Interpretation ID: aiam3628
Account Representative
Fowler-Finch
Inc.
P.O. 63
New Lebanon Center
NY 12126;
Dear Ms. Stewart: This responds to your recent letter asking whether the automatic bel systems in 1979 and 1980-model Volkswagens qualify as a 'passive restraint system' under Federal Motor Vehicle Safety Standard No. 208, *Occupant Crash Protection*. You need this information to determine if one of your insureds can obtain the discount your company offers for automobiles equipped with passive restraints.; The answer to your question is yes. The Volkswagen automatic bel system qualifies as a passive restraint. The agency has stated that a 'passive restraint' is a system that requires no action by vehicle occupants in order to obtain protection. The Volkswagen passive belt automatically surrounds the vehicle occupant without any action on the occupant's part other than closing the vehicle door (i.e., the occupant does not have to touch the belt system). Therefore, the Volkswagen belts you mentioned in your letter are passive restraints, and whether the systems are offered as standard or optional equipment is irrelevant.; I hope this answers all your questions. If you require any furthe information, please contact Hugh Oates of my staff (202-426-2992).; Sincerely, Frank Berndt, Chief Counsel