NHTSA Interpretation File Search
Overview
Understanding NHTSA’s Online Interpretation Files
- 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
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.”
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NHTSA's Interpretation Files Search
Interpretations | Date |
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ID: aiam0610OpenMr. W. Dershko, Engineering Manager, Motor Coach Industries, Inc., Pembina, ND 58271; Mr. W. Dershko Engineering Manager Motor Coach Industries Inc. Pembina ND 58271; Dear Mr. Dershko: This is in reply to your letter of February 7, 1972, to Mr. Lewis Owe of this Office concerning clarification of the requirements of paragraph S4.7 of Standard No. 108.; A label similar to that shown on the enclosure to your letter woul meet the certification requirements of paragraph S4.7.2 of Standard No. 108 as specified in the amendment published in the *Federal Register* on January 12, 1972, (copy enclosed).; 'Associated equipment' covered by Standard No. 108 includes only tha for which requirements are specified in the Standard. The only serviceable item, in addition to the completed assemblies, for which certification is required is a plastic part such as a lens, which must meet the requirements of paragraph S4.1.2.; The requirement for replacement equipment to conform to Standard No 108 was applicable to items manufactured on and after January 1, 1972. Certification of items received by your Service Parts Department after January 1, 1972, is therefore acceptable.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs; |
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ID: aiam1902OpenMr. William J. Moede, Olson Trailer & Body Builders Co.,2740 S. Ashland, P.O. Box 2445, Green Bay, WI 54306; Mr. William J. Moede Olson Trailer & Body Builders Co. 2740 S. Ashland P.O. Box 2445 Green Bay WI 54306; Dear Mr. Moede: This responds to your April 7, 1975, questions whether the Olso two-axle, three-axle, and four-axle 'land-hog' trailers would qualify for exclusion from Standard No. 121, *Air brake systems*, until September 1, 1976, as 'heavy hauler' trailers or if equipped with an axle with a gross weight rating (GAWR) of 24,000 pounds or more.; The trailers you describe do not appear to qualify as a heavy haule trailer because they do not appear to have brake lines which adapt to separation or extension of the vehicle frame, or a bed height of 40 inches or less in the unloaded condition.; Standard No. 121 applies to most air-brake vehicles. Section S3 of th standard does exclude any vehicle manufactured before September 1, 1976, that has a gross axle weight rating for any axle of 24,000 pounds or more.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam4653OpenMr. Mark F. Holmes 2605-C Norris Ct. Philadelphia, PA 19121; Mr. Mark F. Holmes 2605-C Norris Ct. Philadelphia PA 19121; "Dear Mr. Holmes: This is in reply to your letter of September 28 1989, with respect to two lighting devices known as the Strobalarm and the Spotlight Alarm. You are interested in selling these devices in the aftermarket, and have asked whether they would be in violation of any of the standards and regulations of this agency. These devices are 'designed to be used only when a vehicle is parked or broken down.' As we understand your letter and the materials you enclosed, both devices can be incorporated into existing alarm systems, to indicate when an attempted theft is in progress. The 'locator' feature of the devices allows activation from a distance of 400 feet, enabling an approaching owner to easily identify his vehicle. With the use of a pink colored lens, the Strobalarm is intended to serve as an 'emergency distress flare.' You have enclosed two color renderings of these devices, titled 'Interior/Strobe Alarm Light,' and 'Alarm Strobe Light Collision Avoidance Light.' The Federal law and regulation that must be considered to answer your question are the National Traffic and Motor Vehicle Safety Act (Title 15, United States Code, Sections 138l and following), and Federal Motor Vehicle Safety Standard No. l08 Lamps, Reflective Devices and Associated Equipment (Title 49, Code of Federal Regulations, Section 571.108), and Standard No. lll Rearview Mirrors (49 CFR 571.111). Under Section 1397(a)(2)(A) of the Act, a manufacturer, distributor, dealer, or motor vehicle repair business may not render inoperative, in whole or in part, any item of equipment installed in accordance with a Federal motor vehicle safety standard. You will note that this prohibition does not extend to the vehicle owner. Thus, the question to be addressed is whether the installation of either device by a manufacturer, distributor, dealer, or motor vehicle repair business would affect the performance of required safety equipment. The 'Interior Strobe/Alarm Light' appears intended as a 'dome' light, mounted centrally on the headliner above the passenger seats. In this position it has the potential to affect the field of view of the inside rear view mirror required by Standard No. lll, as prescribed by paragraph S5.1.1 (copy enclosed). If the field of view is not met, an outside rearview mirror must be provided on the passenger side. You have not provided the dimensions of this device, and we are unable to advise you further. Other than this cautionary note, the 'Interior Strobe/Alarm Light' does not appear affected by the laws and regulations of this agency. It would, however, be subject to state and local laws where it is sold and used. We are unable to advise you on these, and suggest you contact the American Association of Motor Vehicle Administrators (AAMVA) for an opinion. Its address is 4600 Wilson Boulevard, Arlington, VA 22203. The 'Alarm Strobe Light Collision Avoidance Light' raises another consideration. The collision avoidance portion of the lamp appears intended to serve as a center highmounted stop lamp. Under paragraph S5.4 of Standard No. l08, the center lamp may not be combined with any other lamp or reflective device. Thus, removal of an original equipment center lamp and substitution of your device by a person other than the vehicle owner would be regarded as partially rendering inoperative the original safety equipment, even if your device complied with all other requirements for the center lamp. The center lamp has been required on all passenger cars manufactured on or after September 1, l985. The restriction does not apply, of course, to installation on passenger cars manufactured before September 1, l985, or other types of motor vehicles regardless of date of manufacture. Consideration must still be given, however, to continued compliance with Standard No. lll, and to whether any state specifications exist covering aftermarket center stop lamps. Again, the AAMVA may be able to help you. I hope that this information is useful to you. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure /"; |
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ID: aiam3196OpenMr. Ted J. Szkolnicki, Supervisor, Mechanical Engineering, Motor Coach Industries, Pembina, ND 58271; Mr. Ted J. Szkolnicki Supervisor Mechanical Engineering Motor Coach Industries Pembina ND 58271; Dear Mr. Szkolnicki: This responds to your December 11, 1979, letter asking whether yo would be permiited to install a valve in your braking system that would prevent air from reaching the front axle brakes when your vehicle is in reverse. You want to make such a modification to prevent brake chatter when your vehicle is in reverse and question whether such a modification would comply with the requirements of Standard No. 121, *Air Brake Systems*.; Sections S5.3.3 and S5.3.4 of the standard establish brake actuatio and release times. In an interpretation of those sections (July 23, 1976), the agency stated that the air pressures of 60 psi and 95 psi were only benchmarks, and that the agency would use either of those values or 70 percent of the maximum pressure in the brake chamber, whichever is lower. You state that this interpretation allows you to install a valve, because the maximum air pressure reaching the front brake chamber when the vehicle is in the reverse gear would be 0 and 70 percent of 0 is 0. Therefore, you suggest that your vehicle would pass the tests in these two sections if tested at 0 psi.; The intent of the July 23 interpretation of the sections was to provid flexibility of designs that incorporate lower air pressures than originally contemplated by the air brake standard. The interpretation was not intended as a device to escape from compliance with the air brake standard by creating a situation where front brakes would be rendered inoperative. Accordingly, the agency limits its July 23, 1976, interpretation to those instances where air brakes are receiving air pressure and are performing as designed to stop the vehicle. Using this limitation on our July 23 interpretation, the NHTSSA concludes that your new brake design would violate the standard and, therefore, will not permit the use of the valve that you recommend.; The brake chatter that you refer to in your letter appears to be problem that occurs only in your vehicles. We have not been made aware of similar problems affecting other manufacturers' vehicles. Accordingly, we must assume that something in your design is creating the chatter problem. We suggest that you alter your brake design in a way that elinates the chatter problem while maintaining the vehicle's compliance with the air brake standard.; Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam1451OpenMr. George O. Stevens, Driver & Vehicle Administration, Michigan Department of State, 8351 Billwood Highway, Lansing, MI 48918; Mr. George O. Stevens Driver & Vehicle Administration Michigan Department of State 8351 Billwood Highway Lansing MI 48918; Dear Mr. Stevens: Some time ago you asked our regional office in Chicago for advic concerning the sufficiency of the odometer disclosure form developed by Michigan for use on its certificates of title and other vehicle transfer documents. This will serve to confirm the informal opinion you received from Dick Cook of the regional staff.; As pointed out in the letter sent you by General Motors, the Michiga form lacks certain informational items that are specified in the Federal odometer disclosure regulation. To comply fully with the regulation, the Michigan form would have to include space for the vehicle model and the last plate number. However, we do not regard the absence of these items to be serious enough to mandate an change in the Michigan form, in that the other information provided on the form appears sufficient to accurately identify the vehicle. A transferor who completes the present form and thereby fails to give the additional information would not be misleading the transferee and would therefore not be subject to civil action under the Act. It is our view that a transferor who completes the disclosure statement on the Michigan form would not need to submit an additional disclosure form.; Sincerely, Lawrence R. Schneider, Chief Counsel |
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ID: aiam4203OpenMr. H. Tsujishita, Chief Co-ordinator of Technical Administration Dept., Daihatsu Motor Co., Ltd., 1. Daihatsu-Cho, Ikeda City, Osaka Prefecture, Japan; Mr. H. Tsujishita Chief Co-ordinator of Technical Administration Dept. Daihatsu Motor Co. Ltd. 1. Daihatsu-Cho Ikeda City Osaka Prefecture Japan; Dear Mr. Tsujishita: This responds to your letter requesting an interpretation of several o our standards. First, I would like to apologize for the delay in this response to your letter. I have set forth the responses in the order you asked the questions in your letter.; 1. Standard No. 105, *Hydraulic Brake Systems*. Paragraph S5.2.1 of this standard provides that the parking brak system on a passenger car and some school buses shall be capable of holding the vehicle stationary *(to the limit of traction on the braked wheels) for 5 minutes in both a forward and reverse direction on a 30 percent grade. You stated that your understanding of this provision was as follows. During the tests to determine compliance with this provision, the axles of the subject vehicle must be locked by the parking brake. Your understanding is that the vehicle is permitted to slide down the 30 percent grade, and would be considered as complying with this provision of Standard No. 105 no matter how it slides as long as the vehicle's axles do not turn. This understanding is correct.; The parenthetical note in section S5.2.1 was included in the standar to address the situation where a particular 30 percent grade might have a low traction coefficient. In this situation, a vehicle might slide down the grade even though its parking brake system had held the vehicle axles locked for the required amount of time. NHTSA did not intend vehicle sliding because of a loss of traction by the tires to be considered a failure of the parking brake system. To make this item clear, section S5.2.1 specifies that the parking brake system must hold the vehicle stationary only 'to the limit of traction on the braked wheels.' This language allows the standard not to specify the traction coefficient for the 30 percent grade. Since no particular traction coefficient is specified, compliance testing may be conducted on *any* 30 percent grade that satisfies the requirement of S6.9. That section requires that the parking brake test surface be clean, dry, smooth Portland cement concrete.; 2. Standard No. 110, *Tire Selection and Rims.* Paragraph S4.3 of this standard specifies that a placard containin certain safety performance indication shall be permanently affixed to 'the glove compartment door or an equally accessible location.' You asked if the door latch post, the inner surface of the glove compartment box, and the inward-facing surface of the driver's side door would be considered 'equally accessible locations.' Each of these locations could be equally accessible locations.; In several past interpretations, we have explained that locations fo the placard would be considered equally accessible if two conditions were met. These were:; >>>1. The alternative location must result in the placard bein positioned so that the vehicle operator can readily refer to it, and; 2. The alternative location must keep the placard relatively free fro exposure to substances that could destroy the placard or render it illegible.<<<; If you position the placard on any of your three alternative location so that the vehicle operator can readily refer to it and where the placard would be protected from substances that could destroy it, we would consider each of those alternative locations as 'equally accessible locations' for the purposes of Standard No. 110.; 3. Standard No. 302, *Flammability of Interior Materials*. Paragraph S4.1 of Standard No. 302 sets forth a listing of th components of vehicle occupant compartments that must be certified as complying with the flammability resistance requirements of paragraph S4.3. You listed nine components not specifically listed in paragraph S4.1 and asked whether those components were required to be certified as meeting the flammability resistance requirements. The answer to your question depend on whether the components are designed to absorb energy on contact by occupants in the event of a crash.; paragraph S4.1. represents a complete listing of all components in ne vehicles that must comply with the flammability resistance requirements. Any component not identified in paragraph S4.1 is not subject to the flammability resistance requirements. The only item on that listing that might be applicable to the nine components about which you asked is 'any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.' Thus, you must determine which of the nine components you asked about are so designed. We would assume that knee bolsters are designed to absorb energy on contact by occupants in the event of a crash. These and any other of the nine components so designed must be certified as complying with the flammability requirements of Standard No. 302. Any of the nine components not designed to absorb energy are to required to comply with the flammability requirements.; 4. Part 575.101, *Consumer Information Regulations, Vehicle Stoppin Distance.*; You noted that S575.101 requires vehicle manufacturers to disseminat information about the minimum stopping distance for groups of passenger cars. Section 575.101(c) requires that each passenger car in the group to which the stopping distance information applies shall be capable of performing at least as well as the information indicates, *under the test conditions and procedures specified in S6 an S7 of Standard No. 105* (emphases added). You noted that those sections of Standard No. 105 specify both pre-burnish and post-burnish tests, and that the braking performance varies considerable for the two tests. You asked whether the consumer information on stopping distance must reflect the pre-burnish stopping distance. It need not reflect pre-burnish stopping distance.; As you noted, S575.101(c) specifies that the stopping distanc information should be measured under the test conditions and procedures specified in sections S6 and S7 of Standard No. 105. This specification was added in an amendment published on January 6, 1976 (41 FR 1066). Before that amendment, S575.101 had specified separate test conditions and procedures for the stopping distance information. Those conditions specified that the vehicle's brakes were to be burnished and then the stopping distance was to be measured. In place of those conditions, S575.101(c) now specifies that the stopping distance information should express the *minimum* stopping distances that can be met or exceeded by each vehicle in the group to which the information applies, using the test conditions and procedures of Standard No. 105. Since stopping distances decrease after burnish, the post- burnish results represent the *minimum* stopping distances that can be met or exceeded by the vehicles. Therefore, the pre-burnish stopping distances need not be reflected in the stopping distance information manufacturers make available to consumers.; Sincerely, Erika Z. Jones, Chief Counsel |
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ID: aiam1001OpenMr. Gorou Utsunomiya,Branch Manager,Toyo Kogyo Co., Ltd., USA Rep. Ofc.,23777 Greenfield Road, Suite 462,Southfield, Michigan 48075; Mr. Gorou Utsunomiya Branch Manager Toyo Kogyo Co. Ltd. USA Rep. Ofc. 23777 Greenfield Road Suite 462 Southfield Michigan 48075; Dear Mr. Utsunomiya:#This is in reply to your letter of February 8 1973 concerning the operating point of a hand-operating parking system (Standard No. 105a)#We intend to specify an operating point in the response to petitions for reconsideration of Standard No 105a. This Notice should be published not later than May 1, 1973.#Yours truly,Richard B. Dyson,Assistant Chief Counsel; |
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ID: aiam4829OpenMr. Samuel Yk Lau Kenwo Industries Ltd. Unit 20, 10/F, Block A, Hi-Tech Ind. Center, 5 Pak Tin Par Street, Tsuen Wan Hong Kong; Mr. Samuel Yk Lau Kenwo Industries Ltd. Unit 20 10/F Block A Hi-Tech Ind. Center 5 Pak Tin Par Street Tsuen Wan Hong Kong; Dear Mr. Lau: This is in reply to your letter of January 24, 1991 asking the agency for an opinion with respect to an 'additional brake lamp' that you manufacture and intend to export to the United States. You ask 'if there are any regulations, standards, or approval for this kind of product', and, further, 'does this product need to have any certificate or approval before it can be sold or installed?' Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, has required the additional stop lamp on all passenger cars manufactured on and after September 1, l985. The Standard specifies performance and minimum lens area requirements for the lamp, and these requirements must be met by any lamp that is used as original equipment on passenger cars, and by any lamp that is intended to replace a lamp orignally installed on a car manufactured on and after September 1, l985. If the lamp is intended as replacement equipment, its manufacturer must provide certification to the distributor or dealer of the lamp that the lamp meets Standard No. 108. For lighting equipment this certification may be in the form of a DOT symbol on the product, or a written statement on the packaging that the lamp meets all applicable Federal motor vehicle safety standards, or such other written certification as the lamp manufacturer may choose (e.g., an invoice). In addition, the lamp manufacturer must file an Identification Statement with the agency, and a foreign manufacturer must designate an agent in the United States upon which the agency may serve legal process should that be required. However, there is no requirement that a manufacturer obtain approval from the agency before exporting its certified product to the United States and selling it here. However, Standard No. 108 does not apply to an additional stop lamp that is intended for use in a passenger car manufactured before September 1, l985, and there is no requirement that it be certified as meeting Standard No. 108. Under this circumstance, we advise that the packaging for any such lamp should clearly state that it is not intended to replace an original equipment center lamp so that legal questions regarding its conformity with Federal requirements do not arise. Even though the lamp is not subject to Standard No. 108, its foreign manufacturer must designate an agent in the United States, as mentioned in the previous paragraph. An additional stop lamp for passenger cars manufactured before September 1, l985, is also subject to the laws of the individual States in which the lamp is sold and used. We are unable to advise you on these laws, and suggest that you write for an opinion to the American Association of MOtor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, USA. We enclose a copy of Standard No. 108 and of the SAE standard on supplementary stop lamps that is incorporated by reference. We are also enclosing copies of the Manufacturer Identification and Designation of Agent regulations, and of other materials that our Office of Vehicle Safety Compliance provides in response to inquiries of this nature. Questions on these materials should be addressed to that Office. Sincerely, Paul Jackson Rice Chief Counsel Enclosures; |
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ID: aiam2504OpenMr. James N. Clymer, Topeka Metropolitan Transit, 201 North Kansas, Topeka, KS 666-3; Mr. James N. Clymer Topeka Metropolitan Transit 201 North Kansas Topeka KS 666-3; Dear Mr. Clymer: This responds to your January 4, 1977, letter posing several question concerning the National Highway Traffic Safety Administration's (NHTSA) definition of school bus and its effect upon the use of transit buses to transport children to and from school.; You asked several questions in your letter: >>>(1) Are buses designed and sold for operation as common carriers i urban transportation prohibited from use in school transportation services under Federal Regulations?<<<; Buses sold for operation as common carriers in urban transportatio (transit buses) are not prohibited from use in school transportation. The definition of 'school bus' is not intended to include transit buses on regular common-carrier routes, although they mey be used in some circumstances to transport school students to and from school and related events. This type of bus has never been considered a school bus under the motor vehicle safety standards for school bus construction or under the Pupil Transportation Standarad No. 17 (43 CFR 1204) for school bus operation.; >>>(2) If the answer to (1) is no, must such buses when use incidentally in school transportation services comply with any safety standards required of 'school buses' under the Federal regulations and if so, from which are they exempt and to which must they comply? (of special concern is forward facing seats requirement of 49 CFR S 571.222 - s5.1).<<<; The answer to your question is no. As noted above, common carriers i urban transportation are excluded from the Federal definition of 'school bus' and need not comply with any Federal school bus construction regulation. While Kansas has chosen to define 'school bus' differently (and in a manner to include these transit buses), this state definition represents a voluntary decision to extend Federal construction requirements (such as forward facing seats) to a broader catagory of vehicles than dictated by Federal law and regulations.; >>>(3) Do federal regulations encourage or discourage the incidenta use of common carrier buses to help solve urban school transportation problems?<<<; Federal safety regulations promulgated under the authority of th National Traffic and Motor Vehicle Safety Act neither encourage nor discourage the incidental use of transit buses to transport children to and from school.; >>>(4) Is the Kansas law with regard to school buses, by its definitio in K.S.A. 8-1461 (Supp., 1976), and its requirements of under K.S.A. 8-2009 (Supp., 1976) (which include all safety requirements of the Kansas Transportation Manual, effective May 1, 1976) preempted, as applied to common carriers sold and designed for use in urban transportation, by federal law under 15 U.S.C. S 1392 (d)?<<<; The NHTSA responded to your question on preemption in our letter date June 15, 1976. That response is still valid. With regard to your question concerning the preemption of the Kansas definition of 'school bus,' only state motor vehicle safety standards in conflict with Federal standards are preempted. State definitions of terms are not preempted by Federal definitions.; Sincerely, Frank A. Berndt, Acting Chief Counsel |
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ID: aiam0539OpenMr. W. G. Massey, Project Engineer, Brockway Motor Trucks, Factory & General Office, 106 Central Avenue, Cortland, NY 13045; Mr. W. G. Massey Project Engineer Brockway Motor Trucks Factory & General Office 106 Central Avenue Cortland NY 13045; Dear Mr. Massey: This is in reply to your letter of September 12, 1972, regarding th application of S4.3 of Standard No. 207, Seating Systems, to an auxiliary folding seat installed in Brockway trucks.; As shown in your drawings and photographs, the seat faces forward an has a hinge at the rear of the lower cushion. An upward force at the front of the lower cushion will move the cushion upward and rearward until it presses against the seat back.; The intent of S4.3 is to reduce the forces acting on an occupant in a accident by preventing the seat or seat back from folding onto him. It does not appear from the material you have submitted that any motion of the lower seat cushion will impose such additional forces on an occupant. The folding action is therefore not of the type contemplated by the standard and no restraining device would be required for this seat.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
Request an Interpretation
You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:
The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590
If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.
Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.