Interpretation ID: nht73-3.8

DATE: 01/04/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Toyo Kogyo USA

TITLE: FMVSS INTERPRETATION

TEXT: 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 of 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.