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: aiam0797OpenMr. Satoshi Nishibori, Engineering Representative, Nissan Motor Company, Ltd., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Satoshi Nishibori Engineering Representative Nissan Motor Company Ltd. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Nishibori: This is in reply to your letters of July 25 and 28, 1972, on th subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.; The 'nominal design riding position' specified in Standard 208 an formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.; The term 'most upright position' used in Standard 210 was adopted i part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.; There have, however, been difficulties with the use of the 'mos upright position', in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the mannikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the *Federal Register*.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1885OpenHonorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal 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 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 on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety-related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam0282OpenMr. William J. Henrick, Assistant Counsel, The General Tire & Rubber Company, One General Street, Akron, OH 44309; Mr. William J. Henrick Assistant Counsel The General Tire & Rubber Company One General Street Akron OH 44309; Dear Mr. Henrick: This is in response to your letter of May 17, 1971, concerning th applicability of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.; As you mentioned in your letter, under the regulation, a vehicle deale has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.; The Tire Identification and Record Keeping Regulation and th Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam2745OpenMr. James M. Beach, Collins Industries, Inc., P.O. Box 58, Hutchinson, KS 67501; Mr. James M. Beach Collins Industries Inc. P.O. Box 58 Hutchinson KS 67501; Dear Mr. Beach: This responds to your November 15, 1977, letter asking severa questions concerning Standard No. 217, *Bus Window Retention and Release*.; In your first question, you paraphrase the requirements of S5.3. concerning emergency exit force requirements and release motion and ask whether your understanding of the section is correct. Your interpretation of the standard's requirements are accurate.; Second, you enclosed photographs of a manufacturer's rear emergenc door release mechanism and asked whether it complies with the standard's requirements. The force release mechanism shown in the pictures does not comply with the requirements of Standard No. 217. The release mechanism is not located in the high force access region as required by the standard, and the motion required for release of the exit is not upward as required by paragraph S5.3.3.; Finally, you asked whether your enclosed copy of Standard No. 217 whic includes paragraph S5.2.3.1 is up-to-date. The answer to your question is yes. You have been confused by paragraph S5.2.3.1 because it states that a bus must have, at a minimum, one rear emergency door or a side emergency door and a rear push-out window. The requirement for one rear emergency door does not preclude a schoolbus with a 10,000 pound GVWR or less from using two (double) rear emergency doors. Paragraph S5.4.2.2 states '...the opening of the rear emergency door *or doors* shall be ...' (Emphasis added). The use of the term 'doors' in paragraph S5.4.2.2 indicates that double doors are permitted.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5080OpenMr. Fredd Scheys President S.C.C. CARAT Inc. 109 Maple Avenue Huntsville, AL 35801; Mr. Fredd Scheys President S.C.C. CARAT Inc. 109 Maple Avenue Huntsville AL 35801; "Dear Mr. Scheys: This responds to your letter of October 2, 1992 asking for an explanation of how this agency's regulations would affect two types of vehicle conversions your company plans to undertake. In the first situation, a customer in California wishes to send two 'U.S. spec' cars that he presently owns to Europe for a 39-inch stretch conversion. In the second situation, the customer would take delivery of a 'U.S. spec car' in Europe, use it for tourist purposes, and leave it at your factory for conversion, and subsequent shipment to the United States. You also ask for 'advice for the case where we have to convert a car into an armoured car.' I am pleased to have this opportunity to explain our laws and regulations for you. The National Traffic and Motor Vehicle Safety Act (the Safety Act) provides generally that no person shall manufacture, sell, or import into the United States any motor vehicle unless that vehicle is in conformity with all applicable U.S. motor vehicle safety standards and is covered by a manufacturer's certification to that effect. The certification requirements are set forth in 49 Code of Federal Regulations, Part 567. The certification requirements apply to persons and entities that perform some manufacturing or conversion activities to a vehicle before that vehicle's first sale for purposes other than resale. This means that the original manufacturer of a vehicle (Mercedes-Benz, for instance) must certify that each of its completed vehicles conforms to all applicable U.S. safety standard and permanently affix a label with that statement on each such vehicle. For the purposes of this letter, I am assuming that the cars you call 'U.S. spec' cars are cars to which the original manufacturer has affixed its certification label. If any party performs conversion operations on a certified vehicle before the initial purchase of the vehicle, the party would be an 'alterer' and required to affix its own label identifying itself and certifying that the converted vehicle continues to conform to all applicable Federal motor vehicle safety standards. See 49 CFR 567.7. However, in the situations posited in your letter, the conversions to be performed in Europe by your company would be performed on vehicles after the first purchase of the vehicle for purposes other than resale. This agency does not require any certification to be made or certification label to be affixed by entities that perform conversions on vehicles after the first purchase of those vehicles. Thus, your company need not make its own certification nor affix its own label. Instead, your company must leave in place the original manufacturer's certification label. The only provision in U.S. law that applies to conversion operations performed on vehicles after the first purchase in good faith for purposes other than resale is set forth in Title 15, United States Code, section 1397(b)(2). That section of the law forbids any 'manufacturer, distributor, dealer, or motor vehicle repair business' from 'knowingly rendering inoperative in whole or in part any device or element of design installed in accordance with a Federal motor vehicle safety standard.' This means that your company must ensure that your conversion operations do not cause the converted vehicle to no longer comply with the U.S. motor vehicle safety standards. Pursuant to this responsibility, the agency would, for example, expect that, if the vehicle's weight ratings and tire inflation pressures shown on its original certification labels were no longer valid after conversion, a converter would install new labels showing the correct weight ratings and tire inflation pressures. Assuming your company leaves the original manufacturer's certification label in place on the converted vehicles, the owner of the vehicles should not encounter any difficulties when the converted vehicles are imported into the United States. The importer would simply file a declaration stating that the vehicle conforms to the applicable safety standards and bears an original manufacturer's certification label to that effect, pursuant to 49 CFR 591.5(b). For your information, I have enclosed a copy of an information sheet for new manufacturers that briefly explains our regulations and tells how to obtain copies of those regulations. I hope this information is helpful. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam0778OpenMr. G. L. Hartman, Group Staff Engineer, Superior Coach Division, Sheller-Globe Corporation, Lima, OH 45802; Mr. G. L. Hartman Group Staff Engineer Superior Coach Division Sheller-Globe Corporation Lima OH 45802; Dear Mr. Hartman: This is in reply to your letter of June 23, 1972, concerning th Certification and related regulations (49 CFR Parts 567, 568). You indicate in your letter that many school bus bodies are exceeding by small amounts the weight ratings specified for the chassis by the incomplete manufacturer, and that increasing the capability of the chassis results in expenditures which you believe are not justified by the additional safety achieved. You indicate also that you believe that section 567.5 requires the final-stage manufacturer to use the incomplete vehicle ratings for his ratings, except when differing tire sizes are specified in accordance with 567.4(h).; You appear to be misinterpreting the regulations. There is n requirement that a final-stage manufacturer use the ratings provided by the incomplete vehicle manufacturer. The final-stage manufacturer is free to raise them for purposes of certification, as long as the values he chooses are consistent with the definitions of GAWR and GVWR. If he does raise them, however, he can no longer rely on the assurances of the incomplete vehicle manufacturer as to conformity with the standards, but will be responsible, subject to the Vehicle Safety Act's penalties, for (1) conformity of the vehicle with all applicable standards, and (2) ensuring that no safety problem has been created. If the final-stage manufacturer will not assume this responsibility, in our opinion he cannot reasonably maintain that the limitations imposed by the incomplete manufacturer's ratings are unjustified.; In short, you are free to choose and combine your components as you se fit, as long as you use due care to ensure that the vehicle conforms to the standards and contains no safety-related defects. Observing the component manufacturer's maximum load ratings is usually the easiest way to do this.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3857OpenMr. Billy W. Partridge, Assistant Director, Bureau of Revenue, Mississippi State Tax Commission, P.O. Box 960, Jackson, MI (sic) 39205; Mr. Billy W. Partridge Assistant Director Bureau of Revenue Mississippi State Tax Commission P.O. Box 960 Jackson MI (sic) 39205; Dear Mr. Partridge: This is in response to your letter of June 8, 1984 requesting a copy o the National Highway Traffic Safety Administration's regulation regarding odometer disclosure, 49 CFR Part 580. A copy is enclosed.; You also ask whether the language that Mississippi uses (lines 184-96 and, in particular, the third statement (lines 192-93) is proper. All three statements should begin with the phrase 'I hereby certify that to the best of my knowledge ....' The Agency believes that this language is important because it requires that the transferor certify his disclosure statement. For this reason, it is also important that the phrase precede each of the three statements. As an alternative, you might reword the entire form so that the introductory certification encompasses all alternative statements.; The language is otherwise proper. You sated, in your telephon conversation with Heidi Lewis Coleman of my staff, that you recalled that at one time, the disclosure statement required the transferor to certify that the mileage is unknown, rather than that it is not accurate. Your recollection is correct. The original rule, 38 FR 2978 (Jan. 31, 1973), promulgated by NHTSA, required:; >>>if the transferor knows that the odometer reading differs from th number of miles the vehicle has actually travelled, and that the difference is greater than that caused by odometer calibration error, he shall include a statement that the actual vehicle mileage is unknown.<<<; This statement, however, was changed in 1977 to that in the presen rule (42 FR , Feb. 14, 1977), 42 FR 38906 (Aug 1. 1977)). The Agency found that the statement, that the actual mileage is unknown had been improperly used. In the Notice of Proposed Rulemaking we stated:; >>>This statement has provided a loophole for individuals who hav actually been guilty of rollbacks. Those persons merely check this statement, thereby hoping to exonerate themselves from blame if the mileage is later discovered to be greater than they stated it to be at the time of sale. In order to close this loophole, and at the same time not force transferors to certify a mileage to be correct which they know to be false, NHTSA proposes to adopt a new S580.4(c)(3) to allow transferors to indicate that the milage is not true and should not be relied upon. 42 FR at 9046.<<<; If you have additional questions, please feel free to call or write t our attention.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law |
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ID: aiam2315OpenHonorable John M. Murphy, Chairman, Subcommittee on Consumer Protection and Finance, Committee on Interstate and Foreign Commerce, House of Representatives, Washington, DC 20515; Honorable John M. Murphy Chairman Subcommittee on Consumer Protection and Finance Committee on Interstate and Foreign Commerce House of Representatives Washington DC 20515; Dear Mr. Murphy: I am writing in response to former Chairman Lionel Van Deerlin's Apri 21, 1976, letter concerning Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity*, as applied to motor homes. His letter is particularly concerned with the request of the Recreational Vehicle Industry Association (RVIA) for a delay in the standard's effective date of September 1, 1976, for the first phase of the requirements that apply to motor homes.; This effective date requires clarification in the case of multi-stag vehicles. RVIA members typically manufacture motor homes by installing bodies on chassis that have been supplied to them by other manufacturers. In such situations, the meaning of the September 1, 1976, effective date is not that all motor homes completed after that date must comply with the standard. Section 567.5(a)(7) of 49 CFR Part 567, *Certification*, permits the final stage manufacturer of a multi-stage vehicle to consider as the vehicle's date of manufacture any date that is neither earlier than the completion date of the chassis nor later than the completion date of the entire vehicle. The practical result of this provision is that the standard requires compliance only of those motor homes whose *chassis* are completed on or after September 1, 1976.; Because the ability of a motor home to comply with Standard No. 301-7 is substantially affected by both the design of the chassis and the manner in which the vehicle is completed, it is not meaningful to apply the standard directly to incomplete vehicles. All that the National Highway Traffic Safety Administration (NHTSA) requires of incomplete vehicles is the following: those that are manufactured after September 1, 1976, must be capable of being completed into complying motor homes and must be accompanied by the incomplete vehicle document described in 49 CFR Part 568, *Vehicles Manufactured in Two or More Stages*. That document will include, with respect to Standard No. 301-75, either (i) a statement that the motor home as completed will comply with the standard provided no alterations are made in identified components of the incomplete vehicle, or (ii) a statement of specific conditions of final manufacture under which the completed motor home will comply with the standard. While Part 568 generally offers the incomplete vehicle manufacturer a third option--to make no representation whatever of the compliance status of his product--that option is unavailable in this context because his work substantially affects compliance.; The RVIA has argued that a delay in the standard's effective date fo completed motor homes is necessary for its members to gain experience with chassis that have been designed for completion into complying motor homes. The NHTSA recognizes the need for such experience or its equivalent through the provision of technical information by the incomplete vehicle manufacturer. However, the agency expects motor home manufacturers to obtain this experience or information, through cooperation with the chassis manufacturers, in advance of the September 1, 1976, effective date. While such advance manufacturing or provision of information on the part of chassis manufacturers is not required by any regulations of this agency, it is required by the commercial realities of their relationships with the motor home manufacturers. A simple delay in the standard's effective date would merely delay the date by which incomplete vehicle manufacturers would be required *by the NHTSA* to supply chassis that have been designed for completion into complying motor homes. Such a delay would thus not provide the relief that the RVIA has requested.; The RVIA has, in effect, requested the agency to establish a 'experience interval' by retaining September 1, 1976, as the time by which chassis must be designed for ultimate compliance and setting a new and later 'secondary' effective date for the activities of the RVIA members. With this approach, a completed motor home would be required to comply with Standard No. 301-75 only if it were based on a chassis manufactured after the secondary effective date. While the establishment of such an 'experience interval' might at first appear to be a simple solution to an acknowledged problem, the NHTSA has concluded that it is not only unnecessary but inappropriate as well.; It is unnecessary because the ordinary private dealings between moto home manufacturers and their suppliers can ensure that sufficient technical information, experience with redesigned chassis, or some combination of the two will be available before the 'primary' effective date. The legal requirements of compliance by vehicles built with chassis that are manufactured after that date can be expected to trigger those market forces which will induce suppliers of incomplete vehicles to cooperate with RVIA members. Any 'experience interval' would represent an intrusion by the government into the satisfactory operation of those forces. This position was announced in the agency's response to an RVIA petition for reconsideration of effective dates (39 FR 40857, November 21, 1974) (copy enclosed).; The design of those motor homes that do not already comply wit Standard No. 301-75 can be modified in many ways to achieve compliance. Changes might be made in both chassis and bodies. Bodies might be redesigned in such a way that no change in chassis construction is necessary. Conversely, all of the necessary protection might be incorporated in an upgraded chassis design, assuming that the addition of a motor home body did not present protrusions that would degrade this protection. In fact, this latter approach is already being followed in the case of school buses with a Gross Vehicle Weight Rating of more than 10,000 pounds. I understand that the School Bus Manufacturers Institute and several of its major chassis suppliers have reached agreements that provide for substantially all the necessary impact protection in the chassis.; While RVIA members may not be as successful as the schoolbu manufacturers have been in inducing their chassis suppliers to redesign for compliance, the above example illustrates the importance of the government's avoiding involvement in such contractual relationships. This agency is concerned in the first instance with the performance of completed vehicles, rather than the allocation between incomplete vehicle manufacturers and final- stage manufacturers of the task of redesigning for such performance. The agency lacks both the information and the expertise to determine either the most appropriate form of such redesign or the time that each manufacturer might consider desirable to effect the transition. This determination is therefore best made through cooperation or negotiation between the private parties involved. Because this determination is inextricably connected with decisions concerning the advance supply of redesigned chassis, it is impossible for the NHTSA to become involved in negotiations over the latter without interference in the former. The creation of an 'experience interval' as requested by the RVIA would therefore be inappropriate. In any event, such a modification of the standard's effective dates is prohibited by Section 108 of the Motor Vehicle and Schoolbus Safety Amendments of 1974 (Pub. L. 93-492).; Finally ,the NHTSA has not found it necessary to take special steps t encourage incomplete vehicle manufacturers to furnish advance information to motor home manufacturers. We understand that such cooperation is already taking place.; Sincerely, James B. Gregory, Administrator |
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ID: aiam0328OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co. Ltd., Liaison Office in U.S.A., 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 400 County Avenue Secaucus NJ 07094; Re: Interpretation of Motor Vehicle *Safety Standard No. 101*#Dear Mr Mizuno:#In your letter of April 27 you ask whether it is permissible to use the words 'emergency throttle' to identify the hand throttle which Standard No. 101 requires to be identified by the word 'throttle' alone.#In our opinion the use of identifying words or symbols in addition to those required or permitted by Standard No. 101 is permissible as long as the additional words or symbols do not conflict with those required or permitted. We see no such conflict in this instance and confirm your belief 'that this wording can be used.'#Sincerely, Lawrence R. Schneider, Acting Chief Counsel; |
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ID: aiam1493OpenMr. G. Meier, Technical Service Manager, Porsche/Audi, 818 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. G. Meier Technical Service Manager Porsche/Audi 818 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Meier: This is in reference to your defect notification campaign (NHTSA No 73-0229) concerning possible fires resulting from a short in the radiator cooling fan in some Audi 100's.; The letter which you have sent to the owners of the involved vehicle does not entirely meet the requirements of 49 CFR Part 577. Specifically, the phrase, 'possible hazard that may exist in your vehicle,' may be construed as a disclaimer since it tends to discourage vehicle owners from having their vehicles corrected and is therefore not permitted. It is, however, permissible to state that the defect may not be present in every vehicle being campaigned if such a statement is applicable.; It will not be necessary to send an additional letter in this instance but all future defect notifications must comply with the applicable regulation. If you desire further information, please contact Messrs. W. J. Reinhart or James Murray at this office (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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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.