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: aiam1375OpenMr. Joshua E. Bruner, Rogue Racing, 1858 East 3rd Street, Tempe, AZ 85281; Mr. Joshua E. Bruner Rogue Racing 1858 East 3rd Street Tempe AZ 85281; Dear Mr. Bruner: Dr. Gregory asked me to respond to your January 3, 1974, letter askin whether the National Highway Traffic Safety Administration proposal to modify the definition of Multipurpose Passenger Vehicle would affect importation of The Thing.; The proposed modification would reclassify vehicles like The Thing a passenger vehicles, but it would not prohibit their importation. Volkswagen would have to incorporate several additional safety features in The Thing to meet the higher standards for passenger cars.; We have not made a final decision on the proposed redefinition Volkswagen as the manufacturer of The Thing might be able to give you a better evaluation of The Thing's future than we have at present.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam3348OpenMr. S.A. Spretnjak,Excel Industries, Inc., 1120 North Main Street, Elkhart, Indiana 46514; Mr. S.A. Spretnjak Excel Industries Inc. 1120 North Main Street Elkhart Indiana 46514; Dear Mr. Spretnjak: This responds to your August 15, 1980, letter asking several question about your responsibilities for complying with Federal safety standards. You state that you manufacture a sun roof that can be installed by either an original vehicle manufacturer or a subsequent vehicle alterer.; Before responding to your specific questions, I would like to note tha Federal safety standards apply to different manufacturers depending upon the standard involved. Equipment standards are the responsibility of equipment manufacturers while vehicle standards fall within the responsibilities of a vehicle manufacturer or alterer. For sun roofs, Standard No. 205, *Glazing Materials*, is an equipment standard and might apply to an equipment manufacturer who manufacturers sun roofs if they contain any glazing materials. Some vehicle safety standards might be affected also by the installation of a sun roof. The installer of a sun roof would be entirely responsible for compliance with all of the vehicle safety standards affected by the sun roof installation.; Your first question asks who certifies the sun roof if it is installe as original equipment on a vehicle. The equipment manufacturer who manufacturers the glazing would be responsible for certifying the glazing in accordance with Standard No. 205. The installer of the sun roof, the vehicle manufacturer, would certify the vehicle in compliance with all of the safety standards.; Second, you ask the same question as above with respect to a va conversion or motor home construction. Again, the equipment manufacturer would certify to the glazing standard, and the van converter or motor home builder would certify the vehicle in accordance with Part 567, *Certification*.; Third, you ask who must certify if a dealer adds a sun roof before sal of the vehicle to its first purchaser. The equipment manufacturer certifies to the glazing standard, and the installer of the device would attach an alterer's label to the vehicle in accordance with Part 567.7.; Your fourth question asks who certifies if a body shop adds the su roof for a vehicle owner. As always, the sun roof glazing is certified by the equipment manufacturer. Businesses that modify used vehicles are not required to recertify those vehicles in compliance with any of the safety standards. Such businesses are prohibited from knowingly rendering inoperative any device or element of design installed in a vehicle in compliance with any safety standard.; Fifth, you ask whether as a window manufacturer your onl responsibility is to certify to Standards Nos. 205 and 217. As stated earlier, you would have responsibility to certify to Standard No. 205. However, Standard No. 217 is a vehicle standard, and only a vehicle manufacturer or alterer has responsibility for certifying compliance with that standards.; Your final question asks about testing for compliance with the safet standards. Testing is usually conducted by vehicle manufacturers for those standards that apply to vehicles. For standards that apply only to equipment, the testing is altered and the alterer must attach a label indicating that the vehicle continues to comply with the safety standards, the alterer can certify compliance through any means that, in the exercise of due care, he or she fells is sufficient to assure compliance with the safety standards. Methods available to alterers include: retesting, simulated testing, mathematical modeling, or any other device appropriate for assessing continued compliance with the standards.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4177OpenMr. Larry H. McEntire, Administrator, School Transportation, Florida Department of Education, Tallahassee, FL 32301; Mr. Larry H. McEntire Administrator School Transportation Florida Department of Education Tallahassee FL 32301; Dear Mr. McEntire: I regret the delay in responding to your letter to this office askin whether certain 'mini-vans' designed to carry a maximum of eight persons are classified by NHTSA as 'passenger cars' or 'multipurpose passenger vehicles' (MPV's), for purposes of complying with the Federal motor vehicle safety standards.; I would like to begin by clarifying that the classification of particular vehicle is determined in the first instance by its manufacturer, and not by NHTSA. Under our certification requirements (49 CFR Part 567), manufacturers are required to specify the type of their vehicles in accordance with the definitions set forth in Part 571.3 of our regulations and must certify that their motor vehicles comply with all the motor vehicle safety standards applicable to that type. We define an MPV in Part 571.3 as 'a motor vehicle ... designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.'; Information we have received regarding manufacturer certificatio discloses that manufacturers classify *cargo- carrying* models of the Ford Aerostar, and G.M. Astro and Safari as 'trucks.' A 'truck' is defined in Part 571.3 as 'a motor vehicle...except a trailer, designed primarily for the transportation of property or special purpose equipment.' We understand that *passenger* models of mini-vans designed to carry up to eight passengers utilize the same type of chassis used in truck models. It is likely, therefore, that the passenger model mini-vans you asked about would be classified as MPV's instead of passenger cars. This is verified by the 'MPV' classification given by manufacturers to the Chrysler mini-van and Toyota Van.; On a related matter, you asked for our comments on your Department' recommendation to your school boards that they not condone parents' use of conventional vans (i.e., vans not meeting Federal or State school bus safety regulations) to transport school children to school-related events. Mr. Arnold Spencer of Rockledge, Florida, recently wrote to our office concerning the above recommendation and requested us to explain how our school bus regulations apply to persons owning vans. I have enclosed a copy of our April 25, 1986, response to Mr. Spencer which you might find helpful.; I hope this information is helpful. If you have further questions please feel free to contact us.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam0837OpenMr. W. G. Milby, Project Engineer, Blue Bird Body Company, Fort Valley, GA 31030; Mr. W. G. Milby Project Engineer Blue Bird Body Company Fort Valley GA 31030; Dear Mr. Milby: This is in reply to your letter of August 22, 1972, regarding th applicability of the requirements of S5 and S6 of Motor Vehicle Safety Standard No. 208 to trucks and multipurpose passenger vehicles conforming to S4.3.2 and to buses conforming to S4.4.2 of the standard.; Although sections S6.2 and S6.3 have been amended to refer to bel systems, the reference applies only to vehicles that are required by S4 to meet the injury criteria by use of seat belts. Vehicles manufactured under the options of S4.3.2 and S4.4.2 are not required by the terms of those sections to meet either the occupant crash protection requirements of S5 or the injury criteria of S6. Such vehicles are therefore not affected by the amendments to S6.2 and S6.3, and continue to be exempt from compliance with S5 and S6.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam1725OpenEarl W. Kintner, Esq., Messrs. Arent, Fox, Kintner, Plotkin & Kahn, 1100 Federal Bar Building, 1815 H Street, N.W., Washington, DC 20006; Earl W. Kintner Esq. Messrs. Arent Fox Kintner Plotkin & Kahn 1100 Federal Bar Building 1815 H Street N.W. Washington DC 20006; >>>Re: Petition for Rulemaking - Proposed Amendment of S4.5.6, Federa Motor Vehicle Safety Standard No. 108, As Revised, *October 31, 1970.*<<<; Dear Mr. Kintner: This is in response to the petition for rulemaking of January 1 submitted on behalf of your client, Ideal Corporation, for an amendment of S4.5.6 of Federal Motor Vehicle Safety Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, 35 F.R. 16840.; It is our understanding, based upon the meeting held on February between representatives of your firm, Ideal Corporation, and NHTSA, that your client wishes to continue its established marketing practice of selling variable load flashers in the after market and of advertising these flashers as 'all purpose' flashers. We understand further that variable load flashers frequently are purchased as replacements for fixed load flashers. When a variable load flasher is installed as a replacement for an original equipment fixed load flasher, it does not provide the outage indication required by S4.5.6. Your client therefore questions whether, under these circumstances, it could properly certify compliance with Standard No. 108 when the standard becomes applicable to replacement equipment.; The amendment proposed in the petition would add the following sentenc to S4.5.6:; >>>'Variable load flashers are permitted as replacement equipment b Standard 108 for any vehicle contemplated by Paragraph S2 herein, where such devices shall operate in accordance with Tables I and III, as applicable.'<<<; In our view Standard No. 108 permits your client to continue it practice and to properly certify compliance. S2 states in pertinent part that the standard applies to 'lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies.' This means that equipment must comply with applicable requirements regardless of whether it is used as original or replacement equipment. For example, original and replacement variable load flashers must both meet the appropriate requirements of SAE Standard J590b, 'Automotive Turn Signal Flashers,' October 1965. It is not intended that a variable load flasher used as replacement for a fixed load flasher must provide the outage indication required by S4.5.6 for vehicles originally equipped with a fixed load flasher.; Although there presently is no legal prohibition on the advertising an sale of variable load flashers, we believe that your client should, in the interest of safety, either market variable load flashers only as replacements for like items or call prospective, purchasers' attention to the fact that the flashers do not provide an outage indication. While the owner of a vehicle originally equipped with a fixed load flasher should be free to balance the merits of a fixed load flasher (such as the outage indication) with those of a variable load flasher (such as the continuing flash), he should not be misled as to the characteristics of each type, including the one with which his vehicle was originally equipped.; Please advise us within 10 days of the date of this letter if you wis to pursue this petition further, otherwise we shall consider the petition withdrawn.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel |
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ID: aiam3718OpenMr. Charles Jayne, Tire Manager, J-B Purchasing Corporation, P.O. Box 692, Auburn, NY 13021; Mr. Charles Jayne Tire Manager J-B Purchasing Corporation P.O. Box 692 Auburn NY 13021; Dear Mr. Jayne: This responds to your recent letter asking about the requirements of 4 CFR Part 574, *Tire Identification and Recordkeeping*. You noted that your company currently retreads tires for its own use, and that you soon plan to retread tires for sale to others. You asked if the tires you retread for your own use need to be identified with a tire identification number. The answer is no.; Section 574.5 of the Tire Identification and Recordkeeping regulatio provides, in part, that, 'Each tire retreader, *except tire retreaders who retread tires for their own use*, shall conspicuously label one sidewall of each tire he retreads by permanently molding or branding into or onto the sidewall, ...a tire identification number....' Your question concerns a situation in which a tire retreader retreads some tires for his own use and some tires for sale or lease to others. To answer your question, it is helpful to examine the purpose of the identification requirement.; The purpose of having the tire identification number labeled on th sidewall of retreaded tires is twofold. First, it enables this agency and the user of the retreaded tire to identify the retreader of the tire in the event of some safety problem with the tire. Second, it enables the tire retreader to accurately identify the retreaded tires it may have to recall. In the case of tires offered for sale or use outside your company, it is plain that both these purposes would be served by having the tire identification number on the sidewall. Therefore, Part 574 requires that each such tire have a tire identification number on one sidewall.; However, with respect to tires retreaded for the retreader's own use it is obvious who retreaded the tire, whether or not a tire identification number appears on the sidewall. Hence, the first purpose listed above would not be served by having the tire identification number on the sidewall of these tires. Further, the retreader can inspect all of the retreaded tires it uses to determine if any are subject to its recall, and assure adequate remedy for those which are within the recall, without publicizing the identification numbers of those tires. Thus, the second purpose set forth above also would not be furthered by having the tire identification number on the sidewall of these tires. Please note, however, that any tire not marked with a tire identification number can never legally be sold or otherwise offered for use outside of your company.; Should you have any further questions or need additional informatio about this topic, please contact Steve Kratzke of my staff at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam4527OpenMr. Joseph P. Faia 9703 Lilac Ave. Garfield Heights, OH 44l25; Mr. Joseph P. Faia 9703 Lilac Ave. Garfield Heights OH 44l25; Dear Mr. Faia: This is in reply to your recent undated letter regardin a vehicle lighting accessory for trucks and trailers. It appears from your letter and enclosed diagram that the purpose of the device is to illuminate 'two dimensional displays' on the side or rear of vehicles. A number of such devices would be required, depending on the size of the display to be illuminated. You have not stated the candlepower of the device. Reference is made to a transparent section through which the light is emitted, and to a 'semi-translucent' section which is 'tinted and arranged to function as the running lights commonly seen on trailers.' The color of the light is not specified, but we shall assume that it is amber or red when emitted through the 'semi-translucent' sections, and white when emitted through the transparent sections to illustrate the display. You have asked four questions with regard to this device. The first question is whether it can be used as a 'combination side illumination and marker light.' As a general rule, supplementary lighting devices such as yours are permissible as original equipment if they do not impair the effectiveness of lamps, reflective devices, and associated equipment required by Federal Motor Vehicle Safety Standard No. 108. They are permissible as aftermarket equipment under Federal law if their installation by a person other than the vehicle owner does not 'render inoperative in whole or in part' lighting equipment installed in accordance with Standard No. 108, but their legality is otherwise determined by the laws of the States in which the vehicle is registered and operated. As for whether your device may be used as a combination side illumination and marker light, if you mean as the only side marker lamp, the combination per se is not prohibited by Standard No. 108. However, the side marker lamp in such a combination must comply with photometric, location, color, and other requirements for such lamps, and its effectiveness must not be impaired. One example of impairment would be if the glare from the device's white light masked the conspicuity of the side marker. As a combined device supplementing the required side marker lamp, it is permissible if it does not impair the effectiveness ofthe required side marker. For purposes of this letter and with respect to Standard No. 108 we equate 'impairment of effectiveness' with 'partially inoperative.' Your second question is whether it can be used 'as a backup light and parking light, to be used only in these situations.' It is unclear whether you intend the device to be the backup lamp required by the standard, or one that supplements it. If the former, its use is permissible provided that the backup function meets all requirements of Standard No. 108 that are specified for backup lamps, such as color and photometrics, and provided that the display function does not impair the effectiveness of the backup function. Because the color of light in both functions would be identical, care must be taken to ensure that the backup signal is clearly perceived. If you intend it as a supplementary backup lamp, it is permissible as long as it does not impair the effectiveness of the primary backup lamp. Your term 'parking light' is unclear, because front parking lamps are not required on vehicles whose overall width is 80 inches or more, I assume you mean a lamp on the rear of a vehicle that is not a backup lamp but which can be used to indicate that the vehicle is moving slowly while being parked. The device appears permissible as long as it does not impair the effectiveness of the other lighting equipment on the rear. Your third question is whether the device may be used as a stop lamp, activated only when the brake is applied. Two devices may be used as the original equipment stop lamps, provided all requirements of Standard No. 108 are met and that the display function does not impair the effectiveness of any other lighting equipment. One or more devices could be used as supplementary stop lamps under the same restriction. Your final question is whether it may be used alone as a display light. The answer is yes, subject to the impairment prohibition. The only specifically prohibited use of the lamp is its combination with a clearance lamp, a configuration which appears depicted by the uppermost lights, front and rear, of your Figures 2 and 3. I hope that this answers your question. Sincerely, Erika Z. Jones Chief Counsel; |
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ID: aiam2559OpenMr. Stuart A. Mossman, President, Onics Holding, Inc., 1315 Commerce Center, 129 West Trade Street, Charlotte, North Carolina 28230; Mr. Stuart A. Mossman President Onics Holding Inc. 1315 Commerce Center 129 West Trade Street Charlotte North Carolina 28230; Dear Mr. Mossman: This responds to your March 29, 1977, letter asking whether severa vehicles that you describe would be considered 'vehicles other than passenger cars' for purposes of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; Vehicles other than passenger cars includes: multipurpose passenge vehicles, trucks, buses, motorcycles, and trailers, all of which are defined in the Code of Federal Regulations, Title 49, Part 571.3. Since the vehicles you describe appear to fall within the definition of multipurpose passenger vehicle or truck, they are considered 'vehicles other than passenger cars.' Accordingly, they must comply with the rim marking requirements of Standard No. 120.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0564OpenDavid J. Humphreys, Esq., RVI Washington Counsel, Recreational Vehicle Institute, Inc., Suite 406, 1140 Connecticut Avenue, Washington, DC 20006; David J. Humphreys Esq. RVI Washington Counsel Recreational Vehicle Institute Inc. Suite 406 1140 Connecticut Avenue Washington DC 20006; Dear Mr. Humphreys: This is in reply to your letter of November 29, 1971, requesting ou concurrence on three opinions you have furnished to the Recreational Vehicle Institute concerning the application of Part 567, 'Certification,' and Part 568, 'Vehicles Manufactured in Two or More Stages,' to certain recreational vehicles. The opinions, each the subject of a separate letter from you to Mr. Phillip N. Shrake of RVI, are discussed separately below:; >>>1. Your first letter, dated November 18, 1971, concerns th possibility that travel trailers may be 'vehicles manufactured in two or more stages,' and subject to Part 568 and the appropriate sections of Part 567, if an 'assemblage' is purchased from a supplier for completion, as opposed to when only individual component parts are purchased. This interpretation is correct. Travel trailers, like other vehicles, would be vehicles manufactured in two or more stages, if an assemblage consisting of at least the components specified in the definition of 'incomplete vehicle' (S568.3) is delivered to another person for completion. In addition, each of the first three 'consequences' listed on pages 2 and 3 of your letter are essentially correct. With respect to consequence number 4, the party against whom the NHTSA would proceed should a defect be discovered in a vehicle manufactured in two or more stages would depend upon which manufacturer was responsible for the defect. In most situations, however, it is the final-stage manufacturer who would be contacted first, as this would be necessary to determine whether the defect resulted from his activities or the activities of the incomplete vehicle manufacturer.; 2. Your second letter, dated November 22, 1971, takes the position tha Part 568 applies to the situation where a completed panel or automobile type truck is modified into a motor home. This analysis is incorrect. The definition of incomplete vehicle in Part 568 (S568.3) specifies that such a vehicle 'requires further manufacturing . . . to become a completed vehicle. This is not the same as modifying one completed vehicle into another, the case you describe. In such a situation the issue is only whether sufficient modifications are made to the original truck to consider the one who modifies it a manufacturer in his own right. As the type of vehicle is being changed, as you state, from a truck to a multipurpose passenger vehicle, this question would most likely be answered in the affirmative. In such a case, the manufacturer of the motor home bears full responsibility for compliance with all applicable standards, and stands in the same relationship to the truck manufacturer as all vehicle manufacturers stand to their suppliers when components that must meet standards are involved. The burden would be on the modifying manufacturer to show that his modification did not affect the base vehicle's compliance with a standards, if a nonconformity were discovered. The same reasoning would apply in determining responsibility for safety related defects.; 3. Your third letter of November 29, 1971, discusses two issues. Th first is whether GVWR for trailers should include weight specified for each designated seating position. Based on the definitions of 'designated seating capacity' and 'designated seating position' in 49 CFR 571.3 you conclude that as State laws generally provide that occupants cannot ride in a trailer, the GVWR should not include a figure for each designated seating position. You amplify this with regard to fifth-wheel trailers, stating that if any State allows persons to ride in such trailers, then the appropriate weight for each designated seating position should be included.<<<; Whether or not a trailer has 'designated seating position' depends upo the manufacturer's intention in designating the trailer. If a manufacturer does not include designated seating positions, whether or not due to State law, then such weights need not be included in the gross vehicle weight rating.; Your second question is whether the hitch or tongue weight is to b included in establishing GVWR. This question was answered in our letter of January 4, 1972.; Finally, with reference to inclusion of specific fluids in determinin various weights, those fluids such as water, etc., used in recreational vehicles for purposes other than vehicle operation are considered to be cargo.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4874OpenMr. Keith Salsman 1296 Carman Court Conyers, Ga. 30208; Mr. Keith Salsman 1296 Carman Court Conyers Ga. 30208; Dear Mr. Salsman: This responds to your letter of April 16, l99l asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it relates to the 'Braking Intensity Array' that you have invented. The device is an array of nine rear lamps which include a high mounted stop lamp. The center lamp responds to pressure on the brake pedal. If 'actual braking' occurs, then the lamps adjacent to the center lamp 'will respond appropriately with the adjacent lights lighting under mild braking force', and the remaining pairs of lamps lighting as the braking force increases. You have assured us that the center lamp meets all requirements of Standard No. 108, and that the remaining lamps in the array are controlled by a separate device and will not operate independently. As we see it, the acceptability of your invention under Standard No. 108 is not dependent upon any of the five sections of the standard that you quote. The four pairs of lamps that flank the designed-to-conform center stop lamp are 'additional lamps' within the meaning of S5.1.3, which prohibits the installation of any additional lamp as original equipment if it 'impairs the effectiveness of lighting equipment required by' Standard No. 108. Whether impairment exists is a determination to be made by the person installing the lamp as original equipment, either the manufacturer or the dealer prior to the vehicle's first sale. In this instance, it does not appear to us from your description of the array that it would impair the effectiveness of the center lamp or other stop lamps on a vehicle. We would be concerned if the size of the array is such that the interior rear view mirror could not meet the field of view requirements of Standard No. lll Rearview Mirrors, however, if the field of view is not met, the standard allows, as an alternative, the installation of an exterior rear view mirror on the passenger side. Although your array may be permissible under Federal law, it remains subject to regulation by the individual States in which it is used. We are unable to advise you on State laws and suggest you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Paul Jackson Rice 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.