Interpretation ID: aiam3611
Manager
Engineering
Isuzu Motors America
Inc.
21415 Civic Center Drive
Southfield
MI 48076;
Dear Mr. Tokunaga:#This responds to your letter concerning Safet Standard No. 102, *Transmission Shift Lever Sequence, Starter Interlock, and Transmissions Braking Effect*. You asked whether a 5-speed automatic transmission which you are considering producing meets the requirement of section S3.1.1 that a neutral position be located between forward drive and reverse drive positions.#By way of background information, I would point out that the agency does not give advance approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to determine whether its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. Therefore, the following statements only represent the agency's opinion based on the information provided in your letter.#In reference to the diagram enclosed with your letter, the relevant question is whether, in accordance with the above requirement, there is a neutral position between the HD (highway drive) and R (reverse) positions. As explained below, it is our opinion that the answer to that question is yes.#Your letter states that 'the transmission is neutral whenever the shift lever is at any place on the horizontal line (including its left and right extreme ends) at the center of which the mark 'N' is shown.' Further, your letter indicates that 'the shift lever is spring-loaded to return to the center of the horizontal line ('N' position) whenever the lever is left free on that line.'#In shifting between HD and R, the lever must cross the horizontal line. We understand that if the lever is merely held on the horizontal line at the crossing point, i.e., the extreme right, the transmission will be in neutral. Further, we understand that if the lever is left free in that position, it will return to the center of the horizontal line where it will remain in neutral. Based on these two understandings, it is our opinion that the extreme right crossing point constitutes a neutral position between the HD and R positions.#Sincerely, Frank Berndt, Chief Counsel;