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: aiam3788OpenMichael J. Schmitt, Counsel, Yamaha Motor Corporation, USA, 6555 Katella Avenue, Cypress, CA 90630; Michael J. Schmitt Counsel Yamaha Motor Corporation USA 6555 Katella Avenue Cypress CA 90630; Dear Mr. Schmitt: This is in response to your letter asking for an interpretation on th permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.; Federal Motor Vehicle Safety Standard (FMVSS) No. 108, 'Lamps Reflective Devices, and Associated Equipment (sic) states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the 'A' type headlamp system described as follows:; >>>Type 1A1 or Type 1A . . . . 1 lamp and either Type 2A1 or Type 2A . . . . 1 lamp<<<< The standard is specified this way because the 2A1 lamp is a lower bea lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an 'upper beam', photometrically it provides only 'fill-in' light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.; Sincerely, Barry Felrice, Acting Associate Administrator for Rulemaking |
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ID: aiam3622OpenMr. Max Peck, Superintendent, Thatcher Unified Schools, District No. 4, P.O. Box 610, Thatcher, AZ 85552; Mr. Max Peck Superintendent Thatcher Unified Schools District No. 4 P.O. Box 610 Thatcher AZ 85552; Dear Mr. Peck: This is in response to your letter of September 30, 1982, enclosing 'petition for exemption...on behalf of Capps and Lancaster Service Center'. The petition concerns a single motor vehicle consisting of the body of a 1974 Dodge school bus which has been removed from its original chassis and attached to a new 1981 International Harvester chassis.; This agency does not regulate the use of motor vehicles. That is matter for State governments. We do enforce the Federal motor vehicle safety standards and grant exemptions as appropriate consistent with our authority.; I regret that the exemption process is not available in your case. Par 555 is intended to cover the future vehicle production of bona fide motor vehicle manufacturers, and not a single conversion, performed in the past, by what appears to be a service garage. Under our regulations, the combination of an old body upon a new chassis results in a new motor vehicle required to meet the motor vehicle safety standards in effect when the chassis was manufactured. Compliance is especially important in this instance because of all the school bus safety standards that have become effective since the bus body was manufactured in 1974, and which affect its structure and that of its seats.; This means that Capps and Lancaster are technically in violation of th National Traffic and Motor Vehicle Safety Act, for which a penalty of up to $1000 may be imposed. We do not intend to pursue this, however, unless other violations come to our attention. However, our Office of Vehicle Safety Compliance will be contacting Capps and Lancaster to make them aware of their responsibilities in order to prevent further violations by that company.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2930OpenMr. R. L. Ratz, P.E., Product Safety Engineering, Grumman Flxible, 970 Pittsburgh Drive, Delaware, OH 43015; Mr. R. L. Ratz P.E. Product Safety Engineering Grumman Flxible 970 Pittsburgh Drive Delaware OH 43015; Dear Mr. Ratz: This is in reply to your letter of December 8, 1978, asking whether th front and rear clearance lamps on your Model 870 Urban transit coach comply with Federal Motor Vehicle Safety Standard No. 108.; The front clearance lamps on the Model 870 are combined with the tur signal lamps, side marker lamps, and side reflex reflectors. The units are located 'on line with and just outboard of each rectangular headlamp,' with lens center 32 inches above the road surface, at a point that appears to be at the vehicle's overall width. The rear clearance lamps are combined with the stop lamps and rear side marker lamps, their horizontal center lines 64 inches above the road surface, at approximately the vehicle's overall width. Front and rear identification lamps are mounted at the top of the vehicle.; The general rule expressed by Table II of Standard No. 108 is tha clearance lamps must be mounted 'to indicate the overall width of the vehicle ... and as near the top thereof as practicable.' But a partial exception is provided by S4.3.1.4.: When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps need not meet the requirement of Table II that they be located as close as practicable to the top of the vehicle.'; This means that the mid-body location of the rear clearance lamp i acceptable since the rear identification lamps are at the extreme height of the vehicle. But the exception does not extend to the front clearance lamps. While Standard No. 108 allows the manufacturer to determine what location is 'as close as practicable to the top of the vehicle', there will be instances when the overall width of the vehicle will not be indicated by the highest location. In such instances the best location will be the one that most closely approximates the intent behind the requirement - to indicate the overall width.; Specifically with reference to the Model 870, it appears to us that th close proximity of the combination lamp to the headlamp may result in the effectiveness of the clearance lamp being impaired by the brightness of the headlamp, and that the most practicable location sufficiently indicating the overall width of the vehicle, would be at the outer edges of the body directly below the windshield.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam4372OpenTak Fujitani, Program Manager, Inspection Services, Office of Fleet Administration, 1416 -10th- Street, 2d Floor, Sacramento, CA 95814; Tak Fujitani Program Manager Inspection Services Office of Fleet Administration 1416 -10th- Street 2d Floor Sacramento CA 95814; Dear Mr. Fujitani: This letter responds to your inquiries addressed to Joan Tilghman of m staff. Your letters concern buses purchased by the State of California, and manufactured by Champion Home Builders, Commercial Vehicle Division (Champion). You inform us that Champion is a final stage manufacturer of vehicles built on a Ford chassis. You have rejected delivery of these vehicles because you assert that they do not comply with either California or Federal motor vehicle regulations. This response addresses only those issues arising from Federal requirements.; As I understand your letters, you pose two principle questions. First you ask whether classifying an incomplete vehicle as a 'chassis' rather than as a 'chassis cab' means that a final stage manufacturer can not alter the original chassis manufacturer's gross vehicle weight rating (GVWR). You assert that Champion's altering of the GVWR on a vehicle classified as a 'chassis' is a noncompliance under 49 CFR sections 567.5 and 568.4 which you may use as grounds for rejecting delivery of Champion's vehicles.; Your second question involves data set out in your letter of April 14 suggesting that Champion's certified GVWR for these vehicles is less than the sum of the unloaded vehicle weight, the rated cargo load, and 150 lbs. times the vehicles' designated seating capacity. You state that this circumstance is a second noncompliance with Federal regulations upon which you have rejected delivery of Champion's buses.; >>>*The Cutaway Chassis/Chassis Cab Question*.<<< In both your letters, you refer to provisions of 49 CFR 567.5 an 568.4, and to a 1977 Federal Register document (42 FR 37814, 37816, July 25, 1977). You state your interpretation of these 49 CFR provisions as 'mean(ing) that final stage manufacturers (who build on RV cutaways) are not authorized to alter the (GVWR) imposed by incomplete vehicle manufacturers since final stage manufacturers do not have any basis for certifying a greater load carrying capaci(ty) without altering axle components to handle the extra load.' As I understand it, when you speak of an RV cutaway you mean a vehicle chassis with an incomplete occupant compartment, intended for completion as a recreational vehicle. For any incomplete vehicle (including a cutaway or chassis cab), Part 568 requires the incomplete vehicle manufacturer to provide a document that describes how to complete the vehicle without impairing the vehicle's compliance status. This document is *not* a certification.; If the incomplete vehicle is other than a chassis cab, the final stag manufacturer who builds on the incomplete vehicle must certify its compliance with all applicable Federal motor vehicle safety standards (FMVSS). On the other hand, the certification process is different if an incomplete vehicle meets the agency's definition of 'chassis cab.' The Federal Register document to which you refer amended 49 CFR Parts 567 and 568 to conform with a court decision holding that NHTSA could not require a final stage manufacturer to make the 'sole certification' of compliance for a vehicle built on a chassis cab. As a consequence of this decision, NHTSA established a dual certification scheme for such vehicles in which the chassis cab manufacturer makes one certification statement in each of three categories, and the final stage manufacturer makes corresponding statements depending on how the final stage manufacturer affects any applicable Federal motor vehicle safety standard (FMVSS).; Under this dual certification scheme, the original chassis ca manufacturer may provide instructions telling a final stage manufacturer how to complete a vehicle so that it conforms with applicable FMVSS. The final stage manufacturer has the choice of either conforming his work to the chassis cab manufacturer's instructions and shifting the burden under Part 567 of certifying compliance to the chassis cab manufacturer, or deviating from those instructions, and assuming the certification burden for himself. Further, the final stage manufacturer must certify compliance respecting any FMVSS for which the chassis cab manufacturer makes no representation.; While you are correct that in the 1977 Federal Register document th agency decided to exclude RV cutaways from the definition of 'chassis cab,' the only effect of this exclusion is that dual certification requirements do not apply to vehicles completed on an RV cutaway.; Therefore, the answer to your first question is that a final stag manufacturer may change the GVWR for any incomplete vehicle, irrespective of whether he builds the completed vehicle on an RV cutaway or a chassis cab. However, if the final stage manufacturer changes the GVWR for the vehicle, it must certify that the vehicle complies with all applicable FMVSS at this new GVWR. Compliance with Standards No. 105, *Hydraulic Brake Systems*, and No. 120, *Tire Selection and Rims for Vehicles Other Than Passenger Cars* might well be affected by an increase in the GVWR. The final stage manufacturer is required to exercise 'due care' when certifying that its vehicle complies with all safety standards at this increased GVWR. Our Office of Vehicle Safety Compliance has asked the final stage manufacturer of these vehicles to provide the data and other evidence that were the basis for Champion's certification of compliance at this higher GVWR.; >>>*Champion's Certified GVWR Calculation*.<<< Part 567 of NHTSA regulations sets out requirements for affixing certification label or tag to a motor vehicle. Section 567.4(g)(3) of that Part states that the certified GVWR:; >>>'...shall not be less than the sum of the unloaded vehicle weight rated cargo load, and 150 pounds times the vehicle's designated seating capacity. However, for school buses the minimum occupant weight allowance shall be 120.'<<<; In your April letter, you supply weightmaster readings for the tw Champion motor vehicles that are the subject of your inquiry. While Champion certifies the GVWR for both these vehicles at 12,000 pounds, you indicate that according to your S567.4(g)(3) calculation, the sums are 12,147 pounds and 12,580 pounds. This agency considers vehicle overloading a serious safety problem for the affected vehicle and for the motoring public, and NHTSA may take appropriate remedial action against any manufacturer whose vehicle, laden with its intended cargo load, exceeds the manufacturer's GVWR. NHTSA's Office Of Vehicle Safety Compliance is investigating this matter further.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1170OpenMr. Neal Gilleran, Product Manager Motorcycles, Chaparral Division, Armco Recreational Products, Inc., 5995 North Washington Street, Denver, Colorado 80216; Mr. Neal Gilleran Product Manager Motorcycles Chaparral Division Armco Recreational Products Inc. 5995 North Washington Street Denver Colorado 80216; Dear Mr. Gilleran: This is in reply to your letter of June 21, 1973, concerning Standar No. 123 in which you reference a discussion with Mr. Vinson of this office and ask whether a neutral gear indicator must be provided on motorcycles manufactured on or after September 1, 1974.; Paragraph S5.2.2 *Display illumination and operation* states 'If a item of equipment listed in Table 2, Column 1, is provided, the display for such item shall ... illuminate as specified in Column 2, and shall operate as specified in Column 3'.; One of the two equipment items listed in Table 2 is 'Neutra indication'. However, Paragraph S5.2.2 does not require that the item be provided, only that, if a manufacturer provides it, it shall be a green display lamp and it shall illuminate when the gear selector is in the neutral position.; You are right that this interpretation is at variance with the preambl statement that 'Illumination of the neutral position has been deemed essential'. We are considering whether rulemaking action should be taken on this subject.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4688OpenMr. Donald W. Vierimaa Vice President-Engineering Truck Trailer Manufacturers Association 1020 Princess Street Alexandria, Virginia 22314; Mr. Donald W. Vierimaa Vice President-Engineering Truck Trailer Manufacturers Association 1020 Princess Street Alexandria Virginia 22314; "Dear Mr. Vierimaa: This is in response to your association's reques that this office review the most recent revision of the Truck Trailer Manufacturers Association's (TTMA) Recommended Practice Number 56, 'Trailer Vehicle Identification Number.' After that review, we have the following comments. Please note, however, that these comments do not constitute any sort of NHTSA approval or endorsement of the TTMA's Recommended Practice. The TTMA Recommended Practice appears to provide correct information about NHTSA's vehicle identification number (VIN) requirements, as set forth in 49 CFR Part 565, Vehicle Identification Number-Content Requirements and Standard No. 115, Vehicle Identification Number-Basic Requirements (49 CFR 571.115). However, in several instances, the Recommended Practice goes beyond what is required by NHTSA's VIN regulations to recommend one particular means be used to assign a section of the VIN, when NHTSA's regulations leave the assignment of that section to the discretion of the vehicle manufacturer. Examples of the TTMA recommendations going beyond the NHTSA regulations may be found in the explanations provided in Part 13.0 on the Vehicle Descriptor (Second) Section Code, Part 14.0 Check Digit (Third) Section Code, and Part 15.0 Vehicle Indicator (Fourth) Section Code. While TTMA is free to make these recommendations, it may be helpful for your members to recognize the distinction between VIN information that is required by NHTSA, and therefore must follow an exact format according to Federal law, as opposed to matters that are within the discretion of the assigner of the VIN, and for which the TTMA provides one suggested means by which the requirement(s) may be fulfilled. We offer the following comments on particular sections of this recommended practice: Part 6.0 Definitions The definitions of 'body type,' 'line,' 'make,' and 'series' are not identical to the definitions in Title 49 CFR Part 565. In addition, since this section of your recommended practice states that the definitions in Part 6 'are used in NHTSA regulations,' you may wish to note that NHTSA does not define the terms 'production sequence,' and 'type of trailer' in its regulations. Part 9.1 Location This part should note that 49 CFR Part 567.4(d) requires certification labels (which must include VINs) to be affixed 'to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.' Part 11.0 VIN Content You may wish to note that the content requirements in this part of the recommended practice are a paraphrase and explanation of NHTSA's VIN content requirements, set forth at 49 CFR Part 565 Vehicle Identification Number-Content Requirements. 16.0 References Please note that the National Highway Traffic Safety Administration has issued a VIN system information bulletin dated July 1985. I am enclosing a copy of it. Please feel free to reproduce this information and provide it to your members. They may also receive it directly from NHTSA by writing to us. If there are any further questions or concerns, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure"; |
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ID: aiam4722OpenMr. J. Douglas Smith Engineering Manager Duralite Truck Body and Container Corp. 1300 Bush Street Baltimore, MD 21230; Mr. J. Douglas Smith Engineering Manager Duralite Truck Body and Container Corp. 1300 Bush Street Baltimore MD 21230; Dear Mr. Smith: This is in reply to your letter to Taylor Vinson o this Office. I regret the delay in responding. You have asked for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of clearance lamps. You stated your understanding that 'if a chassis cab is equipped with clearance and marker lamps, it is not necessary to add a second set of two lamps to act as clearance lamps to the front wall of the truck body.' This is not correct. A chassis cab is an incomplete motor vehicle, and not required to comply with Standard No. 108. However, when the chassis cab is completed, the completed vehicle must comply, and be certified by its final-stage manufacturer as complying, with Standard No. 108 (and all other applicable Federal motor vehicle safety standards). Standard No. 108, in pertinent part, requires front clearance lamps to be mounted to indicate the overall width of the vehicle, and as near the top as practicable. This means that if clearance lamps have been mounted on the chassis cab, and if in that location they do not indicate the overall width of the completed motor vehicle and are not as near the top of the completed motor vehicle as practicable, the final stage manufacturer must add a set of clearance lamps to the front of the truck body to meet that requirement. In this event, the cab-mounted clearance lamps may be disconnected or removed. However, this is not true with respect to the mounting of identification lamps on chassis cabs. Standard No. 108 allows them to be mounted as close as practicable to the top of the cab as an alternative to the top of the vehicle. Further, on truck tractors, clearance lamps mounted on the cab may be located to indicate the width of the cab rather than the overall width of the vehicle. I hope this has answered your question. Sincerely, Stephen P. Wood Acting Chief Counsel /; |
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ID: aiam1520OpenMr. C. J. Kidwell, American Safety Equipment Corp., 16055 Ventura Boulevard, Encino, CA 91316; Mr. C. J. Kidwell American Safety Equipment Corp. 16055 Ventura Boulevard Encino CA 91316; Dear Mr. Kidwell: This is in reply to your letter of May 29, 1974, concerning th labeling requirements of Standard No. 218, *Motorcycle Helmets*. You ask for our 'review, comments, interpretation, recommendations, and opinions' on two test reports you had done with respect to the placement of the DOT symbol and its attachment on helmets manufactured to the standard's requirements.; The National Highway Traffic Safety Administration does not provid approval of any item of motor vehicle equipment as conforming to any motor vehicle safety standard. Each item is required to conform, and each manufacturer must determine, by methods within his discretion, whether his product conforms to a standard. With respect to the method of affixing the DOT label to the helmet, any methods that are reasonably designed to provide a label that is clearly legible for the expected life of the helmet would be satisfactory.; We would like to point out, however, that from the photograph an drawings you enclosed, it appears that the DOT symbol on your helmet is partially obscured by a goggle snap and its related material. We do not consider this obscuring of the DOT symbol to conform to the intent of the standard. Accordingly, we recommend that you either reduce the length of the snap and its related material or raise the symbol to attain complete visibility.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5563OpenK. Olsen 8577 South State Spanish Fork, UT 84660; K. Olsen 8577 South State Spanish Fork UT 84660; "Dear Ms. Olsen: This responds to your letter of March 12, 1995 requesting an opinion as to the liability of the manufacturer, dealer, or customer in an accident involving a trailer originally sold with used tires. I apologize for the delay in our response. By way of background information, Chapter 301 of Title 49, U.S. Code, authorizes this agency to issue Federal motor vehicle safety standards (FMVSS) applicable to new motor vehicles and new items of motor vehicle equipment. Section 30112 of Title 49 provides that no person may manufacture for sale, sell, or import a new motor vehicle or a new item of motor vehicle equipment unless that vehicle or equipment complies with all applicable FMVSSs and is covered by a certification of such compliance. Generally speaking, upon the sale of that vehicle or item of equipment to the first retail purchaser, the use of that vehicle or equipment becomes a matter of state regulation. This office cannot give you an opinion as to who may be liable in the accident you described. The question of liability would be a matter of state law. You may wish to consult with a local attorney on the question of liability. I can advise you that FMVSS No. 120, Tire selection and rims for motor vehicles other than passenger cars, generally requires tires installed on new trailers to be new, but includes certain specified exceptions which do not appear to be relevant here. In that connection, please find enclosed a copy of a letter we wrote to a gentleman in Odessa, Texas, dated September 4, 1992, which discusses in some detail our requirements for tires installed on new trailers. This agency does not have any standards for trailer brakes other than air brakes. Also, as indicated above, matters relating to the use of a vehicle, such as connection of the electric brake control to the towing vehicle and loading of the trailer, are not under the jurisdiction of this agency. I hope this information is helpful to you. Based on your March 12, 1995 letter and your telephone and facsimile communications with the staff of this agency's Office of Vehicle Safety Compliance, that office has initiated an inquiry to the trailer manufacturer to determine if a noncompliance exists with FMVSS No. 120. If you have further information or data to offer in this regard, please contact Mr. Luke Loy at this address or at (202) 366-5288 or by FAX at (202) 366-3081. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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ID: aiam0761OpenMr. J. Donald Waldman, P.E., President, Resources Applications, Designs & Controls, Inc., 7045 Marcelle Street, Paramount, CA, 90723; Mr. J. Donald Waldman P.E. President Resources Applications Designs & Controls Inc. 7045 Marcelle Street Paramount CA 90723; Dear Mr. Waldman: This is in reply to your letter of June 13, 1972, concerning th application of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials,' to recreational vehicles. You ask, under paragraph S4.1 of the standard, whether materials not designed to absorb energy on contact by occupants must conform to the standard, and list materials and components which you believe might be within this classification.; Except in the case of the components specifically enumerated in S4.1 components that are designed not to absorb energy on contact by occupants are not subject to the standard. Enumerated components must conform to the standard regardless of whether they are energy-absorbing.; With respect to the materials which you list, whether or not they mus meet the standard depends upon whether they are used in the manufacture of any of the components listed in S4.1, either as surface materials, underlying materials, or padding and cushioning materials. In some cases, consequently, insulating materials such as those you list could fall within the materials that should be tested. In each case the manufacturer must determine whether the material is part of the listed component.; With reference to the components you list, open cabinets and cabine tops would be considered under S4.1 to be compartment shelves and toilets would be considered to be seat backs and seat cushions. Walls would be classified as trim panels. Lavoratories and shower doors are not within the enumerated components.; You also ask, in the case of unitized walls having a depth of 2 inche or more, whether the test should be limited to a section 1/2 inch thick. The thickness of the tested sample depends upon the portion of the component which is tested pursuant to paragraphs S4.2(a), S4.2(b), and S4.2(c). In each case, the portion of the material that is tested is cut to a 1/2 inch thickness when the portion of the material as it appears in the vehicle exceeds that thickness (S5.2.1).; Yours truly, Richard B. Dyson, Assistant 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.