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: aiam1111OpenMr. Wesley L. Barclift, State of Washington, Department of Motor Vehicles, Olympia, WA 98504; Mr. Wesley L. Barclift State of Washington Department of Motor Vehicles Olympia WA 98504; Dear Mr. Barclift: This is in reply to your letter of March 27, 1973, concerning th acceptability of the State of Washington title application form as a means of conforming to the Federal odometer disclosure requirements in new car transactions.; Although we are not anxious to increase the paper work burden in ne car transactions, without good reason, there have been indications of a variety of misleading practices involving new cars and we drafted the requirements to place new car transactions, with one exception, on the same footing as used car transactions. We would therefore urge that a full statement be given to new car purchasers, or at the least, that a statement containing the balance of the information required by section 580.4 be appended to the application form.; The exception is the transfer between dealers of a new car prior to it first sale to a customer. Your letter indicates that you may have overlooked this exception, which is found in section 580.5(b).; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3086OpenMr. David Gibbard, Vesely Company, 2101 N. Lapeer Road, Lapeer, Michigan 48446; Mr. David Gibbard Vesely Company 2101 N. Lapeer Road Lapeer Michigan 48446; Dear Mr. Gibbard: This is in confirmation of your telephone conversation with Mr Schwartz of my office on August 6, 1979, and the previous telephone conversations between Mr. Schwartz and Mr. Arnold, formerly of your company, and Mr. Erickson of our Office of Rulemaking and Mr. Arnold. It also serves to supplement the letter from Michael Finkelstein, Associate Administrator for Rulemaking, to the president of your company, Mr. McCollough.; Barring an order of the Court of Appeals for the Fourth Circuit, w anticipate no changes in the rule beyond those made in Notice 8. Further, the contract with the Society of Automotive Engineers to act as the NHTSA's agent in distributing manufacturer identifiers, which Mr. Arnold was advised the agency was negotiating, has been entered into. We are therefore able to confirm the answer to your company's remaining questions with certainty. The technical questions you raised will be answered first, as we understand you would prefer to have these answers in writing also.; 1. You have asked whether Vesely can use the first two characters o the sequential number (the 12th and 13th characters of the VIN if one includes the check digit) for internal company purposes as the number of vehicles produced is more than 500, but never exceeds 9,999 of a particular model annually. There is nothing in the standard which precludes utilizing the 12th and 13th characters for internal purposes so long as the agency is advised which characters are to be used and that they are to be disregarded.; 2. You have also advised us that Vesely desires to use severa manufacturer identifier the codes beginning with the letter V. When the NHTSA published its rule establishing the manufacturer identifier system on August, 17, 1978, the Society of Automotive Engineers (SAE) immediately submitted a list of approximately 500 identifiers on behalf of vehicle manufacturers. These identifiers had been previously assigned to manufacturers by the SAE in their role as assigner of world manufacturer identifiers on behalf of the International Standard Organization. Unfortunately, the configuration Vesely proposed was reserved by the SAE at that time.; Because of the substantial experience the SAE has had in this area, th NHTSA has contracted with them to assign the remaining manufacturer identifiers. If you would write to the SAE at the address given below, advising them of the types of vehicles you are now producing or intend to produce, they will assign your manufacturer identifiers at no charge. Please write to:; >>>Society of Automotive Engineers 400 Commonwealth Avenue Warrendale, Pennsylvania 15096 Attention: Leo Ziegler<<< I trust this information answers the questions you have concerning th VIN. Please contact us if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4743OpenNormand Laurendeau, Esq. Guy & Gilbert Place Mercantile 770 Sherbrooke Street West Suite 2300 Montreal, Quebec CANADA H3A 1G1; Normand Laurendeau Esq. Guy & Gilbert Place Mercantile 770 Sherbrooke Street West Suite 2300 Montreal Quebec CANADA H3A 1G1; "Dear Mr. Laurendeau: Thank you for your letter on behalf of you client, who distributes auto glass parts in Canada. You had two questions regarding your client's status as an 'intermediate' in the motor vehicle industry. Before I address your specific questions, I believe some background information about this agency may be of assistance to you. The National Highway Traffic Safety Administration (NHTSA) has the authority under the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet our safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates other alleged safety-related defects. I have enclosed an information sheet which briefly describes each of a manufacturer's responsibilities under the Safety Act. The information sheet also explains how a company offering an item of motor vehicle equipment for importation into the United States must designate an agent within this country for service of process. Your letter describes your client as 'one of the major distributors of auto glass parts in all of Canada.' Your letter states that your client's customers demand that your client 'certifies all glasses shipped with D.O.T. number AS1 or AS2 for domestic and export purposes in all countries.' I will now address the specific questions raised in your letter. Your first question was whether your client, as a distributor of automotive safety glass, needs a D.O.T. number to operate in the United States. The answer to this question depends on what role your client has in the process that results in glazing being sold to the customer. The agency has issued Standard No. 205, Glazing Materials (49 CFR 571.205) which specifies performance requirements for glazing for use in motor vehicles. S6 of Standard No. 205 establishes marking and certification requirements for manufacturers and distributors of glazing materials. The marking and certification requirements differ, depending upon whether your client is a 'prime glazing material manufacturer' or simply a manufacturer or distributor. A 'prime glazing material manufacturer' is defined in S6.1 of Standard No. 205 as 'one who fabricates, laminates, or tempers the glazing material.' If your client performs any of these operations, it must comply with the marking and certification requirements set forth in S6.1 through S6.3 of Standard No. 205. S6.1 requires every prime glazing material manufacturer to mark all glazing materials it manufactures in accordance with American National Standard 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways' Z-26.1-1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980 (hereinafter referred to as 'ANS Z26). S6.2 of Standard No. 205 requires each prime glazing material manufacturer to certify each piece of glazing designed as a component of any specific motor vehicle or camper by adding to the mark required by S6.1 the symbol 'DOT' and a manufacturer's code mark that is assigned by this agency. S6.3 requires each prime glazing manufacturer to certify each piece of glazing designed to be cut into components for use in motor vehicles pursuant to the requirements of section 114 of the Safety Act (15 U.S.C. 1403). Assuming that your client would not be considered a 'prime glazing material manufacturer,' but is simply a distributor, it would not need to be assigned a DOT number pursuant to S6.2 of Standard No. 205. In your letter, however, you incorrectly identified the codes AS1 and AS2 as DOT numbers. Those codes are required on glazing materials by section 6 of ANS Z26. As explained below, your client may be required to add such markings to glazing materials, even if your client is only considered a distributor for the purposes of Standard No. 205. Each manufacturer or distributor who cuts a section of glazing material to which Standard No. 205 applies, for use in a motor vehicle or camper, must comply with the requirements set forth in S6.4 and S6.5 of Standard No. 205. For sections of glazing that are cut by the manufacturer or distributor, the manufacturer or distributor must mark it in accordance with section 6 of ANS Z26 (S6.4) and certify it in accordance with section 114 of the Safety Act (S6.5). Your second question asked about the potential liability of a distributor for the certification of automotive safety glazing for importation into the United States. If your client is required to certify glazing it distributes pursuant to the provisions in either S6.2, S6.3, or S6.5 of Standard No. 205, the failure to so certify would be a violation of the standard. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) provides that: No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard ... Thus, if your client is required by Standard No. 205 to certify some glazing it distributes, the failure to make such a certification would be a violation of section 108(a)(1)(A) of the Safety Act. Even if your client is not required to certify the glazing it distributes pursuant to Standard No. 205, section 114 of the Safety Act requires every distributor of motor vehicle equipment (such as glazing) to furnish a certification. Section 114 provides: Every manufacturer or distributor of ... motor vehicle equipment shall furnish to the distributor or dealer at the time of delivery of such ... equipment by such ... distributor the certification that each such ... item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards. In the case of an item of motor vehicle equipment such certification may be in the form of a label or tag on such item or on the outside of a container in which such item is delivered. Section 108(a)(1)(C) of the Safety Act provides that no person shall fail to issue a certificate required by section 114, or issue a certificate to the effect that a motor vehicle or item of motor vehicle equipment conforms to all applicable safety standards, if such person in the exercise of due care has reason to know that such certificate is false or misleading in a material respect. Section 109 of the Safety Act (15 U.S.C. 1398) provides that any violations of section 108 subject the violator to a civil penalty of not to exceed $1,000 for each such violation, up to a maximum penalty of $800,000. I hope this information is helpful. If you have any further questions or need any additional information, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam1541OpenMr. A. Deane, Flyer Industries Limited, 6 Otter Street, Winnipeg, Canada R3T OM6; Mr. A. Deane Flyer Industries Limited 6 Otter Street Winnipeg Canada R3T OM6; Dear Mr. Deane: This responds to your June 5, 1974, question whether electric trackles trolley coaches are motor vehicles under the National Traffic and Motor Vehicle Act of 1966, and if so, whether Standard No. 121, *Air brake systems*, or any other special requirements must be met by this type of vehicle. Section 102(3) of the Act defines motor vehicle:; >>>'Motor vehicle' means any vehicle driven or drawn by mechanica power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.<<<; An electric trackless trolley coach is a motor vehicle under thi definition, and Standard No. 121, *Air brake systems*, applies to a coach equipped with an air brake system. No special requirements apply to trackless trolley coaches. Standard No. 121, *Air brake systems*, requires stopping distance performance which must be met by any bus equipped with air brakes, whether or not it is equipped with supplementary dynamic braking means. In evaluating a vehicle's compliance with the stopping distance performance requirements of S5.3 and S5.7.2.3, auxiliary braking devices may be utilized in making the stops provided such devices are engaged by means of the same service brake pedal or parking brake control that operates the air brakes. It should be noted, however, that these stops must be made with the transmission selector control in neutral or the clutch disengaged (S6.1.3).; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5502OpenRobert D. Dods, Staff Assistant Honolulu Office Senator Daniel K. Inouye Room 7325 Prince Kuhio Federal Building 300 Ala Moana Boulevard Honolulu HI 96850-4975; Robert D. Dods Staff Assistant Honolulu Office Senator Daniel K. Inouye Room 7325 Prince Kuhio Federal Building 300 Ala Moana Boulevard Honolulu HI 96850-4975; Dear Mr. Dods: Joseph Cindrich, National Highway Traffic Safet Administration (NHTSA) Regional Administrator, has forwarded for reply your letter to him of January 25, 1995. You asked for verification that the Federal Motor Vehicle Safety Standards apply to the Commonwealth of the Northern Marianas Islands (CNMI), and 'if the office responsible for enforcement would notify the appropriate CNMI officials of the compliance requirements.' The Federal Motor Vehicle Safety Standards clearly apply in the CNMI. In 1994, the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1381 et seq., was recodified as 49 U.S.C. Chapter 301 - Motor Vehicle Safety. As part of the recodification, 'the Northern Mariana Islands' was added to the definition of a 'State' (49 CFR 30102(a)(10)). This means that it is a violation of 49 U.S.C. 30112(a), (cited in the 1987 letter as 15 U.S.C. 1397(a)(1)(A)), to import a vehicle into the CNMI that does not comply with the Safety Standards. The recodification reflected existing law, and the Safety Standards applied long before it occurred. I enclose a copy of a letter that this Office sent to Ellen A. Lockwood, Assistant United States Attorney, Guam, on December 30, 1987, in which we informed her that the Safety Standards applied in the CNMI at that time, even though the regulations of the U.S. Customs Service did not. I find no record of a response from her. Given the geographical proximity of the United States Attorney's office to the CNMI and the fact that NHTSA has no employees west of California, we recommend that apparent violations be reported to that Office. Between the 1987 letter and the recodification of 1994, Congress enacted the Imported Vehicle Safety Compliance Act of 1988 (P.L. 100-562) which revoked the joint NHTSA - U.S. Customs regulatory authority of 15 U.S.C. 1397(b)(3). Pursuant to the 1988 legislation, NHTSA issued its own import regulation, 49 CFR Part 591, which has superseded the previous joint NHTSA-U.S. Customs regulation, 19 CFR 12.80, with respect to the importation of vehicles and equipment subject to the Safety Standards. As the 1987 letter notes, 12.80 did not apply to the CNMI because the CNMI is outside the Customs Territory of the United States. However, Part 591 clearly applies in the CNMI since it implements Chapter 301. Sincerely, Philip R. Recht Chief Counsel Enclosure; |
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ID: aiam1812OpenMr. P. H. Whitman, Government Representative, The Gates Rubber Company, 999 South Broadway, Denver, CO 80217; Mr. P. H. Whitman Government Representative The Gates Rubber Company 999 South Broadway Denver CO 80217; Dear Mr. Whitman: This responds to your letter of January 30, 1975, concerning th relationship between the requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, and Military Specification MIL-H-3992C.; Part 571.7(c) of the Federal Motor Vehicle Safety Standards, 49 CF 571.7(c), provides that:; >>>No standard applies to a vehicle or item of equipment manufacture for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.<<<; Therefore, brake hose sold to the military in conformity wit MIL-H-3992C is not subject to any of the requirements of Standard No. 106-74. While Part 571.7(c) appears to exclude from the requirements of Standard No. 106-74 only that hose which is sold directly to the Armed Forces, the NHTSA interprets this section as also excluding that hose which is sold to military contractors, under contracts requiring it to conform to military specifications such as MIL-H-3992C, for installation in vehicles which are in turn sold directly to the military. We are considering the issuance of an interpretive amendment of Part 571.7(c) to this effect.; Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam0502OpenMr. G. E. Fouche', Jr., Project Leader, Kendall Company, P. O. Box 1828, 6300 Carmel Road, Charlotte, NC, 28201; Mr. G. E. Fouche' Jr. Project Leader Kendall Company P. O. Box 1828 6300 Carmel Road Charlotte NC 28201; Dear Mr. Fouche': This is in reply to your letter of November 2, 1971, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to synthetic fabrics. You state that certain of these fabrics do not ignite when tested with a stationary flame as they melt and shrink away from the flame, but burn faster than the 4-inch-per-minute rate if the flame is moved to keep it in contact with the fabric. You ask whether materials that behave in this manner comply with the standard.; The standard requires that the vehicle components specified in S4.1 o the standard meet the burn rate requirements when tested as provided in S5.3 of the standard. This procedure specifies a stationary flame. Consequently, we would consider materials which melt and shrink away from the flame, but do not ignite, as long as the other aspects of the test procedure were followed, to comply with the standard.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5350OpenMr. Michael E. Klima Managing Engineer Failure Analysis Associates, Inc. 2100 East Maple Road, Suite 200 Birmingham, MI 48009; Mr. Michael E. Klima Managing Engineer Failure Analysis Associates Inc. 2100 East Maple Road Suite 200 Birmingham MI 48009; Dear Mr. Klima: This responds to your letter of March 29, 1994, to Mr Edward Jettner of this agency concerning the dynamic testing requirements of Standard No. 208, Occupant Crash Protection. Your questions concern the application of this standard to a pickup truck manufactured in April 1988 with a gross vehicle weight rating (GVWR) of 4,400 pounds. You asked whether the injury criteria in S6 apply to this truck, whether a 35 mph fixed barrier crash test is required, and which sections of Standard No. 208 apply to this truck. The safety belt installation requirements for all vehicle types are set forth in Standard No. 208. Section S4.2.1 of Standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in trucks and multipurpose passenger vehicles with a GVWR of 10,000 pounds or less, manufactured on or after January 1, 1976 and before September 1, 1991. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seating positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protection requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic protection for the front outboard seats, and have a warning system for the safety belts provided. Option 3, set forth in S4.1.2.3, requires the manufacturer to install lap or lap/shoulder safety belts at every seating position and to have a warning system for those belts. According to your letter, the manufacturer installed Type 2 seat belt assemblies at the front outboard seating positions. This suggests that the manufacturer chose to comply with Option 3. Under this option, the only requirements in Standard No. 208 that those belts were required to comply with were S7.1, S7.2, and S7.3. The belts were also required to comply with the requirements of Standard No. 209, Seat Belt Assemblies. The manufacturer was not required to certify that the vehicle complied with the dynamic testing requirements of Standard No. 208. The injury criteria in S6 of the standard are applicable only to vehicles which must comply with the dynamic testing requirements. Standard No. 208 does not include a 35 mph fixed barrier crash test requirement. The dynamic crash test in Standard No. 208 is barrier crash test at any speed up to 30 mph. NHTSA does perform some 35 mph barrier crash tests as part of the New Car Assessment Program (NCAP). NCAP is a consumer information program, not a safety compliance test. NHTSA does not test every vehicle under this program. In the 1993 model year program, NHTSA tested 37 new vehicles and released results on 68 additional vehicles which had been tested previously and had not changed significantly in model year 1993. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel; |
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ID: aiam2495OpenMr. David Munafo, Commercial Plastics, 98-34 Jamaica Avenue, Richmond Hill, NY 11418; Mr. David Munafo Commercial Plastics 98-34 Jamaica Avenue Richmond Hill NY 11418; Dear Mr. Munafo: This responds to your letter of December 7, 1976, regarding the use o plastic glazing materials for side windows of school buses. You asked what materials are permitted by Federal regulations for school bus side windows and whether Federal laws concerning the materials that may be used preempt State laws on the same subject.; Section 103(d) of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S1381 *et*. *seq*.) provides in part:; >>>Whenever a Federal motor vehicle safety standard established unde this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.<<<; Safety Standard No. 205, *Glazing Materials* (49 CFR 571.205) currentl does not permit the use of plastic glazing in bus side windows. Therefore, State laws that permit plastic glazing are in direct conflict with Standard No. 205, and it is the agency's opinion that they would be preempted.; I would point out that the agency recently issued a proposal to amen Standard No. 205 that would permit the use of rigid plastic glazing in bus side windows (41 FR 56837, Dec. 30, 1976). I am enclosing a copy of this proposal for your information. I am also enclosing a copy of Standard No. 205 and the ANS Z26 standard that is incorporated by reference in Standard No. 205. From these standards you can determine the various types of glazing materials that are permitted for side windows and the requirements that the glazing must meet.; Regarding your question about replacement glazing, Standard No. 205 i not a vehicle standard and is applicable to all glazing for use in motor vehicles, whether the glazing is to be installed in new vehicles or as replacement in used vehicles. Therefore, glazing manufacturers and fabricators cannot produce glazing to be used in a given location in a vehicle unless the standard permits that type of glazing to be used in that location, regardless of whether it is original or replacement glazing.; Sincerely, Frank Berndt, Acting Chief Counsel |
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ID: aiam0152OpenMr. Yoshiyuki Mizuno, Factory Engineer, Nissan Motor Corporation, 400 County Avenue, Secaucus, NJ 07094; Mr. Yoshiyuki Mizuno Factory Engineer Nissan Motor Corporation 400 County Avenue Secaucus NJ 07094; Dear Mr. Mizuno:#Thank you for your letter of March 7, 1969, to Dr William Haddon, Jr., concerning the location and the identification of the windshield washer switch on the steering column.#The system as you describe it appears to conform to Federal Motor Vehicle Safety Standard No. 101, however, the Bureau does not issue approvals of any specific system, and the development of equipment to comply with the standard is the responsibility of the individual manufacturer.#In reference to your second question about the identification of the windshield washer switch, Paragraph S3.2 reads, in part, '.... The following controls, when mounted on the instrument panel, shall be identified to permit recognition -- >>>... (c) Windshield Washing System, ....'<<<#This section of the regulation does not apply to the identification of controls in any position other than on the instrument panel.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service; |
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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.