Interpretation ID: aiam1373
Esq.
Attorney at Law
One Chester Drive
Great Neck
NY 11021;
Dear Mr. Hollins: Dr. Gregory has asked me to respond to your client's request fo approval of the 'Hollins system' interlock device. In an earlier version, the system was the basis of a petition for an alternative to Standard 208's seatbelt interlock system. That petition was denied by the NHTSA (38 FR 9830, April 20, 1973, and 38 FR 16072, June 20, 1973) as was a petition for reconsideration of our decision (38 FR 33110, November 30, 1973).; Standard 208 establishes performance requirements, but the NHTSA doe not approve or disapprove specific equipment designs. Any design can be used to satisfy Standard 208 which fulfills the performance requirements. We have considered Mr. Hollins' proposal and, as set our (sic) in the *Federal Register*, have determined that his requested changes to the performance requirements are not justified. We feel that our consideration of Mr. Hollins' petition has been full and complete, and that further petitions on this subject will be repetitious within the meaning of 49 CFR S553.35(c).; Sincerely, Lawrence R. Schneider, Chief Counsel