NHTSA & Motor Vehicle Safety

We provide the comprehensive services you need to comply with U.S. motor vehicle safety laws. We advise manufacturers of passenger cars, trucks, buses, RVs, motorcycles, school buses, tires, and all types of original and aftermarket equipment (e.g., engines, lighting, brakes, steering components, air bags, and vehicle electronics). We also serve as counsel to several industry trade associations.

We can assist you on the full range of NHTSA-related matters, including:

• Compliance with Federal Motor Vehicle Safety Standards (FMVSSs)
• Defect determinations, defect/recall notification, and defect/noncompliance investigations
• TREAD Act compliance and reporting, including early warning reporting (EWR) and foreign recall reporting
• Development of internal corporate policies and procedures for identifying and reporting safety defects and other reportable events
• Advocacy (e.g., comments and petitions) in rulemaking proceedings
• Petitions for determinations of inconsequential noncompliance and for temporary exemptions from safety standards
• Advising on NHTSA registration, labeling, and VIN requirements
• Freedom of Information Act (FOIA) and confidentiality matters
• Preparing testimony for congressional committee and regulatory body appearances
• Lobbying congressional committees on motor vehicle safety matters
• Legislative and regulatory monitoring
• Corporate Average Fuel Economy (CAFE) issues
• Regulatory issues arising in product liability litigation

We also handle matters related to the Federal Motor Carrier Safety Administration (FMCSA) and the Pipeline and Hazardous Materials Safety Administration (PhMSA).

Our clients have relied on us in dozens of defect and compliance investigations, countless recalls involving all types of vehicles and equipment, and numerous other NHTSA administrative proceedings. We were involved first-hand in many of the agency’s most important rulemakings, advocating on behalf of manufacturers and trade associations in proceedings involving adoption of new FMVSSs, amendments to existing FMVSSs, TREAD Act rules, the early warning reporting (EWR) rule, and the agency’s defect and noncompliance reporting regulations.

We are actively engaged in industry organizations, such as the Motor & Equipment Manufacturers Association, the Original Equipment Suppliers Association, the Recreation Vehicle Industry Association, the Transportation Safety Equipment Institute, and other automotive-related associations, and have served as counsel to several of these organizations.

We also are active speakers before manufacturers and industry groups. Recent presentations include “NHTSA 101: Introduction to the National Highway Traffic Safety Administration and Its Regulations,” “Legal Strategies for Importers of Motor Vehicles and Motor Vehicle Equipment,” and many other presentations covering NHTSA-related topics.