Interpretation ID: nht68-1.20

DATE: 06/10/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your telegram of May 23, 1968, which sought the views of the Acting Director, Motor Vehicle Safety Performance Service, NHSB, on four questions of interpreting Motor Vehicle Safety Standard No. 114. Our response to these questions is as follows:

1. We agree that paragraph S4.1(b) of the standard requires that removal of the key from the locking system must prevent steering or self-mobility of the car only under normal conditions. A steering or mobility lock which can be circumvented abnormally, as by disassembly of the locking mechanism or the application of excessive force, would not thereby violate the standard.

2. Paragraph S4.2, which provides that the "prime means" for deactivating the car's engine shall not activate either the steering or self-mobility lock, permits the use of the key to activate the lock and to deactivate the engine. The quoted words refer to the action necessary to perform either task, not to the mechanism which accomplishes it.

3. We agree that the warning device required by paragraph S4.4 is unnecessary when the locking system is in either the "on" or "start" positions. We are presently preparing an amendment to the standard which will clarify paragraph S4.4 by providing that the warning need not be activated when the key locking system is in either of those positions.

4. Your final question seeks an interpretation of the words "key left in the locking position." Since those words do not appear in paragraph S4.4, or elsewhere in the standard, we see no reason to provide an interpretation of them.

Sincerely,

WESTERN UNION TELEGRAM

MAY 23, 1968

G C NIELD, ACTING DIR MOTOR VEHICLE SAFETY PERFORMANCE SERVICE NATIONAL WHY SAFETY BUREAU FEDERAL WHY ADMIN DONOHOE BLDG 400 SIXTH ST SW WASHDC

OUR REVIEW OF STANDARD 114, THEFT PROTECTION, INDICATES THAT CONFIRMATION OF SEVERAL INTERPRETATIONS LISTED BELOW IS NECESSARY TO APPLY THE STANDARD WITH CERTAINTY. I WOULD APPRECIATE YOUR CONFIRMATION OF THE FOLLOWING INTERPRETATIONS

1. S4.1(B) CONSISTENT WITH THE ADMINISTRATORS COMMENTS AND SECTION

S4.1 (33 F.R. 6472) THAT REMOVAL OF THE KEY IS REQUIRED TO PREVENT ONLY "NORMAL" ACTIVATION OF THE CARE ENGINE, OUR INTERPRETATION OF SECTION S4.1(B) IS THAT A KEY LOCKING SYSTEM WHICH PREVENTS STEERING UNDER NORMAL CONDITIONS AND/OR PREVENTS NORMAL FORWARD SELF-MOBILITY WHEN THE KEY IS REMOVED, CONSITUTES CONFORMANCE WITH THE REQUIREMENTS.

2. S4.2 WE INTERPRET SECTION S4.2 TO ALLOW USE OF THE KEY TO ACTIVATE THE THEFT DETERRENT DEVICE PROVIDED THERE IS AN INTERMEDIATE POSITION OR MEANS TO DEACTIVATE THE ENGINE WITHOUT ACTIVATING THE DETERRENT,

3. S4.4 SINCE THE RUNNING ENGINE FURNISHES A CONTINUOUS WARNING WE INTERPRET SECTION S4.4 TO MEAN THAT THE WARNING DEVICE NEED NOT BE OPERATBLE WHEN THE DRIVERS DOOR IS OPEN AND THE KEY IS IN THE IGNITION-ON POSITION.

4. S4.4 WE INTERPRET "KEY LEFT IN LOCKING POSITION" TO MEAN THAT THE KEY IS INSERTED FULLY IN THE LOCKING SYSTEM TO THE POSITION PERMITTING OPERATION OF THE LOCKING DEVICE.

R O SORNSON FEDERAL SAFETY COORDINATOR CHRYSLER CORP.