance with the Federal standards.; The proposed redefinition of 'motorcycle (39 FR 15046, April 30, 1974 would exclude certain three-wheeled vehicles and thus does not affect the Autocycle.; Sincerely, James C. Schultz, Acting Chief Counsel |
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ID: aiam0880OpenMr. Ken J. Brown, Product Engineering Manager, Wayne Corporation, Post Office Box 908, Industries Road, Richmond, IN 47374; Mr. Ken J. Brown Product Engineering Manager Wayne Corporation Post Office Box 908 Industries Road Richmond IN 47374; Dear Mr. Brown: This is in response to your request of August 15, 1972, for a interpretation of Standard 217, Bus Window Retention and Release.; It is true that S5.3.2(a)(3) of the standard presently requires maximum torque of 20 inch-pounds. Your discussion of this requirement as it relates to the rotary mechanism you describe has, however, called our attention to a possible problem in the application of the standard. We are presently considering rulemaking to deal with the questions raised, and will notify you of our disposition of the matter. I regret any inconvenience the resultant delay in answering your question may cause you.; Sincerely, Richard B.Dyson, Assistant Chief Counsel |
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ID: aiam3255OpenMr. Adam Victor, Chairman and CEO, Gas Alternative Systems, 65 Rugby Road, Brooklyn, NY 11226; Mr. Adam Victor Chairman and CEO Gas Alternative Systems 65 Rugby Road Brooklyn NY 11226; Dear Mr. Victor: This responds to your March 1, 1980, letter asking what you must do t certify devices that you plan to import for sale in the United States. The devices to which you refer would convert an automobile's fuel system from gas to compressed natural gas or propane.; The National Highway Traffic Safety Administration issues safet standards and requires manufacturers of motor vehicles and equipment to certify that their vehicles or equipment comply with all applicable standards. To certify compliance to the standards, manufacturers must test or conduct some form of analysis of their vehicles or equipment. The Federal government does not get involved in the actual certification process. Once a manufacturer determines that its equipment or vehicles comply with the standards, it can then certify the vehicles or equipment without getting government approval.; With respect to the device that you propose to import, the agency ha no safety standards applicable to this type of a device. Accordingly, as an importer of this equipment, you would have no certification responsibilities. However, the agency has a vehicle safety standard regulating fuel systems. If your device were designed to be installed in new motor vehicles, the manufacturer of those vehicles would be required to insure that your device would comply with the standard applicable to fuel systems. If your device would be installed on used vehicles, no manufacturer, dealer or repair business would be permitted to install it if such installation would render inoperative the compliance of the vehicle with the safety standards.; To help clarify these general guidelines further, I am enclosing a cop of Part 567, *Certification*, which describes how to certify a vehicle in compliance with the safety standards. Further, I am enclosing a copy of our Safety Standard No. 301, *Fuel System Integrity*, which details the fuel system requirements for motor vehicles. Finally, we have prepared a short letter that gives information on the installation of alternate fuel systems in motor vehicles and that is enclosed for your information.; If we can be of further assistance, please contact us. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1268OpenMr. Gene J. Shapiro, The Temple Building, Suite 707, Seventy- seven West Washington Street, Chicago, IL 60602; Mr. Gene J. Shapiro The Temple Building Suite 707 Seventy- seven West Washington Street Chicago IL 60602; Dear Mr. Shapiro: This is in reply to your letter of August 28, 1973, concerning Federa Motor Vehicle Safety Standard No. 218, 'Motorcycle Helmets.' You request information regarding the American National Standards Institute (ANSI) Standard Z90.1, and all existing State standards or regulations requiring the use of headgear by motorcyclists.; First, it appears you may be under the impression the Z90.1 standar and its revisions were issued by the Federal Government. This is not the case. Although the requirements of Federal Motor Vehicle Safety Standard No. 218 are largely, though not entirely, based on the Z90.1-1971 Standard published by the American National Standards Institute, the Institute is a private organization neither sponsored nor supported by the Federal Government. You will have to write to the ANSI if you want any information concerning the Z90.1 standard and its revisions.; You may obtain the existing State standards or regulations requirin the use of headgear by motorcyclists from the Department of Motor Vehicles in each State, respectively. However, it may interest you to know that any State or local requirements for the design or performance of motorcycle helmets, that have a bearing on safety, will have to be identical to the requirements of the Federal standard when the Federal standard goes into effect.; A copy of Standard No. 218 and a copy of the National Traffic and Moto Vehicle Safety Act of 1966, are enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4590OpenMr. Karl H. Mayer Rules and Regulations Dr.Ing.h.c.F.Porsche AG Porschestrasse 42 Stuttgart--Zuffenhausen West Germany; Mr. Karl H. Mayer Rules and Regulations Dr.Ing.h.c.F.Porsche AG Porschestrasse 42 Stuttgart--Zuffenhausen West Germany; "Dear Mr. Mayer: This responds to your request for an interpretation o Federal Motor Vehicle Safety Standards No. l0l, Controls and Displays, and No. l02, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked about the standards in connection with a new transmission and related gear shift mechanism that you are considering producing. I note that your accompanying request for confidentiality was withdrawn by an August l5, l988 letter signed by your attorney, effective September 30, l988. You stated that the new transmission is characterized by two functions, a manual gear shift and an automatic gear shift, combined in a single unit. A motor vehicle incorporating the transmission does not have a clutch pedal. Operation of the transmission is entirely dependent on the position selected for the gear shift lever. The shift lever is located in the middle console, where it can be moved along either of two slots which are located essentially parallel to the longitudinal axis of the vehicle. The left slot (automatic function) is essentially the same as a conventional automatic transmission gear shift lever, with the following positions (in order): P R N D 3 2 l. At the D position (only) of the left slot, the gear shift lever can be transferred to the M (manual) position of the right slot (manual function). The right slot consists of the following positions (in order): + M -. When the gear shift lever is in the right slot, the driver can select a higher gear (+) or lower gear (-) by tapping the shift lever. The shift lever always returns to the 'M' position after being tapped. You plan to provide two shift displays, one on the middle console and the other on the instrument panel. You stated that you believe that a dual function transmission of the type described in your letter is permitted if it meets the various requirements of Standards No. l0l and l02 and asked whether we agree with your interpretation. You also asked three questions related to certain aspects of the transmission and related gear shift lever and shift displays. Your questions are responded to below. By way of background information, and as noted in your letter, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles meet applicable requirements. The following represents our opinion based on the facts provided in your letter. I agree with your basic contention that a dual function transmission of the type described in your letter is permitted if it, and the accompanying gear shift lever and shift displays, meet the various requirements of Standards No. l0l and l02. The performance requirements specified in the two standards do not prohibit dual function transmissions. I have one primary comment concerning how you should evaluate Standards No. l0l and No. l02 with respect to the compliance of a vehicle equipped with the transmission. In some instances, these standards specify different requirements depending on whether a vehicle is equipped with a manual transmission or an automatic transmission. Thus, a critical issue is which of these requirements would need to be met by a vehicle equipped with your planned transmission. While you characterize the transmission as having two functions, a manual gear shift and an automatic gear shift, combined in a single unit, it is our opinion that the transmission is an automatic transmission for purposes of Federal motor vehicle safety standards. It is possible, of course, to manually control most conventional automatic transmissions, at least to some extent, by means of the gear shift lever, e.g., by shifting the lever from D to L. Your transmission would differ from a conventional automatic transmission primarily in having an additional means of manual control. However, the transmission would still be an automatic transmission. Vehicles equipped with the transmission would thus need to meet the requirements specified by Standards No. l0l and No. l02 for vehicles equipped with an automatic transmission, and not the requirements specified for vehicles equipped with a manual transmission. I will now address your three specific questions. You stated that it appears to you that when the shift lever is in the manual slot, it is permissible to have the lever, after tapping to shift up or down, return to the original middle position, and asked for our interpretation on this point. We agree that this basic design is permitted under Standards No. l0l and No. l02. Your second and third questions, which I will address together, concern the shift displays. You stated that you believe it is permissible for both of the dual shift pattern displays, i.e., the one on the middle console and the one on the instrument panel, to be constantly visible so that the driver can simultaneously see the currently used shift mode and also the alternative, and asked for our evaluation of this point. You also asked about the permissibility of two alternative instrument panel displays. I will begin my discussion of these questions by identifying the relevant requirements of Standards No. l0l and No. l02. Section S3.2 of Standard No. l02 states that the '(i)dentification of shift lever positions of automatic transmissions . . . shall be permanently displayed in view of the driver.' NHTSA has previously interpreted 'position' to mean the shift lever positions in relation to each other and the position that the driver has selected at the time of selection. Therefore, the display of a gear lever sequence and a gear position indicator is required for automobiles equipped with automatic transmissions. NHTSA has previously interpreted the requirement for permanent display as requiring a display that can be seen regardless of the operating mode of the engine. Thus, it is not permissible for the required display to be visible (e.g., in the case of an electronic display, be activated) only when the key is in the ignition switch. (I note that on August 25, l988, NHTSA published a notice of proposed rulemaking to amend the requirement for permanent display. A copy is enclosed.) Standard No. l0l specifies requirements for the location, identification and illumination of automatic gear position displays. Section S5.l requires that gear position displays must be visible to the driver under the conditions of S6. Section S6 provides that the driver is restrained by the crash protection equipment installed in accordance with Standard No. 208, Occupant Crash Protection, adjusted in accordance with the manufacturer's instructions. Section S5.3.l and Table 2 of the standard together require that automatic gear position displays be illuminated whenever the ignition switch and/or the headlamps are activated. The entry in Table 2 concerning the automatic gear position display references Standard No. l02. Your design includes the following ten shift lever positions: P R N D 3 2 l + M -. Under section S3.2 of Standard No. l02, all of these positions must be permanently displayed, i.e., there must be a display of the l0 positions in relation to each other and there must be an indication of the position that the driver has selected. As indicated above, Standard No. l0l specifies requirements for the location, identification and illumination of automatic gear position displays. The fact that your design would include more than one gear position display raises several issues, including (l) whether more than one display is permitted, (2) whether each display (where multiple displays are provided) must meet all of the requirements specified by Standards No. l0l and No. l02, and (3) whether multiple displays can be used to meet the requirements of the standards for gear position displays where no single display meets the requirements. It is our opinion that more than one display is permitted. It is also our opinion that if one display meets all of the requirements of Standards No. l0l and No. l02, the additional display(s) provided voluntarily by the manufacturer need not meet any particular requirements (except for section S5.3.5 of Standard No. l0l, which specifies requirements for sources of illumination not otherwise regulated by that standard). We have not previously found it necessary to address the issue of whether multiple displays can be used to meet the requirements of the standards for gear position displays where no single display meets the requirements. However, one commenter on the August 25, l988 notice cited above asked whether two displays could be used together to demonstrate compliance with section S3.2 of Standard No. l02. We plan to address that specific issue in the context of that rulemaking. While it is not entirely clear from your letter, the display on the middle console may provide permanent display (including times when the ignition is not on) of the shift lever positions, i.e., a display of the l0 positions in relation to each other and an indication of the position selected by the driver. It appears, however, that illumination is not provided for this display. Given the reference in Standard No. l0l to Standard No. l02, it is our opinion that where multiple gear position displays are provided and one complies with Standard No. l02 and the others do not, the requirements of Standard No. l0l must be met for the display which complies with Standard No. l02. If the display on the console fully met the requirements of Standards No. l0l and No. l02, it would be unnecessary for the additional display on the instrument panel to also meet the standards (with the exception of section S5.3.5 of Standard No. l0l, as noted above). I note that neither of the alternative instrument panel displays shown in your letter show all of the shift lever positions. While the displays do show P R N D 3 2 l, they show either 4 3 2 l or 4 3 M 2 l instead of + M -. If the instrument panel display, rather than the console display, was to be used to meet the requirements of section S3.2 of Standard No. l0l, it would be necessary for the display to show the l0 actual shift lever positions, including + M -. I also assume that the instrument panel display is not activated when the ignition is not on and thus does not provide a permanent display. I would like to note that the discussion in the preceding paragraph should not be read as a suggestion that you change the instrument panel display to show + M - instead of 4 3 2 l or 4 3 M 2 l. One consequence of your design is that, in the manual mode, the driver would not know what gear the car was in from either observing the location of the gear shift lever or by knowing the shift lever position (+ M or -). Your design takes care of this, however, by providing an indication of actual gear position on the instrument panel display. Assuming that you can meet the requirements of Standards No. l0l and No. l02 by means of the console display, we believe that it would be a desirable feature of your design to indicate actual gear position on the voluntarily provided instrument panel display. I hope this information is helpful. If you have any further questions concerning this matter, please contact me. Sincerely, Erika Z. Jones Chief Counsel"; |
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ID: aiam3605OpenMr. R. H. Zelinski, Vice President, Corporate Engineering, Zimmer Corporation, P.O. Box 2127, Pompano Beach, FL 33061; Mr. R. H. Zelinski Vice President Corporate Engineering Zimmer Corporation P.O. Box 2127 Pompano Beach FL 33061; Dear Mr. Zelinski: Thank you for your letter of August 6, 1982, to the Administrato asking whether there is 'any blanket waiver of standards solely based on a small production of vehicles.'; You are correct that no such waiver exists. Even a single automobil manufactured for use on the public roads must meet all applicable Federal motor vehicle safety standards unless exempted by the Administrator under the provisions of Part 555. A manufacturer whose total motor vehicle production in the year preceding filing of his petition does not exceed 10,000 units is eligible to apply for an exemption of up to three years on a hardship basis. Any manufacturer of motor vehicles may apply for an exemption of up to two years on the three remaining bases that you mention but the exemption extends only to a maximum of 2500 vehicles in any 12-month period that the exemption is in effect.; Under the original exemption authority, in effect from 1968 to 1971 exemptions were available on a hardship basis and the threshold of eligibility was 500 units.; Sincerely, Frank Berndt, 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.