Interpretation ID: nht90-3.14

TYPE: Interpretation-NHTSA

DATE: July 12, 1990

FROM: Robert B. Roden -- Roden & Hayes

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Federal Motor Vehicle Safety Standard #114

ATTACHMT: Attached to letter dated 9-19-90 from P.J. Rice to R. Roden (A36; Std. 114; VSA 108(a)(2)(A)); Also attached to 55 FR 21868, May 30, 1990 (text omitted)

TEXT:

I am writing to request your opinion on the following matter pertaining to Federal Motor Vehicle Standard #114, Theft Protection:

1) Does the Standard #114, Section S4.2(b) require that the key locking systems not allow an ignition key to be removed other than in the "park" position. In other words, does the requirement that the system prevent the vehicle from moving forward on it s own require that the key not be removed except in the "park" position.

2) If the key locking system is replaced for an existing system, is the replacement system required to comply with Standard #114 and particularly, Section S4.2(b)?

3) In addition, how long is the key and/or key locking system required to perform under Section S4.2(b) of the Standard?

We appreciate your opinions with respect to these Standards.