Interpretation ID: aiam2713
Vice President
Lucas Industries
5500 New King Street
Troy
MI 48098;
Dear Mr. Burgess: This responds to Lucas Industries' November 1, 1977, request that th upcoming passive restraint requirements of Standard No. 208, *Occupant Crash Protection*, be amended to provide alternative compliance by means of installation of active lap and shoulder belts equipped with an ignition interlock system.; Section 125 of the National Traffic and Motor Vehicle Safety Act (th Act) provides in relevant part that 'No Federal motor vehicle safety standard may . . . provide that a manufacturer is permitted to comply with such standard by means of . . . any safety belt interlock system.' (15 U.S.C. 1410b(b)(1)). It is the agency's opinion that this provision operates as a strict prohibition on amendments of Standard No. 208 that would have the effect of permitting compliance by provision of an ignition interlock system. This opinion is confirmed by Conference Report language on S 125 which states:; >>>No matter what procedure is followed, the conference substitut prohibits the re-establishment of the safety belt interlock system or continuous buzzer as a mandatory or optional motor vehicle safety standard. H.R. Rep. 93-1452, 93rd Cong. 2d Sess at 45 (1974).<<<; In view of this statutory prohibition, Lucas Industries' request fo amendment of the upcoming requirements of Standard No. 208 cannot be considered by the agency.; Sincerely, Joseph J. Levin, Jr., Chief Counsel