Interpretation ID: aiam0955

Mr. Gorou Utsunomiya,Branch Manager,Toyo Kogyo USA Rep. Ofc. Det.,23777 Greenfield Road, Suite 462,Southfield,Michigan 48075; Mr. Gorou Utsunomiya
Branch Manager
Toyo Kogyo USA Rep. Ofc. Det.
23777 Greenfield Road
Suite 462
Southfield
Michigan 48075;

Dear Mr. Utsunomiya:#This is in reply to your letter of November 28 1972, asking for an interpretation of S5.2 of Safety Standard No. 105a.#The transmission you describe has a separate park position, and this position must be engaged before the ignition key can be removed. We confirm that a vehicle equipped in this manner may meet the parking brake system requirements if S5.2.2 rather than those of S5.2.1.#As for your second question, a vehicle with a manual transmission that must be placed in reverse gear before the ignition key can be removed would also meet the requirements of paragraph S5.2.2#Yours truly,Richard B. Dyson,Assistant Chief Counsel;