Interpretation ID: aiam1309
Executive Vice President
Missouri Automobile Dealers Assoc.
205 East Capitol Avenue
Jefferson City
MO 65101;
Dear Mr. Kalberlon: This is in reply to your letter of October 10, 1973, concerning th legality of disconnecting seat belt interlocks.; The interlock is a required item of safety equipment that must b operable on any new car when it is sold or offered for sale, pursuant to section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act. After an interlock equipped car is sold, however, the purchaser may disconnect the interlock, without violating the Act, by virtue of section 108(b)(1), which exempts transactions after the first purchase of the vehicle.; If a dealer offers to disconnect an interlock as an inducement to th sale of the vehicle, it is our opinion that a violation of the act occurs even though the actual disconnection may take place after delivery of the vehicle. If, on the other hand, the subject of the interlock is not discussed during the sale and the buyer subsequently requests disconnection on the basis of his experience with the vehicle, the dealer would not violate the Act if he disconnected the interlock.; Although a dealer does not violate the act by suggesting that the buye go somewhere else to have the interlock disconnected, I am sure you appreciate the troublesome consequences such advice may bring for the buyer if the resulting disconnection is carelessly performed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel