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: aiam3110OpenMr. Chuck Reeves, Law Clerk, Clanahan, Tanner, Downing and Knowlton, 718 Seventeenth Street, 19th Floor, Denver, CO 80202; Mr. Chuck Reeves Law Clerk Clanahan Tanner Downing and Knowlton 718 Seventeenth Street 19th Floor Denver CO 80202; Dear Mr. Reeves: This is in response to your letter of July 24 and your telephon conversation with Ms. Debra Weiner of my office in which you inquired about the Federal law applicable to the manufacture and use of auxiliary fuel tanks. You indicated that your client will be in the business of manufacturing auxiliary fuel tanks for use in passenger vehicles and on farm equipment. Most of the tanks will apparently be designed for mounting on the vehicles without connection to the vehicle fuel system, although some will be built with some connections.; Below is a discussion of questions numbered 1 and 6 in your letter, a well as a general discussion of the law applicable to the installation of both types of auxiliary tanks. Following is a brief discussion of the questions numbered 2-5 in your letter.; The National Traffic and Motor Vehicle Safety Act, as amended 1974 (the Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable either to entire motor vehicles or to equipment for installation in motor vehicles. Agricultural equipment is not encompassed by the term 'motor vehicle' because Congress clearly did not intend that such equipment be within the coverage of the Act. Therefore, none of the Federal motor vehicle safety standards are applicable to farm equipment and the rest of this letter will be concerned only with passenger vehicles.; Safety Standard No. 301-75, *Fuel System Integrity*, is a vehicl standard which applies to certain vehicles, including passenger cars, that use fuel with a boiling point above 32 degrees F. The standard applies to completed vehicles rather than to fuel tanks or other fuel system components and thus is inapplicable to the manufacture of auxiliary fuel tanks.; Despite the inapplicability of Safety Standard No. 301-75 to thei manufacture, auxiliary fuel tanks of either type you have mentioned must be designed and manufactured for safety. As a manufacturer of auxiliary fuel tanks, your client would be subject to the defects responsibility provisions of the Act (section 151 *et seq*). Upon discovery of a safety-related defect by the Secretary of Transportation, the NHTSA Administrator, or the manufacturer himself, your client, as a manufacturer, would be required to notify vehicle owners, purchasers, and dealers and remedy the defect.; A person who installs an auxiliary fuel tank in a new vehicle prior t its first purchase in good faith for purposes other than resale would be a vehicle alterer under NHTSA regulations if that person modified the vehicle during the installation. As an alterer, your client would be required by 49 CFR 567.7 to affix an additional label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards--including Safety Standard No. 301-75. Should a noncompliance or safety-related defect be discovered in such a vehicle, as a result of the modification, your client would be responsible for notifying vehicle owners and remedying the noncompliance or defect.; If your client connects auxiliary gasoline tanks to used passenge vehicles, he or she would not be required to attach an alterer's label. However, section 108(a)(2)(A) of the Act would apply. Section 108(a)(2)(A) provides in relevant part that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . .<<<; Thus, if your client added an auxiliary tank of either type mentione in your letter to a used passenger vehicle manufactured in accordance with Safety Standard No. 301- 75 and other standards, and in the process knowingly rendered inoperative the compliance of the fuel system or other systems, he or she would have violated section 108(a)(2)(A).; For example, if your client mounted a tank on the exterior of vehicle, without connection to the fuel system, and one of the mounting bolts caused the existing fuel system to leak in an amount in excess of that permitted by Safety Standard no. 301-75, he would be in violation of section 108(a)(2)(A). Depending upon the way in which he attached the tank to the vehicle or to its fuel system your client could also violate sections 108(a)(2)(A) with respect to other safety standards including, but not limited to, the Bumper Standard (49 CFR 581), and Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*.; >>>Questions 2, 3, and 4.<<< According to the Federal Highway Administration which administers th Federal Motor Carrier Safety Regulations, they apply only to motor carriers and not to passenger vehicles that are not involved in interstate commerce. If you have further questions you might wish to contact the Federal Highway Administration directly.; >>>Question 5. Do 49 C.F.R. 171 *et seq*. which regulate th transportation of certain hazardous materials apply to the private carrying of such materials on passenger vehicles or farm equipment?<<<; These regulations are administered by the Research and Special Program Administration, which informs me that the Federal regulations applying to hazardous materials concern the transportation of hazardous materials in commerce. Thus far, the regulations have not been applied to the private carrying of hazardous materials, such as gasoline, in a passenger vehicle or farm machine. If you have further questions you might wish to contact the Research and Special Programs Administration.; In conclusion, please note that, in general, the National Highwa Traffic Safety Administration discourages the use of auxiliary fuel tanks of any kind because of the grave dangers of fire and explosion posed by their improper manufacture or installation. In the near future this agency will be making a press release warning consumers of these hazards and discouraging them from using auxiliary fuel tanks.; I hope that you will find this response helpful and that you have no been inconvenienced by our delay in sending it to you.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam3540OpenMr. M. W. Urban, Sure-View, Inc., 1337 N. Meridan Street, Wichita, KA 67203; Mr. M. W. Urban Sure-View Inc. 1337 N. Meridan Street Wichita KA 67203; Dear Mr. Urban: This responds to your letter of February 8, 1982, concerning complianc with Federal Motor Vehicle Safety Standards, in particular compliance with Safety Standard No. 111, *Rearview Mirrors*.; You are correct that section 102(2) of the National Traffic and Moto Vehicle Safety Act (15 U.S.C. 1392(2)) defines, in part, a motor vehicle safety standard as 'a minimum standard for motor vehicle performance....' Thus, each of the agency's safety standards sets a minimum level of performance which must be met by every manufacturer. Manufacturers are free to utilize designs that exceeds the minimum level of performance set by a standard as long as their products still comply with the standard. Thus, in the case of schoolbus rearview mirrors, a manufacturer must at least comply with the requirements of section 9.1 of Standard No. 111 regarding mirror size, and may voluntarily provide a mirror of a larger size. As explained in the enclosed letter, the Vehicle Safety Act authorizes the agency to regulate aspect of design, such as mirror size.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4285OpenThomas R. Fahl, Esq., Brendel, Flanagan, Sendik & Fahl, S.C., 6324 West North Avenue, Milwaukee, Wisconsin 53213-2099; Thomas R. Fahl Esq. Brendel Flanagan Sendik & Fahl S.C. 6324 West North Avenue Milwaukee Wisconsin 53213-2099; Dear Mr. Fahl: This responds to your letter to Dr. Richard Strombotne, the chief o our Crashworthiness Division. In your letter, you posed three questions about child restraint systems. I will answer those questions in the order you presented them.; >>>1. Does NHTSA have information as to where a family with tw children 3 years of age or under should put the second of two child restraint systems, assuming that the safest place for one is the middle of the rear seat?<<<; NHTSA has not specifically addressed this topic in any of ou regulations or recommendations. We believe, however, that in this situation both child restraint systems should be placed in the rear seat. This belief is based on the generally greater distance from the rear seat to the interior surface in front of that seat and the fact that the interior surface in front of the rear seat is primarily the rear of the front seats. The rear of the front seats tends to be a less hostile surface than the dashboard. Additionally, crash data show that all vehicle occupants (both adults and children) suffer fewer injuries and fatalities in the rear seating positions than in the front seating positions.; >>>2. Has NHTSA developed any rules or regulations suggesting o requiring that manufacturers of child restraint systems advise the consumer where to put a second child restraint, assuming that two children under 3 years of age will be occupying a motor vehicle at the same time and also assuming that neither child restraint system is a backward facing system?<<<; No, NHTSA has not impose any such requirements. With respect to chil restraints manufactured before August 12, 1986, section S5.6.1 of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213) specified that: 'The instructions shall state that the rear center seating position is the safest seating positions to most vehicles for installing a child restraint system.' For child restraints manufactured on or after August 12, 1986, section S5.6.1 requires: 'The instructions shall state that, for maximum safety protection, child restraint system should be installed in a rear seating position in vehicle with two rear seating positions and in the center rear seating position in vehicles with such a seating position.'; NHTSA has somewhat modified its position about the rear *center seating position being the safest place to install a child restraint system in a recent rulemaking action amending Standard No. 210, *Seat Belt Assembly anchorages* (49 CFR S571.210). Please note that this standard applies only to vehicle manufacturers, and not to child restraint manufacturers. However, in an August 19, 1986 rule 951 FR 29552, copy enclosed), section S6(b) of Standard No. 210 requires the owners manual for vehicles manufactured after September 1, 1987 to state that 'according to accident statistics, children are safer when properly restrained in the rear seating positions that in the front seating positions.' We are currently considering whether Standard No. 213 should be amended to include similar language. However, neither of these requirements specifically addresses the situation where two child restraints are to be installed in the same vehicle.; >>>3. Has NHTSA done studies to determine that the right fron passenger seat is not an appropriate place for a child restraint system and, if so, what are the results of those studies?<<<; No study of which we are aware, whether done by this agency or an other party, suggests that the right front passenger seat is not an appropriate place for a child restraint system. In fact, those studies of which were are aware indicate that a properly installed child restraint system in the right front passenger seat will afford the child occupant a high level of safety protection in a crash situation. The safety protection can be maximized by properly installing the child restraint in a rear seating position, but we are aware of no basis for stating that the right front passenger seat is not an appropriate place for a child restraint system.; If you have any further questions on this subject need mor information, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1087OpenMr. Alberto Negro, Manager, Research and Development, Fiat Motor company, Inc., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Alberto Negro Manager Research and Development Fiat Motor company Inc. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Negro: This is in reply to your letter of February 22, 1973, requestin confirmation of your understanding that automobile manufacturers may continue to use glazing materials manufactured before April 1, 1973, that do not conform to the recent amendment to Standard No. 205, 'Glazing Materials', effective on that date, in motor vehicles manufactured after that date.; Standard No. 205, an 'equipment standard', applies to glazing material for use in motor vehicles. It does not apply directly to vehicles in which such materials are used. As a consequence, a vehicle manufacturer may use glazing materials that do not conform to Standard No. 205 as it exists on the date the *vehicle* is manufactured. The glazing material must, however, conform to the standard as it exists on the date that the material is manufactured.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1592OpenMr. R. Vibart, The Secretary General, Societe de Signalisations Automobiles, SEIMA, 11, Chemin des Merisiers, Villemoisson-sur-Orge (1), France, *AIR MAIL*; Mr. R. Vibart The Secretary General Societe de Signalisations Automobiles SEIMA 11 Chemin des Merisiers Villemoisson-sur-Orge (1) France *AIR MAIL*; Dear Mr. Vibart: This is in response to your letter of July 17, 1974, concerning NHTSA' proposal to apply a manufacturer's identification code to motor vehicle lights.; Motor vehicle lights, including those imported in the United States subject to MVSS No. 108, *Lamps, reflective devices, and associated equipment*, would be required to be marked with a manufacturer's identification code under the NHTSA proposal. Just as all motor vehicle lights must meet the performance requirements of Standard 108, if the proposal is adopted as a final rule they would be required to meet the manufacturer's identification code requirement as well.; Thank you for advising us of your views in this matter. We will tak them into account in formulating further action.; Yours truly, Richard B. Dyson, Acting Chief Counsel |
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ID: aiam1068OpenMr. Bruce E. Roberts, President, Yuma Tire & Recapping, Inc., Route 3, Gate City, VA 24251; Mr. Bruce E. Roberts President Yuma Tire & Recapping Inc. Route 3 Gate City VA 24251; Dear Mr. Roberts: This is in reply to your letter of February 28, 1973, requesting detailed explanation of what you must do to conform to Motor Vehicle Safety Standard No. 117, 'Retreaded Pneumatic Tires'. You also ask whether there are record keeping requirements, such as to maintain the name and address of customers to whom tires are sold.; There are specific requirements for retreaders and their dealers t record and maintain the name and address of each tire purchaser. This is done through the use of a code number molded or branded onto each tire. These requirements (49 CFR Part 574, copy enclosed) have been in effect since May 22, 1971.; We have enclosed a copy of Standard No. 117. We regret that we canno provide a detailed explanation of these requirements as you request. We refer you to either private counsel or to one of the many associations of retreaders whom we understand can assist you in implementing the standard. If after reading the standard you have questions of a specific nature regarding its provisions, we will respond to them.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4790OpenMr. Robert Roden Roden & Hayes 2015 First Avenue No., Suite 400 Birmingham, AL 35203; Mr. Robert Roden Roden & Hayes 2015 First Avenue No. Suite 400 Birmingham AL 35203; "Dear Mr. Roden: This responds to your questions about the requirement for key-locking systems in section S4.2(b) of Federal Motor Vehicle Safety Standard No. 114, Theft Protection (49 CFR 571.114). As explained below, the enclosed copy of the agency's recent final rule amending this provision may be relevant to your inquiry (55 FR 21868, May 30, 1990). By way of background, the National Traffic and Motor Vehicle Safety Act, ('Vehicle Safety Act,' 15 USC 1381 et seq.) requires every new motor vehicle sold in the United States to be certified as complying with all applicable Federal motor vehicle safety standards. The Vehicle Safety Act specifies that the manufacturer must certify that each of its vehicles complies with all applicable safety standards in effect on the date of manufacture. Any person violating the Vehicle Safety Act by manufacturing or selling new noncomplying vehicles may be liable for potential penalties of $1,000 per violation up to $800,000 for a related series of violations. One such Federal safety standard is Standard No. 114, Theft Protection, which applies to passenger cars, and to trucks and multipurpose passenger vehicles having a gross vehicle weight rating of 10,000 pounds or less. Your first question asked whether section S4.2(b) requires key locking systems to prevent removal of the ignition key except when the transmission is in the 'park' position. Section S4.2(b) currently requires such vehicles to have a 'key-locking system that, whenever the key is removed, will prevent...(b) either steering or forward self-mobility of the vehicle, or both.' However, the agency has recently amended section S4.2(b) to read as follows: Each vehicle shall have a key-locking system that, whenever the key is removed, prevents: (a) the normal activation of the vehicle's engine or motor, and (b) either steering or forward self-mobility of the vehicle or both. For a vehicle equipped with an automatic transmission with a 'park' position, the key-locking system shall prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. You should be aware that this amendment takes effect on September 1, 1992. For vehicles manufactured before September 1, 1992, S4.2(b) merely requires that when the key is removed, the key-locking system must prevent steering or forward self-mobility, or both. This provision does not address the issue of the transmission's position at the time of key removal. In contrast, under the recent amendment applicable to vehicles manufactured on or after September 1, 1992, S4.2(b) requires automatic transmission vehicles to prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' or becomes locked in 'park' as the direct result of removing the key. Your second question asked whether a replacement key-locking system is required to comply with Standard No. 114. Because Standard No. 114 applies to new motor vehicles and not to motor vehicle equipment, the standard does not in itself require aftermarket replacement systems to comply with its requirements. However, you should be aware that section 108(a)(2)(A) of the Vehicle Safety Act prohibits manufacturers, distributors, dealers, or motor vehicle repair businesses from knowingly 'rendering inoperative,' in whole or in part, any device or element of design installed on or in a vehicle to comply with an applicable safety standard. Your third question asked how long the key locking system is required to perform under S4.2(b) of the standard. The Vehicle Safety Act only requires manufacturers to assure that vehicles and equipment comply with applicable safety standards at the time of the first consumer purchase. However, please note that if at any time a manufacturer or the agency determines that a vehicle or item of equipment contains a safety-related defect, which could result from the failure of a system to operate properly, the manufacturer is required to notify all product purchasers of the defect and remedy the defect without charge. See 15 U.S.C. 1411-1414. I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures"; |
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ID: aiam3055OpenMr. A. L. Bragg, Laboratory Manager, Truck-Lite Co. Inc., 310 East Elmwood Avenue, Falconer, NY 14733; Mr. A. L. Bragg Laboratory Manager Truck-Lite Co. Inc. 310 East Elmwood Avenue Falconer NY 14733; Dear Mr. Bragg: This is in reply to your letter of June 19, 1979, to Mr. W. M. Elliot of this agency requesting clarification of Paragraph S4.3.1.1.1 of Federal Motor Vehicle Safety Standard No. 108.; This Paragraph states: >>>'Clearance lamps may be mounted at a location other than on th front and rear if necessary to indicate the overall width of a vehicle, as for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees in board.'<<<; You have asked the following questions: '1. Is the decision to use another mounting location made at th discretion of the manufacturer?'; Yes. The manufacturer determines whether placement of the lamps i accordance with Standard No. 108 will indicate overall width or whether they are susceptible to damage if so placed, and there is no requirement that it obtain the concurrence of this agency in its decision.; '2. Are there any specific conditions that are required in order t consider it 'necessary' to mount clearance lamps in another location?'; No. The agency has established no criteria of necessity and question on variations from front and rear mounting requirements are treated on an *ad hoc* basis.; '3. When the decision is made to mount the clearance lamps in anothe location, can a manufacturer use *combination* clearance/side marker lamps mounted on the *side of vehicle* to fulfill the clearance lamp requirements.'; Yes, as long as the clearance lamp function is visible from the rea and indicates the overall width of the vehicle.; '4. Section S4.1.1.1 states that in 'such a location they need not b visible at 45 degrees inboard'. Does this mean that they need not be visible from 0 to 45 degrees inboard?'; No. SAE Standard J592e, *Clearance, Side Marker, and Identificatio lamps*, July 1972, requires clearnce (sic) lamps to be visible at the H Point at 10 R and L, 20 R and L, 30 R and L, and at 45 R and L. Paragraph S4.3.1.1.1 specifies that under the alternate mounting positions the lamps need not be visible at the 45 degrees positions. They must, however, be visible at the other positions.; I hope this answers your questions, Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1438OpenMr. Philip H. Taft, Tire Retreading Institute, 1343 L Street, N.W., Washington, D.C. 20005; Mr. Philip H. Taft Tire Retreading Institute 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Taft: This is in reply to your letter of February 22, 1974, concerning a article in the November 1973 *Retreader's Journal* entitled 'Repairing Torn Beads.' You ask whether the article is correct when it states that casings with cord exposed in the bead area may be retreaded.; Standard No. 117 (S5.2) prohibits the retreading of any casing on whic bead wire or cord fabric is exposed before processing. 'Processing' encompasses the entire process, including the making of any needed repairs, by which a casing is retreaded. The NHTSA has taken the position that the only exception to this prohibition is that casings with exposed chafer fabric bay be retreaded. A casing that before processing has any exposed bead or cord material other than chafer fabric, however, may not be retreaded. Therefore, insofar as the Retreader's Journal article states that casings with exposed cord in the bead area may not be retreaded it is incorrect. We have sent a copy of this letter to the *Retreader's Journal*.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3405OpenMr. James J. Schultz, Severy, Incorporated, 2233 El Segundo Boulevard, El Segundo, CA 90245; Mr. James J. Schultz Severy Incorporated 2233 El Segundo Boulevard El Segundo CA 90245; Dear Mr. Schultz: This responds to your recent letter asking whether a 4-wheel driv pickup truck must comply with Safety Standard No. 216, *Roof Crush Resistance*. You also ask whether the definitions of vehicle classification under Federal regulations are mutually exclusive.; The application section of Safety Standard No. 216, section 3 specifies that the standard applies to passenger cars. This means that the standard applies *only* to passenger cars. Therefore, the standard does not apply to a pickup truck.; The definitions of the basic vehicle classifications found in 49 CF Part 571.3 are mutually exclusive. If a vehicle falls within the definition of a 'truck,' the vehicle is not also within the definition of a 'passenger car.' The definition of a passenger car does not specifically exclude trucks because the definition is based on the function of the vehicle. Thus, a passenger car is defined as a motor vehicle designed for carrying persons. A truck, on the other hand, is defined as a vehicle designed primarily for the transportation of property or special purpose equipment. Since a pickup is designed primarily for carrying property and not persons, it is a truck and not a passenger car. Each motor vehicle has a certification label attached to its door which specifies the vehicle's classification.; I hope this has clarified any questions you had concerning vehicl classification under the Federal Motor Vehicle Safety Standards.; 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.