Interpretation ID: aiam0698
U.S. Resident Engineer
CITROEN
801 Second Avenue
New York NY 10017;
Dear Mr. Belier: This is in reply to your letter of April 24, 1972, in which you pose questions about the operation of the seat belt warning system under Standard 208 and about the intent of the headlamp adjustment requirement under Standard 215.; Your questions on Standard 208 deal with the requirement in S7.3.3 tha the warning system in a vehicle with an automatic transmission must not operate when the engine is operating and the gear selector is in the 'Park' position. In answer to your first question, if the two conditions for non-operation exist, the warning system must not operate, regardless of the position of the hand brake lever. If either condition does not exist, e.g., the transmission is in 'Park' but the engine is not operating, it would be permissible to have the system operate, and its operation could be controlled by the hand brake so long as the hand brake circuitry does not interfere with the mandatory operation of the system under S7.3.1 and S7.3.5.; If the shift lever is in the neutral position, as stated in your secon question, you are free to choose whether to have the system operate or not, since S7.3 does not require either operation or non-operation when the transmission is in neutral.; In response to your last question on Standard 208, an 'operatin engine' is an engine that is rotating. It is permissible to have a system in which the warning operates when the transmission is in 'Park' and the ignition is 'On', but the warning must shut off when the engine begins to operate.; The other operating mode of your system has no direct counterpart i Standard 208. As you describe it, returning the ignition to the 'off' position will activate the warning system, even after removal of the key, until the belts are returned to their stowed positions. Our letter of August 17, 1972, explained that this will not conform to the requirement of S7.3.2 that the warning must not operate when the belts at occupied front positions have been operated.; We recognize that there are other possible alternatives to the require interlock system as a means of encouraging seat belt usage, and several have been suggested. We consider it important, however, that these systems work in a substantially uniform manner, for maximum public safety, acceptance and convenience. On the basis of all the material we have received to date, including yours, we have decided that our present requirements represent the best combination for the alternative to passive restraints in the period 1973-1975. I therefore must deny your petition to substitute your system, or allow it as an alternative, for the interlock system.; Sincerely, Douglas W. Toms, Administrator