Interpretation ID: nht75-4.35

DATE: 10/29/75

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Volkswagen of America's August 27, 1975, request for confirmation that a seat belt warning system that activates a 4- to 8-second warning light when the vehicle ignition is turned complies with the requirements of S4.5.3.3 of Standard No. 208, Occupant Crash Protection, although the warning system also activates the same warning light continuously when a separate circuit senses that the front seat belts are not fastened.

Volkswagen's understanding of S4.5.3.3 is correct. As we understand your description, the Volkswagen warning system does provide the automatic 4- to 8-second activation of a warning light called for in S4.5.3.3. This provision prohibits the use of an activation longer than the limits set forth in the standard.

The Volkswagen system provides a different and additional activation of the warning light when the seat belts are not fastened, using a separate circuit to monitor a set of conditions separate from those specified in the requirements of S4.5.3.3. The National Highway Traffic Safety Administration does not consider this activation (which can be longer than 8 seconds) to violate the limit on activation of the automatic reminder specified by the standard.