Interpretation ID: nht73-1.2

DATE: 01/10/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Van Doorne's Automobielfabrieken N.V.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 12, 1972, about compliance of DAF cars with Federal Motor Vehicle Safety Standard No. 102.

Your question concerns the interpretation of paragraph S3.1.2. From your description in the letter and the description in the owner's manual, only one forward drive position is provided and engine braking can be achieved by actuating the transmission low ratio control switch. Under the conditions described above, the Variomatic transmission in DAF cars is not in violation with paragraph S3.1.2 of Standard No. 102. However, it appears that you do not comply with certain other paragraphs of the standard. For example, paragraph S3.1.1 requires that "A neutral position shall be located between forward drive and reverse positions. . . ." and paragraph S3.1.3 requires that "The engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive position."

The DAF 66 owners manual dated September 1972, also indicates non-compliance with other standards; for example, 101, Control Location, Identification and Illumination, 114, Theft Protection, 115, Vehicle Identification Number, etc. It is recommended that all standards and regulations be checked for compliance.

A copy of "Where to Obtain Motor Vehicle Safety Standards and Regulations" is enclosed for your review and information.