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: aiam4186OpenThomas J. Flanagan, Esq., Wiggin & Dana, 195 Church Street, P.O. Box 1832, New Haven, CT 06508; Thomas J. Flanagan Esq. Wiggin & Dana 195 Church Street P.O. Box 1832 New Haven CT 06508; Dear Mr. Flanagan: This responds to your letter to Mr. Brian McLaughlin, of our Rulemakin division, seeking an interpretation of the requirements of 49 CFR 541, *Federal Motor Vehicle Theft Prevention Standard*. You described a situation in which a client, Saab-Scania of America, imports cars subject to the theft prevention standard and uses them directly as company cars or leases them to employees for their personal use. After such use, the company sells the cars to dealers as used cars. On occasion, these vehicles may have an original equipment major part covered by the theft prevention standard that is so badly damaged during such use that the part must be replaced before the vehicle is delivered to a dealer or distributor. When this occurs, you asked whether the repair would be required to be made with a part marked with the full VIN or whether the repair could be made with a properly marked replacement part. We conclude that when a manufacturer uses a car as a company car in the manner you describe, it may make any necessary repairs to damaged major parts by installing parts marked as replacement parts. This conclusion is explained in detail below.; Section 2(7) of the Cost Savings Act (15 U.S.C. 1901(7)) defines manufacturer as 'any person engaged in the manufacturing or assembling of passenger motor vehicles or passenger motor vehicle equipment *including any person importing motor vehicles or motor vehicle equipment for resale*.' (Emphasis added). It is clear under this statutory definition that your client is a 'manufacturer' for the purposes of the theft prevention standard, since it is importing motor vehicles for resale.; Section 606(c)(1) of the Motor Vehicle Information and Cost Savings Ac (15 U.S.C. 2026(c)(1)) requires vehicle manufactures to certify that each vehicle complies with the requirements of the theft prevention standard 'at the time of delivery of such vehicle'. The preamble to the final rule establishing the theft prevention standard discussed this agency's conclusion that the 'delivery' as used in this part of section 606(c)(1) means the delivery from the manufacturer to a dealer or distributor, and that the delivery occurs when the goods are delivered by the seller to a carrier. 50 FR 43166, at 43185-43187, October 24, 1985. In the next sentence, section 606(c)(1) specifies that the certification shall accompany the vehicle until delivery to the first purchaser. NHTSA believes that this statutory requirement means that each vehicle in the lines selected as high theft lines and listed in Appendix A of Part 541 must be delivered to the first purchaser with *all* covered major parts marked in accordance with the theft prevention standard. However, NHTSA does *not* interpret this statutory provision as requiring that ever first purchaser be delivered a vehicle with all covered major parts marked with the VIN. Instead, the agency believes this means that the first purchaser may receive a vehicle with the undamaged covered original equipment major parts marked with the VIN, and with those covered major parts installed by a dealer or distributor to replace damaged original equipment parts marked as replacement parts.; In accordance with this interpretation, NHTSA does not believe that manufacturer delivers a car to itself, when the car is sold to the public as a new car. However, you have noted a circumstance in which cars are *bona fide* used as company cars and are sold to the public as used cars, not new cars. Congress knew that used cars frequently have some replacement parts substituted for the original equipment parts. However, Title VI contains no requirement that used cars have all covered major parts marked with the VIN. In fact, Title VI presumes that when an original equipment major part is so badly damaged that it must be replaced, it will be replaced with a replacement part marked in conformity with Part 541. This reflects a legislative judgment that such replacement does not increase the opportunity for car thieves to steal the car without fear of being apprehended, or otherwise frustrate the purposes of Title VI, even though the car no longer has all major parts marked with the VIN.; On the other hand, a severe burden would be imposed on al manufacturers if they were required to deliver all *bona fide* company cars to distributors or dealers with all covered major parts marked with the VIN. If this were required and the company car were involved in an accident that required a covered major part to be replaced, the manufacturer would have a choice of either asking the factory to produce a replacement part with the VIN marked on the part and waiting to repair the vehicle until the part marked with the VIN arrived, or ending the vehicle's use as a company car and shipping the unrepaired vehicle to a dealer or distributor with the damaged major part marked with the VIN still on the vehicle. Nothing in the legislative history of Title VI explicitly or implicitly suggests that Congress intended such harsh treatment of company cars under the theft prevention standard.; Balancing the absence of negative policy consequences under Title VI i manufacturers are allowed to repair company cars with properly marked parts against the significant burdens that would be imposed on manufacturers if damaged major parts on company cars had to be replaced with parts marked with the full VIN, NHTSA concludes that Title VI of the Cost Savings Act permits cars damaged while in *bona fide* use as company cars and sold to the public as used cars, to be repaired by the manufacturer using properly marked replacement parts. This conclusion is based on NHTSA's interpretation that *bona fide* use of the car as a company car by the manufacturer is, for all practical and policy purposes, tantamount to a delivery of the vehicle under section 606(c)(1). The conclusion is reinforced by the fact that when a company car is later sold to the public as a used car, the consumer purchasing the company car will get a car with the same theft markings as any other used car.; NHTSA would like to note that this interpretation applies only to Titl VI of the Cost Savings Act, and not to any other statutes administered by this agency. Those statutes may have different underlying policy considerations, which might mandate a different conclusion for cars used as company cars. Further, the agency wishes to emphasize that this interpretation applies only to *bona fide* company cars that are sold to the public as used cars, and not to most of the cars manufactured by the manufacturer.; Please feel free to contact me if you have any further questions abou our theft prevention standard.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1384OpenMr. Gordon Needleman, Patent Attorney, Dow Corning Corp., Midland, Michigan 48640; Mr. Gordon Needleman Patent Attorney Dow Corning Corp. Midland Michigan 48640; Dear Mr. Needleman: This is in reply to your letter of January 10, 1974, to Mr. Schneider. It is uncertain whether 'sometime in July of 1974 Federal standard will become effective relating to silicone brake fluids' The proposed effective date for DOT 5 fluids if July 1, 1974, but the comments on this rulemaking action are still under consideration and the actual effective date, if the proposal is adopted, will probably be somewhat later.; It is true the S5.4.3 of Standard No. 105a does not require that al reservoir labelling be 'DOT 3.' The letters '*e.g.*' mean 'for example'. If DOT 4 is the recommended fluid the 'DOT 4' would be the appropriate insertion in the required statement; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam0983OpenMr. F. S. Murley, Administrative Engineer, Oshkosh Truck Corporation, P.O. Box 560, Oshkosh, WI 54901; Mr. F. S. Murley Administrative Engineer Oshkosh Truck Corporation P.O. Box 560 Oshkosh WI 54901; Dear Mr. Murley: This is in response to your letter of January 31, 1973, in which yo asked us to confirm your 'understanding that FMVSS No. 121 will not apply to fire-fighting vehicles until 1 September 1976, two years from the effective date.' In general, you suggest that 'we would expect to comply with FMVSS for firefighting vehicles within two years after the effective date or two years from the date of publication of the FMVSS, whichever date occurs later'.; You have misread the relevant language of 49 CFR S 571.8. That sectio provides that the effective date of a standard as applied to firefighting vehicles is 'either 2 years after the date on which such standard or amendment is published in the Rules and Regulations section of the *Federal Register*, or the effective date specified in the notice, whichever is later', except as otherwise specified in the standard with reference to those vehicles. The alternatives are thus (a) 2 years after the publication date, or (b) the effective date, whichever is later -- *not* 2 years after the effective date, as you have read it.; Your reading would not be reasonable, since the effective date canno be before the publication date, there would be no point to the alternative phrasing.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4169OpenRobert G. Russell, Acting Director, Division of School Traffic Safety and Emergency Planning, Indiana Department of Education, Room 229, Indianapolis, IN 46204-2798; Robert G. Russell Acting Director Division of School Traffic Safety and Emergency Planning Indiana Department of Education Room 229 Indianapolis IN 46204-2798; Dear Mr. Russell: This responds to your letter asking about NHTSA's regulations fo school buses and the relationship between State and Federal school bus definitions and regulations. I regret the delay in responding to your letter.; According to your letter, Indiana distinguishes 'special purpose buses' from 'school buses.' Under your State's law, 'school buses' are defined as motor vehicles, other than special purposes buses, designed for more than 10 passengers and used to transport school children. 'Special purpose buses' are motor vehicles accommodating more than six passengers used by schools to transport handicapped students to special programs, or school children and supervisors to extracurricular school activities. Special purpose buses are prohibited from being used on a regular basis to carry students between their residences and schools and are not required to meet any State identification, construction or equipment standards for school buses.; You asked whether Indiana's definitions of 'school buses' and 'specia purpose buses' conflict with our school bus definition, and how Federal law might preempt State law in this matter.; To begin, it is important to keep in mind how State and Federal schoo bus definitions and regulations differ in their application. The standards we have issued under the National Traffic and Motor Vehicle Safety Act apply to vehicles according to our motor vehicle type classifications regardless of the classifications used by the various states. Our safety standards apply to the manufacture and sale of new motor vehicles, including school buses. Our regulatory definitions, set forth in 49 CFR Part 571.3, define a 'school bus' as a motor vehicle designed to carry 10 or more passengers plus a driver, sold for purposes that include carrying students to or from school or related events. Our definitions do not include one for 'special purpose buses.' A vehicle that is designed to carry 10 or more passengers and meets the Indiana definition of 'special purpose buses' is considered a 'school bus' under Federal law since it is intended for pupil transportation, notwithstanding its exclusion from Indiana's school bus definition.; Therefore, each person selling 10-passenger or larger 'special purpos buses' is required under the Vehicle Safety Act to ensure that those vehicles are certified as school buses. Violation of this Federal requirement by sellers of new school buses is punishable by civil penalties of up to $1,000. The requirement applies to new school bus sellers regardless of whether a vehicle is considered a 'school bus' under the laws of a particular State.; Further, the preemption provisions in section 103(d) of the Vehicl Safety Act are not limited in their effect by the fact that this agency's classification of a vehicle differs from that of one or more of the States. Regardless of how Indiana classifies a vehicle, Indiana may not apply to that vehicle standards which cover the same aspects of performance as Federal standards but are not identical to the Federal standards. The only exception is a State may set higher standards of performance for vehicles procured for the State's own use.; A State's definition of a 'school bus' is, of course, determinative o the application of State requirements to the operation of school buses, such as inspection, maintenance and identification requirements. It appears that the provision in Indiana's definitions that special purpose buses are not 'school buses' excludes those vehicles from the application of Indiana's definitions that special purpose buses are not 'school buses' excludes those vehicles from the application of Indiana's school bus operational requirements. While Indiana is responsible for determining requirements for vehicles operating in that State, NHTSA recommends that each State consider carefully setting operational requirements for all vehicles used to carry school children. Recommendations for specific aspects of States' pupil transportation programs have been issued in Highway Safety Program Standard No. 17, *Pupil Transportation Safety* (copy enclosed), which was promulgated by NHTSA under the Highway Safety Act in connection with the Federal funding of State highway safety programs. While not required to do so, individual States have chosen to adopt some or all of Program Standard No. 17's recommendations and Indiana might want to consider them for their special purpose buses.; You asked whether schools are permitted at any time under Federal la to transport school children to or from school related activities in a vehicle other than a school bus. Strictly speaking, the answer is yes, for two reasons. This is because, first, the requirements of the Vehicle Safety Act apply to new school bus manufacturers and sellers, and not to school bus users. Therefore, we cannot prohibit schools from using noncomplying buses to transport children although we do prohibit the manufacture and sale of new noncomplying school buses. Second, manufacturers and dealers are required to sell complying school buses only if they sell new *buses* for pupil transportation purposes. Other types of vehicles, for example 'multipurpose passenger vehicles' (vehicles constructed on truck chassis which carry nine or fewer passengers), may be sold to carry school children to school or school-related events.; I hope this information is helpful. Please contact my office if yo have further questions.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1691OpenMr. David F. Berry, Works Manager, Birmingham Manufacturing Company, Inc., P. O. Drawer 289, Springville, AL 35146; Mr. David F. Berry Works Manager Birmingham Manufacturing Company Inc. P. O. Drawer 289 Springville AL 35146; Dear Mr. Berry: This is in acknowledgment of your Defect Information Report, i accordance with the defect reporting regulation, Part 573.; The Defect Information Report involves: some trailers equipped wit Standard Forge axles which may have defective brake shoes.; The following National Highway Traffic Safety Administratio identification number has been assigned to the campaign *74-0224*. The first quarterly status report for this campaign is required to be submitted by February 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.; The letter which you have sent to the owners of the subject vehicle does not meet the requirements of Part 577(49 CFR), the Defect Notification regulation. It is therefore necessary that you send a letter which conforms to Part 577 to those owners who have not yet had their vehicles corrected at this time or indicated their intention to do so. A copy of your revised letter should also be sent to this office.; A copy of Part 577 is enclosed. It might be helpful to point out tha Part 577.4(a) and (b) should be quoted exactly. In paragraph (b) the vehicle manufacturer determines that a defect exists in his vehicles even though a specific component may be the cause of the defect.; The reference to motor vehicle equipment in the regulation only applie to equipment campaigns where vehicles are not directly involved. Part 577.4(d) requires a statement that vehicle crash without prior warning may occur in cases where this statement is true. If you desire further information, please contact Messrs. W. Reinhart or James Murray of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Acting Director, Office of Defect Investigation, Motor Vehicle Programs; |
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ID: aiam4493OpenMr. Wayne Apple 14738 Bronson Avenue San Jose, CA 95124; Mr. Wayne Apple 14738 Bronson Avenue San Jose CA 95124; Dear Mr. Apple: This is in reply to your letter of December 29, 1987 in which you ask whether a U-Turn Indicator 'is reasonable, within federal regulations or specifications, and if the Department of Transportation has interest in the concept and/or product.' Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment contains specifications for original and replacement lighting equipment. None of these specifications is for a U-turn indicator. However, a U-turn indicator is acceptable as original vehicle equipment provided it does not impair the effectiveness of the lighting equipment that the standard requires, such as turn signal lamps, headlamps, taillamps, and stop lamps. Your proposed specifications recognize the importance of differentiation between the left turn signal and the U-turn indicator, and we encourage you to minimize the possibility of impairment. Standard No. 108 does not cover a U-turn indicator as an aftermarket device, but it is subject to the general restriction that its installation must not render inoperative, in whole or in part, any lamp, reflective device, or associated equipment that was installed pursuant to Standard No. 108. (15 U.S.C. 1397(a)(2)(A)) The legality of use of an aftermarket device of this nature would be determinable under the laws of the State in which a vehicle equipped with it is registered or operated. The American Association of Motor Vehicle Administrators, 120l Connecticut Ave. N.W., Washington, D.C. 20036, may be able to advise you further on State laws. Accident data available to the agency does not permit us to identify specific crashes in which a vehicle is making a U-turn. However, an analysis of data from one of our files that contains information on almost 3 million crashes indicates that the general type of crash for which U-turn crashes are a subset (left-turning crashes) constitutes less than 6% of the total crash experience. Thus, we believe that the number of U-turn crashes is substantially less than the 6% represented by the broader category of crashes involving left-turning vehicles. We do not know the basis for your statement that your U-turn indicator 'will probably reduce accidents involving U-turns by over thirty percent'. However, the agency is interested in exploring concepts that could enhance vehicle safety. I am providing our Office of Research and Development with a copy of your letter for such further comment as may be warranted. We appreciate your interest in safety. Sincerely, Erika Z. Jones Chief Counsel CC: Michael Finkelstein; |
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ID: aiam3356OpenMr. C. Rodney Kuhns, 132 Frement Place, Los Angeles, CA 90005; Mr. C. Rodney Kuhns 132 Frement Place Los Angeles CA 90005; Dear Mr. Kuhns: This responds to your letter of August 10, 1980, in which you as whether your proposed urban transport vehicle would be classified as an automobile or a motorcycle.; The agency's definition of 'motorcycle' is given in 49 CFR S 571.3 which reads in part:; >>>'Motorcycle' means a motor vehicle with motive power having a sea or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.<<<; Based on our understanding of your drawings, your proposed vehicle ha more than three wheels. If our understanding is correct, your vehicle would be classified as a passenger car rather than as a motorcycle.; The requirements for passenger cars are more stringent than fo motorcycles. We have enclosed a pamphlet prepared by the agency which gives a brief summary of the requirements and applicability of each of the Federal motor vehicle safety standards (issued as of August 1978). However, because of the volume of these standards, we do not provide copies directly. We have enclosed an information sheet which explains how you can obtain up-to-date copies of our standards and other regulations.; This agency does not license any vehicles for street or highway use Licensing is handled by the States. We specify performance requirements, and any motor vehicle must be certified by its manufacturer as being in compliance with all applicable safety standards as of the date of its manufacture. If the vehicle complies with these requirements, we specify no further steps which must be taken.; The agency will provide confidential treatment for your letter an accompanying drawings.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4539OpenMr. Earl Dahl The Goodyear Tire & Rubber Co. Akron, OH 44316-0001; Mr. Earl Dahl The Goodyear Tire & Rubber Co. Akron OH 44316-0001; "Dear Mr. Dahl: This responds to your letter of June 1, 1988, seekin an interpretation of 49 CFR Part 574, Tire Identification and Recordkeeping. Specifically, you asked whether Goodyear could engrave its mold for the Tire Identification Number with a style of characters that was not specifically authorized in the Notes following Figure 1 of 574.5. Note 1 to Figure 1 of Part 574 specifies only four different print types which may be used for the DOT symbol and tire identification number. The style of print that you wish to use is not one of these designated styles. Nevertheless, Note 4 to Figure 1 states that other print types will be permitted if approved by the National Highway Transportation Safety Administration (NHTSA). The agency has examined the print type shown in the diagram attached to your letter and has no objections to your company printing the required information in the print type you submitted. You should be aware that in the final rule establishing Part 574 (35 FR 17257, November 10, 1970), NHTSA explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the information would be easily readable by all persons. The print type that you submitted is easily readable and thus satisfies our concerns in that regard. Accordingly, NHTSA approves your print type. Sincerely, Erika Z. Jones Chief Counsel "; |
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ID: aiam2814OpenMr. E. M. Ryan, Chief Design Engineer, Ward Industries, Inc., P.O. Box 849, Highway 65 South, Conway, AR 72032; Mr. E. M. Ryan Chief Design Engineer Ward Industries Inc. P.O. Box 849 Highway 65 South Conway AR 72032; Dear Mr. Ryan: This responds to your April 27, 1978, letter asking whether a sampl certification label that you submitted complies with the National Highway Traffic Safety Administration's (NHTSA) Part 567, *Certification*.; Military vehicles are exempted from compliance with Federal safet standards. Therefore, the application of the safety standards to these vehicles is a matter of contract between a manufacturer and the military. Since the NHTSA does not mandate Federal safety standards for these vehicles, it is not necessary to put certification labels on them. If you choose to include a label with a vehicle, the label would not be required to comply with any Federal regulations.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0829OpenMr. J. W. Kennebeck, Manager, Safety & Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck Manager Safety & Development Volkswagen of America Inc. Englewood Cliffs NJ 07632; Dear Mr. Kennebeck: This is in reply to your letter of June 26, 1972, on the subject of th conformity of the Volkswagen shoulder belt/knee bar system to the requirements of Standard No. 208. I apologize for our delay.; Your first question is whether the system would meet the requirement for a fully passive system under S4.1.2.1 and S4.1.3 if it were adjusted automatically and met the frontal and lateral crash protection requirements of S5.1 and S5.2 and if the vehicle conformed to Standard 216. Our reply is that a passive seat belt system of the type you describe would appear to satisfy the requirements of S4.1.2.1 and S4.1.3. It would also, however, be required to meet the requirements of S4.5.3. We cannot determine from your description whether the system is capable of fitting the range of occupants specified in S7.1, as required by S4.5.3.3.; Your second question concerns that possibility that the system could b used, with the shoulder belt either active or passive, to meet the second or third option for passenger cars manufactured between August 15, 1973, and August 15, 1975. You point to two variances between the Volkswagen system and the system contemplated by these options. S4.1.2.2 requires the installation of a Type 1 seat belt, whereas the Volkswagen system contains only a shoulder belt and a knee bar. S4.1.2.3 specifies either a Type 1 or a Type 2 seat belt assembly, neither of which is found in the Volkswagen system. It is our opinion that these variances are such that an amendment of the standard would be required to permit the use of the Volkswagen system under either S4.1.2.2 or S4.1.2.3.; With reference to both the passive system discussed in your firs question and a petition for rulemaking in connection with your second, we are particularly concerned with the actual crash performance of a single diagonal belt restraint as opposed to the Type 1 or Type 2 belts permitted in Standard No. 208. The injury criteria presently included in Standard No. 208 may not differentiate between restraint systems with good crash force distribution, such as the air cushion, and those such as the single diagonal belt which could poorly distribute loads on real human occupants. Accordingly, we would appreciate your sending us accident data describing experience with the European-type single diagonal belt.; Sincerely, Lawrence R. Schneider, 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.