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Interpretation ID: aiam1021

Mr. J. W. Kennebeck, Manager, Safety and Development, Volkswagen of America, Inc., Englewood Cliffs, NJ 07632; Mr. J. W. Kennebeck
Manager
Safety and Development
Volkswagen of America
Inc.
Englewood Cliffs
NJ 07632;

Dear Mr. Kennebeck: This is in response to your letter of February 26, 1973, in which yo asked a question concerning the relationship of the seat belt interlock and warning system required by Standard No. 208.; You asked whether the informative warning system, required by S7.3.5. to operate when the driver turned the ignition to 'start' position and 'the operation of the seatbelt systems required by S7.4.1 to start the engine has not been performed', is required to operate when the driver turns the ignition to start under the 'free start' provisions of S7.4.3.; The answer is no. The 'start' warning of S7.3.5.4 is only required t operate when a seatbelt operation 'required to start the engine' has not been performed. When the engine is free to start under S7.4.3, the warning is not required. Of course, if the driver puts the vehicle in gear, the warning must sound under the provisions of S7.3.1 if the required seatbelt operations have not been performed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel