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: aiam1436OpenMr. E. T. Linkous, Western Auto Associate Store, Kenale Shopping Cener(sic), Sanford, North Carolina 27330; Mr. E. T. Linkous Western Auto Associate Store Kenale Shopping Cener(sic) Sanford North Carolina 27330; Dear Mr. Linkous: This responds to your request for information on Standard 119, *Ne pneumatic tires for vehicles other than passenger cars,* and on a 'Petition No.2' concerning exemption of 'Mopeds' from the motor cycle regulatory category.; Standard 119 applies to tires, not vehicles, and therefore it regulate only the manufacturer of the tire, not a retailer of vehicles like yourself.; The 'Petition No. 2' to which you refer was files by Mr. Robert Smit of Ohio Bikes, 631 Broad Street, Columbus, Ohio 43215, asking for a redefinition of 'motorcycle' to exclude Moped-type vehicles, and a change in the lighting standard to exclude Moped-type vehicles from he present motorcycle requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4634OpenMr. John Schroeter August Industries 26717 216th Av., S.E. Maple Valley, WA 98038; Mr. John Schroeter August Industries 26717 216th Av. S.E. Maple Valley WA 98038; "Dear Mr. Schroeter: This responds to your letter asking fo information about the application of Federal safety standards to a head restraint that attaches to the rear window of pickup trucks. I regret the delay in responding. I hope the following information is helpful. By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA is not authorized to certify or approve motor vehicles or motor vehicle equipment for compliance with our Federal motor vehicle safety standards. Instead, under the National Traffic and Motor Vehicle Safety Act (copy enclosed), each manufacturer of a motor vehicle or item of motor vehicle equipment is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the information provided in your letter. There is currently no Federal motor vehicle safety standard that is directly applicable to the product you wish to manufacture and sell. Our standard for head restraints (Standard No. 202) applies only to completed new passenger cars and not to a head restraint device sold as an item of 'aftermarket' equipment for pickup trucks. However, there are other Federal laws that indirectly affect your manufacture and sale of the head restraint device. Under the Safety Act, your device is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall and remedy of products with defects relating to motor vehicle safety. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your head restraints contain a safety related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Safety Standard No. 302, Flammability of Interior Materials (copy enclosed), would also affect your head restraint if your product is installed by a commercial business on either new or used vehicles. A manufacturer installing your head restraint device on a new truck prior to certifying the truck as complying with all applicable Federal motor vehicle safety standards, as required by the Safety Act, has certain responsibilities relating to that obligation to certify. Standard No. 302 establishes flammability resistance requirements for trucks that must be met by certain vehicle components, including head restraints. The new vehicle manufacturer that installs your product on the new vehicle would have to certify the vehicle's compliance with Standard No. 302, and thus would be required to ensure that the head restraint device conforms to the flammability resistance requirements of the standard. A commercial business that installs the head restraint on new or used vehicles would be subject to statutory considerations that affect whether the business may install your product on a vehicle without violating the Safety Act. Section 108(a)(2)(A) of the Act 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 ...' This section requires manufacturers, distributors, dealers or motor vehicle repair businesses (i.e., any person holding him or herself out to the public as in the business of repairing motor vehicles or motor vehicle equipment for compensation) installing your head restraint device on new or used vehicles to ensure that the addition of the apparatus would not negatively affect the compliance of any component or design on a vehicle with applicable Federal safety standards. For example, the commercial entity must ensure that the addition of the device does not degrade from the safety provided by flammable-resistant materials in the vehicle's interior compartment which have been installed in accordance with Standard No. 302. Installation of rapidly burning materials could vitiate the compliance of the materials which were present in the vehicle at the time of its sale to the first consumer and were certified as meeting FMVSS No. 302. Section 109 of the Act specifies a civil penalty of up to $1,000 for each violation of /108. However, the prohibitions of /108(a)(2)(A) do not apply to the actions of a vehicle owner in adding to or otherwise modifying his or her vehicle. Thus, a vehicle owner would not violate the Safety Act by installing the head restraint, even if doing so would negatively affect some safety feature in his or her vehicle. In addition to the materials described above, I am also enclosing a Federal Register notice (53 FR 50047) that NHTSA issued on December 13, 1988, proposing to extend the applicability of Standard No. 202 to light trucks and vans. NHTSA has proposed to make this extension effective September 1, 1991. We expect to announce the agency's next step in the rulemaking proceeding by this fall. Please feel free to contact us if you have further questions. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosures"; |
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ID: aiam1066OpenMrs. Lewis Cook, Young Windows, Inc., Brook and Colwell Roads, Conshohocken, PA 19428; Mrs. Lewis Cook Young Windows Inc. Brook and Colwell Roads Conshohocken PA 19428; Dear Mrs. Cook: This is in reply to your letter of February 20, 1973, requestin clarification of the certification and labeling requirements of Motor Vehicle Safety Standard No. 205, 'Glazing Materials', for persons who cut sections of glazing materials. You state your understanding is that such persons should add to the cut piece the DOT symbol and the manufacturer's code mark used on the larger piece from which the smaller piece was cut. Your understanding of these requirements is not correct. The labeling requirements of Standard No. 205 were most recently amended on November 11, 1972 (37 FR 24035, copy enclosed). These amendments become effective April 1, 1973. They require a person who cuts glazing material to mark it in accordance with section 6 of ANS Z26. This does *not* include the DOT symbol and the mark of the manufacturer of the larger sheet, and these items should *not* be included by persons who only cut the material. That person must also certify the material in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act (15 USC 1403). One method by which this can be done is to affix a removable label to the glazing material which states that it conforms to the Federal safety standard.; You ask how the 'AS12' and 'AS13' marking should be affixed. The 'AS designation is part of the labeling required by section 6 of ANS Z26, and it should be applied in the manner that the other labeling items of that section are applied. We understand etching is the method ordinarily used, and it is appropriate.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4264OpenMr. Allen R. Tank, President, Minikin, 606 NE Lincoln Avenue, St. Cloud, MN 56301; Mr. Allen R. Tank President Minikin 606 NE Lincoln Avenue St. Cloud MN 56301; Dear Mr. Tank: This is in reply to your letter of December 29, 1986, with respect t the definition of 'motorcycle' for purposes of compliance with the Federal motor vehicle safety standards. You have asked whether a vehicle with two wheels at the front, and one at the rear with two tires mounted on it, would still be regarded as a motorcycle.; The definition of a motorcycle is 'a motor vehicle with motive powe having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.' This is techically (sic) inaccurate in part because wheels do not contact the ground. I believe that the drafter of the definition meant to say 'tires' rather than 'wheels.' Thus the configuration about which you have asked is one in which four tires contact the ground, and we therefore conclude that such a vehicle would not be regarded as a motorcycle.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0227OpenMr. J. C. Eckhold, Ford Motor Company, The American Road, Dearborn, MI 48121; Mr. J. C. Eckhold Ford Motor Company The American Road Dearborn MI 48121; This is in reply to your letter of March 19, 1970 with which yo submitted for our examination a sample format for consumer information produced by a computer.; The sample that you submitted does deviate from the requirements of th consumer information regulations in that the required warnings and explanations are placed on a sheet that is separate from the numerical data. The regulations generally require that the information be presented in the form illustrated by the published figures, with the explanatory matter in proximity to the numerical data. I believe that computer printing is flexible enough to allow you to accomplish this.; Sincerely, Douglas W. Toms, Director |
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ID: aiam5025OpenMr. Peter K. Brown President, KC HiLites, Inc. Avenida de Luces Williams, AZ 86046-0155; Mr. Peter K. Brown President KC HiLites Inc. Avenida de Luces Williams AZ 86046-0155; Dear Mr. Brown: This responds to your letter of May 6, 1992, wit respect to your 'quad beam' product. You point out that, in normal operation, the headlamp lower beam is extinguished when the upper beam is activated, 'quad beam' ensures that the lower beam remains activated when the upper beam is used. We advised you on July 2, 1990, that installation of 'quad beam' would be acceptable on certain types of four-lamp headlighting systems. You have now asked whether the device can 'legally be used on two headlamp systems, either sealed beam or replaceable bulb type?' Paragraph S5.5.9 of Federal Motor Vehicle Safety Standard No. 108 states that ' except for certain four-lamp systems enumerated in S5.5.8 the wiring harness or connector assembly of each headlamp system shall be designed so that only those light sources intended for meeting lower beam photometrics are energized when the beam selector switch is in the lower beam position, and that only those light sources intended for meeting upper beam photometrics are energized when the beam selector switch is in the upper beam position.' This would preclude installation of the 'quad beam' on two lamp headlamp systems. Sincerely, Paul Jackson Rice Chief Counsel; |
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ID: aiam1965OpenMr. Heinz Gerth, Assistant Vice President, Engineering, Mercedes-Benz of North America, Inc., P.O. Box 350, Montvale, NJ 07645; Mr. Heinz Gerth Assistant Vice President Engineering Mercedes-Benz of North America Inc. P.O. Box 350 Montvale NJ 07645; Dear Mr. Gerth: This is in response to your letter of May 5, 1975, asking at what poin the test voltage may be measured during testing for compliance with the Standard No. 103, *Windshield Defogging and Defrosting Systems*, requirement that the blower motor test voltage be 15% over nominal system rating at the blower motor or the supply end of the motor dropping resistor. Your question relates to the meaning of 'the supply end of the motor dropping resistor.'; Measurement of the blower motor test voltage should occur at the suppl side of the motor where there is no resistor. Where the system contains a resistor, the voltage should be measured at the supply side of the resistor, not between the resistor and the motor. The reason for this is that the test voltage level specified in the standard is intended to relate only to the voltage as it is fed into the defrosting and defogging system. The purpose of the voltage level specification is to assure a system capability to handle voltage levels that will normally be encountered during operation of the defroster and defogger. This can be accomplished by measurement of the voltage before the current reaches the resistor.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam3958OpenMr. James H. Westlake, Associate Director, American Truck Dealers Division, National Automobile Dealers Association, 8400 Westpark Drive, McLean, VA 22102; Mr. James H. Westlake Associate Director American Truck Dealers Division National Automobile Dealers Association 8400 Westpark Drive McLean VA 22102; Dear Mr. Westlake: This is in reply to your letter of February 25, 1985, to Mr. Stephe Wood of this office asking the following three questions about rebuilding and remanufacturing heavy duty trucks.; >>>'1) When rebuilding a used truck with a glider kit, it is ou understanding that the process is considered 'rebuilding' when the three major components (engine, transmission and rear axle) are reused in the rebuilding process. If one or more of these major components is new, does the production of the truck chassis change its legal character from 'rebuilding' to 'first stage manufacturer'?'<<<; Neither the National Traffic and Motor Vehicle Safety Act ('the Act' nor the Federal Motor Vehicle Safety Standard ('safety standards') contain the terms 'rebuilding' and 'first stage manufacturer'. Your question, however, is clear: when new and used components are used in rebuilding a heavy truck, at what point does the truck become a 'new' vehicle which must comply with all safety standards that apply to trucks.; The agency's regulation on *Combining new and used components*, 49 CF 571.7(e), provides:; >>>'When a new cab is used in the assembly of a truck, the truck wil be considered newly manufactured for purposes of compliance with the safety standards and other provisions of the Act unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components were taken from the same vehicle'.<<<; Thus, in terms of your question, if the three major components ar reused in the rebuilding process and at least two of the three came from the same vehicle, the Federal motor vehicle safety standards do not apply even if a new cab is used. But if one of the three components is new, or if all are used and came from three different motor vehicles, then the standards apply and the truck must meet them, and be certified as meeting them, upon final assembly.; Your reference to 'first stage manufacturer' implies that there may b rebuilding fact situations in which the process is completed by a person other than the manufacturer who initiated it. If the rebuilt truck is 'new', then its assemblers are subject to 49 CFR Part 568 *Vehicle (sic) Manufactured in Two or More Stages*. If the truck meets the definition of 'incomplete vehicle', then the 'incomplete vehicle manufacturer' is required to furnish the specified compliance information necessary for certification to the 'intermediate stage manufacturer' or the 'final stage manufacturer' as the case may be (sec. 568.3).; >>>'2) When a truck chassis is built by a dealer and legally classifie as 'new manufacturing' what federal regulations must be complied with that do not apply when the vehicle is considered rebuilt?'<<<; As indicated above, the truck must be completed to comply with al safety standards that apply to trucks and be certified by its assembler as so conforming in accordance with Part 567 *Certification*. If more than one party is involved in the remanufacturing process, each party is subject to Part 568. In addition, any party remanufacturing a truck that must be certified as conforming is required to file a statement in the form prescribed by Part 566 *Manufacturer Identification*.; >>>'3) What penalties exist for failing to comply with these Federa regulations?'<<<; As provided by section 109(a) of the act, any person violating an provision of the Act or a regulation issued thereunder is subject to a civil penalty of up to $1000 for each violation, up to $800,000 for any related series of violations. In addition, under Section 110(a) of the Act, the agency may seek to restrain the manufacture, sale, offer for sale, introduction, or delivery for introduction into interstate commerce of any rebuilt truck that should have met Federal motor vehicle safety standards but in fact did not do so. Also, section 154 of the Act requires manufacturers to conduct recall campaigns and remedy any non-compliances with applicable safety standards.; I hope this information is helpful. Sincerely, Jeffrey R. Miller, Chief Counsel |
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ID: aiam0677OpenMr. W.W. Marsh, Executive Vice President, National Tire Dealers & Retreaders Association, Inc., 1343 L Street, N.W., Washington, D.C. 20005; Mr. W.W. Marsh Executive Vice President National Tire Dealers & Retreaders Association Inc. 1343 L Street N.W. Washington D.C. 20005; Dear Mr. Marsh: This is in reply to your letter of April 5, 1972, concerning th amendment to Motor Vehicle Safety Standard No. 117, published March 23, 1972 (Docket 1-8, Notice 7,37 F.R. 5950). In your letter you protest against the labeling requirements of the standard. It is not clear from your letter, however, whether you are referring to both the requirements for affixed labels (S6.3.1), or for permanent labeling (S6.3.2), or both, and as a consequence we have treated your comments as referring to the labeling requirements in general.; You state in your letter that retreaders, particularly smal retreaders, cannot meet the labeling requirements 'on any reasonable and practical basis.' You state further that you have demonstrated haw the labeling requirements will force retreaders to hire additional personnel, increase production time, and consequently increase the retreaders' cost per tire. You also claim that the labeling issue is a 'fairly simple problem' whose solution can be easily found within the statutes.; Congress, in enacting section 201 of the National Traffic and Moto Vehicle Safety Act, made it clear that motor vehicle tires should be permanently labeled with specific items of information dealing with their safe use. The labeling requirements of Standard No. 117 are based on this statutory mandate and do recognize and allow for difficulties retreaders might have in meeting all of the requirements for labeling set forth in section 201. For example, Standard No. 117, in not requiring that the generic name of the cord material or the actual number of plies be included in the labeling information for retreaded tires, recognizes that this information will not be available for some casings which are allowed to be used.; The NHTSA considers the labeling requirements of Standard No. 117 to b both reasonable and practical, and believes they can be met by the overwhelming majority of retreaders, if not all, in an economical manner. Each item of information is now available to the retreader should the need to relabel arise. By using the procedures and technology developed for compliance with the Tire Identification and Recordkeeping regulations (49 CFR Part 574), by combining labeling information on the same label where appropriate, and by careful sorting of casings before retreading, the NHTSA believes that even the smallest retreader can meet these requirements. While the requirements will no doubt cause some changes in existing production techniques, with a possible slowing initially of the production process, there is no reason to believe that these changes, once instituted, will result in significant permanent increases in the costs and time needed for the production of retreaded tires.; Finally, you cite figures showing what you claim is an abnormally hig number of retreaded tire manufacturers who have gone out of business in the past year, and ask, 'How many more will be lost before we get reasonable and practical and understandable regulations?' We understand your concern for retreading companies that have gone out of business. But since Standard No. 117 has not yet become effective, these closings are obviously not the result of NHTSA regulations.; Sincerely, Douglas W. Toms, Administrator |
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ID: aiam5475OpenMr. Gerard Bonvin Auto Cheyenne USA Inc. 6611 1/2 West 6th Street Los Angeles, CA 90036; Mr. Gerard Bonvin Auto Cheyenne USA Inc. 6611 1/2 West 6th Street Los Angeles CA 90036; "Dear Mr. Bonvin: This is in reply to your letter of December 15, 1994 with respect to the relationship of certain DOT regulations to the Cheyenne, a small front-wheel drive utility vehicle that you wish to import and distribute in the United States. You have asked the following questions: 'What are the procedure to follow in order to be categorize Small Volume manufacturer?' Your question assumes that we have a category of 'small volume manufacturer.' We do not, and there is no exclusion from the Federal motor vehicle safety standards (FMVSS) based upon the volume produced by the manufacturer. All motor vehicles must comply with all FMVSS, unless the agency has exempted them from one or more of the standards. We do recognize limited production volume in the regulation under which a manufacturer who produces less than 10,000 motor vehicles of all types may apply for a temporary exemption on the basis that compliance would cause it substantial economic hardship, and must provide production information as part of its application. 'Is there really a big difference on the test in order to certified between small volume and over 10000 vehicles?' As indicated above, if a manufacturer produces less than 10,000 vehicles, that fact is relevant only if that manufacturer wishes to file a hardship exemption application. If a small volume manufacturer has not been exempted, it must comply with the same requirements as apply to those whose yearly production exceeds 10,000. 'Is there any difference between two seaters or four seaters on crash test?' That is a question to be answered by a vehicle manufacturer. If a four-seater is heavier than a two-seater, the difference in weight could make a difference in whether a vehicle with a borderline design passes or fails a crash test. 'Is there a rear crash impact?' Yes. FMVSS No. 301 Fuel System Integrity specifies a 30 m.p.h. moving barrier rear impact test. 'Do we need Air Bags if we have Seat belts?' Currently, vehicles like the Cheyenne are not required to have air bags. However, as explained below, air bags are one means of complying with a the automatic protection requirement which is being phased in for vehicles like the Cheyenne, and eventually the Cheyenne will be required to have air bags for both the driver and right front passenger. Generally, Jeep-type vehicles are considered to be 'multipurpose passenger vehicles' (MPVs). Based on your description, we also assume that the Cheyenne will have a GVWR of 8,500 pounds or less. A requirement in FMVSS No. 208, Occupant Crash Protection, which is being phased in requires a specified percentage (varying by year) of each manufacturer's light trucks (a category which includes MPVs with a GVWR of 8,500 pounds or less) manufactured on or after September 1, 1994 to be equipped with automatic crash protection. The two types of automatic crash protection currently offered are automatic safety belts and air bags. A recent amendment of FMVSS No. 208 will require at least 80 percent of each manufacturer's light trucks manufactured on or after September 1, 1997 and before September 1, 1998 to be equipped with an air bag and a manual lap/shoulder belt at the driver's and right front passenger's seating positions. All light trucks manufactured on or after September 1, 1998 must be equipped with an air bag and a manual lap/shoulder belt at these seating positions. 'Do we need a buzzer for the seat belt?' Yes, an audible warning indicator is required. 'Is the dashboard need to be padded?' We cannot answer your question. That decision is to be made by the manufacturer if its tests show that the dashboard is within the head impact area and that some type of padding is necessary to meet FMVSS No. 201 Occupant Protection in Interior Impact. The FMVSS are performance standards and we do not impose design restrictions on the manufacturer, such as requiring that the dashboard be padded. 'Is there any specific ways on how to install the windshield?' No, because that would be design restrictive and, as noted above, the FMVSS are performance standards. The performance requirement for windshields is in FMVSS No. 212 Windshield Retention which specifies what the windshield mounting must do in a 30 mph frontal barrier crash. However, if the MPV is an open vehicle with a fold-down windshield, FMVSS No. 212 does not apply to it. 'What is the surface of the windshield that need to wiped? As far as Windshield Wipers, how many cycles and how many different speed?' You will find the answers to your questions in FMVSS No. 104 Windshield Wiping and Washing Systems. For a copy of these and all our regulations, you should have a copy of 'Title 49 Code of Federal Regulations Parts 400-999'. This is available from the U.S. Government Bookstore at ARCO Plaza, C-Level, 505 South Flower Street, Los Angeles. Sincerely, Philip R. Recht 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.