Interpretation ID: aiam2094
Manager
Emissions
Safety & Development
Volkswagen of America
Inc.
Englewood Cliffs
NJ 07632;
Dear Mr. Kennebeck: This responds to Volkswagen of America's August 27, 1975, request fo confirmation that a seat belt warning system that activates a 4- to 8-second warning light when the vehicle ignitions turned complies with the requirements of S4.5.3.3 of Standard No. 208, *Occupant Crash Protection*, although the warning system also activates the same warning light continuously when a separate circuit senses that the front seat belts are not fastened.; Volkswagen's understanding of S4.5.3.3 is correct. As we understan your description, the Volkswagen warning system does provide the automatic 4- to 8-second activation of a warning light called for in S4.5.3.3. This provision prohibits the use of an activation longer than the limits set forth in the standard.; The Volkswagen system provides a different and additional activation o the warning light when the seat belts are not fastened, using a separate circuit to monitor a set of conditions separate from those specified in the requirements of S4.5.3.3. The National Highway Traffic Safety Administration does not consider this activation (which can be longer than 8 seconds) to violate the limit on activation of the automatic reminder specified by the standard.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;