Interpretation ID: nht74-4.46

DATE: 01/18/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Lewis S. Hollins, Esq., Attorney at Law

TITLE: FMVSS INTERPRETATION

TEXT: Dr. Gregory has asked me to respond to your client's request for approval of the "Hollins system" interlock device. In an earlier version, the system was the basis of a petition for an alternative to Standard 208's seatbelt interlock system. That petition was denied by the NHTSA (38 FR 9830, April 20, 1973, and 38 FR 16072, June 20, 1973) as was a petition for reconsideration of our decision (38 FR 33110, November 30, 1973).

Standard 208 establishes performance requirements, but the NHTSA does not approve or disapprove specific equipment designs. Any design can be used to satisfy Standard 208 which fulfills the performance requirements. We have considered Mr. Hollins' proposal and, as set our in the Federal Register, have determined that his requested changes to the performance requirements are not justified. We feel that our consideration of Mr. Hollins' petition has been full and complete, and that further petitions on this subject will be repetitious within the meaning of 49 CFR @ 553.35(c).

SINCERELY,

December 26, 1973

Dr. James B. Gregory, Administrator National Highway Traffic Safety Administration

Re: Docket No. 69-7 OCCUPANT CRASH PROTECTION Notice 30

Based upon the substance of the text of Notice 30, my client Jesse R. Hollins, entirely without prejudice and as evidence of his desire to be cooperative, has indicated his willingness to alter his system so that:

(a) The Hollins warning system will not function when the engine is operating and the transmission is in "Park" for vehicles equipped with automatic transmissions, or in "Neutral" for vehicles equipped with manual transmissions (S7.3).

(b) The Hollins system will be augmented so as to provide for the interlock feature for the outboard (right) front passenger's seat (S7.4).

I am accordingly so authorized to submit the above to you as an amendment and request prompt acknowledgment and approval of the Hollins system.

This request is submitted within the prescribed 30 days from the date of publication of Docket No. 69-7; Notice 30 in the Federal Register (Vol. 38 No. 230) Friday, November 30, 1973.

Ten copies are enclosed herewith.

Sincerely

LEWIS S. HOLLINS