Interpretation ID: aiam4200
President
C&A Control Systems
Inc.
7117 Commercial Park Drive
Knoxville
TN 37918;
Dear Mr. Cantrell: This responds to your letter regarding the LA-Z-START, a remote contro device which you manufacture for starting automobiles. You ask whether your device is compatible with Standard No. 114, *Theft Protection*. I regret the delay in responding to your letter.; For your information, this agency does not approve motor vehicles o motor vehicle equipment. Instead, NHTSA relies on the self-certification process in the National Traffic and Motor Vehicle Safety Act of 1966, as amended, which requires each manufacturer to certify that a motor vehicle or item of motor vehicle equipment complies with all applicable safety standards.; The product information enclosed with your letter indicates that thi device permits a person to use a remote control device to send a coded signal to start or stop a vehicle engine up to 500 feet away. Your device will shut off the engine immediately if any of the following events occur: (1) the transmission is removed from the park position, (2) the brake pedal is depressed, (3) the engine overspeeds or overheats, or (4) the hood is raised. In addition, the device will not start the engine if the transmission is in forward or reverse gear. The device automatically shuts off the engine after 12 to 14 minutes running time and allows remote shut-off at any time.; Standard No. 114 requires that passenger cars as well as trucks an multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less have a key locking system. When the key is removed, the system must prevent normal activation of the vehicle's engine and prevent either steering or forward self-mobility or both. You state that starting a vehicle with your device does not permit normal activation of the vehicle's engine and either forward motion or steering until the key is inserted into the ignition and turned to the on position. Therefore, the question is whether your device, which permits activation of the engine when the ignition key is removed, permits 'normal activation' of the vehicle.; In previous interpretations, the agency has determined that automotiv remote starting devices with characteristics similar to yours were outside the concept of 'normal activation.' These characteristics have included automatic deactivation of the remotely started engine when a vehicle door is opened, maintenance of the steering column or gear shift locking feature until the ignition key is inserted in the vehicle, and automatic deactivation of the remotely started engine after 15 minutes unless the key is inserted into the ignition.; Your device apparently has some of these same characteristics, as wel as other automatic deactivation features which are comparable in nature. Therefore, we conclude that your device does not conflict with the requirements of Standard No. 114, since it does not permit normal activation of the engine without the ignition key.; Although not related to compliance with Standard No. 114, the agency i concerned about the possibility that a child could accidentally press the transmitter button on your device and, thus, start a car by remote control. This situation could clearly raise safety problems. Therefore, we suggest that you add language to the purchasers' instructions making them aware of this possibility and urging them to take precautions to avoid use of the product by anyone who is not authorized to drive the car.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel