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Interpretation ID: Hyundai_S7v2

    Mr. Robert Babcock
    Hyundai American Technical Center, Inc.
    5075 Venture Drive
    Ann Arbor, MI 48108


    Dear Mr. Babcock:

    This responds to your request for an interpretation regarding the seat belt warning provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant crash protection, that pertain to the audible warning requirement. You asked if a two-second delay is permissible before the audible signal is activated. As explained below, a system as you described would not comply with the audible warning provision of FMVSS No. 208.

    S7.3 of FMVSS No. 208 establishes a warning requirement to alert vehicle drivers that their seat belt is not fastened. S7.3 provides manufacturers with several options for complying with this requirement. Under each option, a continuous or intermittent audible signal must activate when the vehicle ignition is moved to the "on" or "start" position and drivers safety belt is not in use (S7.3(a)(1) and (2)). The audible signal must sound for a period of not less than four seconds and not more than eight seconds.

    In your letter, you asked if a delay was permitted between the time a vehicles ignition is moved to the "on" or "start" position and when the audible signal is activated (assuming the drivers seat belt is not fastened). You stated that self-diagnostic programs may cause a short delay (up to 2 seconds) prior to the vehicle system being capable of functioning fully, and thus may delay the activation of the audible warning for that same period. You asked if this delay, which occurs after the ignition switch is moved to the "on" or "start" position, is permitted under S7.3 of FMVSS No. 208.

    As explained above, S7.3 requires the audible signal to activate when the vehicle ignition is moved to the "on" or "start" position. Therefore, the short delay you described would not be permissible.

    If you have any additional questions, please contact Mr. Chris Calamita of my staff at (202) 366-2992.

    Sincerely,

    Stephen P. Wood
    Assistant Chief Counsel
    for Vehicle Safety Standards and Harmonization

    ref:208
    d.8/12/05