Interpretation ID: aiam0494
Jr.
8106 Post Oak Road
Rockville
MD 20854;
Dear Dr. Lundholm: Thank you for your letter of November 2, 1971, to Secretary Volpe, i reference to our occupant crash protection program.; I am enclosing a copy of the proposed amendment to Federal Moto Vehicle Safety Standard No. 208, Occupant Crash Protection, which would allow an ignition interlock system as an option to front seat passive systems from August 15, 1973, to August 15, 1975. I am also enclosing an explanatory press release.; In regard to your question number one, we require that the interloc system be sequentially linked to the seat switch, such that a person would have to fasten the belt, after being seated, each time he attempted to start the car.; With regard to your questions numbers two and three, the Nationa Traffic and Motor Vehicle Safety Act of 1966 permits us to establish standards which serve as guides for individual state safety programs. It is possible for the states to undertake such anti-tampering regulations. We will certainly be considering such actions once we determine the magnitude and effect of tampering in vehicles which have been produced to meet the Federal standards.; In regard to your question number four, I am not presently aware of an plans by insurance companies to require seat/shoulder belt usage in order to be reimbursed for collision coverage in case of an accident.; You are certainly correct in that the present shoulder belt design often make it difficult to have a properly adjusted shoulder belt and still be able to have a reasonable degree of freedom of movement during normal vehicle operation. We are attacking this problem on two fronts. Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification and Illumination--Passenger Cars, requires that most critical controls, such as the steering wheel, headlamp switch, etc., be within reach by a person restrained by a lap and shoulder belt system. The present version of this standard does not include the parking brake or its release mechanism. The second action, which we are taking, is to propose a requirement that shoulder belt systems in cars manufactured after August 15, 1973, shall be equipped with inertia reel retractors that allow freedom of movement except in a crash situation.; I appreciate your thoughtful comments and your intense interest in ou motor vehicle safety programs. It is very helpful to our efforts to improve highway safety when concerned citizens, such as yourself, take the time to bring their comments and suggestions to our attention.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs;