Interpretation ID: nht72-6.26
DATE: 05/12/72
FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA
TO: CITROEN
TITLE: FMVSS INTERPRETATION
TEXT: This is in reply to your letter of April 24, 1972, in which you posed questions about the operation of the seat belt warning system under Standard 208 and about the intent of the headlamp adjustment requirement under Standard 215.
Your questions on Standard 208 deal with the requirement in S7.3.3 that the warning system in a vehicle with an automatic transmission must not operate when the engine is operating and the gear selector is in the "Park" position. In answer to your first question, if the two conditions for non-operation exist, the warning system must not operate, regardless of the position of the hand brake lever. If either condition does not exist, e.g., the transmission is in "Park" but the engine is not operating, it would be permissible to have the system operate, and its operation could be controlled by the hand brake so long as the hand brake circuitry does not interfere with the mandatory operation of the system under S7.3.1 and S7.3.5.
If the shift lever is in the neutral position, as stated in your second question, you are free to choose whether to have the system operate or not, since S7.3 does not require either operation or non-operation when the transmission is in neutral.
In response to your last question on Standard 208, an "operating engine" is an engine that is rotating. It is permissible to have a system in which the warning operates when the transmission is in "Park" and the ignition is "On", but the warning must shut off when the engine begins to operate.
Your question on Standard 215 is whether the headlamps must be adjustable after the tests "so as to permit restoration of normal lighting" or whether it is sufficient for the lamps to be adjustable +4 degrees vertically and horizontally whether or not this restores normal lighting. Our reply is that the requirement is intended to provide for the safe operation of the lamps after impact and that the lamps must therefore be adjustable in a manner that restores normal lighting.