Interpretation ID: aiam1744
Manager
Emissions
Safety & Development Dept.
Volkswagen of America
Inc.
Englewood Cliffs
NJ 07632;
Dear Mr. Kennebeck: This responds to Volkswagen's December 11, 1974, request fo confirmation that the deletion of the ignition interlock requirement from Standard No. 208, *Occupant crash protection*, does not have the effect of prohibiting installation of an interlock device in a vehicle which meets the requirements of S4.1.2.; Volkswagen will utilize a passive belt system in satisfaction of th requirements of S4.1.2. Passive belts are subject to specific belt assembly requirements of S4.5.3.3. These requirements were recently modified by deletion of the requirement for a belt interlock system (39 FR 38380, October 31, 1974), and passive belt assemblies must now conform to S7.1 (Adjustment), S7.2 (Latch mechanism), and S7.3 (Seat belt warning system).; Your interpretation of these requirements is correct. The Federal moto vehicle safety standards are minimum performance requirements with which each vehicle to which they are applicable must comply. They do not, however, prohibit installation of additional safety devices. As a practical matter, of course, additional devices could not be installed if that installation had the effect of causing the required systems not to comply.; The NHTSA agrees than (sic) an interlock system is important fo ensuring use of a passive belt system.; Yours truly, Richard B. Dyson, Acting Chief Counsel