Interpretation ID: aiam0695
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 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.; Your question on Standard 215 is whether the headlamps must b adjustable after the tests 'so as to permit restoration of normal lighting' or whether it is sufficient for the lamps to be adjustable plus or minus 4 degrees vertically and horizontally whether or not this restores normal lighting. Our reply is that the requirement is intended to provide for the safe operation of the lamps after impact and that the lamps must therefore be adjustable in a manner that restores normal lighting.; Sincerely, Richard B. Dyson, Assistant Chief Counsel