Interpretation ID: bmw102-1.pja

Mr. Karl-Heinz Ziwica
General Manger, Environmental Engineering
BMW of North America, Inc.
BMW Plaza
Montvale, NJ 07645-1866

Dear Mr. Ziwica:

This responds to your request for an interpretation of Standard No. 102, Transmission shift lever sequence, starter interlock, and transmission braking effect. Specifically, you ask whether a park control that is actuated by a separate control instead of by the movement of the transmission shift lever is part of the transmission shift lever sequence. You also ask whether such a park position must be located at the end, adjacent to reverse.

Paragraph S3.1.1 of Standard No 102, Location of transmission shift lever positions on passenger cars, states, in part " . . . If the transmission shift lever sequence includes a park position, it shall be located at the end, adjacent to the reverse drive position." [emphasis added.]

Paragraph S3.1.1 explicitly limits the requirement to those park positions included within the "shift lever sequence." It is our interpretation that if park is not selected by the movement of the shift lever, then the park control is not part of the shift lever sequence. In this case, the sentence quoted above does not apply, and the park control does not have to be located at the end, adjacent to reverse.

I hope this information is helpful. If you have any questions, please contact Paul Atelsek of my staff at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:102
d.9/25/98