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
| Interpretations | Date |
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ID: aiam1901OpenHonorable George Mahon, House of Representatives, Washington, DC 20515; Honorable George Mahon House of Representatives Washington DC 20515; Dear Mr. Mahon: This is in response to your letter of February 13, 1975, forwarding a article from Modern Tire Dealer which cited a speech by Len Barnes of the Automobile Club of Michigan. Mr. Barnes' speech concerned the National Highway Traffic Safety Administration's (NHTSA) Tire Identification and Record Keeping regulation. As we advised you in our letter of March 7, 1975, we believe the questions raised in Mr. Barnes' speech should be answered fully, and delayed our response until we could review our own data in this area.; By Act of Congress (Public Law 91-265), the National Traffic and Moto Vehicle Safety Act was amended in 1970 to require manufacturers and retreaders of tires to maintain the names and addresses of first purchasers so that owners of defective tires may be notified of any defect. The legislative history of this amendment makes it clear that the Congress recognized the need for regulations in the area. Earlier joint attempts by manufacturers and the National Highway Traffic Safety Administration to notify purchasers of defective tires produced inadequate results even in cases where the manufacturer offered to replace the defective tires free of charge. The poor results were attributable to the fact that owners could not be directly notified of the defect.; The magnitude of the problem which the regulation seeks to alleviate i clear. Since the inception of the program in 1966 through 1973, there have been 1,427,670 tires recalled in 88 separate defect recall campaigns. In 1973 alone, there were 116,743 tires recalled in 11 defect recall campaigns, rather than 'less than 100,000' as Mr. Barnes suggests. Further, information available to NHTSA indicates that the cost figure of 75 cents for each tire registration cited in Mr. Barnes' speech is too high, and that the actual processing cost is nearer to 25 cents. While it may be that the higher figure includes the labor cost attributable to salesmen filling out the forms and the office secretary mailing them to the manufacturer, we feel it is highly unlikely that the regulation necessitates hiring additional dealer staff.; Even utilizing Mr. Barnes' cost figures, however, it is NHTSA's vie that 75 cents for each tire registration is not an exorbitant expense in terms of insuring that a motorist will be advised if a tire he purchased is defective and could lead to death, a serious injury, or damage to his vehicle. As a comparison, an average family belonging to the Automobile Club of Michigan, which employs Mr. Barnes, would pay $68.00 or more for the road service protection and travel information offered by the club over the same two year period he was paying 75 cents per tire for defect insurance.; Mr. Barnes also suggests that consumers pay $1,100 for each defectiv tire recalled. This argument is clearly spurious, and ignores the basic purpose of insurance, including that marketed by Mr. Barnes' employer. Even using Mr. Barnes' figure, however, we consider $1,100 a small price to pay to save a life or avoid an injury. You may also be interested to note that a Federal jury in Florida recently returned a $2,300,000 verdict against Sears Roebuck & Company in a tort action involving a defective tire.; With regard to the effectiveness of the recordkeeping regulation, ou records indicate the percentage of tires being recorded is increasing, and should continue to increase when additional enforcement action is taken against manufacturers and dealers who do not comply with the regulation. Further, the percentage of tire failures has fallen from 6% in the 1968-69 period to less than 1% during 1974. Of course, what is most needed to make the regulation effective is the voluntary cooperation of retreaders and dealers in recording, reporting and maintaining the required information.; While this regulation indisputably places an added responsibility o retailers, we also believe that the burden is neither onerous nor unjustified in view of the danger to the consumer. The NHTSA has continually attempted to improve and simplify the procedures for the registration of tires, the most recent example being the Universal Tire Registration Format issued on June 3, 1974.; The alternative suggested by Mr. Barnes, utilizing governmen inspectors, would in our view be even more expensive than the current procedure. There are 67 new tire plants and over 6,000 retreading shops in the United States and many more abroad. To establish Federal inspectors and test equipment in each plant would be enormously expensive. Further, it would run counter to the basic premise of the Motor Vehicles Safety Program which is that manufacturers are self-certifiers, and must take full responsibility for defective vehicles and equipment they place on the market.; For these reasons, we are convinced that the requirement that dealer record the name and address of tire purchasers at the time of sale is reasonable and appropriate.; Sincerely, James B. Gregory, Administrator |
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ID: aiam0613OpenMrs. Avis M. Hicks, Administrator, Nevada State Purchasing Division, Department of Administration, Carson City, NV 89701; Mrs. Avis M. Hicks Administrator Nevada State Purchasing Division Department of Administration Carson City NV 89701; Dear Mrs. Hicks: This is in reply to your letter of December 14, 1971, in which you as certain questions relating to 'Gross Vehicle Weight Rating' (GVWR) as it would apply to our regulations, 49 CFR 567 and 568. Our requirement that certain weight ratings be applied to a label by vehicle manufacturers is a regulation and not a Federal motor vehicle safety standard.; Gross vehicle weight rating as defined in S 568 of the regulation 'means the value specified by the manufacturer as the loaded weight of a single vehicle.' This was further clarified in the *Federal Register* on October 8, 1971, 36 FR 14583, 'To preclude the possibility of understating a vehicle's GVWR, however, the certification regulation is herewith amended to provide that the stated GVWR shall not be less than the sum of unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity.' Unloaded vehicle weight has been defined as '. . . the weight of a vehicle with maximum capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants,' 36 FR 2511.; From the standpoint of the regulation itself, the only other limit o GVWR would be that it should not be more than the sum of the gross axle weight ratings (although it may be less), since otherwise the vehicle would obviously be supplied with axle systems inadequate for its carrying capacity.; Good engineering practice would dictate that weight ratings be based o the weakest component in the system regardless of what it, the weakest component, might be. Of course, weight distribution is one of the factors that must be considered in making these calculations. In the example you have cited, if a manufacturer supplied a rear axle on his vehicle with a stated axle weight rating of 13,000 pounds with tires on the axle having a sum total rating of something less he would be overstating the GAWR of a particular axle on his certification label. GVWR's should not be greater than the total tire capacity or as stated before the sum of the gross axle weight ratings.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs; |
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ID: aiam0306OpenMr. Paul Maloney, Elliot Business Machines, Randolph Industrial Park, Randolph, MA 02368; Mr. Paul Maloney Elliot Business Machines Randolph Industrial Park Randolph MA 02368; Dear Mr. Maloney: This is in reply to your letter of January 22, 1971, requesting that comment whether your system fulfills the requirements of Part 574, the Tire Identification and Record Keeping Regulation.; I am sure you will appreciate the fact that the Administration canno approve each of the various systems developed. Your system, upon a cursory review, appears adequate, however, the regulation speaks for itself concerning the actual requirements.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam5104OpenMs. Janet Taylor Marketing and Sales Manager A-PEX International Co., Ltd. 2900 Lakeside Drive Suite 101 Santa Clara, CA 95054-2812; Ms. Janet Taylor Marketing and Sales Manager A-PEX International Co. Ltd. 2900 Lakeside Drive Suite 101 Santa Clara CA 95054-2812; "Dear Ms. Taylor: This responds to your letter seeking information o how the laws and regulations administered by this agency would apply to a device called the 'Tap Root Equipment Stand.' The equipment stand consists of a base plate which is bolted to the floor of a vehicle, a vertical tube which attaches to the base plate, and a rotating shelf at the top of the tube. The stand is intended to be used for portable equipment such as laptop computers, facsimile machines, and car phones. By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Safety Act), it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable Federal safety standards. The following represents our opinion based on the facts provided in your letter. NHTSA does not have any safety standards specifically covering equipment stands. However, it is possible that the installation of an equipment stand could affect the compliance of a vehicle with some safety standards. All new motor vehicles manufactured for sale in the United States must be certified by their manufacturers as complying with the applicable Federal motor vehicle safety standards. If an equipment stand is installed in a certified vehicle prior to its first sale to a customer, the person making the installation would be considered a vehicle alterer. Under our certification regulation (49 CFR Part 567), a vehicle alterer must certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards. Manufacturers, distributors, dealers, or motor vehicle repair businesses modifying a used vehicle are prohibited by Section 108(a)(2)(A) of the Safety Act from knowingly rendering inoperative any safety device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Thus, if an equipment stand is installed in a used vehicle, any businesses making such installations cannot render inoperative the vehicle's compliance with any of our standards. In order to determine how installation of the Tap Root Equipment Stand could affect the compliance of vehicles with applicable Federal safety standards, you should carefully review each standard, including but not limited to those addressing occupant crash protection and occupant protection in interior impact. In that regard, I am enclosing for your information a fact sheet entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and a booklet entitled Federal Motor Vehicle Safety Standards and Regulations. By way of example, Standard No. 208, Occupant Crash Protection, requires, among other things, that passenger cars and multipurpose passenger vehicles and trucks with a GVWR of 8,500 pounds or less meet specified performance requirements in a crash test. In particular, test dummies occupying the front outboard seating positions must comply with specified injury criteria in a 30 miles per hour barrier crash test. The specified injury criteria are the head injury criteria (HIC), chest acceleration and deflection, and femur loading. Nothing in the testing requirements of Standard No. 208 explicitly prohibits the installation of an equipment stand in the interior of vehicles. However, the Tap Root Equipment Stand appears to have hard surfaces and sharp edges, especially as compared with the padded dashboard, steering wheel, seats, and other components the test dummy may contact in a crash. It may not be possible for a vehicle to satisfy the injury criteria during dynamic testing if the equipment stand was installed in an area contacted by the test dummy, or if the stand interfered with the deployment of air bags. Individual vehicle owners may modify their own vehicles without being subject to the federal safety standards. If the equipment stand is to be installed by such individual owners, however, I urge them to take potential safety hazards, such as those previously listed, into account before attempting to install the equipment stand. Manufacturers of motor vehicles and motor vehicle equipment are also subject to the defect provisions of the National Traffic and Motor Vehicle Safety Act. If data indicated that a device such as an equipment stand exposed occupants to an unreasonable risk of injury, such as from sharp edges resulting in injuries during crashes, the agency might conduct a defect investigation which could lead to a safety recall. I also note that, apart from the issue of whether the equipment stand itself posed any safety risk to vehicle occupants, it is possible that the means of installation could create problems. The manufacturer should ensure that the recommended means of installation would not result in such things as the seepage of vehicle exhaust gases into the passenger compartment or weakening of the metal floor pan. I hope this information is helpful to you and your client. If you have any further questions or need some additional information, please feel free to contact David Elias 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: aiam3879OpenMr. Eddie Cole, Answer Products, Inc., 27967 Beale Court, Valencia, CA 91355; Mr. Eddie Cole Answer Products Inc. 27967 Beale Court Valencia CA 91355; Dear Mr. Cole: This responds to your letter regarding the importation of motorcycl helmets by your company from Italy.; Federal Motor Vehicle Safety Standard No. 218, *Motorcycle Helmets* applies to helmets designed for use by motorcyclists and other motor vehicle users. You stated in your letter that there is a DOT *approval sticker* on the helmet and that your company's name is clearly displayed on the helmet. Standard No. 218 requires that each helmet be permanently and legibly labeled with the manufacturer's name or identification, model designation, size, month and year of manufacture, and the symbol DOT. The DOT symbol does not indicate approval of any helmet by the Department of Transportation. Instead, the DOT symbol represents the manufacturer's certification that the helmet meets all the requirements of Standard No. 218. A copy of this standard is enclosed for your information.; As an importer, your company is also considered a manufacturer unde the provisions of the National Traffic and Motor Vehicle Safety Act which is administered by this agency. Therefore, either your company's name or the Italian manufacturer's name should be affixed to each helmet. Your company and the Italian manufacturer are both responsible for any defect in the helmet or failure to comply with the standard's requirements.; You asked about other regulations of which you should be aware. Copie of these are enclosed:; >>>49 CFR Part 551--*Procedural Rules* (Subpart D-- Service of proces on foreign manufacturers and importers).; 49 CFR Part 566--*Manufacturer Identification*.<<< If you need additional information, please contact this office. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1844OpenHonorable Garner E. Shriver, House of Representatives, Washington, DC 20515; Honorable Garner E. Shriver House of Representatives Washington DC 20515; Dear Mr. Shriver: This is in response to your letter of March 6, 1975, forwardin correspondence from one of your constituents, Mr. Dick Robbins, Jr., commenting on a proposed weakening of the bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would then be 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).; Your interest and that of Mr. Robbins in this matter is appreciated. Sincerely, James C. Schultz, Chief Counsel |
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ID: aiam0756OpenMr. Chester R. Ely, President, Mercury Fabricators, 8335 Atlantic Boulevard, Cudahy, CA 90201; Mr. Chester R. Ely President Mercury Fabricators 8335 Atlantic Boulevard Cudahy CA 90201; Dear Mr. Ely: This is in reply to your letter of June 20, 1972, in which you as whether Motor Vehicle Safety Standards No. 206 (Door Locks and Door Retention Components) and 302 (Flammability of Interior Materials) apply to aluminum sleeper cabs which you manufacture for what appears to be installation on truck tractors.; Each motor vehicle safety standard is by its terms applicable t specific types of motor vehicles and motor vehicle equipment. Each vehicle or item of equipment to which a standard applies must conform to the standard until its first purchase by a user. Components which are incorporated into vehicles before their first purchase are considered to be part of the vehicle, and as a practical matter must conform to all standards applicable to it.; Standard No. 302 becomes effective September 1, 1972, and applies t trucks, which includes truck tractors. If a sleeper cab you manufacture is incorporated into a truck before its first purchase by a user, then it must conform to the standard. Moreover, the components to which the standard applies (paragraph S4.1) include mattress covers, and if you determine the standard applies under the criteria we have provided, mattress covers which you furnish must conform to the standard. You indicate you have tested the flammability of the cab utilizing a torch. While you may test for conformity to the standard in any way you choose, whether or not your product conforms to the standard will be determined by NHTSA utilizing the test procedures specified in the standard. Manufacturers who utilize procedures different from those in the standard should take care to correlate the results they obtained to those that would be obtained using the standard's procedures.; Standard No. 206 also applies to trucks, and will become effective fo all side doors leading to passenger compartments on September 1, 1972. Consequently, if the sleeper cabs you manufacture are incorporated into trucks before their first purchase the sleeper cabs must conform to Standard No. 206.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5554OpenMs. Barbara Bailey Administrative Assistant Camp Berachah Christian Retreat Center 19830 S.E. 328th Place Auburn, WA 98092-2212; Ms. Barbara Bailey Administrative Assistant Camp Berachah Christian Retreat Center 19830 S.E. 328th Place Auburn WA 98092-2212; "Dear Ms. Bailey: This responds to your letter and telephone call t Walter Myers of this office asking two questions about new 15-passenger vans that Camp Berachah leased from a dealer. I apologize for the delay in this response. You first asked whether we require the leased vans to comply with our Federal motor vehicle safety standards (FMVSS) for school buses. You also asked whether we require the vans to comply with those FMVSSs if Camp Berachah loaned or subleased them to a school. Subject to a few considerations, the answer to both questions is no. Some background information on our school bus regulations would be helpful. Our regulations require any person selling or leasing a new vehicle to sell or lease a vehicle that meets all FMVSSs applicable to that vehicle. Accordingly, persons selling or leasing a new school bus must sell or lease a vehicle that meets the FMVSSs applicable to school buses. Under 49 U.S.C. 30101, et seq. (referred to as Safety Act), a school bus is any vehicle that carries 11 or more persons and which is likely to be significantly used to transport students to or from school or related events. Thus, persons selling or leasing a new vehicle that carries 11 or more persons and which is likely to be significantly used to carry students is selling or leasing a new school bus. That means that the new vehicle must meet the school bus FMVSSs. The FMVSSs apply only to new vehicles prior to sale to the first retail purchaser. The onus of complying with the school bus regulations is mainly on the seller or dealer to ensure that each new school bus it sells or leases has been certified to the school bus FMVSSs. The purchaser, on the other hand, is not subject to such constraints. Under our school bus regulations, the purchaser is free to use any vehicle to transport school children. That is because this agency does not regulate the use of vehicles once they have been sold at retail. Turning to your questions, we answer no to your first question based on the following. It was unclear from your letter whether Camp Berachah is connected with a school. In directing NHTSA to issue its school bus regulations, Congress considered buses used to transport children to camps connected with schools to be subject to the school bus FMVSSs. However, you clarified the nature of Camp Berachah in your conversation with Mr. Myers. You said that Camp Berachah is independent from any school and is not in any way affiliated with a school. Based on that information, Camp Berachah does not appear to be a school. Thus, our school bus regulations do not require the leasing of complying school buses for Camp Berachah purposes. In your second question, you asked whether the new leased vans had to comply with the school bus FMVSSs if Camp Berachah lent, rented or subleased them to a school. The answer depends on whether the vans are significantly used for pupil transportation, and if so, whether the dealer knew or should have known of such use. New vans that are likely to be significantly used to transport school children would be school buses, and the dealer leasing the new van is required to lease certified school buses. Use of the vans on a one-time or occasional basis would not constitute significant use as a school bus. However, if Camp Berachah were to sublease the vans to a school for long-term use, we believe the use of those vans for school transportation would be significant within the meaning of the Safety Act. Accordingly, the leasing company could not lease a new van for this purpose. You should also note that the states have the authority to regulate the use of vehicles by motorists. Thus, although NHTSA does not require the sale or use of complying school buses in the situations you described, Washington does have such authority. You may wish to contact the state director of pupil transportation to learn more about any state requirements applicable to vehicles used as school buses. In closing, we would like to note that school buses are one of the safest forms of transportation in this country. We therefore strongly recommend that all 15-passenger vans that are used to transport school children be certified as meeting the school bus safety standards. I hope this information is helpful. Should you have any further questions or need additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam2291OpenMr. Gilbert Theissen, 6S Hayden Hall, 33 Washington Square West, New York, NY 10011; Mr. Gilbert Theissen 6S Hayden Hall 33 Washington Square West New York NY 10011; Dear Mr. Theissen: This is in response to your letter of February 5, 1976, to Mrs Winifred Desmond of this agency concerning braking and rollover characteristics of the Jeep vehicle. We are sorry for the delay in our answer.; The Jeep Corporation is correct in saying that 49 CFR 571.105-75 *Hydraulic Brake Systems*, applies only to passenger cars. It will also apply to school buses manufactured after October 25, 1976. Part 575, Consumer Information Regulations, applies as a whole to all motor vehicles (49 CFR 575.4), but the consumer information item requiring reports on brake performance is limited to passenger cars and motorcycles (49 CFR S 571.101).; With regard to rollover resistance, the agency has issued an advanc notice of proposed rulemaking to collect information on rollover resistance, but no requirement to report on rollover performance exists at this time.; Yours truly, Stephen P. Wood, Assistant Chief Counsel |
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ID: aiam1517OpenMr. George C. Nield,Engineering advisor,Busby Rivkin Sherman Levy and Rehm,900 17th Street, N.W., Suite 1100,Washington, D.C, 20006; Mr. George C. Nield Engineering advisor Busby Rivkin Sherman Levy and Rehm 900 17th Street N.W. Suite 1100 Washington D.C 20006; Dear Mr. Nield:#This is in response to your letter of JUne 10, 1974, i which you asked for our interpretation of the preemption provisions of the National Traffic and Motor Vehicle Safety Act (sec. 103(d)) with respect to the Pennsylvania position on brake hose. A letter that you enclosed from the Pennsylvania Department of Transportation advised a manufacturer's representative that 'Pennsylvania will continue to approve brake hoses under the SAE Standards for air, hydraulic and vacuum hose,' and that the State 'will continue to require the hose be identified in the same manner as our present regulations.' with the Federally-required labeling placed on 'a separate line' from the State's labeling.#Section 103(d) of the Act, 15 U.S.C 1392(d), plainly prohibits any State from establishing or continuing in effect a safety standard applicable to an item of motor vehicle equipment, where there is an applicable Federal standard, unless the State standard is 'identical to the Federal standard.' This preemption provision takes effect whenever a Federal standard is applicable to the same aspect of performance as the State standard. When the new Federal standard on brake hoses comes into effect, with its testing and labeling requirements, any differing State standards, as Pennsylvania's appear to be will be preempted and void.#Sincerely, Lawrence R, Schneider,Chief Counsel; |
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.