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: aiam2496OpenMr. W. G. Milby, Manager, Engineering Services, Blue Bird Body Company, P. O. Box 937, Fort Valley, GA; Mr. W. G. Milby Manager Engineering Services Blue Bird Body Company P. O. Box 937 Fort Valley GA; Dear Mr. Milby: This responds to Blue Bird Body Company's November 2, 1976, request fo confirmation that head and knee contact areas specified under S5.3.1.3 and S5.3.2.2 of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, may be measured by the use of the direct transfer of a medium (such as spray paint) from the head or knee form to the seating surface with the addition of the area that falls within nonintersecting lines that are tangent to the outer bounds of the areas of direct contact. You also request confirmation that the impact requirements of S5.3.1.2, S5.3.1.3, and S5.3.2.2 may be conducted on seating that is attached to a test fixture instead of being mounted in a bus body. In both cases you suggest rulemaking action to make your recommended procedures a part of the standard.; When a standard does not specify a particular aspect of a requirement such as the means to measure contact area, a manufacturer is entitled to use any reasonable method it chooses to demonstrate, in the exercise of due care, that the regulated vehicle or item of equipment in fact conforms to the requirement. For your information, the agency intends to use a contact medium test similar to the test you describe and will include in its computation of 'contact area' the maximum area that falls within nonintersecting line segments that are tangent to the outer bounds of the areas of direct contact. The outer bounds of direct contact do not include areas that represent splattering of the transfer medium without contact of the nead or knee form.; In response to your second request, Standard No. 222 is a vehicl standard. Therefore, the impact requirements have meaning only as they apply to seating when installed in a vehicle. For this reason the agency intends to conduct its compliance testing with the seating installed in a bus. The agency's contemplated procedure may involve the removal of seating around the seating being tested, and the test device may be mounted to the floor in place of the seating that is removed.; However, the requirementk that the seating conform as it is installe does not prohibit a manufacturer from using a different test procedure from that specified, in view of the NHTSA's expressed position on the legal effect of its regulations. To certify compliance, a manufacturer is free to choose any means, in the exercise of due care, to show that a vehicle (or item of equipment) would comply if tested by the NHTSA as specified in the standard. Thus, the NHTSA test procedures need not be duplicated by each manufacturer or compliance test facility. Blue Bird, for example, is free to conduct its test on a test fixture outside the bus as long as it can certify that its vehicle would comply if tested by the NHTSA according to the standard.; In view of this disposition of your requests, the agency does no intend to undertake modification of Standard No. 222 at this time. The NHTSA will continue to monitor the results of tests conducted to determine compliance with the head and kneeform contact area requirements of the standard and will modify the standard if warranted.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0151OpenMr. 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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ID: aiam2479OpenMr. Eugene C. Kellogg, USM Corporation, P.O. Box 103, Birmingham, MI 48012; Mr. Eugene C. Kellogg USM Corporation P.O. Box 103 Birmingham MI 48012; Dear Mr. Kellogg: This is in response to your letter of December 21, 1976, concerning th effective date of 49 CFR Part 581, *Bumper Standard*.; Part 581 was published on March 4, 1976, pursuant to Title I of th Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). It is scheduled to become effective on September 1, 1978, at which time it will absorb Federal Motor Vehicle Safety Standard No. 215, *Exterior Protection*, the currently effective bumper standard.; There has been no action taken to delay the scheduled implementatio date of the Part 581 bumper standard. If a decision were made to delay the standard's effective date, it would be published in the Federal Register.; National Highway Traffic Safety Administration rulemaking procedure permit the filing of petitions for reconsideration of final rulemaking actions. Such petitions must be filed within 30 days of the date on which the final rule is published and must be either granted or denied by the agency. Petitions for reconsideration of Part 581 were submitted by several manufacturers. The agency is still considering the issues raised in those petitions and has not yet made a decision as to their disposition. The agency response to the petitions for reconsideration will be published in the Federal Register.; Sincerely, John Womack, Assistant Chief Counsel |
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ID: aiam0444OpenMr. Elmore J. Baruth, Bostrom Division of UOP, Director Plastics R/D, 133 West Oregon Street, Milwaukee, WI, 53201; Mr. Elmore J. Baruth Bostrom Division of UOP Director Plastics R/D 133 West Oregon Street Milwaukee WI 53201; Dear Mr. Baruth: This is in reply to your letter of August 30, 1971, to Michael Pesko of my staff, concerning Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'. Your letter asks several questions concerning the applicability of the standard to vehicle seats you manufacture. These questions are dealt with individually below.; You first ask whether Standard No. 302 applies to open air tractors earthmoving equipment, or rapid transit seating, or only to ground transportation wherein the people are enclosed by a cab or housing. As stated in paragraph S3. of the standard, it applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. These terms are defined at 49 CFR S571.3, and a copy of this section is enclosed for your information. The vehicles you mention, *i*.*e*., open air tractors, earthmoving equipment, and rapid transit vehicles are generally not vehicles of these types, but if you wish an opinion as to a particular vehicle, you must submit additional information concerning it to us. The criteria you establish, however, 'ground transportation wherein the people are enclosed by a cab or housing' is not an accurate reflection of the specific vehicle types involved, and should not be used as a guideline.; You state that you understand that 'all covering materials, foams thread, welting, etc. used in the construction of a seat is covered', and you are essentially correct, and proceed to ask several questions based on brochures of your product that you forwarded to us. These questions are answered below.; >>>1. *Adhesives*. Adhesives should be tested as part of adjacen materials whenever possible. Both the standard as issued and the notice of proposed rulemaking published May 26, 1971 (36 F.R. 9565) provide for the testing of composite materials, and adhesives joining materials that are to be tested as composites should be tested as part of the composites.; 2. *Seat composite*. Under the present standard, seat composit components that are welded together only at certain points should be treated as composites at the point of weld, and as separate materials between welds, if they are not otherwise uniformly attached to each other at those points. Under the notice of proposed rulemaking of May 26, 1971, however, this configuration would be considered as comprised only of separate materials.; 3, 4, 5. *Bearings, plastic parts and rubber parts, and shoc absorbers*. Components that comprise the seat track or suspension need not meet the standard's burn- rate requirements. Components that are included, however, that are smaller than the sample size specified in S5.2.1 may be tested using the heat-resistant wires specified in S5.1.3.; 6. *Permalator ties*. You describe 'permalator ties' as small diamete wires spaced parallel at about one inch increments, and tied together with hard twisted paper twine that are encapsulated within the foam. As both the wires and the paper twine are incorporated into the foam they must be tested if the particular foam is included within the portions of components set forth in S4.2. Furthermore, they should be tested as part of the foam.; 7. *Paint and decals*. Paint and decals on steel parts that would no be included under S4.1 need not meet the requirements of the standard. Paint and decals on steel parts that are within S4.1 should be tested as part of the steel parts.; 8. *Chassis lubricant*. Seat chassis lubricant is not within th standard's requirements.; 9. *Welting with and without paper core*. Welting with and withou paper core should be tested as part of the material to which it is attached whether it is either, as you mention, extruded vinyl or generated from the parent material. If necessary, it may be tested using the heat-resistant wires specified in S5.1.3.; 10. *Plywood*. Plywood used in seats in seat backs should be teste similarly to other materials used in the same locations.<<<; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4954OpenMr. Stephen C. Bartch Applications Engineer Quigley Motor Company, Inc. Manchester, PA 17345; Mr. Stephen C. Bartch Applications Engineer Quigley Motor Company Inc. Manchester PA 17345; "Dear Mr. Bartch: This responds to your letter concerning Safet Standard No. 301, Fuel System Integrity. You stated that you propose to convert certain 1992 Ford vans to your 4x4 drive system, however, the fuel tank in the vans interferes with the transfer case placement. You therefore plan to either replace the OEM tank with a smaller one that has identical attachments or modify the OEM tank to eliminate the interference. You requested that we summarize your responsibilities regarding Standard No. 301. I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. Our agency is authorized, under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., Safety Act), to issue safety standards applicable to new motor vehicles and 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 Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meets all applicable safety standards. Under NHTSA's certification regulation (49 CFR Part 567), an alterer is a person who alters previously certified vehicles by means other than the addition, substitution, or removal of readily attachable components, or minor finishing operations, or in such a manner that the vehicle's stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale. The operations you propose to conduct on 1992 Ford vans would make you an alterer, and the operations would affect the compliance of the vehicles with Standard No. 301. An alterer is required to certify that every vehicle it alters continues to comply with all applicable safety standards affected by the alteration. See 49 CFR Part 567.7. Alterers make this certification by affixing a permanent label on the altered vehicle, which identifies the alterer, the date of alteration, and states that, as altered, the vehicle continues to comply with all applicable safety standards. Alterers must have some independent basis for their certification that an altered vehicle continues to comply with all applicable safety standards. This does not necessarily mean that an alterer must conduct crash testing, even with respect to standards, such as Standard No. 301, that specify dynamic test requirements. Certifications of continuing compliance for altered vehicles may be based on, among other things, engineering analyses, computer simulations, actual testing, or instructions for alteration voluntarily provided by the original vehicle manufacturer in a 'body builder's guide.' I have enclosed a pamphlet which provides additional information concerning relevant Federal statutes and this agency's standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers. If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure "; |
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ID: aiam2183OpenMr. Hans Sylven, AB Stil-Industri, Box 70,440 20, Vargarda, Sweden; Mr. Hans Sylven AB Stil-Industri Box 70 440 20 Vargarda Sweden; Dear Mr. Sylven: This responds to Stil-Industri's December 12, 1975, question whethe S5.2(d)(1) of Standard No. 209, *Seat* *Belt* *Assemblies*, specifies, in the case of a push-button release, the location and direction of force application used in testing the release under the requirements of S4.3(d)(1). Section S5.2(d)(1) provides in part:; >>>(1)...The buckle release force shall be measured by applying a forc on the buckle in a manner and direction typical of those which would be employed by a seatbelt occupant. For pushbutton-release buckles, the force shall be applied at least 0.125 inch from the edge of the push- button access opening of the buckle in a direction that produces maximum releasing effect...<<<; The NHTSA interprets these provisions of S5.2(d)(1) to permit th manufacturer to apply force in the direction and location that provides the best possible mechanical advantage relative to the manufacturer's buckle design. The only limitation in the case of a push- button design is that the manufacturer must not apply the force any closer than 0.125 inch from the edge of the push-button access opening.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5646OpenMr. Edward J. Googins Chief of Police City of South Portland 30 Anthoine Street South Portland, ME 04106; Mr. Edward J. Googins Chief of Police City of South Portland 30 Anthoine Street South Portland ME 04106; Dear Chief Googins: This responds to your question whether passenge seat belts must be installed on a 1982 school bus with a gross vehicle weight rating (GVWR) of 20,200 pounds. The answer is no, NHTSA's regulations do not call for the belt systems. In a telephone conversation with Dorothy Nakama of my staff, you stated that the subject of your letter, a 1982 International - Model; S1700 bus with a GVWR of 20,200 pounds, was manufactured as a schoo bus. Federal Motor Vehicle Safety Standard No. 222, School bus passenger seating and crash protection, establishes occupant protection requirements for school bus passenger seating and restraining barriers. Standard No. 222 did not in 1982, and does not now, specify that newly manufactured school buses with a GVWR of 20,200 pounds have passenger seat belt assemblies. Thus, under Standard No. 222, your 1982 school bus need not have seat belt assemblies for passengers. However, please note that the States are free to require seat belts in large school buses used to transport students. Enclosed is a February 14, 1992 letter to Mr. Michael A. Martin of the Maine Bureau of Highway Safety, addressing the relationship between Federal school bus safety standards and state law. Note that on page two, NHTSA explains that a State may require seat belt installation for school buses procured by the State, as long as Federal compartmentalization requirements are not compromised. I hope this information is helpful. If you need any further information, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Samuel J. Dubbin Chief Counsel; |
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ID: aiam2029OpenMr. Mitsuru Masada, Chief of Development & Control Department, Takata Kojyo Co., Ltd., No. 10 Mori Bldg. 28, Sakuragawa-Cho Nishikubo Shiba, Minato-Ku Tokyo, Japan 105; Mr. Mitsuru Masada Chief of Development & Control Department Takata Kojyo Co. Ltd. No. 10 Mori Bldg. 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan 105; Dear Mr. Masada: This responds to Takata Kojyo's July 28, 1975, question whethe Standard No. 208, *Occupant Crash Protection*, or Standard No. 209,; Seat Belt Assemblies*, prohibits on a 'continuous loop' three-poin belt system the use of a clip between the outboard attachment point of the lap belt portion and the sliding buckle tongue which engages the inboard attachment hardware. The clip is used to prevent the sliding buckle tongue from falling to the floor when the belt system is retracted after use.; Standard No. 209 contains no provision which prohibits use of the clip Section S7.1.1 of Standard No. 208 requires adjustment of the lap belt portion of seat belts 'by means of an emergency-locking or automatic-locking retractor.' In continuous loop systems, the single retractor must meet this adjustment requirement as well as that for the upper torso portion. At this time, the NHTSA has interpreted S7.1.1 to permit the use of clips which restrict movement of the webbing, but a proposal is outstanding that would restrict the use of certain clips to seat belt assemblies that have 'an individually adjustable' lap belt. The language of that proposal is intended to strictly limit the use of clips which restrict webbing movement. In any case, Standard No. 208 does not at this time prevent use of the clip you describe.; It is noted that the clip could be misadjusted so that slack i introduced in the lap belt, permitting submarining in the event of a crash. This problem could be avoided by permanently attaching the clip at a low enough position so that the belt would be automatically adjustable even for a 50th percentile 6 year old child without possibility of misadjustment. This permanent location could presumably still be high enough on the belt to provide for convenient stowage of the belt tongue after use.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0014OpenMr. Richard H. Lucki U.S. Factory Representative Peugeot U.S. Technical Research Company 1099 Wall Street West Lyndhurst, NJ 07071; Mr. Richard H. Lucki U.S. Factory Representative Peugeot U.S. Technical Research Company 1099 Wall Street West Lyndhurst NJ 07071; "Dear Mr. Lucki: This responds to your letter requesting a interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked whether a planned gear position display for automatic transmission vehicles would meet the standard's requirement that full gear position information be provided in a single location. As discussed below, the answer to that question is yes. By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment meet applicable standards. The following represents our opinion based on the facts provided in your letter. As you are aware, on March 26, l99l, this agency published in the Federal Register a final rule amending Standard No. l02. Among the amendments is a new S3.l.4.4 that requires, for all automatic transmission vehicles, that full gear position information, i.e., identification of shift level positions, including the position of the gears in relation to each other, and the gear position selected, be displayed 'in view of the driver in a single location.' According to a drawing enclosed with your letter, your planned gear position display would be located on the instrument panel, between the speedometer and tachometer. The current gear position, either P, R, N, D, 3, 2, or l, would be shown in a square, by means of electronic display. The position of the gears in relation to each other, i.e., P R N D 3 2 1, would be marked adjacent to the electronic display. You state that the gear positions in relation to each other will be illuminated when the headlamps are activated. It is our opinion that your planned design would meet S3.l.4.4's requirement that full gear position information be displayed in a single location. The gear position selected would be shown in the square electronic display. The position of the gears in relation to each other would be marked adjacent to the electronic display. Because the marking of the position of the gears in relation to each other would be adjacent to the electronic display, it is our opinion that all of the information would be considered to be provided in a single location. I note that this same issue was addressed in the preamble to the March l99l final rule, in connection with a comment submitted by Chrysler. The agency stated the following: If Chrysler wishes to provide a display of current gear position information on the instrument panel, it is free to do so. Under the amendment, it can either provide full gear position information at that location, e.g., include a 'P R N D L' label adjacent to the display, or it can provide a display of current gear position information only on the instrument panel and include a display of full gear position information elsewhere, e.g., on the floor console. 56 FR l2470, March 26, l99l. Your proposed design is consistent with the first of the two options discussed in that paragraph. I hope this responds satisfactorily to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel"; |
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ID: aiam5216OpenMr. Kenneth E. Ross 752 Hillpine Terrace Atlanta, GA 30306; Mr. Kenneth E. Ross 752 Hillpine Terrace Atlanta GA 30306; "Dear Mr. Ross: This responds to your letter requesting informatio about a product that attaches to an automobile's back window. In a telephone conversation with Marvin Shaw of my staff, you stated that your product is a two to three inch high LED sign that extends along most of the rear window. The sign displays any message that the driver chooses. While we do not have information about State or local laws, I am pleased to have this opportunity to explain the applicability of Federal law on your product. By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the National Traffic and Motor Vehicle Safety Act ('Safety Act') establishes a 'self- certification' process under which each manufacturer is responsible for certifying that its products meet all applicable Federal motor vehicle safety standards (FMVSSs). In response to your question, NHTSA currently has no FMVSSs that directly apply to the product you wish to manufacture. I note, however, that there are other Federal requirements that indirectly affect you and your product. Under the Safety Act, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Automotive accessory equipment that a dealer adds before sale of a vehicle must not create a noncompliance with the FMVSSs to which the vehicle manufacturer has certified compliance. For instance, your LED sign should be mounted so that it does not block the field of view required by FMVSS No. 111, Rearview Mirrors. Similarly, for the vehicle to remain in compliance, your system must not impair the effectiveness of the lighting equipment required by FMVSS No. 108, Lamps, Reflective Devices, and Associated Equipment. In particular, the placement of your sign might impair the effectiveness of the center highmounted stop lamp (CHMSL) if it can be operated simultaneously with the CHMSL or at a time when the turn signals are flashing. In addition, manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 108(a)(2)(A) of the Safety Act, which states: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... any 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 ....' It is conceivable that your product, when placed on a vehicle's rear window, could 'render inoperative' the vehicle's ability to comply with FMVSS No. 108 and FMVSS No. 111. Persons in the aforementioned categories that install your product must ensure that such installation does not render inoperative the safety protection provided by the applicable standards. Specifically, your product should be mounted so that it does not interfere with the CHMSL or turn signal lamps nor block the field-of-view required by FMVSS No. 111. The 'render inoperative' prohibition of 108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your product were placed on a rear window by the vehicle owner, then the render inoperative provision would not apply. Nevertheless, in the interest of safety, you should ensure that your product does not adversely affect a vehicle's rear lamps or rearward visibility. We are unable to advise you as to whether the laws of any State address this topic. You should consult the American Association of Motor Vehicle Administrators for an opinion. Its address is 4600 Wilson Boulevard, Arlington, Va. 22203. I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure"; |
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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.