Interpretation ID: aiam3906
870 W. Versailles Ct.
Baton Rouge
LA 70819;
Dear Ms. Goodrich: This responds to your letter asking about regulations for automobil ignition systems and steering wheel locking systems. You asked for information concerning requirements for vehicles with automatic transmissions for the removal of the ignition key while the vehicle is in drive or any gear other than park. You specifically asked whether a driver should be able to remove the key from the ignition while the car is in drive even if the engine is no longer running.; Requirements relating to steering wheel locking systems are set fort in Federal Motor Vehicle Safety Standard No. 114, *Theft Protection*. Section S4.2 of the standard requires (among other things) that vehicles have a key-locking system that, whenever the key is removed, will prevent either steering or forward self- mobility of the vehicle, or both. Section S4.3 of the standard requires engine shall not activate the deterrent that prevents steering or forward self-mobility of the vehicle. Thus, the driver of an automobile may turn off the engine while the car is in motion without activating the steering column lock or impeding forward self-mobility.; Neither Standard No. 114 nor any other standard specifically require that vehicles be designed so that drivers are unable to remove the key from the ignition while the vehicle is in drive. I would note that the agency has conducted rulemaking addressing the issue of inadvertent activation of the steering column lock in moving vehicles. While the National Highway Traffic Safety Administration issued a notice of proposed rulemaking on this subject in May 1978 and a final rule in December 1980, the agency deleted the relevant requirements in a final rule and response to petitions for reconsideration, published in June 1981. In that latter notice, the agency stated that it had determined that the problem of inadvertent activation is not significant enough to require vehicles to be equipped with key-locking systems that provide more protection against inadvertent activation.; Standard No. 102, *Transmission Braking Effect*, also includes requirement relevant to your question. Section S3.1.3 requires that the engine starter for automatic transmission vehicles be inoperative when the transmission shift level is in a forward or reverse drive position.; Copies of Standards Nos. 102 and 114 and the three Federal Registe notices discussed above are enclosed for your convenience.; Sincerely, Jeffrey R. Miller, Chief Counsel