Interpretation ID: nht73-3.38

DATE: 03/05/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 26, 1973, in which you asked a question concerning the relationship of the seat belt interlock and warning system required by Standard No. 208.

You asked whether the informative warning system, required by S7.3.5.4 to operate when the driver turned the ignition to "start" position and "the operation of the seatbelt systems required by S7.4.1 to start the engine has not been performed", is required to operate when the driver turn the ignition to start under the "free start" provisions of S7.4.3.

The answer is no. The "start" warning of S7.3.5.4 is only required to operate when a seatbelt operation "required to start the engine" has not been performed. When the engine is free to start under S7.4.3, the warning is not required. Of course, if the driver puts the vehicle in gear, the warning must sound under the provisions of S7.3.1 if the required seatbelt operations have not been performed.