Interpretation ID: nht74-5.40
DATE: 04/03/74
FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA
TO: House of Representatives
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your March 19, 1974, request for information in behalf of Mr. Robert J. Jones, concerning the commercial offer he received for a device that would defeat the ignition interlock device found on 1974 model passenger cars.
The National Traffic and Motor Vehicle Safety Act of 1966 authorizes the issuance of motor vehicle safety standards, one of which requires occupant crash protection, one aspect of which is the ignition interlock system. Section 108(a)(1) of the Act prohibits the sale, offer for sale, introduction into interstate commerce, or the importation of any motor vehicle which does not conform to the standards. Our regulatory authority over new vehicles ends, however, with the first purchase of the vehicle in good faith for purposes other than resale. While we can prohibit arrangements between a dealer and a purchaser to disconnect the interlock, where they are part of the sales transaction, we have no remedy against arrangements to defeat the safety features made after the sales transaction.
Nevertheless, while selling devices intended to defeat safety equipment may be legal, we consider such practices reprehensible since they increase the chances of death and injury on the highways. We are considering a variety of remedies for the situation reported by Mr. Jones.
ENCLS.
Congress of the United States
House of Representatives
Washington, D.
March 19 1974
Congressional Liasion National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington, D.C. 20590
Sir:
The attached communication is sent for your consideration. Please investigate the statements contained therein and forward me the necessary information for reply, returning the enclosed correspondence with your answer.
Yours truly,
Frank Thompson, Jr.
M.C.
Re: Mr. Robert J. Jones
FEBRUARY 27, 1974
Honorable Francis Thompson House of Representatives Washington, D.C.
Dear Mr. Thompson:
The enclosed letter arrived in the mail today.
Could you have someone on your staff direct this letter from Merit Enterprise to the proper "Consumer Advocate Bureau" or governmental watch dog agency as a register of my protest against obvious effort to thwart the new safety laws?
I protest this crazy bridgefree enterprise that allows groups like Merit Enterprise to make a buck by devising ways to short cut and render unworkable good laws.
Sincerely yours,
Robert J. Jones Lawrenceville, N.J.
Dear New Car Owner:
We trust that you are pleased with your 1974 automobile. We are not so sure that you are pleased with the seal belt-starter interlock system which is standard equipment under a Congressional mandate.
There are times when this system is not only inconvenient, uncomfortable, and impractical, but also unsafe. For instance, when a child is buckled in the passenger's seat, there is a chance that his face or neck can be severely injured in a collision by the shoulder harness.
We are sure that you have already found that an article in either the passenger or center seat makes it necessary to buckle the article up to start the vehicle. This is most inconvenient for those of us who transport a briefcase, a bowling ball, or even a bag of groceries.
Recognizing these shortcomings in the seat belt interlock system, Merit Enterprises manufacturers and markets BELT-MATE, a product which allows you, the vehicle owner to temporarily override the system when it isn't prudent for personal safety.
If you feel the decision, "To Buckle or Not to Buckle", should be made by you instead of Congress, send $ 4.98 in cash, check or money order for your BELT-MATE to Merit Enterprises, Box 4068, Hampstead, N. C. 28443. Your Belt-Mate comes complete with instructions - no wiring needed, and your satisfaction is guaranteed.
Allow 2 to 3 weeks for delivery. North Carolina residents add 4% sales tax.
Awaiting your reply.
Very truly yours,
John R. Merit