Interpretation ID: aiam1664
Staff
Safety
Nissan Motor Co.
Ltd.
P. O. Box 1606
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Kato: This responds to Nissan's November 5, 1974, question whether the recen amendments of Standard No. 208, *Occupant crash protection*, (as amended by 39 FR 38380, October 31, 1974) require a sequential ignition warning light and buzzer (S7.3.5.4) even during the 'excepted' situations where the formerly-required belt interlock system was not required to operate (former S7.4.3). These situations are after the engine is stopped, and either the ignition is still on or has been turned off for a period of not more than 3 minutes, or the driver has not left his seated position for more than 3 minutes.; It is true that our recent amendment of S7.3 and deletion of S7.4 coul be interpreted to require a sequential warning under the conditions you list. Such an interpretation would necessitate major modifications of the warning system that was required prior to the amendment. Our intent in making these amendments was, as noted in the preamble to the notice, only to require the deletion of the interlock feature.; Therefore we would not consider the use of a sequential warning syste which complied with the standard prior to the amendment to be in noncompliance with the standard as amended October 29, 1974. This means that Datsun automobiles will not be considered to violate Standard No. 208 if the sequential warning required by S7.3.5.4 does not operate under the 'excepted' conditions described above.; Yours truly, Richard B. Dyson, Acting Chief Counsel